Complaint Against Alabama Lawyer Jefferson B.


To the Alabama State Bar Disciplinary Commission:
This complaint, signed by Lawyers for Good Government and supported by lawyers admitted to
practice in all 50 states and the District of Columbia, seeks disbarment of and/or other
appropriate sanctions against Jefferson B. Sessions, a member of the Alabama Bar1, based on his
actions that violate the Alabama Rules of Professional Conduct (hereinafter Alabama Rules) and
constitute professional misconduct.

This complaint is predicated on Mr. Sessions’ manifestly dishonest and deceitful behavior,
including certain statements, misstatements, and material omissions described below, occurring
between February 28, 2016 and March 7, 2017 while Mr. Sessions occupied positions of public
trust and responsibility, to wit, United States Senator and Attorney General of the United States.

This complaint describes four distinct types of professional misconduct:

(1) An affirmative misrepresentation of fact under oath during testimony in Mr. Sessions’ Senate
confirmation process, specifically to a question propounded by Senator Al Franken.

(2) During Mr. Sessions’ US Senate confirmation hearing, failure to disclose significant facts
material to an issue of national significance, that is, contacts with the Russian government during
the presidential election.

(3) Perjury committed during Mr. Sessions’ Senate confirmation hearing.

(4) As Attorney General, withholding information about his own discussions with a
representative of the Russian government, all while overseeing investigations into Russian
interference with the US electoral process and Trump-Russia ties.

Legal Predicate for This Complaint
I. Relevant Rules of Professional Conduct for Alabama Lawyers
Rule 8.4(c) of the Alabama Rules states:
“It is professional misconduct for a lawyer to: (c) Engage in conduct involving
dishonesty, fraud, deceit or misrepresentation.”

Mr. Sessions was admitted to the Alabama Bar on September 24, 1973

The scope of this rule is broad, as it includes conduct occurring outside the practice of law, and it
does not require that the objectionable conduct be criminal.

Comments to Rule 8.4 address professional responsibility in the context of “matters of personal
morality.” Such comments indicate that a member shall be professionally answerable for
offenses involving violence, dishonesty, breach of trust, or serious interference with the
administration of justice insofar as they are relevant to law practice. The complainants assert
that Mr. Sessions’ conduct has direct bearing of relevance and critical importance to Mr.
Sessions’ status as an Alabama attorney.

In addition to the statements of misconduct generally applicable to all Alabama bar members,
complainants call the Commission’s attention to that portion of the Comment to Rule 8.4, cited
below, regarding bar members holding public office.

The Comment to Rule 8.4 states that:

“Lawyers holding public office assume legal responsibilities going beyond
those of other citizens. A lawyer's abuse of public office can suggest an
inability to fulfill the professional role of attorney. “

It is significant that the Alabama Rules distinguish the ethical responsibilities of lawyers in
public office from other lawyers, and mandate that lawyers in public offices are to be held to
stricter ethical and professional standards than lawyers not in government service.

The Rule 8.4 Comment makes it clear that Mr. Sessions, both in his present position as Attorney
General of the United States as well as in his previous position of US Senator from Alabama,
was and is subject to a greater ethical obligation than other Alabama bar members. That
obligation is to avoid conduct involving dishonesty, breach of trust, or serious interference with
the administration of justice.

For purposes of the instant Complaint, Mr. Sessions has at all times been a lawyer holding public
office. Mr. Sessions has been a United States Senator from Alabama, was then a nominee for the
role of Attorney General of the United States, and is now the highest-ranking lawyer in public
service in the United States. Mr. Sessions is supposed to be the lawyer for all the citizens of the
United States. The more stringent ethical requirements of Rule 8.4 clearly apply to his behavior,
which is outlined in the Factual Predicate below.

II. Candor Toward a Tribunal

Alabama Professional Responsibility Rule 3.3, Candor Toward the Tribunal, states in pertinent
“(a) A lawyer shall not knowingly:

(1) make a false statement of material fact or law to a tribunal…
(3) offer evidence that the lawyer knows to be false. If a lawyer has offered material
evidence and comes to know of its falsity, the lawyer shall take reasonable remedial
Complainants contend that Mr. Sessions’ US Senate confirmation hearing, conducted before
finders of fact with witnesses under oath, constitutes a Tribunal within the scope of Rule 3.3.

III. Perjury

Under Alabama law, a lie under oath constitutes perjury.

Alabama Code Title 13A. Criminal Code. § 13A-7-4 states that:

“A person commits the crime of perjury in the first degree when in any official
proceeding he swears falsely and his false statement is material to the proceeding in
which it is made.”

Moreover, Perjury by Executive Branch officials to Congress is so serious that there is a specific
federal law criminalizing it. 18 U.S.C. § 1001: US Code - Section 1001: Statements or entries

Complainants contend that Mr. Sessions’ US Senate confirmation hearing, conducted before
finders of fact with witnesses under oath, constitutes an “official proceeding” within the scope of
the Alabama and United States Criminal Codes.

IV. Complainants’ Obligation to Report Breaches of Professional Standards

A number of the signers of this complaint practice in Alabama and/or are members of the
Alabama bar who are compelled to file a complaint alleging a breach of professional conduct
under Rule 8.3(a).

Rule 8.3(a) states that:

“A lawyer possessing unprivileged knowledge of a violation of Rule 8.4
shall report such knowledge to a tribunal or other authority empowered to
investigate or act upon such violation.”

Those complainants who do not practice in Alabama are members of other state and federal bars
many of which, like Alabama, impose an ethical obligation on attorneys to report breaches of
professional conduct. In addition to our professional obligations, we also join in this complaint
because of our aligned and legitimate interest in preserving the integrity and reputation of the
legal profession, an interest which is impacted by the issues giving rise to this Alabama

complaint. It is critical to the integrity and reputation of our shared profession, as well as the
national interests of the United States of America, that lawyers in public office – particularly one
who holds the highest legal position – be honest, trustworthy, and act consistently and with
integrity in the service of justice.

Factual Predicate
To support complainants’ allegations of Mr. Sessions’ misconduct, dishonesty, and perjury, we
first set forth a timeline of activity that frames the context and specific acts addressed in this
complaint. Citations for the Timeline items can be found in the End Notes to this Complaint.

2/28/2016 Sessions is the first senator to endorse Trump’s presidential candidacy.
2 Trump announces Sessions will serve as Chairman of his National Security Advisory
Committee, thus making him privy to highly sensitive national security information.
3 Both Trump and Sessions meet with Russian Ambassador Sergey Kislyak during invitation-only
4/27/2016 backstage campaign reception before Trump’s first foreign policy speech. Mayflower
Hotel, Wash. D.C.
6/14/2016 Democratic National Committee (DNC) says Russian hackers penetrated its computer system.
5 Using Trump campaign funds, Sessions travels to Cleveland to the Republican National
7/18/2016 Committee (RNC) and speaks again with Russian Ambassador Kislyak following an RNC
7/22/2016 WikiLeaks posts 20,000 emails hacked from a number of DNC officials.
7/25/2016 FBI announces they have “high confidence” that Russia is behind the DNC hacking.
8 In news conference, Trump states he hopes “Russia can find Hillary Clinton’s missing 30,000
9 Senate Minority Leader Harry Reid went public with a letter to the FBI in which he expressed
8/27/2016 grave concern that Russia was seeking to interfere in the election and possibly to even
tamper with the tabulation of the vote.
10 President Obama meets with Putin at G20 Summit, warns him to stop hacking, and discusses
11 Sessions and two of his senior aides meet with Ambassador Kislyak in Sessions' office. No
other Senator on the Armed Services Committee (ASC) met with Kislyak in 2016, not
even the Chairman of the ASC. After the Washington Post broke the story about the
meeting, Sessions stated he did not discuss the election. The White House has since
admitted Sessions did indeed speak about the election, but claims it was “only
12 On the same day, Trump tweets that it would be “wonderful” if the US had a relationship with
9/8/2016 Russia, and that he didn’t believe the Russians were behind the hacks. Also, on the
same day, Trump and Pence praise Putin and his leadership style.
13 In the first presidential debate, Clinton states that cyber-attacks on DNC are coming from
10/7/2016 President Obama administration accuses Russia of interfering in US election.
15 In the second presidential debate, Clinton again addresses the gravity of the Russian hacks as
a threat to the integrity of the US electoral process.

16 Vice Presidential candidate Mike Pence tells Meet the Press that “there’s more and more
10/16/2016 evidence” that Russia was behind the DNC hacks and “there should be serious
17 Trump is elected President. Ten days later, Sessions is named as Trump’s pick for US Attorney
18 US intelligence agencies conclude Russia hacked the DNC and intervened in the election in
favor of Trump.
19 President Obama announces sanctions against Russia for trying to influence the election; he
ejects 35 Russian diplomats from the US and orders the closing of two Russian facilities.
20 On the same day that the sanctions were announced, Michael Flynn, President-elect Trump’s
choice for National Security Advisor, speaks to Russian Ambassador Kislyak by phone
five times. The next day, Putin states that Russia will not retaliate in response to the
21 Testifying under oath at his confirmation hearing, Sessions states he “did not have
communications with the Russians.”
22 Sessions is confirmed as Attorney General, and assumes responsibility for directing the
investigation into Russian meddling and interference with the US election.
23 National Security Advisor Michael Flynn resigns following revelations that he had indeed had
2/13/2017 conversations with Kislyak about the sanctions during the Trump campaign, and had
failed to disclose those conversations to Vice President Pence.
24 Sessions never reveals that he himself had met three times with Kislyak, and he fails to
3/1/2017 recuse himself from the Russia-Trump investigation between his confirmation as
Attorney General and March 1, when the Washington Post reported those meetings.
25 Sessions refuses to recuse himself from the Russia-Trump investigation until forced to do so
by public outcry.
26 Sessions sends letter to Senate Judiciary Committee to supplement his testimony. The letter
fails to acknowledge all three meetings with Kislyak, and focuses only on conversations
3/7/2017 about the election. Once again, Sessions avoids the question that Senator Franken
posed, which concerned all communications with Russian representatives during the
time period of the campaign.

Complaints of Professional Misconduct
1. Affirmative Misrepresentation of Fact (The Leahy and Franken

On at least three occasions, Mr. Sessions met with Russian Ambassador Sergey Kislyak during
the presidential campaign: April 27, 2016, July 18, 2016, and September 8, 2016.

In preparing for his Senate confirmation hearing, Mr. Sessions knew that he would encounter
questions regarding involvement with Russia, both because it was a major topic of concern to
senators and the public, and because he received pre-hearing questions about Russia. For
example, Senator Patrick J. Leahy (D-VT) submitted written questions to Sessions, which
included the following: “Several of the president-elect’s nominees or senior advisors have
Russian ties. Have you been in contact with anyone connected to any part of the Russian
government about the 2016 election, either before or after election day?”

Sessions answered: “No.”
On January 10, 2017, at his confirmation hearing, Mr. Sessions did in fact receive questions
about contacts with Russia. Senator Al Franken (D-Minn.) asked Mr. Sessions:

“If there is any evidence that anyone affiliated with the Trump campaign communicated
with the Russian government in the course of this campaign, what will you do?”
[Emphasis added.]
Mr. Sessions, under oath, testified in response:
“Senator Franken, I’m not aware of any of those activities. I have been called a
surrogate at a time or two in that campaign, and I did not have communications with
the Russians, and I‘m unable to comment on it.” [Emphasis added.]
See live video of the testimony at:
In response to Senator Franken’s question about what he, Sessions, would do under a
hypothetical set of circumstances, Sessions volunteered that he personally had had “no
communications with the Russians.”

That was untrue. In violation of both Rules 3.3 and 8.4(c), Mr. Sessions uttered a knowing and
deliberate falsehood on a clearly pertinent matter. It has now been established that Mr. Sessions
had at least three conversations with the Russian ambassador to the United States, Sergey
Kislyak, while Mr. Sessions was serving as the Chairman of Trump’s National Security
Advisory Committee for the campaign.

Senator Franken asked about any communications with the Russians in the course of the
campaign, and not necessarily communications about the campaign. Moreover, Senator
Franken’s question referred specifically to anyone affiliated with the Trump campaign. Finally,
Mr. Sessions’ answer, an affirmative statement in which he volunteered that he personally “had
no communication with the Russians” was a false statement, regardless of the construction of
Mr. Franken’s question.

Mr. Sessions was affiliated with the Trump campaign between March 3, 2016 and through the
election in November 2016. In fact, he was the Chairman of Trump’s National Security
Advisory Committee and Trump’s most high-profile supporter in the Senate. During that time,
he met with Russian Ambassador Kislyak at least three times, once at an invitation-only
reception at the Mayflower Hotel for Trump’s first foreign policy speech, where Sessions,
Trump and Kislyak mingled at the pre-speech reception backstage. They met again at an RNC
gathering in Cleveland where Mr. Sessions used Trump campaign funds for travel expenses.
That meeting took place in an environment framed by the election — the nominating convention
— and a shrewd diplomat would know that currying contacts with Mr. Sessions in his high-
profile role with the Trump campaign might be helpful if Mr. Sessions — as was already being
talked about — wound up with a top position in a Trump administration. Finally, Mr. Sessions
and Kislyak met in private at Mr. Sessions’ office in Washington D.C.

Mr. Sessions’ response to Senator Franken’s question was made with the intent to deceive and
obfuscate the confirmation proceedings of the US Senate. It is inconceivable that Mr. Sessions’
failure to mention his three meetings with the Russian ambassador was anything but deliberate.
Any suggestion by Mr. Sessions that his failure to reveal the meetings was an oversight, or not
relevant to the question, is patently disingenuous.

Moreover, it is inconceivable that a person charged with responsibility for protecting his
country’s national security interests would not remember multiple meetings with a Russian
ambassador suspected by many to be an intelligence asset and a spy recruiter. It would be
incredible to “forget” to fully disclose these meetings in both his certified written vetting
statement and in his sworn statement in reply to Senator Franken's questioning, given that
preparation for his confirmation hearing took place in his own office, where daily calendars and
records of meetings were readily accessible.

Once his false statements had been revealed through persistent investigative journalism, Mr.
Sessions, understandably and conveniently, denied intent to falsify and deceive, a claim he made
only after the media’s revelation: “In retrospect, I should have slowed down and said, ‘But I did
meet one Russian official a couple of times, and that would be the ambassador.’” See, Mark
Landler, Eric Lichtblau, Sessions Recuses Himself from Russia Investigation, NEW YORK TIMES,
March 3, 2017.

Seven weeks elapsed between the untrue utterances at the hearing and Mr. Sessions’ sudden
display of retrospective judgment, during which time he was possessed of all the knowledge he
would need to amend or supplement his confirmation hearing statements. Yet Mr. Sessions did
not choose to timely correct the record. Mr. Sessions’ failure to correct the record of his
“incorrect” testimony is in violation of Section (a)(3) of Rule 3.3, Candor Toward the Tribunal,
which states that a lawyer shall not knowingly

“(3) offer evidence that the lawyer knows to be false. If a lawyer has offered material
evidence and comes to know of its falsity, the lawyer shall take reasonable remedial
Until March 7, Mr. Sessions took no such remedial measures, reflecting the fond hope that his
deceptive answers would remain undiscovered and undisclosed. Even giving him every benefit
of the doubt, that his false statements during his confirmation hearing were unintentional, Mr.
Sessions’ failure to correct the record – by itself – is an ethical violation deserving of sanction.
Admitting his statements to the committee were false only after news sources made his
falsehoods public is not adequate to wash away this ethical violation. And while the harsh glare
of exposure has finally triggered a belated attempt to correct the record in the form of a March 7,
2017 letter from Mr. Sessions to Senator Franken, the former Trump campaign surrogate says
only that he does “not recall any discussions with the Russian ambassador, or any other
representative of the Russian government, about the campaign.” [Emphasis added].

Since Mr. Sessions was not asked “about the campaign,” by Senator Franken, but rather about
whether any Trump campaign surrogates communicated with the Russian government during a
specific time, this answer does not even succeed as a self-serving ex post facto rationalization.
The original false statement remains on the record.

Indeed, as one US Senator has pithily observed about the Trump cabinet’s relationship to the
truth, “They only do the right thing when they are caught doing the wrong thing.” See, Astead
W. Herndon and Tyler Pager, Under Pressure, Sessions Recuses Himself from Campaign
Probes, THE BOSTON GLOBE, March 2, 2017.

2. Failure to Disclose Under Oath
In addition to making false statements under oath in response to Senator Franken’s question, Mr.
Sessions generally did not testify truthfully and completely at his confirmation hearing.

Significantly, Mr. Sessions did not reveal the three meetings with Ambassador Kislyak at all
during his confirmation hearings. He had the opportunity to do so in both his written and oral
responses, yet did not do so. He also failed to disclose his knowledge that other Trump
campaign operatives had repeatedly spoken with Ambassador Kislyak.

It can hardly be argued that this broader obfuscation was incidental or inconsequential, given: a)
the gravity of intelligence agency investigations into contacts between the Trump campaign and
Russian officials; b) Senators demanding an FBI investigation; c) Russian hacking of the
Democratic National Committee; and d) the US imposition of sanctions against a long-standing
political foreign adversary possessing a nuclear arsenal.

During the time that Mr. Sessions was meeting with Ambassador Kislyak, the reports that Russia
was deliberately interfering with the US election to the benefit of Mr. Trump were already a hot
topic in the news. The fact that Mr. Sessions and other Trump surrogates were meeting with a
Russian official at a time when Russia was known to be interfering with the election to benefit
the campaign he was supporting is, without doubt, a material fact.

If Mr. Sessions wished to excuse his contacts with the Russians by saying they had been
undertaken in his capacity as a member of the Senate Armed Services Committee and not as a
senior-level surrogate acting in the interests of the Trump campaign, he could have testified that
such was the case. He did not so testify, clearly aware that if he did so he then would have been
open to a probing line of questioning about what those contacts were, and why he was
unilaterally talking with the ambassador of a country that was a longstanding adversary of the
United States.

The Comment to Rule 3.3 states that “[t]here are circumstances where failure to make a
disclosure is the equivalent of an affirmative misrepresentation.” In this case, Mr. Sessions’
failure to disclose his meetings with the ambassador deprived the Senate of an opportunity to

delve into the context and purpose of those meetings. It limited the Senate’s ability to make an
accurate and informed decision concerning Mr. Sessions’ confirmation as the next Attorney
General of the United States. Mr. Sessions’ failure to reveal that he and other Trump surrogates
met with the ambassador during the course of President Trump’s campaign is unquestionably a
circumstance where the failure to make a disclosure is the equivalent of an affirmative

3. Perjury
As noted above in the Legal Predicate for This Complaint, under Alabama law, a lie under oath
constitutes perjury. “A person commits the crime of perjury in the first degree when in any
official proceeding he swears falsely and his false statement is material to the proceeding in
which it is made.” Alabama Code Title 13A. Criminal Code. § 13A-7-4. Moreover, federal law
criminalizes knowingly or willfully making false statements or concealing information in matters
within the jurisdiction of the executive branch during a Congressional investigation or review. 18
U.S.C. § 1001(a), (c)(2) (1996).

In his testimony, conducted under oath in his confirmation hearing before the US Senate, Mr.
Sessions swore falsely and uttered material false statements, as described above. His behavior
constitutes perjury under both federal and state criminal statutes. It is criminal behavior that
cannot be excused or washed away by simple claims of lack of intent.

4. Dishonesty and Breach of Trust: Failure to Disclose a Material Fact After Confirmation
as Attorney General
Controversy about the Russian hacking and interference with the United States electoral process
continued to rage after Mr. Sessions’ confirmation as the country’s highest-ranking legal officer
and after he assumed responsibility for the investigations into Russian activity.

As soon as Mr. Sessions was confirmed as the US Attorney General, he assumed responsibility
for overseeing the investigation into the Russian interference with the presidential election and
with Trump-Russia ties. It was critically important for him to reveal his communications with
the Russian ambassador, either in his role as a member of the Armed Forces Committee or as the
Chairman of Trump’s National Security Advisory Committee for the campaign.

Although possessing information about contacts with a Russian intelligence asset by himself and
other members of the Trump organization during the campaign, Mr. Sessions did not come
forward with that information until those contacts were revealed by other sources. This was
information that led to Mr. Flynn’s dismissal as National Security Advisor. As a result, Mr.
Sessions seriously interfered with the administration of justice, a violation of Rule 8.4 as
reflected in the comment thereto.

Complainant does not file this complaint lightly, nor does it intend as a political gambit.

It is because Mr. Sessions leads the Department of Justice and serves in the role of US Attorney
General that we have reported his misconduct and requested that the Alabama State Bar
Disciplinary Commission impose stern sanctions on Mr. Sessions. His actions reflect poorly
upon the legal profession. Mr. Sessions is guilty of deceit, dishonesty, misrepresentation and
perjury, and his behavior warrants severe sanction, including, but not limited to, disbarment by
the Commission.

As the Preamble to the Alabama Rules of Professional Conduct states, a lawyer is an officer of
the legal system and a public citizen having special responsibility for the quality of justice. Mr.
Sessions’ conduct clearly violates, indeed insults, the rules that regulate his professional status,
and it cries out for stern sanctioning by the Alabama Bar.

Respectfully submitted,

/s/ Traci Feit Love
Founder & President
Lawyers for Good Government

NB: In support of this Complaint, as filed by Complainant Traci Feit Love on behalf of Lawyers
for Good Government, nearly 2,000 additional lawyer signatories are listed below, representing
each of the United States plus the District of Columbia. The signatories, while not individual
complainants, wish to add their support to this Complaint for the reasons set forth above.


1) Sarah Ferris, Trump Gets First Senate Endorsement, THE HILL, Feb. 28, 2016, available

2) Tom LoBianco, Trump Taps Sessions to Lead National Security Efforts, CNN, Mar. 3,
2016, available at

3) Jacob Heilbrunn, Why I Hosted Trump’s Foreign-Policy Speech, Politico Magazine, Apr.
27, 2016, available at
policy-speech-why-i-hosted-it-213858; Damian Palletta, Donald Trump Goes His Own
Way With Vladimir Putin, WALL ST. J., May 13, 2016, available at
1463172396; Adam Entous, Ellen Nakashima and Greg Miller, Sessions Met with
Russian Envoy Twice Last Year, Encounters He Later did not Disclose, WASH. POST,
Mar. 1, 2017, available at

4) Ellen Nakashima, Russian Government Hackers Penetrated DNC, Stole Opposition
Research on Trump, WASH. POST, June 14, 2016, available at

5) Paul Sonne, Rebecca Ballhaus and Carol E. Lee, Jeff Sessions Used Political Funds for
Republican Convention Expenses, WALL ST. J., Mar. 2, 2017, available at
convention-expenses-1488509301, Rebecca Morin, Josh Meyer and Austin Wright,
Sessions under Fire over Russia Meetings, Politico, Mar. 1, 2017, available at

6) Andrea Peterson, Wikileaks Posts Nearly 20,000 Hacked DNC Emails Online, WASH.
POST, July 22, 2016, available at

7) David E. Sanger and Eric Schmitt, Spy Agency Consensus Grows That Russia Hacked
D.N.C., NY TIMES, July 26, 2016, available at

8) Ashley Parker and David E. Sanger, Donald Trump Calls on Russia to Find Hillary
Clinton’s Missing Emails, NY TIMES, July 26, 2016, available at

9) David E. Sanger, Harry Reid Cites Evidence of Russian Tampering in U.S. Vote, and
Seeks F.B.I. Inquiry, NY TIMES, Aug. 29, 2016, available at

10) Kevin Liptak, Obama Has 'Blunt' Meeting with Putin but 'Gaps of Trust' on Syria
Remain, CNN, Sept. 5, 2016, available at

11) Adam Entous, Ellen Nakashima and Greg Miller, Sessions Met with Russian Envoy Twice
Last Year, Encounters He Later Did Not Disclose, WASH. POST, Mar. 1, 2017, available
9e613afeb09f_story.html?utm_term=.3517c1b299a1 ; Sabrina Saddiqui, Sessions Did
Not Disclose Meetings with Russian Ambassador During Trump Campaign, GUARDIAN,
Mar. 2, 2017, available at
sessions-russian-ambassador-trump-campaign; Aaron Blake, Jeff Sessions’s Denials of
Contact with Russians are Falling Apart Quickly, WASH. POST, Mar. 2, 2017, available at

12) Steven Lee Myers, Trump’s Love for Putin: a Presidential Role Model, NY Times, Sept.
8, 2016, available at
vladimir-putin.html; Kurtis Lee, Mike Pence agrees with Trump that Russia's Putin is
'stronger' leader than Obama, LA TIMES, Sept. 8, 2016, available at

13) Danielle Kurtzleben, Contrary To Trump's Tweet, Russian Hacking Came Up Before
Election (A Lot), NPR, Dec. 12, 2016, available at

14) David E. Sanger and Charlie Savage, U.S. Says Russia Directed Hacks to Influence
Elections, NY TIMES, Oct. 7, 2016, available at

15) Transcript of the Second Debate, NY TIMES, Oct. 10, 2016, available at

16) Eric Bradner, Pence Appears to Split with Trump over Russian Hacking Role, CNN, Oct.
16, 2016, available at

17) Julie Hirschfeld Davis, Trump Turns to His Right Flank to Fill National Security Posts,
NY TIMES, Nov. 18, 2016, available at

18) William M. Arkin, Ken Dilanian and Cynthia McFadden, U.S. Officials: Putin Personally
Involved in U.S. Election Hack, NBC News, Dec. 15, 2016, available at

19) David E. Sanger, Obama Strikes Back at Russia for Election Hacking, NY TIMES, Dec.
29, 2016, available at

20) Jonathan Landay and Arshad Mohammed, Trump Adviser Had Five Calls with Russian
Envoy on Day of Sanctions: Sources, REUTERS, Jan. 23, 2017, available at; Michael S.
Schmidt, Mark Mazzetti and Matt Apuzzo, Trump Campaign Aides Had Repeated
Contacts With Russian Intelligence, NY TIMES, Feb. 14, 2017, available at

21) Adam Entous, Ellen Nakashima and Greg Miller, Sessions Met with Russian Envoy Twice
Last Year, Encounters He Later Did Not Disclose, WASH. POST, Mar. 1, 2017, available

22) Eric Lichtblau and Matt Flegenheimer, Jeff Sessions Confirmed as Attorney General,
Capping Bitter Battle, NY TIMES, Feb. 8, 2017, available at

23) Maggie Haberman, Matthew Rosenberg, Matt Apuzzo and Glenn Thrushfeb, Michael
Flynn Resigns as National Security Adviser, NY TIMES, Feb. 13, 2017, available at

24) Tony Capra and Tony Ortiz, Attorney General Jeff Sessions: ‘I Will Recuse Myself’ If
Necessary, NBC News, Mar. 2 2017, available at
news/attorney-general-jeff-sessions-i-will-recuse-myself-if-necessary-n728046; Ryan
Lizza, Why Would Jeff Sessions Hide His Talks With Sergey Kislyak?, THE NEW YORKER,

Mar. 3, 2017, available at

25) Mark Landler and Eric Lichtblau, Jeff Sessions Recuses Himself From Russia Inquiry,
NY TIMES, Mar. 2, 2017, available at

26) Kevin Johnson, Attorney General Jeff Sessions: Senate Testimony Was 'Correct', USA
TODAY, Mar. 6, 2017, available at