Sussmann Trial 519 Afternoon

IN THE
IN THE UNITED
UNITED STATES
STATES DISTRICT
DISTRICT COURT
COURT
FOR THE DISTRICT OF COLUMBIA
FOR THE DISTRICT OF COLUMBIA
THE UNITED
THE UNITED STATES
STATES OF
OF AMERICA,
AMERICA, Criminal Action
Criminal Action No.
No.
Plaintiff,
Plaintiff, 1:21-CR-00582-CRC-1
1:21-CR-00582-CRC-1
May 19, 2022

May 19, 2022
vs.
vs. 1:56 p.m.
1:56 p.m.
MICHAEL
MICHAEL A. SUSSMANN,
A. SUSSMANN, #AFTERNOON SESSION*
*AFTERNOON SESSION
Defendant.
Defendant.
____________________________________________________________
TRANSCRIPT OF
TRANSCRIPT OF JURY
JURY TRIAL
TRIAL
HELD BEFORE
HELD BEFORE THE
THE HONORABLE
HONORABLE CHRISTOPHER
CHRISTOPHER R.
R. COOPER
COOPER
UNITED STATES
UNITED STATES DISTRICT
DISTRICT JUDGE
JUDGE
____________________________________________________________
APPEARANCES:
APPEARANCES:
For the
For the United
United States:
States: ANDREW DeFILIPPIS,
ANDREW DeFILIPPIS, ESQ.
ESQ.
JONATHAN EDGAR
JONATHAN EDGAR ALGOR,
ALGOR, IV,
IV, ESQ.
ESQ.
BRITTAIN SHAW, ESQ.
BRITTAIN SHAW, ESQ.
SPECIAL COUNSEL'S
SPECIAL COUNSEL'S OFFICE
OFFICE
145 NN Street
145 Street Northeast
Northeast
Washington, DC
Washington, DC 20002
20002
(212) 637-2231
(212) 637-2231
For the
For the Defendant:
Defendant: SEAN M.
SEAN BERKOWITZ, ESQ.
M. BERKOWITZ, ESQ.
MICHAEL BOSWORTH,
MICHAEL BOSWORTH, ESQ.
ESQ.
CATHERINE YAO,
CATHERINE YAO, ESQ.
ESQ.
NATALIE HARDWICK
NATALIE HARDWICK RAO,
RAO, ESQ.
ESQ.
LATHAM && WATKINS
LATHAM WATKINS LLP
LLP
1271 Avenue
1271 Avenue of
of the
the Americas
Americas
New York, NY 10020
New York, NY 10020
(212) 906-1200
(212) 906-1200
Court Reporter:
Court Reporter: Lorraine T.
Lorraine T. Herman,
Herman, RPR,
RPR, CCR
CCR
Official Court
Official Court Reporter
Reporter
U.S. Courthouse,
U.S. Room 6718
Courthouse, Room 6718
333 Constitution
333 Constitution Avenue,
Avenue, NW
NW
(202) 354-3187
(202) 354-3187
990
990
1
1 INDEX
I N D E X
2
2 WITNESS
WITNESS PAGE
PAGE
3
3 JAMES BAKER
JAMES BAKER
4
4 Direct Examination
Direct Examination by Mr. DeFelippis
by Mr. DeFelippis 993
993
JAMES BAKER
JAMES BAKER
5
° Direct Examination
Direct Examination by Mr. DeFilippis
by Mr. DeFilippis 993
993
6
6 Cross-Examination by
Cross-Examination by Mr.
Mr. Berkowitz
Berkowitz 1025
1025
7
7
8
8
9
9 EXHIBITS
E X H I B I T S
10
10 GOVERNMENT'S
GOVERNMENT'S AGE
PAGE
1
11 Government's No.
Government's No. 61
61 Admitted into Evidence
Admitted into Evidence 994
994
12
12
13
13 DEFENSE
DEFENSE AGE
PAGE
14
14 Defense
Defense No.
No. 809
809 Admitted
Admitted into
into Evidence
Evidence 1027
1027
Defense
Defense No.
No. A10
A10 Admitted
Admitted into
into Evidence
Evidence 1034
1034
15
15 Defense
Defense No.
No. A-10
A-10 Admitted
Admitted into
into Evidence
Evidence 1036
1036
Defense
Defense No.
No. 811
811 Admitted
Admitted into
into Evidence
Evidence 1065
1065
16
16 Defense
Defense No.
No. ALO
A10 Admitted
Admitted into
into Evidence
Evidence 1076
1076
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25
25
991
991
1
1 PROCEEDINGS
P R O C E E D I N G S
2
2 MR.
MR. ALGOR: Your Honor,
ALGOR: Your Honor, if
if II may just talk
may just talk briefly
briefly
3
3 about scheduling
about scheduling --
--
4
4 THE COURT:
THE COURT: Sure.
Sure.
5
5 MR.
MR. ALGOR: -- kind
ALGOR: -- kind of
of going
going forward.
forward.
6
6 THE COURT:
THE COURT: Yes.
Yes.
7
7 MR.
MR. ALGOR: So obviously,
ALGOR: So obviously, we
we understand
understand Mr.
Mr. Mook
Mook
8
8 has travel,
has travel, we
we have
have some
some family
family emergencies
emergencies and
and also
also travel
travel
9
9 related to
related to certain
certain witnesses.
witnesses. As the trial
As the trial is
is extended,
extended, we
we
10
10 are seeing
are seeing that
that we
we want to try
want to try to
to get
get some
some of
of those
those people
people
1
11 in tomorrow.
in tomorrow.
12
12 THE COURT:
THE COURT: Okay.
Okay.
13
13 MR.
MR. ALGOR: So our
ALGOR: So our proposal
proposal would
would be
be to
to put
put on
on --
--
14
14 assuming that
assuming that Mr.
Mr. Baker
Baker goes
goes through
through the
the end
end of
of the
the day,
day,
15
15 which II would
which would assume,
assume, the
the continuation
continuation or
or finalizing
finalizing
16
16 testimony regarding
testimony regarding Mr. Baker in
Mr. Baker in the
the morning,
morning, and
and then
then have
have
17
17 Mark Chadason and
Mark Chadason and Kevin
Kevin P.
P. testify
testify for
for the
the government
government
18
18 tomorrow with
tomorrow with the
the understanding
understanding that
that the
the defense
defense would
would have
have
19
19 Mr. Mook.
Mr. Mook.
20
20 I think
I think realistically
realistically that
that would
would involve
involve probably
probably
21
21 a full
a full day
day or
or at
at least
least close
close to,
to, but
but we
we would
would end
end it
it with
with
22
22 Mr.
Mr. Mook's testimony.
Mook's testimony.
23
23 THE COURT:
THE COURT: All
All right.
right. Are
Are we
we going
going to
to be
be able
able to
to
24
24 get there?
get there?
25
25 MR.
MR. ALGOR:
ALGOR: II believe
believe so,
so, Your
Your Honor.
Honor. II don't
don't
992
992
1
1 want to
want to speak
speak for
for defense,
defense, but
but Mr. Chadason's testimony
Mr. Chadason's testimony is
is
2
2 quite short.
quite short. It's obviously
It's obviously the
the agency
agency employees
employees so
so it's
it's
3
3 Limited to
limited to certain
certain aspects.
aspects.
4
4 I don't
I don't think
think that
that their
their --
-- either
either their
their directs
directs
5
5 or their
or their crosses
crosses will
will be
be too
too long,
long, but
but II don't
don't want to speak
want to speak
6
6 for the
for the defense.
defense.
7
7 THE COURT:
THE COURT: All right.
All right. Well, you
Well, you have
have me.
me. I hope
I hope
8
8 you have
you have the
the jury.
jury.
9
9 MR.
MR. ALGOR: Yes, Your
ALGOR: Yes, Your Honor.
Honor.
10
10 THE COURT:
THE COURT: I didn't
I didn't --
-- we
we said
said that
that Fridays
Fridays would
would
1
11 be aa possibility.
be possibility. II didn't
didn't commit
commit to
to letting
letting them
them off
off on
on
12
12 Fridays.
Fridays. Why don't
Why don't we
we bring them back,
bring them back, and
and I'm
I'm going
going to
to
13
13 raise this
raise this issue
issue with
with them
them now,
now, just
just to
to make sure that
make sure that
14
14 noone's got
noone's got any
any plans
plans tomorrow
tomorrow afternoon.
afternoon.
15
15 MR.
MR. ALGOR: Understood, Your
ALGOR: Understood, Your Honor.
Honor.
16
16 MR. DeFILIPPIS: Your
MR. DeFILIPPIS: Your Honor,
Honor, we and the
we and the defense
defense
17
17 conferred about
conferred about the
the issue
issue we
we have
have discussed
discussed with
with Mr.
Mr. Baker.
Baker.
18
18 We've reached
We've reached an
an agreement
agreement on
on that.
that. We are
We are happy
happy to
to get
get on
on
19
19 the phone
the phone to
to describe
describe it
it to
to Your
Your Honor.
Honor.
20
20 THE COURT:
THE COURT: That's okay.
That's okay.
21
21 MR. DeFILIPPIS: Okay.
MR. DeFILIPPIS: Thank you,
Okay. Thank you, Your
Your Honor.
Honor.
22
22 THE COURT:
THE COURT: I don't
I don't need
need to
to hear
hear anything
anything else
else as
as
23
23 long as
long as you
you are
are all
all on
on the
the same
same page.
page.
24
24 Step right
Step right up,
up, Mr.
Mr. Baker.
Baker.
25
25 (Jury entered
(Jury entered the
the courtroom.)
courtroom.)
993
1 DIRECT EXAMINATION OF JAMES BAKER (CONT'D.)
2 THE COURT: Please be seated.
3 Okay. Welcome back, ladies and gentlemen. I hope
4 you had a nice lunch.
5 Before we get back started with Mr. Baker, I just
6 want to go over a few scheduling matters. The parties tell
7 me that we are basically on track, but in order to stay on
8 track, as well as to accommodate some witnesses' travel
9 schedules, we have decided to work tomorrow.
10 I just wanted to make sure that that's okay with
11 everyone. I know we sort of left open the possibilities of
12 convening on Fridays. We will try to get you out a little
13 early, if possible, but as you can probably tell, sometimes
14 it's hard to predict how long these sections will take. So
15 we'll do our best.
16 The good news is I think we're on track in terms
17 of the schedule that we laid out at the beginning of trial.
18 All right?
19 JURORS: (Nodded.)
20 THE COURT: Mr. DeFilippis.
21 MR. DeFILIPPIS: Thank you, Your Honor.
22 BY MR. DeFILIPPIS:
23 Q. Welcome back, Mr. Baker.
24 A. Thank you.
25 Q. Mr. Baker, I'm going to show you one more excerpt

994
994
1
1 of your
of your congressional
congressional testimony
testimony and
and that
that will
will be
be the
the last.
last.
2
2 A.
A. Okay.
Okay.
3
3 Q.
Q. If II could
If could show
show you
you what's
what's been
been premarked
premarked as
as
4
4 Government's Exhibit
Government's Exhibit 61.
61.
5
5 Mr. Baker,
Mr. Baker, your
your first
first appearance
appearance before Congress
before Congress
6
6 was, II think,
was, think, in
in early
early October.
October. CanCan you
you tell
tell from
from the
the cover
cover
7
7 of this
of this page
page here
here which
which date
date your
your second
second appearance
appearance was?
was?
8
8 A.
A. This looks
This looks like
like the
the second
second one,
ome, yes.
yes. It
It was
was
9
9 Thursday, October
Thursday, October 18th,
18th, 2018.
2018.
10
10 MR. DeFILIPPIS: Your
Honor, the
the government
government offers
offers
1
11 Government's Exhibit
Government's Exhibit 61,
61, and
and we'll
we'll focus
focus on
on one
one or
or two
two pages
pages
12
12 of the
of the transcript.
transcript.
13
13 MR. BERKOWITZ: No
MR. BERKOWITZ: No objection
objection toto the
the introduction
introduction
14
14 being consistent
being consistent testimony,
testimony, Your
Your Honor.
Honor.
15
15 THE COURT:
THE COURT: So
So moved.
moved.
16
16 (Government's Exhibit
(Government's Exhibit 61
61 was
was admitted.)
admitted.)
17
17 MR. DeFILIPPIS: If
MR. DeFILIPPIS: If we
we could
could turn
turn to
to Page
Page 122
122 of
of
18
18 the transcript.
the transcript.
19
19 BY
BY MR.
MR. DeFILIPPIS:
DeFILIPPIS:
20
20 Q.
Q. Now, Mr.
Now, Baker, do
Mr. Baker, do you
you remember
remember that
that the
the issue
issue of
of
21
21 your meeting
your meeting with
with Mr.
Mr. Sussmann
Sussmann came
came up
up multiple times during
multiple times during
22
22 the testimony?
the testimony?
23
23 A.
A. ves.
Yes.
24
24 @.
Q. Including on
Including on the
the second
second day?
day?
25
25 A.
A. ves.
Yes.
995
995
1
1 Q.
Q. If II could
If could --
-- again,
again, I'll
I'll read
read the
the part
part of
of someone
someone
2
2 named Mr.
named Mr. Jordan.
Jordan. Who is Mr.
Who is Mr. Jordan?
Jordan? DoDo you
you know?
know?
3
3 A.
A. He is
He is Mr. Jim Jordan,
Mr. Jim Jordan, aa Congressman
Congressman from
from Ohio,
Ohio, II
4
4 believe.
believe.
5
5 ©.
Q. Okay. So
Okay. So why
why don't
don't we
we start
start at
at the
the top
top where
where you
you
6
6 say --
say -- near
near the
the top
top where
where you
you say,
say, "Yes,
"Yes, sir."
sir."
7
7 A.
A. Okay.
Okay.
8
8 "Yes, sir.
"Yes, sir. And
And there
there was
was some
some effort
effort --
-- there
there was
was
9
9 some belief
some belief that
that this
this was
was being
being conducted
conducted in
in aa way
way so
so as
as toto
10 || make
10 it aa covert
make it covert communications
communications channel."
channel."
n
11 @.
Q. "Okay. And
"Okay. And my
my first
first question
question would
would be,
be, How'd
How'd you
you
12
12 get this?
get this? DidDid you
you ask
ask that
that question?"
question?"
13
13 Just pausing
Just there, Mr.
pausing there, Mr. Baker.
Baker. This
This was talking
was talking
14
14 about your
about your meeting
meeting with Mr. Sussmann?
with Mr. Sussmann?
15
15 A.
A. I believe
I believe so,
so, yes.
yes.
16
16 ©.
Q. Okay. So
Okay. So go
go ahead.
ahead.
17
17 A.
A. my response
My response is:
is: "I "I did
did ask
ask that
that question
question atat aa
18
18 high level,
high level, yes.
yes. And
And he
he explained
explained that
that he
he had
had obtained
obtained it it
19
19 from, again,
from, again, cyber
cyber experts
experts who
who were -- who
were -- had --
who had -- who
who had
had
20
20 obtained the
obtained the information.
information. And he said
And he said that
that the
the details
details of of
21
21 it would
it explain themselves;
would explain themselves; that's
that's my recollection.”
my recollection."
22
22 ©.
Q. So the
So the "he"
"he" there,
there, Mr.
Mr. Baker,
Baker, was
was who?
who?
23
23 A.
A. I believe,
I believe, from
from the
the context,
context, it's
it's aa reference
reference to to
24
24 Mr. Sussmann.
Mr. Sussmann.
25
25 ©.
Q. Mr. Jordan
Mr. Jordan then
then says:
says: "And
“And he
he was
was representing
representing aa
996
996
1
1 client when
client he brought
when he this information
brought this information to
to you
you or
or just
just out
out
2
2 of the
of the goodness
goodness of
of his
his heart?
heart? Someone gave
Someone gave it
it to
to him
him and
and he
he
3
3 brought it
brought it to
to you?"
you?"
1
4 A.
A. In that
In that first
first interaction,
interaction, II don't
don't
5
5 remember him
remember him specifically
specifically saying
saying that
that he
he was
was
6
6 acting on
acting on behalf
behalf ofof aa particular client.
particular client.
7
7 Q. Did
Q. Did you
you know
know at
at the
the time
time that
that he
he was
was
8
8 representing the
representing the DNC
DNC in
in the
the Clinton
Clinton campaign?
campaign?
9
9 A.
A. II can't
can't remember.
remember. II hadhad learned
learned that
that atat
10
10 some point.
some point. II don't,
don't, asas II said
said --
-- as
as II think
think II
n
11 said last
said last time,
time, II don't specifically remember
don't specifically remember when
when
12
12 II learned
learned that
that --
-- excuse me --
excuse me -- so
so II don't
don't know
know
13
13 that II had
that had that
that in
in my head when
my head when he
he showed
showed up
up in
in my
my
14
14 office. II just
office. just can't
can't remember.
remember.
15
15 Q. Did
Q. Did you
you learn
learn that
that shortly
shortly thereafter
thereafter if if
16
16 you didn't
you didn't know
know it
it at
at the
the time?
time?
17
17 A.
A. One second
One second toto catch
catch up
up here.
here.
18
18 Q.
Q. Yeah, no
Yeah, no problem.
problem.
19
19 A.
A. II wish
wish II could
could give
give you
you aa better
better answer.
answer.
20
20 II just
just don't
don't remember.
remember.
21
21 Q. II mean,
Q. mean, II just
just find
find it
it unbelievable
unbelievable that
that
22
22 the guy
the guy representing
representing thethe Clinton
Clinton campaign,
campaign, the
the
23
23 Democratic National
Democratic National Committee,
Committee, shows
shows up
up with
with
24
24 information that
information that says,
says, We
We got
got this.
this. AndAnd you
you don't
don't
25
25 ask where
ask where hehe got
got it?
it? You
You didn't know how
didn't know how he
he got
got
997
997
1
1 it?
it? But he
But he got
got it
it from
from some,
some, you
you know,
know, "expert".
"expert".
2
2 A.
A. Well, if II could
Well, if could respond
respond to
to that?
that?
3
3 Q.
Q. sure.
Sure.
4
4 A.
A. II mean,
mean, II was
was so
so uncomfortable
uncomfortable with
with
5
5 being in
being in the
the position
position of
of having
having too
too much
much factual
factual
6
6 information conveyed
information conveyed to
to me
me because
because I'm
I'm not
not an
an
7
7 agent. And
agent. And so
so II wanted
wanted to
to get
get the
the information
information
8
8 into the
into the hands
hands of
of the
the agents
agents as
as quickly
quickly as
as
9
9 possible and
possible and let
let them
them deal with it.
deal with it. If they
If they
10
10 wanted to
wanted to go interview Sussmann
go interview Sussmann and
and ask
ask him
him all
all of
of
1
11 those kinds
those kinds of
of questions,
questions, fine
fine with
with me.
me.
12
12 @.
Q. Okay. Now
Okay. Now going
going back to the
back to the prior, the earlier
prior, the earlier
13
13 part of
part of that
that on
on Page
Page 122,
122, when
when you
you answered,
answered, Mr.
Mr. Baker,
Baker, "I
"I
14
14 can't remember.
can't remember. II had
had learned
learned that
that at
at some
some point.
point. II
15
15 don't --
don't -- as
as II think
think II said
said last
last time,
time, II don't
don't specifically
specifically
16
16 remember when
remember when II learned
learned that."
that."
17
17 And you
And you were
were referring
referring to
to Mr. Sussmann's
Mr. Sussmann's
18
18 representation of
representation of the
the DNC
DNC and
and the
the Clinton
Clinton campaign.
campaign. Do you
Do you
19
19 see that?
see that?
20
20 A.
A. ves.
Yes.
21
21 Q.
Q. When you
When you were expressing this
were expressing this uncertainty
uncertainty as
as to
to
22
22 when you
when you learned
learned that
that Mr.
Mr. Sussmann
Sussmann represented
represented the
the DNC
DNC in
in
23
23 the Clinton
the Clinton campaign,
campaign, did
did you
you mean
mean learned
learned that
that he
he
24
24 represented them
represented them at
at the
the meeting with you
meeting with you or
or represented
represented them
them
25
25 in other
in other contexts?
contexts?
998
998
1
1 A.
A. Represented them
Represented them in
in other
other contexts.
contexts.
2
2 ©.
Q. So when
So when you
you answered:
answered: In In that
that first
first interaction,
interaction,
3
3 II don't
don't remember
remember him
him specifically
specifically saying
saying he
he was
was acting
acting on
on
4
4 behalf of
behalf of aa particular
particular client.
client.
5
5 Mr. Jordan
Mr. Jordan then
then says:
says: DidDid you
you know
know at
at the
the time
time he
he
6
6 was representing
was representing thethe Clinton
Clinton campaign?
campaign?
7
7 So in
So in other
other words,
words, did
did any
any part
part of
of your
your testimony
testimony
8
8 intend to
intend to reflect
reflect that
that you
you knew
knew at
at some
some point
point that
that
9 || Mr.
9 sussmann was
Mr. Sussmann was representing
representing the
the DNC
DNC or
or the
the Clinton
Clinton
10
10 campaign at
campaign at his
his meeting with you?
meeting with you?
n
11 A.
A. Yo.
No.
12
12 ©.
Q. And in
And in this
this instance,
instance, did
did you
you say
say to
to Mr. Jordan or
Mr. Jordan or
13
13 volunteer to
volunteer to him
him that,
that, in
in fact,
fact, Mr.
Mr. Sussmann
Sussmann said
said hehe was
was not
not
14
14 representing any
representing any client?
client?
15
15 A.
A. Wait. I'm
Wait. I'm sorry.
sorry. I'm
I'm confused
confused by
by the
the question.
question.
16
16 ©.
Q. I'm sorry.
I'm sorry. InIn this
this exchange
exchange with
with Mr. Jordan, did
Mr. Jordan, did
17
17 you at
you at any
any point tell Mr.
point tell Mr. Jordan
Jordan that
that Mr.
Mr. Sussmann
Sussmann said,
said, in
in
18
18 fact, that
fact, that hehe wasn't
wasn't representing
representing any
any client
client or
or did
did you
you not
not
19
19 say that?
say that?
20
20 A.
A. I'm sorry.
I'm sorry. Still
Still I'm
I'm losing
losing the
the thrust
thrust ofof your
your
21
21 question.
question.
22
22 ©.
Q. That's okay.
That's okay. SoSo you
you testified
testified that
that Mr.
Mr. Sussmann
Sussmann
23
23 told you
told you affirmatively
affirmatively he he was
was not
not there
there for
for any
any client.
client.
24
24 Right?
Right?
25
25 A.
A. ves.
Yes.
999
999
1
1 ©.
Q. In this
In this exchange
exchange with
with Mr. Jordan, did
Mr. Jordan, did you
you
2
2 [| volunteer that
volunteer that oror say
say that?
that?
3
3 A
A. No.
No.
4
4 ©.
Q. And what
And what was the reason
was the reason for
for that?
that?
5
5 A.
A. I understood
I understood thethe question
question toto be coming from
be coming from aa
6
6 || aieerent angle.
different angle. Did Did he
he --
-- II believe
believe that
that II was
was being
being
7 ||
7 asked, Did
asked, pid he
ne specifically
specifically saysay in
in that
that meeting that he
meeting that he was
was
8 ||
8 representing the
representing tne DNC
onc or
or the
the Clinton
clinton campaign?
campaign?
9
9 When II thought
When thought about
about it,
it, my answer was,
my answer was, No,
No, hehe
10 ||
10 asan't specifically
didn't specifically saysay that
that in
in the
the meeting. That was
meeting. That was my
my
11 ||
11 recollection. No,
recollection. No, he
he didn't
didn't respond
respond to
to that
that --
-- I'm
I'm sorry.
sorry.
12 ||
12 1n response
In response toto that
that question,
question, hehe didn't
didn't say
say that.
that.
13
13 o.
Q. oxay.
Okay.
14
14 A.
A. I didn't
I didn't go on and
go on and elaborate
elaborate what else he
what else he might
might
15 ||
15 nave said
have said or
or anything
anything ofof that
that nature.
nature. II believe
believe II was
was
16 ||
16 trying to
trying to answer
answer thethe question
question that
that II thought
thought Mr.
Mr. Jordan
Jordan waswas
17 ||
17 asking.
asking.
18
18 Q.
Q. And then
And then when you said,
when you said, "I'm
"I'm not
not sure
sure when
when II
19 ||
19 1earned that
learned that he
ne represented
represented the
the DNC
DNC in
in the
the Clinton
Clinton
20 [[
20 campaign,” I1 think
campaign," think you
you testified
testified earlier
earlier you
you meant,
meant, learned
learned
21 ||
21 that he
that ne represented
represented them
them in
in other
other contexts.
contexts.
22
22 A.
A. In the
In the cyber
cyber intrusion
intrusion matter
matter having
having to
to do
do with
with
23 ||
23 russia. The
Russia. The cyber
cyber intrusion
intrusion ofof the
the DNC
DNC having
having to
to do
do with
with
24 ||
24 mussia.
Russia.
25
25 Q.
Q. Got it.
Got it. Okay.
Okay.
1000
1000
1
1 Now switching
Now switching topics,
topics, Mr. Baker.
Mr. Baker. Does the
Does the name
name
2
2 Rodney Joffe
Rodney Joffe mean
mean anything
anything to
to you?
you?
3
3 A.
A. ves.
Yes.
4
4 ©.
Q. And how
And how do
do you
you know,
know, if
if you
you know,
know, Rodney
Rodney Joffe?
Joffe?
5
5 A.
A. Mr. Joffe,
Mr. Joffe, II believe,
believe, isis associated
associated with
with anan
6
6 organization called
organization called Neustar.
Neustar. It's
It's aa company
company named
named Neustar.
Neustar.
7
7 ©.
Q. And how
And how do
do you
you know
know that?
that?
8
8 A.
A. I know
I know that
that --
-- well,
well, in
in the
the aftermath,
aftermath, II guess you
guess you
9
9 would say,
would say, ofof this
this investigation
investigation for
for sure
sure but,
but, to
to the
the best
best
10
10 of my
of recollection, II met
my recollection, met with
with Mr. Sussmann and
Mr. Sussmann and others
others onon
n
11 behalf of
behalf of Neustar
Neustar while
while II was
was general
general counsel
counsel of
of the
the FBI.
FBI.
12
12 So he
So he had
had come
come to
to meet
meet with
with me on behalf
me on behalf of
of that
that client
client atat
13
13 that time.
that time.
14
14 ©.
Q. In that
In that regard,
regard, as
as best
best as
as you
you recall,
recall, was
was that
that
15
15 before or
before or after
after your
your meeting
meeting onon the
the Alfa-Bank issue?
Alfa-Bank issue?
16
16 A.
A. I think
I think that
that was
was before the meeting
before the meeting on
on Alfa-Bank.
Alfa-Bank.
17
17 ©.
Q. And was
And was there
there aa particular
particular issue
issue or
or set
set ofof issues
issues
18
18 that Mr.
that Mr. Sussmann
Sussmann was
was bringing
bringing toto you
you on
on behalf
behalf of
of
19
19 Mr. Joffe?
Mr. Joffe?
20
20 A.
A. Yes.
Yes.
21
21 ©.
Q. And what
And what was that, to
was that, to the
the best
best of
of your
your memory?
memory?
22
22 A.
A. It had
It had to
to do,
do, basically,
basically, with concerns that
with concerns that
23
23 Neustar had
Neustar had about
about aa contract
contract for
for telecommunications
telecommunications
24
24 services/activities that
services/activities that had
had to
to do
do with phone number
with phone number
25
25 portability, telephone,
portability, telephone, cell
cell phone
phone number
number portability.
portability.
1001
1001
1
1 My understanding
My understanding is
is the
the U.S.
U.S. government
government --
-- my
my
2
2 recollection is
recollection is that
that the
the U.S.
U.S. government
government was
was contemplating
contemplating
3
3 giving that
giving that contract
contract to
to aa foreign
foreign company;
company; and
and that
that Neustar
Neustar
4
4 was --
was -- wanted to raise
wanted to raise with the Bureau
with the Bureau national
national security
security
5
5 concerns about
concerns about that,
that, about
about having
having aa foreign
foreign company
company running
running
6
6 part of
part of the
the U.S.
U.S. telecommunications
telecommunications system,
system, and
and so
so they
they came
came
7
7 to meet
to with us.
meet with us.
8
8 This was
This was also
also --
-- they
they clearly
clearly had
had aa business
business
9
9 interest in
interest in this,
this, because
because this
this was a contract
was a contract --
-- that
that II
10
10 understood and
understood and II recall,
recall, to
to the
the best
best of
of my ability --
my ability -- that
that
n
11 they had
they had at
at that
that point
point in
in time.
time.
12
12 So in
So in other
other words,
words, they
they were
were losing
losing the
the business
business
13
13 and it
and it was going to
was going to aa foreign
foreign company,
company, and
and they
they wanted
wanted to
to
14
14 have the
have the FBI
FBI intercede
intercede on
on their
their behalf
behalf with other parts
with other parts of
of
15
15 the U.S.
the U.S. government
government to
to have
have this
this decision
decision reversed,
reversed,
16
16 basically.
basically.
17
17 ©.
Q. And in
And in that
that context,
context, did
did Mr. Sussmann disclose
Mr. Sussmann disclose to
to
18
18 you that
you that he
he was
was coming
coming to
to you
you on
on behalf
behalf of
of aa specific
specific
19
19 client?
client?
20
20 A.
A. Yes.
Yes.
21
21 ©.
Q. And were
And were you
you aware,
aware, in
in that
that context,
context, specifically
specifically
22
22 that Mr.
that Mr. Joffe
Joffe was
was part of that
part of that effort?
effort?
23
23 A.
A. To the
To the best
best of
of my
my recollection.
recollection. We met with
We met with aa
24
24 number of
number of officials
officials from
from Neustar
Neustar and,
and, to
to the
the best
best of
of my
my
25
25 recollection, he
recollection, he was
was there.
there.
1002
1002
1
1 ©.
Q. And was
And was it
it your
your understanding
understanding oror impression
impression that
that
2
2 || there was
there was significant
significant business
business or
or money
money on
on the
the line
line in
in that
that
3 [[
3 -- in
-- in connection
connection with
witn that?
tnatz
a
4 A.
A. Yes, yes.
Yes, yes.
5
5 ©.
Q. And what
And what gave you that
gave you that impression?
impression?
6
6 A.
A. I think
I think it
it was
was from
from what
what they
they said
said in
in the
the meetings
meetings
7 ||
7 ana also
and also some
some separate
separate briefings that II received
briefings that received onon the
the
8 ||
8 macter from my
matter from 1auyers and
my lawyers and other
other officials
officials atat the
the FBI,
Fer, I1
s [[
9 enink.
think.
10
10 ©.
Q. And how
And how aggressively
aggressively oror unaggressively
unaggressively were
were
11 [|
11 wr. sussmann and
Mr. Sussmann and his
his client
client pressing
pressing this
this issue?
issue? Was
Was it
it aa
12 |
12 passing thing
passing thing or
or --
--
13
13 A.
A. No, they
No, they were quite concerned
were quite concerned about
about it.
it. They
They came
came
14 ||
14 in and
in and had
nad at
at least
least one
one meeting with us.
meeting with us. And
And II wouldn't
wouldn't say
say
15 ||
15 they were
they were aggressive
aggressive inin the
the meeting or doing
meeting or doing anything
anything
16 |
16 improper or
improper or anything
anything of
of that
that nature.
nature. They
They were raising
were raising
17 ||
17 serious concerns
serious concerns that
that we
we took
took seriously
seriously and
and evaluated.
evaluated.
18
18 9.
Q. At all
At all times
times did you know
did you know who
who Mr.
Mr. Sussmann
Sussmann was
was
19 |
19 there for?
there forz
20
20 A.
A. Yes, absolutely.
Yes, absolutely. He He was representing Neustar.
was representing Neustar.
21
21 Q.
Q. Mr. Baker,
Mr. Baker, we
we talked
talked earlier
earlier about
about instances
instances inin
22 ||
22 which you
which you may
may have
have been questioned or
been questioned or interviewed
interviewed about
about
23 ||
23 1eaks of
leaks of classified
classified information.
information. AndAnd you
you mentioned
mentioned one
one
24 ||
24 particular such
particular such investigation
investigation that
that was going on
was going on around
around the
the
25
25 [time you
time you left
left the
the FBI?
B12
1003
1003
1
1 A.
A. ves.
Yes.
2
2 ©.
Q. And who
And who was
was the
the --
-- if
if you
you recall,
recall, who
who was
was the
the
3
3 || orosecutor on
prosecutor on that?
tnac2
1
4 A.
A. Mr. John
Mr. John Durham.
Durham.
5
5 ©.
Q. Okay. And
Okay. And what
what was
was the
the ultimate
ultimate outcome
outcome of
of that
that
6
6 || investigation in
investigation in terms
terms of
of whether
whether any
any charges
charges oror allegations
allegations
77 || of wrongdoing
of were brougne2
wrongdoing were brought?
88 A.
A. The investigation
The investigation was
was eventually
eventually closed
closed with
with nono
99 || further action,
further action, no
no charges
charges being brought, no
being brought, no other
other action
action
10 [|
10 veing taken.
being taken.
un
11 ©.
Q. Now, when
Now, the special
when the special counsel's
counsel's investigation
investigation -- ==
12 ||
12 when this
when this investigation
investigation began,
began, did
did there
there come
come aa time
time when
when
13 [|
13 vou were
you were interviewed
interviewed inin connection
connection with the investigation?
with the investigation?
14
14 A.
A. ves.
Yes.
1s
15 ©.
Q. And, in
And, in fact,
fact, did
did there
there come
come multiple times?
multiple times?
16
16 A.
A. Yes.
Yes.
17
17 ©.
Q. And at
And at that
that time,
time, were
were you
you --
-- did
did you
you at
at least
least
18 ||
18 initially have
initially have some
some --
-- so
so you
you obviously
obviously recognize
recognize Mr.
Mr. Durham
Durham
19 ||
19 as having
as having --
-- from
from your
your prior interactions in
prior interactions in the
the prior
prior case?
case?
20
20 A.
A. Yes.
Yes.
21
21 ©.
Q. In your
In your interactions
interactions with the team
with the team on
on this
this case,
case,
22 ||
22 aid you
did you in
in any
any way change, differ,
way change, differ, shade
shade what
what you
you told
told the
the
23 ||
23 team as
team as aa result
result of
of the
the prior
prior investigation?
investigation?
2
24 A.
A. No.
No.
25
25 Q.
Q. And why
And why is
is that?
that?
1004
1004
1
1 A.
A. Because my
Because my obligation
obligation is
is to
to tell
tell you
you the
the truth,
truth,
2
2 first of
first of all.
all. And, secondly, to
And, secondly, to the
the best
best of
of my
my
3
3 recollection, before
recollection, before you
you all
all started
started asking
asking me questions
me questions
4
4 about this
about this and
and related
related matters,
matters, matters relating to
matters relating to the
the
5
5 FBI's investigation
FBI's investigation of of the
the Russia
Russia investigation,
investigation, atat that
that
6
6 point in
point in time
time it
it was
was my
my understanding
understanding that
that both
both Mr. Durham
Mr. Durham
7
7 had closed
had closed the
the case
case with
with aa recommendation
recommendation forfor no
no further
further
8
8 action; and
action; and that,
that, eventually
eventually and
and finally,
finally, the
the Department
Department of of
9
9 Justice, after
Justice, after many
many months, finally had
months, finally had decided
decided toto close
close the
the
10
10 case.
case.
n
11 It had
It had to
to go
go to
to the
the U.S.
U.S. Attorney for the
Attorney for the District
District
12
12 of Columbia,
of Columbia, thethe Assistant
Assistant Attorney General for
Attorney General for National
National
13
13 Security, and
Security, and the
the Deputy
Deputy Attorney
Attorney General.
General. But,
But, finally,
finally,
14
14 the Deputy
the Deputy Attorney General signed
Attorney General signed off
off on
on it
it and
and the
the matter
matter
15
15 was closed,
was closed, asas far
far as
as II understood.
understood.
16
16 ©.
Q. Have you
Have you in
in any
any way
way tailored
tailored your
your telling
telling of
of
17
17 events here,
events here, in
in this
this investigation
investigation oror anywhere,
anywhere, towards
towards what
what
18
18 you think
you think people
people want
want you
you to
to say?
say?
19
19 A.
A. vo.
No.
20
20 ©.
Q. Let's return
Let's return to
to the
the text
text exchange,
exchange, Government's
Government's
21
21 Exhibit 1500,
Exhibit 1500, that
that you
you maintained with Mr.
maintained with Sussmann. Is
Mr. Sussmann. Is it
it
22
22 fair to
fair to say
say you
you continued
continued contact
contact with
with Mr. Sussmann for
Mr. Sussmann for aa
23
23 while after
while after you
you left
left the
the Bureau?
Bureau?
24
24 A.
A. ves.
Yes.
25
25 MR. DeFILIPPIS: So
MR. DeFILIPPIS: So if
if we
we could
could go
go to
to the
the text
text
1005
1005
1
1 || message dated January
message dated sanuary 22nd
22na of
of 2019.
2019.
2 || er
2 BY mr.
MR. perrvreers:
DeFILIPPIS:
3
3 Q.
Q. Mr. Baker,
Mr. Baker, at
at 9:05
9:05 a.m.
a.m. on
on January
January 22nd,
22nd,
4 || mr.
4 sussmann writes
Mr. Sussmann writes to
to you:
you: "Jim,
"sim, we were contacted
we were contacted by by Fox
Fox
5 || saying
5 saving they
they were
were running
running aa news
news story
story and
and asked
asked for
for
6 || comments.
6 comments. my firm gave
My firm them the
gave them the same
same one
one from
from before.
before.
7 || anyway,
7 Anyway, I'm1m passing
passing this
this along
along because
because I1 wouldn't
wouldn't have
have seen
seen
8 || it
8 ic if
if no
no one
one told
told me.
me. Nothing important and
Nothing important and just
just FYI.
Evi. Cancan
9 || we
9 we speak
speax afternoon
aterncon on on unrelated
unrelated topic?"
topic
10
10 Mr. Baker
Mr. Baker how
how did
did you
you take
take this
this text
text message?
message?
11 || what
11 was your
What was your reaction?
reaction?
12
12 A.
A. It was
It was aa friendly
friendly heads
heads upup by
by Michael
Michael about
about this
this
13 | article.
13 article.
14
14 9.
Q. And do
And do you
you have
have any
any recollection,
recollection, sitting
sitting here
here
15 || today,
15 today, of of what
wnat it
it is
is that
that you
you talked
talked about?
about?
16
16 A.
A. The reference
The reference toto may
may we -- "can
we -- "can we
we speak
speak inin
17 || afternoon
17 afternoon on on an
an unrelated
unrelated topic?"
topic?
18
18 9.
Q. Right.
Right.
19
19 A.
A. In 2019,
In 2019, no,
no, II don't
don't really
really recall
recall what
what that
that was
was
20 [[ about
20 about sitting
sitting here
here today.
today.
21
21 Qo.
Q. okay.
Okay.
22
22 MR. DeFILIPPIS: So
MR. DeFILIPPIS: So if
if we
we go
go to
to the
the next
next page.
page.
23 || Br
23 BY mr.
MR. perzrreeis:
DeFILIPPIS:
24
24 ©.
Q. Looks like
Looks like you
you wrote
wrote back: "Thanks. Can
back: "Thanks. Can wewe talk
talk
25 [| after
25 after 3:30
3:30 p.m.
p.m.?" AndAnd wr. Sussmann says,
Mr. Sussmann says, "Sure."
"sure."
1006
1006
1
1 Again, no
Again, no recollection
recollection of
of what
what that
that would
would have
have
2
2 been?
been?
3
3 A
A. No.
No.
4
4 ©.
Q. And then
And then on
on January
January 22nd
22nd of
of 2019,
2019, the
the same
same date,
date,
5
5 at 11:47
at 11:47 a.m.,
a.m., Mr. Sussmann sends
Mr. Sussmann sends you
you what
what appears
appears toto be
be aa
6
6 screenshot of
screenshot of aa Tweet
Tweet by
by the
the former
former president.
president. HowHow did
did you
you
7
7 take that?
take that?
8
8 A.
A. Again, aa friendly
Again, friendly heads
heads up.
up. I'm
I'm quite
quite confident
confident II
9
9 had already
had already seen
seen this
this Tweet
Tweet by
by this
this point
point in
in time
time but,
but, yeah.
yeah.
10
10 ©.
Q. Is that
Is that because
because it
it refers
refers to
to you?
you?
n
11 A.
A. It refers
It refers to
to me and Michael,
me and Michael, yes.
yes. The
The same
same Tweet
Tweet
12
12 from the
from the former
former president.
president.
13
13 ©.
Q. Okay. Moving
Okay. Moving along
along to
to the
the next
next page,
page, which
which is
is aa
14
14 January 22nd,
January 22nd, 2019
2019 message.
message.
15
15 A.
A. ves.
Yes.
16
16 ©.
Q. So the
So the first
first message there at
message there at 4:07
4:07 p.m.,
p.m., there
there is
is
17
17 an article,
an article, the
the headline
headline appears
appears to
to be
be "Baker
"Baker Testimony
Testimony
18
18 Reveals Perkins
Reveals Perkins Coie
Coie Lawyer
Lawyer Provided
Provided Information
Information onon
19 || arfa-sank».
19 Alfa-Bank".
20
20 A.
A. Uh-huh.
Uh-huh.
21
21 ©.
Q. Is this
Is this what
what you
you referred
referred toto earlier,
earlier, that
that when
when
22
22 you testified,
you testified, word got out
word got out to
to the
the public?
public?
23
23 A.
A. Somehow word
Somehow word got out to
got out to the
the public
public in
in aa variety
variety of of
24
24 different ways,
different ways, and
and it
it kept
kept getting
getting repeated
repeated and
and repeated
repeated
25
25 and repeated
and repeated over
over time
time up
up till
till this
this day
day about
about this
this and,
and,
1007
1007
1
1 yeah.
yeah. Again, me being
Again, me being criticized
criticized for
for even
even having
having had
had the
the
2 || meeting
2 with Michael
meeting with michael made
made me
me somehow
somehow part
part of
of aa coupe
coupe plot
plot oror
3
3 something.
something.
4
4 ©.
Q. At any
At any time,
time, till
till this
this date,
date, January
January 22nd
22nd ofof 2019,
2019,
5
5 did Mr.
did Sussmann ever
Mr. Sussmann ever call
call you
you or
or text
text you
you and
and say,
say, Oh,
Oh, by
by
6
6 the way,
the way, II was there for
was there for aa client
client or
or anything
anything ----
7
7 A.
A. Yo.
No.
8
8 Q.
Q. -- in
-- in that
that regard?
regard?
9
9 A
A. Yo.
No.
10
10 ©.
Q. Did anything
Did anything make you think,
make you think, you
you know,
know, sort
sort of
of
n
11 looking back
looking back or
or even
even bring
bring your
your mind
mind toto the
the issue
issue ofof the
the
12
12 fact, whether
fact, whether hehe might
might have
have done
done it
it for
for aa client
client ----
13
13 A
A. um...
Um...
14
14 ©.
Q. -- other
-- other than
than your
your congressional
congressional testimony?
testimony?
15
15 A.
A. Well, II was
Well, was asked
asked about
about it
it there.
there. And,
And, obviously,
obviously,
16
16 as we
as talked about
we talked about it
it earlier,
earlier, II was
was asked
asked about
about itit with
with the
the
17
17 I.G. But
I.G. But II didn't
didn't spend
spend aa lot
lot of
of time
time thinking
thinking about
about that
that
18
18 aspect of
aspect of things,
things, no.
no.
19
19 ©.
Q. Now, at
Now, at 8:11
8:11 a.m.
a.m. on
on June
June 10th
10th of
of 2019
2019 ---- so
so this
this
20
20 is several
is several months later, right,
months later, right, about
about five
five months
months ----
21
21 A.
A. Uh-huh.
Uh-huh.
22
22 ©.
Q. -- Mr.
-- Mr. Sussmann
Sussmann writes
writes "Hi,
"Hi, Jim.
Jim. Heard
Heard you
you saw
saw
23
23 Rodney yesterday.
Rodney yesterday. I'mI'm in
in town
town the
the rest
rest ofof June
June and
and would
would
24
24 enjoy getting
enjoy getting together.
together. Would
Would you
you like
like toto meet for lunch
meet for lunch oror
25
25 dinner one
dinner one of
of these
these days?
days? If If so,
so, let
let me
me know
know what's
what's best,
best,
1008
1008
1
1 | wicnaer.n
Michael."
2
2 The reference
The reference to
to Rodney
Rodney there,
there, any
any recollection
recollection of
of
3
3 [| who
who that
that is?
is2
1
4 A.
A. I believe
I believe itit was
was aa reference
reference to
to Rodney
Rodney Joffe.
Joffe. II
5 [| believe
5 perseve I1 ran
ran into
into Rodney
Rodney on
on the
the margins
margins ofof some
some type
type of
of
6 || event
6 event or
or conference
conference or or something
something in
in D.C.
D.C. when
when II --
-- this
this was
was
7 || the
7 the time
time period
period when
when I1 was
was working
working atat the
the think
think tank.
tank. Part
art
8 [| of
8 of my job --
my job -- at
at RRr Street.
street.
9
9 Part of
Part of mymy job
job at
at aa think
think tank
tank is
is to
to go
go to
to
10 || conferences.
10 conferences. II wentwent toto conferences.
conferences. II met people, and
met people, ana II
11 || think
11 think I1 spoke
spoke briefly
briefly to to him,
him, to
to the
the best
best of
of my
my recollection
recollection
12 || sitting
12 sitting here
nere today.
today.
13
13 Q.
Q. And if
And if that's
that's the
the case,
case, if
if you
you spoke
spoke to
to Mr.
Mr. Joffe,
Joffe,
14 [| when
14 when you
you spoke
spoke to
to him,
him, did you connect
did you connect him
him in
in any
any way
way to
to the
the
15 | September
15 septemper 19th,
19tn, 2016
2016 meeting
meeting with
with Mr.
Mr. Sussmann?
Sussmann?
16
16 A.
A. Yo.
No.
17
17 ©.
Q. And do
And do you
you remember
remember much,
much, or
or if
if anything,
anything, about
about
18 || that
18 that interaction
interaction withwith Mr.
Mr. Joffe
Joffe or
or was it aa fleeting
was it fleeting sort
sort ofof
19 | thing?
19 cningz
20
20 A.
A. It was
It was aa very brief hello-how-are-you
very brief hello-how-are-you exchange
exchange of of
21 || pleasantries.
21 pleasantries. II don'tdon't think
think we
we talked
talked about
about anything
anything
22 [ substantive.
22 substantive.
23
23 MR. DeFILIPPIS: All
MR. DeFILIPPIS: right. If
All right. If we
we could
could move
move onon
24 || to
24 to the
the next
next page.
page.
25
25
1009
1009
1
1 BY
BY MR.
MR. DeFILIPPIS:
DeFILIPPIS:
2
2 Q.
Q. Mr. Baker,
Mr. Baker, there
there are
are aa series
series of
of texts
texts on
on this
this
3
3 page.
page. It looks
It looks like
like you
you make
make arrangements
arrangements to
to meet;
meet; is
is that
that
4
4 correct?
correct?
5
5 A.
A. Yeah, we
Yeah, we went back and
went back and forth
forth trying
trying to
to figure
figure out
out
6
6 a time
a time to
to have
have lunch.
lunch.
7
7 @.
Q. All right.
All right. So
So on
on the
the next
next page,
page, it
it looks
looks like
like you
you
8
8 are firming
are firming up
up plans?
plans?
9
9 A.
A. On the
On the page
page I'm
I'm looking
looking at,
at, June
June 20,
20, 2019
2019 is
is in
in
10
10 the middle.
the Yeah, so
middle. Yeah, so we
we are
are just
just trying
trying to
to establish
establish aa date
date
1
11 and aa time
and time and
and aa location.
location.
12
12 MR. DeFILIPPIS: All
MR. DeFILIPPIS: right. Next
All right. page.
Next page.
13
13 BY
BY MR.
MR. DeFILIPPIS:
DeFILIPPIS:
14
14 Q.
Q. And on
And on this
this page,
page, Mr.
Mr. Baker,
Baker, we
we see
see texts
texts about
about aa
15
15 reservation time
reservation time of
of 12:30.
12:30. And then finally,
And then finally,
16
16 Mr. Sussmann --
Mr. Sussmann -- towards
towards the
the bottom
bottom --
-- says,
says, "be
"be there
there in
in 22
17
17 minutes".
minutes".
18
18 A.
A. ves.
Yes.
19
19 Q.
Q. Now in
Now in July
July of
of 2019,
2019, do
do you
you remember
remember where you
where you
20
20 were working?
were working? Was that --
Was that --
21
21 A.
A. Excuse me.
Excuse me. II don't
don't see
see the
the two
two minutes
minutes thing
thing now
now
22
22 that II am
that am looking
looking at
at it.
it.
23
23 Q.
Q. Oh, I'm
Oh, I'm sorry.
sorry. We We may
may be
be --
-- sorry
sorry about
about that.
that. SoSo
24
24 when you
when you say,
say, "Proper
"Proper 21.
21. SeeSee you
you there
there at
at 12:30".
12:30"
25
25 A.
A. Right.
Right.
1010
1010
1
1 MR. BERKOWITZ: If
MR. BERKOWITZ: If we
we then
then go
go to
to the
the next
next page.
page.
2 || BY
2 BY mm.
MR. perrireers:
DeFILIPPIS:
3
3 ©.
Q. Further [sic]
Further [sic] discussion
discussion ofof this
this meeting?
meeting?
4
4 A.
A. Of the
Of the lunch
lunch meeting?
meeting?
5
5 Q.
Q. ves.
Yes.
6
6 A.
A. Yes, there
Yes, there is
is just
just exchange
exchange back
back and
and forth
forth about
about
7
7 the lunch
the lunch meeting,
meeting, yeah.
yeah.
8
8 ©.
Q. Okay.
Okay.
9
9 A.
A. Then it
Then it says,
says, Be
Be there
there in
in 10
10 minutes, yes.
minutes, yes.
10
10 ©.
Q. veah.
Yeah.
n
11 A.
A. I see
I see now,
now, yes.
yes.
12
12 Q.
Q. My apologies.
My apologies. II am am getting
getting ahead.
ahead.
13
13 So did
So did you,
you, in
in fact,
fact, meet up with
meet up Mr. Sussmann
with Mr. Sussmann inin
14
14 July of
July of 2019?
2019?
15
15 A.
A. Yes, we
Yes, we did.
did. WeWe went to that
went to that place.
place. HeHe didn't
didn't
16
16 like it,
like it, and
and so
so we
we went to aa different
went to different place.
place. HeHe quickly
quickly
17
17 found aa reservation
found reservation oror he
he quickly
quickly got
got aa table
table somewhere
somewhere
18
18 else, and
else, and we
we went
went somewhere
somewhere else
else for
for lunch
lunch but, yes, we
but, yes, we had
had
19
19 lunch.
lunch.
20
20 ©.
Q. And during
And during that
that lunch,
lunch, any
any mention
mention of
of your
your
21
21 September 19th,
September 19th, 2016
2016 meeting,
meeting, asas far
far as
as you
you can
can recall?
recall?
22
22 A.
A. I think
I think we
we probably
probably talked
talked about
about the
the Alfa-Bank
Alfa-Bank inin
23
23 general, the
general, the articles
articles that
that continued
continued to
to come
come out.
out. II think
think
24
24 he may
he have said
may have said something
something about
about somebody
somebody else
else working on
working on
25
25 another article
another article about
about the
the matter.
matter. ButBut we didn't --
we didn't -- II don't
don't
1011
1011
1
1 think we
think we specifically
specifically talked
talked about
about the
the meeting on September
meeting on September
2
2 19th of
19th of 2016.
2016.
3
3 ©.
Q. And during
And during those
those discussions, any acknowledgment
discussions, any acknowledgment
4
4 or mention
or mention by Mr. Sussmann
by Mr. Sussmann that
that he
he had
had been doing it
been doing it for
for aa
5
5 client?
client?
6
6 A.
A. The meeting
The meeting with
with me on September
me on September 19th,
19th, 2016?
20167
7
7 Q.
Q. ves.
Yes.
8
8 A
A. Yo.
No.
9
9 ©.
Q. Any discussion
Any discussion oror mention of whether
mention of whether he
he was
was doing
doing
10
10 it for
it for the
the Clinton
Clinton campaign
campaign or
or the
the DNC?
DNC?
n
11 A.
A. Not that
Not that II recall,
recall, no.
no.
12
12 ©.
Q. Any mention
Any mention of
of whether
whether he
he had
had done
done it
it for
for
13
13 Mr. Joffe
Mr. Joffe or
or Neustar?
Neustar?
14
14 A.
A. No.
No.
15
15 MR. DeFILIPPIS: Then,
MR. DeFILIPPIS: Then, finally,
finally, if
if we
we could
could go
go to
to
16
16 the next
the next page.
page.
17 || BY
17 BY mr.
MR. peFrLIPRIS:
DeFILIPPIS:
18
18 Q.
Q. If we
If we look
look at
at the
the May 5th, 2020
May 5th, 2020 text
text message at
message at
19
19 10:28 p.m.,
10:28 p.m., dodo you
you mind just reading
mind just reading that
that text
text message from
message from
20
20 Mr. Sussmann?
Mr. Sussmann?
21
21 A.
A. From Michael:
From "Jim, II just
Michael: "Jim, just heard
heard the
the good
good news.
news.
22
22 Congratulations to
Congratulations to you
you and
and especially
especially toto Twitter
Twitter for
for getting
getting
23
23 you on
you on their
their team.
team. I've
I've been
been working
working with
with them
them for
for 10
10 years
years
24
24 and I1 love
and love the
the company,
company, great
great issues
issues and
and lots
lots of
of fun
fun
25
25 challenges for
challenges for you
you and
and some
some really
really good
good people."
people."
1012
1012
1
1 I'm sorry.
I'm sorry. I beg
I beg your
your pardon.
pardon. Should II start
Should start
2
2 over?
over? I'll start
I'll start with
with this:
this: "Great issues
"Great issues and
and lots
lots of
of fun
fun
3
3 challenges for
challenges for you
you and
and some
some really
really good
good people.
people. Angela and
Angela and
4
4 Abby on the
Abby on the top
top of
of that
that list.
list. Let
Let me know if
me know if you'd
you'd like
like toto
5
5 catch up
catch up sometime.
sometime. Really
Really happy
happy for
for you.
you. Michael."
Michael."
6
6 ©.
Q. And then
And then how
how do you respond?
do you respond?
7
7 A.
A. "Thanks, Michael.
"Thanks, Michael. II look
look forward
forward to
to working
working with
with
8
8 you! If
you! If you
you don't
don't mind, please keep
mind, please keep it
it under
under your
your hat
hat until
until
9
9 Friday. II haven't
Friday. haven't told
told my current employer
my current employer yet!
yet! Thanks.
Thanks. II
10
10 hope all
hope all is
is well
well with
with you
you and
and your
your family.
family. Take
Take care."
care."
n
11 ©.
Q. All right.
All right. And
And then,
then, Mr. Baker, the
Mr. Baker, the final
final page
page of
of
12
12 this series
this series of
of exchanges
exchanges with
with Mr.
Mr. Sussmann.
Sussmann.
13
13 A.
A. Okay. Yeah.
Okay. Yeah. HeHe starts
starts --
-- from
from Michael
Michael it
it says,
says,
14
14 “Absolutely --
"Absolutely -- II understand
understand it's
it's not
not public.
public. Same
Same to
to you
you
15
15 and your
and your family."
family."
16
16 Do you
Do you want
want me
me to
to keep
keep going?
going?
17
17 ©.
Q. sure. Just
Sure. Just finish
finish it
it out.
out.
18
18 A.
A. Okay. Then
Okay. Then he
he sends
sends me another text
me another text that
that says,
says,
19
19 “Jim, last
"Jim, last Monday
Monday II sent
sent aa detailed Twitter org
detailed Twitter org chart
chart to
to you
you
20
20 at Jimbaker123@yahoo,
at Jimbakerl23eyahoo, and
and tonight
tonight II sent
sent an
an updated
updated version.
version.
21
21 Is that
Is that an
an old
old or
or current
current email
email for
for you,
you, and
and should
should II send
send
22
22 it elsewhere?
it elsewhere? Good
Good luck
luck tomorrow."
tomorrow."
23
23 ©.
Q. Okay. And
Okay. And then
then finally?
finally?
24
24 A.
A. Oh sorry,
Oh sorry, and
and II respond,
respond, "Hey,
"Hey, I'm
I'm so
so sorry.
sorry. II
25
25 had aa rough
had rough week
week last
last week
week and
and I'm
I'm still
still digging
digging out.
out.
1013
1013
1
1 Thanks for
Thanks for thinking
thinking of
of me.
me. II appreciate
appreciate it.
it. Let's talk
Let's talk
2
2 soon.
soon. Best, Jim."
Best, Jim."
3
3 ©.
Q. All right.
All right. SoSo what
what was
was going
going on
on here,
here, generally
generally
4
4 speaking?
speaking?
5
5 A.
A. He was
He was congratulating
congratulating me for getting
me for getting my job at
my job at
6
6 Twitter.
Twitter.
7
7 ©.
Q. And what,
And what, if
if any,
any, connection
connection did
did Mr. Sussmann have
Mr. Sussmann have
8
8 to Twitter?
to Twitter?
9
9 A.
A. He --
He -- it's
it's aa matter of public
matter of public record
record that
that he
he had
had
10
10 represented Twitter
represented Twitter on
on various
various matters.
matters. AndAnd Perkins
Perkins Coie
Coie --
--
n
11 and Perkins
and Perkins Coie
Coie continues
continues toto represent
represent Twitter
Twitter on
on various
various
12 || matters
12 that are
matters that are under
under my supervision.
my supervision.
13
13 ©.
Q. Mr. Baker,
Mr. Baker, II want to go
want to back to
go back to your
your September
September
14
14 19th, 2016
19th, 2016 meeting
meeting with Mr. Sussmann
with Mr. Sussmann and
and ask
ask you,
you, if
if you
you
15
15 knew that
knew that Mr.
Mr. Sussmann
Sussmann were at that
were at that meeting
meeting for
for aa client,
client,
16
16 would that
would that have
have mattered to you?
mattered to you?
17
17 A.
A. ves.
Yes.
18
18 Q.
Q. why?
Why?
19
19 A.
A. Well, it
Well, it --
-- multiple
multiple --
-- II think
think there's
there's multiple
multiple
20
20 dimensions to
dimensions to this.
this. SoSo one
one would
would be,
be, with
with respect
respect toto the
the
21
21 logistics of
logistics of the
the meeting,
meeting, like
like was
was II going
going --
-- would
would II meet
meet
22
22 with Michael
with Michael alone?
alone? Would
Would II meet
meet with
with him
him with somebody
with somebody
23
23 else? Would
else? Would II not
not meet with him
meet with him at
at all,
all, depending
depending onon who
who
24
24 the client
the client was?
was?
25
25 It would
It would make
make me think about
me think about the
the --
-- how
how II would
would
1014
1014
1
1 assess the
assess the reliability
reliability of
of the
the information
information that
that he
he was
was
2
2 conveying, depending
conveying, depending --
-- the
the identity
identity of
of the
the client
client might
might
3
3 impact my
impact assessment of
my assessment of that.
that.
4
4 It might
It might impact
impact how
how II thought
thought about
about whether
whether and
and
5
5 how we
how we should
should prioritize
prioritize the
the work
work on
on the
the information
information that
that he
he
6
6 gave us.
gave us. It would
It would cause
cause me
me to
to think
think deeply
deeply about
about that.
that. And
And
7
7 then it
then it would
would also,
also, II think,
think, make
make me
me think
think about
about the
the extent
extent
8
8 to which
to which II needed
needed to
to have
have my
my team
team of
of lawyers
lawyers conduct
conduct aa legal
legal
9
9 review of
review of the
the material
material that
that was
was being
being presented
presented to
to us.
us.
10
10 In other
In other words, I was
words, I was willing
willing to
to meet with Michael
meet with Michael
n
11 alone because
alone because II had
had high
high confidence
confidence in
in him
him and
and trust.
trust. And
And
12
12 that might
that might have
have --
-- II think
think II would
would have
have made
made aa different
different
13
13 decision and
decision and aa different assessment if
different assessment if he
he had
had said
said that
that hehe
14
14 was appearing
was appearing onon behalf
behalf of
of aa client.
client.
15
15 ©.
Q. So let's
So let's break that down
break that down aa little
little bit,
bit, Mr.
Mr. Baker.
Baker.
16
16 If Mr.
If Sussmann had
Mr. Sussmann had texted
texted you
you and
and said
said he
he wanted to come
wanted to come
17 || meet
17 you for
meet you for some
some work
work he
he was
was doing
doing on
on behalf of the
behalf of the Clinton
Clinton
18
18 campaign, would
campaign, would you
you have
have taken
taken the
the meeting?
meeting?
19
19 A.
A. I don't
I don't think
think II would
would have.
have.
20
20 0.
Q. Why?
Why?
21
21 A.
A. Well, because
Well, the Clinton
because the Clinton campaign
campaign ---- well,
well, former
former
22
22 Secretary of
Secretary of State
State Clinton had been
Clinton had under investigation
been under investigation by by
23
23 the FBI
the FBI with
with respect
respect to
to her
her emails
emails for
for aa long
long period
period of
of
24
24 time. And
time. And by that point
by that in time,
point in time, in
in September,
September, we
we had
had not
not
25
25 technically closed
technically closed the
the investigation,
investigation, butbut we
we had
had completed
completed
1015
1015
1
1 our work
our work as
as we
we had
had announced
announced publicly,
publicly, Director
Director Comey
Comey
2
2 announced publicly.
announced publicly.
3
3 But there
But there was
was still
still aa team
team of
of agents
agents that
that were
were
4
4 working on
working on the
the matter.
matter. The matter,
The to my
matter, to recollection, was
my recollection, was
5
5 still open
still open and,
and, as
as everybody knows, we
everybody knows, we eventually
eventually did
did reopen
reopen
6
6 the case.
the case. So II think
So think II would
would have
have said,
said, II think
think you
you need
need to
to
7
7 || meet with --
meet with -- first
first of
of all,
all, you
you shouldn't
shouldn't meet
meet with
with me.
me. YouYou
8
8 should --
should -- if
if you
you have
have information
information you
you want
want to
to bring
bring us,
us, you
you
9
9 should meet
should with the
meet with the case
case agents
agents associated
associated with
with the
the Hillary
Hillary
10
10 Clinton email
Clinton email investigation,
investigation, referred
referred toto as
as Midyear Exam.
Midyear Exam.
n
11 So II think
So think you
you should
should meet
meet with the Midyear-Exam
with the folks. If
Midyear-Exam folks. If
12
12 you're meeting
you're on behalf
meeting on behalf of
of Clinton,
Clinton, II don't
don't think
think you
you
13
13 should come
should come to
to see
see me.
me.
14
14 ©.
Q. If you
If you had
had learned
learned or
or known
known that
that Mr. Sussmann was
Mr. Sussmann was
15
15 coming in
coming in for
for aa client
client with business interests,
with business interests, would
would you
you
16
16 have taken
have taken the
the meeting?
meeting?
17
17 A.
A. I might
I have taken
might have taken the
the meeting.
meeting. First
First of
of all,
all, II
18
18 would have
would have wanted
wanted toto know
know what
what he
he --
-- who
who are
are you
you talking
talking
19
19 about? What
about? does that
What does that mean?
mean? I I would
would have
have wanted
wanted toto know
know
20 || more
20 about that.
more about that. And
And then,
then, depending
depending upon
upon the
the nature
nature ofof
21
21 that, II might
that, have decided
might have not to
decided not to have
have the
the meeting
meeting atat all
all or
or
22
22 II think
think II would
would have
have decided
decided to
to have
have others
others in
in the
the meeting
meeting
23
23 with me,
with me, depending
depending upon
upon what
what part
part of
of the
the Office
Office of
of General
General
24
24 Counsel, for
Counsel, for example,
example, might
might be
be working in the
working in the area
area related
related
25
25 to the
to the company
company in
in particular.
particular.
1016
1016
1
1 If II could
If could just
just back
back up
up on
on both
both of
of these.
these. Had
Had
2
2 there been
there been any
any reference
reference to,
to, We're
We're coming
coming in
in and
and talking
talking to
to
3
3 you about
you about aa thing
thing related
related to
to Russia,
Russia, and
and if
if he
he said
said Russia
Russia
4
4 and Trump,
and Trump, then
then II certainly
certainly would
would have
have referred
referred this
this to
to what
what
5
5 we called
we called the
the Crossfire
Crossfire Hurricane
Hurricane team.
team.
6
6 Crossfire Hurricane
Crossfire Hurricane was
was the
the code
code name
name for
for the
the
7
7 FBI's investigation
FBI's investigation of
of the
the Trump/Russia
Trump/Russia matter.
matter. So if
So if II had
had
8
8 known anything
known anything of
of that,
that, II would
would have
have said,
said, No.
No. Wait.
Wait. You
You
9
9 need to
need to meet with the
meet with the Crossfire
Crossfire Hurricane
Hurricane team
team and
and not
not with
with
10
10 | me.
me.
n
11 ©.
Q. And would
And would it
it have
have mattered
mattered toto you
you if
if you
you learned
learned
12
12 that he
that he was
was coming
coming inin --
-- would
would it
it have
have mattered to you
mattered to you to
to
13
13 learn that
learn that he
he was
was coming
coming in
in on
on behalf of Rodney
behalf of Rodney Joffe?
Joffe?
14
14 A.
A. same answer,
Same answer, II think,
think, as
as aa moment
moment ago.
ago. ByBy that
that
15
15 point in
point in time
time --
-- well,
well, if
if II had
had understood
understood Mr. Joffe's
Mr. Joffe's
16
16 connection to
connection to Neustar,
Neustar, and
and if
if Mr.
Mr. Joffe
Joffe was
was coming
coming in
in
17
17 related to
related to Neustar, then II would
Neustar, then have wanted
would have wanted to
to have
have aa team
team
18
18 of my
of attorneys with
my attorneys with me
me to
to make sure that
make sure that we
we understood
understood
19
19 exactly what's
exactly what's being
being presented
presented toto us,
us, because
because that
that would
would
20
20 have changed
have changed ---- with
with all
all of
of these
these scenarios,
scenarios, itit would
would have
have
21
21 changed my
changed assessment of
my assessment of the
the logistics
logistics ofof the
the meeting
meeting and
and
22
22 then how
then how II was thinking about
was thinking about who
who was
was bringing
bringing this
this
23
23 information to
information to me.
me.
24
24 ©.
Q. How common
How common or
or uncommon
uncommon is
is it
it for
for the
the general
general
25
25 counsel to
counsel to receive
receive evidence directly? Is
evidence directly? Is that
that something
something youyou
1017
1017
1
1 did often?
did often?
2
2 A.
A. That's not
That's not common,
common, no.
no. As II mentioned
As earlier,
mentioned earlier,
3
3 no.
no.
4
4 ©.
Q. When you
When you said
said you
you might have had
might have had others
others join
join you
you
5
5 in the
in the meeting, would it
meeting, would it have
have been
been just
just lawyers
lawyers or
or might
might
6
6 have you
have you included
included non-lawyers
non-lawyers as as well?
well?
7
7 A.
A. I might
I have included
might have included agents.
agents. II mean -- again,
mean -- again, if if
8
8 he was
he coming in
was coming in on
on behalf
behalf of
of aa client,
client, II think
think initially
initially II
9
9 would have
would have asked
asked more
more questions
questions about
about ---- What
What is
is this
this all
all
10
10 about? What's
about? What's going on? Why
going on? Why dodo you
you want
want to
to meet
meet with
with me?
me?
n
11 Who else should
Who else should II bring
bring with
with me?
me? Should
Should II bring agents?
bring agents?
12
12 Should II bring
Should bring other
other lawyers?
lawyers? Like
Like --
-- just,
just, What
What is
is the
the
13
13 nature and
nature and scope
scope of
of what
what it
it is
is you're
you're talking
talking about?
about?
14
14 ©.
Q. And when
And when you
you testified
testified that
that you
you might,
might, II think,
think,
15
15 conduct aa legal
conduct legal review
review or
or examine
examine legal
legal issues,
issues, what
what sorts
sorts
16
16 of legal
of legal issues
issues did
did you
you have
have in
in mind?
mind?
17
17 A.
A. What is
What is this
this information
information that
that you're
you're bringing
bringing me?
me?
18
18 So I'm
So I'm not
not sure
sure that
that we
we would
would have
have done
done that
that before
before the
the
19 || meeting,
19 but at
meeting, but at some
some point
point in
in time,
time, depending
depending upon
upon who this
who this
20
20 client was,
client like, there
was, like, there might
might bebe aa whole range of
whole range of legal
legal
21
21 issues associated
issues associated with
with this
this type
type ofof data.
data. And
And by "this type
by "this type
22
22 of data,"
of data," II mean communications-related data.
mean communications-related data.
23
23 That kind
That kind of
of data is protected
data is under aa variety
protected under variety ----
24
24 excuse me
excuse -- under
me -- under aa variety
variety of
of laws
laws in
in the
the United
United States
States
25
25 that, in
that, in some
some cases,
cases, make
make it
it aa crime
crime to
to engage
engage in
in that
that type
type
1018
1018
1
1 || of activity.
of activity. and I1 would
And would have
have wanted to make
wanted to make sure
sure that
that my
my
22 [| 1awyers had
lawyers had aa chance
chance to
to think
think through
through that
that data.
data. Where did
Where did
33 || it come
it come from?
from? under what
Under what authority
authority was
was it
it obtained?
obtained? Is it
Is it
44 [| 1aweur for
lawful for the
the FBI
Fer to
to receive
receive this
this information?
information?
55 And II think
And think we
we would
would have
have done
done aa whole legal
whole legal
66 || anaiysis of
analysis of that
tnat before
before we
we would nave let
would have let that
that information
information
77 || come into
come into the
the FBI's
FBI's files,
files, to
to have
have our
our investigators
investigators
88 || votentiaiiy contaminated
potentially contaminated with
with information
information that
that might be
might be
99 || problematic in
problematic in some
some way.
way. 1 would
I would have
have raised
raised aa lot
lot of
of
10 [|
10 questions.
questions.
un
11 Look, lawyers
Look, lawyers are
are slow
slow sometimes.
sometimes. Right?
Right? So that
So that
12 ||
12 cakes time.
takes time. so the
So the lawyers
lawyers would
would have
have delayed
delayed the
the matter,
matter, II
13 |
13 enink.
think.
14
14 Q.
Q. And, Mr.
And, Baker, is
Mr. Baker, is it
it fair
fair to
to say,
say, though,
though, that
that in
in
15 ||
15 this case,
this case, you
you had
had no
no affirmative
affirmative evidence
evidence oror indication
indication
16 |
16 that the
that the data
data you
you were
were presented was illegally
presented was illegally obtained
obtained or
or
17 ||
17 anything? You're
anything? You're just
just saying
saying aa legal
legal issue
issue you
you might think
might think
18 [|
18 avoucz
about?
19
19 A.
A. No, my
No, my understanding
understanding ---- yes
yes --
-- well,
well, let
let me say
me say
20 [[
20 this: The
this: The way
way II thought
thought about
about it
it was
was Michael
Michael was
was bringing
bringing
21 ||
21 me this information
me this information that
that came
came from
from cyber
cyber experts.
experts. SoSo II
22 ||
22 assumed, perhaps
assumed, perhaps incorrectly,
incorrectly, but
but II assumed
assumed at
at the
the time
time that
that
23 ||
23 michael thought it
Michael thought it was lawful to
was lawful to give
give this
this to
to me
me and
and that
that
24 ||
24 these cyber
these cyber researchers,
researchers, whoever
whoever they
they were,
were, just
just accessed
accessed
25
25 [this as
this as part
part of
of what
what anybody
anybody could
could access
access on
on the
the internet.
internet.
1019
1019
1
1 || ana
And soso therefore
therefore I1 really
really didn't
didn't have
have cause
cause to
to think
think that
that
22 [| there would
there would bebe substantial
substantial legal
legal issues
issues associated
associated with
with
33 [[ ena.
that.
41 You know,
You know, II am
am an
an expert
expert on
on surveillance
surveillance law.
law. So So
55 || I1 am
am always
always looking
100king out
out for
for these
these kinds
kinds of
of questions.
questions. So, so,
66 || vean, I1 presumed
yeah, presumed that
that it
it was
was information
information that
that was
was lawfully
lawfully
77 || obtained that
obtained that didn't
didn't have
have all
all these
these various
various legal
legal issues
issues
88 [| associated witn
associated it.
with it.
99 ©.
Q. Mr. Baker,
Mr. Baker, we've
we've talked
talked before
before about
about the
the concept
concept
10 [|
10 of aa formal
of formal confidential
confidential human
human source
source of
of the
the FBI?
FBI?
un
11 A.
A. Yes.
Yes.
12
12 ©.
Q. If you
If you were
were to
to learn
learn or
or think
think that
that the
the person
person who
who
13 ||
13 was either
was either bringing you the
bringing you the information
information oror the
the person they
person they
14 ||
14 were acting
were acting onon venalf of was
behalf of was an
an active
active confidential
confidential human
human
15 ||
15 source, would
source, would that
that matter in this
matter in this calculus?
calculus?
16
16 A.
A. Very much
Very so.
much so.
17
17 9.
Q. Why is
Why is that?
that?
18
18 A.
A. well, because
Well, because the
the --
-- the
the way it works
way it works is,
is, if
if you
you
19 ||
19 nave aa confidential
have confidential human
human source,
source, typically
typically speaking,
speaking, that
that
20 ||
20 source will
source nave what
will have what we
we refer
refer to
to as
as aa handler.
handler. So so an
an
21 ||
21 agent, sometimes
agent, sometimes multiple
multiple agents
agents but
but usually
usually an
an agent,
agent, anan
22 [[
22 ©8T agent;
FBI agent; and
and that
that agent
agent will
will have
have aa relationship
relationship with that
with that
23 ||
23 source that
source that is
is long-term
long-term inin nature.
nature.
24
24 So it's
So it's that
that person's job, that
person's job, that handling
handling agent,
agent, toto
25 ||
25 dear with
deal with the
the confidential
confidential human
human source.
source. And
and we
we do
do this
this inin
1020
1020
1
1 part to
part to make sure the
make sure the source
source is
is being
being dealt
dealt with
with properly,
properly,
2
2 that we
that we are
are following
following the
the rules
rules and
and so
so on.
on. But also
But also to
to make
make
3
3 sure that
sure that the
the source
source is
is protected
protected and
and secure
secure from
from
4
4 disclosure.
disclosure.
5
5 And so
And so issues
issues related
related to
to aa CHS,
CHS, confidential
confidential human
human
6
6 source, are
source, are ones
ones that
that should
should be,
be, in
in my
my view, dealt with
view, dealt by
with by
7
7 the handler,
the handler, the
the field
field office,
office, that
that is
is where the handler
where the handler
8
8 works or
works or the
the headquarters
headquarters component.
component. And II also
And also don't
don't
9
9 really want
really to know,
want to know, if
if II don't
don't have
have to
to know,
know, the
the identity
identity
10
10 of aa confidential
of confidential human
human source.
source.
n
11 For the
For the same
same reason,
reason, II don't
don't want to be
want to be
12
12 responsible for
responsible for that
that person's
person's security,
security, unless
unless II absolutely
absolutely
13
13 have to
have to be.
be. II think
think II would have referred
would have referred all
all of
of that
that toto
14
14 the handler
the handler and
and the
the field
field office
office and
and let
let them
them deal
deal with it,
with it,
15
15 and then
and then have
have the
the information
information come
come up
up through
through that
that chain
chain to to
16 || me
16 and others
me and others at
at the
the FBI,
FBI, if
if that's
that's what
what was
was necessary.
necessary. All All
17
17 of which,
of again, takes
which, again, takes more time.
more time.
18
18 Q.
Q. Mr. Baker,
Mr. Baker, to
to what
what extent,
extent, if
if at
at all,
all, would
would aa
19
19 political affiliation
political affiliation oror motivation
motivation affect
affect the
the FBI's
FBI's
20
20 analysis or
analysis or investigation
investigation ofof this
this information?
information?
21
21 A.
A. Well, as
Well, as II said
said in
in the
the excerpt
excerpt of
of the
the testimony
testimony
22
22 that we
that we read,
read, if
if anybody
anybody ofof any
any stripe
stripe comes
comes to
to the
the FBI
FBI and
and
23
23 needs help
needs help or
or sees
sees aa threat
threat to
to the
the country
country or
or sees
sees crime
crime
24
24 being committed,
being committed, then
then we're
we're going
going to
to take
take that
that information
information
25
25 and we're
and we're going
going to
to deal with it.
deal with it.
1021
1021
1
1 But at
But at the
the same
same time,
time, when
when you're
you're receiving
receiving
2
2 information --
information -- let
let me be more
me be more specific.
specific. When the
When the FBI
FBI is
is
3
3 receiving information,
receiving information, of
of course
course we
we look
look at
at the
the identity
identity of
of
4
4 the source
the source of
of the
the information
information and
and make
make an
an assessment
assessment of
of the
the
5
5 reliability or
reliability or credibility
credibility of
of that
that person.
person.
6
6 And so
And so in
in this
this case,
case, for
for example,
example, if
if the
the opponent
opponent
7
7 in the
in the presidential election of
presidential election of Donald
Donald Trump
Trump brought
brought us
us
8
8 information related
information related to
to Donald
Donald Trump,
Trump, we
we would
would have
have looked
looked at
at
9
9 that very,
that very, very
very carefully.
carefully.
10
10 It's not
It's not to
to say
say we
we wouldn't
wouldn't have
have done anything,
done anything,
n
11 but we
but we would have looked
would have looked at
at it
it differently.
differently. We would
We would have,
have,
12
12 II think,
think, taken
taken more time with
more time with it.
it. We would have
We would have subjected
subjected
13
13 it to
it to additional
additional scrutiny.
scrutiny. Yeah.
Yeah.
14
14 We just
We just --
-- it
it would
would have
have raised
raised very
very serious
serious
15
15 questions, certainly
questions, certainly in
in my
my mind, about the
mind, about the credibility
credibility ofof
16
16 the information
the information ---- the
the credibility
credibility ofof the
the source,
source, the
the
17
17 veracity of
veracity of the
the information
information and
and heightened
heightened -- -- heightened
heightened in in
18 || my
18 my mind
mind aa substantial
substantial concern
concern about
about whether
whether wewe were going to
were going to
19
19 be played
be or pulled
played or pulled into
into the
the politics
politics ofof this.
this.
20
20 It also
It also would
would have
have raised
raised --
-- II mean,
mean, the
the whole
whole
21
21 thing that
thing that we talked about
we talked about earlier
earlier about
about the
the press,
press, that
that
22
22 would have
would have alarmed
alarmed me considerably if
me considerably if II had
had known
known this
this was
was a a
23
23 political candidate
political candidate because,
because, as
as II said
said earlier,
earlier, we
we were
were
24
24 aware of
aware of and
and wary
wary of
of being
being played,
played, basically, and having
basically, and having thethe
25
25 fact of
fact of our
our investigation
investigation bebe "the
“the thing"
thing" that
that enables
enables the
the
1022
1022
1
1 press to
press to report
report on
on something
something that
that is
is otherwise
otherwise flawed
flawed or
or
2
2 incomplete or
incomplete or insufficient.
insufficient. Right?
Right?
3
3 That the
That the press -- in
press -- in my estimation, the
my estimation, the press
press
4
4 doesn't want
doesn't want to
to report
report something
something that's
that's --
-- I'll
I'll use
use the
the term
term
5
5 "a nothing
"a nothing burger".
burger". Right?
Right? They don't
They don't want
want to
to report
report about
about
6
6 that.
that. But they
But they might report about,
might report about, as
as II said
said earlier,
earlier, that
that
7
7 the FBI
the FBI is
is investigating
investigating the
the "nothing
"nothing burger".
burger". And so II
And so
8
8 would have
would have been very wary
been very wary about
about us
us being sucked into
being sucked into that
that
9
9 type of
type of an
an effort
effort with
with respect
respect toto aa variety
variety of
of the
the different
different
10
10 scenarios that
scenarios that you
you were talking about
were talking about there.
there.
n
11 Q.
Q. Mr. Baker,
Mr. Baker, are
are you
you familiar
familiar with
with the
the three-tiered
three-tiered
12
12 investigation, framework
investigation, framework ofof an
an assessment,
assessment, aa preliminary
preliminary
13
13 investigation and
investigation and aa full
full investigation?
investigation?
14
14 A.
A. ves.
Yes.
15
15 ©.
Q. To what
To what extent,
extent, if
if at
at all,
all, would
would these
these factors
factors
16
16 we've been
we've been discussing,
discussing, the
the identity
identity ofof aa client
client or
or the
the
17
17 existence of
existence of aa client,
client, affect
affect any
any decisions
decisions made as to
made as to which
which
18
18 route to
route to pursue
pursue there?
there?
19
19 A.
A. What you
What you describe -- basically,
describe -- those are
basically, those are terms
terms
20
20 that come
that come from
from the
the Attorney General Guidelines,
Attorney General Guidelines, which
which are
are
21
21 the guidelines
the guidelines promulgated
promulgated by the attorney
by the attorney general that
general that
22
22 tells the
tells the FBI
FBI what
what you
you can
can and
and can't
can't --
-- they
they tell
tell the
the FBI
FBI
23
23 what you
what you can
can and
and cannot
cannot investigate
investigate and
and how.
how. Like
Like what
what
24
24 tools you
tools you can
can use
use depending
depending upon
upon the
the amount
amount of
of factual
factual
25
25 information, factual
information, factual predication
predication that
that you
you have.
have. SoSo we
we have
have
1023
1023
1
1 non-predicated investigations,
non-predicated investigations, like
like an
an assessment,
assessment, or
or
2
2 predicated investigations,
predicated investigations, like
like aa preliminary
preliminary investigation
investigation
3
3 or aa full
or full investigation.
investigation.
4
4 So in
So in order
order to
to use
use more
more of
of your
your tools,
tools, you
you have
have to
to
5
5 have more
have more facts,
facts, and
and facts
facts that
that are
are reliable,
reliable, credible,
credible, that
that
6
6 provide you
provide you with
with aa --
-- for
for aa full
full investigation
investigation --
-- an
an
7
7 articulable, factual
articulable, factual basis
basis that
that reasonably
reasonably indicates
indicates that
that
8
8 there's aa crime
there's crime involved,
involved, federal
federal crime,
crime, or
or aa national
national
9
9 security threat
security threat or
or aa need
need to
to collect
collect foreign
foreign intelligence
intelligence
10
10 information.
information.
n
11 So the
So the greater
greater the
the level
level of
of intrusion,
intrusion, the
the more
more
12
12 intrusive the
intrusive the tools
tools are
are that
that you
you use,
use, you
you need
need more facts to
more facts to
13
13 justify that.
justify that. And the credibility
And the credibility ofof the
the information
information weighs
weighs
14
14 heavily into
heavily into the
the Bureau's
Bureau's assessment
assessment of
of those
those facts.
facts.
15
15 ©.
Q. Could things
Could things like
like whether
whether somebody
somebody is
is coming
coming in
in on
on
16
16 their own
their own or
or for
for aa client,
client, or
or whether
whether they
they are
are coming
coming in
in for
for
17
17 a political
a political oror business interest, could
business interest, could those
those things
things affect
affect
18
18 the specific
the specific decisions
decisions that
that have
have to
to be
be made under that
made under that
19
19 rubric?
rubric?
20
20 A.
A. Yes.
Yes.
21
21 ©.
Q. And how?
And how?
22
22 A.
A. Well, it's
Well, it's the
the same
same thing.
thing. Right?
Right? DoDo we
we have
have --
--
23
23 for an
for an assessment,
assessment, you
you need
need aa lawful
lawful purpose,
purpose, meaning
meaning
24
24 investigating crime
investigating crime or
or investigating
investigating aa national
national security
security
25
25 threat or
threat or trying
trying toto collect
collect foreign
foreign intelligence.
intelligence. YouYou don't
don't
1024
1024
1
1 necessarily have
necessarily have to
to have
have predication
predication from
from someone
someone else
else in
in
2
2 order to
order to do
do that.
that. But for
But for aa predicated
predicated investigation,
investigation,
3
3 again, aa preliminary
again, preliminary investigation
investigation or
or aa full
full investigation,
investigation,
4
4 you have
you have to
to have
have some
some facts.
facts.
5
5 For aa preliminary
For preliminary investigation,
investigation, you
you only
only need
need
6
6 information or
information or an
an allegation.
allegation. So that
So that would be enough.
would be enough.
7
7 Something comes
Something comes in,
in, you
you just
just have
have information
information and
and you
you can
can
8
8 open aa preliminary
open investigation.
preliminary investigation. But in
But in order
order to
to use
use all
all
9
9 of the
of the tools
tools that
that the
the FBI
FBI has,
has, all
all of
of the
the investigative
investigative
10
10 tools, you
tools, you need
need to
to have
have aa full
full investigation.
investigation.
n
11 And for
And for that,
that, again,
again, you
you need
need an
an articulable
articulable
12
12 factual basis
factual basis that
that reasonably
reasonably indicates
indicates that
that there
there is
is aa
13
13 crime, aa national
crime, national security
security threat
threat or
or you
you need
need to
to collect
collect
14
14 foreign intelligence.
foreign intelligence. So that's
So that's the
the credibility
credibility of
of the
the
15
15 person or
person or persons
persons or
or whomever
whomever is
is giving
giving it
it to
to you
you is
is highly
highly
16
16 relevant to
relevant to that
that inquiry.
inquiry.
17
17 Does that
Does that answer
answer your
your question?
question? I'm sorry.
I'm sorry.
18
18 ©.
Q. I think
I think so.
so.
19
19 So if
So if something
something comes
comes in
in for,
for, as
as you
you said,
said, the
the
20
20 political opponent
political opponent of
of the
the subject
subject of
of the
the allegations,
allegations, would
would
21
21 that increase
that increase or
or decrease
decrease the
the likelihood
likelihood that
that aa full
full
22
22 investigation would
investigation would be
be open
open or
or the
the same?
same?
23
23 A.
A. It depends
It depends what
what the
the allegation
allegation is.
is. You
You know,
know, if
if
24
24 it's aa murder
it's or something
murder or something like
like that
that and
and there's
there's aa dead
dead
25
25 body, okay,
body, okay, well,
well, that's
that's one
one type
type of
of assessment.
assessment. IfIf there's
there's
1025
1025
1
1 || something like
something 1ixe --
== you
you know,
xnow, if
if somebody
somebody is
is alleging
alleging
2 ||
2 poritical corruption,
political corruption, that
that there
there had
had been
been aa payoff.
payoff. Okay?
Okay?
3
3 What's the
What's the information?
information? Do you
Do you have
have aa videotape
videotape
4 [|
4 of somebody
of somebody exchanging
exchanging money or something
money or something like
like that,
that, or
or if
if
5 ||
5 vou are
you are alleging
alleging something
something like
like this,
tnis, some
some type
type of
of allegedly
allegedly
6 ||
6 nefarious cyber
nefarious cyver connection,
connection, the
the credibility
credibility is
is going
going to
to be
be
7 ||
7 -- the
-- tne credibility
creavitity of
of the
the person
person providing
providing the
the information
information
8 ||
8 coura be
could be instrumental
instrumental in
in assessing
assessing the
the reliability
reliability of
of the
the
3 [|
9 information.
information.
10
10 ©.
Q. Mr. Baker,
Mr. Baker, when
when Mr.
Mr. Sussmann
Sussmann came
came in
in to
to you
you and
and
11 [|
11 naa the
had the meeting
meeting inin your
your office,
office, did
did you
you suspect
suspect that
that he
he
12 ||
12 might ve working
might be working for
for aa political client?
political client?
13
13 A
A. No.
No.
14
14 Q
Q. wny?
Why?
15
15 A.
A. Because he
Because he said
said he
he was
was coming
coming there
there on
on his
his own
own to
to
16 ||
16 neip the
help the Bureau
Bureau and
and not
not on
on behalf of any
behalf of any political
political client
client --
--
17 ||
17 not on
not on behalf
behalf ofof any
any client.
client. SoSo II knew
knew Michael.
michael. ITI trusted
trusted
18 [|
18 michael.
Michael. I I believed
believed Michael
Michael and
and went
went forward
forward onon that
that basis.
basis.
13
19 Q.
Q. Thank you
Thank you very
very much,
much, Mr. Baker.
Mr. Baker.
20
20 CROSS-EXAMINATION OF
CROSS-EXAMINATION OF JAMES
JAMES BAKER
BAKER
21 ||
21 BY
BY wr.
MR. semxowrrz:
BERKOWITZ:
22
22 ©.
Q. I know
I know we've
we've got
got aa lot
lot of
of ground
ground to
to cover.
cover. II ran
ran
23
23 [this morning,
this morning, so so I'm
I'm in
in good
good shape
shape as
as well.
well.
24
24 To get
To get through
through this,
this, we're going to
we're going to go
go as
as quickly
quickly
25 ||
25 as we
as can, but
we can, but it's
it's going
going to
to take
take some
some time.
time.
1026
1026
1
1 A.
A. Tran
I too, so
ran too, so IIam all set.
am all set.
2
2 ©.
Q. AIL right.
All right. Let's start
Let's start eating.
eating.
3
3 We've never
We've never met
met before,
before, have
have we, sir?
we, sir?
a
4 A.
A. That's correct.
That's correct.
5
5 ©.
Q. And do
And do you
you remember
remember how
how many
many times
times you've
you've either
either
6
6 || met or been
met or interviewea by
been interviewed by the
the prosecution team?
prosecution team?
7
7 A.
A. I do
I do not
not remember.
remember.
8
8 Q.
Q. If II told
If told you
you it
it was over ten,
was over ten, would
would that
that surprise
surprise
3
9 [[ vour
you?
10
10 A.
A. Yo.
No.
un
11 9.
Q. okay.
Okay.
12
12 A.
A. I don't
I don't know
know what the accurate
what the accurate number
number is
is so
so --
--
13
13 9.
Q. Well, let's
Well, let's test
test your
your memory
memory aa little
little bit.
bit. Okay?
Okay?
14
14 A.
A. oxay.
Okay.
1s
15 Q.
Q. How many
How many times
times in
in the
the last
last month
month have
have you
you met with
met with
16 |
16 the prosecution
the prosecution team?
team?
17
17 A.
A. In the
In the last
last month,
month, II think
think twice.
twice.
18
18 ©.
Q. okay. That
Okay. That was
was May
May 6th.
6th. Correct?
Correct?
19
19 A.
A. I don't
I don't remember
remember the
the exact
exact dates,
dates, but
but I'll
I'll take
take
20 ||
20 your word
your wora for
for it.
it.
21
21 Q.
Q. When was
When was most recent?
most recent?
22
22 A.
A. Two and
Two and aa half
half weeks
weeks ago
ago or
or so.
so.
23
23 ©.
Q. All right.
All right. And
And you
you testified
testified yesterday
yesterday that
that this
this
24 [|
24 gentleman over
gentleman over here,
here, Mr.
Mr. Sussmann,
Sussmann, is
is your
your friend?
friend?
25
25 A.
A. ves.
Yes.
1027
1027
1
1 Q.
Q. And you
And you weren't
weren't here
here to
to do
do him
him any
any damage.
damage. You
You
2
2 were just
were just here
here to
to answer
answer questions.
questions. Right?
Right?
3
3 A.
A. I don't
I don't think
think II said
said the
the first
first part
part of
of it.
it. II
4
4 think II said
think said II am
am here
here to
to answer
answer the
the questions
questions truthfully.
truthfully.
5
5 @.
Q. It's your
It's your investigation,
investigation, you
you said.
said. I'm
I'm just
just here
here
6
6 to answer
to answer the
the questions.
questions. Right?
Right? It's
It's Mr. DeFilippis'
Mr. DeFilippis'
7
7 investigation. You're
investigation. You're just
just here
here to
to answer
answer the
the questions.
questions.
8
8 Is what
Is what you
you said?
said?
9
9 A.
A. I'm here
I'm here to
to answer
answer the
the questions.
questions.
10
10 Q.
Q. Okay. And
Okay. And you
you know
know that
that we, on behalf
we, on behalf of
of
1
11 Mr. Sussmann, requested
Mr. Sussmann, requested to
to meet with you,
meet with you, don't
don't you,
you, sir?
sir?
12
12 A.
A. I understand
I understand that.
that. II delegated
delegated all
all decisions,
decisions,
13
13 with respect
with respect to
to meeting with you,
meeting with you, to
to my
my attorney.
attorney.
14
14 @.
Q. okay.
Okay.
15
15 MR. BERKOWITZ: Let's
MR. BERKOWITZ: Let's put
put up
up DX-108
DX-108 --
-- DX-808,
DX-808,
16
16 please. II move
please. this into
move this into evidence,
evidence, Your
Your Honor.
Honor.
17
17 MR. DeFILIPPIS: You
MR. DeFILIPPIS: You have
have 809.
809.
18
18 MR. BERKOWITZ: 809,
MR. BERKOWITZ: 809, thank
thank you.
you.
19
19 MR. DeFILIPPIS: No
MR. DeFILIPPIS: objection.
No objection.
20
20 THE COURT:
THE COURT: So moved.
So moved.
21
21 (Defense Exhibit
(Defense Exhibit 809
809 was
was admitted.)
admitted.)
22
22 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
23
23 Q.
Q. Let me
Let me read
read this
this to
to you,
you, sir:
sir: April
April 20th
20th of
of this
this
24
24 year, Mr.
year, Mr. Baker,
Baker, in
in care
care of
of Daniel
Daniel Levin.
Levin. IsIs that
that your
your
25
25 Lawyer?
lawyer?
1028
1028
1
1 A.
A. ves.
Yes.
2
2 ©.
Q. Is he
Is he here
here inin court
court today?
today?
3
3 A
A. No.
No.
4
4 ©.
Q. It says,
It says, "Dear
"Dear Mr.
Mr. Baker,
Baker, we
we are
are counsel
counsel to
to
5
5 || michael sussmann in
Michael Sussmann in the
the above-captioned
above-captioned matter.
matter. Wewe
6 ||
6 understand you
understand you have
nave met with the
met with the Special
Special Counsel
Counsel on
on multiple
multiple
7 [|
7 occasions to
occasions to discuss
discuss your
your recollection
recollection ofof the
the events
events atat
8 ||
8 issue in
issue in this
this case.
case. Wewe would
would very
very much appreciate the
much appreciate the same
same
9 [|
9 courtesy and
courtesy and write
write to
to request
request aa meeting
meeting with
with you
you at
at your
your
10 [|
10 convenience. We
convenience. we believe
believe such
such aa meeting would help
meeting would help
11 [|
11 wr. sussmann as
Mr. Sussmann as we
we continue
continue toto prepare his defense.
prepare his defense. We We
12 ||
12 would be
would pe pleased
pleased toto meet with you
meet with you at
at any
any time
time and
and any
any
13 ||
13 location that
location that is
is best
best for
for you.
you. Sincerely,
Sincerely, Sean
Sean Berkowitz."
Berkowitz."
14
14 Did your
Did your lawyer
lawyer show
show you
you that
that letter,
letter, sir?
sir?
15
15 A.
A. Yo.
No.
16
16 ©.
Q. Are you
Are you aware
aware of
of aa request
request to
to meet
meet with
with us?
us?
17
17 A.
A. I delegated
I delegated the
the decisions
decisions and
and the
the interactions
interactions
18 ||
18 with respect
with respect to
to meeting with you
meeting with you to
to Dan
Dan and
and let
let him
him make
make
19 |
19 those decisions
those decisions on
on my behalf.
my behalf.
20
20 Q.
Q. Did you
Did you say,
say, Hey,
Hey, I'd
I'd like
like to
to meet
meet with
with the
the
21 ||
21 defense to
defense to give
give them
them an
an equal
equal opportunity
opportunity because
because Michael
Michael isis
22 |
22 a friend?
a frien?
23
23 MR. DeFILIPPIS: Objection,
MR. DeFILIPPIS: Your Honor.
Objection, Your Honor. Calls for
Calls for
24 |
24 specuiation.
speculation.
25
25 THE COURT:
THE COURT: Sustained.
Sustained.
1029
1029
1
1 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
2
2 ©.
Q. So you
So you know
know what
what it's
it's like
like to
to be
be under
under criminal
criminal
3
3 investigation. Right?
investigation. Right?
1
4 A.
A. Yes.
Yes.
5
5 ©.
Q. You know
You know what it's like
what it's like to
to be
be under
under criminal
criminal
6
6 investigation by
investigation by this
this man?
man?
7
7 A.
A. ves.
Yes.
8
8 ©.
Q. That's Mr.
That's Mr. Durham?
Durham?
9
9 A.
A. ves.
Yes.
10
10 ©.
Q. In fact,
In fact, sir,
sir, in
in March of 2017
March of 2017 Mr.
Mr. Durham
Durham was
was
n
11 appointed by
appointed by the
the Department
Department of
of Justice
Justice to
to conduct
conduct aa criminal
criminal
12
12 investigation of
investigation of the
the unauthorized
unauthorized disclosure
disclosure ofof classified
classified
13
13 information to
information to aa reporter.
reporter. Correct?
Correct?
14
14 A.
A. I don't
I don't remember
remember exactly
exactly when he was
when he was appointed,
appointed,
15
15 but that's
but that's roughly
roughly correct
correct based on my
based on my recollection
recollection ofof the
the
16
16 timeframe.
timeframe.
17
17 ©.
Q. And you
And you were
were aa subject
subject of
of that
that investigation?
investigation?
18
18 A.
A. I was
I was never
never told
told that
that II was
was aa subject.
subject.
19
19 ©.
Q. Is it
Is it fair
fair to
to say
say that
that your
your lawyer
lawyer refused
refused to
to let
let
20
20 you answer
you answer questions
questions before
before Congress
Congress because
because you
you were
were under
under
21
21 investigation?
investigation?
22
22 A.
A. He did
He did object
object to
to certain
certain questions
questions ---- certain
certain
23
23 questions --
questions -- because
because II was under investigation.
was under investigation. That's
That's
24
24 correct.
correct.
25
25 ©.
Q. Under criminal
Under criminal investigation.
investigation. Right?
Right?
1030
1030
1
1 A.
A. It was
It was aa criminal
criminal investigation
investigation was
was my
my
2
2 || understanding, yes.
understanding, ves.
3
3 ©.
Q. And you
And you refused
refused toto answer
answer those
those questions
questions onon the
the
4
4 [| grounas that
grounds that it
it might incriminate you?
might incriminate you?
5
5 A.
A. I refused
I refused toto answer
answer those
those questions
questions onon advice
advice of
of
6
6 || counser, and
counsel, and it
it was
was aa voluntary
voluntary interview
interview so
so II could
could refuse
refuse
77 || to answer
to answer any
any questions
questions that
that II didn't
didn't want
want to
to answer.
answer.
88 ©.
Q. And the
And the investigation
investigation took
took place
place between 2017 and
between 2017 and
9s [I 2018. Correct?
2019. correct:
10
10 A.
A. say that
Say that again.
again.
un
11 ©.
Q. The investigation
The investigation took
took place
place between 2017 and
between 2017 and
12 |
12 2019. Correct?
2019. correct?
13
13 A.
A. I think
I think it
it was
was not
not closed
closed until
until 2020
2020 by
by the
the
14 |
14 vepartment.
Department.
1s
15 ©.
Q. And you
And you testified
testified that
that the
the subject
subject matter
matter of
of the
the
16 |
16 investigation --
investigation -- without
without getting
getting into
into classified
classified information
information
17 ||
17 -- was
-- was whether you had
whether you had leaked
leaked information
information toto --
-- classified
classified
18 ||
18 information to
information to aa reporter.
reporter. Correct?
correct?
19
19 A.
A. whether II used
Whether used the
the term,
term, unauthorized
unauthorized disclosure
disclosure
20 ||
20 of information,
of information, yes.
ves.
21
21 ©.
Q. If those
If those allegations
allegations had
had been charged, that
been charged, that could
could
22 |
22 have ruined
have ruined your
your career.
career. Right?
Right?
23
23 A.
A. My legal
My legal career?
career?
24
24 ©.
Q. It would
It would have
have been
been aa terrible
terrible thing.
thing. Right?
Right?
25
25 A.
A. Being prosecuted
Being prosecuted for
for aa crime
crime would have been
would have been very
very
1031
1031
1
1 terrible, yes.
terrible, yes.
2
2 ©.
Q. And, in
And, in fact,
fact, sir,
sir, in
in connection
connection with that case,
with that case,
3
3 you believed,
you believed, you
you testified
testified earlier,
earlier, that
that you
you were
were
4
4 authorized by
authorized the director
by the director toto release
release that
that information.
information.
5
5 Correct?
Correct?
6
6 A.
A. ves.
Yes.
7
7 ©.
Q. And there
And there were
were at
at least
least two
two people
people who
who didn't
didn't have
have
8
8 the same
the same recollection
recollection asas you.
you. Correct?
Correct?
9
9 A.
A. That isn't
That isn't --
-- well,
well, I'm
I'm going
going to
to be very careful
be very careful
10
10 here what
here what II say.
say. But
But two
two people
people who
who didn't
didn't recall
recall that
that --
-- II
n
11 don't know
don't know what they remember.
what they remember. II didn't
didn't speak
speak to
to them
them
12
12 directly about
directly about it.
it. II take
take that
that back.
back. II did
did on
on one
one
13
13 occasion --
occasion -- they
they didn't
didn't recall
recall that
that the
the call
call that
that happened
happened
14
14 with the
with the reporter
reporter had
had either
either taken
taken --
-- II think
think one
one witness
witness
15
15 didn't remember
didn't remember it
it even took place
even took place and
and the
the other
other one
one didn't
didn't
16
16 remember me
remember me having
having been authorized to
been authorized to make
make that
that call.
call.
17
17 ©.
Q. So at
So at least
least one
one of
of their
their recollections
recollections was
was
18
18 inconsistent with
inconsistent with yours.
yours. Right?
Right?
19
19 A.
A. Yes. Yes.
Yes. Yes.
20
20 ©.
Q. Memories are
Memories are aa difficult
difficult thing,
thing, aren't
aren't they,
they, sir?
sir?
21
21 A.
A. That's aa difficult
That's question to
difficult question to answer.
answer. That
That
22
22 depends.
depends.
23
23 Q.
Q. Well, even
Well, even today,
today, you
you testified
testified to
to some
some things
things
24
24 that were
that were different
different than
than what
what you've
you've said
said in
in the
the past.
past.
25
25 Correct? Mr.
Correct? Mr. DeFilippis
DeFilippis took
took you
you through
through those
those items.
items.
1032
1032
1
1 A.
A. The I.G.
The I.G. statement
statement was
was certainly
certainly different
different from
from
2
2 what I've
what I've testified
testified today
today and
and yesterday.
yesterday.
3
3 ©.
Q. Saying that
Saying that Mr.
Mr. Sussmann
Sussmann had
had cyber
cyber security
security
4
4 clients is
clients is inconsistent.
inconsistent. Correct?
Correct?
5
5 A.
A. It's inconsistent
It's inconsistent with
with what
what II have
have said
said today;
todays
6
6 that's right.
that's right.
7
7 ©.
Q. So we
So we are
are talking
talking about
about events
events that
that are
are from
from
8
8 September of
September of 2019
2019 --
-- 2016.
2016. Correct?
Correct?
9
9 A.
A. 2016. Correct.
2016. Correct.
10
10 ©.
Q. And although
And although II wasn't
wasn't aa math
math major, we're well
major, we're well
n
11 over five
over five years
years past
past that
that time.
time. Correct?
Correct?
12
12 A.
A. correct.
Correct.
13
13 ©.
Q. And we're
And we're going
going to
to do
do some
some exploring
exploring of
of memory
memory and
and
14
14 kind of
kind of take
take you
you through
through --
-- because
because you've
you've talked
talked about
about this
this
15
15 on aa number
on number ofof occasions.
occasions. Correct?
Correct?
16
16 A.
A. ves.
Yes.
17
17 ©.
Q. With respect
With respect to
to being
being under
under investigation,
investigation,
18 || mr.
18 Baker, you
Mr. Baker, you were under investigation
were under investigation forfor that
that leak
leak issue
issue
19
19 relative to
relative to the
the Office
Office of
of the
the Inspector
Inspector General.
General. Correct?
Correct?
20
20 There was
There was an
an administrative
administrative investigation
investigation ofof you
you also
also with
with
21
21 the OIG.
the 016.
22
22 A.
A. That's correct.
That's correct.
23
23 ©.
Q. You testified
You testified there
there in
in December
December of
of 2021?
20212
24
24 A.
A. Iwas
I interviewed there,
was interviewed there, yes.
yes.
25
25 ©.
Q. Is that
Is that still
still open,
open, sir?
sir?
1033
1033
1
1 A.
A. To my
To my understanding
understanding it
it is
is closed.
closed.
2
2 Q.
Q. And you,
And you, sir,
sir, were
were aware
aware that
that Mr.
Mr. Baker
Baker was
was --
-- II
3
3 mean, Mr.
mean, Mr. Durham
Durham was
was reappointed
reappointed as
as special
special counsel,
counsel,
4
4 correct, in
correct, in or
or around
around 2019?
2019?
5
5 A.
A. For this
For this matter?
matter?
6
6 Q.
Q. ves.
Yes.
7
7 A.
A. ves.
Yes.
8
8 Q.
Q. And when
And when that
that happened,
happened, you
you were
were concerned,
concerned, were
were
9
9 you not?
you not?
10
10 A.
A. Concerned about
Concerned about what?
what?
1
11 Q.
Q. That Mr.
That Durham might
Mr. Durham might come
come and
and investigate
investigate you
you
12
12 more?
more?
13
13 A.
A. II wasn't
wasn't concerned
concerned about
about it.
it. II expected
expected it.
it.
14
14 Q.
Q. All right.
All right. You
You expected
expected to
to be
be investigated
investigated
15
15 further by
further by Mr. Durham. Correct?
Mr. Durham. Correct?
16
16 A.
A. Correct.
Correct.
17
17 Q.
Q. Let's take
Let's take aa look
look at
at JB-LW-04,
JB-LW-04, which
which is
is aa text.
text.
18
18 Let's blow
Let's blow out
out this
this text
text from
from May
May 14th
14th from
from you
you to
to Benjamin
Benjamin
19
19 Wittes.
Wittes. And II want
And to --
want to --
20
20 A.
A. Can somebody
Can somebody blow it up?
blow it up? II can't
can't read
read it.
it.
21
21 Q.
Q. ves, we
Yes, will, sir.
we will, sir.
22
22 A.
A. Thank you.
Thank you.
23
23 Q.
Q. "It went
"It went well".
well". "It's about
"It's about the
the love
love piece."
piece."
24
24 A.
A. I'm having
I'm having aa hard
hard time
time reading
reading this.
this. Is there
Is there aa
25
25 way to
way to blow it up?
blow it up?
1034
1034
1
1 THE COURT:
THE COURT: Hold on,
Hold on, sir.
sir. We'll blow
We'll it up
blow it up for
for
2
2 you.
you.
3
3 MR. BERKOWITZ: It's
MR. BERKOWITZ: It's at
at Page
Page 44 at
at the
the middle
middle of
of
4
4 the page,
the page, Mr.
Mr. Cleave.
Cleave.
5
5 THE WITNESS:
THE WITNESS: Thank you.
Thank you.
6
6 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
7
7 Q.
Q. Do you
Do you recognize
recognize that
that text?
text?
8
8 A.
A. Okay.
Okay. II --
--
9
9 MR. BERKOWITZ: Judge,
MR. BERKOWITZ: Judge, I'd
I'd move
move this
this JB-LW-04
JB-LW-04 into
into
10
10 evidence as
evidence as Defense
Defense Exhibit
Exhibit Al0.
A10.
1
MR. DeFILIPPIS: objection, Your
No objection, Your Honor.
Honor.
12
12 THE COURT:
THE COURT: SoSo moved.
moved.
13
13 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
14
14 Q.
Q. Who is
Who is Benjamin
Benjamin Wittes?
Wittes?
15
15 A.
A. He is
He is the
the head
head of
of something
something called
called Lawfare.
Lawfare. He
He is
is
16
16 also senior
also senior fellow,
fellow, II think
think it
it is,
is, at
at the
the Brookings
Brookings
17
17 Institution. He's
Institution. He's aa friend
friend of
of mine, former boss
mine, former boss also.
also.
18
18 Q.
Q. This was
This was May of 2019?
May of 2019?
19
19 A.
A. I'msorry.
I'm sorry. I I can't
can't see
see it
it on
on the
the screen
screen now.
now.
20
20 (Brief pause.)
(Brief pause.)
21
21 Can you
Can you go
go down
down aa little
little bit just so
bit just so II can
can see
see the
the
22
22 date also?
date also?
23
23 Q.
Q. Do you
Do you see
see the
the date?
date?
24
24 A.
A. It's too
It's too small.
small. I'm
I'm sorry.
sorry. With
With my eyes, II can't
my eyes, can't
25
25 see it.
see it.
1035
1035
1
1 MR. BERKOWITZ: The
MR. BERKOWITZ: The date,
date, Mr.
Mr. Cleaves.
Cleaves.
2
2 THE WITNESS:
THE There we
WITNESS: There we go.
go. Okay.
Okay. Sorry.
Sorry. May
May
3
3 14th, 2019.
14th, 2019. Thank you.
Thank you.
4
4 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
5
5 ©.
Q. And you
And you write:
write: "It
"It went
went well. It was
well. It was about
about the
the
6
6 Love piece
Love piece which was good.
which was good. CNN
CNN Tonight
Tonight was
was okay
okay but
but didn't
didn't
7
7 cover that
cover that at
at all.
all. And now II get
And now get to
to be
be investigated
investigated for
for
8
8 another year
another year or
or two
two by
by John
John Durham.
Durham. Lovely."
Lovely." Correct?
Correct?
9
9 A.
A. Right.
Right.
10
10 Q.
Q. So you
So you expected
expected to
to be
be investigated
investigated further
further by
by
1
11 Mr. Durham. Correct?
Mr. Durham. Correct?
12
12 A.
A. ves, II did.
Yes, did.
13
13 Q.
Q. The day
The day after
after Mr.
Mr. Durham
Durham was appointed, your
was appointed, your
14
14 lawyer reached
lawyer reached out
out to
to him
him to
to offer
offer your
your cooperation.
cooperation.
15
15 Correct?
Correct?
16
16 A.
A. I don't
I don't remember
remember that.
that.
17
17 Q.
Q. Let's take
Let's take aa look
look at
at --
-- well,
well, do
do you
you remember
remember
18
18 going on
going on CNN
CNN and
and saying
saying that
that on
on --
-- you
you work for CNN
work for CNN as
as an
an
19
19 analyst.
analyst. Right?
Right?
20
20 A.
A. Correct.
Correct.
21
21 Q.
Q. Do you
Do you have
have media
media training,
training, sir?
sir?
22
22 A.
A. A little
A little bit, yes.
bit, yes.
23
23 Q.
Q. How to
How to communicate?
communicate?
24
24 A.
A. How to
How to communicate
communicate on
on TV,
TV, yes.
yes. It's aa special
It's special
25
25 thing.
thing.
1036
1036
1
1 Q.
Q. You said
You said that
that you
you would
would cooperate
cooperate in
in any
any way you
way you
2
2 could with
could with the
the Durham
Durham review
review team.
team. Correct?
Correct?
3
3 A.
A. ves.
Yes.
4
4 @.
Q. And let's
And let's take
take aa look,
look, if
if we
we can,
can, at
at JB-LW-06
JB-LW-06 at
at
5
5 1, which
1, we'll mark
which we'll for identification
mark for identification purposes as Defense
purposes as Defense
6
6 Exhibit 811.
Exhibit 811.
7
7 MR. BERKOWITZ: If
MR. BERKOWITZ: If you
you could
could blow out the
blow out the Daniel
Daniel
8
8 Levin portion.
Levin portion.
9
9 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
10
10 Q.
Q. That's from
That's from Mr.
Mr. Levin,
Levin, that's
that's your
your lawyer
lawyer is
is at
at aa
1
11 law firm
law firm of
of White
White && Case.
Case. Correct?
Correct?
12
12 A.
A. ves, Mr.
Yes, Levin, it's
Mr. Levin, it's pronounced. Yes, that's
pronounced. Yes, that's my
my
13
13 Lawyer.
lawyer.
14
14 MR. BERKOWITZ: Can
MR. BERKOWITZ: Can II move
move this
this into
into evidence,
evidence,
15
15 Your Honor?
Your Honor? II would
would move
move it
it into
into evidence
evidence as
as A-10.
A-10.
16
16 THE COURT:
THE COURT: Any objection?
Any objection?
17
No objection.
18
18 THE COURT:
So moved.
19
19 (Defense Exhibit
(Defense Exhibit A-10
A-10 was admitted.)
was admitted.)
20
20 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
21
21 ©.
Q. And it
And it reads
reads "Congratulations
"Congratulations on
on your
your new
new
22
22 assignment. Jim
assignment. Jim asked
asked me to reach
me to reach out
out and
and let
let you
you know
know that
that
23
23 he was
he available if
was available if you/your
you/your staff
staff wish to interview
wish to interview him
him (he
(he
24
24 just spoke
just spoke to
to the
the IG
IG today).
today). If so,
If so, please
please let
let me know."
me know."
25
25 That's what
That's what you
you told
told him
him to
to do.
do. Correct?
Correct?
1037
1037
1
1 A.
A. ves.
Yes.
2
2 Q.
Q. In fact,
In fact, you
you were interviewed several
were interviewed several times
times by
by
3
3 Mr. Durham
Mr. Durham and
and his
his team.
team. Correct?
Correct?
4
4 A.
A. Correct.
Correct.
5
5 ©.
Q. And we'll
And we'll get
get into
into that.
that. Now let's
Now let's try
try and
and --
--
6
6 MR. BERKOWITZ: You
MR. BERKOWITZ: You can
can take
take that
that down.
down.
7
7 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
8
8 @.
Q. ---- to
to put
put into
into perspective,
perspective, II believe
believe you
you
9
9 testified, about
testified, about what
what was
was aa 30-minute
30-minute meeting
meeting that
that you
you had
had
10
10 with Mr.
with Mr. Sussmann
Sussmann onon September
September 19th
19th of
of 2016?
20162
1
11 A.
A. Approximately, yes.
Approximately, yes.
12
12 Q.
Q. Testified for
Testified for about
about four
four --
-- over
over four
four hours
hours about
about
13
13 that meeting
that meeting and
and other
other things?
things?
14
14 A.
A. Today?
Today?
15
15 0.
Q. ves.
Yes.
16
16 A.
A. Today, yes,
Today, yes, II think
think that's
that's right,
right, yeah.
yeah.
17
17 ©.
Q. And you're
And you're aa lawyer.
lawyer. Correct?
Correct?
18
18 A.
A. ves, sir.
Yes, sir.
19
19 Q.
Q. You were
You were the
the general counsel at
general counsel at the
the FBI.
FBI. Correct?
Correct?
20
20 A.
A. ves, sir.
Yes, sir.
21
21 Q.
Q. You were
You were not
not an
an agent?
agent?
22
22 A.
A. correct.
Correct.
23
23 Q.
Q. Not aa Special
Not Special Agent?
Agent?
24
24 A.
A. Correct.
Correct.
25
25 Q.
Q. You weren't
You weren't an
an investigator.
investigator. Correct?
Correct?
1038
1038
1
1 A.
A. correct.
Correct.
2
2 ©.
Q. It was
It was not
not part
part of
of your
your job
job to
to manage
manage
3
3 investigations. Correct?
investigations. Correct?
1
4 A.
A. That's not
That's not directly
directly correct.
correct. AsAs II said
said earlier,
earlier,
5
5 it was
it the job
was the job of
of the
the Office
Office ofof General
General Counsel
Counsel toto conduct
conduct
6
6 oversight with
oversight with respect
respect toto investigations
investigations butbut not
not to
to run
run
7
7 them. That's
them. That's right.
right.
8
8 ©.
Q. It wasn't
It wasn't part
part of
of your
your job
job to
to either
either manage
manage oror
9
9 conduct investigations.
conduct investigations. ThatThat was
was left
left to
to others.
others. Right?
Right?
10
10 A.
A. Correct.
Correct.
n
11 ©.
Q. So in
So in connection
connection with this matter,
with this matter, ifif an
an
12
12 investigation was
investigation was open,
open, that
that would
would not
not be your day-to-day
be your day-to-day
13
13 responsibility. Correct?
responsibility. Correct?
14
14 A.
A. That's correct.
That's correct.
15
15 ©.
Q. It would
It would be the responsibility
be the responsibility of of others.
others. Right?
Right?
16
16 A.
A. Correct. Can
Correct. Can II amend
amend what
what II said
said just
just aa second
second
17
17 ago?
ago?
18
18 Certain investigations
Certain investigations require
require aa lawyer
lawyer toto sign
sign
19
19 off on
off on them,
them, and
and II have
have done
done that
that in
in the
the past.
past. SoSo the
the
20
20 investigation could
investigation could not
not proceed
proceed without
without aa lawyer
lawyer signing
signing off
off
21
21 on it,
on it, and
and II have
have done
done that.
that.
22
22 ©.
Q. Okay. Do
Okay. Do you
you remember
remember being
being asked
asked inin the
the grand
grand
23
23 jury the
jury the following
following question and giving
question and giving the
the following
following answer?
answer?
2
24 MR. BERKOWITZ: Jim
MR. BERKOWITZ: Jim Baker
Baker 11
11 at
at 13,
13, Line
Line 16
16 to
to 24,
24,
25
25 if we
if can put
we can put that
that up,
up, page 13, Line
page 13, Line 16
16 to
to 24.
24.
1039
1039
1
1 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
2
2 ©.
Q. Were you
Were you asked
asked this
this question
question and
and did
did you
you give this
give this
3
3 answer?
answer?
4
4 @. Now
Q. Now in
in your
your role
role as
as general
general counsel
counsel ofof
5
5 the FBI,
the FBI, was
was it
it part
part of
of your
your job
job to
to manage
manage or
or
6
6 conduct investigations
conduct investigations or or was that work
was that work that
that was
was
7
7 left to
left to the
the others
others at
at the
the FBI?
FBI?
8
8 A.
A. That was
That was left
left to
to others
others at
at the
the FBI.
FBI.
9
9 ©.
Q. Were you
Were you asked
asked that
that question
question and
and did
did you
you give that
give that
10
10 answer?
answer?
n
11 A.
A. I believe
I believe so.
so. II haven't
haven't seen
seen this
this transcript
transcript
12
12 before but,
before yes.
but, yes.
13
13 ©.
Q. And you
And you were
were under
under oath
oath when
when you
you gave
gave that
that answer.
answer.
14
14 Correct?
Correct?
15
15 A.
A. ves.
Yes.
16
16 ©.
Q. Okay. And
Okay. And Mr.
Mr. DeFilippis
DeFilippis was
was doing
doing the
the
17
17 questioning?
questioning?
18
18 A.
A. I believe
I believe so,
so, yes.
yes.
19
19 ©.
Q. Okay. Now,
Okay. Now, sir,
sir, you,
you, in
in this
this case,
case, have
have not
not done
done
20
20 any of
any of the
the investigation
investigation inin connection
connection with
with the
the case.
case.
21
21 Correct?
Correct?
22
22 A.
A. Well, the
Well, the reason
reason I'm
I'm hesitating
hesitating isis because
because II was
was
23
23 the person
the person who received the
who received the evidence
evidence in
in the
the first
first instance.
instance.
24
24 ©.
Q. So let's
So let's talk
talk about
about the
the extent
extent of
of your
your role
role in
in
25
25 this situation.
this situation. We'll
We'll get into it
get into it in
in more
more detail.
detail.
1040
1040
1
1 Mr. Sussmann texted
Mr. Sussmann texted you
you on
on September
September 18th
18th of
of 2016.
2016. Correct?
Correct?
2
2 A.
A. Correct. Correct.
Correct. Correct.
3
3 Q.
Q. You take
You take aa meeting
meeting with
with him
him on
on September
September 19th
19th of
of
4
4 20162
2016?
5
5 A.
A. Correct.
Correct.
6
6 Q.
Q. You speak
You speak for,
for, you
you testified
testified today,
today, 30
30 minutes?
minutes?
7
7 A.
A. Correct.
Correct.
8
8 Q.
Q. You get
You get some
some thumb
thumb drives
drives and
and some
some papers.
papers.
9
9 Correct?
Correct?
10
10 A.
A. Correct.
Correct.
1
11 ©.
Q. And you
And you didn't
didn't review
review those.
those. Correct?
Correct?
12
12 A.
A. I think
I think II flipped
flipped through
through the
the papers
papers quickly.
quickly.
13
13 @.
Q. Did you
Did you review
review them
them at
at all
all substantively,
substantively, sir?
sir?
14
14 A.
A. Not really,
Not really, no.
no.
15
15 Q.
Q. Didn't evaluate
Didn't evaluate them.
them. Correct?
Correct?
16
16 A.
A. Correct.
Correct.
17
17 Q.
Q. In fact,
In fact, you
you wanted to get
wanted to get rid
rid of
of them
them as
as quickly
quickly
18
18 as possible.
as possible. Right?
Right?
19
19 A.
A. Correct.
Correct.
20
20 ©.
Q. You didn't
You didn't want
want to
to have
have evidence,
evidence, did
did you?
you?
21
21 A.
A. That's correct.
That's correct.
22
22 Q.
Q. And in
And in fact,
fact, sir,
sir, the
the extent
extent of
of your
your interaction
interaction
23
23 with him
with him was short
was short and
and cordial.
cordial. Right?
Right?
24
24 A.
A. ves.
Yes.
25
25 @.
Q. Okay.
Okay. You wanted
You wanted to
to avoid
avoid becoming
becoming much
much of
of aa
1041
1041
1
1 witness?
witness?
2
2 A.
A. Correct.
Correct.
3
3 ©.
Q. How did
How did that
that work out for
work out for you?
you?
4
4 A.
A. Not very
Not very well.
well.
5
5 ©.
Q. No. He
No. He made
made some
some statements
statements but you didn't
but you didn't want
want
6
6 to conduct
to conduct either
either an
an interview
interview oror aa deposition
deposition ofof him.
him.
7
7 Correct?
Correct?
8
8 A.
A. That's correct.
That's correct.
9
9 Qe.
Q. so --
So --
10
10 A.
A. Excuse me.
Excuse me. Once
Once II realized
realized what
what the
the meeting
meeting was
was
n
11 about and
about and that
that Michael
Michael was
was giving
giving meme information,
information, that
that
12
12 changed my
changed calculation about
my calculation about the
the interaction.
interaction. So So II wanted
wanted
13
13 it to
it to be
be over
over as
as quickly
quickly as
as possible
possible and
and to
to get
get rid
rid of
of this
this
14
14 material
material as as quickly
quickly as
as possible.
possible.
15
15 ©.
Q. Okay. You
Okay. You took
took the
the information
information in.
in. You
You handed
handed itit
16
16 Off to
off to Mr. Priestap. Correct?
Mr. Priestap. Correct? OrOr somebody
somebody came
came and
and got
got it?
it?
17
17 A.
A. Somebody came
Somebody came and
and got
got it;
it; that's
that's correct.
correct.
18
18 ©.
Q. You didn't
You didn't follow
follow upup on
on any
any of
of the
the follow-up
follow-up
19
19 factual investigation.
factual investigation. Correct?
Correct?
20
20 A.
A. I did
I did not
not do
do the
the investigation;
investigation; that's
that's correct.
correct.
21
21 ©.
Q. You called
You called Mr.
Mr. Sussmann
Sussmann back
back on
on the
the 21st
21st to
to see
see if
if
22
22 he would
he give you
would give you the
the name
name of
of the
the reporter.
reporter. Correct?
Correct?
23
23 A.
A. I can't
I can't remember
remember the
the dates
dates but,
but, yes.
yes.
24
24 ©.
Q. He then
He then called
called you
you back
back and
and gave
gave you
you the
the name
name of
of
25
25 the reporter?
the reporter?
1042
1042
1
1 A.
A. ves.
Yes.
2
2 ©.
Q. After that,
After that, fair
fair to
to say
say that
that you
you didn't
didn't talk
talk with
with
3
3 Mr. Sussmann
Mr. Sussmann about
about the
the substance
substance of
of the
the Alfa-Bank
Alfa-Bank
4
4 allegations in
allegations in 2016
2016 or
or 2017.
2017. Correct?
Correct?
5
5 A.
A. I think
I think that's
that's right.
right. Yes.
Yes.
6
6 ©.
Q. A hundred
A hundred percent
percent sure?
sure?
7
7 A.
A. Pretty sure.
Pretty sure.
8
8 ©.
Q. What's pretty
What's pretty sure?
sure?
9
9 A.
A. Meaning II --
Meaning -- you
you know,
know, I've
I've had
had multiple
multiple
10
10 conversations with
conversations with Michael over aa period
Michael over period of
of time,
time, and
and I'm
I'm
n
11 thinking about
thinking about the
the years
years that
that you
you just
just framed,
framed, and
and that
that was
was
12
12 when II was
when still at
was still at the
the FBI.
FBI. So
So II don't
don't think
think that
that II had
had
13
13 other substantive
other substantive conversations
conversations with
with Michael
Michael about
about the
the case
case
14
14 during that
during that time
time period.
period.
15
15 ©.
Q. You didn't
You didn't --
—-
16
16 A.
A. About the
About the Alfa-Bank allegations.
Alfa-Bank allegations.
17
17 ©.
Q. You didn't
You didn't interview
interview Mr. Sussmann?
Mr. Sussmann?
18
18 A.
A. No, II did
No, did not.
not.
19
19 ©.
Q. You didn't
You didn't issue
issue any
any subpoenas
subpoenas oror cause
cause subpoenas
subpoenas
20
20 to be
to issued. Correct?
be issued. Correct?
21
21 A.
A. I did
I did not,
not, no.
no.
22
22 ©.
Q. Didn't ask
Didn't ask to
to speak
speak with
with the
the cyber
cyber experts.
experts.
23
23 Correct?
Correct?
24
24 A.
A. That's correct.
That's correct.
25
25 ©.
Q. And other
And other than
than that,
that, you
you talked
talked to
to The
The New
New York
York
1043
1043
1
1 Times..
Times Correct?
Correct?
2
2 A.
A. I did
I did talk
talk to
to The
The New
New York
York Times
Times twice
twice as
as II
3
3 described earlier.
described earlier.
4
4 @.
Q. And that
And that wasn't to collect
wasn't to collect information.
information. Correct?
Correct?
5
5 A.
A. That's correct.
That's correct.
6
6 Q.
Q. So the
So the extent
extent of
of your
your involvement
involvement in
in this
this case
case was
was
7
7 taking the
taking the stuff
stuff in,
in, talking
talking to
to Mr. Priestap and
Mr. Priestap and handing
handing the
the
8
8 materials off. Correct?
materials off. Correct?
9
9 A.
A. Well, then
Well, then II had
had the
the interactions
interactions with
with The
The New
New
10
10 York Times
York Times,, and
and II got
got briefings
briefings from
from Bill
Bill about
about what
what was
was
1
11 going on
going on with
with the
the investigation,
investigation, what
what the
the ultimate
ultimate result
result
12
12 was.
was.
13
13 Q.
Q. You were
You were in
in receive
receive mode,
mode, but
but you
you didn't
didn't do
do
14
14 anything affirmatively?
anything affirmatively?
15
15 A.
A. Other than
Other than this
this interaction
interaction with
with The
The New
New York
York
16
16 Times;; that's
Times that's correct.
correct.
17
17 Q.
Q. And, sir,
And, sir, you
you have
have no
no personal
personal knowledge
knowledge of
of
18
18 whether Mr.
whether Mr. Sussmann
Sussmann was
was acting
acting on
on behalf of aa client
behalf of client or
or not
not
19
19 acting on
acting on behalf
behalf of
of aa client
client at
at that
that meeting?
meeting?
20
20 A.
A. I have
I have no
no personal
personal knowledge
knowledge about
about that.
that.
21
21 Q.
Q. So you're
So you're not
not here
here to
to testify
testify about
about that.
that.
22
22 Correct?
Correct?
23
23 A.
A. Correct.
Correct.
24
24 @.
Q. So now
So now that
that we've
we've cabined,
cabined, if
if you
you will,
will, where
where
25
25 we're at,
we're at, which
which is
is that
that brief
brief period
period of
of time,
time, II want
want to
to take
take
1044
1044
1
1 you through
you through how
how things
things have
have evolved
evolved at
at least
least in
in terms
terms of
of
2
2 your recollection
your recollection over
over the
the years.
years.
3
3 First of
First of all,
all, you
you testified
testified to
to this
this text
text message,
message,
4
4 correct?
correct?
5
5 A.
A. Which text
Which text message?
message? There
There were
were aa bunch of them.
bunch of them.
6
6 @.
Q. sure, the
Sure, the one
one on
on September
September 18th?
18th?
7
7 A.
A. ves.
Yes.
8
8 ©.
Q. And that's
And that's aa text
text message that you
message that you recovered
recovered inin or
or
9
9 around March
around of this
March of this year.
year. Correct?
Correct?
10
10 A.
A. Correct.
Correct.
n
11 ©.
Q. And Mr.
And Mr. DeFilippis
DeFilippis said
said they
they asked
asked you
you to
to get
get 3500
3500
12 || material,
12 correct, that's
material, correct, that's one
one of
of the
the reasons
reasons that
that you
you looked
looked
13
13 for it?
for it?
14
14 A.
A. Discovery material,
Discovery yes exactly,
material, yes exactly, discovery
discovery
15
15 material relevant
material relevant to
to this
this case
case that
that we're
we're inin right
right now.
now.
16
16 ©.
Q. Did it
Did it ever
ever occur
occur to
to you,
you, sir,
sir, in
in any
any of
of the
the
17
17 period of
period of time,
time, from
from when
when you
you were
were interviewed
interviewed by Congress,
by Congress,
18
18 when you
when you were
were interviewed
interviewed byby the
the I.G.,
I.G., when these people
when these people
19
19 interviewed you
interviewed you multiple times, to
multiple times, to look
look at
at your
your phone
phone and
and
20
20 look for
look for any
any text
text messages?
messages?
21
21 A.
A. So I'm
So I'm hesitating
hesitating about
about the
the timeframe
timeframe because
because
22 || michael
22 was texting
Michael was texting me, you know,
me, you know, about
about the
the Twitter
Twitter job,
job, for
for
23
23 example. That
example. That was in 2020,
was in 2020, and
and so
so that
that was
was when
when II think
think Mr.
Mr.
24
24 Durham was
Durham conducting his
was conducting his investigation,
investigation, this
this investigation
investigation
25
25 by then,
by then, based
based on
on what
what you
you said
said earlier.
earlier.
1045
1045
1
1 So --
So == but
but IT don't
don't recall
recall like
like scrolling
scrolling --
== as
as II
2
2 || described earlier
described earlier --
-- scrolling
scrolling back up, it
back up, it did
did not
not occur
occur to
to
33 [| me. ror better
me. For better or
or worse, it didn't
worse, it aian't occur
occur to
to me.
me.
44 ©.
Q. And nobody
And nobody from
from the
the government
government asked
asked you
you to
to look
look
55 || until March
until Maren oror February
February ofof this
this year.
year. Correct?
correct?
66 A.
A. To the
To the best
best of
of my
my recollection;
recollection; that's
that's correct.
correct.
77 Q.
Q. Okay. Now,
Okay. Now, when
when Mr. Sussmann reached
Mr. Sussmann reached out
out to
to you,
you,
88 [| ne said
he said that
that the
the matter
matter was
was sensitive
sensitive and
and time
time sensitive.
sensitive.
93 [I correct2
Correct?
10
10 A.
A. Yes.
Yes.
un
11 ©.
Q. And you
And you trusted
trusted Mr.
Mr. Sussmann,
Sussmann, didn't
didn't you?
you?
12
12 A.
A. Yes, II did.
Yes, did.
13
13 ©.
Q. okay. You
Okay. You knew
knew him
him to
to be
be or
or you
you believed
believed him
him to
to
14 ||
14 ve an
be an ethical
ethical person.
person. correct?
Correct?
15
15 A.
A. Correct.
Correct.
16
16 ©.
Q. And you
And you believed
believed he
he wouldn't
wouldn't have
have brought
brought you
you
17 ||
17 information if
information if you
you --
-- if
if he,
he, himself,
himself, didn't
didn't believe
believe itit was
was
18 |
18 credible. Correct?
credible. correct?
19
19 A.
A. Correct.
Correct.
20
20 ©.
Q. And the
And the fact
fact that
that Michael
Michael was
was coming
coming on
on his
his own
own
21 ||
21 and not
and not for
for aa client
client didn't
didn't factor
factor heavily
heavily in
in your
your decision
decision
22
22 [to meet
to with him.
meet with hin. Isn't
Isn't that
that right,
right, sir?
sir?
23
23 A.
A. I would
I would say
say that
that it
it did
did factor
factor into
into my
my decision
decision to to
24 ||
24 meet with him,
meet with him, because he said
because he said he
he just
just wanted to help
wanted to help the
the
25 ||
25 Bureau on
Bureau on something
something that
that was
was sensitive
sensitive and
and time
time sensitive.
sensitive.
1046
1046
1
1 And so
And so because
because Michael
Michael was
was aa friend
friend that
that II trusted
trusted
2
2 and had
and had confidence
confidence in,
in, II was
was more
more than
than willing to meet
willing to meet with
with
3
3 him if
him if he
he thought
thought he
he had
had something
something that
that he
he wanted
wanted to
to provide
provide
4
4 to me
to that would
me that help the
would help the Bureau.
Bureau.
5
5 ©.
Q. The reason
The reason that
that you
you decided
decided to
to meet
meet with
with him
him were
were
6
6 that it
that it was
was sensitive
sensitive and
and time
time sensitive
sensitive and
and you
you trusted
trusted
7
7 him. Correct?
him. Correct?
8
8 A.
A. Correct.
Correct.
9
9 ©.
Q. The fact
The fact that
that Mr. Sussmann stated
Mr. Sussmann stated specifically
specifically in in
10
10 his message
his that he
message that he was
was acting
acting on
on his
his own
own and
and not
not for
for aa
n
11 client did
client did not
not factor
factor heavily
heavily into
into your
your decision
decision to
to meet
meet
12
12 with him.
with him. Correct?
Correct?
13
13 A.
A. I disagree
I disagree with
with that.
that.
14
14 ©.
Q. All right.
All right. DoDo you
you remember
remember speaking
speaking with
with these
these
15
15 folks in
folks in March
March of
of this
this year
year --
-- by these folks
by these folks to
to be,
be, correct
correct
16
16 for the
for the record,
record, the
the prosecution
prosecution team,
team, Mr.
Mr. DeFilippis?
DeFilippis?
17
17 A.
A. In March
In March of
of this
this year,
year, II spoke
spoke to
to them,
them, yes.
yes.
18
18 ©.
Q. Okay. And
Okay. And in
in March of this
March of this year,
year, is
is it
it not
not true
true
19
19 that you
that you told
told them
them you
you do not believe
do not believe that
that the
the fact
fact that
that
20
20 Sussmann stated
Sussmann stated specifically
specifically inin his
his texts
texts that
that he
he was
was acting
acting
21
21 on his
on his own
own and
and not
not for
for aa client
client factored
factored heavily
heavily into
into your
your
22
22 decision to
decision to meet with Michael
meet with Michael Sussmann
Sussmann the
the very next day.
very next day.
23
23 You told
You told them
them that?
that?
24
24 A.
A. Can you
Can you repeat
repeat the
the first
first part of that
part of that again?
again?
25
25 sorry.
Sorry.
1047
1047
1
1 ©.
Q. "Baker does
"Baker does not
not believe
believe that
that the
the fact
fact that
that
2
2 Sussmann stated
Sussmann stated specifically
specifically in in his
his text
text message
message that
that he
he was
was
3
3 acting on
acting on his
his own
own and
and not
not for
for aa client
client factored
factored heavily
heavily into
into
4
4 his decision
his decision to to meet with Sussmann
meet with Sussmann the
the very
very next
next day"?
day"?
5
5 A.
A. So, I'm
So, I'm sorry.
sorry. What's
What's your
your question?
question?
6
6 ©.
Q. You told
You told them
them that
that on
on March 4th of
March 4th of 2022.
2022.
7
7 A.
A. sitting here
Sitting here today,
today, II don't
don't recall
recall telling
telling them
them
8
8 that.
that.
9
9 ©.
Q. Refresh your
Refresh your recollection
recollection to to see
see the
the 302
302 of
of your
your
10 || meeting,
10 sir?
meeting, sir?
n
11 A.
A. sure. II haven't
Sure. haven't seen
seen that
that 302
302 before.
before.
12
12 ©.
Q. All right.
All right. And
And to
to orient
orient the
the jury
jury is
is when
when an
an
13
13 agent is
agent is present
present and
and take
take notes.
notes. Correct?
Correct?
14
14 A.
A. It's aa report
It's report ofof an
an interview.
interview.
15
15 ©.
Q. And when
And when aa witness
witness isis interviewed
interviewed byby the
the FBI,
FBI, anan
16
16 agent is
agent is there
there to
to take
take notes,
notes, ifif it's
it's aa fact
fact witness,
witness, and
and
17
17 put it
put it into
into aa report.
report. Correct?
Correct?
18
18 A.
A. Correct.
Correct.
19
19 ©.
Q. You didn't
You didn't do
do that
that with
with Mr.
Mr. Sussmann.
Sussmann. Right?
Right?
20
20 A.
A. Correct.
Correct.
21
21 ©.
Q. So let's
So let's take
take aa look
look at
at JB-16
JB-16 at
at 3,
3, Paragraph
Paragraph 2.2.
22 [| and
22 just for
And just for the
the witness,
witness, I'd
I'd ask
ask you
you to
to read
read Paragraph
Paragraph 22 toto
23
23 yourself, sir?
yourself, sir?
24
24 A.
A. Is that
Is that the
the one
one that's
that's showing?
showing?
25
25 ©.
Q. That's the
That's the one
one that's
that's shown.
shown. You
You can
can read
read the
the
1048
1048
1
1 || whore paragraph,
whole paragraph, but
but I'm
1'm looking
10oking at
at the
the third
third line,
line, the
the
2 ||
2 third --
third -- fourth
fourth and
and fifth
fifth lines.
lines. Read that
Read that to
to yourself
yourself and
and
3 ||
3 ask you
I ask you if
if it
it refreshes
refreshes your
your recollection
recollection about
about what
wnat you
you
4 ||
4 tora the
told the FBI
eer that
that day?
day?
5
5 A.
A. sure. Let
Sure. Let me
me just
just read
read the
the whole
whole paragraph,
paragraph, ifif
6 ||
6 that's okay.
that's okay.
7
7 (Brief pause.)
(Brief pause.)
8
8 Okay. What's
Okay. What's your
your question,
question, sir?
sir?
9
9 ©.
Q. Does it
Does it refresh
refresh your
your recollection
recollection that,
that, on
on March
March
10 ||
10 4th of
4th of 2022,
2022, you
you told
told the
the FBI
FBI and
and Mr.
Mr. DeFilippis
DeFilippis that
that you
you
11 ||
11 asan't pelieve
didn't the fact
believe the fact that
that Mr.
Mr. Sussmann
Sussmann stated
stated
12 ||
12 specifically in
specifically in his
his text
text he
he was
was acting
acting on
on his
his own
own and
and not
not
13 ||
13 for aa client
for client factored
factored heavily
heavily into
into your
your decision
decision toto meet
meet
14 ||
14 with Mr.
with Mr. Sussmann
sussmann the
the next
next day?
day?
15
15 A.
A. I don't
I don't recall
recall making
making that
that statement
statement sitting
sitting here
here
16 |
16 today.
today.
17
17 ©.
Q. And it's
And it's your
your testimony
testimony --
--
18
can take
take that
that down.
down.
19 ||
19 BY
BY mm.
MR. mERxowrrz:
BERKOWITZ:
20
20 @.
Q. It's your
It's your testimony
testimony that
that that's
that's not
not accurate.
accurate.
21 ||
21 correct?
Correct?
22
22 A.
A. It's my
It's testimony today
my testimony today that,
that, as
as II think
think about
about itit
23 ||
23 today, that
today, that that's
that's not
not accurate.
accurate.
2
24 9.
Q. And you're
And you're aware
aware --
--
25
25 A.
A. Can II ask
Can ask you
you aa question?
question? When
When was
was that
that 302?
302?
1049
1049
1
1 What was the
What was the date?
date? What meeting or
What meeting or what
what interview
interview was that
was that
2
2 pertaining to?
pertaining to?
3
3 ©.
Q. There's aa lot
There's lot of
of different meetings and
different meetings and interviews
interviews
4
4 here. This
here. This one
one was
was aa couple
couple of
of months ago on
months ago on March
March 4th
4th of
of
5
5 2022 --
2022 ==
6
6 A.
A. Okay.
Okay.
7
7 ©.
Q. -- in
-- in connection
connection with your trial
with your trial preparation for
preparation for
8
8 today.
today.
9
9 A.
A. That was
That was the
the date that II found
date that found the
the text,
text, yes.
yes.
10
10 ©.
Q. Okay. Did
Okay. Did that
that change
change your
your recollections
recollections atat all
all
n
11 or --
or =
12
12 A.
A. Well it's
Well it's just
just it
it was
was aa very
very --
-- it
it was
was aa very
very
13
13 difficult day
difficult day for
for me
me and
and it
it was
was aa bit
bit upsetting.
upsetting.
14
14 ©.
Q. You didn't
You didn't say,
say, "I
"I need
need some
some time.
time. Let's
Let's not
not
15
15 talk"?
talk"?
16
16 A.
A. I agreed
I agreed to
to talk
talk to
to them
them but, yes. II agreed
but, yes. agreed to
to
17
17 talk to
talk to them
them because
because they
they wanted
wanted to
to know
know about
about --
-- II believe
believe
18
18 that was
that was the
the date
date that
that II found
found the
the material.
material. ButBut II agreed
agreed
19
19 to talk
to talk toto them
them because
because II --
-- yes,
yes, II felt
felt stupid
stupid for
for not
not
20
20 having found
having found that
that material
material before.
before. II did.
did. And there's
And there's
21
21 nothing else
nothing else II can
can say
say about
about that.
that.
22
22 ©.
Q. And they
And they told
told you,
you, sir,
sir, did
did they
they not,
not, that
that that
that
23 || meeting
23 was governed
meeting was governed byby 18
18 U.S.C.
u.s.c. 1001.
1001. Correct?
correct?
24
24 A.
A. I don't
I don't think
think they
they told
told me
me that,
that, but
but II knew
knew that.
that.
25
25 ©.
Q. Okay. Well,
Okay. Well, sir,
sir, isn't
isn't it
it accurate
accurate that
that at
at the
the
1050
1050
1
1 beginning of
beginning of every
every FBI
FBI interview
interview that
that you
you participated
participated in
in in
in
2
2 this case,
this case, you
you were told that
were told that the
the statements
statements you
you made
made to
to
3
3 them were
them were subject
subject to
to 18
18 U.S.C.
U.S.C. 1001.
1001. Correct?
Correct?
4
4 A.
A. I don't
I don't think
think that's
that's correct.
correct.
5
5 @.
Q. Well, on
Well, on this
this situation,
situation, sir,
sir, isn't
isn't that
that what they
what they
6
6 told you
told you on the
on the 22nd?
22nd?
7
7 A.
A. I don't
I don't recall.
recall.
8
8 Q.
Q. But you
But you understood
understood ----
9
9 A.
A. I know
I know very
very well
well it's
it's aa crime
crime to
to make a false
make a false
10
10 statement to
statement to the
the FBI
FBI if
if that's
that's what you are
what you are getting
getting at.
at.
1
11 Whether they say
Whether they say it
it or
or not,
not, II know
know it.
it.
12
12 Q.
Q. Okay. Now,
Okay. Now, taking
taking yourself
yourself back
back to
to September
September 18th
18th
13
13 and 19th
and 19th of
of 2016.
2016.
14
14 A.
A. ves.
Yes.
15
15 Q.
Q. At that
At that point,
point, as
as we
we said,
said, you
you believed
believed
16
16 Mr. Sussmann to
Mr. Sussmann to be
be ethical?
ethical?
17
17 A.
A. ves.
Yes.
18
18 Q.
Q. You believed
You believed him
him to
to be
be credible?
credible?
19
19 A.
A. ves.
Yes.
20
20 Q.
Q. You believed
You believed him
him to
to be
be somebody
somebody who
who was
was honest.
honest.
21
21 Correct?
Correct?
22
22 A.
A. Correct.
Correct.
23
23 Q.
Q. You'd had
You'd had years
years of
of interactions
interactions with
with him.
him.
24
24 Correct?
Correct?
25
25 A.
A. Correct.
Correct.
1051
1051
1
1 ©.
Q. AA couple
couple months earlier, you
months earlier, you and
and he
he had
had been
been
2
2 together on
together on stage
stage at
at an
an event
event where
where he
he interviewed
interviewed you.
you.
3
3 Correct?
Correct?
4
4 A.
A. correct.
Correct.
5
5 ©.
Q. And although
And although you've
you've been
been asked
asked aa number
number of
of
6
6 different questions,
different questions, you
you are
are not
not here
here today
today to
to say
say what --
what --
7
7 well, in
well, in any
any event,
event, you
you are
are --
-- if
if Mr.
Mr. Sussmann
Sussmann came
came toto you
you
8
8 to give
to you aa heads
give you heads up
up about
about aa New
New York
York Times
Times article
article that
that
9
9 was going
was going to
to come
come out
out with
with information
information about
about potential
potential links
links
10
10 to Russia,
to Russia, you
you would have wanted
would have wanted him
him to
to do
do that.
that. Right?
Right?
n
11 A.
A. If that's
If that's what
what he
he had
had said
said initially
initially you
you mean?
mean?
12
12 9.
Q. ves.
Yes.
13
13 A.
A. In the
In the text,
text, for
for example?
example?
14
14 Q.
Q. veah.
Yeah.
15
15 A.
A. Well II would
Well would have
have wanted
wanted him
him to
to come
come to
to the
the FBI.
FBI.
16 || whether
16 Whether I1 would
would have
have met
met with
with him
him myself
myself is
is another
another
17
17 question. II don't
question. don't think
think II would have under
would have under the
the fact
fact
18
18 scenario you
scenario you just
just laid
laid out,
out, because
because we
we were already
were already
19
19 conducting an
conducting an investigating
investigating ofof the
the Trump-Russia
Trump-Russia matter.
matter. AndAnd
20
20 II would
would have
have wanted
wanted agents
agents with
with me in that
me in that kind
kind of
of
21
21 situation.
situation.
22
22 ©.
Q. Okay. You
Okay. You ordinarily
ordinarily would
would have
have met
met with
with
23 || Mr.
23 sussmann on
Mr. Sussmann on the
the basis
basis of
of mutual
mutual trust
trust and
and his
his claim
claim of
of
24
24 the sensitivity
the sensitivity ofof the
the issue.
issue. Right?
Right?
25
25 A.
A. Yes. Just
Yes. Just based
based on
on that
that --
--
1052
1052
1
1 ©.
Q. So let's
So let's turn
turn to
to the
the meeting
meeting onon September
September 19th
19th of
of
2
2 [I 20 --
20 -- 2016.
2016. Okay?
Okay? and at that
And at that meeting
meeting -- --
3
3 A.
A. I'm sorry.
I'm sorry. Could
Could you
you repeat
repeat the
the date
date again?
again? I'mI'm
a
4 | sorry.
sorry.
5
5 ©.
Q. September 19th.
September 19th.
6
6 A.
A. September 19th,
September 19th, got
got it.
it.
7
7 9.
Q. 2016.
2016.
8
8 A.
A. Got it.
Got it.
9
9 Q.
Q. Today you've
Today you've testified
testified toto aa couple
couple ofof things,
things, and
and
10
10 | 1'm going
I'm going to
to get
get aa white board to
white board to help
help us
us plot
plot it
it out
out if
if II
11 [|
11 can. I1 apologize
can. apologize mymy handwriting
hanawriting isis not
not great.
great.
12
12 THE COURT:
THE COURT: Ladies
Ladies and
and gentlemen,
gentlemen, particularly
particularly the
the
13 ||
13 surors in
jurors in the
the gallery,
gallery, can
can everyone
everyone see?
see?
14
14 JURORS: (Nodded
JURORS: (Nodded head).
head).
15 ||
15 BY
BY ur.
MR. mERxoWITZ:
BERKOWITZ:
16
16 ©.
Q. Let's start
Let's start with
with the
the elephant
elephant in in the
the room.
room.
17 ||
17 sitting here
Sitting here today,
today, what
what is
is your
your testimony
testimony about
about what
what
18 ||
18 mr. sussmann told
Mr. Sussmann told you
you relative
relative to
to clients?
clients?
19
19 A.
A. At the
At the meeting
meeting inin person
person on
on the
the 19th
19th of
of September?
September?
20
20 9.
Q. Yes.
Yes.
2
21 A.
A. Okay. My
Okay. My testimony
testimony is
is that
that he
he said
said that
that he
he was
was
22 [[
22 not there
not there on
on behalf
behalf ofof any
any particular client or
particular client or words
words to
to
23 ||
23 that effect.
that effect.
24
24 ©.
Q. On, now
Oh, now it's
it's "words
"words to
to that
that effect."
effect.” Okay.
Okay. Not
Not
25 ||
25 ctnere on
there on --
-- I'll
1'11 tell
tell you
you what
what I'm
I'm going
going toto do
do --
--
1053
1053
1
1 MR. DeFILIPPIS: Objection,
Objection, Your Honor, we
we do
do have
have
2
2 [| a court
a court reporter.
reporter.
3
3 THE COURT:
THE COURT: Overruled.
Overruled.
4
4 MR. BERKOWITZ: I1 understand.
MR. BERKOWITZ: understand.
5
5 [| er
BY wr.
MR. mEmxowrrz:
BERKOWITZ:
6
6 ©.
Q. Again, I'm
Again, I'm paraphrasing,
paraphrasing, "not
"not there
there on
on behalf
behalf of
of
7
7 || any particular
any particurar client".
crientr. Correct?
correct:
8
8 A.
A. Yes, sir.
Yes, sir.
9
9 ©.
Q. Is that
Is that what
what you're
you're aa hundred
hundred percent
percent sure
sure of?
of?
10
10 A.
A. Yes, sir.
Yes, sir.
un
11 ©.
Q. Okay. Number
Okay. Number two,
two, did
did you
you know
know on
on the
the September
September
12
12 [| 19th, 2016
19th, 2016 meeting that Mr.
meeting that Sussmann had
Mr. Sussmann had been
been representing
representing
13
13 [| nitlary For
Hillary For America's campaign and
America's campaign and the
the DNC
DNC in
in connection
connection
14
14 || with the
with the hack
hack investigation.
investigation. DidDid you
you know
know that
that on
on September
September
15
15 [| 19tn when
19th when he
ne met
met with
witn you?
your
16
16 A.
A. sitting here
Sitting here today,
today, II think
think the
the answer
answer is,
is, yes,
yes, II
17
17 || did know
did know that
that by
by that
that point
point in
in time.
time.
18
18 Q.
Q. I've written
I've written down, "yes, DNC
down, "yes, DNC and
and HFA
HFA and
and hack".
hack". II
19
19 || want to
want to be
be really
really clear.
clear. You're
You're not
not saying
saying that
that he
he said
said
20
20 || that in
that in the
the meeting. correct?
meeting. Correct?
2
21 A.
A. Correct.
Correct.
22
22 ©.
Q. And you're
And you're not
not saying
saying hehe said
said he
he was there on
was there on
23
23 || benaif of
behalf of them?
them» You're
You're just
just saying
saying that
that in
in your
your mind
mind you
you
24
24 || xnew that
knew that he
he had
had been
been acting
acting as
as aa lawyer
lawyer for
for those
those two
two
25
25 || entities in
entities in connection
connection with the hack.
with the hack. Correct?
correct?
1054
1054
1
1 A.
A. Correct.
Correct.
2
2 Q.
Q. Did you
Did you know
know that
that Perkins
Perkins Coie
Coie at
at that
that meeting
meeting was
was
3
3 a law
a law firm
firm that
that represented
represented HFA
HFA and
and the
the DNC?
DNC?
4
4 A.
A. They must
They have because
must have because Michael
Michael worked
worked for
for them,
them, so
so
5
5 II guess
guess the
the answer
answer is
is yes.
yes.
6
6 Q.
Q. Okay.
Okay.
7
7 A.
A. But beyond
But beyond the
the hack,
hack, I'm
I'm not
not sure
sure that,
that, at
at that
that
8
8 point in
point in time,
time, II had
had any
any knowledge
knowledge that
that they
they represented
represented --
--
9
9 that Perkins
that Perkins represented
represented the
the DNC
DNC and
and HFA
HFA in
in any
any other
other
10
10 matters.
matters.
1
11 Q.
Q. Okay. The
Okay. The hack.
hack. Right?
Right?
12
12 A.
A. I believe
I believe at
at the
the time
time that
that was
was what
what II understood.
understood.
13
13 Q.
Q. How long
How long was the meeting?
was the meeting?
14
14 A.
A. Which meeting?
Which meeting?
15
15 Q.
Q. September 19th,
September 19th, 2016?
20162
16
16 A.
A. About 30
About 30 minutes.
minutes.
17
17 Q.
Q. How sure
How sure are
are you
you of
of that?
that?
18
18 A.
A. I'm going
I'm going from
from the
the calendar
calendar entries
entries and
and the
the
19
19 entries on
entries on that
that chain
chain of
of custody
custody document.
document.
20
20 Q.
Q. Okay. Not
Okay. Not from
from your
your memory? You're looking
memory? You're looking at
at
21
21 documents?
documents?
22
22 A.
A. I remember
I remember it
it was
was aa short
short meeting.
meeting. II would
would view
view aa
23
23 30-minute meeting
30-minute meeting as
as aa short
short meeting.
meeting. The documents
The documents are
are
24
24 consistent with
consistent with my
my memory.
memory.
25
25 ©.
Q. And he
And he told
told you
you about
about cyber
cyber experts?
experts?
1055
1055
1
1 A.
A. ves, sir.
Yes, sir.
2
2 ©.
Q. And said
And said that
that the
the cyber
cyber experts
experts were
were the
the source
source ofof
3
3 the data
the data and
and materials
materials he
he was
was providing
providing to
to you.
you. Correct?
Correct?
1
4 A.
A. Yes.
Yes.
5
5 ©.
Q. And what
And what did he say
did he say about
about aa news
news organization?
organization?
6
6 A.
A. He said
He said that
that aa news
news organization
organization had
had the
the same
same or
or
7
7 similar information
similar information and
and that
that they
they were
were preparing
preparing toto publish
publish
8
8 an article
an article about
about it
it very
very soon.
soon. And
And from
from the
the notes
notes we looked
we looked
9
9 at, there
at, there was
was aa reference
reference toto it
it being
being as
as soon
soon as
as Friday
Friday of
of
10
10 that week,
that week, which this meeting
which this meeting took
took place on aa Monday.
place on Monday. So So it
it
n
11 was within
was within five
five days.
days.
12
12 ©.
Q. Okay. My
Okay. My handwriting
handwriting isis like
like aa doctor's,
doctor's, but
but I'm
I'm
13
13 not one.
not one. AA news
news organization
organization hadhad the
the information.
Correct?
14
14 A.
A. Two things.
Two things. One, yes. Two,
One, yes. Two, II can't
can't see
see below the
below the
15
15 word below
word below cyber
cyber experts.
experts.
16
16 ©.
Q. Most people
Most people probably
probably can't.
can't. Okay. After cyber
Okay. After cyber
17
17 experts, I've
experts, I've got
got "news
"news organization
organization hadhad information"?
information"?
18
18 A.
A. ves.
Yes.
19
19 ©.
Q. Did he
Did he tell
tell you
you it
it was
was The
The New
New York
York Times
Times at
at that
that
20 | meeting?
20 meeting?
21
21 A.
A. Yo.
No.
22
22 ©.
Q. Okay. And
Okay. And the
the last
last thing
thing II want
want to
to ask
ask you
you about,
about,
23
23 at least
at least for
for purposes
purposes of
of this,
this, and
and II don't
don't know
know that
that II will
will
24
24 be able
be able to
to write it down
write it down but
but you
you will
will work
work with
with me on it
me on it is
is
25
25 did he
did he identify
identify to
to you
you any
any particular cyber experts
particular cyber experts at
at that
that
1056
1056
1
1 meeting?
meeting?
2
2 A.
A. Who had
Who had worked
worked on
on this
this material?
material?
3
3 ©.
Q. No. Any
No. names, Mr.
Any names, Mr. Bellovin,
Bellovin, Ms.
Ms. [sic]
[sic] Blaze?
Blaze?
1
4 A.
A. Mr. Bellovin,
Mr. Bellovin, II think
think it's
it's pronounced,
pronounced, Mr.
Mr.
5
5 Bellovin, Mr.
Bellovin, Mr. Blaze
Blaze and
and Ms. Landau.
Ms. Landau.
6
6 Q.
Q. Okay.
Okay.
7
7 A.
A. Who were,
Who were, as
as II understood
understood it,
it, not
not the
the cyber
cyber
8
8 experts who
experts who had
had generated
generated this
this material.
material. ButBut the
the cyber
cyber
9
9 experts were
experts were people
people of
of the
the caliber
caliber ofof those
those folks
folks that
that II
10
10 just mentioned.
just mentioned.
n
11 ©.
Q. Okay. Did
Okay. Did hehe tell
tell you
you at
at that
that meeting
meeting that
that
12 || wr.
12 Bellovin, Blaze
Mr. Bellovin, Blaze and
and Ms. Landau had
Ms. Landau had vouched for the
vouched for the
13
13 information?
information?
14
14 A.
A. I don't
I don't remember
remember that.
that.
15
15 ©.
Q. So don't
So don't remember
remember isis aa funny
funny thing.
thing. Right?
Right? We We
16
16 are looking
are looking back
back however
however many
many years.
years. Is Is that
that something
something youyou
17
17 would have
would have recalled?
recalled?
18
18 A.
A. I think
I think so.
so.
19
19 9.
Q. Okay. So
Okay. So --
--
20
20 A.
A. Because II know
Because know Susan
Susan quite
quite well.
well. SoSo II think
think II
21
21 would have
would have recalled
recalled that.
that.
22
22 ©.
Q. So is
So is it
it your
your testimony
testimony here
here today
today that,
that, on
on
23
23 September 19th,
September 19th, 2016,
2016, Mr.
Mr. Sussmann
Sussmann told
told you
you that
that those
those
24
24 individuals, Bellovin,
individuals, Bellovin, Blaze
Blaze and
and Landau,
Landau, had
had vouched
vouched for
for the
the
25
25 information he
information he was
was providing you?
providing you?
1057
1057
1
1 A.
A. I don't
I don't recall.
recall. Sitting
Sitting here
here today,
today, II do
do not
not
2
2 || recall him
recall nim saying
saying that
that those
those experts
experts had
had vouched
vouched for
for this
this
33 [[ material.
material.
44 ©.
Q. Are you
Are you saying
saying it
it didn't
didn't happen?
happen?
55 A.
A. I'm saying,
I'm saying, sitting
sitting here
here today
today that
that II do
do not
not
66 [| recalr him
recall nim saying
saying that
that those
those folks,
folks, whose
whose names
names II knew,
knew, had
haa
77 || vouched for
vouched for this
this material.
materia.
88 ©.
Q. And you
And you knew
knew Ms. Landau. Correct?
Ms. Landau. Correct? YouYou saw
saw her
her at
at
99 || some point
some point after
after this
this meeting
meeting with
with Mr. Sussmann. Correct?
Mr. Sussmann. correct?
10
10 A.
A. Yes. I've
Yes. I've seen
seen Ms.
Ms. Landau
Landau many
many times.
times.
un
11 ©.
Q. Didn't ask
Didn't ask her
her about
about it?
it?
12
12 A.
A. To the
To the best
best of
of my
my recollection,
recollection, sitting
sitting here
here
13 ||
13 today, I1 don't
today, don't think
think I've
1've ever
ever discussed
discussed this
this particular
particular
14 ||
14 matter
matter with susan that
with Susan that II can
can recall.
recall.
1s
15 ©.
Q. Now one
Now one of
of the
the reasons
reasons I'm
I'm having
having to
to write
write this
this
16 ||
16 down is
down is because
because you
you didn't
aidn't take
take notes
notes atat the
the meeting.
meeting. So So
17 ||
17 1et me
let ask you
me ask you aa question,
question, did you take
did you take any
any notes
notes at
at the
the
18 |
18 meeting, sirz
meeting, sir?
19
19 A.
A. Not to
Not to my
my recollection,
recollection, no.no.
20
20 @.
Q. Pretty confident
Pretty confident of
of that?
that?
2
21 A.
A. Iam
I very confident
am very confident ofof that.
that.
22
22 ©.
Q. Hundred percent
Hundred percent you
you didn't
didn't take
take notes.
notes. Right?
Right?
23
23 A
A. ves.
Yes.
2
24 ©.
Q. And Mr.
And Mr. Sussmann,
Sussmann, you
you don't
don't recall
recall him
him taking
taking
25 |
25 notes, do
notes, do you?
you?
1058
1058
1
1 A.
A. I don't
I don't recall
recall him
him taking
taking notes?
notes? II think
think he
he was
was
2
2 speaking most
speaking most of
of the
the time.
time.
3
3 ©.
Q. You were
You were in
in the
the headquarters
headquarters ofof the
the FBI.
FBI. Right?
Right?
1
4 A.
A. Yes.
Yes.
5
5 ©.
Q. The big
The big Hoover
Hoover building
building that
that some
some of
of us
us walk
walk by
by onon
6
6 our way
our way to
to Court?
Court?
7
7 A.
A. On Pennsylvania
On Pennsylvania Avenue,
Avenue, yes.
yes.
8
8 ©.
Q. It is
It is littered
littered with
with agents,
agents, is
is it
it not?
not?
9
9 A.
A. There are
There are many agents in
many agents in that
that building,
building, yes.
yes.
10
10 ©.
Q. And if
And if you
you had
had wanted
wanted to
to get
get an
an agent
agent toto come
come toto
n
11 the meeting,
the meeting, youyou could
could have.
have. Correct?
Correct?
12
12 A.
A. I could
I could have
have probably called Bill
probably called Bill Priestap,
Priestap, for
for
13
13 example, and
example, and if
if he
he was available, asked
was available, asked him
him to
to come
come to
to the
the
14
14 meeting; that's correct.
meeting; that's correct.
15
15 ©.
Q. You were
You were the
the General
General Counsel of the
Counsel of the FBI.
FBI. IfIf you
you
16
16 wanted an
wanted an agent
agent in
in aa meeting,
meeting, you
you could
could have
have gotten
gotten him
him oror
17
17 her there.
her there. Right?
Right?
18
18 A.
A. I think
I think it's
it's harder
harder than
than you're
you're saying,
saying, but
but II
19
19 probably, with
probably, with some
some amount
amount of
of delay,
delay, could
could have
have gotten
gotten anan
20
20 agent up
agent up to
to the
the meeting
meeting ifif it
it was
was imperative.
imperative.
21
21 ©.
Q. And you
And you testified
testified on
on direct,
direct, sir,
sir, that
that you
you didn't
didn't
22
22 have an
have an agent
agent there,
there, because
because you
you didn't
didn't know
know what
what
23 || Mr.
23 sussmann wanted
Mr. Sussmann wanted to
to talk
talk about.
about. Right?
Right?
24
24 A.
A. Correct.
Correct.
25
25 ©.
Q. You thought,
You thought, well, maybe he's
well, maybe he's bringing
bringing something
something
1059
1059
1
1 that implicates
that implicates the
the FBI?
FBI?
2
2 A.
A. ves.
Yes.
3
3 ©.
Q. But once
But once he
he showed
showed up
up and
and told
told you
you what
what he
he had,
had,
4
4 you didn't
you didn't say,
say, well,
well, you
you know
know what, Michael, thanks
what, Michael, thanks very
very
5 [| much.
5 much. LetLet me get an
me get an agent,
agent, because
because II don't
don't want
want to
to hold
hold onon
6
6 to this
to this evidence
evidence and
and it
it might be helpful
might be helpful for
for them
them to
to talk
talk to
to
7
7 you? You
you? You didn't
didn't do
do that.
that. Right?
Right?
8
8 A.
A. I didn't
I didn't do that.
do that.
9
9 ©.
Q. You didn't
You didn't even
even try?
try?
10
10 A.
A. Ididn't
I didn't even try; that's
even try; that's correct.
correct. InIn the
the middle
middle
n
11 of the
of the meeting, no, II did
meeting, no, did not
not try.
try.
12
12 ©.
Q. At the
At the beginning
beginning ofof the
the meeting?
meeting?
13
13 A.
A. At any
At any part
part in
in the
the meeting.
meeting.
14
14 ©.
Q. Are you
Are you aware
aware that
that nobody
nobody from
from the
the FBI
FBI ever
ever
15
15 followed up
followed up to
to interview
interview Mr.
Mr. Sussmann?
Sussmann?
16
16 A.
A. Iam
I not aware
am not aware of
of that.
that. Well, let me
Well, let me back
back up.
up. II
17
17 have heard
have heard that.
that. AtAt the
the time
time we're
we're talking
talking about,
about, in
in the
the
18
18 timeframe that
timeframe that we're talking about
we're talking about and
and prior to the
prior to the time
time
19
19 when Bill
when Bill Priestap
Priestap informed
informed me that the
me that the Bureau
Bureau had
had concluded
concluded
20
20 that there
that there was nothing to
was nothing to the
the case
case or
or to
to the
the allegations.
allegations. II
21
21 didn't hear
didn't hear about
about whether
whether Michael
Michael had
had been
been interviewed
interviewed atat
22
22 all one
all one way
way or
or the
the other.
other.
23
23 ©.
Q. It would
It would be logical, would
be logical, it not,
would it not, sir,
sir, for
for them
them
24
24 to have
to have interviewed
interviewed him?
him?
25
25 A.
A. It would
It would have
have been
been logical,
logical, yes.
yes.
1060
1060
1
1 ©.
Q. Are you
Are you aware,
aware, sir,
sir, that
that Mr. Sussmann's name
Mr. Sussmann's name was
was
2
2 not in
not in the
the investigative
investigative file
file that
that was given to
was given to the
the case
case
3
3 agent that
agent that was investigating the
was investigating the case?
case?
1
4 A.
A. I did
I did not
not know
know that.
that.
5
5 ©.
Q. Would you
Would you find
find that
that unusual?
unusual?
6
6 A.
A. The reason
The reason I'm
I'm hesitating
hesitating isis because, as II said
because, as said
7
7 earlier, II thought
earlier, thought of
of --
=- II myself thought of
myself thought of Michael
Michael as
as aa
8
8 sensitive source
sensitive source at
at least
least or
or aa confidential
confidential human
human source.
source.
9 || and
9 so the
And so the extent
extent to
to which
which particular individuals in
particular individuals in the
the
10
10 investigation would
investigation would or
or would not know
would not know his
his identity
identity would not
would not
n
11 be something
be something that
that II would
would normally
normally get
get involved
involved with
with or
or --
==
12
12 yeah, that
yeah, that II would
would normally
normally get
get involved
involved with.
with.
13
13 Q.
Q. Well, now
Well, now you're
you're just
just speculating.
speculating. Right,
Right, sir?
sir?
14
14 You don't
You don't know
know that
that to
to be the case,
be the case, do
do you?
you?
15
15 A.
A. Know what
Know what to
to be the case?
be the case? Sorry.
Sorry.
16
16 ©.
Q. That you
That you would have held
would have held Mr. Sussmann's name
Mr. Sussmann's name back?
back?
17
17 A.
A. I believe
I believe that
that II did hold his
did hold his name
name back,
back, at
at least
least
18
18 on that
on that one
one occasion
occasion that
that we
we talked
talked about
about earlier
earlier today.
today.
19
19 ©.
Q. Okay. Well,
Okay. Well, we'll cover that
we'll cover that as
as we kind of
we kind of go
go
20
20 through, but
through, but let's
let's mark that as
mark that as another
another one.
one. You
You recall
recall
21
21 sitting here
sitting here today
today that
that Ms. Kelly asked
Ms. Kelly asked you
you for
for the
the identity
identity
22
22 of the
of the source,
source, and
and you
you wouldn't give it
wouldn't give it to
to her?
her?
23
23 A.
A. Who is
Who is Ms.
Ms. Kelly?
Kelly?
24
24 Q.
Q. Jordan Kelly.
Jordan Kelly.
25
25 A.
A. Hmm. And
Hmm. what is
And what is the
the --
--
1061
1061
1
1 Q.
Q. So let's
So let's set
set it
it up.
up. This
This is
is another
another one
one that
that II
2
2 want to
want to make sure everybody
make sure everybody knows?
knows?
3
3 A.
A. sure.
Sure.
4
4 @.
Q. You testified
You testified or
or you're
you're testifying
testifying now
now that,
that, in
in
5
5 the meeting
the when you
meeting when you handed
handed off
off the
the drives
drives --
-- I'm
I'm sorry.
sorry.
6
6 When you signed
When you signed the
the custody,
custody, somebody
somebody asked
asked you
you where
where you
you
7
7 got it?
got it?
8
8 A.
A. I don't
I don't --
-- the
the document
document we
we looked
looked at
at earlier,
earlier, the
the
9
9 chain of
chain of custody
custody document,
document, not
not on
on the
the top
top but
but the
the second
second
10
10 block where
block where II signed,
signed, it
it says
says that
that II released
released it
it to
to SSA
SSA
1
11 Strzok. So
Strzok. So II interpret
interpret that
that to
to mean that II gave
mean that gave those
those
12
12 papers and
papers and the
the thumb
thumb drives
drives that
that Michael
Michael gave
gave me
me to
to Pete
Pete
13
13 Strzok.
Strzok. And II --
And -- yeah,
yeah, so
so II will
will stop
stop there.
there.
14
14 @.
Q. So you
So you just
just testified
testified that
that you
you withheld
withheld the
the name
name
15
15 of Mr.
of Sussmann from
Mr. Sussmann from somebody
somebody who
who asked
asked around
around that
that time.
time.
16
16 Correct?
Correct?
17
17 A.
A. My recollection
My recollection is
is that
that some
some --
-- that
that another
another
18
18 person brought
person -- sometime
brought -- sometime after
after II gave
gave the
the information
information to
to
19
19 Pete, somebody
Pete, somebody else
else brought
brought the
the chain
chain of
of custody
custody document
document to
to
20
20 me. And II think
me. And think that
that is
is the
the person
person that
that II did not disclose
did not disclose
21
21 Michael's identity to.
Michael's identity to.
22
22 Q.
Q. Do you
Do you remember
remember if
if II told
told you
you it
it was Special
was Special
23
23 Agent Hellman and
Agent Hellman and Jordan
Jordan Kelly,
Kelly, would
would that
that ring
ring aa bell?
bell?
24
24 A.
A. No --
No -- II mean,
mean, it
it does not.
does not.
25
25 Q.
Q. There's been
There's been testimony
testimony in
in this
this case
case about
about somebody
somebody
1062
1062
1
1 presenting aa form
presenting form to
to you.
you. That's who
That's who asked
asked for
for the
the identity
identity
2
2 of the,
of the, where
where you
you got
got the
the information
information and
and you
you refused
refused to
to
3
3 tell them.
tell them. Correct?
Correct?
4
4 A.
A. I'll take
I'll take your
your word
word for
for it.
it.
5
5 Q.
Q. No.
No. No.
No.
6
6 A.
A. Well you
Well you said
said there
there had
had been
been testimony.
testimony.
7
7 Q.
Q. Your words
Your are important.
words are important. Not mine.
Not mine.
8
8 So at
So at the
the meeting --
meeting --
9
9 A.
A. At the
At the meeting.
meeting.
10
10 Q.
Q. -- where
-- where you
you signed
signed the
the chain
chain of
of custody
custody form.
form. II
1
11 think that's
think that's Government's
Government's Exhibit
Exhibit 280
280 --
-- let's
let's pull
pull up
up 280
280
12
12 =- II just
-- just want
want to
to make
make sure
sure we
we are
are clear
clear on
on this,
this, 282,
282, thank
thank
13
13 you.
you.
14
14 THE WITNESS:
THE WITNESS: Yes, thank
Yes, thank you.
you.
15
can publish
publish that
that to
to the
the jury.
jury.
16
16 It's in
It's in evidence.
evidence.
17
17 (Whereupon, the
(Whereupon, the exhibit
exhibit was
was published.)
published.)
18
18 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
19
19 @.
Q. This form,
This form, sir.
sir.
20
20 A.
A. ves.
Yes.
21
21 ©.
Q. Somebody presented
Somebody you this
presented you this form
form in
in your
your presence.
presence.
22
22 Correct?
Correct?
23
23 A.
A. At some
At some point,
point, yes.
yes.
24
24 @.
Q. It wasn't
It wasn't the
the 19th.
19th. Correct?
Correct?
25
25 A.
A. I don't
I don't know
know when it was.
when it was. It wasn't
It wasn't --
-- Pete
Pete
1063
1063
1
1 Strzok did
Strzok did not
not come
come with
with this
this form
form when he showed
when he showed up
up to
to take
take
2
2 the materials.
the materials.
3
3 ©.
Q. Somebody brought
Somebody you this
brought you this form.
form. Correct?
Correct?
4
4 A.
A. correct.
Correct.
5
5 ©.
Q. The testimony
The testimony sitting
sitting here
here today
today you
you don't
don't
6
6 remember who
remember who it
it was?
was?
7
7 A.
A. I don't
I don't specifically
specifically remember
remember who
who it
it was.
was.
8
8 ©.
Q. You don't
You don't remember
remember if
if it
it was one person
was one or two
person or two or
or
9
9 three. Right?
three. Right?
10
10 A.
A. I don't
I don't remember
remember how
how many people showed
many people showed up;
up; that's
that's
n
11 correct.
correct.
12
12 ©.
Q. The first
The first time
time you
you ever
ever signed
signed one
one of
of these
these forms.
forms.
13
13 Right?
Right?
14
14 A.
A. Yes, II think
Yes, think that's
that's right.
right.
15
15 ©.
Q. And at
And at that
that meeting
meeting oror gathering
gathering ofof people
people when
when
16
16 they had
they had you
you sign
sign the
the form,
form, somebody
somebody inin that
that meeting
meeting asked
asked
17
17 you, Hey,
you, Hey, where
where did
did you
you get
get it
it from?
from? Right?
Right?
18
18 A.
A. I believe
I believe that
that to
to be
be the
the case.
case.
19
19 ©.
Q. What level
What level of
of confidence
confidence do
do you
you have?
have?
20
20 A.
A. Medium, II guess.
Medium, guess. II don't
don't know.
know.
21
21 ©.
Q. Did you
Did you or
or did
did you
you not
not or
or you
you just
just don't
don't remember
remember
22
22 withhold Mr.
withhold Mr. Sussmann's
Sussmann's name
name from
from anybody
anybody atat the
the FBI
FBI who
who
23
23 asked you
asked you where
where you
you got
got the
the information
information from?
from?
24
24 A.
A. I don't
I don't remember
remember specifically
specifically withholding
withholding it it or,
or,
25
25 like, making
like, making aa big
big deal out of
deal out of that.
that. What
What II think
think isis that,
that,
1064
1064
1
1 | ifif I1 did
aia that
nae --
2
2 ©.
Q. Stop. You
Stop. You don't
don't remember
remember doing
doing it?
it?
3
3 A.
A. I remember
I remember people
people coming
coming --
-- II remember
remember someone
someone
4 [| coming
4 coming to to bring
bring me the form.
me the form. II remember
rememper signing
signing it.
it. II
5 || remember
5 remember having
naving some
some discussion
aiscussion with
with them.
them. II don't
don't remember
rememver
6 || some
6 some extended
extendea colloquy,
colloquy, you
you know,
know, extended
extended discussion
discussion about
about
7 || the
7 the originating
originating source
source of
of the
the information.
information.
8
8 9.
Q. Okay. My
Okay. My question
question --
-- II think
think it's
it's simple
simple but
but --
--
9 [I do
9 do you
vou remember,
remember, one
one way
way or
or the
the other,
other, whether
whether you
you withheld
withheld
10 [| wr.
10 sussmann's name
Mr. Sussmann's name from
from somebody
somebody atat the
the FBI
FBI who
who asked
asked you
you
11 | to
11 to identify
identify thethe source
source of
of the
the information?
information?
12
12 A.
A. sitting here
Sitting here today,
today, right
right now,
now, II have
have to
to say
say that
that
13 || I1 don't
13 don't specifically
remember intentionally
intentionally withholding
withholding that
that
14 | information
14 information from
from FBI
FBI people
people who
who asked
asked me,
me, no.
no.
1s
15 Q.
Q. ALL right.
All right. SoSo after
after that
that meeting
meeting ---- well
well --
--
16
16 THE COURT:
THE COURT: Mr.
Mr. Berkowitz,
Berkowitz, might
might this
this be
be aa good
good
17 || time
17 time toto take
take our
our afternoon
afternoon break?
break?
18
18 MR. BERKOWITZ: Sure,
MR. BERKOWITZ: Sure, Judge.
Judge.
19
19 THE COURT:
THE COURT: All
All right.
right. WhyWhy don't
don't we
we take
take our
our
20 || 15-minute
20 15-minute break,
break, ladies
ladies and
and gentlemen.
gentlemen. No No discussions about
discussions about
21 || the
21 the case.
case. No research about
No research about the
the case,
case, and
and we will reconvene
we will reconvene
22 [| at
22 at quarter
quarter until
until four.
four.
23
23 (Jury exited
(Jury exited the
the courtroom.)
courtroom.)
2
24 THE COURT:
THE COURT: You
You can
can step
step down.
down.
25
25 DEPUTY CLERK:
DEPUTY CLERK: This
This court
court will
will now
now stand
stand in
in
1065
1065
1
1 recess.
recess. You may
You may be
be dismissed.
dismissed.
2
2 (Recess taken.)
(Recess taken.)
3
3 MR. BERKOWITZ: Apparently,
MR. BERKOWITZ: Apparently, for
for the
the record,
record, II
4
4 didn't move
didn't in --
move in -- II moved in 810
moved in 810 twice,
twice, and
and I'd
I'd like
like to
to move
move
5
5 in 811,
in 811, Defense's
Defense's Exhibit
Exhibit 811.
811.
6
No objection.
7
7 THE COURT:
THE COURT: So
So moved.
moved.
8
8 (Defense Exhibit
811 was
was admitted.)
admitted.)
9
9 THE COURT:
THE COURT: ile can
We can bring
bring the
the witness
witness back in
back in
10
10 whenever you
whenever you are
are ready.
ready.
1
11 (Witness took
(Witness took the
the stand.)
stand.)
12
12 THE COURT:
THE COURT: Mr. Baker,
Mr. Baker, feel
feel free
free to
to take
take aa seat
seat
13
13 before the
before the jury
jury comes
comes in.
in.
14
14 THE WITNESS:
THE WITNESS: Thank you,
Thank you, sir.
sir.
15
15 (Jury entered
(Jury entered the
the courtroom.)
courtroom.)
16
16 THE COURT:
THE COURT: Welcome back,
Welcome back, ladies
ladies and
and gentlemen.
gentlemen.
17
17 Mr. Berkowitz,
Mr. Berkowitz, take
take us
us down
down the
the home
home stretch.
stretch.
18
18 MR. BERKOWITZ: I'll
MR. BERKOWITZ: I'll do
do my
my best,
best, Judge,
Judge, at
at least
least
19
19 for the
for the day.
day.
20
20 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
21
21 ©.
Q. At the
At the beginning
beginning of
of the
the testimony,
testimony, Mr.
Mr. Baker,
Baker,
22
22 before II showed
before showed you
you the
the letter
letter we had sent
we had sent your
your lawyer
lawyer
23
23 requesting to
requesting to meet
meet with you, II said,
with you, said, you
you testified
testified yesterday
yesterday
24
24 you were
you were not
not out
out to
to hurt
hurt Michael
Michael Sussmann.
Sussmann. Do you
Do you remember
remember
25
25 that?
that?
1066
1066
1
1 A.
A. Say that
Say that again,
again, sir.
sir.
2
2 THE COURT:
THE COURT: Or you
Or you can
can move
move the
the mic,
mic, one
one way or
way or
3
3 the other.
the other.
4
4 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
5
5 ©.
Q. When we
When started my
we started my cross-examination
cross-examination today,
today, right
right
6
6 before II showed
before showed the
the letter
letter where we requested
where we requested to
to meet
meet with,
with,
7
7 II said,
said, yesterday
yesterday you
you testified
testified that
that you
you were
were not
not out
out to
to
8
8 hurt Michael
hurt Michael Sussmann.
Sussmann. AndAnd you
you said,
said, you
you don't
don't think
think you
you
9
9 said that.
said that. Right?
Right?
10
10 A.
A. I don't
I don't understand
understand your
your question,
question, sir.
sir. I'm
I'm sorry.
sorry.
n
11 ©.
Q. sir, you
Sir, you testified
testified yesterday
yesterday that
that you
you weren't
weren't out
out
12
12 to get
to get Michael?
Michael?
13
13 A.
A. I wasn't
I wasn't out
out to
to get
get Michael,
Michael, yes,
yes, sir.
sir.
14
14 ©.
Q. Okay. Now,
Okay. Now, taking
taking us
us back
back to
to our
our time
time period,
period,
15
15 we've left
we've left you
you getting
getting the
the information
information from
from Mr. Sussmann on
Mr. Sussmann on
16
16 the 19th,
the 19th, and
and you
you immediately
immediately oror very
very close
close afterwards
afterwards
17
17 called Mr.
called Priestap?
Mr. Priestap?
18
18 A.
A. ves, sir.
Yes, sir.
19
19 ©.
Q. And you
And you had
had aa conversation
conversation with
with him.
him. Correct?
Correct?
20
20 A.
A. Yes, sir.
Yes, sir.
21
21 ©.
Q. Now we've
Now we've seen
seen notes
notes of
of the
the conversation.
conversation.
22
22 Correct?
Correct?
23
23 A.
A. ves, sir.
Yes, sir.
24
24 ©.
Q. Those refreshed
Those refreshed your
your recollection.
recollection. Correct?
Correct?
25
25 A.
A. Yes, sir.
Yes, sir.
1067
1067
1
1 ©.
Q. so let's
So let's talk
talk just
just briefly
briefly about
about where that
where that
2
2 conversation took
conversation took place.
place. What's
What's your
your memory
memory today
today of
of where
where
3
3 the conversation
the conversation with
with Mr.
Mr. Priestap
Priestap took
took place?
place?
1
4 A.
A. My memory
My memory today
today is
is that
that the
the conversation
conversation took
took
5
5 place on
place on the
the phone.
phone. Because
Because when
when II looked
looked at
at that
that custody
custody
6
6 document, it
document, it said
said that
that II relinquished
relinquished the
the material
material to
to Pete
Pete
7
7 Strzok. Focusing
Strzok. Focusing onon that,
that, II think
think that
that means that Pete
means that Pete came
came
8
8 and got
and got the
the material from me.
material from me. IfIf II had
had gone
gone to
to see
see Bill
Bill inin
9
9 person, II think
person, think II would
would have
have just
just left
left it
it with
with him
him and
and tried
tried
10
10 to get
to rid of
get rid of it
it as
as quickly
quickly as
as possible.
possible. So So that's
that's how
how II am
am
n
11 thinking about
thinking about it
it today.
today.
12
12 ©.
Q. Well these
Well these notes
notes are
are an
an important
important part
part of
of your
your
13
13 testimony, so
testimony, so how
how high
high is
is your
your level
level of
of confidence
confidence as
as to
to
14
14 whether that
whether that conversation
conversation with
with Mr. Priestap was
Mr. Priestap was over
over the
the
15
15 phone or
phone or in
in person?
person?
16
16 A.
A. Based on
Based on the
the chain
chain of
of logic
logic that
that II just
just explained
explained
17
17 to you,
to you, II am
am highly
highly confident
confident that
that it
it was
was over
over the
the phone.
phone.
18
18 ©.
Q. So you're
So you're recreating,
recreating, ifif you
you will, what you
will, what you
19
19 believe happened
believe happened based
based on
on various
various data
data points. Correct?
points. Correct?
20
20 A.
A. My memory
My memory is
is of
of speaking
speaking toto him
him on
on the
the phone,
phone, but
but
21
21 I'm not
I'm not certain
certain about
about that.
that. And
And so
so --
-- but looking at
but looking at these
these
22
22 other pieces,
other pieces, especially
especially the
the chain
chain of
of custody
custody document
document that
that
23
23 IT just
just referenced,
referenced, that
that makes me more
makes me more confident
confident that
that my
my
24
24 memory
memory isis correct
correct that
that it
it was
was on
on the
the phone.
phone.
25
25 ©.
Q. How long
How long was the conversation
was the conversation with
with Mr.
Mr. Priestap?
Priestap?
1068
1068
1
1 A.
A. I don't
I don't think
think itit was
was aa very
very long
long conversation.
conversation.
2
2 [| Ten minutes,
Ten maybe, fifteen
minutes, maybe, fifteen minutes, something like
minutes, something like that.
that.
3
3 ©.
Q. And you
And you didn't
didn't take
take notes
notes of
of that
that conversation,
conversation,
a
4 [| ata you?
did your
5
5 A.
A. No, II did
No, did not.
not.
6
6 ©.
Q. After your
After your conversation
conversation with
with Mr. Priestap, he
Mr. Priestap, he came
came
7
7 || back to
back to you
you and
and said
said that
that they'd
they'd like
like to
to get
get some
some
88 || information back;
information back: is
is that
that correct?
correct? We'd
we'd like
Like to
to have
nave you
you
99 || reach out
reach out to
to Mr.
Mr. Sussmann
sussmann toto ask
ask him
him the
the name
name of
of the
the news
news
10 ||
10 media organization. Correct?
media organization. correct?
un
11 A.
A. Yes.
Yes.
12
12 ©.
Q. And he
And he said,
said, we need more
we need time to
more time to evaluate
evaluate the
the
13 ||
13 data if
data if there's
there's aa story
story coming
coming out,
out, essentially.
essentially. Correct?
correct?
14
14 A.
A. We need
We need more
more time
time to
to evaluate
evaluate the
the data
data because
because the
the
15 ||
15 story will
story will interfere
interfere with
with the
the investigation.
investigation.
16
16 ©.
Q. And you
And you called
called Mr.
Mr. Sussmann
Sussmann onon September
September 21st.
21st.
17 ||
17 correct
Correct?
18
18 A.
A. I think
I think from
from what we looked
what we looked at
at earlier,
earlier, that's
that's
19 |
19 correct.
correct.
20
20 ©.
Q. Let's take
Let's take aa look
look at
at Government's
Exhibit 1400
1400 at
at
21 ||
21 page 93,
Page 93, the
the second-to-last
second-to-last line,
line, which
which is
is in
in evidence.
evidence. So So
22 [
22 or212
9/21?
23
23 A.
A. Uh-huh.
Uh-huh.
2
24 Q
Q. 3:34pm?
3:34 p.m.?
25
25 A.
A. ves.
Yes.
1069
1069
1
1 Q.
Q. From your
From your phone.
phone. Correct?
Correct?
2
2 A.
A. ves.
Yes.
3
3 ©.
Q. That was
That was the
the call
call that
that you
you made
made to
to Mr.
Mr. Sussmann
Sussmann
4
4 two days
two days after
after your
your meeting. Correct?
meeting. Correct?
5
5 A.
A. That looks
That looks right.
right.
6
6 ©.
Q. And the
And the call
call lasted
lasted for
for 13
13 minutes.
minutes. DidDid it
it not?
not?
7
7 A.
A. ves.
Yes.
8
8 ©.
Q. Can you
Can you tell
tell the
the jury
jury what
what happened
happened inin that
that call?
call?
9
9 What did
What did he
he say
say to
to you
you and
and what
what did
did you
you say
say to
to him?
him?
10
10 A.
A. To the
To the best
best ofof my
my recollection,
recollection, II asked
asked him
him toto
n
11 provide us
provide us with the identity
with the identity ofof whatever
whatever news
news organization
organization
12
12 it was
it that was
was that was planning
planning toto publish
publish this
this article
article relatively
relatively
13
13 soon.
soon.
14
14 Q.
Q. What else?
What else?
15
15 A.
A. I don't
I don't remember
remember discussing other matters
discussing other matters inin
16
16 connection with
connection that phone
with that phone call.
call.
17
17 ©.
Q. what did
What did he
he say
say to
to you?
you?
18
18 A.
A. I believe
I believe he
he said
said he
he needed
needed to
to check
check with somebody
with somebody
19
19 -- he
-- he needed
needed some
some time
time to
to --
-- let
let me
me back
back up.
up. HeHe couldn't
couldn't
20
20 answer my
answer question on
my question on the
the phone;
phone; that
that he
he needed
needed to
to have
have aa
21
21 conversation with
conversation with someone
someone or
or aa person or persons
person or persons and
and that
that hehe
22
22 would get
would get back
back to
to me.
me.
23
23 Q.
Q. Is that
Is that the
the extent
extent --
--
24
24 A.
A. Very cordial
Very cordial call.
call. Very
Very friendly
friendly call
call that
that was,
was,
25
25 yeah.
yeah.
1070
1070
1
1 ©.
Q. Is that
Is that the
the extent
extent of
of what
what you
you remember
remember about
about the
the
2
2 13-minute call
13-minute call on
on September
September 21st,
21st, 2016?
2016?
3
3 A.
A. sitting here
Sitting here today,
today, yes,
yes, that's
that's what
what II remember
remember
4
4 about the
about the call.
call. II amam not
not remembering
remembering anything
anything else
else about
about
5
5 that call
that call at
at this
this moment.
moment.
6
6 Q.
Q. Is it
Is it possible,
possible, sir,
sir, that
that in
in that
that call
call
7 || Mr.
7 sussmann said
Mr. Sussmann said to
to you,
you, II need
need toto check
check with
with my clients in
my clients in
8
8 order --
order -- to
to let
let you
you know
know whether
whether II can
can give
give you
you the
the name
name ofof
9
9 the news
the news organization?
organization?
10
10 A.
A. I don't
I don't remember
remember him
him saying
saying that.
that.
n
11 ©.
Q. One way
One way or
or the
the other?
other?
12
12 A.
A. I don't
I don't remember
remember ---- what
what do
do you
you mean
mean one
one way or
way or
13
13 the other?
the other?
14
14 ©.
Q. When you
When you say
say you
you don't remember him
don't remember him saying
saying that,
that,
15
15 sometimes you
sometimes you don't
don't remember.
remember. II don't
don't remember
remember whether
whether he
he
16
16 did or
did or hehe didn't
didn't or
or --
—-
17
17 A.
A. I don't
I don't remember
remember him
him saying
saying anything
anything about
about having
having
18
18 to check
to check with
with clients.
clients.
19
19 ©.
Q. What's your
What's your level
level of
of confidence
confidence onon that
that one,
one, sir?
sir?
20
20 A.
A. I think
I think high.
high.
21
21 ©.
Q. How high?
How high?
22
22 A.
A. igh.
High.
23
23 ©.
Q. You gave
You gave aa percentage
percentage onon the
the meeting on the
meeting on the 19th
19th
24
24 so --
so --
25
25 A.
A. Well, II wouldn't
Well, wouldn't make it aa hundred
make it hundred percent,
percent, yes;
yes;
10m
1071
1
1 that's correct.
that's correct. It's below
It's below that.
that.
2
2 ©.
Q. Anything better
Anything than that?
better than that? II mean --
mean --
3
3 A.
A. seventy-five percent
Seventy-five to --
percent to -- at
at least
least 75
75 percent.
percent.
4
4 ©.
Q. So is
So is it
it 25
25 percent
percent chance
chance that
that he
he mentioned
mentioned
5
5 clients on
clients on that
that call?
call?
6
6 A.
A. I don't
I don't think
think he
he mentioned clients on
mentioned clients on that
that call.
call.
7
7 ©.
Q. But you're
But you're not
not sure.
sure. Are you?
Are you?
8
8 A.
A. I'm very
I'm very confident
confident that,
that, over
over the
the entire
entire period
period ofof
9
9 time that
time that we've
we've been
been talking
talking about,
about, that
that he
he never
never said
said that
that
10
10 he had
he had clients.
clients.
n
11 ©.
Q. sir, you're
Sir, you're not
not sure
sure whether
whether hehe said
said hehe had
had to
to
12
12 check with
check with his
his clients
clients on
on that
that call?
call? That's
That's all
all I'm
I'm asking.
asking.
13
13 A.
A. Well, II don't
Well, don't recall
recall him
him ever
ever saying
saying that
that he
he had
had
14
14 clients in
clients in connection
connection with
with that
that matter
matter ---- with
with that
that matter.
matter.
15
15 Therefore, II conclude
Therefore, conclude that
that on
on this
this call
call he
he did not say
did not say it
it
16
16 either. And
either. And of
of that
that II am
am very
very confident.
confident.
17
17 ©.
Q. And that's
And that's some
some --
-- over
over aa period
period of
of things
things that
that
18
18 happened aa long
happened long time
time ago.
ago. Right,
Right, Mr.
Mr. Baker?
Baker?
19
19 A.
A. It happened
It happened on
on September
September 21,
21, 2016,
2016, five
five years
years ago
ago
20
20 -- more
-- than five
more than five years
years ago.
ago. Sorry.
Sorry.
21
21 ©.
Q. And you
And you are
are arriving
arriving at
at the
the conclusion
conclusion that
that he
he
22 || must
22 not have
must not have mentioned
mentioned client
client on
on the
the call
call because you would
because you would
23
23 have remembered
have remembered if
if he
he did?
did?
24
24 A.
A. I recall
I recall that
that he
he never
never did.
did. Therefore,
Therefore, inin this
this
25
25 call, II conclude
call, conclude he
he didn't
didn't do it either.
do it either.
1072
1072
1
1 ©.
Q. But you
But you can't
can't tell
tell this
this jury,
jury, can
can you,
you, what
what
2
2 [| happened for
happened for 13
13 minutes on that
minutes on that call.
call. Correct?
Correct? You've
You've
33 || essentiatiy summarized
essentially summarized aa one-minute
one-minute call.
carr.
41 A.
A. Yes.
Yes.
55 9.
Q. Now --
Now -—-
66 A.
A. Excuse me.
Excuse me. But
But II believe
believe that
that II had
had to
to explain
explain toto
77 || nin why
him why we
we needed
needed more
more time.
time. I'mI'm sorry.
sorry. I1 believe
believe II needed
needed
88 || to explain
to explain to
to him
nim why
why we
we needed
needed the
the identity
identity ofof the
the reporter
reporter
99 || so that
so that we
we could
could getget the
the extra
extra time
time and
and so
so II --
-- II believe
believe II
10 ||
10 game him
game nim some
some amount
amount ofof background
background with respect to
with respect to that.
that.
un
11 ©.
Q. Do you
Do you know
know whether
whether you
you did?
did?
12
12 A.
A. Do II know
Do know whether
whether II did?
did? No,
No, II don't
don't know
know whether
whether
13 ||
13 I1 did
did because
because I1 don't
don't have
have aa transcript
transcript of
of it
it nor
nor do
do II have
have
14 |
14 notes.
notes.
1s
15 ©.
Q. And this
And this afternoon's
afternoon's questioning
questioning after
after the
the break
break
16 ||
16 nas been
has been going,
going, it it looks
looks like,
like, for
for less
less than
than 13
13 minutes.
minutes. So So
17 ||
17 13 minutes
13 is aa long
minutes is long time,
time, isn't
isn'c it,
it, sir?
sir?
18
18 A.
A. Thirteen minutes
Thirteen is 13
minutes is 13 minutes.
minutes.
13
19 ©.
Q. You then
You then had
had another
another call
call with
with him
him the
the next
next day.
day.
20 |
20 correct?
Correct?
2
21 A.
A. Do you
Do you have
have the
the record
record again?
again? I'm
I'm sorry.
sorry.
22
22 MR. BERKOWITZ: Yes.
MR. BERKOWITZ: Yes. Let's
Let's pull
pull up
up those
those two
two
23 |
23 carts.
calls.
24 ||
24 BY
BY wr.
MR. BERKOWITZ:
BERKOWITZ:
25
25 ©.
Q. So this
So this isis the
the 22nd.
22nd. There
There was
was aa four-minute
four-minute call
call
1073
1073
1
1 and one-minute
and one-minute call.
call. Do you
Do you see
see that?
that?
2
2 A.
A. Yes, II thought
Yes, thought we
we said
said earlier
earlier that
that this
this one,
one,
3
3 based on
based on this
this call
call and
and the
the number
number it
it went
went to
to and
and then
then the
the
4
4 texts, that
texts, that this
this call
call likely
likely went
went to
to my
my executive
executive assistant,
assistant,
5
5 so II didn't
so didn't actually
actually speak
speak to
to him
him in
in this
this call.
call.
6
6 Q.
Q. By this
By this call,
call, let's
let's be
be really
really clear
clear for
for the
the jury,
jury,
7
7 9/22 at
9/22 at 10:28
10:28 for
for 44 minutes. Correct?
minutes. Correct?
8
8 A.
A. Correct.
Correct.
9
9 ©.
Q. Now you
Now you originally
originally testified
testified that
that on
on that
that call
call at
at
10
10 10:28 Mr.
10:28 Mr. Sussmann
Sussmann gave you the
gave you the name
name of
of Eric
Eric Lichtblau.
Lichtblau.
n
11 That's what
That's you initially
what you initially said.
said. Correct?
Correct?
12
12 A.
A. I think
I think that's
that's right,
right, yes.
yes.
13
13 Q.
Q. Then Mr.
Then DeFilippis said
Mr. DeFilippis said --
-- well,
well, wait.
wait. Let
Let me
me
14
14 show you
show you aa text
text at
at 1500
1500 where
where he
he texted
texted you
you at,
at, II think
think it
it
15
15 was 10:34
was 10:34 saying,
saying, II tried
tried to
to reach
reach you
you or
or words
words to
to that
that
16
16 effect.
effect.
17
17 A.
A. ves.
Yes.
18
18 ©.
Q. And that
And that reminded
reminded you
you that
that that
that first
first call
call
19
19 couldn't have
couldn't have been
been when you spoke
when you spoke with
with Mr. Sussmann.
Mr. Sussmann.
20
20 Correct?
Correct?
21
21 A.
A. We eventually
We eventually figured
figured that
that out,
out, yes.
yes.
22
22 ©.
Q. So you
So you are
are speculating
speculating that
that he
he must
must have
have spoken
spoken toto
23
23 your executive
your executive assistant?
assistant?
24
24 A.
A. ves.
Yes.
25
25 ©.
Q. You don't
You don't know
know that,
that, but that's your
but that's your best
best belief.
belief.
1074
1074
1
1 Correct?
Correct?
2
2 A.
A. Yes --
Yes -- well,
well, based on the
based on the text
text that
that Michael
Michael said
said
3
3 that he
that he had
had called.
called.
4
4 Q.
Q. And then
And then he
he calls
calls you
you at
at 11:04,
11:04, and
and you
you speak
speak for
for
5
5 approximately aa minute,
approximately according to
minute, according to the
the phone
phone records.
records.
6
6 Correct?
Correct?
7
7 A.
A. I don't
I don't see
see the
the 11
11 --
-- no,
no, the
the 11:04
11:04 is
is aa different
different
8
8 number.
number.
9
9 @.
Q. okay.
Okay.
10
10 MR. BERKOWITZ: Do
MR. BERKOWITZ: Do we
we have
have the
the follow-up
follow-up call?
call?
1
11 THE WITNESS:
THE WITNESS: There's another
There's another thing
thing below
below that,
that, II
12
12 think.
think.
13
13 MR. BERKOWITZ: 11:05.
MR. BERKOWITZ: 11:05. You're
You're right.
right.
14
14 THE WITNESS:
THE There we
WITNESS: There we go.
go. 11:05.
11:05. Yep.
Yep.
15
15 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
16
16 Q.
Q. So that's
So that's --
-- you
you think
think that's
that's the
the number.
number. That's
That's
17
17 a two-minute
a two-minute call.
call. Right?
Right?
18
18 A.
A. ves, sir.
Yes, sir.
19
19 ©.
Q. And in
And in that
that call,
call, your
your recollection
recollection isis what
what of
of
20
20 that two-minute
that two-minute call?
call?
21
21 A.
A. That --
That -- I'm
I'm deducing
deducing that
that this
this is
is the
the call
call in
in
22
22 which he
which he provided
provided meme with
with the
the name
name of
of the
the reporter.
reporter.
23
23 @.
Q. Eric Lichtblau.
Eric Lichtblau. Correct?
Correct?
24
24 A.
A. ves, sir.
Yes, sir
25
25 Q.
Q. I think
I think you
you testified,
testified, Mr.
Mr. Baker,
Baker, that
that there
there was a
was a
1075
1075
1
1 [| tremendous amount
tremendous amount of
of activity
activity relative
relative to
to aa Russia
Russia
2 ||
2 investigation that
investigation that was
was going on.
going on. Correct?
Correct?
3
3 A.
A. Yes, sir.
Yes, sir.
4
4 ©.
Q. Something called
Something called Crossfire Hurricane?
Crossfire Hurricane?
5
5 A.
A. Yes, sir.
Yes, sir.
6
6 ©.
Q. And that
And that was the FBI
was the FBI code
code name
name for
for investigations
investigations
7 ||
7 into potential
into potential links
1inks between
between Russia
mussia and
and Mr. Trump
Mr. Trump?
8
8 A.
A. Mr. Trump
Mr. Trump and
and his
his campaign.
campaign.
9
9 Just to
Just to be
be clear,
clear, Crossfire
Crossfire Hurricane
Hurricane was
was the
the
10 ||
10 umbrella investigation,
umbrella investigation, andand there
there were
were aa number
number of
of
11 |
11 subinvestigations under
subinvestigations under that
that umbrella
umbrella investigation.
investigation.
12
12 ©.
Q. Now, I'm
Now, I'm going to fast
going to fast forward
forward and
and I'm
I'm going
going toto do
do
13 ||
13 as much
as of this
much of this chronologically
chronologically as as I1 can.
can. I'm
1'm going
going toto fast
fast
14 ||
14 forward to
forward to March of 2017.
March of 2017. Soso we
we were
were just
just in
in September.
september.
15 [|
15 after that call
After that call where
where Mr.
Mr. Sussmann
sussmann provided you with
provided you with the
the
16 |
16 name of
name of Eric
Eric Lichtblau,
Licntblau, you
you didn't
didn't speak
speak with
with him
him again
again
17 ||
17 about this
about this matter and Alfa-Bank
matter and Alfa-Bank inin 2016
2016 or
or 2017.
2017. Correct?
Correct?
18 ||
18 that was
That was the
the last
last contact?
contact?
19
19 A.
A. That's to
That's to the
the best
best of
of my recollection, yes,
my recollection, yes, sir.
sir.
20
20 ©.
Q. So in
So in March
March of
of 2017,
2017, do you recall
do you recall attending
attending aa
21 ||
21 meeting with Acting
meeting with Acting Attorney General Dana
Attorney General Dana Boente
Boente --
--
22
22 A.
A. Dana Boente.
Dana Boente.
23
23 ©.
Q. Thank you.
Thank you.
24
24 A.
A. II attended
attended various
various meetings
meetings with
with the
the Department.
Department.
25 ||
25 and I1 know
And know I've
I've met with Dana.
met with pana. Andand he
he eventually
eventually waswas my
my
1076
1076
1
1 successor at
successor at the
the Office
Office --
-- he
he became
became the
the General
General Counsel
Counsel at
at
2
2 the FBI,
the FBI, so
so I've
I've met
met with
with Dana.
Dana.
3
3 ©.
Q. I am
I am talking
talking specifically,
specifically, and
and I'll
I'll be
be as
as clear
clear as
as
4
4 II can
can about
about aa March
March 6th,
6th, 2017
2017 meeting
meeting where
where Trisha
Trisha Anderson,
Anderson,
5
5 yourself --
yourself -- and
and we'll
we'll run
run through
through who
who these
these people
people are
are --
--
6
6 Jim Rybicki,
Jim Rybicki, Carl
Carl Gaddis,
Gaddis, Andy
Andy McCabe, Bill Priestap,
McCabe, Bill Priestap, Mary
Mary
7 || Mecord,
7 Tasha, and
McCord, Tasha, and --
-- II always
always confuse
confuse her
her name
name --
-- Gauhar --
Gauhar --
8
8 A.
A. Gavhar.
Gauhar.
9
9 ©.
Q. Gauhar, Dana
Gauhar, Dana Boente
Boente and
and others
others were
were at
at debriefing
debriefing
10
10 on the
on the status
status or
or update
update ofof various
various portions
portions ofof the
the FBI's
FBI's
n
11 Russia investigation.
Russia investigation. Do Do you
you remember
remember that
that meeting?
meeting?
12
12 A.
A. only vaguely.
Only vaguely.
13
13 ©.
Q. Okay. Tell
Okay. Tell me
me what
what you
you recall
recall about
about it.
it.
14
14 A.
A. That at
That at some
some point in time
point in time we
we had
had some
some briefing
briefing
15
15 for Dana
for Dana about
about case-related
case-related matters.
matters.
16
16 ©.
Q. Let's take
Let's take aa look
look at
at aa meeting
meeting invite,
invite, which
which I'll
I'll
17 || mark
17 for identification
mark for identification as as DX-559.
px-s59.
18
can blow
blow that
that up,
up, Mr. Cleaves.
Mr. Cleaves.
19
19 II move
move into
into evidence
evidence Defense
Defense Exhibit
Exhibit 559.
559.
20
20 MR.
MR. ALGOR:
ALGOR: NoNo objection.
objection.
2
21 THE COURT:
THE COURT: So So admitted.
admitted.
22
22 (Defense Exhibit
(Defense Exhibit A10
A10 was
was admitted.)
admitted.)
23 | BY
23 BY Mr.
MR. BERKOWITZ:
BERKOWITZ:
24
24 ©.
Q. So this
So this is
is March
March of
of 2017
2017 on
on our
our chronology
chronology and
and it
it
25
25 says, "briefing
says, "briefing for
for the
the ADAG".
ADAG". DoDo you
you see
see that?
that?
1077
1077
1
1 A.
A. ves, sir.
Yes, sir.
2
2 9.
Q. Can you
Can you explain
explain for
for the
the jury
jury what an ADAG
what an is?
ADAG is?
3
3 A.
A. That means
That the Acting
means the Acting Deputy
Deputy Attorney General.
Attorney General.
4
4 ©.
Q. And that
And that is
is aa pretty
pretty senior
senior role.
role. Correct?
Correct?
5
5 A.
A. It was
It was the
the acting
acting number
number two
two person of the
person of the
6
6 || vepartment of
Department of Justice.
sustice.
7
7 ©.
Q. And at
And at the
the time,
time, the
the attorney
attorney general
general was
was Attorney
Attorney
8
8 || cenerar Sessions;
General sessions: isis that
that right?
rignez
9
9 A.
A. I don't
I don't remember
remember when he was
when he confirmed.
was confirmed.
10
10 Q.
Q. He recused
He recused himself
himself from
from the
the investigation?
investigation?
un
11 A.
A. He did
He did recuse
recuse himself
himself from
from the
the Russia
Russia
12 |
12 investigation. Yes,
investigation. ves, sir.
sir.
13
13 9.
Q. So was
So was Dana
Dana Boente
Boente the
the highest-ranking
highest-ranking person
person from
from
14 ||
14 the attorney
the attorney general's
general's office
office that
that had
had oversight
oversight over
over this
this
15 |
15 investigation?
investigation?
16
16 A.
A. He was
He was not
not part
part of
of the
the attorney
attorney general's
general's office.
office.
17 ||
17 se was
He was part of the
part of the Deputy
peputy Attorney
Attorney General's
General's office.
office. But
But
18 ||
18 for the
for the purposes
purposes of
of those
those investigations
investigations oror --
-- Crossfire
Crossfire
19 ||
19 nurricane, let's
Hurricane, let's say,
say, hehe would
would have
have been
been the
the highest-ranking
highest-ranking
20 [[
20 person in
person in the
the Department
Department working
working on
on that
that matter.
matter.
21
21 ©.
Q. And there
And there were
were senior
senior people
people from
from the
the FBI
FBI there
there as
as
22 [[
22 weil. Correct?
well. correct?
23
23 A.
A. Let me
Let me just
just look
look at
at it
it for
for aa second.
second. Yes.
Yes.
2
24 9.
Q. Who is
Who is Andrew
Andrew McCabe?
McCabe?
25
25 A.
A. At this
At this point
point in
in time,
time, he
he was
was the
the Deputy
Deputy Director
Director
1078
1078
1
1 || of
of the
tne FBI,
ear, the
the number
number two
two guy at the
guy at tne FBI.
Fer.
22 ©.
Q. so right
So right below --
below --
33 A.
A. Right below
Right below Jim
Jim Comey,
Comey, yes,
yes, sir.
sir.
44 ©.
Q. And you
And you see
see Jim
Jim Rybicki,
Rybicki, who's that?
who's that?
55 A.
A. He was
He was the
the Chief
Chief ofof Staff
Staff to
to the
the Director
Director of
of the
the
66 || FBI.
eer. He's
me's Chief
chief of
of Staff
stars to
to Jim
Jim Comey.
comey.
77 ©.
Q. And you
And you are
are listed,
listed, James
James Baker.
Baker. Correct?
Correct?
88 A.
A. Yes, sir.
Yes, sir.
99 ©.
Q. 0GC, Office
OGC, of General
Office of General Counsel,
Counsel, FBI?
FEI?
10
10 A.
A. Correct.
Correct.
un
11 ©.
Q. And the
And the meeting
meeting organizer
organizer oror at
at least
least of
of this
this
12 | calendar
12 calendar is
is Tashina
Tashina Gauhar?
Gauharz
13
13 A.
A. ves, sir.
Yes, sir.
14
14 Q.
Q. Who is
Who is she?
she?
15
15 A.
A. At this
At this point
point in
in time,
time, she
she was
was an
an Associate Deputy
Associate Deputy
16 | attorney
16 General working
Attorney General working onon the
the staff
staff ofof the
the Deputy
Deputy Attorney
Attorney
17 || General.
17 ceneral. And
and her
ner portfolio
portfolio waswas national
national security.
security.
18
18 ©.
Q. And did
And did you
you know
know Ms. Gauhar at
Ms. Gauhar at the
the time?
time?
19
19 A.
A. I had
I had known
known her
her for
for aa long
long time.
time. II had
had hired
hired her
her
20 || into
20 into the
the department.
department.
21
21 ©.
Q. Did you
Did you respect
respect her
her at
at the
the time?
time?
22
22 A.
A. Yes.
Yes.
23
23 ©.
Q. Found her
Found her to
to be ethical?
be ethical?
2
24 A.
A. Yes. Absolutely.
Yes. Absolutely.
25
25 @.
Q. Now, you
Now, you said
said that
that you
you had
had aa vague recollection of
vague recollection of
1079
1079
1
1 this meeting.
this meeting. Correct?
Correct?
2
2 A.
A. ves, sir.
Yes, sir.
3
3 ©.
Q. Can you
Can you tell
tell the
the jury,
jury, as
as best
best you
you can,
can, what
what your
your
4
4 vague recollection
vague recollection of
of the
the meeting
meeting is?
is?
5
5 A.
A. That there
That there was
was some
some briefing
briefing for
for Dana
Dana on
on aa number
number
6
6 of case-related
of case-related matters.
matters.
7
7 Q.
Q. Anything else?
Anything else?
8
8 A.
A. That's about
That's about it.
it.
9
9 ©.
Q. And you
And you attended.
attended. Correct?
Correct?
10
10 A.
A. I believe
I believe so,
so, yes.
yes. If
If II remember
remember it,
it, therefore
therefore II
1
11 attended it.
attended it. Yes,
Yes, sir.
sir.
12
12 Q.
Q. Okay. Let
Okay. Let me
me show
show you
you what
what we'll
we'll marked for
marked for
13
13 identification as
identification as DX-558.
DX-558. II move
move into
into evidence
evidence Defense
Defense
14
14 Exhibit 558?
Exhibit 5587
15
MR. DeFILIPPIS: No objection,
objection, Your
Your Honor.
Honor.
16
16 THE COURT:
So moved.
17
17 (Defense Exhibit
558 was
was admitted.)
admitted.)
18
18 MR. BERKOWITZ: And
MR. BERKOWITZ: And if
if we
we could
could just
just blow out the
blow out the
19
19 top of
top of that,
that, Mr.
Mr. Cleaves.
Cleaves.
20
20 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
21
21 Q.
Q. It says
It says "Brief
"Brief for
for DAG".
DAG". Appear to say
Appear to say that?
that?
22
22 A.
A. ves, sir.
Yes, sir.
23
23 Q.
Q. It says
It says "Focus
"Focus on
on Russians".
Russians".
24
24 A.
A. ves.
Yes.
25
25 @.
Q. I'm going
I'm going to
to move us to
move us to Page
Page 66 of
of that
that exhibit.
exhibit.
1080
1080
1
1 || Do
vo you
vou recognize
recognize Ms.
ms. Gauhar's
caunar's handwriting
handwriting byby any
any chance?
chance?
2
2 A.
A. vo.
No.
3
3 MR. BERKOWITZ: If
MR. BERKOWITZ: If you
you could
could blow out the
blow out the middle
middle
4 || of
4 of the
the page -- above
page -- above that
that if
if you
you will.
will. Yeah,
vean, from
from there
there onon
5s [| down.
5 gown.
6 || BY
6 BY mr.
MR. eemxowrrz:
BERKOWITZ:
7
7 9.
Q. I'm going
I'm going to
to read
read it.
it. So
So if
if you
you think
think I've
I've
8 || misread
8 it, let
misread it, 1et me know. It
me know. 1c says,
says, server-late
server-late summer,
summer, FBI
Fer
9 || got
9 got info.
info. Computer
computer server
server connected
connected toto Alfa-Bank. That is
Alfa-Bank. That is
10 | aa Russian
10 Russian bank.
bank. ItIt says
says maybe
maybe Mccabe
McCabe ---- I'm
I'm not
not sure
sure but
but
11 || Freedman.
11 rreeaman. Russian
Russian oligarch
oligarch connected
connected toto Putin.
Putin. Something
Something
12 || with
12 with bank
bank plus
plus server
server of
of Trump
Trump organization.
Organization.
13
13 And then
And then below that it
below that it says,
says, "attorney"
"attorney" brought
brought toto
14 [| FBI
14 #1 onon behalf of his
behalf of his client.
client. Also
Also advised
advised others
others inin media
media
15 || NYT.
15 wvr. Dopo you
you see
see that,
that, sir?
sir?
16
16 A.
A. Yes.
Yes.
17
17 9.
Q. Do you
Do you recall
recall anybody
anybody at
at the
the meeting saying that,
meeting saying that,
18 || with
18 with respect
respect toto the
the server
server allegations,
allegations, anan attorney
attorney had
had
19 || brought
19 vrougnt toto the
the FBI
FBI on
on behalf
behalf of
of his
his client?
client?
20
20 A.
A. Do II recall
Do recall --
-- say
say that
that again,
again, sir.
sir.
21
21 ©.
Q. Do you
Do you recall
recall anybody
anybody at
at the
the meeting saying that
meeting saying that
22
22 [the information
the information about
about Russia
Russia and
and Alfa-Bank
Alfa-Bank had
had been brought
been brought
23 || to
23 to the
the FBI
FBI by an attorney
by an attorney on
on behalf
behalf of
of his
his client?
client?
2
24 A.
A. I don't
I don't recall
recall that.
that.
25
25 Q.
Q. Were you
Were you shown
shown these
these notes
notes before,
before, sir?
sir?
1081
1081
1
1 A.
A. No.
No.
2
2 Q.
Q. When your
When your recollection
recollection was
was refreshed
refreshed with
with
3
3 Mr. Priestap's
Mr. Priestap's notes,
notes, were
were you
you shown
shown these
these notes?
notes?
4
4 A
A. No.
No.
5
5 Q.
Q. This is
This is the
the first
first time
time you
you are
are seeing
seeing these
these notes,
notes,
6
6 sir?
sir?
7
7 A.
A. I've seen
I've seen them
them referenced
referenced in
in the
the public.
public.
8
8 @.
Q. You've read
You've read articles
articles about
about the
the case?
case?
9
9 A.
A. About this
About this case?
case?
10
10 Q.
Q. ves.
Yes.
1
11 A.
A. ves.
Yes.
12
12 @.
Q. Is your
Is your testimony
testimony today
today influenced
influenced at
at all
all by
by what
what
13
13 you've read
you've read outside
outside of
of this?
this?
14
14 A.
A. No, II am
No, am giving you the
giving you the best
best testimony
testimony II possibly
possibly
15
15 can based
can based on
on my
my recollection
recollection and
and review
review of
of the
the documents
documents
16
16 that are
that are in
in evidence.
evidence.
17
17 Q.
Q. And recollection
And recollection of
of events
events that
that happened
happened well over
well over
18
18 five years
five years ago.
ago. Correct?
Correct?
19
19 A.
A. ves, sir.
Yes, sir.
20
20 @.
Q. Okay. Do
Okay. Do you
you remember,
remember, sir,
sir, anybody
anybody at
at this
this March
March
21
21 6th meeting
6th talking about
meeting talking about an
an attorney
attorney bringing
bringing information
information
22
22 about the
about the Trump-Russia
Trump-Russia thing
thing on
on behalf
behalf of
of his
his clients?
clients?
23
23 A.
A. I don't
I don't remember
remember that.
that.
24
24 @.
Q. Do you
Do you remember
remember standing
standing up
up and
and saying,
saying, No,
No, you've
you've
25
25 got it
got it wrong.
wrong. He didn't
He didn't have
have any
any clients?
clients?
1082
1082
1
1 A.
A. No, II don't
No, don't remember
remember that.
that.
2
2 ©.
Q. Do you
Do you have
have any
any idea
idea what the source
what the source ofof that
that
3
3 [[ information was,
information was, sir?
sirz
1
4 A.
A. I don't
I don't recall
recall providing
providing the
the briefing
briefing myself.
myself. So So
5
5 || 1m not
I'm not sure
sure who
wno --
-- can
can you
you --
-- I'm
I'm not
not sure.
sure. II can't
can't
66 || remember all
remember all of
of the
the FBI
Fer attendees
attendees there.
there. IfIf it
it was
was for
for the
the
77 || vac, it
DAG, it was
was probably
probably Andy
andy McCabe
Mccabe that
that was
was giving
giving the
the
88 [| briefing, so
briefing, so it
it was
was probably
probably Andy
Andy that
that was
was going through
going through
9s [I ens.
this.
10
10 ©.
Q. Do you
Do you remember
remember thinking
thinking II should
should correct
correct him?
him?
un
11 A.
A. No, II don't
No, don't remember
remember that.
that.
12
12 ©.
Q. Number two
Number two guy
guy in
in the
the FBI?
FBI?
13
13 A.
A. No, II don't
No, don't remember
remember doing that or
doing that or thinking
thinking that.
that.
14
14 9.
Q. Does seeing
Does seeing somebody
somebody else's
else's notes
notes of
of aa meeting
meeting
15 [|
15 that you
that you attended
attended refresh
refresh your
your recollection
recollection about
about the
the fact
fact
16 |
16 that Mr.
that Mr. Sussmann
Sussmann brought
brought the
the information
information to
to the
the FBI
FBI on
on
17 ||
17 behalf of
behalf of his
nis clients?
clients?
18
18 A.
A. To the
To the contrary.
contrary.
13
19 ©.
Q. You still
You still believe
believe that
that he
he never
never told
told you
you that
that itit
20 ||
20 was on
was on behalf of his
behalf of his clients.
clients. correct?
Correct?
2
21 A.
A. That's what
That's what II believe
believe and
and recall
recall sitting
sitting here
here
22 ||
22 today, to
today, to the
the best
best of
of my
my recollection.
recollection.
23
23 ©.
Q. All right.
All right. Let's
Let's move on because
move on because that's
that's March
March ofof
24
24 "17. You
'17. You are
are then
then questioned
questioned in in October
October of
of 2018.
2018. Correct?
Correct?
25
25 A.
A. In the
In the Congressional
Congressional -- -- is
is that
that what
what you
you are
are
1083
1083
1
1 referring to,
referring to, the
the Congressional
Congressional testimony?
testimony?
2
2 ©.
Q. (Nodded head)
(Nodded head)
3
3 A.
A. ves.
Yes.
4
4 ©.
Q. And Mr.
And Mr. DeFilippis
DeFilippis took
took you
you through
through some
some of
of the
the
5
5 sworn testimony.
sworn testimony. I'mI'm going
going to
to do
do the
the same
same just
just to
to make sure
make sure
6
6 that we
that we are
are marching through this
marching through this and
and everybody
everybody has
has aa sense
sense
7
7 of the
of the timing.
timing. Okay?
Okay?
8
8 A.
A. Certainly.
Certainly.
9
9 ©.
Q. And when
And when you
you gave voluntary information
gave voluntary information toto
10
10 Congress, you
Congress, you understood
understood that
that you
you were
were under
under oath?
oath?
n
11 A.
A. II don't
don't think
think II was
was under
under oath,
oath, but
but II understood
understood
12
12 that it's
that it's aa crime
crime to
to make
make false
false statements
statements to
to Congress.
Congress.
13
13 ©.
Q. So you
So you tried
tried to
to be
be as
as careful
careful as
as you
you could.
could.
14
14 Correct?
Correct?
15
15 A.
A. II tried
tried to
to be
be as
as careful
careful as
as II could
could in
in that
that
16
16 environment, yes,
environment, yes, sir.
sir.
17
17 ©.
Q. You tried
You tried to
to be as truthful
be as truthful as
as you
you could?
could?
18
18 A.
A. (No response)
(No response)
19
19 ©.
Q. Tried to
Tried to be as truthful
be as truthful as
as you
you could?
could?
20
20 A.
A. Yes, sir.
Yes, sir.
21
21 MR. BERKOWITZ: So
MR. BERKOWITZ: So let's
let's take
take aa look
look at
at the
the
22
22 testimony. This
testimony. This is
is JB-03
JB-03 and,
and, Mr. DeFilippis, what
Mr. DeFilippis, was the
what was the
23
23 Government Exhibit
Government Exhibit if
if you
you recall?
recall?
24
24 Actually, it's
Actually, it's Government's
Exhibit 57.
57. IfIf we
we
25
25 could go
could go to
to Page
Page 53.
53.
1084
1084
1
1 || BY
BY mr.
MR. eerxowrrz:
BERKOWITZ:
22 ©.
Q. I want
I want to
to focus
focus on
on when
when Mr.
Mr. Sussmann
Sussmann came
came toto you.
you.
33 || Sir,
sir, were
were you
you asked
asked these
these questions
questions and
and did
did you
you give
give these
these
42 [| answers?
answers2
55 Q. Okay.
Q. Okay. So So when
when Mr.
Mr. Sussmann
Sussmann came
came to
to
66 provide you
provide you evidence,
evidence, you
you were not specifically
were not specifically
77 aware that
aware that he
he was representing the
was representing the DNC
DNC or
or the
the
88 Hillary Clinton
Hillary Clinton campaign
campaign atat the
the time?
time?
99 A.
A. IIdon't recall. II don't
don't recall. don't recall
recall him
him
10
10 specifically saying
specifically saying that
that at
at that
that time.
time.
un
11 Sir, that
Sir, that was
was the
the answer
answer toto the
the question.
question.
12 | Correct?
12 correct?
13
13 A.
A. ves, sir.
Yes, sir.
14
14 ©.
Q. And you
And you didn't
didn't volunteer,
volunteer, not
not only
only do
do II not
not
15 || specifically
15 specifically recall
recall him
him saying
saying that,
that, but
but he
he affirmatively
affirmatively
16 | told
16 told me
me that
that he
ne wasn't
wasn't there
there on
on behalf
behalf of
of clients.
clients. YouYou
17 || didn't
17 didn't offer
offer that
that information?
information?
18
18 A.
A. I did
I did not
not say
say that;
that; that's
that's correct.
correct.
13
19 Q.
Q. Is that
Is that because
because you
you didn't
didn't remember
remember it
it at
at that
that
20
20 [time or
time or you
you chose
chose to
to hold
hold it
it back?
back?
2
21 A.
A. No. No.
No. It's because
No. It's because II don't
don't think
think II remembered
remembered
22 [[ it
22 it at
at that
that time.
tine.
23
23 ©.
Q. Because, among
Because, among other
other things,
things, you
you said
said you
you weren't
weren't
24 || really
24 really prepared for questioning
prepared for questioning onon that
that topic?
topic?
25
25 A.
A. That's correct.
That's correct.
1085
1085
1
1 Q.
Q. Okay.
Okay. Next question.
Next question.
2
2 Q.
Q. Okay. When Mr.
Okay. When Sussmann did
Mr. Sussmann did provide
provide you
you
3
3 this evidence,
this evidence, did
did you
you react
react in
in any
any way
way with
with
4
4 concern? Were
concern? you alarmed?
Were you alarmed? Were
Were you
you ---- did
did you
you
5
5 believe it
believe it was
was inappropriate
inappropriate forfor him
him to
to come
come to
to
6
6 you with
you with this
this information?
information?
7
7 A.
A. No,
No, II did
did not
not believe
believe it
it was
was
8
8 inappropriate. It
inappropriate. It was
was aa citizen
citizen providing
providing
9
9 information to
information to the
the FBI
FBI about
about aa matter
matter that
that they
they
10
10 thought had
thought had either
either toto do with aa crime
do with crime oror some
some
n
11 national security
national security threat.
threat. And so it
And so it did
did not
not seem
seem
12
12 inappropriate to
inappropriate to me.
me.
13
13 That was
That your answer
was your answer to
to that
that question,
question, sir,
sir, was
was it
it
14
14 not?
not?
15
15 A.
A. ves, sir.
Yes, sir.
16
16 ©.
Q. And then
And then the
the next
next question
question and
and answer,
answer, the
the bottom
bottom
17
17 of the
of the page.
page.
18
18 So II guess
So guess it's
it's just
just my interpretation --
my interpretation --
19
19 MR. BERKOWITZ: We'll
MR. BERKOWITZ: We'll get
get this
this set
set up.
up.
20
20 THE WITNESS:
THE There you
WITNESS: There you go.
go.
2
21 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
22
22 ©.
Q. I'll start
I'll start reading
reading it:
it: So
So II guess
guess it
it is
is just
just my
my
23
23 interpretation, but
interpretation, but II believe
believe last
last round
round --
-- and
and this
this is
is aa
24
24 question --
question -- it
it was somewhat implied
was somewhat implied that
that if
if he
he did
did have
have an
an
25
25 association to
association to the
the Democratic
Democratic National
National Committee
Committee and
and the
the
1086
1086
1
1 Hillary Clinton
Hillary Clinton campaign,
campaign, that
that that
that might lead someone
might lead someone to
to
2
2 believe that
believe that something
something improper
improper was
was done.
done.
3
3 And II wonder
And wonder if
if you
you could
could just
just explain
explain to
to me, you
me, you
4
4 know, why
know, why your
your review
review is
is that
that it
it was
was not
not improper
improper because
because
5
5 just the
just the mere
mere notion
notion that
that someone
someone who
who was
was aa Democrat
Democrat or
or aa
6
6 Republican, you
Republican, you know,
know, comes
comes to
to you
you with information, should
with information, should
7
7 that information
that information somehow
somehow be
be discounted
discounted or
or considered
considered less
less
8
8 credible because
credible because of,
of, you
you know,
know, partisan affiliation?
partisan affiliation?
9
9 Do you
Do you remember
remember that
that question?
question?
10
10 A.
A. Basically, yes.
Basically, yes.
n
11 ©.
Q. And you
And you answered:
answered:
12
12 A.
A. Well, the FBI
Well, the FBI is
is responsible
responsible for
for
13
13 protecting everybody
protecting everybody inin this
this country.
country. Period,
Period,
14
14 full stop.
full stop. And
And we
we do
do that
that without
without regard
regard toto who
who
15
15 they are
they are or
or what
what their
their political
political background
background is is or
or
16
16 anything else.
anything else. IfIf they
they believe
believe they
they have
have evidence
evidence
17
17 of aa crime
of crime or
or believe they have
believe they have been
been aa victim
victim ofof aa
18
18 crime, we
crime, we will do what
will do we can
what we can within our lawful
within our lawful
19
19 authorities to
authorities to protect
protect them.
them. And so when
And so when aa
20
20 citizen comes
citizen comes with evidence, we
with evidence, we accept
accept it.
it. That
That
21
21 is my
is just general
my just general understanding
understanding over
over many, many
many, many
22
22 years. We,
years. We, the
the Bureau,
Bureau, we,
we, the
the Department
Department of of
23
23 Justice. And
Justice. so that
And so that is
is how
how II construed
construed what
what
24
24 Michael was
Michael was doing.
doing. ItIt was,
was, he
he believed
believed hehe had
had
25
25 evidence, again,
evidence, again, either
either of
of aa crime
crime of
of aa national
national
1087
1087
1
1 security threat,
security threat, and
and he
he believed
believed it
it was
was
2
2 appropriate to
appropriate to provide
provide it
it to
to us.
us. When he did,
When he did, II
3
3 didn't think
didn't think there
there was
was anything
anything improper
improper about
about itit
4
4 whatsoever.
whatsoever.
5
5 Were you
Were you asked
asked that
that question
question and
and did
did you
you give that
give that
6
6 answer?
answer?
7
7 A.
A. ves, sir.
Yes, sir.
8
8 ©.
Q. Okay. And,
Okay. And, sir,
sir, whether
whether Mr. Sussmann had
Mr. Sussmann had aa
9
9 political affiliation
political affiliation oror interest
interest in
in providing
providing you
you the
the
10
10 information, if
information, if he
he believed that the
believed that the evidence
evidence was
was aa national
national
n
11 security threat,
security threat, you
you would
would have
have wanted
wanted him
him to
to provide
provide it it to
to
12
12 you. Correct?
you. Correct?
13
13 A.
A. ves.
Yes.
14
14 ©.
Q. You then
You then testified,
testified, sir
sir --
-- well,
well, so
so at
at that
that time
time
15
15 -- that
-- that was
was October
October 3rd.
3rd. Correct?
Correct?
16
16 A.
A. I lost
I lost track
track of
of the
the dates,
dates, but
but II think
think so.
so.
17
17 ©.
Q. I'll take
I'll take aa look
look at
at the
the beginning
beginning just
just to
to orient
orient
18
18 people. October
people. October 3rd
3rd of
of 2018.
2018. And that was
And that was around
around the
the time
time
19
19 that you
that you were
were interviewing
interviewing atat the
the law
law firm
firm of
of Perkins
Perkins Coie.
Coie.
20
20 Correct?
Correct?
21
21 A.
A. Roughly, yes,
Roughly, yes, sir.
sir.
22
22 ©.
Q. And as
And as of
of October
October of
of 2018,
2018, you
you continued
continued toto find
find
23 || Mr.
23 sussmann an
Mr. Sussmann an ethical
ethical and
and honorable
honorable man.
man. Correct?
Correct?
24
24 A.
A. ves.
Yes.
25
25 ©.
Q. You were
You were interested
interested in
in the
the possibility
possibility ofof working
working
1088
1088
1
1 with him
with him at
at his
his law
law firm.
firm. Correct?
Correct?
2
2 A.
A. Yes. Absolutely,
Yes. yes.
Absolutely, yes.
3
3 ©.
Q. And he
And he did
did what
what he
he could
could to
to help
help you
you with
with that.
that.
4
4 Correct?
Correct?
5
5 A.
A. Absolutely, yes.
Absolutely, yes.
6
6 @.
Q. It ended
It ended up
up not
not working
working out.
out. Right?
Right?
7
7 A.
A. correct.
Correct.
8
8 ©.
Q. Then --
Then -- and
and this
this was -- let's
was -- let's be
be clear.
clear. This
This was
was
9
9 a tough
a tough time
time for
for both
both you
you and
and Mr.
Mr. Sussmann
Sussmann in
in terms
terms of
of press
press
10
10 and other
and other things.
things. Right?
Right? You
You talked
talked about
about the
the pressures
pressures
n
11 and things.
and things. ItIt was
was aa very
very tense
tense time.
time. Correct?
Correct?
12
12 A.
A. ves.
Yes.
13
13 Q.
Q. For both
For both of
of you?
you?
14
14 A.
A. ves.
Yes.
15
15 ©.
Q. And you
And you talked
talked about
about the
the strain
strain that
that it
it caused
caused
16
16 upon you
upon you with
with people
people talking
talking about
about hanging
hanging and
and doing
doing that,
that,
17
17 that was
that was both
both for
for you
you and
and Mr.
Mr. Sussmann.
Sussmann. Right?
Right?
18
18 A.
A. I believe
I believe he
he was suffering the
was suffering the same
same kind
kind of
of media
media
19
19 and social
and social media torrent of
media torrent of negativity.
negativity. II don't know how
don't know how
20
20 else to
else to describe
describe it,
it, yes.
yes.
21
21 ©.
Q. And you
And you had
had the
the additional
additional burden
burden of
of being under
being under
22
22 investigation, aa criminal
investigation, criminal investigation,
investigation, atat that
that time,
time, by
by
23 | me.
23 purham
Mr. Durham?
24
24 A.
A. well, yes.
Well, yes. ByBy that
that --
-- just
just to
to be
be clear,
clear, by that
by that
25
25 point in
point in time,
time, II had
had been
been told
told that
that before
before II left
left the
the Bureau
Bureau
1089
1089
1
1 -- let's
-- let's back
back up.
up. Before II left
Before left of
of the
the Bureau,
Bureau, II was
was told
told
2
2 that Mr.
that Mr. Durham
Durham himself
himself had
had completed
completed his
his investigation,
investigation, had
had
3
3 written aa lengthy
written lengthy report,
report, had
had concluded
concluded that
that no
no offenses,
offenses, no
no
4
4 criminal offenses
criminal offenses had
had been
been committed,
committed, and
and he
he had
had submitted
submitted
5
5 that report
that report to,
to, among
among others,
others, the
the FBI,
FBI, that
that the
the report
report had
had
6
6 been referred
been referred to
to the
the security
security division
division of
of the
the FBI
FBI for
for
7
7 whatever further
whatever further actions
actions were
were appropriate,
appropriate, and
and that
that it
it also
also
8
8 had been
had been sent,
sent, II believe,
believe, to
to the
the Department
Department of
of Justice.
Justice.
9
9 ©.
Q. But at
But at the
the --
—-
10
10 A.
A. But just
But just to
to be
be clear,
clear, the
the Department
Department had
had not
not
n
11 declined the
declined the matter
matter at
at that
that point
point in
in time.
time. Does
Does that
that make
make
12
12 sense?
sense?
13
13 ©.
Q. Yes. Let
Yes. Let me just clarify.
me just clarify. AsAs of
of October
October 3rd,
3rd, the
the
14
14 day we
day we just
just went
went over
over and
and you
you testified,
testified, your
your lawyer
lawyer refused
refused
15
15 you --
you -- refused
refused to
to allow
allow you
you to
to answer
answer questions
questions because
because hehe
16
16 said you
said you were
were under
under investigation
investigation byby John
John Durham
Durham at
at that
that
17
17 time. Correct?
time. Correct?
18
18 A.
A. The investigation
The investigation was
was still
still open
open at
at that
that time.
time.
19
19 That's correct.
That's correct.
20
20 ©.
Q. Let's take
Let's take aa look
look at
at that
that same
same exhibit
exhibit we
we were
were
21
21 looking at,
looking at, Page
Page 37,
37, start
start with
with Mr. Jordan, all
Mr. Jordan, all the
the way
way to
to
22
22 the bottom.
the bottom.
23
23 And your
And your lawyer
lawyer was
was present
present with
with you
you on
on October
October
24
24 3rd, 2018.
3rd, 2018. Correct?
Correct?
25
25 A.
A. Yes, sir.
Yes, sir.
1090
1090
1
1 ©.
Q. And he
And he says:
says: Just
Just toto clarify
clarify for
for us
us --
-- Mr.
Mr. Jordan
Jordan
2
2 says --
says -- your
your counsel,
counsel, advising
advising Mr. Baker not
Mr. Baker not to
to answer
answer that
that
3
3 question because
question because of
of ---- not
not because of it's
because of it's classified
classified ---- not
not
4
4 because of
because of any
any classification
classification concerns,
concerns, but
but because
because there's
there's
5
5 an ongoing
an ongoing investigation
investigation by by whom?
whom?
6
6 MR. LEVIN [your
MR. LEVIN [your lawyer]:
lawyer]: TheThe Justice
Justice
7
7 Department.
Department.
8
8 MR. JORDAN: II mean,
MR. JORDAN: mean, is
is the
the Inspector
Inspector
9
9 General looking
General looking atat this
this or
or this
this --
--
10
10 MR. LEVIN: No,
MR. LEVIN: No, it's
it's Mr. John Durham,
Mr. John Durham, aa
n
11 prosecutor.
prosecutor.
12
12 MR. JORDAN: Mr.
MR. JORDAN: Huber?
Mr. Huber?
13
13 MR. LEVIN: Durham.
MR. LEVIN: Durham. Durham.
Durham.
14
14 Both say
Both say it
it again.
again.
15
15 MR. LEVIN: John
MR. LEVIN: John Durham.
Durham.
16
16 So that
So that is
is what
what you
you at
at least
least knew
knew as
as of
of October
October 3,3,
17
17 2018. Correct?
2018. Correct?
18
18 A.
A. ves, sir.
Yes, sir.
19
19 ©.
Q. And having
And having been
been asked
asked in
in your
your testimony
testimony that
that was
was
20
20 subject to
subject to perjury
perjury onon October
October 3rd
3rd about
about your
your interactions
interactions
21
21 with Mr.
with Mr. Sussmann
Sussmann ----
22
22 A.
A. ves, sir.
Yes, sir.
23
23 ©.
Q. -- you
-- you were
were called
called back
back aa little
little over
over two
two weeks
weeks
24
24 later, on
later, on October
October 18th
18th on
on 2018.
2018. Correct?
Correct?
25
25 A.
A. Correct.
Correct.
1091
1091
1
1 ©.
Q. And at
And at that
that point,
point, there
there was not aa surprise
was not surprise
2
2 element. In
element. In other
other words, you knew,
words, you knew, given
given the
the media
media and
and
3
3 other things,
other things, that
that there
there might
might be additional questioning
be additional questioning
4
4 about your
about your interaction
interaction with
with Mr. Sussmann. Correct?
Mr. Sussmann. Correct?
5
5 A.
A. Yes.
Yes.
6
6 ©.
Q. And did
And did you
you go
go back
back and
and prepare
prepare for
for it
it in
in any
any more
more
7
7 detail, sir?
detail, sir?
8
8 A.
A. I don't
I don't think
think so,
so, no.
no.
9
9 ©.
Q. But you
But you weren't
weren't surprised
surprised this
this time
time around.
around.
10
10 Correct?
Correct?
n
11 A.
A. correct.
Correct.
12
12 ©.
Q. And you
And you knew
knew you
you were
were ---- you
you were subject to
were subject to
13
13 perjury in
perjury in answering
answering their
their questions. Correct?
questions. Correct?
14
14 A.
A. I don't
I don't know
know about
about perjury
perjury but
but false
false statements.
statements.
15
15 II don't
don't know
know what
what the
the exact
exact crime
crime is.
is. You
You can't
can't make
make aa
16
16 false statement
false statement toto Congress. That much
Congress. That much II know.
know.
17
17 ©.
Q. You were
You were subject
subject to
to prosecution
prosecution ifif --
--
18
18 A.
A. If II made
If made aa false
false statement;
statement; that's
that's correct.
correct.
19
MR. BERKOWITZ: So let's
let's take
take aa look
look at
at Page
Page 122.
122.
20
20 And let's
And let's start
start with
with Mr.
Mr. Jordan
Jordan inin the
the middle
middle ofof the
the page
page
21
21 and was
and was he
he representing
representing aa client?
client?
22 | BY
22 BY mr.
MR. ERxowrTZ:
BERKOWITZ:
23
23 ©.
Q. I'll read
I'll read the
the questions.
questions. Again, this is
Again, this is the
the same
same
24
24 Mr. Jordan that
Mr. Jordan that we've
we've seen
seen before. Correct?
before. Correct?
25
25 A.
A. Yes, sir.
Yes, sir.
1092
1092
1
1 MR. JORDAN: And
MR. JORDAN: was he
And was he representing
representing aa
2
2 client when
client when he
he brought
brought this
this information
information toto you?
you?
3
3 Or just
Or just out
out of
of the
the goodness
goodness ofof his
his heart,
heart, someone
someone
4
4 gave it
gave it to
to him
him and
and he
he brought it to
brought it to you?
you?
5
5 MR. BAKER: In
MR. BAKER: In that
that first
first interaction,
interaction, II
6
6 don't remember
don't remember him
him specifically
specifically saying
saying that
that he
he was
was
7
7 acting on
acting on behalf
behalf ofof aa particular client.
particular client.
8
8 And that
And that was your recollection
was your recollection at
at the
the time?
time?
9
9 A.
A. ves, sir.
Yes, sir.
10
10 ©.
Q. You didn't
You didn't say,
say, No,
No, he
he specifically
specifically told
told me he was
me he was
n
11 not acting
not acting onon behalf
behalf of
of aa client.
client. You
You didn't
didn't say
say that.
that.
12
12 Correct?
Correct?
13
13 A.
A. I did
I did not
not say
say that.
that.
14
14 Q.
Q. That's because
That's because II think
think you
you said
said you
you were
were taking
taking aa
15
15 different angle
different angle on
on answering
answering hishis question.
question. Were
Were you
you being
being
16
16 careful here?
careful here?
17
17 A.
A. Idon't
I know. II was
don't know. trying to
was trying to answer
answer his
his question
question
18
18 to the
to the best of my
best of ability under
my ability under these
these circumstances.
circumstances. As As II
19
19 said earlier,
said earlier, this
this was
was aa --
-- the
the whole
whole thing
thing was
was terrible,
terrible,
20
20 and II was
and was doing
doing the
the best
best that
that II could
could to
to answer
answer the
the
21
21 questions truthfully.
questions truthfully.
22
22 ©.
Q. And this
And this is
is aa pretty
pretty terrible
terrible experience
experience asas well.
well.
23
23 Right?
Right?
24
24 A.
A. It's more
It's orderly.
more orderly.
25
25 ©.
Q. (Gestured with
(Gestured with hand
hand to
to ear.)
ear.)
1093
1093
1
1 A.
A. This is
This is more
more orderly.
orderly. It's
It's terrible
terrible but orderly.
but orderly.
2
2 ©.
Q. And you're
And you're doing
doing the
the best you can.
best you can. Right,
Right, sir?
sir?
3
3 A.
A. Yes, sir.
Yes, sir.
4
4 ©.
Q. But it's
But it's hard
hard to
to remember
remember events
events from
from aa long
long time
time
5s
5 [| ago, isn't
ago, 1snre it?
sez
6
6 A.
A. It depends
It depends on
on what
what the
the event
event is.
is. II remember
remember Jim
Jim
7
7 || comey being
Comey being fired,
fire, for
for example.
exampie. That's
That's aa long
long time
time ago
ago and
ana
8 ||
8 I1 have
nave aa clear
clear recollection
recollection ofof that.
that. So so it
it depends
depends on
on what
what
3 [|
9 vourre talking
you're tarking about.
avout.
10
10 ©.
Q. It depends
It depends on
on what
what you're
you're talking
talking about.
about. And
And
11 ||
11 remembering whether
remembering whether somebody
somebody said
said they
they were acting on
were acting on behalf
behalf
12 ||
12 of aa particular
of particular client
client or
or not
not is
is not
not something
something you
you focused
focused
13 ||
13 on until
on untis the
the special
special counsel
counsel started
started asking
asking you
you about
about it
it in
in
14 [|
14 une, isn't
June, isn't that
that right,
rignt, in
in 2020?
20202
15
15 A.
A. It's when
It's when they
they started
started toto focus
focus on
on it
it and
and asked
asked meme
16 |
16 very particular,
very particular, well-formulated,
well-formulated, specific
specific questions about
questions about
17 ||
17 that, honing
that, honing in
in very
very deeply
deeply on
on that,
that, and
and then
then provided
provided meme
18 ||
18 wich those
with those notes
notes from
from Mr.
mr. Priestap
Priestap that
that we
we talked
talked about
about
19 ||
19 earlier; that's
earlier; that's when
when II remembered
remembered what
what II have
have been
been
20 ||
20 testifying about
testifying avout yesterday
yesterday and
ana today.
today.
21
21 ©.
Q. Understood. But
Understood. But this
this --
-- the
the event
event of
of your
your meeting
meeting
22 ||
22 with Mr.
with mr. Sussmann
sussmann on
on the
the 19th
19th of
of September
September ofof 2016
2016 was not
was not
23 ||
23 an event
an event like
like Mr.
Mr. Comey
comey being
being fired.
fired. Correct?
Correct?
2
24 A.
A. That's correct.
That's correct.
25
25 ©.
Q. It was
It was not
not an
an event
event that
that was seared in
was seared in your
your mind.
mind.
1094
1094
1
1 Correct?
Correct?
2
2 A.
A. At the
At the time
time that
that we're talking about,
we're talking about, with
with respect
respect
3
3 to the
to the testimony
testimony here,
here, that's
that's correct,
correct, in
in this
this transcript
transcript
4
4 that we're
that we're talking
talking about.
about.
5
5 ©.
Q. In this
In this transcript,
transcript, subject
subject to
to prosecution
prosecution when
when
6
6 you're answering
you're answering the
the questions.
questions. Correct?
Correct?
7
7 A.
A. When I'm
When I'm answering
answering the
the questions
questions toto the
the best
best of
of my
my
8
8 ability based
ability based on
on what
what II recalled
recalled at
at the
the time,
time, yes.
yes.
9
9 2°.
Q.
10
10 MR. JORDAN: Did
MR. JORDAN: Did you
you know
know at
at the
the time
time
n
11 that he
that he was
was representing
representing thethe DNC
DNC and
and the
the Clinton
Clinton
12
12 campaign?
campaign?
13
13 MR. BAKER: II can't
MR. BAKER: can't remember.
remember. II had
had
14
14 learned that
learned that at
at some
some point.
point. II don't
don't --
-- as
as II said
said
15
15 last time,
last time, II don't
don't specifically
remember when
when II
16
16 learned that.
learned that. SoSo II just
just don't
don't know
know that
that II had
had
17
17 that in
that in my
my head
head when
when he
he showed
showed up
up in
in my
my office.
office. II
18
18 just can't
just can't remember.
remember.
19
19 MR. JORDAN: Did
MR. JORDAN: Did you
you learn
learn that
that shortly
shortly
20
20 thereafter, if
thereafter, if you
you don't
don't know
know at
at this
this time?
time?
21
21 MR. BAKER: II wish
MR. BAKER: wish II could
could give
give you
you aa
22
22 better answer.
better answer. II just
just don't
don't remember.
remember.
23
23 And that
And that was the state
was the state of
of your
your memory
memory at
at that
that
24
24 time, you
time, you just
just didn't
didn't remember.
remember. Correct?
Correct?
25
25 A.
A. Yes, sir.
Yes, sir. Yes,
Yes, sir.
sir.
1095
1095
1
1 Q.
Q. Today, you
Today, you do
do remember
remember that
that he
he --
-- that
that you
you knew
knew at
at
2
2 that point
that point he
he was
was representing
representing the
the DNC
DNC and
and the
the HFA
HFA and
and the
the
3
3 hack.
hack. Correct?
Correct?
4
4 A.
A. ves, sir.
Yes, sir.
5
5 @.
Q. Next question.
Next question.
6
6 MR. JORDAN: II mean
MR. JORDAN: mean II just
just find
find that
that
7
7 unbelievable that
unbelievable that the
the guy representing the
guy representing the Clinton
Clinton
8
8 campaign, the
campaign, the Democratic
Democratic National
National Committee
Committee shows
shows
9
9 up with
up with information
information that
that says,
says, We
We got
got this,
this, and
and
10
10 you don't
you don't ask
ask where he got
where he got it.
it. You don't
You don't know
know how
how
1
11 he got
he got it,
it, but
but he
he got it from
got it from some,
some, you
you know,
know,
12
12 “expert”.
"expert".
13
13 MR. BAKER. Well,
MR. BAKER. sure. If
Well, sure. If II could
could
14
14 respond to
respond to that?
that?
15
15 MR. JORDAN: Sure.
MR. JORDAN: Sure.
16
16 MR. BAKER: II mean,
MR. BAKER: mean, so
so II was
was
17
17 unconfortable with
uncomfortable being in
with being in the
the position
position ofof having
having
18
18 too much
too much factual
factual information
information conveyed
conveyed to
to me,
me,
19
19 because I'm
because I'm not
not an
an agent.
agent. And so
And so II wanted
wanted to
to get
get
20
20 this --
this -- get
get the
the information
information into
into the
the hands
hands of
of the
the
21
21 agents as
agents as quickly
quickly as
as possible
possible and
and let
let them
them deal
deal
22
22 with it.
with it. If they
If they wanted to go
wanted to go interview
interview Sussmann
Sussmann
23
23 and ask
and ask him
him all
all those
those kind
kind of
of questions,
questions, fine
fine with
with
24
24 me.
me.
25
25 Correct?
Correct?
1096
1096
1
1 A.
A. Yes, sir.
Yes, sir.
2
2 Q.
Q. And that's
And that's what
what you
you told
told Congress
Congress on
on October 18th
October 18th
3
3 of 2018.
of 2018. Correct?
Correct?
4
4 A.
A. ves, sir.
Yes, sir.
5
5 Q.
Q. Now, the
Now, the next
next day,
day, Mr.
Mr. Sussmann
Sussmann sends
sends you
you aa text.
text.
6
6 Correct?
Correct?
7
7 A.
A. I have
I have to
to go
go back and look
back and look at
at the
the dates.
dates. II think
think
8
8 so.
so.
9
9 Q.
Q. Government's Exhibit
Government's Exhibit 1500,
1500, October
October 19th,
19th, 2018
2018 at
at
10
10 8:39 a.m.
8:39 a.m.
1
11 A.
A. I'm sorry.
I'm sorry. The
The testimony
testimony was
was on
on the
the 18th.
18th. Right?
Right?
12
12 Is that
Is that what
what we
we just
just --
--
13
13 Q.
Q. You are
You are correct
correct and
and helpful.
helpful. So
So there
there was
was the
the
14
14 first one
first one on
on the
the 3rd?
3rd?
15
15 A.
A. Second on
Second on the
the 18th.
18th.
16
16 Q.
Q. The 18th
The 18th and
and the
the time
time when
when you're
you're interviewing
interviewing
17
17 with Perkins
with Perkins Coie.
Coie. Correct?
Correct?
18
18 A.
A. I think
I think so.
so. Roughly that
Roughly that time
time period.
period.
19
19 Q.
Q. So what
So what I'm
I'm looking
looking at
at is
is --
==
20
20 A.
A. A couple
A couple more, yeah.
more, yeah.
21
21 Q.
Q. So, yeah.
So, yeah.
22
MR. BERKOWITZ: So pause
pause there.
there.
23
23 THE WITNESS:
THE Yep.
WITNESS: Yep.
24
24 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
25
25 @.
Q. On October
On October 12th
12th he
he had
had sent
sent you
you aa Wall
Wall Street
Street
1097
1097
1
1 || Journal
sournar article
articie that
that was
was critical
critical of
of him
nim and
ana you?
you:
22 A.
A. I don't
I don't even
even know
know if
if it
it was
was about
about me. Honestly,
me. Honestly,
33 [| I'm
1m not
not sure
sure I1 read
read it
it at
at the
tne time.
time.
44 ©.
Q. So Mr.
So Mr. Sussmann,
Sussmann, atat the
the time
time you're
you're interviewing
interviewing
55 || with
with Perkins
perkins Coie
coie sends
sends you
you aa relatively
relatively short
short article
article and
and
66 [I you
vou don't
don't --
-- did
aia you
you not
not read
read it
it or
or you
you just
just don't
don't remember,
rememver,
77 | either
eitner way:
way?
88 A.
A. I don't
I don't remember
remember reading
reading it.
it.
99 ©.
Q. Meaning that
Meaning that you
you probably didn't?
probably didn't?
10
10 A.
A. Correct.
Correct.
un
11 ©.
Q. Okay. And
Okay. And then
then the
the next
next --
-- I'm
I'm sorry.
sorry. Then
Then on
on
12 || the
12 the 19th
19th after
after your
your testimony
testimony --
-- so
so II think
think the
the next
next one
one ----
13
13 A.
A. Un-hun.
Uh-huh.
14
14 Q.
Q. At 8:39
At 8:39 he
he sends
sends you
you aa piece
piece that
that says.
says. "R.
'R.
15 || Michael
15 michael Sussmann
sussmann is
is an
an honorable
honorable man."
man." And
and it
it says,
says, "I
"I hope
hope
16 || your
16 vour day
day went
went well.
well. Here
Here is
is John
John Devaney's
Devaney's letter
letter to
to the
the
17 || editor.
17 editor. Let's
zet's talk
talk next
next week
week about
about the
the future."
future.” Right?
Right?
18
18 A.
A. Yes. That's
Yes. That's what it says,
what it says, yes.
ves.
13
19 ©.
Q. And you
And you don't
don't remember
remember whether
whether you
you read
read this
this or
or
20 | not?
20 note
2
21 A.
A. Correct.
Correct.
22
22 ©.
Q. But you
But you do
do know
know Mr.
Mr. Sussmann
Sussmann sent
sent it
it to
to you.
you.
23 || Correct?
23 correct?
2
24 A.
A. Obviously, yes.
Obviously, yes.
25
25 @.
Q. And if
And if we
we could
could look
look at
at just
just the
the last
last paragraph
paragraph
1098
1098
1
1 || that
chat Mr.
wr. DeFilippis
veririppis showed
showed you?
your
22 MR. BERKOWITZ: Could
MR. BERKOWITZ: Could we
we blow that out?
blow that out?
33 || ev
BY wr.
MR. semcowrrz:
BERKOWITZ:
44 ©.
Q. It says,
It says, "In
"In addition,
addition, and
and as
as Perkins
Perkins Coie
Coie has
has
55 || previously
previously publicly state, Mr.
publicly stated, sussmann's meeting
Mr. Sussmann's meeting with tne
with the
66 || FBI,
eer, General
General Counsel
counsel James
James Baker
Baxer was
was on
on behalf
behalf of
of aa client
client
77 || with
with no
no connection
connection toto either
either the
tne Clinton
clinton campaign,
campaign, the
the DNC
onc
88 || or
or any
any other
otner political
poritical law
1aw group crient.r
group client."
99 Do you
Do you see
see that?
that?
10
10 A.
A. Yes, II do.
Yes, do.
un
11 ©.
Q. And you
And you didn't
didn't read
read that?
that?
12
12 A.
A. I don't
I don't remember
remember reading
reading that.
that.
13
13 ©.
Q. Any idea
Any idea why
why Mr. Sussmann would
Mr. Sussmann would send
send you,
you, to
to your
your
14 | knowledge,
14 knowledge, something
something that
that you
you say
say contradicts
contradicts what
what hehe told
told
15 || you
15 vou aa couple
couple ofof years
years before?
before?
16
16 A.
A. say that
Say that again?
again? DoDo II know
know why
why Michael
Michael sent
sent this
this
17 || to
17 to mez
me?
18
18 ©.
Q. To your
To your knowledge,
knowledge, if
if Mr.
Mr. Sussmann
Sussmann had
had lied
lied to
to you
you
19 || about
19 avout whether
whether hehe had
had aa client,
client, why
why would he send
would he send you
you
20 || something
20 something saying
saying he
he did
did have
have aa client?
client?
2
21 A.
A. Idon't
I know. You'd
don't know. You'd have
have to
to ask
ask him.
him.
22
22 ©.
Q. And with
And with respect,
respect, sir,
sir, to
to John
John Devaney
Devaney --
--
23
23 A.
A. Uh-huh.
Uh-huh.
24
24 Q.
Q. That's the
That's the managing
managing partner
partner ofof Perkins
Perkins Coie.
Coie.
25 || Correct?
25 correct?
1099
1099
1
1 A.
A. Yes, sir.
Yes, sir.
2
2 Q.
Q. And that's
And that's somebody
somebody that
that you
you had
had interviewed
interviewed with
with
3
3 or not?
or not?
4
4 A.
A. I believe
I believe so,
so, yes.
yes.
5
5 Q.
Q. Okay.
Okay.
6
can take
take that
that down.
down.
7
7 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
8
8 Q.
Q. And despite
And despite interviewing
interviewing with
with Perkins
Perkins Coie,
Coie, being
being
9
9 close to
close to Michael,
Michael, you
you don't
don't believe
believe you
you read
read the
the article
article he
he
10
10 sent you?
sent you?
1
11 A.
A. I don't
I don't recall,
recall, sitting
sitting here
here today,
today, having
having read
read
12
12 that article
that article oror that
that letter
letter at
at the
the time.
time.
13
13 Q.
Q. Now, moving
Now, forward, sir,
moving forward, sir, you
you testified
testified again
again
14
14 under oath
under oath in
in July
July of
of 2019.
2019.
15
15 A.
A. Is this
Is this the
the I.G.
I.G. thing?
thing?
16
16 @.
Q. We will
We will call
call it
it "the
"the thing",
thing", but it's testimony
but it's testimony
17
17 under oath.
under oath.
18
18 A.
A. Yeah. II just
Yeah. just couldn't
couldn't remember
remember what
what the
the date was.
date was.
19
19 Q.
Q. It's the
It's the I.G.
I.G. testimony
testimony on
on July
July of
of 2019.
2019.
20
20 A.
A. Okay.
Okay.
21
21 ©.
Q. And if
And if we
we could
could pull
pull that,
that, just
just that
that cover
cover page
page
22
22 up. And
up. And if
if we
we go
go to
to Page
Page 22 of
of that
that document,
document, it's
it's aa
23
23 Ms. Terzaken, Ann
Ms. Terzaken, Ann Marie
Marie Terzaken.
Terzaken. Do Do you
you remember
remember who she
who she
24
24 was?
was?
25
25 A.
A. ves.
Yes.
1100
1100
1
1 ©.
Q. In the
In the middle
middle of
of the
the line,
line, Page
Page 14
14 to
to 17,
17, 14
14 to
to 18
18
2
2 we'll make
we'll make it,
it, she
she says
says "All
"All of
of the
the preliminaries
preliminaries from
from our
our
3
3 prior meetings
prior meetings still
still apply.
apply. You
You are
are still
still aa fact
fact witness
witness
4
4 appearing voluntarily,
appearing voluntarily, which we appreciate.
which we appreciate. YouYou are
are still
still
5
5 under oath.
under oath. Do Do you
you understand
understand that?
that?
6
6 Answer by
Answer by Mr. Baker: Yes."
Mr. Baker: Yes."
7
7 Do you
Do you remember
remember that?
that?
8
8 A.
A. Yes --
Yes -- well,
well, II don't
don't remember
remember it,
it, but
but that's
that's what
what
9
9 the transcript
the transcript says.
says.
10
10 ©.
Q. And Mr.
And Mr. DeFilippis
DeFilippis took
took you
you through
through some
some
n
11 testimony, and
testimony, and II want
want to
to go
go over
over it
it again.
again. And we'll start
And we'll start
12
12 on Page
on Page 30,
30, Line
Line 20
20 through
through the
the end
end and
and then
then we'll
we'll continue
continue
13
13 on. And
on. And by
by this
this time,
time, you
you had
had been questioned twice
been questioned twice by
by
14
14 governmental agencies
governmental agencies about
about this
this meeting.
meeting. Correct?
Correct?
15
15 A.
A. ves.
Yes.
16
16 ©.
Q. Okay.
Okay.
17
17 And Ms.
And Ms. Terzaken
Terzaken says:
says: "Okay.
"Okay. With
With Michael
Michael
18
18 Sussmann, your
Sussmann, your conversations
conversations with
with him
him before
before the
the election,
election,
19
19 if you
if you could
could briefly
briefly describe
describe how
how the
the conversations
conversations came
came
20
20 about, what
about, information he
what information he provided
provided toto you?
you?
21
21 MR. BAKER: So
MR. BAKER: So I'll
I'll go
go into
into the
the Sussmann
Sussmann
22
22 Stuff. Yeah,
stuff. Yeah, okay.
okay. SoSo he
he came
came in,
in, he,
he, he,
he, all
all of
of
23
23 this is
this is gone
gone over
over in
in the
the transcript
transcript with
with the
the
24
24 Committee, so
Committee, so II wasn't
wasn't --
=- I'll
I'll just
just try
try to
to
25
25 summarize briefly.
summarize briefly. Okay?
Okay?
1101
1101
1
1 My basic recollection
My basic recollection is,
is, in
in some
some way,
way,
2
2 shape or
shape or form,
form, Michael reached out
Michael reached out and
and wanted
wanted to
to
3
3 come in
come in and
and meet
meet with
with me.
me. And so we
And so scheduled
we scheduled
4
4 that. So
that. So Michael came in
Michael came in and
and met
met with
with me. And he
me. And he
5
5 had some
had some amount
amount of
of information,
information, physical
physical evidence
evidence
6
6 printed out,
printed out, and
and also
also aa thumb
thumb drive
drive or
or two,
two, that
that
7
7 he said
he said related
related to
to strange
strange interactions
interactions that
that were
were
8
8 some number
some number of
of people
people that
that were
were his
his clients
clients who
who
9
9 were, he
were, he described,
described, as
as II recall
recall it,
it, sort
sort of
of cyber
cyber
10
10 experts had
experts had found
found about
about some
some strange
strange connection
connection
1
11 between some
between some part
part of
of Donald
Donald Trump's
Trump's organization
organization
12
12 and Alfa-Bank,
and Alfa-Bank, which
which was
was described
described as
as being
being
13
13 controlled by
controlled by the
the Kremlin.
Kremlin. And that
And that it
it appeared
appeared
14
14 to be
to be the
the case
case that
that this
this was
was aa --
-- it
it was,
was, it,
it, it
it
15
15 was surmised
was surmised this
this was a back
was a back channel,
channel, what
what you
you
16
16 call it,
call it, aa back
back channel
channel of
of electronic
electronic
17
17 communications that
communications that somehow
somehow the
the Trump
Trump Organization
Organization
18
18 were using
were using this,
this, what
what looked
looked like,
like, basically,
basically, aa
19
19 surreptitious channel
surreptitious channel to
to communicate
communicate with
with each
each
20
20 other.
other. So he
So he presented me with
presented me with this
this information.
information.
21
21 II listened
listened to
to him.
him. I, you
I, you know,
know, took
took the
the
22
22 information from
information from him,
him, and
and II think
think immediately
immediately
23
23 called up,
called up, II believe
believe it
it was,
was, Priestap
Priestap and
and II either
either
24
24 went down
went down to
to Priestap
Priestap or
or he
he sent
sent somebody
somebody to
to get
get
25
25 it, but
it, but II got
got it
it out
out of
of my
my hands
hands like
like you
you know
know
1102
1102
1
1 that afternoon
that afternoon or
or that
that day,
day, whatever
whatever it
it was.
was.
2
2 And you
And you then
then go on to
go on to say,
say, "you
"you know
know shortly
shortly after
after
3
3 || Michael
michael had
nad given
given it
it to
to me.v
me."
41 So let's
So let's focus
focus on
on "the
"the client"
client” word.
word.
55 MR. BERKOWITZ: We
MR. BERKOWITZ: We will
will blow
blow it
it up
up in
in that
that
66 || sentence,
sentence, Mr.
mr. Cleaves.
cleaves.
77 || BY
BY mr.
MR. eerxowrrz:
BERKOWITZ:
88 9.
Q. So you
So you were
were summarizing
summarizing your
your interaction
interaction with
with
99 || Mr.
mr. Sussmann
sussmann for
for the
the committee.
committee. Correct?
correct?
10
10 A.
A. For the
For the I.G.
I.G.
un
11 ©.
Q. 1.6. And
I.G. you chose
And you chose to
to use
use the
the word
word "number
"number of
of
12 | people
12 people that
that were
were his
his clients."
clients. Correct?
correct?
13
13 A.
A. ves, sir.
Yes, sir.
14
14 ©.
Q. And you
And you told
told the
the jury
jury that
that that
that was
was aa mistake?
mistake? I I
15 || think
15 think I1 said
said it
it was
was inaccurate,
inaccurate, imprecise,
imprecise, wrong,
wrong, mistake,
mistake,
16 [| yes.
16 ves. It1t is
is not
not correct.
correct.
17
17 Q.
Q. Was it
Was it aa lie?
lie?
18
18 A.
A. Idon't
I think it
don't think it was
was aa lie.
lie.
13
19 @.
Q. why not?
Why not?
20
20 A.
A. Because II had
Because had no
no intention
intention ofof deceiving
deceiving the
the I.G.
I.G.
21 || in
21 in any
any way, shape or
way, shape or form.
form.
22
22 9.
Q. And --
And --
23
23 A.
A. And II said
And said above
above --
-- excuse
excuse me.
me. II said
said above
above "I'll
"I'll
24 || just
24 just try
try to
to summarize
summarize it.
it. It's
It's been
been talked
talked about
about in
in these
these
25 || transcripts.
25 transcripts. Go Go back
back and
and look
look at
at those."
those.” Obviously,
Obviously, I I was
was
1103
1103
1
1 there and
there and available
available to
to answer
answer any
any follow-up
follow-up questions
questions that
that
2
2 they had.
they had.
3
3 ©.
Q. You said
You said that
that your
your use
use of
of the
the word
word "clients"
"clients" was
was
4
4 shorthand. Correct?
shorthand. Correct?
5
5 A.
A. That's how
That's how II am
am thinking
thinking about
about itit today.
today. Yes,
Yes,
6
6 sir.
sir.
7
7 Q.
Q. Shorthand for
Shorthand for what?
what?
8
8 A.
A. For the
For the cybersecurity
cybersecurity experts.
experts.
9
9 ©.
Q. That seems
That seems like
like it
it makes
makes it
it longer
longer because
because you
you
10 || mention
10 cybersecurity experts.
mention cybersecurity experts. Whywhy add
add the
the word
word client
client inin
n
11 your answer?
your answer?
12
12 A.
A. I think
I think today,
today, trying
trying to
to think
think about
about how
how II was
was
13
13 thinking on
thinking on that
that day,
day, that
that it
it was
was just
just aa shorthand
shorthand way to
way to
14
14 describe the
describe the people
people with
with whom
whom he
he was
was connected.
connected. I'll
I'll just
just
15
15 stop there,
stop there, yeah.
yeah.
16
16 ©.
Q. And this
And this is
is obviously
obviously anan area
area of
of intense
intense focus.
focus.
17 || and
17 And I1 still
still --
== I1 just
just --
-- did
did you
you believe
believe atat the
the time
time that
that
18
18 the cybersecurity
the cybersecurity experts
experts were
were his
his clients
clients when you said
when you said
19
19 that?
that?
20
20 A.
A. No, II don't
No, don't think
think so,
so, but
but II was
was not
not particularly
particularly
21
21 focused on
focused on this
this client
client question
question atat that
that point
point in
in time.
time. As As II
22
22 said earlier,
said earlier, II was
was being
being attacked
attacked for
for even
even having
having had
had the
the
23 || meeting
23 in the
meeting in the first
first place.
place. II was
was being obviously
being obviously
24
24 questioned about
questioned about it
it in
in multiple settings. II was
multiple settings. was being
being
25
25 attacked in
attacked in the
the media, on social
media, on social media,
media, on
on Fox
Fox News,
News,
1104
1104
1
1 elsewhere.
elsewhere.
2
2 So that
So that was
was the
the focus
focus of
of my attention like,
my attention like, Wow!
Wow!
3
3 Like why
Like why did
did you
you even
even meet
meet with Michael?
with Michael? Oh my
Oh my God!
God! This
This
4
4 is all
is all corrupt.
corrupt. This is
This is the
the swamp
swamp and
and so
so on
on and
and so
so forth,
forth,
5
5 all of
all of which
which II thought
thought was completely wrong
was completely wrong and
and still
still to
to
6
6 this day
this day think
think is
is completely
completely wrong.
wrong. But in
But in any
any event,
event, that
that
7
7 was where
was where my
my mind
mind was
was focused.
focused. It was
It not focused
was not focused on
on this
this
8
8 question that
question that we're
we're talking
talking about
about very
very specifically
specifically today.
today.
9
9 ©.
Q. And, sir,
And, sir, you
you realize
realize that,
that, if
if somebody
somebody had
had
10
10 determined that
determined that you
you were
were intentionally
intentionally trying
trying to
to deceive,
deceive,
n
11 you could
you could have
have been prosecuted for
been prosecuted for saying
saying that.
that. Correct?
Correct?
12
12 A.
A. And II said
And said it
it under
under oath.
oath. ItIt is
is said
said at
at the
the start
start
13
13 of the
of the transcript
transcript that
that you
you showed.
showed.
14
14 Q.
Q. And is
And is it
it possible
possible that
that you
you said
said it
it because
because that's
that's
15
15 what Mr.
what Mr. Sussmann
Sussmann had
had indicated
indicated to
to you
you in
in one
one of
of his
his
16
16 follow-up calls,
follow-up calls, sir?
sir?
17
17 A
A. Yo.
No.
18
18 ©.
Q. Did you
Did you go
go back
back and
and correct
correct this
this in
in any
any way,
way, sir?
sir?
19
19 A.
A. I haven't
I haven't seen
seen this
this whole
whole transcript,
transcript, soso II don't
don't
20
20 know. But
know. But I'm
I'm guessing that you
guessing that you all
all would
would have
have informed
informed meme
21
21 of that
of that had
had that
that been
been the
the case.
case.
22
22 ©.
Q. So that
So that testimony
testimony was
was on
on October
October --=- I'm
I'm sorry
sorry ----
23
23 July of
July of 2019.
2019. Correct?
Correct?
24
24 A.
A. ves.
Yes.
25
25 ©.
Q. And at
And at some
some point
point after
after that
that and
and you
you were
were ----
1105
1105
1
1 || v=. ourham was
Mr. Durham appointed in
was appointed in connection
connection with tnis
with this
2 ||
2 investigation, correct,
investigation, correct, sometime
sometime in
in 2020?
2020? We talked about
We talked about
3 [|
3 this earlier?
this earnier:
1
4 A.
A. When was
When he appointed
was he appointed inin this
this investigation?
investigation? II
5s [|
5 thougnt it
thought it was 2019.
was 2019.
6
6 e.
Q. 2019.
2019.
7
7 A.
A. I thought
I thought you
you said
said that
that earlier.
earlier. Yeah,
Yeah, okay.
okay.
8
8 ©.
Q. And you
And you had
had volunteered
volunteered toto speak
speak to
to him.
him. Correct?
Correct?
9
9 A.
A. Yes, sir.
Yes, sir.
10
10 ©.
Q. And just
And just to
to orient
orient everybody,
everybody, inin February
February ofof 2020,
2020,
11 ||
11 vou did
you aid have
nave aa meet -- you
meet -- you did
did meet with him?
meet with him?
12
12 A.
A. I don't
I don't remember
remember the
the dates.
dates. II know
know that
that I've
I've met
met
13 [|
13 with him
with nim multiple
multiple times,
times, as
as you
you indicated
indicated earlier.
earlier.
14
14 9.
Q. And do
And do you
you remember,
remember, when you met
when you with him
met with him in
in or
or
15 ||
15 around early
around early 2020,
2020, that
that you
you were
were advised
advised along
along with
with your
your
16 ||
16 1awyer of
lawyer of the
the background
background and
and nature
nature of
of the
the review
review that
that
17 ||
17 wr. purhan's team
Mr. Durham's team was
was conducting
conducting atat the
the request
request of
of Attorney
Attorney
18 ||
18 General Barr
General Barr and
and also
also of
of the
the fact
fact that
that the
the provisions
provisions ofof
19 ||
19 micie 18
Title 18 U.S.
us. Code,
code, Section
section 1001
1001 applied
applied to
to the
the interview?
interview?
20
20 A.
A. I would
I would have
have known
known that
that had
had they
they not
not even
even said
said it.
it.
21
21 ©.
Q. Do you
Do you remember
remember in
in early
early 2020
2020 them
them advising
advising you
you ofof
22 ||
22 chat fact?
that face?
23
23 A.
A. Not particularly.
Not particularly.
24
24 ©.
Q. Would it
Would it refresh
refresh your
your recollection
recollection toto see
see aa 302
302 ofof
25 |
25 nae
that?
1106
1106
1
1 A.
A. Not necessarily
Not necessarily because
because II just
just know
know that
that that
that isis
2
2 [| the case
the case when
when you're
you're always
always speaking
speaking toto the
the FBI
FBI or
or the
the
33 [| sustice Department.
Justice pepartment.
44 ©.
Q. I mean,
I it's not
mean, it's not every
every day
day that
that Mr.
Mr. Durham
Durham
55s || interviews you.
interviews you. Right?
rignez
66 A.
A. No, that's
No, that's correct.
correct.
77 Q.
Q. It's the
It's the first
first time
time you
you saw
saw him
him after
after you
you were
were the
the
88 [| subject of
subject of the
the criminal
criminal investigation
investigation byby him?
him?
99 A.
A. Again, II was
Again, never told
was never told that
that II was
was aa subject.
subject. WasWas
10 [|
10 that the
that the first
first time?
time? Yeah,
vean, II think
think that
that was
was the
the first
first time.
time.
un
11 ©.
Q. Do you
Do you remember
remember him
him explaining
explaining his
his new
new mandate
mandate toto
12 ||
12 you then?
you chen?
13
13 A.
A. I don't
I don't remember
remember him
him explaining
explaining that,
that, but
but II knew
knew
14 [|
14 what it
what it was
was and
and we
we talked
talked about
about it
it at
at some
some point.
point. And
And II
15 ||
15 could tell
could te11 from
from the
the questions
questions that
that he
he was
was asking
asking me
me about
about
16 |
16 the FBI
the FBI and
and our
our investigation
investigation ofof Russia,
Russia, what
what he
he was
was focused
focused
17 |
17 on.
on.
18
18 ©.
Q. At some
At some point
point after
after that,
that, they
they called
called you
you back
back for
for
19 ||
19 an additional
an additional interview
interview that
that focused
focused more
more directly
directly on
on
20 ||
20 Mr. Sussmann.
Mr. sussmann. Correct?
correct?
2
21 A.
A. At some
At some point
point in
in time,
time, yes.
yes.
22
22 ©.
Q. June of
June of 2020,
2020, does
does that
that sound
sound familiar?
familiar?
23
23 A.
A. It could
It could be.
be.
24
24 ©.
Q. Do you
Do you remember
remember where
where you
you were
were when
when you
you had
had that
that
25 ||
25 interview, sir?
interview, sirz
1107
1107
1
1 A.
A. That interview?
That interview?
2
2 Q.
Q. veah.
Yeah.
3
3 A.
A. I think
I think that
that was at FBI
was at FBI headquarters.
headquarters.
4
4 @.
Q. And you
And you were
were there
there with
with your
your lawyer?
lawyer?
5
5 A.
A. ves, sir.
Yes, sir.
6
6 Q.
Q. Mr. Durham
Mr. Durham was
was there.
there. Correct?
Correct?
7
7 A.
A. I believe
I believe so,
so, yes.
yes.
8
8 Q.
Q. Andrew DeFilippis
Andrew DeFilippis was
was there?
there?
9
9 A.
A. I think
I think so.
so. II can't
can't remember
remember everybody
everybody who
who was
was in
in
10
10 the room,
the room, but
but there
there were
were aa number
number of
of people
people in
in the
the room
room to
to
1
11 the best
the best of
of my recollection.
my recollection.
12
12 Q.
Q. Would it
Would it refresh
refresh your
your recollection
recollection to
to see
see aa 302
302 of
of
13
13 who was
who was there
there and
and where
where it
it took
took place?
place?
14
14 A.
A. sure, yes.
Sure, yes.
15
15 MR. BERKOWITZ: Let's
MR. BERKOWITZ: Let's take
take aa look
look at
at JB-07-001
JB-07-001 to
to
16
16 refresh the
refresh the witness's
witness's recollection,
recollection, just
just that
that first
first
17
17 paragraph, and
paragraph, and you
you can
can read
read that
that to
to yourself.
yourself.
18
18 THE WITNESS:
THE WITNESS: Can II just
Can just ask
ask aa question?
question? These
These
19
19 are 302s?
are 302s? Because they
Because they don't
don't look
look like
like 302s
302s to
to me.
me. II just
just
20
20 want to
want to make
make that
that note.
note.
21
21 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
22
22 Q.
Q. Well take
Well take aa look
look at
at the
the bottom
bottom of
of this.
this. That's
That's aa
23
23 fair point.
fair point. II certainly
certainly don't
don't want to misrepresent
want to it to
misrepresent it to
24
24 you.
you.
25
25 MR. BERKOWITZ: Can
MR. BERKOWITZ: Can you
you blow
blow that
that out
out Mr.
Mr. --
--
1108
1108
1
1 THE WITNESS:
THE WITNESS: Yes, that
Yes, that doesn't
doesn't indicate
indicate that
that it's
it's
2
2 [a 302.
a 302.
3
3 || ev
BY wr.
MR. semcowrrz:
BERKOWITZ:
44 ©.
Q. What II would
What would represent,
represent, sir,
sir, is
is there's
there's various
various
55 || classified
classified information
information which you're well
which you're well familiar
familiar with
with and
ana
66 || certain
certain things
things were declassified in
were declassified in connection
connection with this
with this
77 || case.
case. This
mis is,
is, I1 believe,
believe, the
the declassified
declassified version
version ofof the
the
88 [| notes
notes that
that were
were taken.
taken. Does
Does that
that help
help you?
you? II don't
don't want
want toto
93 || misread you.
mislead you.
10
10 A.
A. I understand
I understand what you are
what you are saying,
saying, yes.
yes.
un
11 9.
Q. okay.
Okay.
12
12 A.
A. It's aa substitute
It's substitute document,
document, basically
basically with
with the
the
13 || text
13 text from
from the
the other
other document
document with
with redactions.
redactions.
14
14 Q.
Q. So it's
So it's aa report
report of
of the
the interview.
interview. It's
It's just
just not
not
15 | termed
15 termed aa 302,
302, but
but it's
it's essentially
essentially anan FBI
FBI agent's
agent's notes
notes ofof
16 | what
16 what you
you relayed
relayed and
and what
what they
they communicated
communicated to to you.
you. Does
Does
17 | that
17 that make
make sense?
sense?
18
18 A.
A. FBI agent's
FBI agent's report
report of
of an
an interview,
interview, that's
that's how
how II
19 || think
19 think about
about aa 230.
230. The
The notes
notes are
are one
one thing.
thing.
20
20 9.
Q. Yes.
Yes.
2
21 A.
A. The report
The report of
of the
the interview
interview isis aa separate
separate thing.
thing.
22
22 ©.
Q. You're correct.
You're correct. These
These are
are aa report
report of
of his
his
23 [| interview.
23 interview.
2
24 A.
A. Okay, gotcha.
Okay, gotcha.
25
25 ©.
Q. So just
So just read
read that
that to
to yourself.
yourself.
1109
1109
1
1 A.
A. Okay. Sorry.
Okay. Sorry.
2
2 (Brief pause.)
(Brief pause.)
3
3 Okay. I've
Okay. I've read
read it.
it.
4
4 ©.
Q. Okay. So
Okay. So does
does that
that refresh
refresh your
your recollection
recollection that
that
5 [| mr.
5 burnam was
Mr. Durham there, Mr.
was there, Mr. DeFilippis,
DeFilippis, FBI
FBI Agent
Agent Furhman
Furhman and
and
6
6 special Agent
Special John Farley?
Agent John Farley?
7
7 A.
A. ves.
Yes.
8
8 ©.
Q. And you
And you were
were informed
informed generally
generally of
of the
the purpose
purpose of
of
9
9 the interview
the interview and
and Mr.
Mr. Durham
Durham was
was conducting
conducting an
an
10
10 investigation. Correct?
investigation. Correct?
n
11 A.
A. That's what
That's what it
it says.
says. II don't
don't specifically
specifically
12
12 remember that.
remember that.
13
13 ©.
Q. And they
And they remind
remind you,
you, as
as you
you know,
know, even
even though
though you
you
14
14 don't need
don't need reminding,
reminding, that
that the
the provisions of 18
provisions of 18 U.S.C.
U.S.C. 1001,
1001,
15
15 False Statements,
False Statements, applied
applied toto the
the interview.
interview. Correct?
Correct?
16
16 A.
A. That's what
That's what it
it says.
says.
17
17 ©.
Q. So let's
So let's get to the
get to the meat
meat of
of some
some of
of the
the things.
things.
18
18 Do you
Do you remember
remember telling
telling them
them at
at that
that meeting
meeting that
that your
your
19
19 recollection was
recollection was that
that you
you did
did not
not know
know at
at the
the time
time of
of your
your
20 || meeting
20 with Mr.
meeting with Mr. Sussmann
Sussmann that
that Mr. Sussmann was
Mr. Sussmann was representing
representing
21
21 the DNC
the DNC in
in other
other matters?
matters? So So the
the opposite
opposite of
of what
what you
you said
said
22
22 today. You
today. You told
told --
--
23
23 A.
A. Yeah, II don't
Yeah, don't remember.
remember. Sorry.
Sorry.
24
24 ©.
Q. Do you
Do you remember
remember telling,
telling, in
in June
June of
of 2020,
2020,
25
25 Mr. DeFilippis
Mr. DeFilippis and
and Mr. Durham that
Mr. Durham that you
you don't
don't remember
remember at
at the
the
1110
1110
1
1 || time you
time you met
met with
with Mr.
mr. Sussmann
sussmann that
that you
you were
were aware
aware he
he was
was
2 [|
2 representing the
pNC in
in other
other matters?
matters?
3
3 A.
A. Over time,
Over time, II have
have had
had aa hard
hard time
time placing
placing exactly
exactly
4 ||
4 when it
when it was
was that
that II learned
learned that
that information.
information. So So I've
I've --
--
5 ||
5 sitting here
sitting nere today,
today, based
based onon Priestap's
priestap's notes,
notes, that
that tells
tells me
me
6 [|
6 that I1 must
that nave learned
must have learned that
that before
before the
the meeting
meeting with
with
7 ||
7 michaer
Michael onon the
the 19th
19th of
of September.
september.
8
8 9.
Q. So your
So your memory
memory has
has evolved
evolved based
based on
on seeing
seeing other
other
3 [|
9 veopiers notes?
people's notes?
10
10 A.
A. I know
I know that
that II was
was in
in aa briefing
briefing where
where other
other FBI
FBI
11 ||
11 officials discussed
officials discussed that
that Michael
Michael was
was representing
representing thethe DNC
DNC or
or
12 ||
12 the Hillary
the millary campaign
campaign in
in some
some fashion
fashion inin connection
connection with the
with the
13 ||
13 hack. I1 specifically
hack. specifically andand clearly
clearly remember
remember that.
that. II don't
don't
14 ||
14 remember exactly
remember exactly when
when that
that was.
was.
15
15 So from
So from looking
looking atat Mr.
Mr. Priestap's
Priestap's notes,
notes, when
when
16 |
16 there's aa reference
there's reference inin there
there to
to the
the --
-- II can't
can't remember.
rememper. II
17 ||
17 don't have
don't have the
the notes
notes in
in front
front ofof me
me --
-- but there's aa
but there's
18 ||
18 reference to
reference to that
that entities.
entities. So so therefore
therefore that
that tells
tells me,
me,
19 [|
19 an-na,
Ah-ha, I1 must
must have
have known
known itit by
by that
that point
point in
in time,
time, so
so II
20 [[
20 probably learned
probably learned itit in
in the
the summer
summer of
of 2016
2016 before
before the
the
21 ||
21 meeting.
meeting.
22
22 ©.
Q. But at
But at the
the meeting
meeting inin June
June of
of 2020
2020 with
with the
the FBI
FBI
23 [|
23 and Mr.
and Durham and
Mr. Durham and Mr. DeFilippis, your
Mr. DeFilippis, your recollection
recollection waswas
24 ||
24 that you
that you did
did not
not remember
remember oror did
did not
not know,
know, at
at the
the time
time that
that
25 [
25 mr. Sussmann
Mr. sussmann met
met with
with you,
you, that
that he
he was representing the
was representing the DNC
DNC
11
1111
1
1 in other
in other matters?
matters?
2
2 A.
A. If that's
If that's what
what the
the notes
notes say.
say. II can't
can't see
see that
that
3
3 part of
part of the
the notes,
notes, but I'll take
but I'll take your
your word
word for
for it.
it.
4
4 ©.
Q. Do you
Do you need
need your
your recollection
recollection refreshed?
refreshed?
5
5 A.
A. I wouldn't
I wouldn't remember
remember it,
it, even
even if
if you
you showed
showed meme the
the
6
6 document. So
document. So it's
it's up
up to
to you
you if
if you
you want
want to
to show
show me
me the
the
7
7 document.
document.
8
8 ©.
Q. Are you
Are you denying
denying that
that that's
that's what
what you
you said?
said?
9
9 A.
A. No, I'm
No, I'm not
not denying
denying it.
it.
10
10 ©.
Q. Do you
Do you remember
remember also
also telling
telling Mr. DeFilippis and
Mr. DeFilippis and
n
11 Mr. Durham that,
Mr. Durham that, with
with respect
respect toto your
your meeting
meeting about
about
12 || Alfa-Bank
12 with Mr.
Alfa-Bank with sussmann, you
Mr. Sussmann, you recalled
recalled that
that Mr. Sussmann
Mr. Sussmann
13
13 called you
called you at
at work
work and
and said
said he
he needed
needed to
to see
see Baker
Baker at
at
14
14 Baker's office?
Baker's office?
15
15 A.
A. Yes. II remember
Yes. remember that
that II thought
thought that
that it
it was
was aa
16
16 phone call
phone call that
that Michael
Michael ---- II remember
remember thinking
thinking then
then that
that
17 || michael
17 initiated all
Michael initiated all of
of this
this meeting
meeting and
and everything
everything through
through
18
18 a phone
a phone call
call to
to me.
me.
19
19 ©.
Q. That was
That was wrong. Right?
wrong. Right?
20
20 A.
A. That was
That was wrong.
wrong.
21
21 ©.
Q. Memories are
Memories are aa difficult
difficult thing.
thing. Are they not,
Are they not,
22
22 sir?
sir?
23
23 A.
A. don't know
I don't know how
how to
to answer
answer that
that question.
question.
24
24 ©.
Q. It's aa hard
It's hard thing
thing toto remember
remember something
something from
from over
over
25
25 five years
five years ago;
ago; isn't
isn't it,
it, sir?
sir?
112
1112
1
1 A.
A. As II said
As said earlier,
earlier, there
there are
are certain
certain things
things that
that
2
2 you can
you can remember
remember and
and certain
certain things
things that
that are
are difficult
difficult toto
3
3 remember. I'm
remember. I'm not
not aa neuroscientist,
neuroscientist, andand II can't
can't explain
explain howhow
4
4 human memory
human memory works.
works.
5
5 ©.
Q. And you
And you testified
testified yesterday
yesterday with
with some
some conviction
conviction
6
6 that you
that you were
were at
at home
home when
when you
you received
received the
the text
text from
from
7 || Mr.
7 sussmann. Correct?
Mr. Sussmann. correct?
8
8 A.
A. ves.
Yes.
9
9 ©.
Q. Your memory,
Your memory, based on the
based on the text,
text, led
led you
you to
to believe
believe
10
10 you must
you have been
must have been home.
home. Correct?
Correct?
n
11 A.
A. The memory
The memory based
based on
on the
the text
text and
and then
then something
something
12
12 triggered me
triggered me about
about the
the date, and so
date, and so II looked
looked and
and II thought
thought
13
13 -- and
-- and II saw
saw that
that it
it was
was aa Sunday.
Sunday. Then
Then that
that triggered
triggered the
the
14
14 memory, Oh, yeah,
memory, Oh, yeah, II remember
remember exactly
exactly where
where II was
was standing
standing
15
15 when II read
when read that
that text.
text.
16
16 ©.
Q. Do you
Do you remember
remember telling
telling Mr.
Mr. DeFilippis
DeFilippis and
and
17 || wr.
17 purham at
Mr. Durham at that
that meeting that Mr.
meeting that Sussmann did
Mr. Sussmann did not
not specify
specify
18
18 that he
that he was
was representing
representing aa client
client regarding
regarding the
the matter nor
matter nor
19
19 did you
did you ask
ask if
if he
he was
was representing
client? YouYou said
said --
--
20
20 told them
told them you
you did
did not
not know
know Sussmann
Sussmann was
was ---- it
it did
did not
not seem
seem
21
21 like Sussmann
like Sussmann was
was representing
representing aa client.
client. Do Do you
you remember
remember
22
22 telling them
telling them that?
that?
23
23 A.
A. ves.
Yes.
24
24 ©.
Q. Okay. So
Okay. So at
at that
that point,
point, you
you didn't
didn't remember
remember that
that
25
25 he'd said
he'd said he
he was
was not
not there
there on
on behalf
behalf of
of aa client.
client. Correct?
Correct?
1113
1113
1
1 A.
A. Yes. II don't
Yes. don't remember
remember exactly
exactly the
the words
words you
you just
just
2
2 read but,
read but, yes,
yes, what you say
what you say makes sense.
makes sense.
3
3 Q.
Q. It didn't
It didn't come
come up,
up, essentially.
essentially. You
You told
told them,
them,
4
4 essentially, it
essentially, it didn't
didn't come
come up
up in
in your
your meeting whether he
meeting whether he
5
5 had aa client
had client or
or whether
whether he
he did not.
did not.
6
6 A.
A. I don't
I don't have
have the
the notes
notes in
in front
front of
of me,
me, the
the
7
7 document that
document that you're
you're reading
reading from.
from. SoSo if
if you
you could
could show
show me
me
8
8 that, that
that, that might help me
might help me remember
remember what
what II said.
said.
9
9 @.
Q. So we'll
So we'll see
see if
if we
we can
can help
help refresh
refresh your
your
10
10 recollection about
recollection about what you said
what you said in
in 2020.
2020.
1
11 MR. BERKOWITZ: That's
MR. BERKOWITZ: That's JB-709,
JB-709, Paragraph
Paragraph 3,
3, middle
middle
12
12 of the
of the page, again, just
page, again, just for
for the
the witness.
witness.
13
13 THE WITNESS:
THE The middle
WITNESS: The middle ofof this
this paragraph? It's
paragraph? It's
14
14 a long
a long paragraph.
paragraph.
15
15 THE COURT:
THE COURT: Why don't
Why don't you
you highlight
highlight what
what you
you want
want
16
16 him to
him to focus
focus on.
on.
17
17 MR. BERKOWITZ: It's
MR. BERKOWITZ: It's the
the one
one that's
that's "with
"with respect
respect
18
18 to."
to." Yeah.
Yeah. One, two,
One, two, three
three --
-- representing.
representing.
19
19 THE WITNESS:
THE WITNESS: There it
There it is.
is. I see.
I see.
20
20 Okay.
Okay. So what's
So what's your
your question,
question, sir?
sir?
21
21 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
22
22 Q.
Q. Did you
Did you tell
tell Mr. DeFilippis and
Mr. DeFilippis and Mr.
Mr. Durham
Durham at
at that
that
23
23 meeting that Sussmann
meeting that Sussmann did
did not
not specify
specify that
that he
he was
was
24
24 representing aa client
representing client regarding
regarding aa matter
matter nor
nor did
did you
you ask
ask him
him
25
25 if he
if he was
was representing
client? You said
You said it
it did
did not
not seem
seem
1114
1114
1
1 || like
1ixe he
ne was
was representing
representing aa client.
client. Did
pid you
you tell
tell him
him that?
that?
2
2 A.
A. That sounds
That sounds right.
right. Yes,
Yes, sir.
sir.
3
3 ©.
Q. You didn't
You didn't tell
tell them,
them, No,
No, he
he specifically
specifically said
said he
he
4 [| was
4 was not
not acting
acting on
on behalf
benarf of
of aa client.
client. Correct?
correct?
5
5 A.
A. Correct.
Correct.
6
6 ©.
Q. You went
You went on
on to
to tell
tell them
them at
at that
that first
first substantive
substantive
7 || meeting
7 with Mr.
meeting with Me. Baker
Baker and
and mr. perilippis about
Mr. DeFilippis about this
this that
that
8 || Mr.
8 mr. Bellovin,
serlovin, Mr.
wr. Blaze
Blaze and
and Ms.
Ms. Landau,
Landau, that
that Mr.
Mr. --
-- strike
strike
s [I that.
9 cha.
10
10 Do you
Do you recall
recall telling
telling Mr. DeFilippis and
Mr. DeFilippis and
11 || wr.
11 burham that
Mr. Durham that you
you learned,
learned, during
during your
your meeting
meeting with
with
12 || wr.
12 sussmann, that
Mr. Sussmann, that mr. Blaze, Mr.
Mr. Blaze, Mr. Bellovin
Bellovin and
and Ms. Landau
Ms. Landau
13 || had
13 nad vouched
vouched for
for the
the information
information Sussmann
Sussmann provided
provided toto you
you and
and
14 || --
14 -- period.
period. DoDo you
you remember
rememver that?
that?
15
15 A.
A. No, II don't
No, don't remember
remember that.
that.
16
16 ©.
Q. And would
And would that
that be
be inconsistent
inconsistent with
with what
what you
you said
said
17 | today?
17 todayz
18
18 A.
A. I don't
I don't remember
remember the
the vouching thing right
vouching thing right now.
now.
13
19 ©.
Q. In fact
In fact --
—-
20
20 A.
A. sitting here
Sitting here today,
today, II don't
don't remember
remember the
the vouching
vouching
21 || thing.
21 thing.
22
22 ©.
Q. And what
And what you
you said
said yesterday,
yesterday, and
and we tried to
we tried to just
just
23 || summarize
23 summarize today,
today, was
was that
that you
you thought
thought at
at that
that meeting
meeting he
he
24 || said
24 said that
that Bellovin,
Bellovin, Blaze
Blaze and
and Landau
Landau were
were --
-- they
they were
were --
--
25 | his
25 nis cyber
cyber experts
experts were
were people like that.
people like that. Correct?
Correct?
1115
1115
1
1 A.
A. That's what
That's what II recall
recall sitting
sitting here
here today,
today, yes.
ves.
2
2 ©.
Q. And would
And would it
it --
-- and
and you
you don't
don't remember
remember telling
telling
3
3 Mr. DeFilippis
Mr. DeFilippis and
and Mr. Durham that
Mr. Durham that you
you learned
learned that
that they
they had
had
4
4 vouched for
vouched for the
the information?
information?
5
5 A.
A. I don't
I don't remember
remember saying
saying that,
that, no.
no.
6
6 Q.
Q. Would it
Would it refresh
refresh your
your recollection
see the
the
7
7 paragraph?
paragraph?
8
8 A.
A. I don't
I don't think
think so
so because -- if
because -- if you
you want
want to
to show
show it
it
9
9 to me,
to obviously, but
me, obviously, but II just
just don't
don't remember
remember using
using that
that
10
10 terminology or
terminology or having
having that
that terminology
terminology associated
associated with
with this
this
n
11 part of
part of my conversation with
my conversation with Michael.
Michael.
12
12 ©.
Q. why don't
Why don't we
we just
just pull
pull it
it up
up so
so you
you can
can look
look at
at it
it
13
13 to see
to see ifif there's
there's anything
anything more.
more.
14
14 A.
A. sure.
Sure.
15
15 MR. BERKOWITZ: Paragraph
MR. BERKOWITZ: Paragraph 6,
6, at
at the
the bottom
bottom ofof Page
Page
16
16 99 of
of JB-07
JB-07 and
and the
the top
top of
of Page
Page 8.
8.
17 || BY
17 BY mr.
MR. BERKOWITZ:
BERKOWITZ:
18
18 ©.
Q. And just
And just read
read it
it to
to yourself.
yourself.
19
19 A.
A. Uh-huh.
Uh-huh.
20
20 (Brief pause.)
(Brief pause.)
21
21 Yes, sir,
Yes, sir, I've
I've read
read it.
it.
22
22 ©.
Q. And does
And does that
that refresh
refresh your
your recollection?
recollection?
23
23 A.
A. No, it
No, it does
does not.
not.
24
24 Q.
Q. Is it
Is it inconsistent
inconsistent with
with what
what you
you said
said today?
today?
25
25 A.
A. It's different.
It's different. II don't
don't remember
remember using
using the
the
1116
1116
1
1 "vouching” word.
"vouching" word.
2
2 ©.
Q. And that
And that wasn't your testimony
wasn't your testimony yesterday.
yesterday.
3
3 Correct?
Correct?
1
4 A.
A. That was
That not my
was not testimony in
my testimony in this
this tribunal.
tribunal.
5
5 ©.
Q. And Mr.
And Mr. DeFilippis
DeFilippis and
and Mr.
Mr. Durham,
Durham, at
at that
that meeting
meeting
6
6 -- and
-- and just
just to
to set
set them
them --
-- you're
you're in
in the
the FBI
FBI headquarters.
headquarters.
7
7 In aa secure
In secure facility?
facility? Do Do you
you remember?
remember?
8
8 A.
A. ves.
Yes.
9
9 ©.
Q. Okay. The
Okay. The agents
agents are
are there.
there. Were
Were you
you with
with the
the
10
10 FBI at
FBI at this
this time?
time?
n
11 A.
A. Yo.
No.
12
12 ©.
Q. Okay. So
Okay. So you're
you're back -- they
back -- they are
are there
there and
and they
they
13
13 are talking
are talking to
to you,
you, and
and they
they are
are showing
showing you
you documents
documents and
and
14
14 they are
they are asking
asking you
you questions.
questions. Right?
Right?
15
15 A.
A. ves.
Yes.
16
16 ©.
Q. And it's
And it's aa stressful
stressful environment.
environment. Right?
Right?
17
17 A.
A. ves.
Yes.
18
18 ©.
Q. Okay. And
Okay. And they
they are
are trying
trying to
to say,
say, Well,
Well, what
what
19
19 about this?
about this? What
What about
about that?
that? They
They are
are asking
asking you
you questions
questions
20
20 to elicit
to elicit information.
information. Right?
Right?
21
21 A.
A. ves.
Yes.
22
22 ©.
Q. It's aa little
It's little different
different than
than the
the smooth
smooth discussion
discussion
23
23 we had
we had yesterday
yesterday and
and today
today after
after you've
you've been
been through
through things.
things.
24
24 Right? It's
Right? It's aa back-and-forth about what's
back-and-forth about what's happened.
happened.
25
25 Correct? Iterative?
Correct? Iterative?
1117
1117
1
1 A.
A. It was
It was iterative
iterative and
and back-and-forth.
back-and-forth. It It was not
was not
2
2 disorderly. It
disorderly. It was
was aa professional
professional discussion
discussion with
with them.
them.
3
3 ©.
Q. And they
And they asked
asked you
you in
in that
that meeting
meeting about
about that
that
4
4 chain of
chain of custody
custody form.
form. Right?
Right?
5
5 A.
A. I don't
I don't remember
remember when they asked
when they asked me about that.
me about that.
6
6 Q.
Q. Okay. Do
Okay. Do you
you remember
remember being
being asked
asked about
about it?
it?
7
7 A.
A. At some
At some point,
point, yes.
yes.
8
8 ©.
Q. Would it
Would it refresh
refresh your
your recollection
see aa
9
9 paragraph to
paragraph to remind
remind you
you that
that you
you were
were shown
shown aa chain
chain ofof
10
10 custody form?
custody form?
n
11 A.
A. If it's
If it's in
in the
the document
document that
that we are looking
we are looking at,at, II
12
12 assume that
assume that they
they talked
talked to
to me about it
me about it then.
then.
13
13 ©.
Q. Let's just
Let's just pull
pull it
it up
up for
for you
you because
because II don't
don't want
want
14
14 to --
to == I'm
I'm not
not looking
looking to
to vouch
vouch --
-- no
no pun
pun intended
intended --
-- for
for
15
15 this.
this.
16
16 MR. BERKOWITZ: Page
MR. BERKOWITZ: Page 10,
10, Paragraph
Paragraph 3.
3.
17
17 THE WITNESS:
THE WITNESS: Which part do
Which part do you
you want
want me to focus
me to focus
18
18 on? Read
on? Read the
the whole
whole thing?
thing?
19 || BY
19 BY mr.
MR. BERKOWITZ:
BERKOWITZ:
20
20 ©.
Q. Why don't
Why don't you
you read
read the
the first
first sentence
sentence for
for now,
now, and
and
21
21 then I'll
then I'll ask
ask other
other ones.
ones.
22
22 A.
A. Okay, yes.
Okay, yes. SoSo it
it appears
appears that
that they
they asked
asked me about
me about
23
23 it during
it during that
that session.
session.
24
24 ©.
Q. And do
And do you
you recall
recall telling
telling them
them that
that you
you cannot
cannot
25
25 recall not
recall not identifying
identifying Mr. Sussmann as
Mr. Sussmann as the
the source
source of
of the
the
118
1118
1
1 || arfa-sank information provided
Alfa-Bank information provided to
to you
you when
when you
you were asked by
were asked by
2 | ws.
2 xerrye
Ms. Kelly?
3
3 A.
A. I cannot
I cannot recall
recall identifying
identifying Sussmann
Sussmann asas aa source
source
4 [I --
4 -- I1 do
do not
not recall
recall --
-- yes.
yes. Okay.
okay. Sorry.
sorry. what's your
What's your
5 [| question?
5 question:
6
6 ©.
Q. So sitting
So sitting here
here today,
today, is
is my question not
my question not --
-- do
do
7 || you
7 vou recall
recalr telling
telling them
them that
that you
you certainly
certainly didn't
didn't remember
remember
8 || withholding
8 wichnording Mr. sussmann's name
Mr. Sussmann's name from
from anybody?
anybody?
9
9 A.
A. I've had
I've had aa hard
hard time
time with
with this
this particular
particular point
point
10 || and
10 and I1 don't
don't --= I1 just
just am
am not
not clear
clear --
-- II don't
don't clearly
clearly
11 || remember,
11 remember, like,
like, making
making a a big
big thing
thing out
out of
of withholding
withholding that
that
12 || information.
12 information. And And as
as II explained earlier, if
explained earlier, if II did,
did, it's
it's
13 || because
13 vecause I1 was
was thinking
thinking ofof Michael
Michael as
as aa confidential
confidential human
human
14 | source.
14 source.
1s
15 ©.
Q. Iam
I not saying
am not saying if
if you
you did
did or
or didn't.
didn't. YouYou cannot
cannot
16 [| think
16 think of
of any
any reason
reason why
why you
you would
would knowingly
knowingly keep
keep someone
someone
17 || from
17 from knowing
knowing the
the identity
identity of
of Mr.
Mr. Sussmann
Sussmann who
who gave
gave you
you the
the
18 | information.
18 information. Correct?
correct?
19
19 A.
A. Well, that's
Well, that's what it says,
what it says, yes.
ves.
20
20 ©.
Q. what's that?
What's that?
2
21 A.
A. That is
That is what
what it
it says,
says, yes.
yes.
22
22 ©.
Q. In fact,
In fact, you
you were surprised to
were surprised to hear
hear that
that no
no FBI
FBI
23 || written
23 written documentation
documentation or or record
record identified
identified Mr. Sussmann as
Mr. Sussmann as
24 || the
24 the original
original source
source of
of the
the information
information provided. Correct?
provided. Correct?
25
25 A.
A. That II was
That was surprised
surprised about,
about, because
because II had
had told
told
1119
1119
1
1 Bill about
Bill about this,
this, and
and II think
think II told
told Pete
Pete Strzok
Strzok about
about it.
it.
2
2 And the fact
And the fact that
that nobody
nobody wrote
wrote it
it down
down anywhere,
anywhere, when
when II
3
3 heard that,
heard that, II don't
don't know
know if
if it's
it's actually
actually true
true or
or not,
not, but
but II
4
4 take them
take them at
at their
their word that, yeah,
word that, yeah, II found
found that
that to
to be
be
5
5 surprising.
surprising.
6
6 Q.
Q. You then,
You then, sir,
sir, were
were --
--
7
7 MR. BERKOWITZ: And
MR. BERKOWITZ: And II may be at
may be at aa good
good breaking
breaking
8
8 point, Judge.
point, Judge.
9
9 THE COURT:
THE COURT: How are
How are we
we doing,
doing, ladies
ladies and
and
10
10 gentlemen?
gentlemen? Another 15 minutes
Another 15 or so?
minutes or so? Keep
Keep going?
going?
1
11 MR. BERKOWITZ: At
MR. BERKOWITZ: At least
least we have some
we have some attention.
attention.
12
12 We'll keep
We'll keep going,
going, Judge.
Judge. Very
Very good.
good.
13
13 BY
BY MR.
MR. BERKOWITZ:
BERKOWITZ:
14
14 Q.
Q. And at
And at that
that time,
time, you
you were
were there
there with
with your
your
15
15 attorney.
attorney. Correct?
Correct?
16
16 A.
A. ves.
Yes.
17
17 Q.
Q. Did they
Did they tell
tell you
you at
at that
that meeting on June
meeting on June 11th
11th of
of
18
18 2020 that
2020 that they
they had
had notes
notes from
from Mr.
Mr. Priestap?
Priestap?
19
19 A.
A. At some
At some point
point in
in time
time they
they showed
showed me the notes.
me the notes. II
20
20 don't know
don't know if
if it
it was
was in
in this
this meeting
meeting or
or aa subsequent
subsequent one.
one.
21
21 Q.
Q. So let's
So let's then
then turn
turn --
-- aa week
week later
later you're
you're back.
back.
22
22 Do you
Do you remember
remember that?
that?
23
23 A.
A. Not really,
Not really, no.
no.
24
24 @.
Q. Why do
Why do you
you think
think they
they called
called you
you back a week
back a week
25
25 later?
later?
1120
1120
1
1 A.
A. I don't
I don't know.
know.
2
2 ©.
Q. You don't
You don't remember
remember that?
that?
3
3 A.
A. I don't
I don't remember
remember the
the exact
exact chronology
chronology ofof the
the
4
4 dates. Whatever
dates. they are
Whatever they are is
is what
what they
they are.
are.
5
5 ©.
Q. Did Mr.
Did Mr. DeFilippis
DeFilippis oror Mr. Durham ask
Mr. Durham ask you
you to
to go
go
6
6 back and
back and think
think harder
harder about
about certain
certain things?
things?
7
7 A.
A. don't remember
I don't remember that.
that.
8
8 ©.
Q. Well, do
Well, do you
you remember
remember when
when you
you met
met with
with them
them on
on
9
9 June 18th
June 18th of
of 2020?
2020? DoDo you
you remember
remember generally
generally that
that date?
date?
10
10 A.
A. I'll take
I'll take your
your word
word for
for it.
it. II don't
don't remember
remember that
that
n
11 date specifically.
date specifically.
12
12 ©.
Q. Just to
Just to orient,
orient, September
September of
of '16
'16 is
is the
the meeting
meeting
13
13 with Mr.
with Mr. Sussmann,
Sussmann, March of '17
March of '17 are
are the
the Tasha
Tasha [sic]
[sic] Gauhar's
Gauhar's
14
14 notes on
notes on behalf
behalf of
of aa client,
client, 2018
2018 in
in October
October we've
we've got the
got the
15
15 two congressional
two congressional testimonies,
testimonies, July
July of
of 2019
2019 we've
we've got
got the
the
16
16 1.6. --
I.G. ==
17
17 A.
A. Uh-huh.
Uh-huh.
18
18 Q.
Q. -- cybersecurity
-- cybersecurity clients,
clients, June
June 8th
8th of
of 2020
2020 ---- June
June
19
19 11th of
11th of 2020
2020 is
is that
that first
first interview
interview we
we just
just walked
walked through,
through,
20
20 and now
and now we're
we're on
on June
June 18th
18th of
of 2020.
2020.
21
21 A.
A. Okay.
Okay.
22
22 ©.
Q. And at
And at the
the outset
outset of
of that
that interview,
interview, dodo you
you
23
23 remember your
remember your lawyer
lawyer advising
advising Mr.
Mr. Durham
Durham and
and DeFelippis
DeFelippis
24
24 that, in
that, in the
the interest
interest of
of full
full disclosure,
disclosure, hehe wanted
wanted to
to
25
25 advise that
advise that you
you had
had been
been contacted
contacted by the Senate
by the Senate Judiciary
Judiciary
nz
1121
1
1 Committee.
Committee. Do you
Do you remember
remember that?
that?
2
2 A.
A. No, actually
No, actually II don't.
don't.
3
3 ©.
Q. Do you
Do you remember
remember him
him saying
saying that
that subsequent
subsequent toto the
the
4
4 prior interview
prior interview ---- meaning after the
meaning after the interview
interview onon the
the 11th.
llth.
5
5 Sometimes these
Sometimes these words
words are
are aa little
little bit
bit more complicated than
more complicated than
6
6 they need
they need to
to be,
be, but
but after
after your
your interview
interview on
on the
the 11th,
llth, you
you
7
7 had thought
had thought long
long and
and hard
hard about
about the
the discussion
discussion during
during the
the
8
8 interview about
interview about whether
whether you
you had
had affirmatively
affirmatively concealed
concealed or or
9
9 withheld from
withheld from other
other FBI
FBI employees
employees the
the identity
identity ofof Michael
Michael
10
10 Sussmann as
Sussmann as the
the source
source who
who provided you with
provided you with the
the information
information
n
11 regarding alleged
regarding alleged backchannel
backchannel communications
communications between
between servers
servers
12
12 of Alfa-Bank
of Alfa-Bank andand the
the Trump
Trump Organization.
Organization.
13
13 Do you
Do you remember
remember being
being asked
asked to
to think
think "long
"long and
and
14
14 hard" about
hard" about that?
that?
15
15 A.
A. Yo.
No.
16
16 ©.
Q. Do you
Do you remember
remember thinking
thinking long
long and
and hard
hard about
about it?
it?
17
17 A.
A. I've been
I've thinking about
been thinking about this
this whole
whole thing
thing aa lot
lot
18
18 for the
for the last
last several
several years,
years, so
so it's
it's hard
hard for
for me
me to
to answer
answer
19
19 that question.
that question.
20
20 ©.
Q. Do you
Do you remember
remember your
your lawyer
lawyer telling
telling them
them that
that you
you
21
21 thought long
thought long and
and hard
hard about
about it?
it?
22
22 A.
A. Not in
Not in particular,
particular, no.
no.
23
23 ©.
Q. And your
And your lawyer
lawyer --
-- do
do you
you remember
remember your
your lawyer
lawyer
24
24 saying that
saying that you
you could
could not
not recall
recall any
any such
such action
action on
on your
your
25
25 part to
part to withhold
withhold the
the identity
identity of
of Michael
Michael Sussmann?
Sussmann? DoDo you
you
1122
1122
1
1 || remember
remember that
that conversation
conversation at at the
the beginning
beginning ofof your
your
2 || interview
2 interview onon the
tne 18th?
18en2
3
3 A.
A. Not really,
Not really, no.
no.
4
4 ©.
Q. And do
And do you
you remember
remember them,
them, again
again --
-- do
do you
you remember
remember
5 || them
5 them showing
snowing you
you the
the notes
notes auring this meeting?
during this meeting?
6
6 A.
A. Which notes?
Which notes?
7
7 Q.
Q. Mr. Priestap's
Mr. Priestap's notes.
notes.
8
8 A.
A. I can't
I can't remember
remember when
when II saw
saw those
those notes
notes for
for the
the
9 [| first
9 first time.
time.
10
10 ©.
Q. And do
And do you
you remember
remember reiterating
reiterating to to them
them that
that
11 || wr.
11 sussmann contacted
Mr. Sussmann contacted you
you by phone and
by phone and requested
requested aa meeting?
meeting?
12 || Do
12 po you
you remember
remember telling
telling them
them that?
that?
13
13 A.
A. I know
I know II thought
thought that
that for
for aa long
long time.
time.
14
14 ©.
Q. And at
And at that
that meeting
meeting you,
you, for
for the
the first
first time,
time,
15 || said
15 said --
-- at
at least
1east according
according to to my
my records
records --
-- that
that
16 || wr.
16 sussmann said
Mr. Sussmann said he
he was
was not
not there
there on
on behalf
behalf of
of any
any client.
client.
17 || and
17 he did
And he did not
not say
say he
he was
was there
there representing
representing the
the Clinton
Clinton
18 || campaign.
18 campaign.
13
19 Remember, that
Remember, that was
was the
the meeting
meeting where
where you
you said
said "not
"not
20 || there
20 there on
on behalf
behalf of
of any
any client".
ciientr.
2
21 A.
A. I don't
I don't remember
remember which particular meeting
which particular meeting itit was
was
22 || on
22 on which particular date.
which particular date. Obviously
Obviously II remember,
remember, atat some
some
23 [ point
23 point in
in time,
time, telling
telling them
them that.
that.
24
24 ©.
Q. Is it
Is it fair
fair to
to say
say that
that the
the moment
moment that
that you
you started
started
25 || telling
25 telling them
them he
he was
was not
not there
there on
on behalf
behalf of
of any
any client
client was
was
123
1123
1
1 when you
when you saw
saw Mr.
Mr. Priestap's
Priestap's notes?
notes?
2
2 A.
A. It was
It was aa combination
combination of
of them
them asking
asking me
me all
all of
of
3
3 these very
these very specific
specific questions
questions and
and following
following up
up on
on it
it and
and
4
4 then looking
then looking at
at Bill's
Bill's notes
notes that
that triggered
triggered my
my memory about
memory about
5
5 the conversation
the conversation with
with Michael.
Michael.
6
6 ©.
Q. Such that
Such that today,
today, May 18th --
May 18th -- 19th?
19th? I'm
I'm losing
losing
7
7 track.
track.
8
8 A.
A. 19th, II think.
19th, think.
9
9 ©.
Q. -- 19th
-- 19th of
of 2022,
2022, you
you now
now remember
remember saying,
saying, with
with aa
10
10 hundred percent
hundred percent certainty
certainty that
that Mr. Sussmann told
Mr. Sussmann told you
you he
he was
was
n
11 not there
not there on
on behalf
behalf of
of any
any particular client. Correct?
particular client. Correct?
12
12 A.
A. Yes. That's
Yes. That's my memory sitting
my memory sitting here
here today.
today.
13
13 ©.
Q. So you've
So you've added
added "particular"
"particular toto what
what you
you told
told them
them
14
14 on that
on that date.
date. Correct?
Correct?
15
15 A.
A. I'd have
I'd have to
to look
look at
at that
that again.
again. But
But that
that is
is mymy
16 || memory.
16 hat is
memory. That is my
my testimony
testimony sitting
sitting here
here today
today with
with
17
17 respect to
respect to what he said.
what he said.
18
18 ©.
Q. A hundred
A hundred percent
percent accuracy
accuracy is
is what
what you
you said
said
19
19 yesterday.
yesterday.
20
20 A.
A. Yes, sir.
Yes, sir.
21
21 ©.
Q. Now, you
Now, you also
also talked
talked at
at that
that meeting about the
meeting about the
22
22 researchers. Correct?
researchers. Correct?
23
23 A.
A. I'm sorry,
I'm sorry, when?
when?
24
24 ©.
Q. The cyber
The cyber researchers.
researchers. At At that
that meeting
meeting you
you said
said
25
25 Mr. Sussmann
Mr. Sussmann advised
advised you
you that
that cyber
cyber researchers
researchers brought
brought thethe
1124
1124
1
1 information to
information to you,
you, but
but things
things were a bit
were a bit murky
murky in
in your
your mind
mind
2
2 as to
as to the
the actual
actual origins
origins of
of the
the information.
information. Do you
Do you
3
3 remember telling
remember telling them
them that?
that?
4
4 A.
A. I don't
I don't remember
remember telling
telling them
them that,
that, but
but II remember
remember
5
5 that.
that.
6
6 ©.
Q. You remember
You remember that
that being
being the
the case?
case?
7
7 A.
A. I remember
I remember that
that that's
that's what,
what, in
in general,
general, occurred.
occurred.
8
8 That's my
That's memory.
my memory.
9
9 ©.
Q. And at
And at that
that meeting
meeting for
for the
the first
first time,
time, you
you told
told
10
10 them, After
them, After thinking
thinking about
about it
it further,
further, you
you recalled
recalled being
being
n
11 briefed at
briefed at some
some point
point on
on an
an unrecalled
unrecalled date
date about
about the
the
12
12 investigation involving
investigation involving the
the intrusion
intrusion ofof the
the DNC
DNC computers
computers
13
13 and possibly
and possibly learning
learning at
at that
that briefing
briefing that
that Sussmann,
Sussmann, who
who
14
14 you knew
you knew from
from previous
previous contacts,
contacts, was
was representing
representing the
the DNC
DNC on
on
15
15 that matter.
that matter.
16
16 Do you
Do you remember
remember that
that that
that was
was the
the meeting where
meeting where
17
17 you said,
you said, "After
"After further
further thought,
thought, Mr.
Mr. Sussmann
Sussmann was
was
18
18 representing the
DNC at
at least
least on
on the
the hack?
hack?
19
19 A.
A. Again, II don't
Again, remember that
don't remember that it
it was
was at
at that
that
20
20 particular meeting,
particular but II remember
meeting, but remember at
at some
some point
point
21
21 acknowledging that.
acknowledging that.
22
22 ©.
Q. And that's
And that's because
because you
you believed
believed that
that --
-- or
or you
you had
had
23
23 seen Mr.
seen Mr. Priestap's
Priestap's notes
notes at
at that
that time.
time. Correct?
Correct? That's
That's
24
24 what triggered
what triggered your
your recollection,
recollection, isis it
it not?
not?
25
25 A.
A. Yes, yes,
Yes, yes, yes.
yes. I'm
I'm sorry.
sorry. Yes.
Yes. II think
think so.
so.
1125
1125
1
1 Again,
Again, II can't
can't remember
remember specifically
specifically when
when II saw
saw Bill's
Bill's
2
2 notes. But
notes. But at
at some
some point
point in
in time
time II did,
did, and
and that's
that's what
what
3
3 triggered my
triggered my set
set of
of memories on this.
memories on this.
4
4 ©.
Q. And you
And you told
told them
them on
on June
June 18th
18th of
of 2020,
2020, that
that you
you
5
5 believed the
believed the information
information Mr.
Mr. Sussmann
Sussmann provided
provided you
you was
was
6
6 credible. Correct?
credible. Correct?
7
7 A.
A. I'm sorry.
I'm sorry. That
That doesn't
doesn't make sense to
make sense to me.
me. Could
Could
8
8 you repeat
you repeat that?
that?
9
9 ©.
Q. You told
You told Mr. Durham and
Mr. Durham and Mr.
Mr. DeFilippis
DeFilippis onon June
June
10
10 18th of
18th of 2020
2020 that
that you
you believed
believed the
the information
information Mr. Sussmann
Mr. Sussmann
n
11 provided you
provided you was
was credible
credible for
for several
several reasons.
reasons.
12
12 A.
A. I'm struggling
I'm struggling with
with that.
that.
13
13 ©.
Q. Let me
Let me give
give you
you some
some more context.
more context.
14
14 A.
A. Yeah.
Yeah.
15
15 ©.
Q. You said
You said that
that you
you believed
believed Sussmann,
Sussmann, aa former
former DOJ
DOJ
16
16 prosecutor, to
prosecutor, to be an ethical
be an ethical person.
person. That's
That's true.
true. Correct?
Correct?
17
17 Do you
Do you remember
remember telling
telling them
them that?
that?
18
18 A.
A. ves.
Yes.
19
19 ©.
Q. And do
And do you
you remember
remember telling
telling them
them that
that you
you also
also
20
20 believed he
believed he wouldn't
wouldn't have
have brought
brought the
the information
information to to you
you if
if
21
21 he did
he did not
not himself
himself believe
believe itit was
was credible?
credible?
22
22 A.
A. ves.
Yes.
23
23 ©.
Q. And do
And do you
you remember
remember telling
telling him
him that
that the
the
24
24 researchers who
researchers who found
found the
the information
information believed
believed itit to
to be
be
25
25 credible?
credible?
1126
1126
1
1 A.
A. That's what
That's what II understood,
understood, yes.
yes.
2
2 ©.
Q. And, finally,
And, finally, you
you believed
believed itit was
was credible
credible enough
enough
3
3 for the
for the FBI
FBI to
to accept
accept and
and review
review the
the information.
Correct?
1
4 A.
A. Yes.
Yes.
5
5 ©.
Q. And in
And in addition,
addition, he he had
had told
told you
you about
about aa news
news
6
6 organization. And
organization. And when you called
when you called him
him to
to get
get the
the name
name of
of
7
7 the news
the news organization,
organization, he he gave
gave you
you one
one and
and you
you spoke
spoke with
with aa
8
8 reporter who
reporter who said,
said, in
in fact,
fact, II have
have been in touch
been in touch with
with
9 || Mr.
9 sussmann. Right?
Mr. Sussmann. wrigne2
10
10 A.
A. I don't
I don't know
know about
about that
that last
last piece,
piece, but
but II know
know
n
11 that he
that he --
-- well,
well, II guess he must
guess he have been
must have been in
in touch
touch with
with
12 || wr.
12 sussmann, yes.
Mr. Sussmann, yes. That
That makes
makes sense,
sense, yes.
ves.
13
13 ©.
Q. And that
And that further
further atat least
least verified
verified some
some of
of what
what
14
14 Mr. Sussmann
Mr. Sussmann was
was telling
telling you.
you. Correct?
Correct?
15
15 A.
A. Yes. Yes.
Yes. Yes.
16
16 ©.
Q. Now, so
Now, so --
-- and
and II will represent to
will represent to you
you that
that you
you
17
17 did review
did review the
the Mr. Priestap notes?
Mr. Priestap notes?
18
18 A.
A. At that
At that meeting?
meeting?
19
19 ©.
Q. Yes. And
Yes. it says,
And it says, Having
Having reviewed
reviewed --
-- let
let me just
me just
20
20 say, do
say, do you
you remember
remember them
them giving
giving you
you the
the Priestap
Priestap notes
notes and
and
21
21 having reviewed
having reviewed notes
notes ofof their
their telephone,
telephone, telling
telling them,
them,
22
22 Having reviewed
Having reviewed notes
notes ofof Mr.
Mr. Priestap's
Priestap's telephone
telephone
23
23 conversation about
conversation about the
the Alfa-Bank matter when
Alfa-Bank matter when it
it first
first arose,
arose,
24
24 and recognizing
and recognizing that
that the
the notes
notes indicate
indicate that
that you
you told
told
25
25 Priestap that
Priestap that Sussmann
Sussmann said
said he
he was not acting
was not acting on
on behalf
behalf of
of aa
1127
1127
1
1 || cient.
client. vou said
You said that
that that
that must be what
must be what you
you told
told to
to
2 ||
2 eriestap.
Priestap. correct?
Correct?
3
3 A.
A. ves.
Yes.
4
4 ©.
Q. And so
And so it's
it's those
those notes
notes that
that made you say,
made you say, "It
"It
5 ||
5 must nave been
must have been that".
that". correctz
Correct?
6
6 A.
A. The notes
The notes and
and the
the questions
questions triggered
triggered the
the memory.
memory.
7 ||
7 my
My memory on this
memory on this point,
point, sitting
sitting here
here today
today right
right now,
now, is
is
8 [[
8 crear.
clear.
9
9 ©.
Q. And you
And you said
said that
that --
-- and
and you
you looked
looked at
at the
the DNC
DNC on
on
10 ||
10 the notes
the notes --
-- and
and we'll
we'll get to the
get to the notes
notes probably
probably tomorrow
tomorrow -- --
11 [|
11 and you
and you said
said when
when you
you saw
saw DNC
DNC and
and Clinton,
Clinton, that
that you
you must
must
12 |
12 nave told
have told Priestap
priestap that,
that, just
just as
as you
you told
told him
him the
the other
other
13 ||
13 things that
things that are
are reflected
reflected in
in Priestap's
priestap's notes.
notes. Correct?
Correct?
14
14 A.
A. Correct as
Correct as to
to the
the piece
piece about
about --
-- that
that II must
must have
have
15 ||
15 tora Bill
told Bill about
about the
the DNC
DNC and
and the
the Clinton
Clinton campaign
campaign --
-- and
ana
16 ||
16 that's wnat
that's what I1 am
am saying
saying to
to you
you today
today is
is what
what helps
helps me anchor
me anchor
17 ||
17 the timing
the timing ---- that
that II must
must have
have learned
learned about
about Michael's
Michael's
18 ||
18 relationship with
relationship with the
the DNC
DNC and
and the
the Hillary
Hillary campaign
campaign prior
prior toto
19 |
19 that conversation
that conversation with
with Bill.
Bin.
20
20 So some
So some time
time between the hacks
between the hacks and
and that
that time
time --
-- atat
21 ||
21 my
my meeting
meeting with
with Michael
Michael ---- that's
that's when
when II learned
learned about
about his
his
22 ||
22 association --
association -- his
his representation,
representation, more accurately put,
more accurately put, ofof
23
23 [the DNC
the pNC and
and the
the HFA.
uEA.
24
24 ©.
Q. Did you
Did you talk
talk to
to Mr.
Mr. Priestap
Priestap about
about the
the notes?
notes?
25
25 A.
A. I don't
I don't think
think I've
I've ever
ever talked
talked to
to Bill
Bill Priestap
Priestap
1128
1128
1
1 || about
avout those
those notes.
notes.
2
2 ©.
Q. You didn't
You didn't say,
say, What
What did
did you
you mean when you
mean when you wrote
wrote
3 || this?
3 enis2 Correct?
correct:
1
4 A.
A. No, because
No, because II don't
don't remember
remember seeing
seeing the
the notes
notes
5 [| until
5 until -- -- what
wnat was
was it,
it, 2020
2020 you
you are
are saying?
saying? Yeah,
vean, 2020,
2020, and
ana
6 [| at
6 at that
that time
time both
botn Bill
Bill and
ana II left
left the
the FBI.
FI.
7
7 ©.
Q. And your
And your testimony
testimony today
today about
about what
what happened
happened atat
8 || that
8 that meeting
meeting isis aided
aided in
in significant,
significant, if
if not
not in
in whole
whole part,
part,
9 || by
9 by mr. eriestap's notes.
Mr. Priestap's notes. Correct?
correct?
10
10 A.
A. It was
It was triggered
triggered by Bill's notes.
by Bill's notes. And
And II have
have aa --
--
11 || sitting
11 sitting here
here today,
today, II have
have aa present
present recollection
recollection ofof what
what
12 || michael
12 said in
Michael said in the
the meeting.
meeting.
13
13 ©.
Q. Based on
Based on the
the notes.
notes. Correct?
Correct?
14
14 A.
A. The notes
The notes and
and the
the very
very specific
specific questioning
questioning that
that
15 || they
15 they ---- that
that I1 went
went through
through with
with Mr.
Mr. Durham
Durham and
and his
his team.
team.
16 || They
16 they asked
asked me repeatea and
me repeated and very
very specific
specific questions
questions about
about
17 || this
17 this matter.
matter. Andand so
so that
that --
-- and
and probing
probing my
my memory about
memory about
18 || that
18 chat and
and then
then looking
looking at
at Bill's
Bill's notes
notes made
made me remember what
me remember what
19 || I1 am
19 an telling
ter1ing you
you today.
today.
20
20 Q.
Q. Did they
Did they threaten
threaten you,
you, sir,
sir, with
with anything
anything --
-- based
based
21 [[ on
21 on the
the fact
fact that
that you
you had
had previously
previously told
told folks
folks under
under oath
oath oror
22 || subject
22 subject to to perjury
perjury ---- that
that you
you had
had said
said inconsistent
inconsistent things?
things?
23
23 A.
A. ur. Durham
Mr. Durham and
and his
his team
team have
have never
never threatened
threatened meme
24
24 [in any
in any way.
way.
25
25 ©.
Q. But you
But you understood,
understood, sir,
sir, did
did you
you not,
not, as
as aa lawyer,
lawyer,
1129
1129
1
1 that if
that if you
you had
had said
said something
something that
that someone
someone determined
determined was
was
2
2 false, under
false, under oath,
oath, or
or subject
subject to
to perjury,
perjury, you
you could
could be
be
3
3 prosecuted.
prosecuted. Correct?
Correct?
4
4 A.
A. ves.
Yes.
5
5 THE COURT:
All right. We're going
We're going to
to wrap
wrap it
it up
up
6
6 there, ladies
there, ladies and
and gentlemen,
gentlemen, and
and dismiss
dismiss you
you for
for the
the
7
7 evening.
evening. Another long
Another long day.
day. Thank you
Thank you for
for your
your patience.
patience.
8
8 No discussions
No discussions about
about the
the case.
case. No research
No research about
about
9
9 the case.
the case. No social
No social media
media contact
contact or
or interactions
interactions about
about the
the
10
10 case.
case. All right?
All right?
1
11 Have aa great
Have great night,
night, and
and we
we will
will see
see you
you back
back here
here
12
12 at 9:00
at 9:00 o'clock
o'clock inin the
the morning.
morning.
13
13 (Jury exited
(Jury exited the
the courtroom.)
courtroom.)
14
14 THE COURT:
THE COURT: All right,
All right, sir.
sir. You can
You can step
step down.
down.
15
15 THE WITNESS:
Thank you.
16
16 MR. BERKOWITZ: And,
MR. BERKOWITZ: And, Your
Your Honor,
Honor, obviously
obviously
17
17 Mr. Baker, as
Mr. Baker, as aa lawyer,
lawyer, knows
knows that
that he's
he's not
not to
to discuss
discuss his
his
18
18 testimony.
testimony.
19
19 THE COURT:
THE COURT: I'm sure
I'm sure he
he understands
understands that.
that.
20
20 THE WITNESS:
Thank you.
21
21 THE COURT:
All right. Okay.
Okay. We'll see
We'll see you
you in
in
22
22 the morning.
the morning.
23
23 (Proceedings concluded
(Proceedings concluded at
at 5:13
5:13 p.m.)
p.m.)
24
24
25
25
1130
1130
1
1 CERTIFICATE
C E R T I F I C A T E
2
2
3
3 1, Lorraine
I, Lorraine T.
T. Herman,
Herman, Official
Official Court
Court Reporter, do
Reporter, do
4
4 hereby certify
hereby certify that
that the
the above
above and
and foregoing
foregoing is
is aa true
true and
and
5
5 accurate transcript
accurate transcript of
of my stenographic notes
my stenographic notes and
and is
is aa
6
6 complete transcript
complete transcript of
of the
the proceedings in the
proceedings in the above-entitled
above-entitled
7
7 || matter to the
matter to the best
best of
of my
my ability.
ability.
8
8
9
9
10
10
n
11
12
12
13
13
14
14 May 20, 2022
May 20, 2022 Is]
/s/
DATE
DATE Lorraine T.
Lorraine T. Herman
Herman
15
15
16
16
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25
25
1131
1107/24 1113/10 04 [2] 1033/17 17 [1] 1100/1 2018 [10] 994/9

1113/16 1115/14 1034/9 18 [5] 1049/23 1082/24 1087/18
BY MR.
1117/15 1119/6 06 [1] 1036/4 1050/3 1100/1 1087/22 1089/24
BERKOWITZ:
1119/10 1129/15 07 [1] 1115/16 1105/19 1109/14 1090/17 1090/24
[34] 1025/20
MR. DeFILIPPIS: 18th [15] 994/9 1096/3 1096/9
1027/21 1028/25
[18] 992/15 1 1040/1 1044/6 1120/14
1034/5 1034/12 10 [5] 1010/9
992/20 993/20 1050/12 1090/24 2019 [21] 1005/1
1035/3 1036/8 1011/23 1036/15
994/9 994/16 1096/2 1096/11 1005/19 1006/4
1036/19 1037/6 1036/19 1117/16
1004/24 1005/21 1096/15 1096/16 1006/14 1007/4
1038/25 1048/18 1001 [4] 1049/23
1008/22 1009/11 1120/9 1120/20 1007/19 1009/9
1052/14 1053/4 1050/3 1105/19
1011/14 1027/16 1122/2 1123/6 1009/19 1010/14
1062/17 1065/19 1109/14
1027/18 1028/22 1125/4 1125/10 1030/9 1030/12
1066/3 1072/23 10020 [1] 989/20
1034/10 1036/16 19 [1] 989/4 1032/8 1033/4
1074/14 1076/22 108 [1] 1027/15
1052/25 1065/5 19th [26] 1008/15 1034/18 1035/3
1079/19 1080/5 10:28 [3] 1011/19
1079/14 1010/21 1011/2 1099/14 1099/19
1083/25 1085/20 1073/7 1073/10
THE COURT: [35] 1011/6 1013/14 1104/23 1105/5
1091/21 1096/23 10:34 [1] 1073/15
991/3 991/5 1037/10 1040/3 1105/6 1120/15
1098/2 1099/6 10th [1] 1007/19
991/11 991/22 1050/13 1052/1 202 [1] 989/25
1102/6 1107/20 11 [2] 1038/24
992/6 992/9 1052/5 1052/6 2020 [21] 1011/18
1108/2 1113/20 1074/7
992/19 992/21 1052/19 1053/12 1030/13 1044/23
1115/16 1117/18 11:04 [2] 1074/4
993/1 993/19 1053/15 1054/15 1093/14 1105/2
1119/12 1074/7
994/14 1027/19 1056/23 1062/24 1105/10 1105/15
BY MR. 11:05 [2] 1074/13
1028/24 1033/25 1066/16 1070/23 1105/21 1106/22
DeFILIPPIS: [8] 1074/14
1034/11 1036/15 1093/22 1096/9 1109/24 1110/22
993/21 994/18 11:47 [1] 1006/5
1036/17 1052/11 1097/12 1110/7 1113/10 1119/18
1005/1 1005/22 11th [4] 1119/17
1053/2 1064/15 1123/6 1123/8 1120/9 1120/18
1008/24 1009/12 1120/19 1121/4
1064/18 1064/23 1123/9 1120/19 1120/20
1010/1 1011/16 1121/6
1065/6 1065/8 1:21-CR-00582-C 1125/4 1125/10
DEPUTY CLERK: 1200 [1] 989/20
1065/11 1065/15 RC-1 [1] 989/3 1128/5 1128/5
[1] 1064/24 122 [3] 994/17
1066/1 1076/20 1:56 [1] 989/4 2021 [1] 1032/23
JURORS: [2] 997/13 1091/19
1079/15 1113/14 2022 [6] 989/4
993/18 1052/13
1119/8 1129/4 1271 [1] 989/19 2 1047/6 1048/10
MR. ALGOR: [8] 12:30 [2] 1009/15 20 [4] 1009/9
1129/13 1129/18 1049/5 1123/9
991/1 991/4 991/6 1009/24 1052/2 1100/12
1129/20 1130/14
991/12 991/24 12th [1] 1096/25 1130/14
THE WITNESS: 20th [1] 1027/23
992/8 992/14 13 [7] 1038/24 20001 [1] 989/25
[15] 1034/4 21 [3] 1009/24
1076/19 1038/25 1069/6 20002 [1] 989/14
1035/1 1062/13 1068/22 1071/19
MR. 1072/2 1072/16 2016 [22] 1008/15
1065/13 1074/10 212 [2] 989/15
BERKOWITZ: 1072/17 1072/18 1010/21 1011/2
1074/13 1085/19 989/20
[39] 994/12 13-minute [1] 1011/6 1013/14
1096/22 1107/17 21st [3] 1041/21
1009/25 1027/14 1070/2 1032/8 1032/9
1107/25 1113/12 1068/16 1070/2
1027/17 1034/2 14 [2] 1100/1 1037/10 1040/1
1113/18 1117/16 22 [1] 1073/7
1034/8 1034/25 1100/1 1040/4 1042/4
1129/14 1129/19 2231 [1] 989/15
1036/6 1036/13 1400 [1] 1068/20 1050/13 1052/2 22nd [7] 1005/1
1037/5 1038/23 ' 145 [1] 989/14 1052/7 1053/12 1005/3 1006/4
1048/17 1053/3 '16 [1] 1120/12 14th [2] 1033/18 1054/15 1056/23 1006/14 1007/4
1062/14 1064/17 '17 [2] 1082/24 1035/3 1070/2 1071/19 1050/6 1072/25
1065/2 1065/17 1120/13 15 [1] 1119/10 1075/17 1093/22 230 [1] 1108/19
1072/21 1074/9 15-minute [1] 1110/20 24 [2] 1038/24
1074/12 1076/17 / 1064/20 2017 [9] 1029/10 1038/25
1079/17 1080/2 /s [1] 1130/14 1500 [3] 1004/21 1030/8 1030/11 25 [1] 1071/4
1083/20 1085/18 1073/14 1096/9 1042/4 1075/14 280 [2] 1062/11
1091/18 1096/21 0 16 [3] 1038/24 1075/17 1075/20 1062/11
1098/1 1099/5 001 [1] 1107/15 1038/25 1047/21 1076/4 1076/24 282 [1] 1062/12
1102/4 1107/14 03 [1] 1083/22
1132
3 809 [3] 1027/17 993/8 990/15 990/16 1066/1 1072/21

1027/18 1027/21 according [2] 994/16 1027/21 1075/16 1080/20
30 [3] 1040/6
810 [1] 1065/4 1074/5 1122/15 1036/19 1065/8 1086/25 1090/14
1054/16 1100/12
811 [4] 1036/6 accuracy [1] 1076/21 1076/22 1091/23 1098/16
30-minute [2]
1065/5 1065/5 1123/18 1079/17 1099/13 1100/11
1037/9 1054/23
1065/8 accurate [5] advice [1] 1030/5 1106/9 1113/12
302 [7] 1047/9
8:11 [1] 1007/19 1026/12 1048/20 advise [1] 1122/4 1123/15
1047/11 1048/25
8:39 [2] 1096/10 1048/23 1049/25 1120/25 1124/19 1125/1
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1097/14 1130/5 advised [3] agencies [1]
1108/2 1108/15
8th [1] 1120/18 accurately [1] 1080/14 1105/15 1100/14
302s [2] 1107/19
1127/22 1123/25 agency [1] 992/2
1107/19 9 acknowledging advising [3] agent [20] 997/7
3187 [1] 989/25 9/21 [1] 1068/22
[1] 1124/21 1090/2 1105/21 1019/21 1019/21
333 [1] 989/24 9/22 [1] 1073/7 acknowledgment 1120/23 1019/22 1019/22
3500 [1] 1044/11 906-1200 [1]
[1] 1011/3 affect [3] 1020/19 1019/24 1037/21
354-3187 [1] 989/20 acting [18] 996/6 1022/17 1023/17 1037/23 1047/13
989/25 93 [1] 1068/21 998/3 1019/14 affiliation [3] 1047/16 1058/10
37 [1] 1089/21 9:00 [1] 1129/12 1043/18 1043/19 1020/19 1086/8 1058/16 1058/20
3:30 [1] 1005/25 9:05 [1] 1005/3
1046/10 1046/20 1087/9 1058/22 1059/5
3:34 [1] 1068/24
A 1047/3 1048/12 affirmative [1] 1060/3 1061/23
3rd [6] 1087/15
1053/24 1075/21 1018/15 1095/19 1109/5
1087/18 1089/13 A-10 [2] 1036/15
1077/3 1077/5 affirmatively [4] 1109/6
1089/24 1090/20 1036/19
1092/7 1092/11 998/23 1043/14 Agent Hellman [1]
1096/14 a.m [4] 1005/3 1093/11 1114/4 1084/15 1121/8 1061/23
4 1006/5 1007/19 1126/25 after [24] 1000/15 agent's [2]
1096/10 action [5] 989/2 1004/9 1004/23 1108/15 1108/18
4:07 [1] 1006/16 A10 [2] 1034/10
4th [3] 1047/6 1003/9 1003/9 1005/25 1035/13 agents [11] 997/8
1076/22 1004/8 1121/24 1042/2 1055/16 1015/3 1015/9
1048/10 1049/4 Abby [1] 1012/4 actions [1] 1057/9 1061/18 1017/7 1017/11
5 ability [4] 1001/10 1089/7 1064/15 1068/6 1019/21 1051/20
1092/18 1094/8 active [1] 1019/14 1069/4 1072/15 1058/8 1058/9
53 [1] 1083/25
1130/7 activities [1] 1075/15 1097/12 1095/21 1116/9
558 [3] 1079/13
able [2] 991/23 1000/24 1102/2 1104/25 aggressive [1]
1079/14 1079/17
1055/24 activity [2] 1018/1 1106/7 1106/18 1002/15
559 [2] 1076/17
about [186] 1075/1 1116/23 1121/4 aggressively [1]
1076/19
above [6] 1028/5 actual [1] 1124/2 1121/6 1124/10 1002/10
57 [1] 1083/24
1080/4 1102/23 actually [4] 1124/17 ago [11] 1016/14
5:13 [1] 1129/23
1102/23 1130/4 1073/5 1083/24 aftermath [1] 1026/22 1038/17
5th [1] 1011/18
1130/6 1119/3 1121/2 1000/8 1049/4 1071/18
6 above-captioned ADAG [2] afternoon [6] 1071/19 1071/20
61 [3] 994/4 [1] 1028/5 1076/25 1077/2 989/5 992/14 1081/18 1093/5
994/11 994/16 above-entitled [1] add [1] 1103/10 1005/9 1005/17 1093/7 1111/25
637-2231 [1] 1130/6 added [1] 1064/17 1102/1 agreed [3]
989/15 absolutely [6] 1123/13 afternoon's [1] 1049/16 1049/16
6718 [1] 989/24 1002/20 1012/14 addition [2] 1072/15 1049/18
6th [3] 1026/18 1020/12 1078/24 1098/4 1126/5 afterwards [1] agreement [1]
1076/4 1081/21 1088/2 1088/5 additional [4] 1066/16 992/18
accept [2] 1021/13 1088/21 again [29] 995/1 Ah [1] 1110/19
7 1086/20 1126/3 1091/3 1106/19 995/19 1006/1 Ah-ha [1] 1110/19
709 [1] 1113/11 access [1] administrative [1] 1006/8 1007/1 ahead [2] 995/16
75 [1] 1071/3 1018/25 1032/20 1017/7 1020/17 1010/12
accessed [1] admitted [13] 1024/3 1024/11 aided [1] 1128/8
8 1018/24 990/11 990/14 1030/10 1046/24 alarmed [2]
808 [1] 1027/15 accommodate [1]
990/14 990/15 1052/3 1053/6 1021/22 1085/4
1133
A 1042/16 1059/20 1018/6 1020/20 998/7 998/14 apologize [1]

1080/18 analyst [1] 998/17 998/18 1052/11
Alfa [14] 1000/15
alleged [1] 1035/19 998/23 1003/6 Apparently [1]
1000/16 1006/19
1121/11 anchor [1] 1003/22 1004/16 1065/3
1010/22 1042/3
allegedly [1] 1127/16 1005/14 1007/4 Appear [1]
1042/16 1075/17
1025/5 Anderson [1] 1008/2 1008/14 1079/21
1080/9 1080/22
alleging [2] 1076/4 1010/20 1011/3 appearance [2]
1101/12 1111/12
1025/1 1025/5 ANDREW [3] 1011/9 1011/12 994/5 994/7
1118/1 1121/12
allow [1] 1089/15 989/12 1077/24 1013/7 1016/2 APPEARANCES
1126/23
alone [2] 1013/22 1107/8 1020/22 1022/17 [1] 989/11
Alfa-Bank [14]
1014/11 Andy [3] 1076/6 1025/16 1025/17 appeared [1]
1000/15 1000/16
along [3] 1005/7 1082/7 1082/8 1027/1 1028/12 1101/13
1006/19 1010/22
1006/13 1105/15 Angela [1] 1012/3 1028/12 1030/7 appearing [2]
1042/3 1042/16
already [2] angle [2] 999/6 1036/1 1036/16 1014/14 1100/4
1075/17 1080/9
1006/9 1051/18 1092/15 1039/20 1041/18 appears [3]
1080/22 1101/12
also [18] 991/8 Ann [1] 1099/23 1042/19 1044/16 1006/5 1006/17
1111/12 1118/1
1001/8 1002/7 announced [2] 1044/20 1051/7 1117/22
1121/12 1126/23
1014/7 1020/2 1015/1 1015/2 1052/22 1053/7 applied [2]
ALGOR [1]
1020/8 1021/20 another [11] 1054/8 1054/9 1105/19 1109/15
989/12
1032/20 1034/16 1010/25 1012/18 1055/25 1056/3 apply [1] 1100/3
all [58] 991/23
1034/17 1034/22 1035/8 1051/16 1057/17 1059/13 appointed [5]
992/7 992/23
1080/14 1089/7 1060/20 1061/1 1080/1 1081/25 1029/11 1029/14
993/18 997/10
1101/6 1105/18 1061/17 1072/19 1082/2 1085/3 1035/13 1105/1
1002/18 1004/2
1111/10 1123/21 1074/11 1119/10 1090/4 1091/6 1105/4
1004/3 1008/23
1125/19 1129/7 1098/8 1098/13 appreciate [3]
1009/7 1009/12
although [2] answer [37] 1102/21 1103/1 1013/1 1028/8
1012/10 1012/11
1032/10 1051/5 996/19 999/9 1104/6 1104/18 1100/4
1013/3 1013/23
always [3] 1019/5 999/16 1016/14 1118/16 1121/24 appropriate [2]
1015/7 1015/17
1076/7 1106/2 1024/17 1027/2 1122/16 1122/20 1087/2 1089/7
1015/21 1016/20
am [19] 1009/22 1027/4 1027/6 1122/25 1123/11 approximately [2]
1017/9 1019/7
1010/12 1019/4 1027/7 1027/9 1128/24 1037/11 1074/5
1020/13 1020/16
1019/5 1026/1 1029/20 1030/3 anybody [7] April [1] 1027/23
1020/18 1022/15
1027/4 1057/21 1030/5 1030/7 1018/25 1020/22 are [78] 991/10
1024/8 1024/9
1059/16 1067/10 1030/7 1031/21 1063/22 1080/17 991/23 992/18
1026/1 1026/2
1067/17 1070/4 1038/23 1039/3 1080/21 1081/20 992/23 993/7
1026/23 1027/12
1071/16 1076/3 1039/10 1039/13 1118/8 1008/20 1009/2
1033/14 1035/7
1081/14 1103/5 1053/16 1054/5 anything [21] 1009/8 1009/10
1040/13 1044/3
1118/10 1118/15 1069/20 1084/11 992/22 999/15 1013/12 1015/18
1046/14 1047/12
1127/16 1128/19 1085/13 1085/16 1000/2 1002/15 1018/11 1020/2
1049/10 1059/22
amend [1] 1087/6 1089/15 1002/16 1007/6 1020/6 1022/11
1064/15 1064/19
1038/16 1090/2 1092/17 1007/10 1008/17 1022/19 1022/20
1071/12 1081/12
AMERICA [1] 1092/20 1094/22 1008/21 1016/8 1023/5 1023/12
1082/6 1082/23
989/2 1100/6 1103/1 1018/17 1021/10 1023/16 1025/5
1089/21 1095/23
America's [1] 1103/11 1111/23 1043/14 1070/4 1028/4 1028/16
1100/2 1100/22
1053/13 1121/18 1070/17 1071/2 1031/20 1032/7
1104/4 1104/5
Americas [1] answered [3] 1079/7 1086/16 1032/7 1050/10
1104/20 1111/17
989/19 997/13 998/2 1087/3 1115/13 1051/6 1051/7
1123/2 1129/5
among [2] 1086/11 1128/20 1054/17 1054/23
1129/10 1129/14
1084/23 1089/5 answering [4] Anyway [1] 1056/16 1057/4
1129/21
amount [5] 1091/13 1092/15 1005/7 1058/9 1059/14
allegation [2]
1022/24 1058/19 1094/6 1094/7 anywhere [2] 1060/1 1062/7
1024/6 1024/23
1072/10 1075/1 answers [1] 1004/17 1119/2 1062/12 1065/10
allegations [7]
1101/5 1084/4 apologies [1] 1067/12 1071/7
1003/6 1024/20
analysis [2] any [62] 992/14 1010/12 1071/21 1073/22
1030/21 1042/4
1134
A 1015/1 1015/5 1112/19 1113/24 991/14 1041/24 1045/2

1015/10 1016/14 1117/21 1120/5 attacked [2] 1050/12 1056/16
are... [35] 1076/5
1017/2 1017/6 asked [33] 999/7 1103/22 1103/25 1059/16 1060/16
1078/7 1081/5
1018/25 1019/20 1005/5 1007/15 attended [4] 1060/17 1065/9
1081/16 1082/24
1020/21 1021/23 1007/16 1017/9 1075/24 1079/9 1065/16 1066/14
1082/25 1083/6
1022/6 1022/17 1036/22 1038/22 1079/11 1082/15 1068/7 1068/8
1086/15 1096/13
1024/19 1025/23 1039/2 1039/9 attendees [1] 1069/19 1069/22
1100/3 1100/4
1025/24 1025/25 1044/11 1045/4 1082/6 1084/20 1089/1
1107/19 1108/10
1028/11 1031/8 1051/5 1058/13 attending [1] 1090/23 1091/6
1108/19 1108/22
1033/3 1034/10 1060/21 1061/6 1075/20 1096/7 1101/15
1111/8 1111/21
1035/18 1036/5 1061/15 1062/1 attention [2] 1101/16 1102/25
1111/21 1112/1
1036/15 1038/4 1063/16 1063/23 1104/2 1119/11 1104/18 1106/18
1112/2 1116/9
1039/4 1040/17 1064/10 1064/14 attorney [22] 1116/12 1116/24
1116/12 1116/13
1040/18 1041/13 1069/10 1084/3 1004/11 1004/12 1117/1 1119/21
1116/13 1116/14
1041/13 1041/14 1087/5 1090/19 1004/13 1004/14 1119/24 1120/6
1116/18 1116/19
1041/14 1043/2 1093/15 1117/3 1022/20 1022/21 1129/11
1117/11 1119/9
1045/1 1048/22 1117/5 1117/6 1027/13 1075/21 back-and-forth [2]
1120/4 1120/4
1050/15 1053/24 1117/22 1118/1 1077/3 1077/7 1116/24 1117/1
1120/13 1121/5
1054/23 1055/9 1121/13 1128/16 1077/7 1077/14 backchannel [1]
1127/13 1128/5
1055/9 1056/7 asking [8] 999/17 1077/16 1077/17 1121/11
area [2] 1015/24
1060/6 1060/7 1004/3 1071/12 1078/16 1078/16 background [3]
1103/16
1060/19 1060/20 1093/13 1106/15 1080/13 1080/18 1072/10 1086/15
aren't [1] 1031/20
1067/10 1067/10 1116/14 1116/19 1080/23 1081/21 1105/16
arose [1] 1126/23
1067/13 1075/13 1123/2 1105/17 1119/15 Baker [53] 991/14
around [7]
1075/13 1076/3 aspect [1] attorneys [1] 991/16 992/17
1002/24 1033/4
1076/3 1076/17 1007/18 1016/18 992/24 993/1
1044/9 1061/15
1077/21 1079/3 aspects [1] 992/3 authorities [1] 993/5 993/23
1087/18 1091/9
1079/13 1083/13 assess [1] 1014/1 1086/19 993/25 994/5
1105/15
1083/13 1083/15 assessing [1] authority [1] 994/20 995/13
arrangements [1]
1083/15 1083/17 1025/8 1018/3 995/22 997/13
1009/3
1083/17 1083/19 assessment [9] authorized [2] 1000/1 1002/21
arriving [1]
1083/19 1087/22 1014/3 1014/13 1031/4 1031/16 1005/3 1005/10
1071/21
1089/13 1090/16 1016/21 1021/4 available [3] 1006/17 1009/2
article [10]
1092/18 1092/22 1022/12 1023/1 1036/23 1058/13 1009/14 1012/11
1005/13 1006/17
1094/14 1095/21 1023/14 1023/23 1103/1 1013/13 1014/15
1010/25 1051/8
1095/21 1098/4 1024/25 Avenue [3] 1018/14 1019/9
1055/8 1069/12
1101/9 1101/12 assignment [1] 989/19 989/24 1020/18 1022/11
1097/1 1097/5
1103/21 1105/13 1036/22 1058/7 1025/10 1025/19
1099/9 1099/12
1109/13 1112/1 assistant [3] avoid [1] 1040/251025/20 1027/24
articles [2]
1117/25 1118/3 1004/12 1073/4 aware [10] 1028/4 1032/18
1010/23 1081/8
1118/12 1118/13 1073/23 1001/21 1021/24 1033/2 1038/24
articulable [2]
1118/23 1121/10 Associate [1] 1028/16 1033/2 1047/1 1065/12
1023/7 1024/11
1124/2 1127/12 1078/15 1048/24 1059/14 1065/21 1071/18
as [112] 991/9
1127/14 1128/25 associated [6] 1059/16 1060/1 1074/25 1078/7
992/22 992/23
1129/17 1000/5 1015/9 1084/7 1110/1 1090/2 1092/5
993/8 993/8
ask [21] 995/12 1017/21 1019/2 1094/13 1094/21
993/13 994/3
995/17 996/25 1019/8 1115/10 B 1095/13 1095/16
995/9 996/10 back [44] 992/12 1098/6 1100/6
997/10 1013/14 association [2]
996/10 997/8 993/3 993/5
1042/22 1047/22 1085/25 1127/22 1100/21 1111/13
997/8 997/15 993/23 997/12
1048/3 1048/25 assume [2] 1114/7 1129/17
997/21 1000/14 1005/24 1007/11 Baker's [1]
1055/22 1057/11 991/15 1117/12
1000/14 1003/19 1009/5 1010/6
1057/17 1068/9 assumed [2] 1111/14
1003/23 1004/15 1013/13 1016/1
1095/10 1095/23 1018/22 1018/22 bank [16]
1004/15 1007/16 1031/12 1041/21 1000/15 1000/16
1098/21 1107/18 assuming [1]
1010/21 1010/21
1135
B 1060/11 1060/14 1026/6 1030/21 1092/7 1092/11 1124/22 1125/5

1060/15 1063/18 1030/24 1030/25 1093/11 1098/6 1125/10 1125/15
bank... [14]
1064/16 1065/1 1031/16 1051/1 1112/25 1114/4 1125/20 1125/24
1006/19 1010/22
1073/6 1075/9 1051/5 1053/12 1120/14 1122/16 1126/2
1042/3 1042/16
1076/3 1078/23 1053/24 1059/21 1122/20 1122/25 bell [1] 1061/23
1075/17 1080/9
1083/13 1083/15 1059/25 1061/25 1123/11 1126/25 Bellovin [8]
1080/10 1080/12
1083/17 1083/19 1062/6 1071/9 being [31] 994/14 1056/3 1056/4
1080/22 1101/12
1086/7 1088/8 1072/16 1073/19 995/9 997/5 999/6 1056/5 1056/12
1111/12 1118/1
1088/24 1089/10 1077/19 1080/22 1003/9 1003/10 1056/24 1114/8
1121/12 1126/23
1091/3 1101/14 1086/17 1088/25 1007/1 1014/9 1114/12 1114/24
Barr [1] 1105/18
1106/23 1114/16 1089/4 1089/6 1016/19 1020/1 below [7] 1055/14
based [15]
1119/4 1119/7 1089/8 1090/19 1020/24 1021/24 1055/15 1071/1
1029/15 1044/25
1121/6 1125/16 1093/19 1100/13 1022/8 1030/25 1074/11 1078/2
1051/25 1067/16
1125/24 1127/1 1102/24 1104/11 1032/17 1038/22 1078/3 1080/13
1067/19 1073/3
1129/2 1104/21 1112/10 1055/9 1088/21 Benjamin [2]
1074/2 1081/15
became [1] 1116/23 1120/25 1092/15 1093/7 1033/18 1034/14
1094/8 1110/5
1076/1 1121/17 1126/8 1093/23 1095/17 BERKOWITZ [5]
1110/8 1112/9
because [56] 1126/11 1127/5 1099/8 1101/12 989/17 990/6
1112/11 1128/13
997/6 1001/9 before [26] 989/8 1103/22 1103/23 1028/13 1064/16
1128/20
1004/1 1005/7 993/5 994/5 1103/24 1117/6 1065/17
basic [1] 1101/1
1006/10 1014/11 1000/15 1000/16 1121/13 1124/6 best [27] 993/15
basically [8]
1014/21 1016/19 1004/3 1005/6 1124/10 1000/9 1000/14
993/7 1000/22
1019/18 1021/23 1017/18 1018/6 belief [2] 995/9 1000/21 1001/10
1001/16 1021/24
1025/15 1028/21 1019/9 1026/3 1073/25 1001/23 1001/24
1022/19 1086/10
1029/20 1029/23 1029/20 1039/12 believe [45] 1004/2 1007/25
1101/18 1108/12
1032/14 1039/22 1047/11 1049/20 991/25 995/4 1008/11 1013/2
basis [4] 1023/7
1044/21 1045/24 1065/13 1065/22 995/15 995/23 1028/13 1045/6
1024/12 1025/18
1046/1 1049/17 1066/6 1080/25 999/6 999/15 1057/12 1065/18
1051/23
1049/19 1051/18 1088/25 1089/1 1000/5 1008/4 1069/10 1073/25
be [80] 991/13
1054/4 1056/20 1091/24 1098/15 1008/5 1028/10 1075/19 1079/3
991/23 992/5
1057/16 1058/22 1100/18 1110/6 1037/8 1039/11 1081/14 1082/22
992/11 993/2
1059/5 1060/6 1110/20 1039/18 1045/17 1092/18 1092/20
994/1 995/11
1067/5 1068/14 beg [1] 1012/1 1046/19 1047/1 1093/2 1094/7
999/5 1006/5
1071/22 1072/13 began [1] 1048/11 1049/17 1107/11 1130/7
1006/17 1009/16
1082/23 1084/19 1003/12 1054/12 1060/17 better [4] 996/19
1009/23 1010/9
1084/21 1084/23 beginning [6] 1063/18 1067/19 1045/3 1071/2
1013/20 1015/24
1086/4 1086/8 993/17 1050/1 1069/18 1072/6 1094/22
1017/20 1018/8
1089/15 1090/3 1059/12 1065/21 1072/7 1072/9 between [6]
1019/2 1020/6
1090/3 1090/4 1087/17 1122/1 1079/10 1082/19 1030/8 1030/11
1020/11 1020/13
1090/4 1092/14 behalf [41] 996/6 1082/21 1085/5 1075/7 1101/11
1021/2 1021/19
1095/19 1102/20 998/4 1000/11 1085/7 1085/23 1121/11 1127/20
1021/25 1023/18
1103/9 1104/14 1000/12 1000/18 1086/2 1086/16 beyond [1]
1024/6 1024/22
1106/1 1107/19 1001/14 1001/18 1086/17 1088/18 1054/7
1025/6 1025/8
1115/8 1117/13 1014/14 1014/17 1089/8 1099/4 big [3] 1058/5
1025/12 1028/12
1118/13 1118/25 1015/12 1016/13 1099/9 1101/23 1063/25 1118/11
1029/2 1029/5
1124/22 1128/4 1017/8 1019/14 1103/17 1107/7 Bill [10] 1043/10
1031/9 1033/14
becoming [1] 1025/16 1025/17 1108/7 1112/9 1058/12 1059/19
1035/7 1035/10
1040/25 1027/10 1028/19 1125/21 1067/8 1076/6
1038/12 1038/15
been [47] 994/3 1043/18 1043/19 believed [17] 1119/1 1127/15
1041/13 1042/20
1002/22 1006/2 1052/22 1053/6 1025/18 1031/3 1127/19 1127/25
1045/13 1045/14
1011/4 1011/23 1053/23 1080/14 1045/13 1045/16 1128/6
1046/15 1050/16
1014/22 1016/2 1080/19 1080/23 1050/15 1050/18 Bill Priestap [1]
1050/18 1050/20
1017/5 1022/8 1081/22 1082/17 1050/20 1086/24 1127/25
1053/19 1055/24
1022/16 1025/2 1082/20 1084/16 1087/1 1087/10 Bill's [4] 1123/4
1059/6 1059/23
1136
B 1100/19 1100/25 caliber [1] 1056/9 can [52] 993/13 Carl [1] 1076/6
bring [8] 992/12 call [40] 1007/5 994/6 1005/8 case [39] 1003/19
Bill's... [3] 1125/1
1007/11 1015/8 1031/13 1031/16 1005/16 1005/24 1003/21 1004/7
1128/10 1128/18
1017/11 1017/11 1069/3 1069/6 1010/21 1022/22 1004/10 1008/13
bit [7] 1014/15
1017/12 1064/4 1069/8 1069/16 1022/23 1022/24 1015/6 1015/9
1026/13 1034/21
1065/9 1069/24 1069/24 1024/7 1025/25 1018/15 1021/6
1035/22 1049/13
bringing [7] 1070/2 1070/4 1033/20 1034/21 1028/8 1031/2
1121/5 1124/1
1000/18 1016/22 1070/5 1070/6 1034/21 1036/4 1036/11 1039/19
Blaze [7] 1056/3
1017/17 1018/20 1071/5 1071/6 1036/14 1037/6 1039/20 1042/13
1056/5 1056/12
1019/13 1058/25 1071/12 1071/15 1038/16 1038/25 1043/6 1044/15
1056/24 1114/8
1081/21 1071/22 1071/25 1046/24 1047/25 1050/2 1059/20
1114/12 1114/24
BRITTAIN [1] 1072/2 1072/3 1048/18 1048/25 1060/2 1060/3
block [1] 1061/10
989/13 1072/19 1072/25 1049/21 1052/11 1060/14 1060/15
blow [11] 1033/18
Brookings [1] 1073/1 1073/3 1052/13 1057/14 1061/25 1063/18
1033/20 1033/25
1034/16 1073/4 1073/5 1062/15 1064/24 1064/21 1064/21
1034/1 1036/7
brought [17] 1073/6 1073/9 1065/9 1066/2 1076/15 1079/6
1076/18 1079/18
996/1 996/3 1073/18 1074/10 1069/8 1070/8 1081/8 1081/9
1080/3 1098/2
1003/7 1003/9 1074/17 1074/19 1072/1 1075/13 1101/14 1104/21
1102/5 1107/25
1021/7 1045/16 1074/20 1074/21 1076/4 1076/18 1106/2 1108/7
board [1] 1052/10
1061/18 1061/19 1075/15 1099/16 1077/2 1079/3 1124/6 1129/8
body [1] 1024/25
1063/3 1080/13 1101/16 1111/16 1079/3 1081/15 1129/9 1129/10
Boente [4]
1080/19 1080/22 1111/18 1082/5 1086/18 case-related [2]
1075/21 1075/22
1082/16 1092/2 called [16] 1000/6 1093/2 1099/6 1076/15 1079/6
1076/9 1077/13
1092/4 1123/25 1016/5 1034/15 1107/17 1107/18 cases [1] 1017/25
boss [1] 1034/17
1125/20 1041/21 1041/24 1107/25 1112/2 catch [2] 996/17
BOSWORTH [1]
building [2] 1058/12 1066/17 1113/9 1115/12 1012/5
989/17
1058/5 1058/9 1068/16 1074/3 1129/14 CATHERINE [1]
both [7] 1004/6
bunch [1] 1044/5 1075/4 1090/23 can't [21] 996/9 989/18
1016/1 1088/9
burden [1] 1101/23 1106/18 996/14 997/14 cause [3] 1014/6
1088/13 1088/17
1088/21 1111/13 1119/24 1022/22 1033/20 1019/1 1042/19
1090/14 1128/6
Bureau [9] 1126/6 1034/19 1034/24 caused [1]
bottom [5]
1001/4 1004/23 calls [4] 1028/23 1041/23 1055/14 1088/15
1009/16 1085/16
1025/16 1045/25 1072/23 1074/4 1055/16 1072/1 CCR [1] 989/23
1089/22 1107/22
1046/4 1059/19 1104/16 1082/5 1091/15 cell [1] 1000/25
1115/15
1086/22 1088/25 came [15] 994/21 1094/13 1094/18 certain [10] 991/9
break [4] 1014/15
1089/1 1001/6 1002/13 1107/9 1110/16 992/3 1029/22
1064/17 1064/20
Bureau's [1] 1018/21 1025/10 1111/2 1112/3 1029/22 1038/18
1072/15
1023/14 1041/16 1041/17 1122/8 1125/1 1067/21 1108/6
breaking [1]
burger [2] 1022/5 1051/7 1067/7 candidate [1] 1112/1 1112/2
1119/7
1022/7 1068/6 1084/2 1021/23 1120/6
brief [7] 1008/20
business [5] 1084/5 1100/19 cannot [4] certainly [6]
1034/20 1043/25
1001/8 1001/12 1100/22 1101/4 1022/23 1117/24 1016/4 1021/15
1048/7 1079/21
1002/2 1015/15 campaign [22] 1118/3 1118/15 1032/1 1083/8
1109/2 1115/20
1023/17 996/8 996/22 captioned [1] 1107/23 1118/7
briefed [1]
997/18 997/23 1028/5 certainty [1]
1124/11 C 998/6 998/10 care [2] 1012/10 1123/10
briefing [7] cabined [1] 999/8 999/20 1027/24 certify [1] 1130/4
1076/14 1076/25 1043/24
1011/10 1014/18 career [2] Chadason [1]
1079/5 1082/4 calculation [1] 1014/21 1053/13 1030/22 1030/23 991/17
1082/8 1110/10 1041/12 1075/8 1084/8 careful [4] 1031/9 Chadason's [1]
1124/13 calculus [1] 1086/1 1094/12 1083/13 1083/15 992/1
briefings [2] 1019/15 1095/8 1098/7 1092/16 chain [9] 1020/15
1002/7 1043/10 calendar [2] 1110/12 1122/18 carefully [1] 1054/19 1061/9
briefly [5] 991/2 1054/18 1078/12 1127/15 1127/18 1021/9 1061/19 1062/10
1008/11 1067/1
1137
C 1118/10 1127/8 998/6 998/9 999/8 999/5 1001/18 concern [2]

clearly [3] 1001/8 999/19 1011/10 1015/15 1016/2 1021/18 1085/4
chain... [4]
1110/13 1118/10 1014/17 1014/21 1016/12 1016/13 concerned [4]
1067/16 1067/22
Cleave [1] 1034/4 1014/22 1015/10 1016/16 1017/8 1002/13 1033/8
1117/4 1117/9
Cleaves [4] 1015/12 1084/8 1023/15 1023/16 1033/10 1033/13
challenges [2]
1035/1 1076/18 1086/1 1094/11 1025/15 1045/20 concerns [4]
1011/25 1012/3
1079/19 1102/6 1095/7 1098/7 1064/3 1064/4 1000/22 1001/5
chance [3]
client [65] 996/1 1122/17 1127/11 1068/13 1002/17 1090/4
1018/2 1071/4
996/6 998/4 1127/15 comments [1] conclude [2]
1080/1
998/14 998/18 close [4] 991/21 1005/6 1071/15 1071/25
change [2]
998/23 1000/12 1004/9 1066/16 commit [1] concluded [3]
1003/22 1049/10
1001/19 1002/11 1099/9 992/11 1059/19 1089/3
changed [3]
1007/6 1007/12 closed [6] 1003/8 committed [2] 1129/23
1016/20 1016/21
1011/5 1013/15 1004/7 1004/15 1020/24 1089/4 conclusion [1]
1041/12
1013/24 1014/2 1014/25 1030/13 committee [6] 1071/21
channel [4]
1014/14 1015/15 1033/1 996/23 1085/25 conduct [7]
995/10 1101/15
1017/8 1017/20 CNN [3] 1035/6 1095/8 1100/24 1014/8 1017/15
1101/16 1101/19
1022/16 1022/17 1035/18 1035/18 1102/9 1121/1 1029/11 1038/5
charged [1]
1023/16 1025/12 code [3] 1016/6 common [2] 1038/9 1039/6
1030/21
1025/16 1025/17 1075/6 1105/19 1016/24 1017/2 1041/6
charges [2]
1043/18 1043/19 Coie [10] 1006/18 communicate [3] conducted [1]
1003/6 1003/9
1045/21 1046/11 1013/10 1013/11 1035/23 1035/24 995/9
chart [1] 1012/19
1046/21 1047/3 1054/2 1087/19 1101/19 conducting [4]
check [4] 1069/18
1048/13 1052/22 1096/17 1097/5 communicated 1044/24 1051/19
1070/7 1070/18
1053/7 1071/22 1098/4 1098/24 [1] 1108/16 1105/17 1109/9
1071/12
1080/14 1080/19 1099/8 communications conference [1]
Chief [2] 1078/5
1080/23 1091/21 collect [4] 1023/9 [4] 995/10 1008/6
1078/6
1092/2 1092/7 1023/25 1024/13 1017/22 1101/17 conferences [2]
chose [2]
1092/11 1093/12 1043/4 1121/11 1008/10 1008/10
1084/20 1102/11
1098/6 1098/8 colloquy [1] communications- conferred [1]
CHRISTOPHER
1098/19 1098/20 1064/6 related [1] 992/17
[1] 989/8
1102/4 1103/10 COLUMBIA [2] 1017/22 confidence [5]
chronologically
1103/21 1112/18 989/1 1004/12 company [6] 1014/11 1046/2
[1] 1075/13
1112/19 1112/21 combination [1] 1000/6 1001/3 1063/19 1067/13
chronology [2]
1112/25 1113/5 1123/2 1001/5 1001/13 1070/19
1076/24 1120/3
1113/24 1113/25 come [20] 1011/24 1015/25 confident [7]
CHS [1] 1020/5
1114/1 1114/4 1000/12 1003/12 complete [1] 1006/8 1057/20
circumstances [1]
1120/14 1122/16 1003/15 1010/23 1130/6 1057/21 1067/17
1092/18
1122/20 1122/25 1014/16 1015/13 completed [2] 1067/23 1071/8
citizen [2] 1085/8
1123/11 1127/1 1018/3 1018/7 1014/25 1089/2 1071/16
1086/20
clients [19] 1020/15 1022/20 completely [2] confidential [8]
claim [1] 1051/23
1032/4 1052/18 1033/11 1051/9 1104/5 1104/6 1019/10 1019/14
clarify [2]
1070/7 1070/18 1051/15 1058/10 complicated [1] 1019/19 1019/25
1089/13 1090/1
1071/5 1071/6 1058/13 1063/1 1121/5 1020/5 1020/10
classification [1]
1071/10 1071/12 1085/5 1101/3 component [1] 1060/8 1118/13
1090/4
1071/14 1081/22 1113/3 1113/4 1020/8 confirmed [1]
classified [6]
1081/25 1082/17 comes [6] Computer [1] 1077/9
1002/23 1029/12
1082/20 1084/16 1020/22 1024/7 1080/9 confuse [1]
1030/16 1030/17
1101/8 1102/12 1024/19 1065/13 computers [1] 1076/7
1090/3 1108/5
1103/3 1103/18 1086/6 1086/20 1124/12 confused [1]
clear [11] 1053/19
1120/18 Comey [5] 1015/1 concealed [1] 998/15
1062/12 1073/6
Clinton [22] 1078/3 1078/6 1121/8 congratulating [1]
1075/9 1076/3
996/8 996/22 1093/7 1093/23 concept [1] 1013/5
1088/8 1088/24
997/18 997/23 coming [15] 1019/9 Congratulations
1089/10 1093/8
[2] 1011/22
1138
C 1001/21 1125/13 1104/4 1028/9 1062/10 1067/5

contexts [3] corruption [1] Courthouse [1] 1067/22 1117/4
Congratulations...
997/25 998/1 1025/2 989/24 1117/10
[1] 1036/21
999/21 could [47] 994/3 courtroom [4] cyber [19] 995/19
Congress [7]
continuation [1] 994/17 995/1 992/25 1064/23 999/22 999/23
994/5 1029/20
991/15 996/19 997/2 1065/15 1129/13 1018/21 1018/24
1044/17 1083/10
continue [2] 1004/25 1008/23 cover [5] 994/6 1025/6 1032/3
1083/12 1091/16
1028/11 1100/12 1011/15 1016/1 1025/22 1035/7 1042/22 1054/25
1096/2
continued [3] 1018/25 1023/15 1060/19 1099/21 1055/2 1055/15
congressional [5]
1004/22 1010/23 1023/17 1025/8 covert [1] 995/10 1055/16 1055/25
994/1 1007/14
1087/22 1030/6 1030/21 CR [1] 989/3 1056/7 1056/8
1082/25 1083/1
continues [1] 1036/2 1036/7 CRC [1] 989/3 1101/9 1114/25
1120/15
1013/11 1038/20 1052/3 credibility [7] 1123/24 1123/25
Congressman [1]
contract [3] 1058/11 1058/12 1021/5 1021/15 cybersecurity [4]
995/3
1000/23 1001/3 1058/16 1058/19 1021/16 1023/13 1103/8 1103/10
connect [1]
1001/9 1072/9 1079/18 1024/14 1025/6 1103/18 1120/18
1008/14
contradicts [1] 1080/3 1083/13 1025/7
connected [3]
1098/14 1083/15 1083/17 credible [9] D
1080/9 1080/11 D.C [1] 1008/6
contrary [1] 1083/19 1083/25 1023/5 1045/18
1103/14 DAG [2] 1079/21
1082/18 1086/3 1088/3 1050/18 1086/8
connection [18] 1082/7
controlled [1] 1092/20 1094/21 1125/6 1125/11
1002/3 1003/13 damage [1]
1101/13 1095/13 1097/25 1125/21 1125/25
1013/7 1016/16 1027/1
convenience [1] 1098/2 1099/21 1126/2
1025/6 1031/2 Dan [1] 1028/18
1028/10 1100/19 1104/11 crime [14]
1038/11 1039/20 Dana [8] 1075/21
convening [1] 1106/15 1106/23 1017/25 1020/23
1049/7 1053/13 1075/22 1075/25
993/12 1113/7 1121/24 1023/8 1023/8
1053/25 1069/16 1076/2 1076/9
conversation [16] 1125/7 1129/2 1023/24 1024/13
1071/14 1098/7 1076/15 1077/13
1066/19 1066/21 couldn't [3] 1030/25 1050/9
1101/10 1105/1 1079/5
1067/2 1067/3 1069/19 1073/19 1083/12 1085/10
1108/6 1110/12 Daniel [2]
1067/4 1067/14 1099/18 1086/17 1086/18
considerably [1] 1027/24 1036/7
1067/25 1068/1 counsel [16] 1086/25 1091/15
1021/22 data [10] 1017/21
1068/3 1068/6 1000/11 1015/24 criminal [9] 989/2
considered [1] 1017/22 1017/22
1069/21 1115/11 1016/25 1028/4 1029/2 1029/5
1086/7 1017/23 1018/2
1122/1 1123/5 1028/6 1030/6 1029/11 1029/25
consistent [2] 1018/16 1055/3
1126/23 1127/19 1033/3 1037/19 1030/1 1088/22
994/14 1054/24 1067/19 1068/13
conversations [4] 1038/5 1039/4 1089/4 1106/8
Constitution [1] 1068/14
1042/10 1042/13 1058/15 1076/1 critical [1] 1097/1
989/24 date [19] 994/7
1100/18 1100/19 1078/9 1090/2 criticized [1]
construed [1] 1006/4 1007/4
conveyed [2] 1093/13 1098/6 1007/1
1086/23 1009/10 1034/22
997/6 1095/18 counsel's [2] cross [3] 990/6
CONT'D [1] 993/1 1034/23 1035/1
conveying [1] 989/13 1003/11 1025/20 1066/5
contact [3] 1049/1 1049/9
1014/2 country [2] cross-examinatio
1004/22 1075/18 1049/18 1052/3
conviction [1] 1020/23 1086/13 n [3] 990/6
1129/9 1099/18 1112/12
1112/5 coupe [1] 1007/2 1025/20 1066/5
contacted [3] 1120/9 1120/11
COOPER [1] couple [5] 1049/4 crosses [1] 992/5
1005/4 1120/25 1122/22 1123/14
989/8 1051/1 1052/9 Crossfire [6]
1122/11 1124/11 1130/14
cooperate [1] 1096/20 1098/15 1016/5 1016/6
contacts [1] dated [1] 1005/1
1036/1 course [1] 1021/3 1016/9 1075/4
1124/14 dates [6] 1026/19
cooperation [1] court [8] 989/1 1075/9 1077/18
contaminated [1] 1041/23 1087/16
1035/14 989/23 989/23 current [2]
1018/8 1096/7 1105/12
cordial [2] 1028/2 1053/2 1012/9 1012/21
contemplating [1] 1120/4
1040/23 1069/24 1058/6 1064/25 custody [9]
1001/2 day [22] 991/14
correct [244] 1130/3 1054/19 1061/6
context [4] 991/21 994/24
corrupt [1] courtesy [1] 1061/9 1061/19
995/23 1001/17
1139
D deeply [2] 1014/6 1015/20 1015/23 1041/3 1041/20 1030/7 1031/7

1093/17 1017/19 1022/24 1042/18 1042/21 1031/10 1031/11
day... [19]
DeFelippis [2] depends [5] 1043/2 1044/16 1031/13 1031/15
1006/25 1035/13
990/4 1120/23 1024/23 1031/22 1045/2 1045/12 1031/15 1035/6
1038/12 1038/12
Defendant [2] 1093/6 1093/8 1045/23 1046/11 1040/11 1040/15
1046/22 1047/4
989/6 989/17 1093/10 1049/10 1049/20 1040/20 1041/5
1048/4 1048/14
defense [16] deposition [1] 1049/22 1053/11 1041/18 1042/2
1049/13 1065/19
990/13 991/18 1041/6 1053/14 1053/17 1042/15 1042/17
1072/19 1089/14
992/1 992/6 Deputy [7] 1054/2 1055/5 1042/19 1042/22
1096/5 1097/16
992/16 1027/21 1004/13 1004/14 1055/19 1055/25 1043/13 1045/3
1102/1 1103/13
1028/11 1028/21 1077/3 1077/17 1056/11 1057/17 1045/11 1045/17
1104/6 1106/4
1034/10 1036/5 1077/25 1078/15 1059/11 1060/4 1045/21 1047/19
1129/7
1036/19 1065/8 1078/16 1060/17 1061/20 1048/11 1049/14
day-to-day [1]
1076/19 1076/22 describe [5] 1063/1 1063/17 1057/4 1057/11
1038/12
1079/13 1079/17 992/19 1022/19 1063/21 1063/21 1057/16 1057/22
days [3] 1007/25
Defense's [1] 1088/20 1100/19 1064/1 1068/4 1058/21 1058/22
1055/11 1069/4
1065/5 1103/14 1068/5 1069/6 1059/4 1059/7
DC [2] 989/14
DeFILIPPIS [26] described [4] 1069/9 1069/9 1059/8 1059/9
989/25
989/12 990/5 1043/3 1045/2 1069/17 1070/16 1059/10 1059/21
dead [1] 1024/24
993/20 1031/25 1101/9 1101/12 1071/15 1071/23 1065/4 1068/3
deal [6] 997/9
1039/16 1044/11 despite [1] 1071/24 1072/11 1070/16 1071/25
1019/25 1020/14
1046/16 1048/10 1099/8 1072/12 1072/13 1073/5 1075/16
1020/25 1063/25
1073/13 1083/4 detail [2] 1039/25 1077/11 1078/18 1081/25 1084/14
1095/21
1083/22 1098/1 1091/7 1078/21 1084/3 1084/17 1084/19
dealt [2] 1020/1
1100/10 1107/8 detailed [1] 1084/18 1085/2 1087/3 1092/10
1020/6
1109/5 1109/25 1012/19 1085/3 1085/4 1092/11 1094/24
Dear [1] 1028/4
1110/23 1111/10 details [1] 995/20 1085/7 1085/11 1097/9 1098/11
debriefing [1]
1112/16 1113/22 determined [2] 1085/24 1087/2 1112/24 1113/3
1076/9
1114/7 1114/10 1104/10 1129/1 1087/5 1088/3 1113/4 1114/3
deceive [1]
1115/3 1116/5 Devaney [1] 1091/6 1092/13 1118/7 1118/15
1104/10
1120/5 1125/9 1098/22 1094/10 1094/19 1128/2
deceiving [1]
DeFilippis' [1] Devaney's [1] 1097/6 1098/20 differ [1] 1003/22
1102/20
1027/6 1097/16 1103/17 1104/3 different [14]
December [1]
delay [1] 1058/19 did [135] 995/12 1104/18 1105/11 999/6 1006/24
1032/23
delayed [1] 995/17 996/7 1105/11 1109/19 1010/16 1014/12
decided [5] 993/9
1018/12 996/15 997/23 1110/24 1110/24 1014/13 1022/9
1004/9 1015/21
delegated [2] 998/5 998/7 1112/17 1112/19 1031/24 1032/1
1015/22 1046/5
1027/12 1028/17 998/12 998/16 1112/20 1112/20 1049/3 1051/6
decision [8]
Democrat [1] 998/18 999/1 1113/5 1113/22 1074/7 1092/15
1001/15 1014/13
1086/5 999/6 999/7 1113/23 1113/24 1115/25 1116/22
1045/21 1045/23
Democratic [3] 1001/17 1002/18 1113/25 1114/1 differently [1]
1046/11 1046/22
996/23 1085/25 1003/12 1003/15 1118/12 1118/15 1021/11
1047/4 1048/13
1095/8 1003/17 1003/22 1119/17 1120/5 difficult [5]
decisions [5]
denying [2] 1005/10 1006/6 1122/17 1125/2 1031/20 1031/21
1022/17 1023/18
1111/8 1111/9 1007/5 1007/10 1125/21 1126/17 1049/13 1111/21
1027/12 1028/17
department [12] 1008/14 1010/13 1127/24 1128/2 1112/2
1028/19
1004/8 1029/11 1010/15 1013/7 1128/20 1128/25 digging [1]
declassified [2]
1030/14 1075/24 1015/5 1017/1 didn't [74] 992/10 1012/25
1108/6 1108/7
1077/6 1077/20 1017/16 1018/2 992/11 996/16 dimensions [1]
declined [1]
1078/20 1086/22 1025/11 1028/14 996/25 999/10 1013/20
1089/11
1089/8 1089/10 1028/20 1029/22 999/11 999/12 dinner [1]
decrease [1]
1090/7 1106/3 1031/12 1035/12 999/14 1007/17 1007/25
1024/21
depending [6] 1039/2 1039/9 1010/15 1010/25 direct [4] 990/4
deducing [1]
1013/23 1014/2 1040/13 1040/20 1019/1 1019/7 990/5 993/1
1074/21
1140
D 1094/11 1095/2 1111/4 1111/10 1021/8 1101/11 DX-808 [1]

1098/7 1109/21 1112/16 1112/21 done [9] 1007/12 1027/15
direct... [1]
1110/2 1110/11 1114/10 1114/14 1011/12 1017/18
1058/21
1110/25 1124/12 1116/7 1117/6 1018/5 1021/10 E
directly [4] each [1] 1101/19
1124/14 1124/18 1117/17 1117/24 1038/19 1038/21
1016/25 1031/12 ear [1] 1092/25
1127/9 1127/11 1118/4 1118/6 1039/19 1086/2
1038/4 1106/19 earlier [28]
1127/15 1127/18 1119/22 1119/24 down [14]
director [4] 997/12 999/20
1127/23 1120/8 1120/9 1014/15 1034/21
1015/1 1031/4 1002/21 1006/21
do [126] 993/15 1120/22 1121/1 1037/6 1048/18
1077/25 1078/5 1007/16 1017/2
994/20 995/2 1121/3 1121/13 1053/18 1055/24
directs [1] 992/4 1021/21 1021/23
997/18 999/22 1121/16 1121/20 1057/16 1064/24
disagree [1] 1022/6 1031/3
999/23 1000/4 1121/23 1121/25 1065/17 1080/5
1046/13 1038/4 1043/3
1000/7 1000/22 1122/4 1122/4 1099/6 1101/24
disclose [2] 1044/25 1045/2
1000/24 1005/14 1122/10 1122/12 1119/2 1129/14
1001/17 1061/20 1051/1 1060/7
1008/17 1009/19 1124/2 1124/16 drive [1] 1101/6
disclosure [4] 1060/18 1061/8
1011/19 1012/6 1125/17 1125/19 drives [3] 1040/8
1020/4 1029/12 1068/18 1073/2
1012/16 1017/10 1125/23 1126/20 1061/5 1061/12
1030/19 1120/24 1092/19 1093/19
1019/25 1023/22 1130/3 Durham [39]
discounted [1] 1103/22 1105/3
1024/2 1025/3 doctor's [1] 1003/4 1003/18
1086/7 1105/7 1105/13
1026/5 1026/7 1055/12 1004/6 1029/8
discovery [2] 1112/1 1118/12
1027/1 1032/13 document [13] 1029/10 1033/3
1044/14 1044/14 early [4] 993/13
1034/7 1034/23 1054/19 1061/8 1033/11 1033/15
discuss [2] 994/6 1105/15
1035/17 1035/21 1061/9 1061/19 1035/8 1035/11
1028/7 1129/17 1105/21
1036/25 1038/22 1067/6 1067/22 1035/13 1036/2
discussed [3] eating [1] 1026/2
1041/20 1043/13 1099/22 1108/12 1037/3 1044/24
992/17 1057/13 EDGAR [1]
1046/14 1046/19 1108/13 1111/6 1088/23 1089/2
1110/11 989/12
1047/19 1051/10 1111/7 1113/7 1089/16 1090/10
discussing [2] editor [1] 1097/17
1052/25 1053/1 1117/11 1090/13 1090/13
1022/16 1069/15 effect [3] 1052/23
1057/1 1057/5 documentation 1090/15 1105/1
discussion [7] 1052/24 1073/16
1057/25 1059/7 [1] 1118/23 1106/4 1107/6
1010/3 1011/9 effort [3] 995/8
1059/8 1060/14 documents [4] 1109/5 1109/9
1064/5 1064/6 1001/22 1022/9
1061/22 1063/19 1054/21 1054/23 1109/25 1110/23
1116/22 1117/2 either [13] 992/4
1064/9 1065/18 1081/15 1116/13 1111/11 1112/17
1121/7 1019/13 1026/5
1065/24 1070/12 does [14] 1000/1 1113/22 1114/11
discussions [3] 1031/14 1038/8
1071/25 1072/11 1015/19 1024/17 1115/3 1116/5
1011/3 1064/20 1041/6 1071/16
1072/12 1072/13 1047/1 1048/9 1120/5 1120/23
1129/8 1071/25 1085/10
1072/21 1073/1 1061/24 1082/14 1125/9 1128/15
dismiss [1] 1086/25 1097/7
1074/10 1075/12 1089/11 1106/22 1128/23
1129/6 1098/7 1101/23
1075/20 1076/11 1108/8 1108/16 Durham's [1]
dismissed [1] elaborate [1]
1076/25 1080/1 1109/4 1115/22 1105/17
1065/1 999/14
1080/15 1080/17 1115/23 during [8] 994/21
disorderly [1] election [2]
1080/20 1080/21 doesn't [3] 1010/20 1011/3
1117/2 1021/7 1100/18
1081/20 1081/24 1022/4 1108/1 1042/14 1114/11
DISTRICT [4] electronic [1]
1082/2 1082/10 1125/7 1117/23 1121/7
989/1 989/1 989/9 1101/16
1083/5 1084/14 doing [12] 1122/5
1004/11 element [1]
1085/10 1086/9 1002/15 1011/4 DX [4] 1027/15
division [1] 1091/2
1086/14 1086/18 1011/9 1014/17 1027/15 1076/17
1089/6 elephant [1]
1095/1 1097/22 1039/16 1064/2 1079/13
DNC [28] 996/8 1052/16
1098/9 1098/10 1082/13 1086/24 DX-108 [1]
997/18 997/22 elicit [1] 1116/20
1098/16 1099/23 1088/16 1092/20 1027/15
998/9 999/8 else [15] 992/22
1100/5 1100/7 1093/2 1119/9 DX-558 [1]
999/19 999/23 999/14 1010/18
1105/14 1105/21 DOJ [1] 1125/15 1079/13
1011/10 1053/13 1010/18 1010/24
1106/11 1106/24 don't [160] DX-559 [1]
1053/18 1054/3 1013/23 1017/11
1109/18 1109/24 Donald [3] 1021/7 1076/17
1054/9 1084/7
1141
E 1009/10 1036/14 1036/15 1079/14 1079/17 1031/2 1037/2

estimation [1] 1039/23 1040/20 1079/25 1083/23 1040/17 1040/22
else... [8] 1024/1
1022/3 1059/6 1062/16 1083/24 1089/20 1045/20 1046/9
1049/21 1061/19
ethical [5] 1068/21 1076/19 1096/9 1046/19 1047/1
1069/14 1070/4
1045/14 1050/16 1079/13 1081/16 existence [1] 1047/16 1048/11
1079/7 1086/16
1078/23 1087/23 1084/6 1085/3 1022/17 1051/17 1082/15
1088/20
1125/16 1086/16 1086/20 exited [2] 1100/3 1105/18
else's [1] 1082/14
evaluate [3] 1086/25 1087/10 1064/23 1129/13 1105/22 1114/19
elsewhere [2]
1040/15 1068/12 1101/5 expected [3] 1118/22 1119/2
1012/22 1104/1
1068/14 evolved [2] 1033/13 1033/14 1126/8 1128/21
email [2] 1012/21
evaluated [1] 1044/1 1110/8 1035/10 factor [3] 1045/21
1015/10
1002/17 exact [3] 1026/19 experience [1] 1045/23 1046/11
emails [1]
even [12] 1007/1 1091/15 1120/3 1092/22 factored [3]
1014/23
1007/11 1031/15 exactly [7] expert [3] 997/1 1046/21 1047/3
emergencies [1]
1031/23 1059/9 1016/19 1029/14 1019/4 1095/12 1048/13
991/8
1059/10 1097/2 1044/14 1110/3 experts [16] factors [1]
employees [2]
1103/22 1104/3 1110/14 1112/14 995/19 1018/21 1022/15
992/2 1121/9
1105/20 1109/13 1113/1 1042/22 1054/25 facts [5] 1023/5
employer [1]
1111/5 Exam [2] 1015/10 1055/2 1055/15 1023/5 1023/12
1012/9
evening [1] 1015/11 1055/17 1055/25 1023/14 1024/4
enables [1]
1129/7 examination [6] 1056/8 1056/9 factual [7] 997/5
1021/25
event [8] 1008/6 990/4 990/5 990/6 1057/2 1101/10 1022/24 1022/25
end [3] 991/14
1051/2 1051/7 993/1 1025/20 1103/8 1103/10 1023/7 1024/12
991/21 1100/12
1093/6 1093/21 1066/5 1103/18 1114/25 1041/19 1095/18
ended [1] 1088/6
1093/23 1093/25 examine [1] explain [6] fair [6] 1004/22
engage [1]
1104/6 1017/15 995/21 1072/6 1018/14 1029/19
1017/25
events [5] example [6] 1072/8 1077/2 1042/2 1107/23
enjoy [1] 1007/24
1004/17 1028/7 1015/24 1021/6 1086/3 1112/3 1122/24
enough [2]
1032/7 1081/17 1044/23 1051/13 explained [3] false [7] 1050/9
1024/6 1126/2
1093/4 1058/13 1093/7 995/18 1067/16 1083/12 1091/14
entered [2]
eventually [5] excerpt [2] 1118/12 1091/16 1091/18
992/25 1065/15
1003/8 1004/8 993/25 1020/21 explaining [2] 1109/15 1129/2
entire [1] 1071/8
1015/5 1073/21 exchange [5] 1106/11 1106/13 familiar [3]
entities [2]
1075/25 998/16 999/1 exploring [1] 1022/11 1106/22
1053/25 1110/18
ever [7] 1007/5 1004/20 1008/20 1032/13 1108/5
entitled [1]
1044/16 1057/13 1010/6 expressing [1] family [3] 991/8
1130/6
1059/14 1063/12 exchanges [1] 997/21 1012/10 1012/15
entries [2]
1071/13 1127/25 1012/12 extended [3] far [2] 1004/15
1054/18 1054/19
every [2] 1050/1 exchanging [1] 991/9 1064/6 1010/21
environment [2]
1106/4 1025/4 1064/6 Farley [1] 1109/6
1083/16 1116/16
everybody [6] excuse [6] 996/12 extent [9] 1014/7 fashion [1]
equal [1] 1028/21
1015/5 1061/2 1009/21 1017/24 1020/18 1022/15 1110/12
Eric [3] 1073/10
1083/6 1086/13 1041/10 1072/6 1039/24 1040/22 fast [2] 1075/12
1074/23 1075/16
1105/10 1107/9 1102/23 1043/6 1060/9 1075/13
especially [2]
everyone [2] executive [2] 1069/23 1070/1 FBI [66] 1000/11
1011/22 1067/22
993/11 1052/13 1073/4 1073/23 extra [1] 1072/9 1001/14 1002/8
ESQ [7] 989/12
everything [1] exhibit [22] 994/4 eyes [1] 1034/24 1002/25 1014/23
989/12 989/13
1111/17 994/11 994/16 1018/4 1019/10
1004/21 1027/21 F
989/17 989/17
evidence [27] 1019/22 1020/16
989/18 989/18 facility [1] 1116/7
990/11 990/14 1034/10 1036/6 1020/22 1021/2
essentially [5]
990/14 990/15 1036/19 1062/11 fact [27] 998/13 1022/7 1022/22
1068/13 1072/3 998/18 1003/15
990/15 990/16 1062/17 1065/5 1022/22 1024/9
1108/15 1113/3 1007/12 1010/13
1016/25 1018/15 1065/8 1068/20 1037/19 1039/5
1113/4
1027/16 1034/10 1076/19 1076/22 1021/25 1029/10 1039/7 1039/8
establish [1]
1142
F 1095/6 follow-up [4] Freedman [1] general [27]

fine [2] 997/11 1041/18 1074/10 1080/11 1000/11 1004/12
FBI... [47]
1095/23 1103/1 1104/16 Friday [2] 1012/9 1004/13 1004/14
1042/12 1047/15
finish [1] 1012/17 followed [1] 1055/9 1010/23 1015/23
1048/4 1048/10
fired [2] 1093/7 1059/15 Fridays [3] 1016/24 1022/20
1050/1 1050/10
1093/23 following [4] 992/10 992/12 1022/21 1032/19
1051/15 1058/3
firm [5] 1005/6 1020/2 1038/23 993/12 1037/19 1038/5
1058/15 1059/1
1036/11 1054/3 1038/23 1123/3 friend [4] 1026/24 1039/4 1058/15
1059/14 1063/22
1087/19 1088/1 foregoing [1] 1028/22 1034/17 1075/21 1076/1
1064/10 1064/14
firming [1] 1009/8 1130/4 1046/1 1077/3 1077/7
1075/6 1076/2
first [29] 994/5 foreign [6] 1001/3 friendly [3] 1077/8 1078/9
1077/21 1078/1
995/11 996/4 1001/5 1001/13 1005/12 1006/8 1078/16 1078/17
1078/1 1078/6
998/2 1004/2 1023/9 1023/25 1069/24 1086/21 1090/9
1078/9 1080/8
1006/16 1015/7 1024/14 front [2] 1110/17 1098/6 1105/18
1080/14 1080/19
1015/17 1027/3 form [12] 1062/1 1113/6 1124/7
1080/23 1082/6
1039/23 1044/3 1062/10 1062/19 full [9] 991/21 general's [3]
1082/12 1082/16
1046/24 1063/12 1062/21 1063/1 1022/13 1023/3 1077/14 1077/16
1085/9 1086/12
1073/18 1081/5 1063/3 1063/16 1023/6 1024/3 1077/17
1089/5 1089/6
1092/5 1096/14 1064/4 1101/2 1024/10 1024/21 generally [3]
1098/6 1106/2
1103/23 1106/7 1102/21 1117/4 1086/14 1120/24 1013/3 1109/8
1106/16 1107/3
1106/10 1106/10 1117/10 fun [2] 1011/24 1120/9
1108/15 1108/18
1107/16 1114/6 formal [1] 1012/2 generated [1]
1109/5 1110/10
1117/20 1120/19 1019/10 funny [1] 1056/15 1056/8
1110/22 1116/6
1122/9 1122/14 former [5] 1006/6 Furhman [1] gentleman [1]
1116/10 1118/22
1124/9 1126/23 1006/12 1014/21 1109/5 1026/24
1121/9 1126/3
five [8] 1007/20 1034/17 1125/15 further [9] 1003/9 gentlemen [6]
1128/6
1032/11 1055/11 forms [1] 1063/12 1004/7 1010/3 993/3 1052/12
FBI's [5] 1004/5
1071/3 1071/19 formulated [1] 1033/15 1035/10 1064/20 1065/16
1016/7 1018/7
1071/20 1081/18 1093/16 1089/7 1124/10 1119/10 1129/6
1020/19 1076/10
1111/25 forth [5] 1009/5 1124/17 1126/13 Gestured [1]
February [2]
flawed [1] 1022/1 1010/6 1104/4 future [1] 1097/17 1092/25
1045/5 1105/10
fleeting [1] 1116/24 1117/1 FYI [1] 1005/8 get [34] 991/10
federal [1] 1023/8
1008/18 forward [6] 991/5 991/24 992/18
feel [1] 1065/12
flipped [1] 1012/7 1025/18 G 993/5 993/12
fellow [1] 1034/16
1040/12 1075/12 1075/14 Gaddis [1] 1076/6 995/12 997/7
felt [1] 1049/19 gallery [1]
focus [9] 994/11 1099/13 1025/24 1035/7
few [1] 993/6
1079/23 1084/2 found [8] 1010/17 1052/13 1037/5 1039/25
field [2] 1020/7 game [1] 1072/10
1093/15 1102/4 1049/9 1049/18 1040/8 1040/17
1020/14
1103/16 1104/2 1049/20 1078/23 gathering [1] 1041/13 1044/11
fifteen [1] 1068/2 1063/15
1113/16 1117/17 1101/10 1119/4 1052/10 1058/10
fifth [1] 1048/2 Gauhar [5]
focused [6] 1125/24 1059/5 1060/11
figure [1] 1009/5
1093/12 1103/21 four [4] 1037/12 1076/7 1076/8 1060/12 1063/17
figured [1]
1104/7 1104/7 1037/12 1064/22 1076/9 1078/12 1066/12 1066/13
1073/21 1078/18
1106/16 1106/19 1072/25 1067/10 1068/7
file [1] 1060/2 Gauhar's [2]
Focusing [1] four-minute [1] 1069/22 1072/9
files [1] 1018/7 1080/1 1120/13
1067/7 1072/25 1085/19 1095/19
final [1] 1012/11 gave [15] 996/2
folks [6] 1015/11 fourth [1] 1048/2 1095/20 1101/24
finalizing [1] 1002/5 1005/6
1046/15 1046/15 Fox [2] 1005/4 1109/17 1126/6
991/15 1014/6 1039/13
1056/9 1057/6 1103/25 1127/10
finally [7] 1004/8 1041/24 1061/11
1128/21 framed [1] getting [8]
1004/9 1004/13 1061/12 1061/18 1006/24 1007/24
follow [5] 1042/11
1009/15 1011/15 1070/23 1073/10 1010/12 1011/22
1041/18 1041/18 framework [1]
1012/23 1126/2 1083/9 1092/4
1074/10 1103/1 1022/12 1013/5 1030/16
find [4] 996/21 1118/17 1126/7
1104/16 free [1] 1065/12 1050/10 1066/15
1060/5 1087/22
1143
G 1012/3 1012/22 1126/11 1066/19 1067/8 1067/19 1069/8

1025/23 1035/6 guessing [1] 1071/10 1071/11 1071/18 1071/19
give [13] 996/19
1064/16 1119/7 1104/20 1071/13 1072/6 1072/2 1081/17
1018/23 1028/21
1119/12 guidelines [2] 1072/19 1074/3 1116/24 1128/7
1039/2 1039/9
goodness [2] 1022/20 1022/21 1076/14 1077/14 happy [2] 992/18
1041/22 1051/8
996/2 1092/3 guy [4] 996/22 1078/19 1078/19 1012/5
1060/22 1070/8
got [29] 992/14 1078/1 1082/12 1078/25 1080/18 hard [11] 993/14
1084/3 1087/5
996/24 996/25 1095/7 1080/22 1085/10 1033/24 1093/4
1094/21 1125/13
996/25 997/1 1086/24 1087/8 1110/3 1111/24
given [3] 1060/2
999/25 1006/22 H 1088/21 1088/25 1118/9 1121/7
1091/2 1102/3 ha [1] 1110/19
1006/23 1010/17 1089/2 1089/2 1121/14 1121/16
giving [7] 1001/3 hack [8] 1053/14 1089/3 1089/4
1025/22 1041/16 1121/18 1121/21
1024/15 1038/23 1053/18 1053/25 1089/4 1089/5
1041/17 1043/10 harder [2]
1041/11 1081/14 1054/7 1054/11
1052/6 1052/8 1089/8 1089/10 1058/18 1120/6
1082/7 1126/20 1095/3 1110/13
1055/17 1061/7 1094/13 1094/16 HARDWICK [1]
go [28] 993/6 1124/18
1062/2 1063/23 1096/25 1098/18 989/18
995/16 997/10 hacks [1] 1127/20 1098/19 1099/2
1067/8 1080/9 has [6] 991/8
999/14 1004/11 had [136] 993/4
1081/25 1095/9 1100/13 1101/5 1024/9 1072/16
1004/25 1005/22 995/18 995/19
1095/10 1095/11 1101/10 1102/3 1083/6 1098/4
1008/9 1010/1 995/19 996/9
1095/11 1101/25 1102/20 1103/2 1110/8
1011/15 1013/13 996/13 997/14
1120/14 1120/15 1103/22 1104/9 hat [1] 1012/8
1025/24 1034/21 1000/12 1000/22 1104/15 1104/21
gotcha [1] have [173]
1035/2 1060/19 1000/23 1000/24 1105/8 1105/20
1108/24 haven't [4]
1074/14 1083/25 1001/8 1001/11
gotten [2] 1106/24 1110/3 1012/9 1039/11
1085/20 1091/6 1002/14 1004/7
1058/16 1058/19 1113/5 1114/13 1047/11 1104/19
1095/22 1096/7 1004/9 1004/11
governed [1] 1115/3 1116/23 having [21] 997/5
1099/22 1100/11 1006/9 1007/1
1049/23 1118/9 1118/25 999/22 999/23
1100/21 1102/2 1010/18 1011/4
government [7] 1119/18 1120/25 1001/5 1003/19
1102/25 1104/18 1011/12 1012/25 1121/7 1121/8
991/17 994/10 1007/1 1021/24
1120/5 1013/9 1014/11
1001/1 1001/2 1124/22 1126/5 1031/16 1033/24
God [1] 1104/3 1014/13 1014/16 1128/21 1128/22
1001/15 1045/4 1049/20 1057/15
goes [1] 991/14 1014/22 1014/24 1129/1
1083/23 1064/5 1070/17
going [37] 991/5 1014/25 1015/1
GOVERNMENT'S half [1] 1026/22 1090/19 1095/17
991/23 992/12 1015/14 1016/1
[9] 990/10 994/4 hand [1] 1092/25 1099/11 1103/22
993/25 997/12 1016/7 1016/15
994/11 994/16 handed [2] 1115/10 1126/19
1001/13 1002/24 1017/4 1018/2
1004/20 1062/11 1041/15 1061/5 1126/21 1126/22
1012/16 1013/3 1018/15 1021/22 handing [1]
1068/20 1083/24 he [224]
1013/21 1017/10 1025/2 1025/11
1096/9 1043/7 he'd [1] 1112/25
1020/24 1020/25 1030/17 1030/21 handler [4]
governmental [1] he's [4] 1034/17
1021/18 1025/6 1031/14 1032/3
1100/14 1019/20 1020/7 1058/25 1078/6
1025/24 1025/25 1037/9 1042/9
grand [1] 1038/22 1020/7 1020/14 1129/17
1031/9 1032/13 1042/12 1043/9
great [4] 1011/24 handling [1] head [5] 996/13
1035/18 1043/11 1046/2 1046/3
1012/2 1052/11 1019/24 1034/15 1052/14
1051/9 1052/10 1050/23 1051/1
1129/11 hands [3] 997/8 1083/2 1094/17
1052/25 1054/18 1051/11 1053/12 1095/20 1101/25
greater [1] headline [1]
1072/16 1075/2 1053/24 1054/8
1023/11 handwriting [3] 1006/17
1075/12 1075/12 1055/6 1055/13
ground [1] 1052/11 1055/12 headquarters [4]
1075/13 1079/25 1055/17 1056/2
1025/22 1080/1 1020/8 1058/3
1080/7 1082/8 1056/8 1056/12
grounds [1] hanging [1] 1107/3 1116/6
1083/5 1119/10 1056/24 1057/2
1030/4 1088/16 heads [3]
1119/12 1129/5 1057/6 1058/10
group [1] 1098/8 happen [1] 1005/12 1006/8
gone [2] 1067/8 1059/3 1059/19
guess [6] 1000/8 1057/4 1051/8
1100/23 1059/21 1062/6
1054/5 1063/20 happened [10] hear [3] 992/22
good [10] 993/16 1063/16 1065/22 1031/13 1033/8
1085/18 1085/22 1059/21 1118/22
1011/21 1011/25
1144
H 1118/6 1123/12 1067/9 1067/20 home [3] 1065/17 human [9]

1123/16 1127/7 1068/9 1069/9 1112/6 1112/10 1019/10 1019/14
heard [4] 1007/22
1128/11 1129/11 1069/10 1070/10 honest [1] 1019/19 1019/25
1011/21 1059/17
hereby [1] 1130/4 1070/14 1070/17 1050/20 1020/5 1020/10
1119/3
Herman [3] 1071/13 1072/7 Honestly [1] 1060/8 1112/4
heart [2] 996/2
989/23 1130/3 1072/8 1072/10 1097/2 1118/13
1092/3
1130/14 1072/19 1073/5 honing [1] hundred [6]
heavily [6]
hesitating [3] 1075/16 1082/10 1093/17 1042/6 1053/9
1023/14 1045/21
1039/22 1044/21 1084/9 1084/15 Honor [17] 991/2 1057/22 1070/25
1046/11 1046/21
1060/6 1085/5 1087/11 991/25 992/9 1123/10 1123/18
1047/3 1048/13
Hey [3] 1012/24 1088/1 1092/4 992/15 992/16 Hurricane [6]
heightened [2]
1028/20 1063/17 1092/6 1095/23 992/19 992/21 1016/5 1016/6
1021/17 1021/17
HFA [5] 1053/18 1097/1 1098/21 993/21 994/10 1016/9 1075/4
held [2] 989/8
1054/3 1054/9 1100/18 1101/21 994/14 1027/16 1075/9 1077/19
1060/16
1095/2 1127/23 1101/22 1105/8 1028/23 1034/11 hurt [2] 1065/24
Hellman [1]
Hi [1] 1007/22 1105/11 1105/13 1036/15 1053/1 1066/8
1061/23
high [6] 995/18 1105/14 1106/7 1079/15 1129/16
hello [1] 1008/20
1014/11 1067/13 1106/8 1106/11 honorable [3] I
hello-how-are-yo I'd [5] 1028/20
1070/20 1070/21 1106/13 1113/16 989/8 1087/23
u [1] 1008/20 1034/9 1047/22
1070/22 1113/24 1114/1 1097/15
help [10] 1020/23
highest [2] 1121/3 1125/23 Hoover [1] 1058/5 1065/4 1123/15
1025/16 1028/10 I'll [19] 995/1
1077/13 1077/19 1126/6 1127/12 hope [4] 992/7
1045/24 1046/4 1012/2 1022/4
highest-ranking himself [5] 993/3 1012/10
1052/10 1088/3 1026/19 1052/25
[2] 1077/13 1045/17 1077/10 1097/15
1108/8 1113/8
1077/19 1077/11 1089/2 hours [1] 1037/12 1062/4 1065/18
1113/9
highlight [1] 1125/21 how [39] 993/14 1076/3 1076/16
helpful [2] 1059/6 1085/22 1087/17
1113/15 hired [1] 1078/19 996/25 1000/4
1096/13 1091/23 1100/21
highly [2] his [45] 996/2 1000/7 1002/10
helps [1] 1127/16 1100/24 1102/23
1024/15 1067/17 998/10 1002/11 1005/10 1006/6
her [11] 1014/23 1103/14 1111/3
Hillary [6] 1015/9 1025/15 1028/11 1008/20 1012/6
1057/8 1057/11 1117/21 1120/10
1053/13 1084/8 1037/3 1044/24 1013/25 1014/4
1058/17 1060/22 I'm [77] 992/12
1086/1 1110/12 1045/20 1046/10 1014/5 1016/22
1076/7 1078/17
1127/18 1046/10 1046/20 1016/24 1022/23 993/25 997/6
1078/19 1078/19 998/15 998/15
him [85] 996/2 1046/21 1047/2 1023/21 1026/5
1078/21 1078/23
996/5 997/10 1047/3 1047/4 1026/15 1035/23 998/16 998/20
here [45] 994/7 998/20 999/11
998/3 998/13 1048/12 1048/12 1035/24 1041/3
996/17 1004/17 999/18 1005/7
1008/11 1008/14 1051/23 1060/10 1044/1 1054/13
1005/14 1005/20
1008/14 1013/22 1060/17 1071/12 1054/17 1063/10 1006/8 1007/23
1008/12 1013/3
1013/23 1014/11 1075/8 1080/14 1067/10 1067/13 1009/9 1009/23
1026/24 1027/1
1027/1 1028/18 1080/19 1080/23 1067/25 1070/21 1012/1 1012/24
1027/2 1027/4
1035/14 1036/23 1081/22 1082/17 1086/23 1088/19 1012/25 1017/18
1027/5 1027/7
1036/25 1040/3 1082/20 1088/1 1095/10 1100/19 1024/17 1025/23
1027/9 1028/2 1027/5 1027/9
1040/23 1041/6 1089/2 1092/3 1103/5 1103/12
1031/10 1043/21
1045/13 1045/13 1092/15 1092/17 1108/18 1111/23 1031/9 1033/24
1047/7 1048/15 1034/19 1034/24
1045/22 1045/24 1101/8 1102/12 1112/3 1119/9
1049/4 1051/6
1046/3 1046/5 1103/18 1104/15 How'd [1] 995/11 1039/22 1042/10
1052/17 1053/16 1044/21 1047/5
1046/7 1046/12 1106/11 1108/22 however [1]
1056/22 1057/1 1048/1 1052/3
1050/18 1050/20 1114/25 1127/21 1056/16
1057/5 1057/12 1052/3 1052/10
1050/23 1051/10 1127/22 1128/15 Huber [1]
1060/21 1063/5 1052/25 1053/6
1051/15 1051/16 1128/23 1129/17 1090/12
1064/12 1070/3 1054/7 1054/18
1057/2 1057/6 Hmm [1] 1060/25 huh [7] 1006/20
1082/21 1092/16
1057/24 1058/1 hold [4] 1034/1 1007/21 1068/23 1055/12 1057/5
1094/3 1097/16
1058/13 1058/16 1059/5 1060/17 1097/13 1098/23 1057/15 1060/6
1099/11 1110/5
1059/24 1066/19 1084/20 1115/19 1120/17 1061/5 1066/10
1114/20 1115/1
1145
I 1018/16 info [1] 1080/9 1003/18 1017/8 interpret [1]

immediately [2] information [95] 1051/11 1073/11 1061/11
I'm... [32] 1067/21
1066/16 1101/22 995/20 996/1 initiated [1] interpretation [2]
1071/8 1071/12
impact [2] 1014/3 996/24 997/6 1111/17 1085/18 1085/23
1072/7 1072/21
1014/4 997/7 1002/23 inquiry [1] interview [27]
1074/21 1075/12
imperative [1] 1006/18 1014/1 1024/16 997/10 1030/6
1075/12 1075/13
1058/20 1014/5 1015/8 Inspector [2] 1036/23 1041/6
1079/25 1080/7
implicates [1] 1016/23 1017/17 1032/19 1090/8 1042/17 1047/14
1080/10 1082/5
1059/1 1018/4 1018/6 instance [2] 1049/1 1050/1
1082/5 1083/5
implied [1] 1018/8 1018/21 998/12 1039/23 1059/15 1095/22
1094/7 1095/19
1085/24 1019/6 1019/13 instances [1] 1105/19 1106/19
1096/11 1096/19
important [3] 1020/15 1020/20 1002/21 1106/25 1107/1
1097/3 1097/11
1005/8 1062/7 1020/24 1021/2 Institution [1] 1108/14 1108/18
1104/20 1104/22
1067/12 1021/3 1021/4 1034/17 1108/21 1108/23
1111/9 1112/3
imprecise [1] 1021/8 1021/16 instrumental [1] 1109/9 1109/15
1117/14 1123/6
1102/15 1021/17 1022/25 1025/8 1120/19 1120/22
1123/23 1124/25
impression [2] 1023/10 1023/13 insufficient [1] 1121/4 1121/4
1125/7 1125/12
1002/1 1002/5 1024/6 1024/7 1022/2 1121/6 1121/8
1129/19
improper [4] 1025/3 1025/7 intelligence [3] 1122/2
I've [18] 1011/23
1002/16 1086/2 1025/9 1029/13 1023/9 1023/25 interviewed [13]
1032/2 1042/9
1086/4 1087/3 1030/16 1030/17 1024/14 1002/22 1003/13
1053/18 1055/17
inaccurate [1] 1030/18 1030/20 intend [1] 998/8 1026/6 1032/24
1057/10 1057/13
1102/15 1031/4 1041/11 intended [1] 1037/2 1044/17
1075/25 1076/2
inappropriate [3] 1041/15 1043/4 1117/14 1044/18 1044/19
1080/7 1081/7
1085/5 1085/8 1045/17 1051/9 intense [1] 1047/15 1051/2
1105/12 1109/3
1085/12 1055/7 1055/13 1103/16 1059/21 1059/24
1110/4 1115/21
included [2] 1055/17 1056/13 intention [1] 1099/2
1118/9 1121/17
1017/6 1017/7 1056/25 1061/18 1102/20 interviewing [4]
1127/25
Including [1] 1062/2 1063/23 intentionally [2] 1087/19 1096/16
I.G [9] 1007/17
994/24 1064/7 1064/11 1064/13 1104/10 1097/4 1099/8
1032/1 1044/18
incomplete [1] 1064/14 1066/15 interaction [9] interviews [2]
1099/15 1099/19
1022/2 1068/8 1080/22 996/4 998/2 1049/3 1106/5
1102/10 1102/11
inconsistent [6] 1081/21 1082/3 1008/18 1040/22 introduction [1]
1102/20 1120/16
1031/18 1032/4 1082/16 1083/9 1041/12 1043/15 994/13
idea [2] 1082/2
1032/5 1114/16 1084/17 1085/6 1091/4 1092/5 intrusion [4]
1098/13
1115/24 1128/22 1085/9 1086/6 1102/8 999/22 999/23
identification [3]
incorrectly [1] 1086/7 1087/10 interactions [8] 1023/11 1124/12
1036/5 1076/17
1018/22 1092/2 1095/9 1003/19 1003/21 intrusive [1]
1079/13
increase [1] 1095/18 1095/20 1028/17 1043/9 1023/12
identified [1]
1024/21 1100/20 1101/5 1050/23 1090/20 investigate [2]
1118/23
incriminate [1] 1101/20 1101/22 1101/7 1129/9 1022/23 1033/11
identify [2]
1030/4 1108/5 1110/4 intercede [1] investigated [3]
1055/25 1064/11
indicate [2] 1114/13 1115/4 1001/14 1033/14 1035/7
identifying [2]
1108/1 1126/24 1116/20 1118/1 interest [4] 1035/10
1117/25 1118/3
indicated [2] 1118/12 1118/18 1001/9 1023/17 investigating [5]
identity [13]
1104/15 1105/13 1118/24 1121/10 1087/9 1120/24 1022/7 1023/24
1014/2 1020/9
indicates [2] 1124/1 1124/2 interested [1] 1023/24 1051/19
1021/3 1022/16
1023/7 1024/12 1125/5 1125/10 1087/25 1060/3
1060/10 1060/21
indication [1] 1125/20 1125/24 interests [1] investigation [76]
1061/21 1062/1
1018/15 1126/3 1015/15 1000/9 1002/24
1069/11 1072/8
individuals [2] informed [3] interfere [1] 1003/6 1003/8
1118/17 1121/9
1056/24 1060/9 1059/19 1104/20 1068/15 1003/11 1003/12
1121/25
influenced [1] 1109/8 internet [1] 1003/13 1003/23
IG [1] 1036/24
1081/12 initially [4] 1018/25 1004/5 1004/5
illegally [1]
1146
I 1043/6 1111/24 1113/13 1016/13 1016/16 992/13 993/5

involving [1] 1113/17 1115/25 Joffe's [1] 993/10 995/13
investigation...
1124/12 1116/16 1116/22 1016/15 996/1 996/14
[66] 1004/17
is [178] 1116/24 1117/11 John [8] 1003/4 996/20 996/21
1014/22 1014/25
isn't [8] 1031/9 1118/12 1119/3 1035/8 1089/16 1005/8 1009/10
1015/10 1016/7
1045/22 1049/25 1121/18 1127/4 1090/10 1090/15 1010/6 1011/19
1020/20 1021/25
1050/5 1072/17 items [1] 1031/25 1097/16 1098/22 1011/21 1012/17
1022/12 1022/13
1093/5 1093/14 iterative [2] 1109/6 1016/1 1017/5
1022/13 1023/2
1111/25 1116/25 1117/1 join [1] 1017/4 1017/12 1018/17
1023/3 1023/6
issue [12] 992/13 IV [1] 989/12 JONATHAN [1] 1018/24 1021/14
1024/2 1024/3
992/17 994/20 989/12 1024/7 1027/2
1024/3 1024/5
1000/15 1000/17 J Jordan [23] 995/2 1027/5 1027/7
1024/8 1024/10 JAMES [4] 993/1
1002/11 1007/11 995/2 995/3 1034/21 1036/24
1024/22 1027/5 1025/20 1078/7
1018/17 1028/8 995/25 998/5 1038/16 1042/11
1027/7 1029/3 1098/6
1032/18 1042/19 998/12 998/16 1045/24 1047/22
1029/6 1029/12 January [5]
1051/24 998/17 999/1 1048/5 1049/12
1029/17 1029/21 1005/1 1005/3
issued [1] 999/16 1060/24 1051/18 1051/25
1029/23 1029/25 1006/4 1006/14
1042/20 1061/23 1089/21 1053/23 1056/10
1030/1 1030/8 1007/4
issues [9] 1090/1 1090/8 1060/13 1061/14
1030/11 1030/16 JB [8] 1033/17
1000/17 1011/24 1090/12 1091/20 1062/12 1063/21
1032/17 1032/18 1034/9 1036/4
1012/2 1017/15 1091/24 1092/1 1067/1 1067/9
1032/20 1038/12 1047/21 1083/22
1017/16 1017/21 1094/10 1094/19 1067/16 1067/23
1038/20 1039/20 1107/15 1113/11
1019/2 1019/7 1095/6 1095/15 1075/9 1075/14
1041/19 1041/20 1115/16
1020/5 Journal [1] 1077/23 1079/18
1043/11 1044/24 JB-03 [1] 1083/22
it [361] 1097/1 1083/5 1085/18
1044/24 1053/14 JB-07 [1] 1115/16
it's [69] 992/2 JUDGE [6] 989/9 1085/22 1086/3
1060/10 1068/15 JB-07-001 [1]
992/2 993/14 1034/9 1064/18 1086/5 1086/21
1075/2 1075/10 1107/15
995/23 1000/6 1065/18 1119/8 1087/17 1088/24
1075/11 1076/11 JB-16 [1] 1047/21
1012/14 1013/9 1119/12 1089/10 1089/13
1077/10 1077/12 JB-709 [1]
1019/24 1021/10 Judiciary [1] 1089/14 1090/1
1077/15 1088/22 1113/11
1023/22 1024/24 1120/25 1092/3 1094/16
1088/22 1089/2 JB-LW-04 [2]
1025/25 1027/5 July [6] 1009/19 1094/18 1094/22
1089/16 1089/18 1033/17 1034/9
1027/6 1029/2 1010/14 1099/14 1094/24 1095/6
1090/5 1105/2 JB-LW-06 [1]
1029/5 1032/5 1099/19 1104/23 1096/12 1097/6
1105/4 1106/8 1036/4
1033/23 1034/3 1120/15 1097/25 1099/18
1106/16 1109/10 Jim [13] 995/3
1034/24 1035/24 June [14] 1099/21 1100/24
1124/12 1005/4 1007/22
1036/12 1047/14 1007/19 1007/23 1102/24 1103/13
investigations [9] 1011/21 1012/19
1047/16 1048/17 1009/9 1093/14 1103/14 1103/17
1023/1 1023/2 1013/2 1036/22
1048/20 1048/22 1106/22 1109/24 1105/10 1106/1
1038/3 1038/6 1038/24 1076/6
1049/12 1050/9 1110/22 1119/17 1107/16 1107/18
1038/9 1038/18 1078/3 1078/4
1052/24 1056/4 1120/9 1120/18 1107/19 1108/14
1039/6 1075/6 1078/6 1093/6
1058/18 1062/16 1120/18 1120/20 1108/25 1113/1
1077/18 Jimbaker123 [1]
1064/8 1071/1 1125/4 1125/9 1113/12 1114/22
investigative [2] 1012/20
1083/12 1083/24 jurors [1] 1052/13 1115/9 1115/12
1024/9 1060/2 job [9] 1008/8
1084/21 1085/18 jury [16] 989/8 1115/18 1116/6
investigator [1] 1008/9 1013/5
1090/3 1090/10 992/8 992/25 1117/13 1118/10
1037/25 1019/24 1038/2
1092/24 1093/1 1038/23 1047/12 1120/12 1120/19
investigators [1] 1038/5 1038/8
1093/4 1093/15 1062/15 1064/23 1126/19 1127/12
1018/7 1039/5 1044/22
1099/16 1099/19 1065/13 1065/15 Justice [7]
invite [1] 1076/16 Joffe [11] 1000/2
1099/22 1102/24 1069/8 1072/1 1004/9 1029/11
involve [1] 991/20 1000/4 1000/5
1106/4 1106/7 1073/6 1077/2 1077/6 1086/23
involved [3] 1000/19 1001/22
1108/1 1108/12 1079/3 1102/14 1089/8 1090/6
1023/8 1060/11 1008/4 1008/13
1108/14 1108/14 1129/13 1106/3
1060/12 1008/18 1011/13
1108/15 1111/6 just [97] 991/2 justify [1]
involvement [1]
1147
J 1072/12 1072/12 1055/22 1068/21 1015/14 1016/11 1039/24 1047/21

1073/25 1075/25 1075/18 1085/23 1094/14 1094/16 1049/14 1052/1
justify... [1]
1078/18 1080/8 1094/15 1097/25 1110/4 1110/6 1052/16 1060/20
1023/13
1086/4 1086/6 1121/18 1126/10 1110/20 1114/11 1061/1 1062/11
K 1086/8 1088/19 lasted [1] 1069/6 1115/3 1127/17 1067/1 1068/20
keep [5] 1012/8 1091/14 1091/15 late [1] 1080/8 1127/21 1072/22 1073/6
1012/16 1118/16 1091/16 1092/17 later [4] 1007/20 learning [1] 1076/16 1077/19
1119/10 1119/12 1094/10 1094/16 1090/24 1119/21 1124/13 1082/23 1083/21
Kelly [5] 1060/21 1094/20 1095/10 1119/25 least [17] 991/21 1088/8 1089/1
1060/23 1060/24 1095/11 1097/2 LATHAM [1] 1002/14 1003/17 1089/20 1091/19
1061/23 1118/2 1097/22 1098/16 989/19 1031/7 1031/17 1091/20 1097/17
kept [1] 1006/24 1098/21 1101/21 law [6] 1019/4 1044/1 1055/23 1102/4 1107/15
Kevin [1] 991/17 1101/25 1102/2 1036/11 1054/3 1060/8 1060/17 1109/17 1117/13
kind [7] 991/5 1104/20 1105/12 1087/19 1088/1 1065/18 1071/3 1119/21
1017/23 1032/14 1106/1 1109/13 1098/8 1078/11 1090/16 letter [5] 1028/14
1051/20 1060/19 1109/19 1110/10 Lawfare [1] 1119/11 1122/15 1065/22 1066/6
1088/18 1095/23 1110/24 1111/23 1034/15 1124/18 1126/13 1097/16 1099/12
kinds [2] 997/11 1112/20 1119/3 lawful [4] 1018/4 led [1] 1112/9 letting [1] 992/11
1019/5 1119/20 1120/1 1018/23 1023/23 left [11] 993/11 level [5] 995/18
knew [14] 998/8 1122/13 1126/10 1086/18 1002/25 1004/23 1023/11 1063/19
1013/15 1025/17 1126/10 lawfully [1] 1038/9 1039/7 1067/13 1070/19
1045/13 1049/24 knowing [1] 1019/6 1039/8 1066/15 Levin [8] 1027/24
1053/24 1057/6 1118/17 laws [1] 1017/24 1067/9 1088/25 1036/8 1036/10
1057/8 1090/16 knowingly [1] lawyer [23] 1089/1 1128/6 1036/12 1090/6
1091/2 1091/12 1118/16 1006/18 1027/25 legal [10] 1014/8 1090/10 1090/13
1095/1 1106/13 knowledge [5] 1028/14 1029/19 1017/15 1017/15 1090/15
1124/14 1043/17 1043/20 1035/14 1036/10 1017/16 1017/20 Lichtblau [3]
know [94] 993/11 1054/8 1098/14 1036/13 1037/17 1018/5 1018/17 1073/10 1074/23
995/2 996/7 1098/18 1038/18 1038/20 1019/2 1019/7 1075/16
996/12 996/16 known [6] 1053/24 1065/22 1030/23 lie [2] 1102/17
996/25 997/1 1015/14 1016/8 1089/14 1089/23 lengthy [1] 1102/18
998/5 1000/4 1021/22 1078/19 1090/6 1105/16 1089/3 lied [1] 1098/18
1000/4 1000/7 1105/20 1110/19 1107/4 1120/23 less [2] 1072/16 like [40] 994/8
1000/8 1002/18 knows [3] 1015/5 1121/20 1121/23 1086/7 1005/24 1007/24
1007/10 1007/25 1061/2 1129/17 1121/23 1128/25 let [26] 997/9 1009/3 1009/7
1012/4 1015/18 Kremlin [1] 1129/17 1007/25 1012/4 1010/16 1012/4
1015/19 1019/4 1101/13 lawyers [8] 1018/6 1018/19 1013/21 1017/12
1020/9 1020/9 1002/8 1014/8 1020/14 1021/2 1017/20 1022/23
L 1017/5 1017/6 1027/23 1028/18 1023/1 1023/2
1024/23 1025/1
ladies [6] 993/3 1017/12 1018/2 1029/19 1036/22 1023/15 1024/24
1025/22 1026/12
1052/12 1064/20 1018/11 1018/12 1036/24 1048/5 1025/1 1025/4
1027/10 1029/2
1065/16 1119/9 lead [1] 1086/1 1057/17 1059/5 1025/5 1028/20
1029/5 1031/11
1129/6 leak [1] 1032/18 1059/16 1069/19 1029/2 1029/5
1036/22 1036/24
laid [2] 993/17 leaked [1] 1070/8 1073/13 1045/1 1055/12
1042/9 1044/22
1051/18 1030/17 1077/23 1079/12 1063/25 1065/4
1049/17 1050/9
Landau [8] leaks [1] 1002/23 1080/8 1089/13 1068/2 1068/7
1050/11 1053/11
1056/5 1056/12 learn [4] 996/15 1095/21 1125/13 1068/8 1072/16
1053/14 1053/17
1056/24 1057/8 1016/13 1019/12 1126/19 1093/23 1101/18
1054/2 1055/23
1057/10 1114/8 1094/19 let's [38] 1004/20 1101/25 1103/9
1056/20 1058/22
1114/12 1114/24 learned [19] 1013/1 1014/15 1104/2 1104/3
1059/4 1060/4
last [15] 994/1 996/9 996/12 1026/2 1026/13 1107/19 1112/21
1060/10 1060/14
996/11 997/15 997/14 997/16 1027/15 1033/17 1114/1 1114/25
1060/15 1062/25
1012/19 1012/25 997/22 997/23 1033/18 1035/17 1118/11
1063/20 1064/6
1026/15 1026/17 999/19 999/20 1036/4 1037/5 likelihood [1]
1070/8 1072/11
1148
L 1097/25 1102/25 1004/21 1079/12 McCord [1]

1107/15 1107/19 major [1] 1032/10 Mary [1] 1076/6 1076/7
likelihood... [1]
1107/22 1115/12 make [27] 992/13 material [13] me [116] 992/7
1024/21
1123/15 993/10 995/10 1014/9 1041/14 993/7 996/12
likely [1] 1073/4
looked [10] 1007/10 1009/3 1044/12 1044/14 997/6 997/11
limited [1] 992/3
1021/8 1021/11 1013/25 1014/7 1044/15 1049/18 1000/12 1004/3
line [7] 1002/2
1044/12 1055/8 1016/18 1017/25 1049/20 1056/2 1005/8 1006/11
1038/24 1038/25
1061/8 1067/5 1018/1 1020/1 1056/8 1057/3 1007/1 1007/2
1048/1 1068/21
1068/18 1101/18 1020/2 1021/4 1057/7 1067/6 1007/25 1009/21
1100/1 1100/12
1112/12 1127/9 1028/18 1031/16 1067/8 1011/6 1012/4
lines [1] 1048/2
looking [16] 1050/9 1061/2 materials [3] 1012/16 1012/18
links [2] 1051/9
1007/11 1009/9 1062/12 1070/25 1043/8 1055/3 1013/1 1013/5
1075/7
1009/22 1019/5 1083/5 1083/12 1063/2 1013/25 1014/6
list [1] 1012/4
1048/1 1054/20 1089/11 1091/15 math [1] 1032/10 1014/7 1015/7
listed [1] 1078/7
1056/16 1067/21 1100/2 1107/20 matter [29] 1015/13 1015/23
listened [1]
1089/21 1090/9 1108/17 1125/7 999/22 1002/8 1016/10 1016/18
1101/21
1096/19 1110/15 makes [4] 1004/14 1010/25 1016/23 1017/10
littered [1] 1058/8
1117/11 1117/14 1067/23 1103/9 1013/9 1015/4 1017/11 1017/17
little [8] 993/12
1123/4 1128/18 1113/2 1126/12 1015/4 1016/7 1017/24 1018/19
1014/15 1026/13
looks [6] 994/8 making [3] 1018/12 1019/15 1018/21 1018/23
1034/21 1035/22
1005/24 1009/3 1048/15 1063/25 1028/5 1030/15 1020/16 1021/2
1090/23 1116/22
1009/7 1069/5 1118/11 1033/5 1038/11 1021/22 1027/23
1121/5
1072/16 man [3] 1029/6 1045/8 1051/19 1031/16 1036/22
LLP [1] 989/19
Lorraine [3] 1087/23 1097/15 1057/14 1071/14 1036/24 1041/10
location [2]
989/23 1130/3 manage [3] 1071/14 1075/17 1041/11 1044/22
1009/11 1028/13
1130/14 1038/2 1038/8 1077/20 1085/9 1045/3 1045/3
logic [1] 1067/16
losing [3] 998/201039/5 1089/11 1112/18 1046/4 1048/5
logical [2]
1001/12 1123/6 managing [1] 1113/24 1124/15 1049/13 1049/24
1059/23 1059/25
lost [1] 1087/16 1098/24 1126/23 1128/17 1051/20 1055/24
logistics [2]
lot [5] 1007/17 mandate [1] 1130/7 1057/17 1059/5
1013/21 1016/21
1018/9 1025/22 1106/11 mattered [3] 1059/16 1059/19
long [20] 992/5
1049/3 1121/17 many [9] 1004/9 1013/16 1016/11 1061/12 1061/20
992/23 993/14
lots [2] 1011/24 1026/5 1026/15 1016/12 1064/4 1064/14
1014/23 1019/23
1012/2 1056/16 1057/10 matters [12] 1067/8 1067/23
1054/13 1067/25
love [3] 1011/24 1058/9 1063/10 993/6 1004/4 1069/19 1069/22
1068/1 1071/18
1033/23 1035/6 1086/21 1086/21 1004/4 1013/10 1072/6 1073/13
1072/17 1078/19
Lovely [1] 1035/8March [16] 1013/12 1054/10 1074/22 1076/13
1093/4 1093/7
luck [1] 1012/22 1029/10 1044/9 1069/15 1076/15 1077/23 1079/12
1113/14 1121/7
lunch [8] 993/4 1045/5 1046/15 1079/6 1109/21 1080/8 1084/16
1121/13 1121/16
1007/24 1009/6 1046/17 1046/18 1110/2 1111/1 1085/12 1086/3
1121/21 1122/13
1010/4 1010/7 1047/6 1048/9 may [15] 989/4 1089/13 1092/10
1129/7
1010/18 1010/19 1049/4 1075/14 991/2 1002/22 1093/15 1093/17
long-term [1]
1010/20 1075/20 1076/4 1005/16 1009/23 1095/18 1095/24
1019/23
LW [3] 1033/17 1076/24 1081/20 1010/24 1011/18 1097/2 1098/17
longer [1] 1103/9
1034/9 1036/4 1082/23 1120/13 1026/18 1033/18 1101/3 1101/4
look [26] 1011/18
marching [1] 1034/18 1035/2 1101/20 1102/3
1012/7 1018/11 M 1083/6 1065/1 1119/7 1102/23 1104/20
1021/3 1033/17 made [10] 1007/2 margins [1] 1123/6 1130/14 1106/15 1107/19
1035/17 1036/4 1014/12 1022/17 1008/5 maybe [3] 1110/5 1110/17
1044/19 1044/20 1023/18 1041/5 Marie [1] 1099/23 1058/25 1068/2 1110/18 1111/5
1045/4 1047/21 1050/2 1069/3 mark [4] 991/17 1080/10 1111/6 1111/18
1068/20 1076/16 1091/18 1127/4 1036/5 1060/20 McCabe [4] 1112/12 1113/6
1077/23 1083/21 1128/18 1076/17 1076/6 1077/24 1113/7 1113/8
1087/17 1089/20 maintained [1] marked [1] 1080/10 1082/7 1115/9 1117/5
1091/19 1096/7
1149
M 999/7 999/10 1122/19 1122/21 989/5 989/17 1012/8 1017/16

1000/15 1000/16 1123/21 1123/24 1005/12 1006/11 1021/15 1021/18
me... [13] 1117/12
1002/14 1002/15 1124/9 1124/16 1007/2 1008/1 1053/23 1093/25
1117/17 1117/22
1007/2 1008/15 1124/20 1126/18 1011/21 1012/5 1104/7 1124/1
1119/19 1121/18
1010/3 1010/4 1127/21 1128/8 1012/7 1012/13 mine [2] 1034/17
1123/2 1125/7
1010/7 1010/21 1128/12 1013/22 1014/10 1062/7
1125/13 1126/19
1011/1 1011/6 meetings [4] 1018/20 1018/23 minute [10]
1127/16 1128/16
1013/14 1013/15 1002/6 1049/3 1025/17 1025/18 1037/9 1054/23
1128/18 1128/23
1013/21 1014/18 1075/24 1100/3 1025/18 1028/5 1064/20 1070/2
mean [19] 996/21
1015/12 1015/16 memories [3] 1028/21 1041/11 1072/3 1072/25
997/4 997/23
1015/17 1015/21 1031/20 1111/21 1042/10 1042/13 1073/1 1074/5
1000/2 1015/19
1015/22 1016/21 1125/3 1044/22 1045/20 1074/17 1074/20
1017/7 1017/22
1017/5 1017/19 memory [22] 1046/1 1046/22 minutes [15]
1021/20 1033/3
1025/11 1027/13 1000/21 1026/13 1054/4 1059/4 1009/17 1009/21
1051/11 1061/11
1028/9 1028/10 1032/13 1054/20 1059/21 1060/7 1010/9 1040/6
1061/24 1070/12
1028/18 1037/9 1054/24 1067/2 1061/12 1065/24 1054/16 1068/2
1071/2 1090/8
1037/13 1040/3 1067/4 1067/20 1066/8 1066/12 1068/2 1069/6
1095/6 1095/16
1041/10 1043/19 1067/24 1094/23 1066/13 1074/2 1072/2 1072/16
1106/4 1128/2
1047/10 1049/1 1110/8 1112/4 1086/24 1097/15 1072/17 1072/18
meaning [4]
1049/23 1052/1 1112/9 1112/11 1098/16 1099/9 1072/18 1073/7
1023/23 1042/9
1052/2 1052/19 1112/14 1123/4 1100/17 1101/2 1119/10
1097/9 1121/4
1053/12 1053/20 1123/12 1123/16 1101/4 1102/3 mislead [1]
means [2] 1067/7
1054/2 1054/13 1124/8 1127/6 1104/3 1110/7 1108/9
1077/3
1054/14 1054/22 1127/7 1128/17 1110/11 1111/16 misread [1]
meant [1] 999/20
1054/23 1054/23 mention [5] 1111/17 1115/11 1080/8
meat [1] 1109/17
1055/10 1055/20 1010/20 1011/4 1118/13 1121/9 misrepresent [1]
media [9]
1056/1 1056/11 1011/9 1011/12 1121/25 1123/5 1107/23
1035/21 1068/10
1057/9 1057/16 1103/10 1127/21 1128/12 mistake [2]
1080/14 1088/18
1057/18 1058/11 mentioned [6] Michael's [2] 1102/14 1102/15
1088/19 1091/2
1058/14 1058/16 1002/23 1017/2 1061/21 1127/17 mode [1] 1043/13
1103/25 1103/25
1058/20 1059/11 1056/10 1071/4 middle [8] moment [3]
1129/9
1059/12 1059/13 1071/6 1071/22 1009/10 1034/3 1016/14 1070/5
Medium [1]
1061/5 1062/8 mere [1] 1086/5 1059/10 1080/3 1122/24
1063/20
1062/9 1063/15 message [11] 1091/20 1100/1 Monday [2]
meet [34] 1000/12
1063/16 1064/15 1005/1 1005/10 1113/11 1113/13 1012/19 1055/10
1001/7 1007/24
1069/4 1070/23 1006/14 1006/16 Midyear [2] money [2] 1002/2
1009/3 1010/13
1075/21 1076/4 1011/18 1011/19 1015/10 1015/11 1025/4
1013/21 1013/22
1076/11 1076/16 1044/3 1044/5 Midyear-Exam [1] month [2]
1013/23 1014/10
1078/11 1079/1 1044/8 1046/10 1015/11 1026/15 1026/17
1014/17 1015/7
1079/4 1080/17 1047/2 might [24] 999/14 months [5]
1015/7 1015/9
1080/21 1081/21 messages [1] 1007/12 1014/2 1004/9 1007/20
1015/11 1016/9
1082/14 1093/21 1044/20 1014/4 1014/12 1007/20 1049/4
1017/10 1027/11
1098/5 1100/14 met [18] 1000/10 1015/17 1015/21 1051/1
1028/12 1028/16
1103/23 1109/18 1001/23 1008/10 1015/24 1017/4 Mook [2] 991/7
1028/20 1045/22
1109/20 1110/6 1026/3 1026/6 1017/5 1017/7 991/19
1045/24 1046/2
1110/21 1110/22 1026/15 1028/6 1017/14 1017/20 Mook's [1] 991/22
1046/5 1046/11
1111/11 1111/17 1051/16 1051/22 1018/8 1018/17 more [27] 993/25
1046/22 1047/4
1112/17 1113/4 1053/15 1075/25 1022/6 1025/12 1015/20 1017/9
1048/13 1065/23
1113/23 1114/7 1076/2 1101/4 1030/4 1033/11 1020/17 1021/2
1066/6 1101/3
1114/11 1114/23 1105/12 1105/14 1059/6 1064/16 1021/12 1023/4
1104/3 1105/11
1116/5 1117/3 1110/1 1110/25 1086/1 1091/3 1023/5 1023/11
1105/11
1119/17 1119/20 1120/8 1113/8 1023/12 1033/12
meeting [123]
1120/12 1122/5 mic [1] 1066/2 mind [10] 1039/25 1046/2
994/21 995/14
1122/11 1122/14 MICHAEL [56] 1007/11 1011/19 1067/23 1068/12
997/24 998/10
1150
M 994/20 995/13 1107/6 1109/5 1005/4 1005/25 1056/12 1057/8

1000/1 1002/21 1109/9 1109/25 1006/5 1007/22 1057/10 1060/21
more... [12]
1005/3 1005/10 1110/23 1111/11 1008/15 1009/16 1060/23 1078/18
1068/14 1071/20
1009/2 1009/14 1112/17 1113/22 1010/13 1011/4 1080/1 1100/17
1072/7 1091/6
1012/11 1013/13 1114/11 1115/3 1012/12 1013/7 1114/8 1114/12
1092/24 1093/1
1014/15 1018/14 1116/5 1120/5 1013/14 1013/15 1118/2
1096/20 1106/19
1019/9 1020/18 1120/23 1125/9 1014/16 1025/10 Ms. Gauhar [1]
1115/13 1121/5
1022/11 1025/10 1128/15 1128/23 1026/24 1027/11 1078/18
1125/13 1127/22
1025/19 1027/24 Mr. Durham's [1] 1028/11 1032/3 Ms. Gauhar's [1]
morning [4]
1028/4 1032/18 1105/17 1037/10 1040/1 1080/1
991/16 1025/23
1033/2 1065/12 Mr. Jim [1] 995/3 1041/21 1042/3 Ms. Kelly [3]
1129/12 1129/22
1071/18 1074/25 Mr. Joffe [7] 1042/17 1043/18 1060/21 1060/23
most [3] 1026/21
1090/2 1100/6 1000/5 1000/19 1045/7 1045/11 1118/2
1055/16 1058/2
1114/7 1129/17 1001/22 1008/13 1046/9 1047/19 Ms. Landau [6]
motivation [1]
Mr. Bellovin [4] 1008/18 1011/13 1048/11 1048/14 1056/5 1056/12
1020/19
1056/3 1056/4 1016/16 1050/16 1051/7 1057/8 1057/10
move [12]
1056/12 1114/8 Mr. Joffe's [1] 1051/23 1052/18 1114/8 1114/12
1008/23 1027/16
Mr. Berkowitz [2] 1016/15 1053/12 1056/23 Ms. Terzaken [1]
1034/9 1036/14
1064/16 1065/17 Mr. John [1] 1057/9 1057/24 1100/17
1036/15 1065/4
Mr. Blaze [3] 1003/4 1058/23 1059/15 much [10] 997/5
1065/4 1066/2
1056/5 1114/8 Mr. Jordan [12] 1061/15 1066/15 1008/17 1019/16
1076/19 1079/13
1114/12 995/2 995/2 1068/9 1068/16 1025/19 1028/8
1079/25 1082/23
Mr. Chadason's 995/25 998/5 1069/3 1070/7 1040/25 1059/5
moved [7] 994/15
[1] 992/1 998/12 998/16 1073/10 1073/19 1075/13 1091/16
1027/20 1034/12
Mr. Cleave [1] 999/1 999/16 1082/16 1084/2 1095/18
1036/18 1065/4
1034/4 1089/21 1090/1 1084/5 1085/2 multiple [10]
1065/7 1079/16
Mr. Cleaves [3] 1091/20 1091/24 1087/8 1087/23 994/21 1003/15
moving [2]
1076/18 1079/19 Mr. Levin [2] 1088/9 1088/17 1013/19 1013/19
1006/13 1099/13
1102/6 1036/10 1036/12 1090/21 1091/4 1019/21 1028/6
Mr [40] 990/4
Mr. Comey [1] Mr. Mook [2] 1093/22 1096/5 1042/9 1044/19
990/5 990/6
1093/23 991/7 991/19 1097/4 1097/22 1103/24 1105/13
992/17 993/25
Mr. DeFilippis Mr. Mook's [1] 1098/13 1098/18 murder [1]
995/22 997/13
[23] 993/20 991/22 1102/9 1104/15 1024/24
998/17 1007/5
1031/25 1039/16 Mr. Priestap [11] 1106/20 1109/20 murky [1] 1124/1
1011/20 1015/14
1044/11 1046/16 1041/16 1043/7 1109/20 1110/1 must [12] 1054/4
1035/1 1044/23
1048/10 1073/13 1066/17 1067/3 1110/25 1111/12 1071/22 1073/22
1056/4 1065/21
1083/4 1083/22 1067/14 1067/25 1111/12 1112/7 1110/6 1110/19
1075/15 1090/6
1098/1 1100/10 1068/6 1093/18 1112/17 1114/12 1112/10 1126/11
1090/8 1090/10
1109/5 1109/25 1119/18 1126/17 1117/25 1118/17 1127/1 1127/5
1090/10 1090/12
1110/23 1111/10 1127/24 1118/23 1120/13 1127/11 1127/14
1090/12 1090/13
1112/16 1113/22 Mr. Priestap's [7] 1122/16 1123/25 1127/17
1090/15 1092/1
1114/7 1114/10 1081/3 1110/15 1124/17 1125/5 mutual [1]
1092/5 1094/10
1115/3 1116/5 1122/7 1123/1 1125/10 1126/9 1051/23
1094/13 1094/19
1120/5 1125/9 1124/23 1126/22 1126/12 1126/14 my [97] 995/11
1094/21 1095/6
Mr. DeFilippis' [1] 1128/9 Mr. Sussmann's 995/17 995/21
1095/13 1095/15
1027/6 Mr. Sussmann [7] 997/17 1060/1 996/13 996/13
1095/16 1100/21
Mr. Durham [30] [103] 994/21 1060/16 1063/22 999/9 999/10
1107/25 1114/8
1003/18 1004/6 995/14 995/24 1064/10 1098/5 1000/10 1001/1
1114/12 1122/11
1029/8 1029/10 997/22 998/9 1118/8 1001/1 1001/10
1123/10
1033/3 1033/11 998/13 998/17 Mr. Trump [2] 1001/23 1001/24
Mr. [261]
1033/15 1035/11 998/22 1000/10 1075/7 1075/8 1002/8 1004/1
Mr. Baker [34]
1035/13 1037/3 1000/18 1001/17 Ms [2] 1056/3 1004/2 1004/6
991/14 991/16
1088/23 1089/2 1002/11 1002/18 1099/23 1005/6 1008/8
992/24 993/5
1105/1 1106/4 1004/21 1004/22 Ms. [12] 1056/5 1008/9 1008/11
993/23 994/5
1151
M 1118/8 1126/6 1106/9 1128/23 1076/20 1079/15 1110/17 1111/2

named [2] 995/2 new [9] 989/20 1080/2 1081/1 1111/3 1113/6
my... [76] 1010/12
1000/6 1036/21 1042/25 1081/4 1081/14 1119/18 1119/19
1012/9 1013/5
names [2] 1056/3 1043/2 1043/9 1081/24 1082/1 1120/14 1122/5
1013/12 1014/3
1057/6 1043/15 1051/8 1082/11 1082/13 1122/6 1122/7
1014/8 1015/4
NATALIE [1] 1055/19 1106/11 1083/18 1084/21 1122/8 1123/1
1016/18 1016/21
989/18 news [13] 993/16 1084/21 1085/7 1123/4 1124/23
1018/1 1018/19
national [12] 1005/5 1011/21 1089/3 1089/3 1125/2 1126/17
1020/6 1021/15
996/23 1001/4 1055/5 1055/6 1090/10 1091/8 1126/20 1126/21
1021/18 1022/3
1004/12 1023/8 1055/13 1055/17 1092/10 1098/7 1126/22 1126/24
1027/13 1028/19
1023/24 1024/13 1068/9 1069/11 1102/20 1103/20 1127/4 1127/6
1029/15 1030/1
1078/17 1085/11 1070/9 1103/25 1104/17 1106/6 1127/10 1127/10
1030/23 1033/1
1085/25 1086/25 1126/5 1126/7 1111/9 1114/3 1127/13 1127/24
1034/24 1036/12
1087/10 1095/8 next [18] 1005/22 1114/15 1115/5 1128/1 1128/4
1041/12 1045/6
nature [6] 999/15 1006/13 1008/24 1115/23 1116/11 1128/9 1128/10
1045/23 1048/22
1002/16 1015/20 1009/7 1009/12 1117/14 1118/22 1128/13 1128/14
1052/11 1052/21
1017/13 1019/23 1010/1 1011/16 1119/23 1121/2 1128/18 1130/5
1054/24 1055/12
1105/16 1046/22 1047/4 1121/15 1121/22 nothing [5]
1057/12 1057/19
near [1] 995/6 1048/14 1072/19 1122/3 1128/4 1005/8 1022/5
1061/17 1064/8
necessarily [2] 1085/1 1085/16 1129/8 1129/8 1022/7 1049/21
1065/18 1066/5
1024/1 1106/1 1095/5 1096/5 1129/9 1059/20
1067/4 1067/20
necessary [1] 1097/11 1097/12 nobody [3] notion [1] 1086/5
1067/23 1069/10
1020/16 1097/17 1045/4 1059/14 now [39] 992/13
1069/20 1070/7
need [17] 992/22 nice [1] 993/4 1119/2 994/20 997/12
1073/4 1075/19
1015/6 1016/9 night [1] 1129/11 Nodded [3] 1000/1 1003/11
1075/25 1081/15
1023/9 1023/12 no [98] 989/2 993/19 1052/14 1007/19 1009/19
1082/22 1085/18
1023/23 1024/5 994/13 996/18 1083/2 1009/21 1010/11
1085/22 1086/21
1024/10 1024/11 998/11 999/3 non [2] 1017/6 1034/19 1035/7
1092/18 1094/7
1024/13 1049/14 999/9 999/11 1023/1 1037/5 1039/4
1094/17 1094/17
1068/12 1068/14 1002/13 1003/8 non-lawyers [1] 1039/19 1043/24
1101/1 1101/25
1070/7 1109/14 1003/9 1003/9 1017/6 1044/15 1045/7
1104/2 1104/3
1111/4 1121/6 1003/24 1004/7 non-predicated 1050/12 1052/24
1104/7 1107/11
needed [8] 1004/19 1005/8 [1] 1023/1 1057/15 1060/13
1115/11 1116/4
1014/8 1069/18 1005/19 1006/1 noone's [1] 1061/4 1064/12
1118/6 1122/15
1069/19 1069/20 1006/3 1007/7 992/14 1064/25 1066/14
1123/4 1123/12
1072/7 1072/7 1007/9 1007/18 normally [2] 1066/21 1072/5
1123/15 1123/16
1072/8 1111/13 1008/16 1011/8 1060/11 1060/12 1073/9 1075/12
1124/8 1125/3
needs [1] 1011/11 1011/14 Northeast [1] 1078/25 1096/5
1127/7 1127/21
1020/23 1016/8 1017/2 989/14 1099/13 1114/18
1128/17 1130/5
nefarious [1] 1017/3 1018/15 not [165] 1117/20 1120/20
1130/7
1025/6 1018/19 1025/13 note [1] 1107/20 1123/9 1123/21
myself [3]
negativity [1] 1026/10 1027/19 notes [58] 1126/16 1127/7
1051/16 1060/7
1088/19 1028/3 1028/15 1047/13 1047/16 number [18]
1082/4
neuroscientist [1] 1034/11 1036/17 1055/8 1057/16 1000/24 1000/25
N 1112/3 1040/14 1041/5 1057/17 1057/22 1001/24 1026/12
name [19] 1000/1 Neustar [10] 1042/18 1042/21 1057/25 1058/1 1032/15 1051/5
1016/6 1041/22 1000/6 1000/6 1043/17 1043/20 1066/21 1067/12 1053/11 1073/3
1041/24 1060/1 1000/11 1000/23 1055/21 1056/3 1068/3 1072/14 1074/8 1074/16
1060/16 1060/17 1001/3 1001/24 1057/19 1059/11 1080/25 1081/3 1075/10 1077/5
1061/14 1063/22 1002/20 1011/13 1061/24 1062/5 1081/3 1081/5 1078/1 1079/5
1064/10 1068/9 1016/16 1016/17 1062/5 1064/14 1082/14 1093/18 1082/12 1101/8
1070/8 1073/10 never [7] 1026/3 1064/20 1064/21 1108/8 1108/15 1102/11 1107/10
1074/22 1075/6 1029/18 1071/9 1065/6 1068/5 1108/19 1110/5 NW [1] 989/24
1075/16 1076/7 1071/24 1082/19 1072/12 1074/7 1110/9 1110/15 NY [1] 989/20
1152
N 1089/3 1089/4 1056/11 1056/19 1076/12 1084/14 1091/3 1098/8

offer [2] 1035/14 1060/19 1064/8 open [7] 993/11 1101/20 1108/13
NYT [1] 1080/15
1084/17 1066/14 1074/9 1015/5 1024/8 1109/21 1110/2
O offers [1] 994/10 1076/13 1079/12 1024/22 1032/25 1110/8 1110/10
o'clock [1] office [15] 989/13 1081/20 1083/7 1038/12 1089/18 1111/1 1117/21
1129/12 996/14 1015/23 1084/5 1085/1 opponent [2] 1121/9 1127/12
oath [9] 1039/13 1020/7 1020/14 1085/2 1087/8 1021/6 1024/20 others [11]
1083/10 1083/11 1025/11 1032/19 1097/11 1099/5 opportunity [1] 1000/10 1015/22
1099/14 1099/17 1038/5 1076/1 1099/20 1100/16 1028/21 1017/4 1020/16
1100/5 1104/12 1077/14 1077/16 1100/17 1100/22 opposite [1] 1038/9 1038/15
1128/21 1129/2 1077/17 1078/9 1100/25 1105/7 1109/21 1039/7 1039/8
object [1] 1094/17 1111/14 1108/11 1108/24 order [5] 993/7 1076/9 1080/14
1029/22 Official [2] 989/23 1109/1 1109/3 1023/4 1024/2 1089/5
objection [10] 1130/3 1109/4 1112/24 1024/8 1070/8 otherwise [1]
994/13 1027/19 officials [3] 1113/20 1116/9 orderly [3] 1022/1
1028/23 1034/11 1001/24 1002/8 1116/12 1116/18 1092/24 1093/1 our [13] 991/13
1036/16 1036/17 1110/11 1117/6 1117/22 1093/1 993/15 1015/1
1053/1 1065/6 often [1] 1017/1 1118/4 1120/21 ordinarily [1] 1018/7 1021/25
1076/20 1079/15 OGC [1] 1078/9 1129/21 1051/22 1058/6 1064/17
obligation [1] Oh [6] 1007/5 old [1] 1012/21 org [1] 1012/19 1064/19 1066/14
1004/1 1009/23 1012/24 oligarch [1] organization [14] 1076/24 1086/18
obtained [5] 1052/24 1104/3 1080/11 1000/6 1055/5 1100/2 1106/16
995/18 995/20 1112/14 once [2] 1041/10 1055/6 1055/13 out [37] 993/12
1018/3 1018/16 Ohio [1] 995/3 1059/3 1055/17 1068/10 993/17 996/1
1019/7 OIG [1] 1032/21 one [45] 993/25 1069/11 1070/9 1006/22 1006/23
obviously [11] okay [95] 991/12 994/8 994/11 1080/12 1101/11 1009/5 1010/23
991/7 992/2 992/20 992/21 996/17 1002/14 1101/17 1121/12 1012/17 1012/25
1003/18 1007/15 993/3 993/10 1002/23 1005/6 1126/6 1126/7 1019/5 1033/18
1097/24 1102/25 994/2 995/5 995/7 1005/8 1007/25 organizer [1] 1035/14 1036/7
1103/16 1103/23 995/11 995/16 1013/20 1024/25 1078/11 1036/22 1041/3
1115/9 1122/22 997/12 998/22 1031/12 1031/14 orient [4] 1047/12 1045/7 1051/9
1129/16 999/13 999/25 1031/15 1031/17 1087/17 1105/10 1051/18 1052/10
occasion [2] 1003/5 1005/21 1044/6 1044/12 1120/12 1063/25 1065/24
1031/13 1060/18 1006/13 1010/8 1047/24 1047/25 original [1] 1066/7 1066/11
occasions [2] 1012/13 1012/18 1049/4 1055/13 1118/24 1066/13 1068/9
1028/7 1032/15 1012/23 1024/25 1055/14 1057/15 originally [1] 1068/13 1073/21
occur [3] 1044/16 1025/2 1026/11 1059/22 1060/18 1073/9 1079/18 1080/3
1045/2 1045/3 1026/13 1026/14 1060/20 1061/1 originating [1] 1088/6 1092/3
occurred [1] 1026/18 1027/10 1063/8 1063/12 1064/7 1098/2 1101/2
1124/7 1027/14 1034/8 1064/9 1066/2 origins [1] 1124/2 1101/6 1101/25
October [16] 1035/2 1035/6 1070/11 1070/12 other [39] 997/25 1107/25 1118/11
994/6 994/9 1038/22 1039/16 1070/19 1072/3 998/1 998/7 outcome [1]
1082/24 1087/15 1039/19 1040/25 1073/1 1073/2 999/21 1001/12 1003/5
1087/18 1087/22 1041/15 1045/7 1096/14 1097/12 1001/14 1002/8 outset [1]
1089/13 1089/23 1045/13 1046/18 1104/15 1108/19 1003/9 1007/14 1120/22
1090/16 1090/20 1048/6 1048/8 1113/17 1113/18 1014/10 1017/12 outside [1]
1090/24 1096/2 1049/6 1049/10 1119/20 1126/7 1031/15 1037/13 1081/13
1096/9 1096/25 1049/25 1050/12 one-minute [2] 1042/13 1042/25 over [23] 993/6
1104/22 1120/14 1051/22 1052/2 1072/3 1073/1 1043/15 1054/9 1006/25 1012/2
off [7] 992/11 1052/21 1052/24 ones [2] 1020/6 1059/22 1064/9 1026/8 1026/24
1004/14 1038/19 1053/11 1054/6 1117/21 1066/3 1067/22 1032/11 1037/12
1038/20 1041/16 1054/11 1054/20 ongoing [1] 1069/15 1070/11 1041/13 1042/10
1043/8 1061/5 1055/12 1055/16 1090/5 1070/13 1084/23 1044/2 1067/14
offenses [2] 1055/22 1056/6 only [3] 1024/5 1088/10 1091/2 1067/17 1071/8
1153
O part [26] 995/1 1012/3 1031/7 persons [2] 998/17 1001/11

997/13 998/7 1031/10 1044/18 1024/15 1069/21 1004/6 1006/9
over... [10]
1001/6 1001/22 1055/16 1056/9 perspective [1] 1014/24 1016/15
1071/17 1077/14
1007/2 1008/7 1063/10 1063/15 1037/8 1017/19 1050/15
1081/17 1086/21
1008/9 1015/23 1064/3 1064/14 pertaining [1] 1053/17 1054/8
1089/14 1090/23
1018/25 1020/1 1076/5 1077/21 1049/2 1057/9 1062/23
1100/11 1100/23
1027/3 1038/2 1087/18 1088/16 Pete [6] 1061/12 1076/14 1077/25
1110/3 1111/24
1038/8 1039/5 1101/8 1102/12 1061/19 1062/25 1078/15 1088/25
Overruled [1]
1046/24 1059/13 1103/14 1107/10 1067/6 1067/7 1089/11 1091/1
1053/3
1067/12 1077/16 1114/25 1119/1 1094/14 1095/2
oversight [2]
1077/17 1101/11 people's [1] phone [16] 1103/21 1104/25
1038/6 1077/14
1111/3 1115/11 1110/9 992/19 1000/24 1106/14 1106/18
own [7] 1023/16
1117/17 1121/25 percent [9] 1000/25 1044/19 1106/21 1107/23
1025/15 1045/20
1128/8 1042/6 1053/9 1067/5 1067/15 1110/19 1112/24
1046/10 1046/21
participated [1] 1057/22 1070/25 1067/17 1067/20 1117/7 1118/9
1047/3 1048/12
1050/1 1071/3 1071/3 1067/24 1069/1 1119/8 1119/19
P particular [20] 1071/4 1123/10 1069/16 1069/20 1122/23 1124/11
p.m [6] 989/4 996/6 998/4 1123/18 1074/5 1111/16 1124/20 1125/2
1005/25 1006/16 1000/17 1002/24 percentage [1] 1111/18 1122/11 1127/7
1011/19 1068/24 1015/25 1052/22 1070/23 physical [1] points [1]
1129/23 1053/7 1055/25 perhaps [1] 1101/5 1067/19
page [37] 990/2 1057/13 1060/9 1018/22 piece [5] 1033/23 political [10]
990/10 990/13 1092/7 1093/12 period [12] 1035/6 1097/14 1020/19 1021/23
992/23 994/7 1093/16 1118/9 1008/7 1014/23 1126/10 1127/14 1023/17 1024/20
994/17 997/13 1121/22 1122/21 1042/10 1042/14 pieces [1] 1025/2 1025/12
1005/22 1006/13 1122/22 1123/11 1043/25 1044/17 1067/22 1025/16 1086/15
1008/24 1009/3 1123/13 1124/20 1066/14 1071/8 place [11] 1087/9 1098/8
1009/7 1009/9 particularly [3] 1071/17 1086/13 1010/15 1010/16 politics [1]
1009/12 1009/14 1052/12 1103/20 1096/18 1114/14 1030/8 1030/11 1021/19
1010/1 1011/16 1105/23 perjury [5] 1031/15 1055/10 portability [2]
1012/11 1034/3 parties [1] 993/6 1090/20 1091/13 1067/2 1067/3 1000/25 1000/25
1034/4 1038/25 partisan [1] 1091/14 1128/22 1067/5 1103/23 portfolio [1]
1068/21 1079/25 1086/8 1129/2 1107/13 1078/17
1080/4 1083/25 partner [1] Perkins [11] placing [1] portion [1]
1085/17 1089/21 1098/24 1006/18 1013/10 1110/3 1036/8
1091/19 1091/20 parts [1] 1001/14 1013/11 1054/2 Plaintiff [1] 989/3 portions [1]
1099/21 1099/22 passing [2] 1054/9 1087/19 planning [1] 1076/10
1100/1 1100/12 1002/12 1005/7 1096/17 1097/5 1069/12 position [2] 997/5
1113/12 1115/15 past [3] 1031/24 1098/4 1098/24 plans [2] 992/14 1095/17
1115/16 1117/16 1032/11 1038/19 1099/8 1009/8 possibilities [1]
pages [1] 994/11 patience [1] person [18] played [2] 993/11
papers [3] 1040/8 1129/7 1019/12 1019/13 1021/19 1021/24 possibility [2]
1040/12 1061/12 pause [5] 1021/5 1024/15 pleasantries [1] 992/11 1087/25
paragraph [13] 1034/20 1048/7 1025/7 1039/23 1008/21 possible [9]
1047/21 1047/22 1096/22 1109/2 1045/14 1052/19 please [4] 993/2 993/13 997/9
1048/1 1048/5 1115/20 1061/18 1061/20 1012/8 1027/16 1040/18 1041/13
1097/25 1107/17 pausing [1] 1063/8 1067/9 1036/24 1041/14 1067/10
1113/11 1113/13 995/13 1067/15 1069/21 pleased [1] 1070/6 1095/21
1113/14 1115/7 payoff [1] 1025/2 1077/5 1077/13 1028/12 1104/14
1115/15 1117/9 Pennsylvania [1] 1077/20 1125/16 plot [2] 1007/2 possibly [2]
1117/16 1058/7 person's [2] 1052/10 1081/14 1124/13
paraphrasing [1] people [23] 1019/24 1020/12 plus [1] 1080/12 potential [2]
1053/6 991/10 1004/18 personal [2] point [40] 996/10 1051/9 1075/7
pardon [1] 1012/1 1008/10 1011/25 1043/17 1043/20 997/14 998/8 potentially [1]
1154
P previously [2] 1020/1 pun [1] 1117/14 1030/7 1051/6

1098/5 1128/21 proposal [1] purpose [2] 1084/3 1089/15
potentially... [1]
Priestap [21] 991/13 1023/23 1109/8 1091/13 1091/23
1018/8
1041/16 1043/7 prosecuted [3] purposes [3] 1092/21 1093/16
predicated [3]
1058/12 1059/19 1030/25 1104/11 1036/5 1055/23 1094/6 1094/7
1023/1 1023/2
1066/17 1067/3 1129/3 1077/18 1095/23 1103/1
1024/2
1067/14 1067/25 prosecution [5] pursue [1] 1106/15 1116/14
predication [2]
1068/6 1076/6 1026/6 1026/16 1022/18 1116/19 1123/3
1022/25 1024/1
1093/18 1101/23 1046/16 1091/17 put [6] 991/13 1127/6 1128/16
predict [1] 993/14
1101/24 1119/18 1094/5 1027/15 1037/8 quickly [10] 997/8
preliminaries [1]
1126/17 1126/20 prosecutor [3] 1038/25 1047/17 1010/16 1010/17
1100/2
1126/25 1127/2 1003/3 1090/11 1127/22 1025/24 1040/12
preliminary [5]
1127/12 1127/24 1125/16 Putin [1] 1080/11 1040/17 1041/13
1022/12 1023/2
1127/25 protect [1] 1041/14 1067/10
1024/3 1024/5
Priestap's [9] 1086/19 Q 1095/21
1024/8 quarter [1]
1081/3 1110/5 protected [2] quite [4] 992/2
premarked [1] 1064/22
1110/15 1122/7 1017/23 1020/3 1002/13 1006/8
994/3 question [40]
1123/1 1124/23 protecting [1] 1056/20
preparation [1] 995/11 995/12
1126/22 1127/13 1086/13
1049/7
1128/9 provide [7] 995/17 998/15 R
prepare [2] 998/21 999/5 raise [2] 992/13
printed [1] 1101/6 1023/6 1046/3
1028/11 1091/6 999/12 999/16 1001/4
prior [8] 997/12 1069/11 1084/6
prepared [1] 1024/17 1031/21 raised [3] 1018/9
1003/19 1003/19 1085/2 1087/2
1084/24 1038/23 1039/2 1021/14 1021/20
1003/23 1059/18 1087/11
preparing [1] 1039/9 1047/5 raising [1]
1100/3 1121/4 provided [11]
1055/7 1048/8 1048/25 1002/16
1127/18 1006/18 1074/22
presence [1] 1051/17 1057/17 ran [3] 1008/5
prioritize [1] 1075/15 1093/17
1062/21 1064/8 1066/10 1025/22 1026/1
1014/5 1100/20 1114/13
present [3] 1069/20 1084/11 range [1] 1017/20
probably [11] 1118/1 1118/24
1047/13 1089/23 1085/1 1085/13 ranking [2]
991/20 993/13 1121/10 1125/5
1128/11 1085/16 1085/24 1077/13 1077/19
1010/22 1055/16 1125/11
presented [5] 1086/9 1087/5 RAO [1] 989/18
1058/12 1058/19 providing [6]
1014/9 1016/19 1090/3 1092/15 reach [3] 1036/22
1082/7 1082/8 1025/7 1055/3
1018/16 1062/21 1092/17 1095/5 1068/9 1073/15
1097/9 1110/20 1056/25 1082/4
1101/20 1103/21 1104/8 reached [4]
1127/10 1085/8 1087/9
presenting [1] 1107/18 1111/23 992/18 1035/14
probing [1] provisions [2]
1062/1 1113/20 1118/5 1045/7 1101/2
1128/17 1105/18 1109/14
president [2] 1118/6 1121/19 react [1] 1085/3
problem [1] public [5]
1006/6 1006/12 questioned [4] reaction [1]
996/18 1006/22 1006/23
presidential [1] 1002/22 1082/24 1005/11
problematic [1] 1012/14 1013/9
1021/7 1100/13 1103/24 read [27] 995/1
1018/9 1081/7
press [5] 1021/21 questioning [5] 1020/22 1027/23
proceed [1] publicly [3]
1022/1 1022/3 1039/17 1072/15 1033/20 1047/22
1038/20 1015/1 1015/2
1022/3 1088/9 1084/24 1091/3 1047/25 1048/2
proceedings [2] 1098/5
pressing [1] 1128/14 1048/5 1080/7
1129/23 1130/6 publish [3]
1002/11 questions [34] 1081/8 1081/13
professional [1] 1055/7 1062/15
pressures [1] 997/11 1004/3 1091/23 1097/3
1117/2 1069/12
1088/10 1017/9 1018/10 1097/6 1097/19
promulgated [1] published [1]
presumed [1] 1019/5 1021/15 1098/11 1099/9
1022/21 1062/17
1019/6 1027/2 1027/4 1099/11 1107/17
pronounced [2] pull [5] 1062/11
pretty [5] 1042/7 1027/6 1027/7 1108/25 1109/3
1036/12 1056/4 1072/22 1099/21
1042/8 1057/20 1027/9 1029/20 1112/15 1113/2
Proper [1] 1115/12 1117/13
1077/4 1092/22 1029/22 1029/23 1115/18 1115/21
1009/24 pulled [1]
previous [1] 1030/3 1030/5 1117/18 1117/20
properly [1] 1021/19
1124/14
1155
R 1056/17 1056/21 1046/16 1065/3 991/16 1112/18 1022/5 1022/6

1094/8 1111/12 1072/21 1118/23 1113/24 1121/11 1047/14 1047/17
reading [6]
1124/10 records [2] reiterating [1] 1089/3 1089/5
1011/19 1033/24
receive [3] 1074/5 1122/15 1122/10 1089/5 1108/14
1085/22 1097/8
1016/25 1018/4 recovered [1] related [11] 991/9 1108/18 1108/21
1098/12 1113/7
1043/13 1044/8 1004/4 1015/24 1108/22
reads [1] 1036/21
received [3] recreating [1] 1016/3 1016/17 reporter [12]
ready [1] 1065/10
1002/7 1039/23 1067/18 1017/22 1020/5 989/23 989/23
realistically [1]
1112/6 recuse [1] 1021/8 1076/15 1029/13 1030/18
991/20
receiving [2] 1077/11 1079/6 1101/7 1031/14 1041/22
realize [1] 1104/9
1021/1 1021/3 recused [1] relating [1] 1041/25 1053/2
realized [1]
recent [1] 1077/10 1004/4 1072/8 1074/22
1041/10
1026/21 redactions [1] relationship [2] 1126/8 1130/3
really [12]
recess [2] 1065/1 1108/13 1019/22 1127/18 represent [3]
1005/19 1011/25
1065/2 refer [1] 1019/20 relative [3] 1013/11 1108/4
1012/3 1012/5
recognize [3] reference [8] 1032/19 1052/18 1126/16
1019/1 1020/9
1003/18 1034/7 995/23 1005/16 1075/1 representation [2]
1040/14 1053/19
1080/1 1008/2 1008/4 relatively [2] 997/18 1127/22
1073/6 1084/24
recognizing [1] 1016/2 1055/9 1069/12 1097/5 represented [10]
1119/23 1122/3
1126/24 1110/16 1110/18 relayed [1] 997/22 997/24
reappointed [1]
recollection [51] referenced [2] 1108/16 997/24 998/1
1033/3
995/21 999/11 1067/23 1081/7 release [1] 1031/4 999/19 999/21
reason [6] 999/4
1000/10 1001/2 referred [5] released [1] 1013/10 1054/3
1020/11 1039/22
1001/23 1001/25 1006/21 1015/10 1061/10 1054/8 1054/9
1046/5 1060/6
1004/3 1005/14 1016/4 1020/13 relevant [2] representing [30]
1118/16
1006/1 1008/2 1089/6 1024/16 1044/15 995/25 996/8
reasonably [2]
1008/11 1015/4 referring [2] reliability [3] 996/22 998/6
1023/7 1024/12
1028/7 1029/15 997/17 1083/1 1014/1 1021/5 998/9 998/14
reasons [3]
1031/8 1044/2 refers [2] 1006/10 1025/8 998/18 999/8
1044/12 1057/15
1045/6 1047/9 1006/11 reliable [1] 1002/20 1053/12
1125/11
1048/3 1048/9 reflect [1] 998/8 1023/5 1084/7 1091/21
recall [43]
1057/12 1057/19 reflected [1] relinquished [1] 1092/1 1094/11
1000/14 1001/10
1061/17 1066/24 1127/13 1067/6 1095/2 1095/7
1003/2 1005/19
1069/10 1074/19 refresh [11] remember [162] 1109/20 1110/2
1010/21 1011/11
1075/19 1078/25 1047/9 1048/9 remembered [3] 1110/11 1110/25
1031/10 1031/13
1079/4 1081/2 1082/15 1105/24 1071/23 1084/21 1112/18 1112/19
1045/1 1047/7
1081/15 1081/17 1107/12 1107/16 1093/19 1112/21 1113/18
1048/15 1050/7
1082/15 1082/22 1109/4 1113/9 remembering [2] 1113/24 1113/25
1057/1 1057/2
1092/8 1093/8 1115/6 1115/22 1070/4 1093/11 1114/1 1122/17
1057/6 1057/14
1101/1 1105/24 1117/8 remind [2] 1124/14 1124/18
1057/24 1058/1
1107/11 1107/12 refreshed [3] 1109/13 1117/9 Republican [1]
1060/20 1071/13
1107/16 1109/4 1066/24 1081/2 reminded [1] 1086/6
1071/24 1075/20
1109/19 1110/23 1111/4 1073/18 request [3]
1076/13 1080/17
1111/4 1113/10 refreshes [1] reminding [1] 1028/9 1028/16
1080/20 1080/21
1115/6 1115/22 1048/3 1109/14 1105/17
1080/24 1082/4
1117/8 1124/24 refuse [1] 1030/6 reopen [1] 1015/5 requested [3]
1082/21 1083/23
1128/11 refused [6] repeat [3] 1027/11 1066/6
1084/9 1084/9
recollections [2] 1029/19 1030/3 1046/24 1052/3 1122/11
1084/15 1099/11
1031/17 1049/10 1030/5 1062/2 1125/8 requesting [1]
1101/9 1114/10
recommendation 1089/14 1089/15 repeated [4] 1065/23
1115/1 1117/24
[1] 1004/7 regard [3] 1006/24 1006/24 require [1]
1117/25 1118/3
reconvene [1] 1000/14 1007/8 1006/25 1128/16 1038/18
1118/4 1118/7
1064/21 1086/14 report [13] research [2]
1121/24
record [5] 1013/9 regarding [4] 1022/1 1022/4 1064/21 1129/8
recalled [5]
1156
R 1022/5 1023/22 round [1] 1085/23 1069/18 1070/7 1042/2 1045/23

1026/2 1026/23 route [1] 1022/18 1071/9 1071/11 1049/14 1049/21
researchers [5]
1027/2 1027/6 RPR [1] 989/23 1073/2 1073/11 1050/11 1051/6
1018/24 1123/22
1029/3 1029/25 rubric [1] 1023/19 1073/13 1074/2 1055/5 1059/4
1123/24 1123/25
1030/22 1030/24 ruined [1] 1078/25 1084/23 1064/12 1066/1
1125/24
1031/18 1032/6 1030/22 1089/16 1092/14 1069/9 1069/9
reservation [2]
1033/14 1035/9 rules [1] 1020/2 1092/19 1093/11 1069/17 1070/14
1009/15 1010/17
1035/19 1037/16 run [2] 1038/6 1094/14 1101/7 1071/15 1077/19
respect [15]
1038/7 1038/9 1076/5 1102/15 1102/23 1079/21 1080/20
1013/20 1014/23
1038/15 1040/18 running [2] 1102/23 1103/3 1084/18 1090/14
1022/9 1027/13
1040/23 1042/5 1001/5 1005/5 1103/18 1103/22 1092/10 1092/11
1028/18 1032/17
1044/15 1045/22 Russia [15] 1104/12 1104/12 1092/13 1098/14
1038/6 1072/10
1046/14 1047/12 999/23 999/24 1104/14 1105/7 1098/16 1102/2
1078/21 1080/18
1047/19 1051/10 1004/5 1016/3 1105/20 1109/21 1111/2 1113/2
1094/2 1098/22
1051/24 1054/11 1016/3 1016/7 1111/8 1111/13 1116/18 1122/17
1111/11 1113/17
1056/15 1057/22 1051/10 1051/19 1112/1 1112/19 1122/24 1126/20
1123/17
1058/3 1058/17 1075/1 1075/7 1112/25 1113/8 1127/4 1128/2
respond [5] 997/2
1058/23 1059/7 1076/11 1077/11 1113/10 1113/25 saying [35] 996/5
999/11 1012/6
1060/13 1063/9 1080/22 1081/22 1114/3 1114/16 998/3 1005/5
1012/24 1095/14
1063/13 1063/14 1106/16 1114/22 1114/24 1018/17 1032/3
response [3]
1063/17 1064/12 Russian [2] 1115/24 1122/15 1035/18 1053/19
995/17 999/12
1064/15 1064/19 1080/10 1080/11 1122/16 1122/19 1053/22 1053/23
1083/18
1066/5 1066/9 Russians [1] 1123/17 1123/18 1057/2 1057/4
responsibility [2]
1069/5 1071/18 1079/23 1123/24 1124/17 1057/5 1057/6
1038/13 1038/15
1073/12 1074/13 Rybicki [2] 1125/15 1126/8 1058/18 1070/10
responsible [2]
1074/17 1077/8 1076/6 1078/4 1126/25 1127/1 1070/14 1070/17
1020/12 1086/12
1078/2 1078/3 1127/9 1127/11 1071/13 1073/15
rest [1] 1007/23
1082/23 1088/6 S 1128/12 1128/22 1080/17 1080/21
result [2] 1003/23
1088/10 1088/17 said [108] 992/10 1129/1 1081/24 1084/10
1043/11 995/20 996/10
1092/23 1093/2 same [17] 992/23 1084/15 1092/6
return [1] 996/11 997/15
1093/14 1096/11 1005/6 1006/4 1098/20 1104/11
1004/20 998/13 998/17
1097/17 1106/5 1006/11 1012/14 1108/10 1115/5
Reveals [1] 999/15 999/18
1111/19 1114/2 1016/14 1020/11 1118/15 1121/3
1006/18 1002/6 1010/24
1114/18 1116/14 1021/1 1023/22 1121/24 1123/9
reversed [1]
1116/16 1116/20 1014/13 1014/16 1024/22 1028/8 1127/16 1128/5
1001/15 1015/6 1016/3
1116/24 1117/4 1031/8 1055/6 says [31] 995/25
review [10] 1016/8 1017/4
1126/9 1127/7 1083/5 1088/18 996/24 998/5
1014/9 1017/15 1020/21 1021/23
1129/5 1129/10 1089/20 1091/23 1005/25 1009/16
1036/2 1040/11
1129/14 1129/21 1022/6 1024/19 saw [8] 1007/22 1010/9 1012/13
1040/13 1081/15
ring [1] 1061/23 1025/15 1027/3 1057/8 1106/7 1012/18 1028/4
1086/4 1105/16 1027/4 1027/5
Rodney [7] 1112/13 1122/8 1061/10 1076/25
1126/3 1126/17 1027/8 1031/24
1000/2 1000/4 1123/1 1125/1 1079/21 1079/23
reviewed [3] 1032/5 1036/1
1007/23 1008/2 1127/11 1080/8 1080/10
1126/19 1126/21 1038/4 1038/16
1008/4 1008/5 say [55] 995/6 1080/13 1090/1
1126/22 1044/11 1044/25 995/6 998/12
1016/13 1090/2 1095/9
rid [3] 1040/17 1045/8 1045/24
role [3] 1039/4 998/19 999/2 1097/14 1097/15
1041/13 1067/10 1050/15 1051/11
1039/24 1077/4 999/7 999/10 1097/18 1098/4
right [93] 991/23
room [4] 989/24 1052/21 1053/19 999/12 1000/9 1100/2 1100/9
992/7 992/24
1052/16 1107/10 1053/22 1055/2 1002/14 1004/18 1100/17 1109/11
993/18 998/24 1055/6 1060/6
1107/10 1004/22 1007/5 1109/16 1118/19
1005/18 1007/20
rough [1] 1012/25 1062/6 1065/23 1009/24 1018/14 1118/21 1126/19
1008/23 1009/7 1066/7 1066/8
roughly [3] 1018/19 1021/10 scenario [1]
1009/12 1009/25 1066/9 1067/6
1029/15 1087/21 1028/20 1029/19 1051/18
1012/11 1013/3 1068/7 1068/12
1096/18 1030/10 1031/10 scenarios [2]
1018/11 1022/2
1157
S 1015/13 1034/19 sentence [2] 1003/22 significant [2]

1034/21 1034/23 1102/6 1117/20 shape [3] 1002/2 1128/8
scenarios... [2]
1034/25 1041/21 separate [2] 1025/23 1101/2 signing [2]
1016/20 1022/10
1047/9 1052/13 1002/7 1108/21 1102/21 1038/20 1064/4
schedule [1]
1055/14 1067/8 September [27] SHAW [1] 989/13 similar [1] 1055/7
993/17
1073/1 1074/7 1008/15 1010/21 she [4] 1078/14 simple [1] 1064/8
scheduled [1]
1076/25 1078/4 1011/1 1011/6 1078/15 1099/23 Sincerely [1]
1101/3
1080/15 1098/9 1013/13 1014/24 1100/2 1028/13
schedules [1]
1105/24 1107/12 1032/8 1037/10 short [5] 992/2 sir [116] 995/6
993/9
1111/2 1111/13 1040/1 1040/3 1040/23 1054/22 995/8 1026/3
scheduling [2]
1113/9 1113/19 1044/6 1050/12 1054/23 1097/5 1027/11 1027/23
991/3 993/6
1115/6 1115/13 1052/1 1052/5 shorthand [3] 1028/14 1029/10
scope [1]
1117/8 1129/11 1052/6 1052/19 1103/4 1103/7 1031/2 1031/20
1017/13
1129/21 1053/11 1053/14 1103/13 1032/25 1033/2
screen [1]
seeing [5] 991/10 1054/15 1056/23 shortly [3] 996/15 1033/21 1034/1
1034/19
1081/5 1082/14 1068/16 1070/2 1094/19 1102/2 1035/21 1037/18
screenshot [1]
1110/8 1128/4 1071/19 1075/14 should [13] 1037/20 1039/19
1006/6
seem [3] 1085/11 1093/22 1110/7 1012/1 1012/21 1040/13 1040/22
scrolling [2]
1112/20 1113/25 1120/12 1014/5 1015/8 1043/17 1044/16
1045/1 1045/2
seems [1] 1103/9 series [2] 1009/2 1015/9 1015/11 1045/22 1047/10
scrutiny [1]
seen [10] 1005/7 1012/12 1015/13 1017/11 1047/23 1048/8
1021/13
1006/9 1039/11 serious [2] 1017/11 1017/12 1049/22 1049/25
SEAN [2] 989/17
1047/11 1057/10 1002/17 1021/14 1020/6 1082/10 1050/5 1053/8
1028/13
1066/21 1081/7 seriously [1] 1086/6 1053/10 1055/1
seared [1]
1091/24 1104/19 1002/17 shouldn't [1] 1057/18 1058/21
1093/25
1124/23 server [4] 1080/8 1015/7 1059/23 1060/1
seat [1] 1065/12
sees [2] 1020/23 1080/9 1080/12 show [8] 993/25 1060/13 1062/19
seated [1] 993/2
1020/23 1080/18 994/3 1028/14 1065/14 1066/1
second [9] 994/7
Senate [1] server-late [1] 1073/14 1079/12 1066/10 1066/11
994/8 994/24
1120/25 1080/8 1111/6 1113/7 1066/13 1066/18
996/17 1038/16
send [3] 1012/21 servers [1] 1115/8 1066/20 1066/23
1061/9 1068/21
1098/13 1098/19 1121/11 showed [11] 1066/25 1070/6
1077/23 1096/15
sends [5] 1006/5 services [1] 996/13 1059/3 1070/19 1071/11
second-to-last [1]
1012/18 1096/5 1000/24 1063/1 1063/10 1072/17 1074/18
1068/21
1097/5 1097/14 services/activities 1065/22 1066/6 1074/24 1075/3
secondly [1]
senior [3] [1] 1000/24 1094/17 1098/1 1075/5 1075/19
1004/2
1034/16 1077/4 session [2] 989/5 1104/13 1111/5 1077/1 1077/12
Secretary [1]
1077/21 1117/23 1119/19 1078/3 1078/8
1014/22
sense [6] 1083/6 Sessions [1] showing [3] 1078/13 1079/2
Section [1]
1089/12 1108/17 1077/8 1047/24 1116/13 1079/11 1079/22
1105/19
1113/2 1125/7 set [6] 1000/17 1122/5 1080/15 1080/20
sections [1]
1126/12 1026/1 1061/1 shown [4] 1080/25 1081/6
993/14
sensitive [7] 1085/19 1116/6 1047/25 1080/25 1081/19 1081/20
secure [2] 1020/3
1045/8 1045/8 1125/3 1081/3 1117/9 1082/3 1083/16
1116/7
1045/25 1045/25 settings [1] shows [2] 996/23 1083/20 1084/3
security [12]
1046/6 1046/6 1103/24 1095/8 1084/11 1084/13
1001/4 1004/13
1060/8 Seventy [1] sic [3] 1010/3 1085/13 1085/15
1020/12 1023/9
sensitivity [1] 1071/3 1056/3 1120/13 1087/7 1087/8
1023/24 1024/13
1051/24 Seventy-five [1] sign [2] 1038/18 1087/14 1087/21
1032/3 1078/17
sent [9] 1012/19 1071/3 1063/16 1089/25 1090/18
1085/11 1087/1
1012/20 1065/22 several [4] signed [5] 1090/22 1091/7
1087/11 1089/6
1089/8 1096/25 1007/20 1037/2 1004/14 1061/6 1091/25 1092/9
see [32] 997/19
1097/22 1098/16 1121/18 1125/11 1061/10 1062/10 1093/2 1093/3
1009/14 1009/21
1099/10 1101/24 shade [1] 1063/12 1094/25 1094/25
1009/24 1010/11
1158
S 1064/6 1068/7 1112/11 1129/1 992/5 1005/9 stand [2] 1064/25

1069/19 1071/17 sometime [3] 1005/16 1031/11 1065/11
sir... [25] 1095/4
1072/10 1076/14 1012/5 1061/18 1040/6 1042/22 standing [2]
1096/1 1096/4
1076/14 1079/5 1105/2 1073/5 1074/4 1081/24 1112/14
1098/22 1099/1
1083/4 1085/10 sometimes [5] 1075/16 1105/8 start [10] 995/5
1099/13 1102/13
1094/14 1095/11 993/13 1018/11 speaking [6] 1012/1 1012/2
1103/6 1104/9
1100/10 1101/1 1019/21 1070/15 1013/4 1019/19 1026/2 1052/16
1104/16 1104/18
1101/5 1101/8 1121/5 1046/14 1058/2 1085/22 1089/21
1105/9 1106/25
1101/10 1101/11 somewhat [1] 1067/20 1106/2 1091/20 1100/11
1107/5 1108/4
1104/25 1106/14 1085/24 special [9] 989/13 1104/12
1111/22 1111/25
1106/18 1106/21 somewhere [2] 1003/11 1028/6 started [6] 993/5
1113/20 1114/2
1109/17 1110/12 1010/17 1010/18 1033/3 1035/24 1004/3 1066/5
1115/21 1119/6
1112/5 1117/7 soon [4] 1013/2 1037/23 1061/22 1093/13 1093/15
1123/20 1128/20
1119/11 1119/19 1055/8 1055/9 1093/13 1109/6 1122/24
1128/25 1129/14
1122/22 1124/11 1069/13 specific [7] starts [1] 1012/13
sitting [24]
1124/20 1125/2 sorry [32] 998/15 1001/18 1021/2 state [2] 1014/22
1005/14 1005/20
1125/13 1126/13 998/16 998/20 1023/18 1093/16 1094/23
1008/12 1047/7
1127/20 999/11 1009/23 1123/3 1128/14 stated [5] 1046/9
1048/15 1052/17
somebody [23] 1009/23 1012/1 1128/16 1046/20 1047/2
1053/16 1057/1
1010/24 1013/22 1012/24 1012/24 specifically [28] 1048/11 1098/5
1057/5 1057/12
1023/15 1025/1 1024/17 1034/19 996/5 996/11 statement [5]
1060/21 1063/5
1025/4 1033/20 1034/24 1035/2 997/15 998/3 1032/1 1048/15
1064/12 1070/3
1041/16 1041/17 1046/25 1047/5 999/7 999/10 1050/10 1091/16
1082/21 1099/11
1050/20 1061/6 1052/3 1052/4 1001/21 1011/1 1091/18
1110/5 1114/20
1061/15 1061/19 1060/15 1061/5 1046/9 1046/20 statements [5]
1115/1 1118/6
1061/25 1062/21 1066/10 1071/20 1047/2 1048/12 1041/5 1050/2
1123/12 1123/16
1063/3 1063/16 1072/7 1072/21 1063/7 1063/24 1083/12 1091/14
1127/7 1128/11
1064/10 1069/18 1096/11 1097/11 1064/13 1076/3 1109/15
situation [3]
1082/14 1093/11 1104/22 1109/1 1084/6 1084/10 STATES [5] 989/1
1039/25 1050/5
1099/2 1101/24 1109/23 1118/4 1084/15 1092/6 989/2 989/9
1051/21
1104/9 1123/23 1124/25 1092/10 1094/15 989/12 1017/24
slow [1] 1018/11
somehow [4] 1125/7 1104/8 1109/11 status [1]
small [1] 1034/24
1006/23 1007/2 sort [4] 993/11 1110/13 1114/3 1076/10
smooth [1]
1086/7 1101/17 1007/10 1008/18 1120/11 1125/1 stay [1] 993/7
1116/22
someone [10] 1101/9 specify [2] stenographic [1]
so [207]
995/1 996/2 sorts [1] 1017/15 1112/17 1113/23 1130/5
social [3] 1088/19
1024/1 1064/3 sound [1] speculating [2] step [3] 992/24
1103/25 1129/9
1069/21 1086/1 1106/22 1060/13 1073/22 1064/24 1129/14
some [68] 991/8
1086/5 1092/3 sounds [1] speculation [1] still [13] 998/20
991/10 993/8
1118/16 1129/1 1114/2 1028/24 1012/25 1015/3
995/8 995/9
something [28] source [24] spend [1] 1015/5 1032/25
996/10 997/1
1007/3 1008/6 1019/10 1019/15 1007/17 1042/12 1082/19
997/14 998/8
1010/24 1016/25 1019/19 1019/20 spoke [7] 1089/18 1100/3
1002/7 1003/18
1022/1 1022/4 1019/23 1019/25 1008/11 1008/13 1100/3 1100/4
1008/5 1011/25
1024/7 1024/19 1020/1 1020/3 1008/14 1036/24 1103/17 1104/5
1012/3 1014/17
1024/24 1025/1 1020/6 1020/10 1046/17 1073/19 stop [4] 1061/13
1017/19 1017/25
1025/4 1025/5 1021/4 1021/16 1126/7 1064/2 1086/14
1018/9 1024/4
1034/15 1045/25 1055/2 1060/8 spoken [1] 1103/15
1025/5 1025/25
1046/3 1056/16 1060/8 1060/22 1073/22 story [3] 1005/5
1031/23 1032/13
1058/25 1060/11 1064/7 1064/11 SSA [1] 1061/10 1068/13 1068/15
1040/8 1040/8
1068/2 1075/4 1082/2 1117/25 staff [4] 1036/23 strain [1] 1088/15
1041/5 1049/14
1080/11 1086/2 1118/3 1118/14 1078/5 1078/6 strange [2]
1057/9 1058/5
1093/12 1098/14 1118/24 1121/10 1078/16 1101/7 1101/10
1058/19 1061/17
1098/20 1111/24 speak [11] 992/1 stage [1] 1051/2 Street [3] 989/14
1062/23 1064/5
1159
S 1022/8 995/14 995/24 1114/12 1114/13 takes [2] 1018/12

suffering [1] 997/10 997/22 1117/25 1118/3 1020/17
Street... [2]
1088/18 998/9 998/13 1118/17 1118/23 taking [6] 1043/7
1008/8 1096/25
summarize [3] 998/17 998/22 1120/13 1121/10 1050/12 1057/24
stressful [1]
1100/25 1102/24 1000/10 1000/18 1121/25 1122/11 1058/1 1066/14
1116/16
1114/23 1001/17 1002/11 1122/16 1123/10 1092/14
stretch [1]
summarized [1] 1002/18 1004/21 1123/25 1124/13 talk [15] 991/2
1065/17
1072/3 1004/22 1005/4 1124/17 1125/5 1005/24 1013/1
strike [1] 1114/8
summarizing [1] 1005/25 1006/5 1125/10 1125/15 1039/24 1042/2
stripe [1] 1020/22
1102/8 1007/5 1007/22 1126/9 1126/12 1043/2 1049/15
struggling [1]
summer [2] 1008/15 1009/16 1126/14 1126/25 1049/16 1049/17
1125/12
1080/8 1110/20 1010/13 1011/4 Sussmann's [7] 1049/19 1058/23
Strzok [5]
Sunday [1] 1011/20 1012/12 997/17 1060/1 1059/6 1067/1
1061/11 1061/13
1112/13 1013/7 1013/14 1060/16 1063/22 1097/17 1127/24
1063/1 1067/7
supervision [1] 1013/15 1014/16 1064/10 1098/5 talked [20]
1119/1
1013/12 1015/14 1025/10 1118/8 1002/21 1005/15
stuff [2] 1043/7
sure [38] 991/4 1026/24 1027/11 Sustained [1] 1007/16 1008/21
1100/22
992/13 993/10 1028/5 1028/11 1028/25 1010/22 1011/1
stupid [1]
997/3 999/18 1032/3 1037/10 swamp [1] 1104/4 1019/9 1021/21
1049/19
1000/9 1005/25 1040/1 1041/21 switching [1] 1032/14 1042/25
subinvestigations
1012/17 1016/18 1042/3 1042/17 1000/1 1060/18 1088/10
[1] 1075/11
1017/18 1018/1 1043/18 1045/7 sworn [1] 1083/5 1088/15 1093/18
subject [13]
1020/1 1020/3 1045/11 1046/9 system [1] 1001/6 1102/24 1105/2
1024/20 1029/17
1042/6 1042/7 1046/20 1046/22 1106/14 1117/12
1029/18 1030/15
1042/8 1044/6 1047/2 1047/4 T 1123/21 1127/25
1050/3 1090/20 table [1] 1010/17 talking [19]
1047/11 1048/5 1047/19 1048/11
1091/12 1091/17 tailored [1]
1053/9 1054/7 1048/14 1050/16 995/13 1015/18
1094/5 1106/8 1004/16
1054/17 1061/2 1051/7 1051/23 1016/2 1017/13
1106/9 1128/22 take [41] 993/14 1022/10 1032/7
1061/3 1062/12 1052/18 1053/12
1129/2 1005/10 1006/7
1064/18 1071/7 1056/23 1057/9 1043/7 1059/17
subjected [1] 1012/10 1020/24 1059/18 1071/9
1071/11 1080/10 1057/24 1058/23
1021/12 1025/25 1026/19 1076/3 1081/21
1082/5 1082/5 1059/15 1061/15
submitted [1] 1031/12 1032/14 1088/16 1093/9
1083/5 1095/13 1065/24 1066/8
1089/4 1033/17 1035/17 1093/10 1094/2
1095/15 1097/3 1066/15 1068/9
subpoenas [2] 1036/4 1037/6
1107/14 1115/14 1068/16 1069/3 1094/4 1104/8
1042/19 1042/19 1040/3 1043/25
1129/19 1070/7 1073/10 1116/13
subsequent [2] 1047/13 1047/16 tank [2] 1008/7
surmised [1] 1073/19 1075/15
1119/20 1121/3 1047/21 1048/18 1008/9
1101/15 1082/16 1084/2
substance [1] 1057/16 1057/17 Tasha [2] 1076/7
surprise [2] 1084/5 1085/2
1042/3 1057/22 1062/4
1026/8 1091/1 1087/8 1087/23 1120/13
substantial [2] 1063/1 1064/17
surprised [3] 1088/9 1088/17 Tashina [1]
1019/2 1021/18 1064/19 1065/12 1078/12
1091/9 1118/22 1090/21 1091/4
substantive [3] 1065/17 1068/3
1118/25 1093/22 1095/22 team [16] 1003/21
1008/22 1042/13 1068/20 1076/16 1003/23 1011/23
surprising [1] 1096/5 1097/4
1114/6 1083/21 1087/17 1014/8 1015/3
1119/5 1097/15 1097/22
substantively [1] 1089/20 1091/19 1016/5 1016/9
surreptitious [1] 1098/13 1098/18
1040/13 1099/6 1107/15
1101/19 1100/18 1100/21 1016/17 1026/6
substitute [1] 1107/22 1111/3
surveillance [1] 1102/9 1104/15 1026/16 1036/2
1108/12 1119/4 1120/10
1019/4 1106/20 1109/20 1037/3 1046/16
successor [1] taken [8] 1003/10 1105/17 1128/15
Susan [2] 1109/20 1110/1
1076/1 1014/18 1015/16 1128/23
1056/20 1057/14 1110/25 1111/12
such [4] 1002/24 1015/17 1021/12 technically [1]
suspect [1] 1111/12 1112/7
1028/10 1121/24 1031/14 1065/2
1025/11 1112/17 1112/20 1014/25
1123/6 1108/8
SUSSMANN [132] 1112/21 1113/23 telecommunicatio
sucked [1]
989/5 994/21 ns [2] 1000/23
1160
T 1006/22 1017/14 texted [3] 1068/18 1070/3 1114/6 1116/6

1026/23 1030/15 1014/16 1040/1 1071/1 1071/12 1117/2 1117/24
telecommunicatio
1031/3 1031/23 1073/14 1071/17 1073/11 1118/7 1119/4
ns... [1] 1001/6
1032/2 1032/23 texting [1] 1073/12 1073/25 1120/8 1121/20
telephone [3]
1037/9 1037/12 1044/22 1074/16 1074/16 1122/4 1122/5
1000/25 1126/21
1040/6 1044/3 texts [4] 1009/2 1074/16 1075/19 1122/10 1122/12
1126/22
1052/9 1058/21 1009/14 1046/20 1079/8 1082/21 1122/23 1122/25
tell [20] 993/6
1061/4 1061/14 1073/4 1082/23 1084/18 1123/2 1123/13
993/13 994/6
1065/23 1066/7 than [11] 1007/14 1084/25 1089/19 1124/3 1124/4
998/17 1004/1
1066/11 1073/9 1031/24 1042/25 1091/18 1092/14 1124/10 1125/4
1022/22 1052/25
1074/25 1087/14 1043/15 1046/2 1093/7 1093/19 1125/17 1125/19
1055/19 1056/11
1089/14 1099/13 1058/18 1071/2 1093/24 1094/3 1126/20 1126/21
1062/3 1069/8
1112/5 1071/20 1072/16 1096/2 1097/18 themselves [1]
1072/1 1076/13
testify [2] 991/17 1116/22 1121/5 1098/24 1099/2 995/21
1079/3 1106/15
1043/21 thank [15] 992/21 1100/8 1103/5 then [47] 991/16
1113/22 1114/1
testifying [2] 993/21 993/24 1104/14 1106/6 995/25 998/5
1114/3 1114/6
1061/4 1093/20 1025/19 1027/18 1107/22 1108/18 999/18 1006/4
1119/17
testimonies [1] 1033/22 1034/5 1109/11 1109/16 1009/15 1010/1
telling [23]
1120/15 1035/3 1062/12 1111/2 1111/8 1010/9 1011/15
1004/16 1047/7
testimony [39] 1062/14 1065/14 1113/11 1113/17 1012/6 1012/11
1109/18 1109/24
991/16 991/22 1075/23 1129/7 1115/1 1118/19 1012/18 1012/23
1111/10 1112/16
992/1 994/1 1129/15 1129/20 1123/12 1124/7 1014/7 1015/20
1112/22 1114/10
994/14 994/22 thanks [5] 1124/8 1124/22 1016/4 1016/17
1115/2 1117/24
998/7 1006/17 1005/24 1012/7 1124/23 1125/2 1016/22 1020/15
1118/7 1121/20
1007/14 1020/21 1012/9 1013/1 1125/16 1126/1 1020/24 1041/24
1122/12 1122/23
1048/17 1048/20 1059/4 1127/16 1127/21 1043/9 1044/25
1122/25 1124/3
1048/22 1052/17 that [954] their [11] 992/4 1072/19 1073/3
1124/4 1125/17
1052/21 1056/22 that's [104] 992/4 992/5 1073/13 1074/4
1125/19 1125/23
1061/25 1062/6 992/20 993/10 1001/14 1011/23 1080/13 1082/24
1126/14 1126/21
1063/5 1065/21 995/21 998/22 1023/16 1031/17 1085/16 1087/14
1128/19
1067/13 1081/12 1008/13 1017/2 1086/15 1091/13 1088/8 1093/17
tells [3] 1022/22
1081/14 1083/1 1020/16 1022/4 1119/4 1126/21 1097/11 1097/11
1110/5 1110/18
1083/5 1083/22 1024/14 1024/25 them [67] 992/11 1100/12 1102/2
ten [2] 1026/8
1090/19 1094/3 1026/4 1029/8 992/12 992/13 1106/12 1111/16
1068/2
1096/11 1097/12 1029/15 1029/23 997/9 997/24 1112/11 1112/13
tense [1] 1088/11
1099/16 1099/19 1031/21 1032/6 997/24 998/1 1117/12 1117/21
term [3] 1019/23
1100/11 1104/22 1032/22 1036/10 999/21 1005/6 1119/6 1119/21
1022/4 1030/19
1116/2 1116/4 1036/10 1036/12 1011/23 1020/14 1123/4 1128/18
termed [1]
1123/16 1128/7 1036/25 1037/16 1028/21 1031/11 there [87] 991/24
1108/15
1129/18 1038/4 1038/7 1038/7 1038/19 995/8 995/8
terminology [2]
text [26] 1004/20 1038/14 1040/21 1040/13 1040/15 995/13 995/22
1115/10 1115/10
1004/25 1005/10 1041/8 1041/17 1040/17 1044/5 998/23 1000/17
terms [5] 993/16
1007/5 1011/18 1041/20 1042/5 1046/17 1046/19 1001/25 1002/2
1003/6 1022/19
1011/19 1012/18 1042/24 1043/5 1046/23 1047/6 1002/19 1003/12
1044/1 1088/9
1033/17 1033/18 1043/16 1044/8 1047/7 1049/16 1003/15 1006/16
terrible [5]
1034/7 1044/3 1044/12 1045/6 1049/17 1049/19 1006/16 1007/6
1030/24 1031/1
1044/5 1044/8 1047/24 1047/25 1050/3 1053/23 1007/15 1008/2
1092/19 1092/22
1044/20 1047/2 1047/25 1048/6 1054/4 1059/6 1009/2 1009/16
1093/1
1048/12 1049/9 1048/20 1048/23 1059/23 1062/3 1009/24 1010/6
Terzaken [3]
1051/13 1073/14 1050/4 1050/10 1064/5 1081/7 1010/9 1015/3
1099/23 1099/23
1074/2 1096/5 1051/11 1058/14 1086/19 1095/21 1016/2 1017/20
1100/17
1108/13 1112/6 1059/10 1062/1 1105/21 1109/18 1019/2 1022/10
test [1] 1026/13
1112/9 1112/11 1062/11 1063/10 1112/20 1112/22 1022/18 1024/12
testified [27]
1112/15 1063/14 1067/10 1113/3 1114/3 1025/2 1025/15
998/22 999/20
1161
T 1084/3 1092/18 things [22] 1080/7 1083/11 1121/21 1122/13

1102/24 1107/18 1007/18 1023/15 1084/21 1087/3 1124/17
there... [56]
1108/22 1121/5 1023/17 1031/23 1087/16 1091/8 threat [7] 1020/23
1031/7 1032/20
1123/3 1037/13 1044/1 1092/14 1096/7 1023/9 1023/25
1032/23 1032/24
they [69] 997/9 1052/9 1055/14 1096/18 1097/12 1024/13 1085/11
1033/24 1035/2
1001/6 1001/8 1071/17 1084/23 1101/22 1102/15 1087/1 1087/11
1044/5 1047/16
1001/11 1001/12 1088/10 1088/11 1102/18 1103/12 threaten [1]
1052/22 1052/25
1001/13 1002/6 1091/3 1108/6 1103/12 1103/20 1128/20
1053/6 1053/22
1002/13 1002/13 1109/17 1112/1 1104/6 1106/10 threatened [1]
1055/9 1058/9
1002/15 1002/16 1112/2 1116/23 1107/3 1107/9 1128/23
1058/17 1058/22
1005/5 1018/24 1120/6 1124/1 1108/19 1115/8 three [3] 1022/11
1059/20 1061/13
1019/13 1022/5 1127/13 1128/22 1118/16 1119/1 1063/9 1113/18
1062/6 1072/25
1022/6 1022/22 think [112] 1119/24 1120/6 three-tiered [1]
1074/14 1074/25
1023/16 1031/11 991/20 992/4 1121/13 1123/8 1022/11
1075/10 1077/21
1031/13 1031/20 993/16 994/6 1124/25 1127/25 through [19]
1077/21 1079/5
1044/11 1049/17 996/10 997/15 thinking [14] 991/14 1018/2
1080/4 1082/6
1049/22 1049/22 999/20 1000/16 1007/17 1013/1 1020/15 1025/24
1084/16 1085/20
1049/24 1050/5 1002/6 1002/9 1016/22 1042/11 1031/25 1032/14
1087/3 1091/1
1050/11 1054/4 1004/18 1007/10 1067/11 1082/10 1040/12 1044/1
1091/3 1096/13
1054/8 1055/7 1008/7 1008/9 1082/13 1103/5 1060/20 1076/5
1096/22 1103/1
1063/16 1085/9 1008/11 1008/21 1103/13 1111/16 1082/8 1083/4
1103/15 1107/4
1086/15 1086/16 1010/22 1010/23 1118/13 1121/16 1083/6 1100/10
1107/6 1107/8
1086/16 1086/17 1011/1 1013/19 1121/17 1124/10 1100/12 1111/17
1107/10 1107/13
1093/11 1093/15 1013/25 1014/6 third [2] 1048/1 1116/23 1120/19
1109/5 1110/16
1095/22 1103/2 1014/7 1014/7 1048/2 1128/15
1112/1 1112/25
1105/20 1106/18 1014/12 1014/19 Thirteen [1] thrust [1] 998/20
1113/19 1116/9
1107/19 1108/16 1015/6 1015/6 1072/18 thumb [3] 1040/8
1116/12 1119/14
1109/13 1111/21 1015/11 1015/12 this [203] 1061/12 1101/6
1122/16 1122/17
1114/24 1115/3 1015/22 1016/14 those [27] 991/10 Thursday [1]
1122/20 1122/25
1116/12 1116/12 1017/8 1017/14 997/11 1011/3 994/9
1123/11 1129/6
1116/13 1116/14 1018/2 1018/5 1022/19 1023/14 tiered [1] 1022/11
there's [14]
1116/18 1116/19 1018/13 1018/17 1023/17 1028/19 till [2] 1006/25
1013/19 1023/8
1117/3 1117/5 1019/1 1019/12 1030/3 1030/5 1007/4
1024/24 1024/25
1117/12 1117/22 1020/13 1021/12 1030/21 1031/25 time [121] 996/7
1049/3 1049/20
1119/17 1119/18 1024/18 1026/17 1040/11 1053/24 996/11 996/16
1061/25 1068/13
1119/19 1119/24 1027/3 1027/4 1056/9 1056/23 997/15 998/5
1074/11 1090/4
1120/4 1120/4 1030/13 1031/14 1057/2 1057/6 1000/13 1001/11
1108/4 1110/16
1121/6 1128/15 1034/16 1037/16 1061/11 1066/24 1002/25 1003/12
1110/17 1115/13
1128/16 1128/20 1040/12 1042/5 1072/22 1077/18 1003/17 1004/6
thereafter [2]
they'd [1] 1068/7 1042/12 1044/23 1093/18 1095/23 1006/9 1006/25
996/15 1094/20
thing [26] 1048/22 1049/24 1102/25 1122/8 1007/4 1007/17
therefore [5]
1002/12 1008/19 1050/4 1051/17 1127/4 1128/1 1008/7 1009/6
1019/1 1071/15
1009/21 1016/3 1053/16 1056/4 though [2] 1009/11 1009/15
1071/24 1079/10
1021/21 1021/25 1056/18 1056/20 1018/14 1109/13 1014/24 1014/24
1110/18
1023/22 1030/24 1057/13 1058/1 thought [21] 1016/15 1017/19
these [26] 993/14
1031/20 1035/25 1058/18 1061/20 999/9 999/16 1018/12 1018/22
1007/25 1016/1
1055/22 1056/15 1062/11 1063/14 1014/4 1018/20 1020/17 1021/1
1016/20 1018/24
1074/11 1081/22 1063/25 1064/8 1018/23 1046/3 1021/12 1025/25
1019/5 1019/7
1092/19 1099/15 1066/8 1067/7 1058/25 1060/7 1028/12 1032/11
1022/15 1044/18
1099/16 1108/19 1067/9 1068/1 1060/7 1073/2 1033/24 1042/10
1046/14 1046/15
1108/21 1111/21 1068/18 1070/20 1085/10 1104/5 1042/14 1043/25
1063/12 1067/12
1111/24 1114/18 1071/6 1073/12 1105/5 1105/7 1044/17 1045/8
1067/21 1076/5
1114/21 1117/18 1073/14 1074/12 1111/15 1112/12 1045/25 1046/6
1080/25 1081/3
1118/11 1121/17 1074/16 1074/25 1114/23 1121/7 1049/14 1053/17
1081/5 1084/3
1162
T 1127/17 1125/9 1126/5 travel [3] 991/8 1116/18

Title [1] 1105/19 1126/24 1127/1 991/8 993/8 turn [3] 994/17
time... [80]
today [58] 1127/12 1127/12 tremendous [1] 1052/1 1119/21
1054/8 1054/12
1005/15 1005/20 1127/15 1128/21 1075/1 TV [1] 1035/24
1058/2 1059/17
1008/12 1028/2 tomorrow [6] trial [4] 989/8 Tweet [3] 1006/6
1059/18 1061/15
1031/23 1032/2 991/11 991/18 991/9 993/17 1006/9 1006/11
1063/12 1064/17
1032/5 1036/24 992/14 993/9 1049/7 twice [4] 1026/17
1066/14 1068/12
1037/14 1037/16 1012/22 1127/10 tribunal [1] 1043/2 1065/4
1068/14 1069/19
1040/6 1047/7 tonight [2] 1116/4 1100/13
1071/9 1071/18
1048/16 1048/22 1012/20 1035/6 tried [7] 1067/9 Twitter [7]
1072/7 1072/9
1048/23 1049/8 too [5] 992/5 1073/15 1083/13 1011/22 1012/19
1072/17 1076/14
1051/6 1052/9 997/5 1026/1 1083/15 1083/17 1013/6 1013/8
1077/7 1077/25
1052/17 1053/16 1034/24 1095/18 1083/19 1114/22 1013/10 1013/11
1078/15 1078/18
1056/22 1057/1 took [15] 1002/17 triggered [7] 1044/22
1078/19 1078/21
1057/5 1057/13 1030/8 1030/11 1112/12 1112/13 two [22] 994/11
1081/5 1084/8
1060/18 1060/21 1031/15 1031/25 1123/4 1124/24 1009/21 1026/22
1084/10 1084/20
1063/5 1064/12 1041/15 1055/10 1125/3 1127/6 1031/7 1031/10
1084/22 1087/14
1066/5 1067/2 1065/11 1067/2 1128/10 1035/8 1053/11
1087/18 1088/9
1067/4 1067/11 1067/3 1067/4 Trisha [1] 1076/4 1053/24 1055/14
1088/11 1088/22
1070/3 1081/12 1083/4 1100/10 true [4] 1046/18 1055/14 1063/8
1088/25 1089/11
1082/22 1093/20 1101/21 1107/13 1119/3 1125/16 1069/4 1072/22
1089/17 1089/18
1095/1 1099/11 tools [5] 1022/24 1130/4 1074/17 1074/20
1091/9 1092/8
1103/5 1103/12 1023/4 1023/12 Trump [11] 1077/5 1078/1
1093/4 1093/7
1104/8 1109/22 1024/9 1024/10 1016/4 1016/7 1082/12 1090/23
1094/2 1094/8
1110/5 1114/17 top [6] 995/5 1021/7 1021/8 1101/6 1113/18
1094/10 1094/15
1114/20 1114/23 995/6 1012/4 1051/19 1075/7 1120/15
1094/20 1094/24
1115/1 1115/24 1061/9 1079/19 1075/8 1080/12 two-minute [2]
1096/16 1096/18
1116/23 1118/6 1115/16 1081/22 1101/17 1074/17 1074/20
1097/3 1097/4
1123/6 1123/12 topic [3] 1005/9 1121/12 type [7] 1008/5
1099/12 1100/13
1123/16 1127/7 1005/17 1084/24 Trump's [1] 1017/21 1017/21
1103/17 1103/21
1127/16 1128/7 topics [1] 1000/1 1101/11 1017/25 1022/9
1106/7 1106/10
1128/11 1128/19 torrent [1] Trump-Russia [2] 1024/25 1025/5
1106/10 1106/21
together [2] 1088/19 1051/19 1081/22 typically [1]
1109/19 1110/1
1007/24 1051/2 touch [2] 1126/8 Trump/Russia [1] 1019/19
1110/3 1110/3
told [47] 998/23 1126/11 1016/7
1110/19 1110/24
1003/22 1005/8 tough [1] 1088/9 trust [2] 1014/11 U
1116/10 1118/9 U.S [7] 989/24
1012/9 1026/8 towards [2] 1051/23
1119/14 1119/19 1001/1 1001/2
1029/18 1036/25 1004/17 1009/16 trusted [4]
1122/9 1122/13 1001/6 1001/15
1046/19 1046/23 town [1] 1007/23 1025/17 1045/11
1122/14 1122/23 1004/11 1105/19
1047/6 1048/4 track [5] 993/7 1046/1 1046/6
1124/9 1124/23 U.S.C [3] 1049/23
1048/10 1049/22 993/8 993/16 truth [1] 1004/1
1125/2 1127/20 1050/3 1109/14
1049/24 1050/2 1087/16 1123/7 truthful [2]
1127/20 1128/6 Uh [7] 1006/20
1050/6 1052/18 training [1] 1083/17 1083/19
timeframe [3] 1007/21 1068/23
1054/25 1056/23 1035/21 truthfully [2]
1029/16 1044/21 1097/13 1098/23
1059/3 1061/22 transcript [13] 1027/4 1092/21
1059/18 1115/19 1120/17
1082/19 1084/16 989/8 994/12 try [8] 991/10
times [15] 994/21 Uh-huh [7]
1088/25 1089/1 994/18 1039/11 993/12 1037/5
1002/18 1003/15 1006/20 1007/21
1092/10 1096/2 1072/13 1094/3 1059/9 1059/10
1026/5 1026/15 1068/23 1097/13
1098/14 1102/14 1094/5 1100/9 1059/11 1100/24
1037/2 1043/1 1098/23 1115/19
1106/9 1109/22 1100/23 1104/13 1102/24
1043/2 1043/10 1120/17
1112/20 1113/3 1104/19 1130/5 trying [8] 999/16
1043/16 1044/19 ultimate [2]
1118/25 1119/1 1130/6 1009/5 1009/10
1051/8 1055/19 1003/5 1043/11
1123/10 1123/13 transcripts [1] 1023/25 1092/17
1057/10 1105/13 Um [1] 1007/13
1124/9 1125/4 1102/25 1103/12 1104/10
timing [2] 1083/7
1163
U 1020/12 1069/11 1079/25 1100/4 1087/11 1095/19

unrecalled [1] 1087/2 1090/1 voluntary [2] 1095/22 1101/2
umbrella [2]
1124/11 use [7] 1022/4 1030/6 1083/9 1120/24
1075/10 1075/11
unrelated [2] 1022/24 1023/4 volunteer [3] wary [2] 1021/24
unaggressively
1005/9 1005/17 1023/12 1024/8 998/13 999/2 1022/8
[1] 1002/10
until [6] 1012/8 1102/11 1103/3 1084/14 was [383]
unauthorized [2]
1030/13 1045/5 used [1] 1030/19 volunteered [1] Washington [2]
1029/12 1030/19
1064/22 1093/13 using [3] 1101/18 1105/8 989/14 989/25
unbelievable [2]
1128/5 1115/9 1115/25 vouch [1] wasn't [11]
996/21 1095/7
unusual [1] usually [1] 1117/14 998/18 1032/10
uncertainty [1]
1060/5 1019/21 vouched [6] 1033/13 1038/8
997/21
up [52] 992/24 1056/12 1056/24 1043/4 1062/24
uncomfortable [2]
994/21 996/13 V 1057/2 1057/7 1062/25 1066/13
997/4 1095/17 vague [2] 1078/25 1114/13 1115/4
996/17 996/23 1084/16 1100/24
uncommon [1] 1079/4
1005/12 1006/8 vouching [3] 1116/2
1016/24 vaguely [1]
1006/25 1009/8 1114/18 1114/20 WATKINS [1]
under [28] 1012/8 1076/12
1010/13 1012/5 1116/1 989/19
1013/12 1014/22 variety [4]
1016/1 1020/15 way [24] 995/9
1017/23 1017/24
1027/15 1033/20 1006/23 1017/23 W 1003/22 1004/16
1018/3 1023/18 1017/24 1022/9 wait [3] 998/15
1033/25 1034/1 1007/6 1008/14
1029/2 1029/5 various [7] 1016/8 1073/13
1038/25 1041/18 1018/9 1018/20
1029/20 1029/23 1013/10 1013/11 walk [1] 1058/5
1041/18 1045/2 1019/18 1033/25
1029/25 1032/17 1019/7 1067/19 walked [1]
1051/8 1058/20 1036/1 1058/6
1032/18 1039/13 1075/24 1076/10 1120/19
1059/3 1059/15 1059/22 1064/9
1051/17 1075/11 1108/4 Wall [1] 1096/25
1059/16 1061/1 1066/2 1070/11
1083/10 1083/11 veracity [1] want [33] 991/10
1062/11 1063/1 1070/12 1085/3
1088/21 1089/16 1021/17 992/1 992/5 993/6
1063/10 1069/19 1089/21 1097/7
1092/18 1099/14 verified [1] 1004/18 1012/16
1072/22 1074/10 1101/1 1102/21
1099/17 1100/5 1126/13 1013/13 1015/8
1076/18 1081/24 1103/13 1104/18
1104/12 1128/21 version [2] 1017/10 1020/9
1085/19 1088/6 1128/24
1129/2 1012/20 1108/7 1020/11 1022/4
1089/1 1094/17 ways [1] 1006/24
understand [8] very [33] 1008/20 1022/5 1030/7
1095/9 1099/22 we [148]
991/7 1012/14 1019/16 1021/9 1033/19 1040/20
1101/23 1102/5 We'd [1] 1068/8
1027/12 1028/6 1021/9 1021/14 1041/5 1043/25
1103/1 1104/16 we'll [17] 993/15
1053/4 1066/10 1022/8 1025/19 1053/19 1055/22
1111/6 1113/3 994/11 1034/1
1100/5 1108/10 1028/8 1030/25 1059/5 1061/2
1113/4 1115/12 1036/5 1037/5
understanding [8] 1031/9 1041/4 1062/12 1084/2
1117/13 1123/3 1039/25 1060/19
991/18 1001/1 1046/22 1047/4 1100/11 1107/20
1129/5 1076/5 1079/12
1002/1 1004/6 1049/12 1049/12 1107/23 1108/8
update [1] 1085/19 1100/2
1018/19 1030/2 1050/9 1055/8 1111/6 1113/15
1076/10 1100/11 1100/12
1033/1 1086/21 1057/21 1059/4 1115/8 1117/13
updated [1] 1113/9 1119/12
understands [1] 1066/16 1068/1 1117/17
1012/20 1127/10 1129/21
1129/19 1069/24 1069/24 wanted [27]
upon [5] 1015/20 we're [16] 993/16
understood [14] 1071/8 1071/16 993/10 997/7
1015/23 1017/19 1016/2 1020/24
992/15 999/5 1088/11 1093/16 997/10 1001/4
1022/24 1088/16 1020/25 1025/24
1001/10 1004/15 1093/17 1104/8 1001/13 1014/16
upsetting [1] 1032/10 1032/13
1016/15 1016/18 1119/12 1123/3 1015/18 1015/19
1049/13 1043/25 1044/15
1050/8 1054/12 1128/14 1128/16 1016/17 1018/1
us [17] 1001/7 1059/17 1059/18
1056/7 1083/10 victim [1] 1086/17 1040/17 1040/25
1002/14 1014/6 1094/2 1094/4
1083/11 1093/21 videotape [1] 1041/12 1045/24
1014/9 1015/8 1104/8 1120/20
1126/1 1128/25 1025/3 1046/3 1049/17
1016/19 1021/7 1129/5
UNITED [5] 989/1 view [2] 1020/6 1051/10 1051/15
1022/8 1028/16 we've [12] 992/18
989/2 989/9 1054/22 1051/20 1058/10
1052/10 1058/5 1019/9 1022/16
989/12 1017/24 voluntarily [1] 1058/16 1058/23
1065/17 1066/14 1025/22 1026/3
unless [1]
1164
W 1025/18 1033/23 1110/1 1112/6 1094/5 1094/7 1035/6 1036/5

1035/5 1073/3 1114/24 1114/24 1094/15 1094/17 1043/25 1044/5
we've... [7]
1073/4 1089/14 1114/25 1116/9 1096/16 1103/18 1054/14 1055/10
1043/24 1066/15
1097/16 1101/24 1117/9 1118/1 1105/4 1105/14 1060/9 1068/21
1066/21 1071/9
1114/6 1128/15 1118/22 1119/6 1106/2 1106/24 1074/22 1076/16
1091/24 1120/14
were [109] 995/19 1119/14 1124/1 1110/4 1110/14 1100/4 1101/12
1120/15
997/17 997/21 weren't [5] 1110/15 1112/6 1104/5 1108/5
week [6] 1012/25
1001/12 1001/21 1027/1 1037/25 1112/15 1117/5 1117/17 1122/6
1012/25 1055/10
1002/10 1002/13 1066/11 1084/23 1118/1 1119/2 1122/21 1122/22
1097/17 1119/21
1002/15 1002/16 1091/9 1120/8 1122/8 while [2] 1000/11
1119/24
1003/7 1003/13 what [159] 1123/1 1123/23 1004/23
weeks [2]
1003/17 1005/4 what's [14] 994/3 1125/1 1126/6 white [2] 1036/11
1026/22 1090/23
1005/5 1009/20 1007/25 1016/19 1126/23 1127/11 1052/10
weighs [1]
1013/15 1015/3 1017/10 1025/3 1127/21 1128/2 who [46] 995/2
1023/13
1018/16 1018/24 1042/8 1047/5 whenever [1] 995/19 995/19
Welcome [3]
1019/12 1019/14 1048/8 1067/2 1065/10 995/19 995/22
993/3 993/23
1021/18 1021/23 1070/19 1113/20 where [28] 995/5 1002/18 1003/2
1065/16
1022/10 1027/2 1116/24 1118/4 995/6 996/25 1003/2 1008/3
well [62] 992/7
1029/17 1029/20 1118/20 1009/19 1018/2 1013/23 1015/18
993/8 997/2
1031/3 1031/7 whatever [4] 1020/7 1043/24 1016/22 1017/11
1000/8 1007/15
1031/24 1032/18 1069/11 1089/7 1051/2 1061/6 1017/19 1019/12
1012/10 1013/19
1033/2 1033/8 1102/1 1120/4 1061/10 1062/2 1031/7 1031/10
1014/21 1014/21
1033/8 1037/2 whatsoever [1] 1062/10 1063/17 1034/14 1039/23
1016/15 1017/6
1037/19 1037/21 1087/4 1063/23 1066/6 1050/20 1056/2
1018/19 1019/18
1039/2 1039/9 when [87] 996/1 1067/1 1067/2 1056/7 1056/8
1020/21 1023/22
1039/13 1043/13 996/11 996/13 1073/14 1075/15 1060/23 1061/15
1024/25 1025/23
1044/5 1044/17 997/13 997/16 1076/4 1095/10 1062/1 1063/6
1026/13 1031/9
1044/18 1046/5 997/21 997/22 1104/7 1106/24 1063/7 1063/22
1031/23 1032/10
1050/2 1050/3 998/2 999/9 1107/13 1110/10 1064/10 1064/14
1033/23 1035/5
1051/18 1055/2 999/18 999/18 1112/14 1122/19 1076/5 1077/24
1035/17 1039/22
1055/7 1056/7 1003/11 1003/12 1124/16 1078/14 1082/5
1041/4 1043/9
1056/9 1058/3 1003/12 1006/21 Whereupon [1] 1086/5 1086/14
1049/12 1049/25
1058/15 1065/24 1008/6 1008/7 1062/17 1099/23 1101/8
1050/5 1050/9
1066/7 1075/10 1008/14 1009/24 whether [29] 1107/9 1107/13
1051/7 1051/15
1075/14 1076/9 1017/4 1017/14 1003/6 1007/12 1118/17 1121/10
1056/20 1058/25
1077/21 1080/25 1021/1 1021/2 1011/9 1011/12 1124/13 1125/24
1059/4 1059/16
1081/3 1083/10 1025/10 1026/21 1014/4 1021/18 1126/8
1060/13 1060/19
1084/3 1084/6 1029/14 1033/8 1023/15 1023/16 who's [1] 1078/4
1062/6 1064/15
1085/4 1085/4 1039/13 1042/12 1030/17 1030/19 whoever [1]
1067/12 1070/25
1087/5 1087/19 1044/17 1044/18 1043/18 1050/11 1018/24
1071/13 1073/13
1087/25 1089/7 1044/18 1044/23 1051/16 1059/21 whole [10]
1074/2 1077/22
1089/16 1089/20 1045/7 1047/12 1064/9 1067/14 1017/20 1018/5
1081/17 1086/12
1090/23 1091/12 1047/15 1048/25 1070/8 1070/15 1021/20 1048/1
1087/14 1088/24
1091/12 1091/17 1053/15 1059/19 1071/11 1072/11 1048/5 1092/19
1092/22 1093/16
1092/14 1092/15 1061/5 1061/6 1072/12 1072/12 1104/19 1117/18
1095/13 1097/16
1093/11 1101/7 1062/25 1063/1 1087/8 1093/11 1121/17 1128/8
1100/8 1107/22
1101/8 1101/9 1063/15 1066/5 1097/19 1098/19 whom [2] 1090/5
1108/5 1116/18
1101/18 1102/8 1067/5 1070/14 1113/4 1113/5 1103/14
1118/19 1120/8
1102/12 1103/18 1073/19 1077/9 1121/8 whomever [1]
1126/11
1104/10 1104/25 1081/2 1083/9 which [27] 991/15 1024/15
well-formulated
1105/15 1106/7 1084/2 1084/5 994/7 1002/22 whose [1] 1057/6
[1] 1093/16
1106/24 1107/4 1085/2 1086/19 1006/13 1014/8 why [23] 992/12
went [15] 1008/10
1107/10 1108/6 1087/2 1092/2 1020/17 1022/17 995/5 1003/25
1009/5 1010/15
1108/8 1109/8 1093/15 1093/19 1022/20 1033/17 1013/18 1014/20
1010/16 1010/18
1165
W 1086/3 1018/5 1018/6 wrongdoing [1] 1050/23 1098/21

word [13] 1018/9 1018/12 1003/7 you're [34]
why... [18]
1006/22 1006/23 1019/2 1019/15 wrote [3] 1005/24 1015/12 1017/13
1017/10 1019/17
1026/20 1055/15 1020/13 1020/18 1119/2 1128/2 1017/17 1018/17
1025/14 1064/19
1062/4 1102/4 1021/8 1021/11 1021/1 1027/7
1072/7 1072/8
1102/11 1103/3 1021/11 1021/12 Y 1037/17 1043/21
1086/4 1098/13 yahoo [1]
1103/10 1111/3 1021/14 1021/20 1048/24 1053/9
1098/16 1098/19 1012/20
1116/1 1119/4 1021/22 1022/8 1053/19 1053/22
1102/19 1103/10 YAO [1] 989/18
1120/10 1022/15 1024/6 1053/23 1054/20
1104/3 1113/15 yeah [30] 996/18 1058/18 1060/13
words [10] 998/7 1024/20 1024/22
1115/12 1117/20 1006/9 1007/1
1001/12 1014/10 1026/8 1028/8 1061/4 1067/18
1118/16 1119/24 1009/5 1009/10
1052/22 1052/24 1028/10 1028/12 1071/7 1071/11
will [21] 992/5 1010/7 1010/10
1062/7 1073/15 1030/24 1030/25 1074/13 1093/2
993/12 993/14 1012/13 1019/6
1091/2 1113/1 1036/1 1036/15 1093/9 1093/10
994/1 1019/20 1021/13 1037/16 1094/6 1096/16
1121/5 1038/12 1038/15
1019/22 1033/21 1051/14 1060/12 1097/4 1106/2
work [9] 993/9 1041/22 1045/23
1043/24 1055/23 1061/13 1069/25 1108/5 1108/22
1014/5 1014/17 1046/4 1051/10
1055/24 1061/13 1080/4 1096/20
1015/1 1035/18 1051/15 1051/16 1113/7 1116/6
1064/21 1064/25 1096/21 1099/18 1116/12 1119/21
1039/6 1041/3 1051/17 1051/20
1067/18 1068/15 1100/22 1103/15 you've [11]
1055/24 1111/13 1051/22 1054/22
1080/4 1086/18 1105/7 1106/10
worked [2] 1056/17 1056/21 1026/5 1031/24
1099/16 1102/5 1107/2 1109/23
1054/4 1056/2 1059/23 1059/23 1032/14 1051/5
1126/16 1129/11 1112/14 1113/18 1052/9 1072/2
working [12] 1059/25 1060/5
willing [2] 1119/4 1125/14
1008/7 1009/20 1060/10 1060/10 1081/8 1081/13
1014/10 1046/2 1128/5
1010/24 1011/23 1060/10 1060/11 1081/24 1116/23
wish [3] 996/19 year [7] 1027/24 1123/13
1012/7 1015/4 1060/12 1060/16
1036/23 1094/21 1035/8 1044/9
1015/24 1025/12 1061/23 1067/9 you/your [1]
withheld [3] 1045/5 1046/15
1077/20 1078/16 1069/22 1071/22 1036/23
1061/14 1064/9 1046/17 1046/18 your [161]
1087/25 1088/6 1077/19 1087/11
1121/9 years [13]
works [3] 1098/13 1098/19 yours [1] 1031/18
withhold [2] 1011/23 1032/11 yourself [7]
1019/18 1020/8 1104/20 1105/20
1063/22 1121/25 1042/11 1044/2
1112/4 1105/24 1107/12 1047/23 1048/2
withholding [4] 1050/23 1056/16 1050/12 1076/5
worse [1] 1045/3 1108/4 1114/16
1063/24 1064/13 1071/19 1071/20 1107/17 1108/25
would [110] 1115/2 1115/6
1118/8 1118/11 1081/18 1086/22 1115/18
991/13 991/15 1117/8 1118/16
within [2] 1098/15 1111/25
991/18 991/20 wouldn't [8]
1055/11 1086/18 1121/18
991/21 992/10 1002/14 1005/7
without [3] Yep [2] 1074/14
995/11 995/21 1021/10 1045/16
1030/16 1038/20 1096/23
1000/9 1006/1 1060/22 1070/25
1086/14 yes [236]
1007/23 1007/24 1111/5 1125/20
witness [10] yesterday [12]
1013/16 1013/20 Wow [1] 1104/2
990/2 1031/14 1007/23 1026/23
1013/21 1013/22 wrap [1] 1129/5
1041/1 1047/15 1032/2 1065/23
1013/23 1013/25 write [4] 1028/9
1047/16 1047/22 1066/7 1066/11
1013/25 1014/6 1035/5 1055/24
1065/9 1065/11 1093/20 1112/5
1014/7 1014/12 1057/15
1100/3 1113/12 1114/22 1116/2
1014/18 1014/19 writes [2] 1005/4
witness's [1] 1116/23 1123/19
1015/6 1015/15 1007/22
1107/16 yet [1] 1012/9
1015/18 1015/19 written [3]
witnesses [1] York [7] 989/20
1015/22 1016/4 1053/18 1089/3
991/9 1042/25 1043/2
1016/8 1016/11 1118/23
witnesses' [1] 1043/10 1043/15
1016/12 1016/17 wrong [6]
993/8 1051/8 1055/19
1016/19 1016/20 1081/25 1102/15
Wittes [2] you [921]
1017/5 1017/9 1104/5 1104/6
1033/19 1034/14 you'd [3] 1012/4
1017/18 1018/1 1111/19 1111/20
wonder [1]

Sussmann Trial 519 Afternoon

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Sussmann Trial 519 Afternoon

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IN THE

May 19, 2022

1 DIRECT EXAMINATION OF JAMES BAKER (CONT'D.)

2 THE COURT: Please be seated.

3 Okay. Welcome back, ladies and gentlemen. I hope

4 you had a nice lunch.

5 Before we get back started with Mr. Baker, I just

6 want to go over a few scheduling matters. The parties tell

7 me that we are basically on track, but in order to stay on

8 track, as well as to accommodate some witnesses' travel

9 schedules, we have decided to work tomorrow.

10 I just wanted to make sure that that's okay with

11 everyone. I know we sort of left open the possibilities of

12 convening on Fridays. We will try to get you out a little

13 early, if possible, but as you can probably tell, sometimes

14 it's hard to predict how long these sections will take. So

15 we'll do our best.

16 The good news is I think we're on track in terms

17 of the schedule that we laid out at the beginning of trial.

20 THE COURT: Mr. DeFilippis.

21 MR. DeFILIPPIS: Thank you, Your Honor.

23 Q. Welcome back, Mr. Baker.

25 Q. Mr. Baker, I'm going to show you one more excerpt

1107/24 1113/10 04 [2] 1033/17 17 [1] 1100/1 2018 [10] 994/9

3 809 [3] 1027/17 993/8 990/15 990/16 1066/1 1072/21

A 1042/16 1059/20 1018/6 1020/20 998/7 998/14 apologize [1]

A 1015/1 1015/5 1112/19 1113/24 991/14 1041/24 1045/2

B 1060/11 1060/14 1026/6 1030/21 1092/7 1092/11 1124/22 1125/5

C 1118/10 1127/8 998/6 998/9 999/8 999/5 1001/18 concern [2]

C 1001/21 1125/13 1104/4 1028/9 1062/10 1067/5

D deeply [2] 1014/6 1015/20 1015/23 1041/3 1041/20 1030/7 1031/7

D 1094/11 1095/2 1111/4 1111/10 1021/8 1101/11 DX-808 [1]

E 1009/10 1036/14 1036/15 1079/14 1079/17 1031/2 1037/2

F 1095/6 follow-up [4] Freedman [1] general [27]

G 1012/3 1012/22 1126/11 1066/19 1067/8 1067/19 1069/8

H 1118/6 1123/12 1067/9 1067/20 home [3] 1065/17 human [9]

I 1018/16 info [1] 1080/9 1003/18 1017/8 interpret [1]

I 1043/6 1111/24 1113/13 1016/13 1016/16 992/13 993/5

J 1072/12 1072/12 1055/22 1068/21 1015/14 1016/11 1039/24 1047/21

L 1097/25 1102/25 1004/21 1079/12 McCord [1]

M 999/7 999/10 1122/19 1122/21 989/5 989/17 1012/8 1017/16

M 994/20 995/13 1107/6 1109/5 1005/4 1005/25 1056/12 1057/8

M 1118/8 1126/6 1106/9 1128/23 1076/20 1079/15 1110/17 1111/2

N 1089/3 1089/4 1056/11 1056/19 1076/12 1084/14 1091/3 1098/8

O part [26] 995/1 1012/3 1031/7 persons [2] 998/17 1001/11

P previously [2] 1020/1 pun [1] 1117/14 1030/7 1051/6

R 1056/17 1056/21 1046/16 1065/3 991/16 1112/18 1022/5 1022/6

R 1022/5 1023/22 round [1] 1085/23 1069/18 1070/7 1042/2 1045/23

S 1015/13 1034/19 sentence [2] 1003/22 significant [2]

S 1064/6 1068/7 1112/11 1129/1 992/5 1005/9 stand [2] 1064/25

S 1022/8 995/14 995/24 1114/12 1114/13 takes [2] 1018/12

T 1006/22 1017/14 texted [3] 1068/18 1070/3 1114/6 1116/6

T 1084/3 1092/18 things [22] 1080/7 1083/11 1121/21 1122/13

T 1127/17 1125/9 1126/5 travel [3] 991/8 1116/18

U 1020/12 1069/11 1079/25 1100/4 1087/11 1095/19

W 1025/18 1033/23 1110/1 1112/6 1094/5 1094/7 1035/6 1036/5

W 1086/3 1018/5 1018/6 wrongdoing [1] 1050/23 1098/21

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