Sussmann Trial 525 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 25, 2022

May 25, 2022
vs.
vs. 2:08 p.m.
2:08 pum.
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
2834
2834
1
1 INDEX
I N D E X
2
2 WITNESS
WITNESS AGE
PAGE
3
3 BRANDON CHARNOV
BRANDON CHARNOV
4
4 Direct Examination
Direct Examination by Ms. Rao
by Ms. Rao 2837
2837
Cross-Examination by
Cross-Examination by Mr.
Mr. Keilty
Keilty 2850
2850
5
5
6
6 JIMMA ELLIOTT-STEVENS
JIMMA ELLIOTT-STEVENS
7
Direct Examination by Ms. Rao
by Ms. Rao 2856
2856
Cross-Examination by Ms.
Ms. Shaw
Shaw 2863
2863
8
8
9
9 MARTHA STANSELL-GAMM
MARTHA STANSELL-GAMM
10
Direct Examination by Ms. Yao
by Ms. Yao 2865
2865
Cross-Examination by Ms.
Ms. Shaw
Shaw 2873
2873
1
11
12
12
13
13 EXHIBITS
E X H I B I T S
14
14 EXHIBIT
EXHIBIT AGE
PAGE
15
15 Defense
Defense No.
No. 102
102 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 105
105 Admitted
Admitted into
into Evidence
Evidence 2840
2840
16
16 Defense
Defense No.
No. 106
106 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 107
107 Admitted
Admitted into
into Evidence
Evidence 2840
2840
17
17 Defense
Defense No.
No. 109
109 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 110
110 Admitted
Admitted into
into Evidence
Evidence 2840
2840
18
18 Defense
Defense No.
No. 112
112 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 114
114 Admitted
Admitted into
into Evidence
Evidence 2840
2840
19
19 Defense
Defense No.
No. 115
115 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 117
117 Admitted
Admitted into
into Evidence
Evidence 2840
2840
20
20 Defense
Defense No.
No. 118
118 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 120
120 Admitted
Admitted into
into Evidence
Evidence 2840
2840
21
21 Defense
Defense No.
No. 121
121 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 123
123 Admitted
Admitted into
into Evidence
Evidence 2840
2840
22
22 Defense
Defense No.
No. 124
124 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 125
125 Admitted
Admitted into
into Evidence
Evidence 2840
2840
23
23 Defense
Defense No.
No. 127
127 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 128
128 Admitted
Admitted into
into Evidence
Evidence 2840
2840
24
24 Defense
Defense No.
No. 130
130 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 132
132 Admitted
Admitted into
into Evidence
Evidence 2840
2840
25
25 Defense
Defense No.
No. 134
134 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense
Defense No.
No. 136
136 Admitted
Admitted into
into Evidence
Evidence 2840
2840
2835
2835
1
1 EXHIBITS
EXHIBITS (CONT'D)
(CONT'D) AGE
PAGE
2
2 Defense No.
Defense No. 137
137 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense No.
Defense No. 138
138 Admitted
Admitted into
into Evidence
Evidence 2840
2840
3
3 Defense No. 140
Defense No. 140 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense No.
Defense No. 141
141 Admitted
Admitted into
into Evidence
Evidence 2840
2840
4
4 Defense No.
Defense No. 142
142 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense No.
Defense No. 144
144 Admitted
Admitted into
into Evidence
Evidence 2840
2840
5
5 Defense No. 145
Admitted into
into Evidence
Evidence 2840
2840
Defense No.
Defense No. 146
146 Admitted
Admitted into
into Evidence
Evidence 2840
2840
6
6 Defense No.
Defense No. 147
147 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense No. 148
Admitted into
into Evidence
Evidence 2840
2840
7
7 Defense No.
Defense No. 149
149 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense No.
Defense No. 150
150 Admitted
Admitted into
into Evidence
Evidence 2840
2840
8
8 Defense No. 151
Admitted into
into Evidence
Evidence 2840
2840
Defense No.
Defense No. 152
152 Admitted
Admitted into
into Evidence
Evidence 2840
2840
9
9 Defense No.
Defense No. 153
153 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense No.
Defense No. 154
154 Admitted
Admitted into
into Evidence
Evidence 2840
2840
10
10 Defense No. 155
Admitted into
into Evidence
Evidence 2840
2840
Defense No.
Defense No. 164
164 Admitted
Admitted into
into Evidence
Evidence 2840
2840
1
11 Defense No.
Defense No. 165
165 Admitted
Admitted into
into Evidence
Evidence 2840
2840
Defense No. 900
Admitted into
into Evidence
Evidence 2841
2841
12
12
13
13
14
14
15
15
16
16
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25
25
2836
2836
1
1 PROCEEDINGS
P R O C E E D I N G S
2
2 THE COURT:
THE COURT: The
The jury
jury is
is outside.
outside. Why don't we
Why don't we go
go
3
3 ahead and
ahead and get
get started
started with
with your
your summary
summary witness?
witness?
4
4 MR. BERKOWITZ: We'll
MR. BERKOWITZ: We'll call
call him,
him, Judge.
Judge. We
We do
do have
have
5
5 one or
one or two
two things
things --
-- II don't know that
don't know that they
they need
need to
to be
be done
done
6
6 now, but
now, but before
before we
we leave,
leave, we
we have
have aa couple
couple issues
issues we
we want
want to
to
7
7 raise with
raise with you.
you.
8
8 THE COURT:
THE COURT: Okay.
Okay.
9
9 MS. RRO: Good
MS. RAO: Good afternoon,
afternoon, Your
Your Honor.
Honor. We
We call
call to
to
10
10 the stand
the stand --
--
1
11 THE COURT:
THE COURT: Wait.
Wait. Let's
Let's wait for our
wait for our jury.
jury.
12
12 MS. RRO: That's
MS. RAO: That's right.
right. Great
Great idea.
idea.
13
13 (Jury entered
(Jury entered the
the courtroom.)
courtroom.)
14
14 THE COURT:
THE COURT: All right.
All right. Welcome back,
Welcome back, ladies
ladies and
and
15
15 gentlemen.
gentlemen. II hope
hope you
you had
had aa nice
nice lunch.
lunch.
16
16 Let's wait
Let's wait till
till everyone
everyone fills
fills in.
in.
17
17 All right.
All right. Please be
Please be seated.
seated. And II believe
And believe
18
18 Ms. Rao will
Ms. Rao will be
be presenting
presenting the
the defense's
defense's next
next witness.
witness.
19
19 MS. RRO: Good
MS. RAO: Good afternoon,
afterncon, Your
Your Honor.
Honor. The
The defense
defense
20
20 calls Brandon
calls Brandon Charnov
Charnov to
to the
the stand.
stand.
21
21 THE COURT:
THE COURT: Good
Good afternoon,
afternoon, sir.
sir. II think
think you
you know
know
22
22 the drill.
the drill. Remove
Remove your
your mask and raise
mask and raise your
your right
right hand.
hand.
23
23 DEPUTY CLERK:
DEPUTY CLERK: DoDo you
you solemnly
solemnly affirm
affirm and
and truly
truly
24
24 declare that
declare that the
the testimony
testimony you
you are
are about
about to
to give
give will
will be
be the
the
25
25 truth, the
truth, the whole truth and
whole truth and nothing
nothing but
but the
the truth
truth and
and this
this
2837
2837
1
1 you do
you do under
under the
the pain
pain and
and penalty
penalty of
of perjury?
perjury?
2
2 THE WITNESS:
THE WITNESS: Yes.
Yes.
3
3
4
4 BY
BY MS.
MS. RRO:
RAO:
5
5 ©.
Q. Good afternoon,
Good afternoon, Mr.
Mr. Charnov,
Charnov, can
can you
you state
state and
and
6
6 spell your
spell your name
name for
for the
the record,
record, please?
please?
7
7 A.
A. Brandon Charnov.
Brandon Charnov. B-R-A-N-D-O-N,
B-R-A-N-D-O-N, C-H-A-R-N-O-V.
C-H-A-R-N-O-V.
8
8 Q.
Q. And are
And are you
you currently
currently employed?
employed?
9
9 A.
A. ves.
Yes.
10
10 Q.
Q. And where
And where are
are you
you employed?
employed?
1
11 A.
A. At Latham
At Latham && Watkins.
Watkins.
12
12 ©.
Q. And how
And how long
long have
have you
you been
been there?
there?
13
13 A.
A. Just under
Just under two
two years.
years.
14
14 Q.
Q. And what's
And what's your
your role
role at
at Latham
Latham && Watkins?
Watkins?
15
15 A.
A. My official
My official title
title is
is project assistant.
project assistant.
16
16 @.
Q. Can you
Can you explain
explain for
for the
the jury
jury what that is?
what that is?
17
17 A.
A. Yeah.
Yeah. It's very
It's very similar
similar work to what
work to a junior
what a junior
18
18 paralegal would
paralegal would do.
do.
19
19 @.
Q. And what's
And what's that?
that?
20
20 A.
A. Primarily assisting
Primarily assisting with
with cases.
cases. II specialize
specialize in
in
21
21 litigation and
litigation and trial.
trial. That's
That's why
why I'm
I'm here.
here. So
So primarily
primarily
22
22 assisting with
assisting with filings,
filings, binder
binder prep, document review,
prep, document review,
23
23 organization, that
organization, that kind
kind of
of thing.
thing.
24
24 ©.
Q. And II understand
And understand you're
you're heading
heading out
out in
in aa few
few
25
25 months?
months?
2838
2838
1
1 A.
A. Yes, IIam
Yes, am. I will
I will be
be starting
starting law
law school
school in
in the
the
2
2 || fall.
far.
3
3 THE COURT:
THE COURT: #hy in
Why in the
the world
world would you want
would you want to
to do
do
a
4 [| that?
ehaee
5
5 (Laughs all
(Laughs all around.)
around.)
6
6 || Br
BY ms.
MS. mao:
RAO:
7
7 ©.
Q. so prior
So prior to
to today,
today, were
were you
you given
given some
some documents
documents
8
8 [| to
to review
review in
in connection
connection with
witn this
this matter?
matter?
3
9 A.
A. Iwas.
I was.
10
10 ©.
Q. And what
And what were those documents,
were those documents, generally
generally speaking?
speaking?
un
11 A.
A. Those were
Those were FBI
FBI records.
records. II believe
believe they
they were
were
12
12 || produced
produced by
by special
special counsel
counsel in
in discovery,
discovery, and
and they
they fell
fell into
into
13
13 || sort
sort of
of three
three main
main buckets. one was
buckets. One was emails
emails involving
involving the
the
14
14 || FBI.
FBI. Two
Two was
was instant
instant messages,
messages, so
so Lynk
Lynk messages, and those
messages, and those
15
15 || were
were internal
internal between
vetween members
members of
of the
the FBI.
FBI. And three were,
And three were,
16
16 || sort
sort of,
of, other
other FBI
FBI documents, including things
documents, including things such
such as
as
17
17 || memos.
memos.
18
18 ©.
Q. And one
And one thing
thing to
to clarify
clarify upfront,
upfront, this
this case
case isis
19
19 || focused
focused on
on allegations
allegations related
related to
to Alfa-Bank.
Alfa-sank. Did
Did any
any of
of the
the
20
20 || documents
documents that
that you
you reviewed
reviewed involve
involve anything
anything related
related to
to
21
21 || arfa-sanxe
Alfa-Bank?
22
22 A
A. vo.
No.
23
23 ©.
Q. And when
And when you
you were given these
were given these documents
documents toto review,
review
24
24 || were
were you
you given
given any
any directions? what were
directions? What were you
you told
told to
to do?
do?
25
25 A.
A. Yes. II was
Yes. was told
told to
to review
review the
the documents
documents and
and to
to
2839
2839
1
1 [| confirm the
confirm the date
date on
on the
the document,
document, the
the type
type of
of document,
document, so
so
22 [| one of
one of those
those three
three buckets that I1 mentioned
buckets that mentioned earlier,
earlier, and
and
33 || which of
which of the
the clients
clients that
that Mr.
Mr. Sussmann
Sussmann represented
represented in
in those
those
42 [| documents.
documents.
55 MS. RRO: May

MS. RAO: May II approach
approach the
the witness, Your Honor?
witness, Your Honor?
66 THE COURT:
THE COURT: You
You may.
may.
77 MS. RAO: And
MS. RAO: these are
And these are all
all exhibits
exhibits that
that the
the
88 || court has
Court nas that
that we've
we've already
already provided,
provided, but we're happy
but we're happy to
to
99 || give you
give you aa copy
copy of
of the
the binder, if you'd
binder, if you'd like,
like, as
as well.
well.
10 |
10 BY
BY ms.
MS. mao:
RAO:
un
11 ©.
Q. So, Mr.
So, Mr. Charnov,
Charnov, I'm
I'm showing
showing you
you --
-- the
the binder
binder
12 ||
12 contains aa number
contains number of
of exhibits
exhibits marked
marked for
for identification.
identification.
13
13 MS. RAO: For
MS. RAO: For the
the record,
record, the
the binder
binder includes
includes
14 ||
14 Exnivics DX-102,
Exhibits px-102, Defense
Defense Exhibit
Exhibit 105,
105, Defense
Defense Exhibit
Exhibit 106,
106,
15 ||
15 pefense Exhibit
Defense Exnibit 107,
107, Defense
Defense Exhibit
Exnibit 109,
109, Defense
Defense Exhibit
Exhibit
16 ||
16 110, Defense
110, Defense Exhibit
Exnibit 112,
112, Defense
Defense Exhibit
Exhibit 114,
114, Defense
Defense
17 ||
17 xnivic 115,
Exhibit 115, Defense
pefense Exhibit
Exnibit 117,
117, Defense
pefense Exhibit
Exhibit 118,
11s,
18 ||
18 pefense Exhibit
Defense Exhibit 120,
120, Defense
Defense Exhibit
Exhibit 121,
121, Defense
Defense Exhibit
Exhibit
19 ||
19 123, Defense
Exhibit 124,
124, Defense
pefense Exhibit
Exhibit 125,
125, Defense
Defense
20 ||
20 Exhibit 127,
Defense Exhibit
Exhibit 128,
128, Defense
Defense Exhibit
Exhibit 130,
130,
21 ||
21 pefense Exhibit
132, Defense
Defense Exhibit
Exhibit 134,
134, Defense
Defense Exhibit
Exhibit
22 [[
22 136, Defense
Exhibit 137,
137, Defense
Defense Exhibit
Exhibit 138,
138, Defense
Defense
23 [[
23 Exhibit 140,
Defense Exhibit
Exhibit 141,
141, Defense
Defense Exhibit
Exhibit 142
142
24 [|
24 vefense Exhibit
144, Defense
Defense Exhibit
Exhibit 145,
145, Defense
Defense Exhibit
Exhibit
25 ||
25 146, Defense
146, pefense Exhibit
Exhibit 147,
147, Defense
Defense Exhibit
Exhibit 148,
148, Defense
Defense
2840
2840
1
1 Exhibit 149,
Defense Exhibit
Exhibit 150,
150, Defense
Defense Exhibit
Exhibit 151,
151,
2
2 Defense Exhibit
152, Defense
Defense Exhibit
Exhibit 153,
153, Defense
Defense Exhibit
Exhibit
3
3 154, Defense
Exhibit 155,
155, Defense
Defense Exhibit
Exhibit 164
164 and
and Defense
Defense
4
4 Exhibit 165.
Exhibit 165.
5
5 BY
BY MS.
MS. RRO:
RAO:
6
6 Q.
Q. And, Mr.
And, Mr. Charnov, what are
Charnov, what are those
those exhibits
exhibits that
that II
7
7 just referenced
just referenced that
that are
are in
in your
your binder?
binder?
8
8 A.
A. Those exhibits
Those exhibits are
are the
the exhibits
exhibits that
that II mentioned
mentioned
9
9 earlier that
earlier that II reviewed.
reviewed.
10
10 Q.
Q. Okay.
Okay.
1
11 MS. RAO: And,
MS. RAO: Your Honor,
And, Your Honor, we
we would
would offer
offer those
those
12
12 exhibits II just
exhibits just read
read into
into the
the record
record into
into evidence.
evidence.
13
13 MR. KEILTY: No
MR. KEILTY: objection, Your
No objection, Your Honor.
Honor.
14
14 THE COURT:
THE COURT: So
So moved.
moved.
15
15 (Defense Exhibits
(Defense Exhibits 102,
102, 105-107,
105-107, 109-112,
109-112, 114,
114, 115,
115, 117,
117,
16
16 118, 120,
118, 120, 121,
121, 123-125,
123-125, 127,
127, 128,
128, 130,
130, 132,
132, 134,
134, 136-138,
136-138,
17
17 140-142, 144-155,
140-142, 144-155, 164,
164, and
and 165
165 were admitted.)
were admitted.)
18
18 BY
BY MS.
MS. RRO:
RAO:
19
19 Q.
Q. Now, Mr.
Now, Mr. Charnov, in connection
Charnov, in connection with
with reviewing
reviewing
20
20 those documents,
those documents, did
did you
you also
also assist
assist in
in preparing
preparing aa chart
chart
21
21 that summarized
that summarized those
those exhibits?
exhibits?
22
22 A.
A. Idid.
I did.
23
23 Q.
Q. Okay.
Okay.
24
24 And I'd
And I'd like
like to
to show
show you
you what has been
what has been marked
marked for
for
25
25 identification as
identification as Defense
Defense Exhibit
Exhibit 900.
900.
2841
2841
1
1 Mr. Charnov,
Mr. Charnov, what is Defense
what is Defense Exhibit
Exhibit 900?
900?
2
2 A.
A. Defense Exhibit
Defense Exhibit 900
900 is
is the
the exhibit
exhibit that
that was
was
3
3 created based
created based on
on the
the data
data from
from the
the chart
chart that
that II put
put
4
4 together. It
together. It involves
involves records
records of
of FBI's
FBI's communications
communications andand
5 [| meetings
5 relating to
meetings relating to Mr.
Mr. Sussmann's
sussmann's representation
representation of of
6
6 Hillary for
Hillary for America, the Democratic
America, the Democratic National
National Committee
Committee and
and
7
7 the Democratic
the Democratic Congressional
Congressional Campaign
Campaign Committee.
Committee.
8
8 ©.
Q. And does
And does this
this summarize
summarize all
all of
of those
those exhibits
exhibits that
that
9
9 are in
are in the
the binder that we
binder that just mentioned?
we just mentioned?
10
10 A.
A. ves.
Yes.
n
11 ©.
Q. And did
And did you
you review
review this
this chart
chart to
to ensure
ensure it
it fairly
fairly
12
12 and accurately
and accurately summarized
summarized the
the records
records that
that you
you reviewed?
reviewed?
13
13 A.
A. ves.
Yes.
14
14 Q.
Q. Okay.
Okay.
15
15 MS. RRO: Your
MS. RAO: Your Honor,
Honor, atat this
this time
time we
we would
would offer
offer
16
16 Defense Exhibit
Defense Exhibit 900
900 into
into evidence
evidence asas aa summary
summary chart.
chart.
17
17 MR. KEILTY: No
MR. KEILTY: objection.
No objection.
18
18 THE COURT:
THE COURT: SoSo moved.
moved.
19
19 (Defense Exhibit
(Defense Exhibit 900
900 was
was admitted.)
admitted.)
20 || Br
20 BY ms.
MS. mao:
RAO:
21
21 ©.
Q. Now, let's
Now, let's take
take aa moment to explain
moment to explain what
what this
this
22
22 shows. So
shows. So starting
starting at
at the
the beginning,
beginning, I I think
think you
you mentioned
mentioned
23
23 that it
that it reflects
reflects FBI
FBI communications
communications and
and meetings related to
meetings related to
24
24 Mr. Sussmann's representation
Mr. Sussmann's representation ofof some
some political
political clients.
clients.
25
25 Now, what
Now, what months are --
months are -- does
does this
this chart
chart focus
focus on?
on?
2842
2842
1
1 A.
A. This focuses
This focuses on
on the
the months
months of
of June
June to
to October
October of
of
2
2 2016.
2016.
3
3 ©.
Q. Okay.
Okay.
4
4 And communications
And communications related
related to
to which
which clients?
clients? II
5
5 think you
think you had
had mentioned
mentioned --
-- II think
think they
they are
are abbreviated
abbreviated
6
6 here, so
here, so II just
just want
want to
to make sure we
make sure we know
know what
what the
the
7
7 abbreviations stand
abbreviations stand for?
for?
8
8 A.
A. Yes. So
Yes. So the
the DNC
DNC abbreviation
abbreviation isis the
the Democratic
Democratic
9
9 National Committee.
National Committee. The The HFA
HFA is
is Hillary
Hillary for
for America, and
America, and
10
10 DCee, or
DCCC, or DD triple
triple C,
C, is
is the
the Democratic
Democratic Congressional
Congressional
n
11 Campaign Committee.
Campaign Committee.
12
12 ©.
Q. So we
So we have
have there
there in
in the
the middle
middle the
the various
various months,
months,
13
13 June, July,
June, July, August, September, October
August, September, October ofof 2016,
2016, and
and above
above
14
14 that there
that there are
are differently-colored shaded boxes.
differently-colored shaded boxes. Can
Can you
you
15
15 explain for
explain for the
the jury
jury what
what those
those represent?
represent?
16
16 A.
A. Yes. Each
Yes. Each different
different colored
colored shaded
shaded box
box represents
represents
17
17 a communication
a communication that
that took
took place
place on
on that
that day
day that
that II reviewed
reviewed
18
18 in evidence
in evidence inin these
these exhibits
exhibits that
that indicates
indicates Mr.
Mr. Sussmann's
Sussmann's
19
19 representation of
representation of one
one of
of those
those three
three clients.
clients.
20
20 ©.
Q. Okay. And
Okay. And the
the numbers
numbers under
under the
the boxes, does that
boxes, does that
21
21 reflect the
reflect the date
date of
of the
the communication?
communication?
22
22 A.
A. ves.
Yes.
23
23 Q.
Q. Okay.
Okay.
24
24 And then
And then II also
also see
see above
above that
that there's
there's some
some lines
lines
25
25 that show
that show calendars.
calendars. What
What do those represent?
do those represent?
2843
2843
1
1 A.
A. Those calendars
Those calendars represent
represent meetings between
meetings between
2 | Mr.
2 sussmann and
Mr. Sussmann and the
the FBI.
FBI.
3
3 ©.
Q. Okay.
Okay.
1
4 A.
A. On those
On those dates listed.
dates listed.
5
5 ©.
Q. Okay. And
Okay. And there
there are
are some
some varying
varying shades
shades ofof blue
blue
6
6 for the
for the different
different boxes,
boxes, both
both the
the boxes
boxes sort
sort of
of closer
closer to
to
7
7 the months
the and then
months and then the
the meetings.
meetings. CanCan you
you just
just explain
explain what
what
8
8 the multiple
the colors represent?
multiple colors represent?
9
9 A.
A. Yes. So
Yes. So the
the lightest
lightest shade
shade of
of blue,
blue, which
which almost
almost
10
10 appears as
appears as white, is representing
white, is representing the
the HFA,
HFA, when
when Mr. Sussmann
Mr. Sussmann
n
11 represents the
represents the HFA.
HFA. The
The middle
middle shade
shade of
of blue
blue is
is the
the DNC,
DNC,
12
12 and the
and the darkest
darkest shade
shade of
of blue
blue is
is the
the DD triple
triple C.
C.
13
13 ©.
Q. Some boxes
Some have multiple
boxes have multiple colors.
colors. SoSo what does
what does
14
14 that reflect
that reflect inin the
the chart?
chart?
15
15 A.
A. So that
So that reflects
reflects when Mr. Sussmann
when Mr. Sussmann represents
represents
16 || multiple
16 clients. That
multiple clients. could either
That could either be
be in
in the
the form
form of
of one
one
17
17 document that
document that II reviewed
reviewed that
that had
had him
him representing
representing multiple
multiple
18
18 clients or
clients or multiple documents that
multiple documents that both took place
both took place on
on the
the
19
19 same day
same day where
where each
each one
one had
had him
him representing
representing aa different
different
20
20 client.
client.
21
21 ©.
Q. Okay.
Okay.
22
22 And then
And then finally,
finally, II think
think on
on the
the right-hand
right-hand side
side
23
23 on the
on the bottom, there appear
bottom, there appear to
to be
be aa list
list of
of exhibits.
exhibits. And And II
24
24 think that's
think that's just
just the
the exhibits
exhibits we just read
we just read into
into the
the record
record
25
25 that are
that are summarized
summarized here;
here; is
is that
that right?
right?
2844
2844
1
1 A.
A. That is
That is correct.
correct.
2
2 ©.
Q. So now,
So now, just
just to
to get
get aa sense
sense of
of the
the documents
documents you
you
3
3 reviewed and
reviewed and how
how you
you put
put this
this chart
chart together,
together, let's
let's take
take aa
4
4 look at
look at aa few
few examples.
examples. Okay?
Okay?
5
5 So let's
So let's start
start with
with Defense
Defense Exhibit
Exhibit 121?
1212
6
6 MS. RRO: Mr.
MS. RAO: Cleaves, if
Mr. Cleaves, if you
you could
could pull
pull that
that up.
up.
7
7 You can
You can just
just snip
snip at
at the
the top
top just
just to
to show
show what
what the
the header
header isis
8
8 just to
just to begin
begin with.
with. TheThe to/from
to/from information
information too,
too, just
just the
the
9
9 full piece.
full piece. Yep.
Yep. Perfect.
Perfect.
10 || BY
10 BY ms.
MS. mao:
RAO:
n
11 ©.
Q. So, Mr.
So, Mr. Charnov,
Charnov, can
can you
you explain,
explain, you
you know,
know, what
what
12
12 this is?
this is?
13
13 A.
A. This is
This is an
an email
email from
from the
the FBI
FBI dated
dated August
August 3rd,
3rd,
14
14 2016 titled
2016 titled "extortion
"extortion threat
threat to
to the
the Hillary
Hillary campaign
campaign
15
15 unclassified FOUO".
unclassified FOUO".
16
16 ©.
Q. Generally speaking,
Generally speaking, the
the "from"
"from" and
and the
the "to"
"to"
17
17 information reflects
information reflects FBI
FBI recipients;
recipients; isis that
that right?
right?
18
18 A.
A. ves.
Yes.
19
19 ©.
Q. And is
And is Mr.
Mr. Sussmann
Sussmann referenced
referenced inin this
this email?
email?
20
20 A.
A. de is.
He is.
21
21 ©.
Q. Okay. And
Okay. And let's
let's take
take aa look
look at
at that.
that. II think
think
22
22 it's going
it's going toto be
be the
the email
email lower
lower in
in the
the chain.
chain. Yep.
Yep. There
There
23
23 we go.
we go. Okay.
Okay.
24
24 And if
And if you
you could
could just
just read
read that
that first
first paragraph
paragraph
25
25 for me
for under "good
me under "good morning, Rodney".
morning, Rodney".
2845
2845
1
1 A.
A. "WFO/CY-3 received
"WFO/CY-3 received email
email from
from DNC
DNC attorney
attorney
2
2 Sussmann late
Sussmann late last
last night
night regarding
regarding anan extortion
extortion message
message
3
3 received by
received by the
the Hillary
Hillary campaign
campaign threatening
threatening DDOS
DDOS attacks
attacks
4
4 beginning 08/08/2016
beginning 08/08/2016 if if ransom
ransom is
is not
not paid.
paid. II will
will forward
forward
5
5 the message
the (green side)
message (green side) to
to you
you for
for visibility
visibility and
and potential
potential
6
6 action given
action given the
the apparent
apparent cyber
cyber criminal
criminal nature
nature of
of the
the
7
7 threat."
threat."
8
8 ©.
Q. Thank you.
Thank you.
9
9 MS. RAO: And
MS. RAO: if we
And if can pull
we can pull back up Defense
back up Defense
10
10 Exhibit 900.
Exhibit 900.
n
11 BY
BY MS.
MS. RAO:
RAO:
12
12 ©.
Q. And so
And so can
can you
you explain
explain how
how that
that August
August 3rd
3rd email
email
13
13 we just
we just looked
looked atat is
is reflected
reflected here
here on
on your
your chart?
chart?
14
14 A.
A. Yes. So
Yes. So this
this is
is going to appear
going to appear on
on August
August 3rd
3rd in
in
15
15 the box.
the box. You
You can
can see
see the
the box
box is
is shaded
shaded with
with the
the light
light blue,
blue,
16
16 representing HFA,
representing HFA, as
as well
well as
as the
the dark
dark blue,
blue, representing
representing DNC
DNC
17
17 because they
because they were
were both
both mentioned
mentioned inin the
the email.
email.
18
18 ©.
Q. Let's take
Let's take aa look
look at
at Defense
Defense Exhibit
Exhibit 128.
128. Okay.
Okay.
19
19 Mr. Charnov,
Mr. Charnov, what's this document?
what's this document?
20
20 A.
A. This document
This is an
document is an FBI
FBI email
email from
from an
an FBI
FBI agent
agent
21
21 labeled "Unclassified/FOUO",
labeled "Unclassified/FOUO", subject
subject "briefings
"briefings for
for private
private
22
22 sector organizations-unclassified
sector organizations-unclassified FOUO".
FOUO".
23
23 ©.
Q. All of
All of the
the individuals
individuals onon this
this email
email chain
chain are
are FBI
FBI
24
24 employees; is
employees; is that
that right?
right?
25
25 A.
A. ves.
Yes.
2846
2846
1
1 ©.
Q. And then
And then if
if we
we can
can take
take aa look
look at
at Page
Page 22 in
in the
the
2 || August
2 10th email.
August 10th email. and if we
And if can just
we can just --
-- if
if you
you can
can read
read
3
3 those first
those first two
two paragraphs
paragraphs for
for me under "good
me under "good afternoon,
afternoon,
4
4 Lucy".
Lucy".
5
5 A.
A. "on Thursday,
"On Thursday, August 11, 2016,
August 11, 2016, aa group of folks
group of folks
6
6 from the
from the DNC
DNC will
will receive
receive aa threat
threat briefing at the
briefing at the secret
secret
7
7 level of
level of FBI
FBI headquarters.
headquarters.
8
8 on Friday,
On Friday, August
August 12,
12, 2016,
2016, aa group
group of
of folks
folks from
from
9
9 HEA, 'Hillary
HFA, ‘Hillary for
for America',
America’, Secretary
Secretary Clinton's
Clinton's presidential
presidential
10
10 campaign, will
campaign, will receive
receive the
the same
same threat
threat briefing
briefing atat the
the
n
11 secret level
secret level at
at FBI
FBI HQ.
HQ. OnOn the
the afternoon
afternoon ofof August
August 12,
12,
12
12 2016, the
2016, the DCCC,
DCCC, Democratic
Democratic Congressional Campaign Committee,
Congressional Campaign Committee,
13
13 will receive
will receive the
the threat
threat briefing
briefing at
at the
the secret
secret level
level atat FBI
FBI
14
14 HO."
HQ."
15
15 ©.
Q. And does
And does this
this email
email indicate
indicate who the individuals
who the individuals
16
16 are from
are from the
the DNC,
DNC, HFA
HFA and
and DCCC
DCCC that
that will
will attend
attend the
the meeting?
meeting?
17
17 A.
A. It does.
It does.
18
18 ©.
Q. Okay. Let's
Okay. Let's take
take aa look
look at
at that.
that. And
And we
we don't
don't
19
19 need to
need to read
read all
all of
of the
the attendees,
attendees, but safe to
but safe to say
say that
that
20
20 Mr. Sussmann
Mr. Sussmann isis listed
listed as
as an
an attendee
attendee at
at the
the DNC
DNC meeting?
meeting?
21
21 A.
A. ves.
Yes.
22
22 ©.
Q. And the
And the HFA
HFA meeting?
meeting?
23
23 A.
A. ves.
Yes.
24
24 ©.
Q. And the
And the DCCC
DCCC meeting?
meeting?
25
25 A.
A. ves.
Yes.
2847
2847
1
1 ©.
Q. Okay.
Okay. Let's take
Let's take aa look
look back at Defense
back at Defense Exhibit
Exhibit
2
2 900.
900.
3
3 If you
If you can
can explain
explain for
for the
the jury
jury how
how this
this exhibit,
exhibit,
4
4 Defense Exhibit
128, would
would be reflected on
be reflected on your
your chart?
chart?
5
5 A.
A. Yes. So
Yes. So first,
first, this
this is
is aa communication.
communication. So So II
6
6 reflected that
reflected that under
under August
August 11th,
llth, because
because that
that is
is the
the date
date
7
7 of the
of the top
top email.
email. And I reflected
And I reflected that
that having
having all
all three
three
8
8 shades for
shades for DNC,
DNC, HFA
HFA and
and DCCC
DCCC because
because all
all three
three of
of them
them were
were
9 || mentioned
9 mentioned inin this
this email.
emaii.
10
10 In addition,
In addition, there
there were
were two
two meetings
meetings referenced
referenced inin
n
11 this email,
this email, one
one on
on Thursday, August 11th.
Thursday, August llth. SoSo the
the calendar
calendar
12
12 at the
at the top
top under
under August
August 11th
11th is
is shaded
shaded that
that middle shade of
middle shade of
13
13 blue for
blue for DNC,
DNC, and
and the
the meeting
meeting on
on August
August 12th
12th is
is shaded
shaded dark
dark
14
14 blue for
blue for DCCC.
DCCC.
15
15 ©.
Q. And let's
And let's take
take aa look
look at
at Defense
Defense Exhibit
Exhibit 144.
144. AndAnd
16
16 what's this
what's this document?
document?
17
17 A.
A. This appears
This appears to
to be
be an
an FBI
FBI memo labeled
memo labeled
18
18 “Unclassified FOUO"
"Unclassified FOUO" dated
dated September
September 22nd,
22nd, 2016,
2016, title,
title,
19
19 “UFOUO cyber
"UFOUO cyber related
related target
target entity-Hillary
entity-Hillary forfor America
America
20
20 campaign".
campaign".
21
21 ©.
Q. Does this
Does this document
document mention
mention Mr.
Mr. Sussmann
Sussmann as
as well?
well?
22
22 A.
A. ves.
Yes.
23
23 ©.
Q. Okay. Let's
Okay. Let's take
take aa look
look atat that.
that. II think
think it's
it's
24
24 the third
the third paragraph.
paragraph. CanCan you
you just
just read
read that
that for
for us?
us?
25
25 A.
A. "On August
"On August 9th,
9th, 2016,
2016, at
at 11:47
11:47 p.m.,
p.m., FBI
FBI received
received
2848
2848
1
1 an email
an email from
from Hillary
Hillary for
for America
America (HFA)
(HFA) campaign
campaign attorney
attorney
2
2 || michael sussmann. In
Michael Sussmann. In the
the email
email Sussmann
Sussmann wrote,
wrote, 'Rodney,
'Rodney,
3
3 thank you
thank you for
for your
your message today. Thankfully,
message today. Thankfully, there
there was
was no
no
4
4 DDoS. We
DDoS. appreciate your
We appreciate your attention
attention and
and assistance.
assistance. Regards
Regards
5 | michaerrr.
5 Michael'".
6
6 Q.
Q. Before we
Before we turn
turn back
back to
to Defense
Defense Exhibit
Exhibit 900,
900, let's
let's
7
7 take aa look
take look at
at Defense
Defense Exhibit
Exhibit 145.
145. And
And this
this is
is also
also aa
8
8 document that's
document that's dated
dated September
September 22nd,
22nd, 2016.
2016. AndAnd can
can you
you
9
9 just state
just state briefly
briefly what this appears
what this appears toto be?
be?
10
10 A.
A. This appears
This appears to
to be
be an
an email
email from
from Michael
Michael A.
A.
n
11 Sussmann to
Sussmann to members of the
members of the DOJ
DOJ and
and FBI,
FBI, subject
subject "DNC
"DNC and
and
12
12 DCCC Intrusions".
DCCC Intrusions”.
13
13 ©.
Q. Okay. And
Okay. And if
if we
we can
can take
take aa look
look atat the
the very
very
14
14 bottom of
bottom of Page
Page 1,
1, which
which II think
think is
is sort
sort ofof the
the "from"
"from"
15
15 information, and
information, and then
then the
the top
top of
of Page
Page 2.
2.
16
16 And can
And can you
you just
just read
read that
that for
for us?
us?
17
17 A.
A. "Michael, II hope
"Michael, hope all
all is
is well
well since
since wewe last
last met
met in
in
18 || August
18 August atat FBI
FBI HQ.
HO. Would you have
Would you have time
time in
in the
the next
next several
several
19
19 business days
business days to
to chat
chat with
with NSD, the FBI
NSD, the FBI and
and our
our colleagues
colleagues
20
20 from the
from the U.S.
U.S. Attorney's
Attorney's Office
Office for
for the
the Northern
Northern District
District of of
21
21 California (copied)?
California (copied)? WeWe are
are likely
likely toto have
have some
some information
information
22
22 requests for
requests for one
one or
or both
both of
of your
your clients
clients and
and would
would like
like toto
23
23 talk through
talk through them
them with
with you.
you. Regards."
Regards."
24
24 ©.
Q. And can
And can you
you tell
tell from
from looking
looking atat the
the document
document what
what
25
25 the "one
the "one or
or both
both of
of your
your clients"
clients" is
is referring
referring to?
to?
2849
2849
1
1 A.
A. Yes. Based
Yes. Based onon the
the subject,
subject, which
which reads
reads "DNC
"DNC and
and
2
2 || pece intrusions",
DCCC intrusions, I1 believe
believe that
that those
those are
are the
the two
two clients
clients
33 || that are
that are mentioned.
mentionea.
44 ©.
Q. Okay. And
Okay. And just
just if
if we
we can
can go
go back for aa second
back for second toto
55 || vefense Exhibit
Defense mxnibit 121.
121.
66 MS. RAO: Okay.
MS. RAO: Okay. If If you
you could
could blow
blow up
up the
the top
top ofof
77| tre email.
the ema.
88 [| ews.
BY MS. mao:
RAO:
99 ©.
Q. And this
And this is
is an
an email
email from
from Rodney
Rodney Hays
Hays atat the
the FBI
FEI
10 ||
10 to other
to other FBI
FB employees;
employees; isis that
that right?
rignez
un
11 A.
A. Yes.
Yes.
12
12 ©.
Q. Okay. Now
Okay. Now II want to take
want to take aa look
look at
at --
-- go
go back
back toto
13 ||
13 pefense Exhibit
Defense Exhibit 144.
144. AndAnd if
if we
we can
can take
take aa look
look again
again at
at
14 ||
14 that third
that third paragraph that we
paragraph that we focused
focused on
on here.
here. And
And we see
we see
15 ||
15 nere, this
here, this reflects
reflects outreach
outreach onon August Sth from
August 9th from Mr. sussmann
Mr. Sussmann
16 |
16 to Rodney.
to Rodney. Understanding
understanding you're
you're looking
looking at
at the
the document
document
17 ||
17 nere, but
here, but do
do you
you think
think that
that refers
refers to
to Rodney
Rodney Hays
Hays that
that was
was
18 ||
18 referenced probably
referenced probably inin the
the other
other email
email because he was
because he was
19 ||
19 nandling aa lot
handling lot of
of communications
communications with
with Mr.
Mr. Sussmann?
Sussmann?
20
20 A.
A. I believe
I believe so.
so.
21
21 Qo.
Q. okay.
Okay.
22
22 And then
And then now
now let's
let's go
go back
back to
to Defense
Defense Exhibit
Exhibit 900.
900.
23 ||
23 so we
So looked at
we looked at Defense
Defense Exhibit
Exhibit 144
144 and
and 145,
145, which
which were both
were both
24 ||
24 on September
on september 22nd.
22nd. And so how
And so how did
did you
you reflect
reflect those
those two
two
25 ||
25 aitferent communications
different communications on on this
this chart?
chart?
2850
2850
1
1 A.
A. So on
So on the
the chart
chart there's
there's aa square
square for
for September
September
2
2 22nd, and
22nd, and it
it has
has three
three shades
shades of
of blue
blue for
for DNC,
DNC, HFA
HFA and
and DCCC.
DCCC.
3
3 Exhibit DX-144,
Exhibit DX-144, which
which is
is the
the FBI
FBI memo,
memo, this
this represents
represents
4
4 Hillary for
Hillary for America, So this
America, so this was
was why
why we
we have
have the
the light
light blue
blue
5
5 HFA one.
HFA one.
6
6 The other
The other two
two are
are from
from the
the DX-145
DX-145 document,
document, which
which
7
7 indicates his
indicates his involvement
involvement with
with the
the DNC
DNC and
and DCCC.
DCCC. So neither
So neither
8
8 of those
of those individual
individual documents
documents has
has all
all three,
three, but
but since
since they
they
9
9 were on
were on the
the same
same date,
date, we included all
we included all three
three in
in this
this
10
10 exhibit.
exhibit.
1
11 Q.
Q. So some
So some of
of the
the boxes,
boxes, and
and this
this is
is an
an example
example of
of
12
12 that, reflect
that, reflect multiple
multiple communications
communications on
on one
one day?
day?
13
13 A.
A. ves.
Yes.
14
14 MS. RRO: II have
MS. RAO: have no
no further
further questions,
questions,
15
15 Mr. Charnov.
Mr. Charnov.
16
16 THE WITNESS:
THE WITNESS: Thank
Thank you.
you.
17
17 MR. KEILTY: Just
MR. KEILTY: Just briefly,
briefly, Your
Your Honor.
Honor. Thanks.
Thanks.
18
18 CROSS-EXAMINATION
CROSS-EXAMINATION OFBRANDON
OF BRANDON CHARNOV
CHARNOV
19
19 BY
BY MR.
MR. KEILTY:
KEILTY:
20
20 @.
Q. Good afternoon,
Good afternoon, sir,
sir, how
how are
are you?
you?
21
21 A.
A. I'm good,
I'm good, good
good afternoon.
afternoon.
22
22 Q.
Q. Great. My
Great. My name
name is
is Mike
Mike Keilty.
Keilty. I'm
I'm aa prosecutor
prosecutor
23
23 for the
for the government.
government. We've
We've never
never spoken
spoken before;
before; isis that
that
24
24 right?
right?
25
25 A.
A. We have
We have not.
not.
2851
2851
1
1 Q.
Q. First of
First of all,
all, congratulations
congratulations on
on law
law school.
school.
2
2 A.
A. Thank you
Thank you very
very much.
much. II appreciate
appreciate that.
that.
3
3 MR. KEILTY: So
MR. KEILTY: So can
can we
we pull
pull up
up Defense
Defense Exhibit
Exhibit
4
4 900, please?
900, please?
5
5 BY
BY MR.
MR. KEILTY:
KEILTY:
6
6 Q.
Q. So this
So this is
is aa pretty detailed chart.
pretty detailed chart. II think
think you'd
you'd
7
7 agree. Right?
agree. Right?
8
8 A.
A. ves.
Yes.
9
9 Q.
Q. A lot
A lot of
of colors
colors and
and shadings.
shadings. Correct?
Correct?
10
10 A.
A. ves.
Yes.
1
11 Q.
Q. And it
And it covers,
covers, what,
what, 1,
1, 2,
2, 3,
3, 4,
4, 55 months;
months; is
is that
that
12
12 correct?
correct?
13
13 A.
A. ves.
Yes.
14
14 Q.
Q. And there's
And there's aa lot
lot of
of days
days in
in there;
there; is
is that
that right?
right?
15
15 A.
A. ves.
Yes.
16
16 Q.
Q. And Ms.
And Ms. Rao
Rao went
went through
through aa number
number of
of different
different
17
17 documents
documents with you
with you of
of different
different communications;
communications; is
is that
that
18
18 right?
right?
19
19 A.
A. ves.
Yes.
20
20 Q.
Q. Okay. Is
Okay. Is the
the date
date of
of September
September 18th,
18th, 2016
2016 listed
listed
21
21 in this
in this --
--
22
22 A.
A. It is
It is not.
not.
23
23 Q.
Q. -- chart?
-- chart?
24
24 A.
A. It is
It is not.
not.
25
25 MR. KEILTY: Can
MR. KEILTY: you pull
Can you up Government's
pull up Government's Exhibit
Exhibit
2852
2852
1
1 1500?
1500? Ms.
Ms. Arsenault, can you
Arsenault, can you just
just go
go down
down for
for me a little
me a little
2
2 bit?
bit?
3
3 BY
BY MR.
MR. KEILTY:
KEILTY:
4
4 @.
Q. sir, is
Sir, is this
this document in your
document in your chart?
chart?
5
5 A.
A. It is
It is not.
not.
6
6 Q.
Q. Can you
Can you go
go to
to --
-- is
is the
the date
date of
of September
September 19th
19th in
in
7
7 your chart,
your chart, sir?
sir?
8
8 A.
A. You'd have
You'd have to
to pull
pull the
the chart
chart back up. I'm
back up. I'm sorry.
sorry.
9
9 There were
There were aa lot
lot of
of dates
dates on
on there.
there.
10
10 Q.
Q. No.
No. II understand.
understand.
1
11 MR. KEILTY: Can
MR. KEILTY: you go
Can you go back
back to
to Defense
Defense Exhibit
Exhibit
12
12 900, please?
900, please?
13
13 THE WITNESS:
THE WITNESS: September 19th
September 19th is
is not
not on
on the
the chart.
chart.
14
14 BY
BY MR.
MR. KEILTY:
KEILTY:
15
15 ©.
Q. And are
And are you
you aware
aware that's
that's the
the day
day when
when Mr.
Mr. Sussmann
Sussmann
16
16 met with the
met with the FBI,
FBI, General
General Counsel
Counsel Jim
Jim Baker?
Baker?
17
17 A.
A. To be
To be honest,
honest, this
this is
is the
the first
first time
time I'm
I'm hearing
hearing
18
18 of this.
of this.
19
19 Q.
Q. Understood.
Understood. Okay.
Okay.
20
20 MR. KEILTY: Can
MR. KEILTY: you pull
Can you up Government's
pull up Government's Exhibit
Exhibit
21
21 2432
243?
22
22 BY
BY MR.
MR. KEILTY:
KEILTY:
23
23 Q.
Q. Have you
Have you seen
seen these
these notes
notes before,
before, sir?
sir?
24
24 A.
A. I don't
I don't believe
believe II have.
have.
25
25 Q.
Q. Okay.
Okay. And II assume
And assume then
then you
you haven't
haven't seen
seen other
other
2853
2853
1
1 notes as
notes as well
well from
from that
that date
date from
from somebody
somebody named
named Trisha
Trisha
2
2 Anderson; is that
Anderson; is that right?
right?
3
3 A.
A. I have
I have not.
not.
4
4 @.
Q. Okay.
Okay. And you
And you --
--
5
5 MR. KEILTY: Government
MR. KEILTY: Exhibit --
Government Exhibit -- I'm
I'm sorry.
sorry.
6
6 Defense Exhibit
Defense Exhibit 900
900 one
one more time.
more time.
7
7 BY
BY MR.
MR. KEILTY:
KEILTY:
8
8 ©.
Q. And you
And you didn't
didn't talk
talk about,
about, with
with Ms.
Ms. Rao,
Rao, any
any
9
9 billing records
billing records from
from September
September 19th,
19th, did
did you?
you?
10
10 A
A. No.
No.
1
11 Q.
Q. This chart
This chart only
only goes
goes to
to October
October of
of 2017;
2017; is
is that
that
12
12 correct?
correct?
13
13 A.
A. That is
That is correct.
correct.
14
14 @.
Q. Okay. Are
Okay. Are you
you aware
aware of
of whether
whether Mr.
Mr. Sussmann
Sussmann went
went
15
15 to the
to the CIA
CIA in
in February
February of
of 2017?
20172
16
16 A.
A. I'm sorry
I'm sorry --
-- the
the question before, did
question before, did you
you say
say 2016
2016
17
17 or '17?
or "172
18
18 Q.
Q. What's the
What's the date
date range
range of
of this
this chart?
chart?
19
19 A.
A. This is
This is 2016.
2016.
20
20 @.
Q. Correct.
Correct.
21
21 A.
A. Yes.
Yes. II just
just wanted to be
wanted to be clear.
clear.
22
22 Q.
Q. So February
So February 2017
2017 does
does not
not appear
appear on
on this
this chart?
chart?
23
23 A.
A. No.
No.
24
24 Q.
Q. Were you
Were you aware
aware that
that Mr.
Mr. Sussmann
Sussmann went to the
went to the CIA
CIA
25
25 in February
in February of
of 2017?
20172
2854
2854
1
1 A.
A. I was
I was not
not aware.
aware.
2
2 Q.
Q. But that
But that definitely doesn't appear
definitely doesn't appear on
on this
this chart?
chart?
3
3 A.
A. Correct.
Correct.
4
4 @.
Q. Okay.
Okay.
5
5 MR. KEILTY: No
MR. KEILTY: further questions
No further questions --
-- II need
need to
to
6
6 finish one.
finish one.
7
7 BY
BY MR.
MR. KEILTY:
KEILTY:
8
8 Q.
Q. You would
You would agree,
agree, II assume
assume --
-- you've
you've seen
seen some
some of
of
9
9 this trial;
this trial; is
is that
that correct?
correct?
10
10 A.
A. I've seen
I've seen only
only snippets
snippets not
not aa ton
ton of
of it.
it.
1
11 Q.
Q. You would
You would agree
agree that
that September
September 19th
19th is
is aa fairly
fairly
12
12 critical date
critical date in
in this
this case
case in
in 2016?
2016?
13
13 A.
A. To be
To be honest,
honest, II don't
don't know
know enough
enough about
about it.
it. II
14
14 don't disagree.
don't disagree. II just
just don't
don't have
have an
an opinion.
opinion.
15
15 MR. KEILTY: That's
MR. KEILTY: That's fair.
fair. Okay.
Okay. Thank
Thank you,
you, Your
Your
16
16 Honor.
Honor.
17
17 THE COURT:
THE COURT: Ms. Rao?
Ms. Rao?
18
18 MS. RRO: Nothing
MS. RAO: Nothing further,
further, Your
Your Honor.
Honor.
19
19 THE COURT:
THE COURT: Thank
Thank you
you very
very much
much for
for your
your
20
20 testimony, sir.
testimony, sir. You can
You can be
be excused.
excused.
21
21 THE WITNESS:
THE WITNESS: Thank you.
Thank you.
22
22 (Bench conference)
(Bench conference)
23
23 THE COURT:
THE COURT: Are the
Are the character
character witnesses
witnesses ready?
ready?
24
24 MR. BERKOWITZ: They
MR. BERKOWITZ: They are,
are, Your
Your Honor.
Honor
25
25 THE COURT:
THE COURT: Okay.
Okay. Why
Why don't
don't we go forward?
we go forward?
2855
2855
1
1 MS. SHAW: Your
MS. SHAW: Your Honor,
Honor, just
just quickly.
quickly. II know
know that
that
2
2 some judges
some judges have
have particular
particular ground
ground rules
rules for
for cross-examining
cross-examining
3
3 character witnesses,
character witnesses, and
and I'm
I'm not
not planning
planning anything
anything
4
4 extensive. But
extensive. But II just
just --
-- it
it would
would obviously
obviously bebe dependent
dependent on on
5
5 what they
what they say.
say. But
But II just
just wanted to know
wanted to know if
if Your
Your Honor
Honor had
had
6
6 any particular
any particular restrictions
restrictions beyond
beyond scope?
scope?
7
7 THE COURT:
THE COURT: None
None beyond scope, but
beyond scope, but we'll
we'll see
see ifif
8
8 there are
there are any
any objections.
objections. ButBut frankly,
frankly, we
we don't get aa lot
don't get lot
9
9 of character
of character witnesses.
witnesses.
10
10 MS. SHAW: II know.
MS. SHAW: know. This
This is
is aa first
first for
for me.
me.
n
11 THE COURT:
THE COURT: All
ALL right.
right. We'll
We'll just
just see
see how
how it
it
12
12 goes.
goes.
13
13 MS. SHAW: All
MS. SHAW: All right.
right.
14
14 (Bench conference
(Bench conference concluded)
concluded)
15
15 THE COURT:
THE COURT: All
All right.
right. Ladies
Ladies and
and gentlemen,
gentlemen, at at
16
16 the beginning
the beginning of
of the
the government's
government's case,
case, when
when II --
-- they
they
17
17 called, II believe,
called, believe, Agent Martin as
Agent Martin as an
an expert
expert witness,
witness, II told
told
18
18 you that
you that there
there were two kinds
were two kinds of
of witnesses.
witnesses. There
There were
were
19
19 experts and
experts and then
then there
there were lay witnesses,
were lay witnesses, who actually know
who actually know
20
20 something about
something about the
the actual
actual evidence
evidence in
in the
the case.
case.
21
21 That was
That a misstatement.
was a misstatement. There's
There's actually
actually aa third
third
22
22 type of
type of witness
witness called
called aa character
character witness, and II believe
witness, and believe
23 || Mr.
23 sussmann is
Mr. Sussmann is prepared
prepared to
to call
call at
at least
least one
one character
character
24
24 witness and
witness and maybe two at
maybe two at this
this time.
time. Okay?
Okay?
25
25 Who will
Who will be presenting the
be presenting the next
next witness?
witness?
2856
2856
1
1 MS. RAO: II will.
MS. RAO: will.
2
2 THE COURT:
THE COURT: Ms.
Ms. Rao,
Rao, you're
you're on.
on.
3
3 MS. RRO: The
MS. RAO: The defense
defense calls
calls Ms.
Ms. Jimma
Jimma
4
4 Elliott-Stevens.
Elliott-Stevens.
5
5 THE COURT:
THE COURT: Okay.
Okay. Step right
Step right up,
up, ma'am.
ma'am.
6
6 All right.
All right. Good afternoon.
Good afternoon.
7
7 THE WITNESS:
THE WITNESS: Good afternoon.
Good afternoon.
8
8 THE COURT:
THE COURT: If you
If you could
could step
step up,
up, make yourself
make yourself
9
9 comfortable, and
comfortable, and remain
remain standing
standing and
and raise
raise your
your right
right hand
hand
10
10 to be
to sworn in
be sworn in by the courtroom
by the courtroom deputy.
deputy.
1
11 DEPUTY CLERK:
DEPUTY CLERK: Do you
Do you solemnly
solemnly affirm
affirm and
and truly
truly
12
12 declare that
declare that the
the testimony
testimony you
you are
are about
about to
to give
give will
will be
be the
the
13
13 truth, the
truth, the whole truth and
whole truth and nothing
nothing but
but the
the truth
truth and
and this
this
14
14 you do
you do under
under the
the pain
pain and
and penalty
penalty of
of perjury?
perjury?
15
15 THE WITNESS:
THE WITNESS: II swear.
swear.
16
16 THE COURT:
THE COURT: Okay.
Okay. Feel free
Feel free to
to remove
remove your
your mask,
mask,
17
17 ma'am, and have
ma'am, and have aa seat.
seat.
18
18 THE WITNESS:
THE Thank you.
WITNESS: Thank you.
19
19 THE COURT:
THE COURT: Okay.
Okay.
20
20
21
21 BY
BY MS.
MS. RRO:
RAO:
22
22 Q.
Q. Good afternoon,
Good afternoon, Ms.
Ms. Elliott
Elliott --
--
23
23 THE COURT:
THE COURT: Move that
Move that mike just aa bit
mike just bit little
little
24
24 closer to
closer to you
you so
so we
we can
can all
all hear
hear what
what you
you have
have to
to say.
say.
25
25 Okay?
Okay?
2857
2857
1
1 THE WITNESS:
THE WITNESS: I'm pretty
I'm pretty loud.
loud.
2
2 THE COURT:
THE COURT: Okay.
Okay.
3
3 [| ey
BY ms.
MS. mao:
RAO:
4
4 ©.
Q. Good afternoon,
Good afternoon, Ms.
Ms. Elliott-Stevens.
Elliott-Stevens.
5
5 A.
A. Good afternoon.
Good afternoon.
6
6 ©.
Q. Can you
Can you state
state and
and spell
spell your
your name
name for
for the
the record?
record?
7
7 A.
A. Sure, it's
Sure, it's Jimma
Jimma Elliott-Stevens.
Elliott-Stevens. TheThe first
first name
name
8 || is
8 is J-I-M-M-A,
s-1-M-u-a, and
and the
the last
1ast name
name is
is Elliott-Stevens,
Eiliote-stevens,
9 || E-L-L-I-O-T-T
9 e-r-r-1-0-r-r hyphen
hyphen S-T-E-V-E-N-S.
s-r-e-v-e-n-s.
10
10 ©.
Q. And Ms.
And Ms. Elliott-Stevens,
Elliott-Stevens, what is your
what is your current
current
1 | role?
11 rote:
12
12 A.
A. I currently
I currently work
work for
for the
the Thomson
Thomson Reuters
Reuters
13 || Corporation.
13 corporation. It's1t's aa global
global corporation
corporation that
that engages
engages in
in news
news
14 || and
14 and other
other things.
things. II amam the
the general
general counsel
counsel of
of our
our entity in
entity in
15 || Switzerland,
15 switzerland, which
which is
is aa holding
holding company
company that
that has
has other
other
16 | entities
16 entities reporting
reporting into
into it.
it.
17
17 I am
I am also
also the
the chief
chief compliance
compliance officer
officer for
for the
the
18 || entire
18 entire enterprise,
enterprise, soso that's
that's globally,
globally, and
and I'm
I'm the
the chief
chief
19 || privacy
19 orivacy officer.
officer.
20
20 ©.
Q. And where
And where are
are you
you currently
currently based?
based?
2
21 A.
A. Iam
I currently based
am currently based in
in Zurich,
Zurich, Switzerland.
Switzerland.
22
22 ©.
Q. And you
And you mentioned
mentioned you
you are
are counsel.
counsel. How
How long
long have
have
23 || you
23 you been
been aa lawyer?
1awyer>
2
24 A.
A. Twas
I sworn in
was sworn in in
in 2005.
2005.
25
25 @.
Q. Okay. And
Okay. And just
just briefly,
briefly, for
for the
the jury,
jury, can
can you
you
2858
2858
1
1 take us
take us from
from high
high school
school to
to sort
sort of
of present
present and
and give
give us
us aa
2
2 sense of
sense of your
your educational
educational and
and employment
employment history?
history?
3
3 A.
A. sure. II am
Sure. amaa native
native of
of Washington,
Washington, D.C.,
D.C., born
born and
and
4
4 raised. II went
raised. to the
went to the model academic Benjamin
model academic Benjamin Banneker
Banneker
5
5 senior high
senior high school,
school, which
which is
is an
an all-economic
all-economic high
high school.
school.
6
6 From there,
From there, II enlisted
enlisted in
in the
the United
United States
States Marine
Marine
7
7 Corps in
Corps in aa college
college and
and Marine program. II went
Marine program. went to
to aa private
private
8
8 school in
school in Michigan,
Michigan, where
where II ultimately
ultimately left
left and
and ended
ended up
up
9
9 transferring to
transferring to the
the University
University ofof Maryland
Maryland later
later and
and
10
10 graduated from
graduated from there
there and
and undergrad.
undergrad.
n
11 I then
I then went
went straight
straight onon to
to the
the George
George Washington
Washington
12
12 University Law
University Law School.
School. II also
also did a stent
did a stent at
at Oxford
Oxford
13
13 University in
University in England
England studying
studying human
human rights
rights law,
law, all
all while
while
14
14 working at
working at the
the Department
Department ofof Justice
Justice at
at the
the time.
time. SoSo there
there
15
15 was aa lot
was lot going
going on.
on.
16
16 ©.
Q. And you
And you mentioned
mentioned the
the Department
Department ofof Justice.
Justice. YouYou
17
17 subsequently left
subsequently left the
the Department
Department ofof Justice?
Justice?
18
18 A.
A. Idid.
I did. I I stayed
stayed at
at the
the Department
Department ofof Justice
Justice for
for
19
19 several years.
several years. II always
always say
say that's
that's the
the agency
agency that
that gave
gave me
me
20 || my
20 my wings.
wings. II then
then went
went on
on to
to the
the FDA,
FDA, the
the Food
Food and
and Drug
Drug
21
21 Administration, then the
Administration, then the U.S.
U.S. Department
Department of
of Agriculture,
Agriculture,
22
22 veterans affairs
veterans affairs and
and II finished
finished up
up --
-- or
or rounded
rounded up
up my time
my time
23
23 in government
in government ---- II went to Social
went to Social Security
Security Administration
Administration
24
24 and then
and then rounded
rounded my
my time
time at
at the
the Department
Department ofof Treasury
Treasury
25
25 before II left
before left to
to go
go to
to private industry.
private industry.
2859
2859
1
1 ©.
Q. And do
And do you
you know
know Michael
Michael Sussmann?
Sussmann?
2
2 A.
A. Ido.
I do.
3
3 ©.
Q. Okay. And
Okay. And how
how did
did you
you come
come to
to know
know him?
him?
4
4 A.
A. I came
I came to
to meet Michael in
meet Michael in the
the early
early '90s.
'90s. II was
was
5
5 assigned to
assigned to him
him as
as an
an admin
admin assistant.
assistant. II was
was an
an admin
admin
6
6 assistant at
assistant at Justice
Justice while
while II was
was going
going through
through school.
school. AndAnd
7
7 I1 was
was assigned
assigned to to him
him and
and another
another Special
Special Assistant
Assistant atat the
the
8
8 time and
time and ultimately
ultimately aa couple
couple more,
more, but yeah.
but yeah.
9
9 ©.
Q. And how
And how long
long were you Mr.
were you Sussmann's assistant?
Mr. Sussmann's assistant?
10
10 A.
A. Probably about
Probably about two
two to
to three
three years.
years.
n
11 ©.
Q. Okay. And
Okay. And generally
generally speaking,
speaking, what
what was
was your
your
12
12 relationship like?
relationship like? How
How was
was he
he as
as aa boss?
boss?
13
13 A.
A. He was
He was aa great boss. He
great boss. He was
was aa little
little demanding.
demanding.
14
14 He worked
He really hard.
worked really hard. II worked
worked really
really hard.
hard. II had
had
15
15 something to
something to prove
prove as
as well,
well, and
and he
he was nice and
was nice and kind.
kind. YouYou
16
16 know, we
know, we had
had aa pretty
pretty good
good working relationship.
working relationship.
17
17 ©.
Q. And did
And did at
at some
some point
point you
you also
also develop
develop aa personal
personal
18
18 relationship?
relationship?
19
19 A.
A. Yes. II had
Yes. had aa unique
unique situation
situation while
while II was
was in
in
20
20 school. II had
school. had aa very
very young
young child.
child. AtAt the
the time,
time, my
my son
son was
was
21
21 three, and
three, and my office was
my office was incredibly
incredibly understanding.
understanding. And so II
And so
22
22 used to
used to bring
bring my
my son
son to
to the
the office
office quite
quite aa bit. And my
bit. And my son,
son,
23
23 who is
who is completely
completely gregarious,
gregarious, got
got to
to know
know just
just about
about all
all of
of
24
24 the Special
the Special Assistants and the
Assistants and the Deputy
Deputy Assistant
Assistant Attorney
Attorney
25
25 Generals at
Generals at that
that time.
time.
2860
2860
1
1 So he
So he took
took aa strong
strong liking
liking to
to Michael and vice
Michael and vice
2
2 versa.
versa. And so he
And so he spent
spent aa lot
lot of
of time
time in
in Michael's
Michael's office.
office.
3
3 So from
So from there,
there, we
we kind
kind of
of forged
forged aa --
-- II would
would say
say it
it was
was
4
4 still an
still an employment
employment relationship
relationship forfor sure.
sure. But
But it
it did,
did,
5
5 eventually, turn
eventually, turn into
into more
more of
of aa friendship.
friendship.
6
6 ©.
Q. And, you
And, you know,
know, what
what kind
kind of
of role,
role, you
you know,
know, did
did hehe
7
7 play in
play in your
your son's
son's life,
life, you
you know,
know, beginning then and
beginning then and over
over
8
8 time?
time?
9
9 A.
A. Yeah. It
Yeah. It was
was --
-- he
he was
was really
really instrumental
instrumental in in mymy
10
10 son's upbringing.
son's upbringing. At the time,
At the time, II was
was separated
separated and
and going
going
n
11 through aa divorce,
through divorce, and
and Michael
Michael would -- he
would -- he took
took an
an interest
interest
12
12 in my
in son. He
my son. He had
had other
other friends
friends that
that had
had kids.
kids. AndAnd so
so he
he
13
13 would allow
would allow my son to
my son to join
join him
him on
on trips
trips and
and to
to amusement
amusement
14
14 parks and
parks and different
different events,
events, which
which certainly
certainly my son
my son
15
15 appreciated.
appreciated.
16
16 And even
And even as
as my
my son
son grew
grew into
into his
his teen
teen years,
years, they
they
17
17 stayed really
stayed really closely
closely connected.
connected. So So we
we really
really refer
refer toto
18 || michael
18 Michael asas my son's Godfather.
my son's Godfather.
19
19 ©.
Q. And what
And what about
about you?
you? Did
Did you
you also
also continue
continue to to have
have
20
20 a relationship
a relationship with him, you
with him, you know,
know, aside
aside from
from the
the
21
21 relationship he
relationship he had
had with
with your
your son?
son?
22
22 A.
A. Yes, definitely.
Yes, definitely. So So II was
was assigned
assigned toto the
the
23
23 criminal division
criminal division atat that
that time
time in
in the
the front
front office,
office, butbut II
24
24 went to
went to aa different
different part
part of
of the
the criminal
criminal division
division toto our
our
25
25 internal security
internal security section
section and
and started
started working
working there.
there. So So atat
2861
2861
1
1 the time,
the time, II was
was applying
applying to
to law
law schools,
schools, and
and Michael
Michael was,
was,
2
2 again, he
again, he was
was my
my confidant.
confidant.
3
3 He --
He -- eventually
eventually it
it turned
turned into
into aa very
very strong
strong
4
4 mentorship, giving me
mentorship, giving a lot
me a lot of
of guidance and direction
guidance and direction as
as II
5
5 got into
got into law
law school
school and
and had
had to
to make decisions beyond
make decisions beyond that.
that.
6 [| ana
6 then, once
And then, once II became
became aa lawyer,
lawyer, II would
would pretty
pretty much
much say,
say,
7
7 every move
every move II made
made careerwise,
careerwise, II didn't
didn't make
make aa move
move without
without
8
8 him, without
him, without consulting
consulting with
with him
him or
or discussing
discussing it.
it. And so
And so
9
9 that meant
that meant aa lot
lot to
to me.
me.
10
10 ©.
Q. And what
And what about
about professionally?
professionally? We We talked
talked aa little
little
n
11 bit about
bit about the
the time
time you
you worked with him
worked with him at
at the
the Department
Department ofof
12
12 Justice. Have
Justice. Have you
you had
had the
the opportunity
opportunity toto work
work with him
with him
13
13 since then?
since then?
14
14 A.
A. Yes. So
Yes. So once
once II left
left the
the federal
federal government space
government space
15
15 and II went
and went to
to private
private industry,
industry, II was
was able
able to
to engage
engage outside
outside
16
16 counsel for
counsel for aa few
few companies.
companies. AndAnd so
so Michael
Michael was
was working
working at
at
17
17 Perkins Coie
Perkins Coie atat the
the time,
time, and
and that
that was one of
was one of the
the firms
firms that
that
18
18 II brought
brought in
in when
when II was
was with
with aa company
company called
called N4,
M4, which
which was
was
19
19 a technology
a technology company.
company. II also
also brought
brought the
the firm,
firm, rather,
rather, into
into
20
20 Thomson Reuters
Thomson Reuters where
where II am
am now,
now, and
and Michael
Michael was
was the
the
21
21 relationship partner.
relationship partner.
22
22 ©.
Q. And what
And what was he like
was he like as,
as, you
you know,
know, aa lawyer
lawyer and
and
23
23 outside counsel?
outside counsel? Tables
Tables have
have turned
turned aa little
little bit,
bit, it
it seems.
seems.
24
24 A.
A. well, definitely.
Well, definitely. We We definitely
definitely used
used to
to joke
joke that
that
25
25 you now
you now work
work for
for me.
me. But
But he
he was
was incredibly
incredibly trustworthy.
trustworthy.
2862
2862
1
1 One of
One of the
the things
things --
-- II worked in aa space
worked in space where
where we have aa lot
we have lot
2
2 of high-end
of high-end law
law firms,
firms, and
and this
this firm
firm was
was new
new to
to the
the company.
company.
3
3 So they
So they had
had aa bit
bit of
of proving
proving to
to do.
do.
4
4 So II kind
So kind of
of let
let them
them run
run their
their own
own show
show and
and have
have
5
5 to impress
to impress the
the chief
chief legal
legal officer
officer on
on his
his own.
own. And he was
And he was
6
6 able to
able to do
do that
that on
on both occasions, even
both occasions, even at
at the
the former
former
7
7 company, whereby,
company, whereby, even
even when
when II left
left that
that company,
company, they
they
8
8 continued the
continued the relationship
relationship with Michael and
with Michael and the
the firm
firm until
until
9 || nv
9 company came
my company came to
to really
really rely
rely on
on him,
him, his
his judgment,
judgment, thethe
10
10 lawyers that
lawyers that represented
represented the
the firm
firm and
and that
that he
he oversaw
oversaw so,
so,
n
11 yeah.
yeah.
12
12 ©.
Q. And then,
And then, just
just finally,
finally, in
in the
the almost
almost 3030 --
-- if
if my
my
13 || math
13 is right
math is right --
-- years
years you've
you've known
known Mr.
Mr. Sussmann,
Sussmann, what's
what's
14
14 your overall
your overall impression
impression of
of his
his reputation
reputation for
for honesty
honesty and
and
15
15 truthfulness?
truthfulness?
16
16 A.
A. Yes, it
Yes, it has
has been
been almost
almost 30
30 because
because mymy son
son was
was
17
17 three at
three at the
the time,
time, and
and my son is
my son is 33
33 today.
today. So So that's
that's been
been aa
18
18 long time.
long time.
19
19 As long
As long as
as I've
I've known
known Michael
Michael --
-- II mean,
mean, as
as II
20
20 said, he
said, he was
was pretty
pretty instrumental
instrumental inin my life, and
my life, and he's
he's come
come
21
21 to know
to know my family. I've
my family. I've come
come to
to know
know his
his family.
family. He's
He's
22
22 always been
always someone whose
been someone whose integrity
integrity has
has been
been beyond
beyond
23
23 reproach. You
reproach. You know,
know, II know
know him
him as,
as, again,
again, an
an honest,
honest,
24
24 hard-working, man
hard-working, man of
of faith.
faith. SoSo I've
I've never
never had
had any
any issues
issues
25
25 with his
with his character
character oror his
his integrity.
integrity.
2863
2863
1
1 MS. RAO: Thank
MS. RAO: Thank you
you so
so much,
much, Ms. Elliott-Stevens.
Ms. Elliott-Stevens.
2
2 No further
No further questions.
questions.
3
3 THE WITNESS:
THE WITNESS: OfOf course.
course.
4
4 THE COURT:
THE COURT: Counsel.
Counsel. Real
Real quick.
quick.
5
(Bench conference)
6
6 THE COURT:
THE COURT: The only
The only ground
ground rule
rule in
in this
this show
show is
is
7
7 don't ask
don't ask her
her whether
whether her
her opinion
opinion of
of him
him would
would change
change if
if he
he
8
8 were guilty
were guilty of
of the
the crime.
crime. Okay?
Okay?
9
9 MS. SHAW: Understood.
MS. SHAW: Understood.
10
concluded)
1
11 CROSS-EXAMINATION
CROSS-EXAMINATION OF
OF JIMMA
JIMMA ELLIOTT-STEVENS
ELLIOTT-STEVENS
12
12 BY
BY MS. SHAW:
MS. SHAW:
13
13 @.
Q. Good afternoon.
Good afternoon.
14
14 A.
A. Good afternoon.
Good afternoon.
15
15 Q.
Q. My name
My name is
is Brittany
Brittany Shaw.
Shaw. Along
Along with
with my
my
16
16 colleagues, II represent
colleagues, represent the
the United
United States
States in
in this
this matter.
matter.
17
17 It's nice
It's nice to
to meet
meet you.
you.
18
18 A.
A. Nice to
Nice to meet
meet you.
you.
19
19 Q.
Q. I don't
I don't have
have many questions for
many questions for you.
you.
20
20 A.
A. Okay.
Okay.
21
21 @.
Q. But, you
But, you know,
know, it's
it's clear
clear that
that you
you and
and
22
22 Mr. Sussmann are
Mr. Sussmann are good
good friends,
friends, and
and you've
you've been
been good
good friends
friends
23
23 for many
for years. Right?
many years. Right? You
You are
are not
not here
here because
because you
you know
know
24
24 anything about
anything about the
the case.
case. You are
You are just
just here
here as
as aa friend.
friend.
25
25 And you
And you haven't
haven't --
-- you
you have
have to
to say
say yes
yes or
or no
no just
just for
for the
the
2864
2864
1
1 record.
record.
2
2 A.
A. That's correct.
That's correct.
3
3 Q.
Q. We are
We are both
both nodding
nodding to
to each
each other.
other.
4
4 A.
A. Right.
Right.
5
5 @.
Q. So you
So you haven't
haven't sat
sat through
through the
the evidence.
evidence. Right?
Right?
6
6 A.
A. No. II actually
No. actually --
-- no.
no. II don't
don't know
know much about
much about
7
7 the case.
the case.
8
8 ©.
Q. And the
And the jury
jury has
has sat
sat through
through the
the evidence,
evidence, but
but you
you
9
9 haven't been
haven't been here
here while
while they
they have
have been
been here.
here. Right?
Right?
10
10 A.
A. That's correct.
That's correct.
1
11 Q.
Q. Thank you
Thank you very
very much.
much.
12
12 A.
A. sure.
Sure.
13
13 THE COURT:
THE COURT: NoNo redirect,
redirect, II take
take it?
it?
14
14 MS. RRO: No,
MS. RAO: No, Your
Your Honor.
Honor.
15
15 THE COURT:
THE COURT: Okay.
Okay. Thank
Thank you
you very
very much
much for
for your
your
16
16 testimony, ma'am.
testimony, You are
ma'am. You are excused.
excused. Have
Have aa great
great day.
day.
17
17 THE WITNESS:
THE Thank you.
WITNESS: Thank you.
18
18 MS. YAO: Good
MS. YAO: Good afternoon.
afternoon.
19
19 THE COURT:
THE COURT: Good
Good afternoon.
afternoon.
20
20 MS. YAO: The
MS. YAO: The defense
defense calls
calls Marty
Marty Stansell-Gamm
Stansell-Gamn to
to
21
21 the stand.
the stand.
22
22 THE COURT:
THE COURT: Very well.
Very well.
23
23 Welcome, ma'am.
Welcome, ma'am. Please step
Please step right
right up.
up. If you
If you
24
24 could remain
could remain standing,
standing, raise
raise your
your right
right hand
hand and
and remove
remove your
your
25
25 mask.
mask.
2865
2865
1
1 DEPUTY CLERK:
DEPUTY CLERK: Do you
Do you solemnly
solemnly affirm
affirm and
and truly
truly
2
2 declare that
declare that the
the testimony
testimony you
you are
are about
about to
to give
give will
will be
be the
the
3
3 truth, the
truth, the whole
whole truth
truth and
and nothing
nothing but the truth
but the truth and
and this
this
4
4 you do
you do under
under the
the pain
pain and
and penalty
penalty of
of perjury?
perjury?
5
5 THE WITNESS:
THE WITNESS: II do.
do.
6
6 THE COURT:
THE COURT: Okay.
Okay. Please have
Please have aa seat,
seat, ma'am.
ma'am.
7
7 THE WITNESS:
THE WITNESS: Thank you.
Thank you.
8
8
9
9 BY
BY MS.
MS. YAO:
YAO:
10
10 Q.
Q. Could you
Could you please
please state
state and
and spell
spell your
your name
name for
for the
the
1
11 record?
record?
12
12 A.
A. My name
My name is
is Martha
Martha Stansell-Gamm.
Stansell-Gamm. Last name
Last name is
is
13
13 S-T-A-N-S-E-L-L hyphen
S-T-A-N-S-E-L-L hyphen G-A-M-}.
G-A-M-M.
14
14 Q.
Q. What do
What do you
you currently
currently do?
do?
15
15 A.
A. I am
I am retired
retired from
from the
the Department
Department of
of Justice.
Justice.
16
16 Q.
Q. How long
How long have
have you
you been
been retired
retired for?
for?
17
17 A.
A. Oh, goodness,
Oh, goodness, over
over 14
14 years.
years.
18
18 Q.
Q. That sounds
That sounds great.
great.
19
19 A.
A. Its.
It is.
20
20 @.
Q. We're going
We're going to
to start
start with
with your
your background.
background. Can
Can
21
21 you please
you please briefly
briefly walk through your
walk through your legal
legal career?
career?
22
22 A.
A. sure. II spent
Sure. spent aa couple
couple of
of years
years in
in Michigan
Michigan in
in
23
23 practice and
practice and then,
then, in
in 1980,
1980, II was
was commissioned
commissioned in
in the
the United
United
24
24 Stated Air
Stated Force as
Air Force as aa judge
judge advocate.
advocate.
25
25 ©.
Q. And what
And what does it mean
does it to be
mean to be aa judge
judge advocate?
advocate?
2866
2866
1
1 A.
A. A judge
A judge advocate
advocate is
is an
an active
active duty
duty lawyer
lawyer inin the
the
2 | air
2 Force.
Air Force.
3
3 ©.
Q. And what
And what did you do
did you after that?
do after that?
4
4 A.
A. My first
My first assignment
assignment was
was in
in Germany.
Germany. II spent
spent four
four
5
5 years in
years in Germany,
Germany, half
half in
in prosecution,
prosecution, half
half in
in defense.
defense.
6 [| after
6 Germany, II was
After Germany, was selected
selected toto teach
teach at
at the
the Air
Air Force
Force
7
7 judge advocate
judge advocate school.
school. II was
was on
on the
the faculty
faculty there
there for
for three
three
8
8 years. And
years. And then
then was
was given
given permission
permission toto go
go to
to Harvard
Harvard for
for aa
9
9 year for
year for an
an advanced
advanced degree
degree in
in international
international law.
law. My last
My last
10
10 position in
position in the
the Air Force was
Air Force was three
three years
years in
in Hawaii
Hawaii asas the
the
n
11 chief of
chief of international
international lawlaw for
for the
the Air Forces in
Air Forces in the
the Pacific
Pacific
12
12 region.
region.
13
13 ©.
Q. And so,
And so, II take
take it,
it, you
you left
left Hawaii
Hawaii and
and came
came toto the
the
14
14 Department of
Department of Justice;
Justice; isis that
that right?
right?
15
15 A.
A. Yes. It
Yes. It was time to
was time to stop
stop moving
moving around
around so
so much.
much.
16
16 ©.
Q. And what
And what were you doing
were you doing at
at the
the Department
Department ofof
17
17 Justice?
Justice?
18
18 A.
A. I got
I got very
very lucky.
lucky. II went into the
went into the Department
Department of of
19
19 Justice just
Justice just as
as the
the very
very first
first computer
computer crime
crime unit
unit was
was being
being
20
20 formed. There
formed. There were five of
were five of us.
us. ItIt was
was 1991.
1991. This
This is
is
21
21 before the
before the World Wide Web
World Wide Web existed.
existed. There
There were
were very
very few
few
22
22 experts in
experts in government.
government.
23
23 And so
And so our
our first
first task,
task, really,
really, was
was to
to just
just try
try to
to
24
24 figure out
figure out what we were
what we supposed to
were supposed to do,
do, and
and we
we consulted
consulted
25
25 every expert
every expert wewe could
could find,
find, experts
experts inin the
the agencies,
agencies, inin
2867
2867
1
1 universities, in
universities, in companies,
companies, who
who could
could help
help us
us understand
understand the
the
2
2 nature and
nature and scope
scope of
of the
the computer
computer crime
crime problem, where they
problem, where they
3
3 expected it
expected it to
to go, and what
go, and we ought
what we ought to
to be
be doing to prepare.
doing to prepare.
4
4 So we
So we quickly
quickly figured
figured out
out this
this was
was going
going to
to be
be an
an
5
5 interdisciplinary problem.
interdisciplinary problem. We needed to
We needed to be
be able
able to
to look
look at
at
6
6 legislation, figure
legislation, figure out
out what
what needed
needed to
to be changed. We
be changed. had
We had
7
7 to learn
to learn aa lot
lot about
about how
how to
to investigate
investigate these
these cases
cases with
with the
the
8
8 agencies, because,
agencies, because, ifif you
you think
think about
about it,
it, the
the global
global network
network
9
9 was really
was really our
our crime
crime scene.
scene. SoSo we
we had
had to
to learn
learn where
where the
the
10
10 evidence lay
evidence lay and
and how
how procedurally
procedurally toto obtain
obtain it.
it.
n
11 We also
We also had
had to
to work
work internationally.
internationally. As As we all
we all
12
12 know now,
know now, trivially
trivially easy
easy for
for criminals
criminals toto hop
hop around
around the
the
13
13 world, but
world, that's not
but that's not allowed
allowed for
for prosecutors
prosecutors and
and agents.
agents.
14
14 So we
So had to
we had to find
find counterparts
counterparts overseas
overseas who
who could
could help
help us.
us.
15
15 Of course,
Of course, they
they were
were at
at the
the very
very beginning
beginning ofof this
this as
as well.
well.
16
16 We had
We had to
to find
find AUSAs
AUSAS who could and
who could and would
would help
help us
us
17
17 investigate cases
investigate cases very
very quickly
quickly because the evidence
because the evidence is
is often
often
18
18 femoral. So
femoral. So we
we were
were in
in the
the network
network building
building business,
business, but
but
19
19 our network
our network was
was human.
human.
20
20 ©.
Q. So how
So how long
long were
were you
you in
in that
that position for?
position for?
21
21 A.
A. We were
We were aa unit
unit for
for about
about five
five years
years growing
growing
22
22 larger. And
larger. And then
then the
the Department
Department promoted
promoted us
us to
to become
become aa
23
23 section. So
section. So we
we became
became the
the Computer Crime and
Computer Crime and Intellectual
Intellectual
24
24 Property Section,
Property Section, otherwise
otherwise known
known as
as CCIPS.
CCIPS. AndAnd Scott
Scott
25
25 Charney, who
Charney, who had
had been
been the
the chief
chief of
of our
our unit,
unit, became
became the
the
2868
2868
1
1 section chief
section chief and
and II was
was his
his deputy.
deputy. II think
think that's
that's where
where we
we
2
2 were when
were when Michael
Michael Sussmann
Sussmann was hired into
was hired into the
the section.
section.
3
3 ©.
Q. Okay.
Okay.
1
4 A.
A. And just
And just to
to complete,
complete, Scott
Scott left
left in
in about
about 1999,
1999,
5
5 and II finished
and finished out
out my time in
my time in the
the Department
Department asas the
the chief
chief of of
6
6 the section.
the section.
7
7 Q.
Q. Okay. So
Okay. So you
you were
were both
both Deputy
Deputy Chief
Chief and
and then
then
8
8 later you
later you became
became chief
chief of
of CCIPS?
CCIPS?
9
9 A.
A. That's right.
That's right.
10
10 ©.
Q. And you
And you anticipated
anticipated my my question,
question, dodo you
you know
know
n
11 Michael Sussmann?
Michael Sussmann?
12
12 A.
A. Yes, of
Yes, of course.
course.
13
13 ©.
Q. And how
And how did
did you
you come
come to
to know
know him?
him?
14
14 A.
A. scott and
Scott and II found
found Michael
Michael in
in the
the front
front office,
office, as as
15
15 we call
we call it,
it, the
the criminal
criminal division's
division's staff.
staff. He He was,
was, asas II
16
16 recall, working
recall, working for
for Mark Richard. Mark
Mark Richard. was the
Mark was the Deputy
Deputy
17 || assistant
17 Attorney General
Assistant Attorney General who supervised all
who supervised all of
of the
the
18
18 division's international
division's international work.
work.
19
19 So that
So that was
was Michael's
Michael's particular
particular experience,
experience, and
and
20
20 it was
it also his
was also his interest.
interest. So So we
we knew
knew we
we were
were going
going toto need
need
21
21 a lot
a lot more
more of
of that,
that, so
so we were very
we were lucky to
very lucky to get
get him.
him.
22
22 ©.
Q. And do
And do you
you recall
recall what
what Mr.
Mr. Sussmann
Sussmann was
was doing
doing in in
23
23 the section
the section with
with you?
you?
24
24 A.
A. We were
We were too
too small
small to
to have
have anybody
anybody specialize
specialize inin
25
25 anything. So
anything. So all
all the
the lawyers
lawyers answered
answered questions
questions from
from AUSAs.
AUSAs.
2869
2869
1
1 Our primary
Our primary mission was, in
mission was, in growing
growing the
the program,
program, to
to support
Support
2
2 the AUSAs
the nationwide and
AUSAs nationwide and whatever
whatever it
it was
was that
that they
they needed
needed
3
3 from us.
from us. So everybody
So everybody did that.
did that. Everybody at
Everybody at various
various times
times
4
4 worked on
worked on legislation.
legislation.
5
5 The legislation
The legislation that
that we did, II called
we did, called it
it blank
blank
6
6 screen work.
screen work. We were
We were working
working from
from nothing.
nothing. And so
And so we
we
7
7 needed to
needed to come
come up
up with
with constructs
constructs and
and then
then have
have everybody
everybody
8
8 throw tomatoes
throw tomatoes at
at it
it to
to make sure that
make sure that those
those ideas
ideas held
held up.
up.
9
9 So everybody
So everybody participated
participated in
in that.
that.
10
10 Everybody assisted
Everybody assisted with
with training.
training. We did
We did aa lot
lot of
of
n
11 training domestically,
training domestically, AUSAs on the
AUSAs on the technology,
technology, agents
agents on
on
12
12 the very
the very complicated
complicated electronic
electronic search
search and
and seizure
seizure law
law in
in
13
13 which we
which we had
had become
become the
the experts.
experts. And we
And we also
also had
had all
all of
of the
the
14
14 international work.
international work. So everybody
So everybody did
did everything.
everything.
15
15 ©.
Q. And what
And what was your professional
was your professional relationship
relationship with
with
16
16 him like?
him like?
17
17 A.
A. Iwas
I very interested
was very interested in
in getting
getting toto know
know everybody
everybody
18
18 on the
on the staff.
staff. And to the
And to the extent
extent that
that they
they wanted
wanted toto tell
tell me
me
19
19 who they
who they were
were or
or anything
anything about
about them,
them, II was
was always
always
20
20 interested in
interested in knowing
knowing that.
that.
21
21 Somehow II found
Somehow found out
out that
that Michael,
Michael, asas aa young
young man,
man,
22
22 had had
had had aa tragedy
tragedy in
in his
his life.
life. AsAs II remember
remember it,
it, his
his family
family
23
23 had been
had been vacationing
vacationing together,
together, and
and there
there was
was aa horrible
horrible
24
24 hotel fire.
hotel fire. AndAnd all
all the
the members
members of
of his
his family
family escaped
escaped
25
25 except for
except for his
his father,
father, who
who died in the
died in the fire.
fire. II think
think
2870
2870
1
1 Michael was in
Michael was in his
his early 20s when
early 20s when that
that happened.
happened.
2
2 Not long
Not long after
after he
he came
came to
to the
the section,
section, as
as II
3
3 remember it,
remember it, he
he had
had another
another challenge.
challenge. HisHis older
older sister,
sister,
4
4 Marjorie, developed aa brain
Marjorie, developed brain tumor.
tumor. And she was
And she was being
being
5
5 treated at
treated at Sloan
Sloan Kettering.
Kettering. TheThe family
family --
-- she
she had
had young
young
6
6 children. The
children. The family
family needed
needed help.
help.
7
7 Michael asked
Michael asked us
us for
for permission
permission toto go
go up
up to
to New
New
8
8 Jersey and
Jersey and New York and
New York and give
give help
help to
to Marjorie,
Marjorie, her
her family,
family,
9
9 get her
get her to
to Sloan
Sloan Kettering,
Kettering, support
support his
his mother.
mother. OfOf course
course
10
10 we gave
we him all
gave him all of
of the
the time
time he
he asked
asked for
for and
and needed.
needed.
n
11 I remember,
I remember, at
at one
one point
point after
after Marjorie
Marjorie had
had been
been
12
12 ill for
ill for aa long
long time,
time, she
she came
came to
to the
the section
section to
to thank
thank us
us for
for
13
13 allowing her
allowing her brother
brother to
to be
be with her. So
with her. So II would say
would say
14
14 Michael, more
Michael, more than
than his
his contemporaries,
contemporaries, hadhad been tempered by
been tempered by
15
15 tragedy, which
tragedy, which made him more
made him mature in
more mature in all
all kinds
kinds of
of ways
ways
16
16 that you
that you might
might notice
notice even
even if
if you
you didn't
didn't know
know those
those stories.
stories.
17
17 But it
But it also
also interestingly
interestingly opened
opened him
him to
to joy.
joy. AndAnd
18
18 II remember
remember when he met
when he met Apple, his wife,
Apple, his wife, who
who swept
swept him
him off
off
19
19 his feet,
his feet, he
he was
was one
one of
of the
the most ebullient fellows
most ebullient fellows I'd
I'd ever
ever
20
20 seen when
seen when they
they were
were married. And together,
married. And together, they
they have
have shared
shared
21
21 the joy
the joy of
of their
their three
three terrific
terrific children.
children.
22
22 So Michael
So Michael has
has known
known life's
life's pain.
pain. HeHe has
has known
known
23
23 life's beauty.
life's beauty. And
And II would
would say
say it
it has
has centered
centered him.
him. HeHe is
is
24
24 less inclined
less inclined toto be
be moved by life's
moved by life's smaller
smaller vicissitudes.
vicissitudes.
25
25 He is
He is aa mature
mature person.
person.
2871
2871
1
1 ©.
Q. I want
I want to
to turn
turn aa little
little bit
bit back
back to
to your
your work
work
2
2 relationship with
relationship with him.
him. Can
Can you
you describe
describe at at aa high
high level
level
3
3 what kinds
what kinds ofof projects
projects hehe was
was working
working on?
on?
1
4 A.
A. Un-huh, certainly.
Uh-huh, certainly.
5
5 One of
One of the
the most
most important
important projects
projects that
that Michael
Michael
6
6 worked on
worked on was
was the
the G8
G8 technology
technology subgroup.
subgroup. It It was
was the
the G8
G8 in
in
7
7 those days,
those days, now
now returned
returned to
to the
the G7.
G7. But
But the
the Heads
Heads of
of State
State
8
8 of the
of the countries
countries decided
decided that
that they
they needed
needed toto create
create aa
9
9 subgroup to
subgroup to advise
advise them
them and
and to
to make progress against
make progress against
10
10 computer-related crime.
computer-related crime.
n
11 At the
At the very
very beginning,
beginning, as
as II remember
remember it,
it, Scott
Scott
12
12 Charney chaired
Charney chaired the
the meeting, and II was
meeting, and the head
was the head of
of the
the U.S.
U.S.
13
13 delegation. That
delegation. That became
became unworkable
unworkable fairly
fairly quickly.
quickly. We We
14
14 needed to
needed to promote
promote and
and develop
develop other
other people
people toto do
do that
that work.
work.
15 || And
15 Michael was
And Michael was aa perfect
perfect fit
fit for
for that.
that. It It was
was intensely
intensely
16
16 legal, in
legal, in some
some ways, but it
ways, but it was
was also
also diplomatic,
diplomatic, because
because
17
17 there were
there were these
these eight
eight delegations coming from
delegations coming from very
very
18
18 different legal
different legal perspectives
perspectives andand very
very different
different experiences
experiences
19
19 with the
with the technology.
technology.
20
20 The thing
The thing that
that was
was so
so great
great about
about the
the G8
G8 subgroup
subgroup
21
21 was that
was that it
it decided
decided to
to be practically oriented.
be practically oriented. AndAnd one
one of
of
22
22 the most
the important things
most important things it
it did,
did, and
and II know
know that
that Michael
Michael
23
23 shepherded this
shepherded this project, was they
project, was they created
created aa 24/7
24/7 response
response
24
24 network. It
network. It is
is one
one of
of the
the biggest
biggest problems
problems we we were having
were having
25
25 was getting
was getting assistance
assistance overseas
overseas quickly
quickly inin trying
trying toto trace
trace
2872
2872
1
1 the source
the source of
of aa computer
computer penetration.
penetration.
2
2 So this
So this task
task fell
fell to
to the
the G8
G8 subgroup,
subgroup, and
and they
they
3
3 created aa system
created system in
in which
which every
every country
country agreed
agreed to
to have
have
4
4 somebody on
somebody on duty
duty or
or reachable
reachable on
on duty
duty all
all the
the time
time in
in order
order
5
5 to gather
to evidence to
gather evidence to assist
assist with
with cases
cases that
that came
came from
from
6
6 overseas.
overseas. This was
This was very
very important
important for
for us.
us. It was
It also very
was also very
7
7 important for
important for other
other countries,
countries, because a lot
because a lot of
of the
the data
data
8
8 that they
that they were
were seeking
seeking was in systems
was in systems in
in the
the U.S.
U.S.
9
9 ©.
Q. So when
So when did
did Mr.
Mr. Sussmann
Sussmann begin working with
begin working with you?
you?
10
10 A.
A. I believe,
I believe, II would guess it
would guess it was
was around
around '97,
'97, '96
'96 or
or
n
11 197. And
'97. And we
we would
would have
have mentored him to
mentored him to take
take the
the leading
leading
12
12 role in
role in leading
leading the
the U.S.
U.S. delegation
delegation toto the
the G7.
G7.
13
13 But this
But this --
-- just
just as
as an
an ancillary
ancillary matter, the other
matter, the other
14
14 big international
big international project
project that
that we had was
we had was the
the negotiation
negotiation ofof
15
15 an international
an international treaty
treaty at
at the
the Council of Europe.
Council of Europe. II had
had the
the
16
16 pleasure of,
pleasure of, just
just recently,
recently, participating
participating with
with them
them after
after 2020
17
17 years, and
years, and there
there are
are now
now 66
66 countries.
countries. ButBut one
one of
of the
the most
most
18
18 important things
important things about
about this
this is
is that
that they
they adopted
adopted the
the idea
idea
19
19 that the
that the G7
G7 came
came up
up with,
with, and
and they
they have
have incorporated
incorporated the
the
20
20 24/7 network.
24/7 network.
21
21 It is
It is now,
now, as
as aa matter
matter of
of treaty,
treaty, extended
extended to
to the
the
22
22 66 countries
66 countries that
that are
are parties
parties toto the
the convention.
convention. So So the
the G8
GB
23
23 originated this
originated this idea,
idea, which
which has
has been
been tremendously
tremendously important
important
24
24 in fighting
in fighting computer
computer crime.
crime. Michael
Michael can
can take
take aa lot
lot of
of
25
25 credit for
credit for that.
that.
2873
2873
1
1 Q.
Q. Great.
Great.
2
2 So you've
So you've known
known Mr.
Mr. Sussmann
Sussmann for
for over
over 20
20 years
years
3
3 now; is
now; is that
that right?
right? Hopefully my
Hopefully math is
my math is right?
right?
4
4 A.
A. Is that
Is that right?
right? Yeah.
Yeah. Not quite.
Not quite. Not quite.
Not quite.
5
5 Q.
Q. All right.
All right. Well over
Well over 20
20 years;
years; is
is that
that fair?
fair?
6
6 A.
A. A little
A little bit less.
bit less.
7
7 Q.
Q. Okay.
Okay.
8
8 Now, in
Now, in the
the time
time that
that you've
you've known
known Mr.
Mr. Sussmann,
Sussmann,
9
9 what's your
what's your overall
overall impression
impression of
of his
his reputation
reputation for
for honesty
honesty
10
10 and truthfulness?
and truthfulness?
1
11 A.
A. Michael is
Michael is an
an earnest
earnest guy.
guy. He's
He's aa sincere
sincere person.
person.
12
12 He has
He has --
-- II mean
mean II have
have confidence
confidence --
-- II did
did have
have confidence
confidence
13
13 in his
in his truthfulness,
truthfulness, in
in letting
letting us
us know
know when
when there
there was a
was a
14
14 problem.
problem. I would
I would bank
bank on
on it.
it.
15
15 Q.
Q. And you
And you believe
believe him
him to
to be
be an
an honest
honest and
and truthful
truthful
16
16 person?
person?
17
17 A.
A. Oh IIdo.
Oh, do.
18
18 Q.
Q. Thank you.
Thank you.
19
19 CROSS-EXAMINATION OF
CROSS-EXAMINATION MARTHA STANSELL-GAMM
OF MARTHA STANSELL-GAMM
20
20 BY
BY MS. SHAW:
MS. SHAW:
21
21 @.
Q. Good afternoon.
Good afternoon.
22
22 A.
A. Good afternoon.
Good afternoon.
23
23 Q.
Q. My name
My name is
is Brittany
Brittany Shaw.
Shaw. II represent
represent the
the United
United
24
24 States, along
States, along with
with my colleagues at
my colleagues at counsel
counsel table.
table. It's
It's
25
25 nice to
nice to meet you.
meet you.
2874
2874
1
1 I don't
I don't have
have many questions for
many questions for you,
you, and
and thank
thank you
you
2
2 for sharing
for sharing your
your stories
stories about
about CCIPS.
CCIPS. It's fascinating
It's fascinating --
--
3
3 A.
A. You are
You are most
most welcome.
welcome. II amam very
very proud
proud of
of them
them asas
4
4 you can
you can tell.
tell. II haven't
haven't been
been there
there in
in aa long
long time,
time, but
but they
they
5
5 are still
are still wonderful.
wonderful.
6
6 Q.
Q. All right.
All right. SoSo it's
it's clear
clear from
from what
what you've
you've told
told us
us
7
7 that you
that you have
have strong
strong feelings
feelings about
about Mr. Sussmann. You've
Mr. Sussmann. You've
8
8 had aa long
had long relationship
relationship with
with him.
him. Have
Have you
you been
been sitting
sitting inin
9
9 the courtroom
the courtroom listening
listening to
to the
the evidence
evidence here?
here?
10
10 A.
A. ALL II know
All know is
is what
what II have
have read
read in
in the
the press.
press.
n
11 ©.
Q. Right.
Right.
12
12 A.
A. I did
I did meet with Michael
meet with Michael in
in November,
November, but
but we did
we did
13
13 not discuss
not discuss the
the case
case at
at all.
all.
14
14 ©.
Q. But you
But you haven't
haven't been
been sitting
sitting inin the
the courtroom,
courtroom,
15
15 like the
like the jury
jury has,
has, listening
listening to
to the
the evidence?
evidence?
16
16 A.
A. No, no.
No, no. II haven't
haven't heard
heard any
any of
of the
the testimony.
testimony.
17
17 MS. SHAW: Thank
MS. SHAW: Thank you,
you, ma'am.
ma'am.
18
18 MS. YAO: Nothing
MS. YAO: Nothing further,
further, Your
Your Honor.
Honor.
19
19 THE COURT:
THE COURT: Okay,
Okay, ma'am, thank you
ma'am, thank you very
very much
much for
for
20
20 your testimony.
your testimony.
21
21 THE WITNESS:
THE WITNESS: MyMy pleasure.
pleasure.
22
22 THE COURT:
THE COURT: You
You are
are excused
excused and
and have
have aa great
great day.
day.
23
23 Counsel, quick
Counsel, sidebar.
quick sidebar.
24
(Bench conference)
25
25 THE COURT:
THE COURT: Should
Should we
we take
take aa short
short break
break and
and take
take
2875
2875
1
1 || stock
stock ofof where
where we are2
we are?
22 MR. BERKOWITZ: II think

MR. BERKOWITZ: think that
that makes good sense,
makes good sense,
33 || Your
vour Honor.
monor.
44 MR. DeFILIPPIS: Yes,
MR. DeFILIPPIS: Yes, Your
Your Honor.
Honor.
concluded)
66 THE COURT:
THE COURT: All
All right.
right. Ladies
Ladies and
and gentlemen,
gentlemen,
77 || we're
werre going
going to
to take
take aa short
short --
-- about
about aa 10-minute
10-minute break.
break. And
and
88 [| I'm
1'm going
going to
to meet
meet with
with counsel
counsel toto see
see where
where things
things stand.
stand.
99 || ana we wi1l
And we let you
will let you know
know when
when you
you come
come back. okay?
back. Okay?
10
10 (Jury exited
(Jury exited the
the courtroom.)
courtroom.)
un
11 THE COURT:
THE COURT: All
All right.
right. Please
Please be
be seated.
seated.
12
12 All right.
All right. SoSo II guess the first
guess the first thing
thing is
is the
the
13 || HSPCI
13 msect testimony.
testimony. I've
1've read
read the
the excerpts
excerpts that
that came
came in
in in
in the
the
14 || government's
14 government's case
case and
and the
the proposed
proposed additions
additions under
under Rule
Rule 106
106
15 || from
15 from the
the defense.
defense. They seem to
They seem to relate
relate to
to generally
generally the
the same
same
16 | subject
16 subject matter ana complete
matter and complete the
tne story.
story.
17
17 The subject
The subject matter
matter of
of the
the excerpts
excerpts offered
offered by
by the
the
18 || government
18 government are,
are, you
you know,
know, Did
Did he
he come
come alone
alone or
or on
on behalf
behalf of
of
19 || aa client?
19 client? The
he logistics
logistics of
of the
the meeting, was anyone
meeting, was anyone else
else
20 || there?
20 there? Didpid he
ne leave
leave documents?
documents? Waswas there
there any
any follow-up
follow-up
21 || about
21 about the
the information
information that
that he
he provided?
provided? DidDid aa client
client direct
direct
22
22 [him to
him to do
do anything?
anything?
23
23 The excerpts
The excerpts that
that I've
I've read
read seem
seem to
to cover
cover that
that
24 || same
24 same ground,
ground, but
but is
is there
there aa dispute
dispute or
or does
does the
the government
government
25 || contest
25 contest that?
tharz
2876
2876
1
1 MR. DeFILIPPIS: Your
MR. DeFILIPPIS: Your Honor,
Honor, before this court
before this court
2
2 session, Mr.
session, Mr. Berkowitz,
Berkowitz, II think,
think, had
had presented
presented us
us with
with what
what
3
3 we understand
we understand is
is aa narrowed
narrowed proposal
proposal from
from the
the defense,
defense,
4
4 bottom of
bottom of Page
Page 56
56 to
to 58.
58.
5
5 MR. BERKOWITZ: II believe,
MR. BERKOWITZ: believe, Your
Your Honor,
Honor, you
you have
have --
==
6
6 it's bottom
it's bottom of
of Page
Page 56
56 to
to the
the bottom
bottom of
of Page
Page 58.
58.
7
7 THE COURT:
THE COURT: Right.
Right. Starting with
Starting "and who
with "and who in
in the
the
8
8 FBI did
FBI did you
you speak
speak with"?
with"?
9
9 MR. DeFILIPPIS: (Nodded
MR. DeFILIPPIS: (Nodded head)
head)
10
10 THE COURT:
THE COURT: And
And going
going through
through "best
"best interest
interest of
of
1
11 the Bureau
the Bureau and
and of
of our
our country
country so
so that
that II mean
mean --"
=="
12
12 MR. DeFILIPPIS: Yeah,
MR. DeFILIPPIS: Yeah, so,
so, Your
Your Honor,
Honor, if
if that's
that's
13
13 the proposal,
the proposal, that
that more limited proposal,
more limited proposal, we're
we're not
not going
going to
to
14
14 object to
object to that.
that.
15
15 THE COURT:
THE COURT: Okay.
Okay. Good.
Good. We all
We all agree.
agree.
16
16 And, Mr.
And, Berkowitz, how
Mr. Berkowitz, how do
do you
you want
want to
to take
take up
up the
the
17
17 sealed motion
sealed that was
motion that filed just
was filed just before
before lunch?
lunch?
18
18 MR. BERKOWITZ: Your
MR. BERKOWITZ: Your Honor,
Honor, we
we don't
don't know
know what
what
19
19 the --
the =
20
20 THE COURT:
THE COURT: Is there
Is there an
an objection
objection to
to the
the request
request
21
21 by the
by the government?
government?
22
Honor, we did take
we did take aa quick
quick
23
23 look at
look at the
the motion.
motion. II think,
think, at
at this
this phase,
phase, we're
we're not
not able
able
24
24 to say
to say for
for sure
sure whether
whether we
we object.
object. There
There are
are aa couple
couple of
of
25
25 things we
things want to
we want to do
do some
some research
research on
on that
that won't take us
won't take us
2877
2877
1
1 long, but
long, but we'd
we'd just
just like
like aa little
little chance
chance to
to do
do that.
that.
2
2 1f we
If we do
do oppose
oppose it,
it, we'd
we'd ask
ask to
to give
give you
you something
something
3
3 this evening.
this evening.
4
4 THE COURT:
THE COURT: All right.
All right. So the
So the defense
defense then
then won't
won't
5
5 be prepared
be to rest
prepared to rest today.
today. We'd have to
We'd have to defer
defer that
that decision
decision
6
6 until tomorrow?
until tomorrow? And
And II assume
assume --
-- I'll
I'll bring
bring them
them back,
back, and
and
7
7 we can
we can read
read them
them the
the HSPCI
HSPCI testimony,
testimony, and
and Mr.
Mr. Sussmann
Sussmann would
would
8
8 be the
be the only
only other
other witness.
witness. Correct?
Correct?
9
9 MR. BERKOWITZ: That
MR. BERKOWITZ: That is
is correct.
correct. And a decision
And a decision
10
10 on this
on this issue
issue will
will help
help inform
inform that
that decision.
decision. And so II --
And so ==
n
11 we certainly
we certainly are
are not
not looking
looking to
to put
put the
the government
government onon the
the
12
12 spot. They
spot. They should
should be entitled to
be entitled to do
do their
their research.
research. If If
13
13 there is
there is an
an issue
issue that
that we can do
we can do or
or raise
raise and
and get
get your
your steer
steer
14
14 sooner rather
sooner rather than
than later,
later, it
it would
would help
help us
us so
so that
that there
there isis
15
15 not an
not an unnecessary
unnecessary delay.
delay. We chose, as
We chose, as we
we were
were preparing,
preparing,
16
16 to file
to file it
it right
right at
at the
the close
close of
of their
their case
case and
and did
did so.
so.
17
17 So we're
So we're trying
trying to
to do
do what
what we
we can,
can, and
and our
our case
case
18
18 has gone
has gone quicker
quicker than
than we
we anticipated,
anticipated, but
but we
we would
would like
like some
some
19
19 direction from
direction from you
you to
to help
help inform
inform aa final
final decision.
decision.
20
20 THE COURT:
THE COURT: Okay.
Okay. And
And II know
know that
that the
the motion
motion was
was
21
21 filed under
filed under seal
seal because
because the
the attachments
attachments are
are confidential;
confidential;
22
22 is that
is that correct?
correct? Is Is the
the motion
motion itself
itself or
or the
the fact
fact of
of the
the
23 || motion
23 or the
motion or the subject
subject matter
matter of
of the
the motion, there is
motion, there is no
no
24
24 reason that
reason that that
that should
should bebe sealed.
sealed. Correct?
Correct?
25
25 MR. BERKOWITZ: I1 believe
MR. BERKOWITZ: believe that's
that's correct.
correct.
2878
2878
1
1 THE COURT:
THE COURT: Okay.
Okay. So just
So just for
for the
the record,
record, the
the
2
2 || motion is to
motion is to preclude
preclude --
-- if
if Mr. Sussmann were
Mr. Sussmann were to
to testify
testify -- --
3
3 to preclude
to the government
preclude the government from
from cross-examining
cross-examining him
him on
on
4
4 materials that were
materials that submitted to
were submitted to the
the government
government prior
prior ----
5
5 preindictment to
preindictment to persuade
persuade the
the government
government not
not to
to go
go forward
forward
6
6 with the
with the case?
case?
7
7 MR. BERKOWITZ: That's
MR. BERKOWITZ: That's correct.
correct.
8
8 THE COURT:
THE COURT: Okay.
Okay. II mean, since this
mean, since this was
was just
just
9
9 filed, the
filed, the government
government obviously
obviously should
should have
have an
an opportunity
opportunity
10
10 to think
to think about
about it.
it. OnOn its
its face,
face, it
it seems
seems like
like 408
408 and
and 410
410
n
11 would apply.
would apply. II don't
don't --
-- II would be hard-pressed
would be hard-pressed toto come
come up up
12
12 with an
with an example
example of
of preindictment negotiations between
preindictment negotiations between the
the
13
13 parties in
parties in aa criminal
criminal case
case that
that would
would be
be used
used at
at trial
trial or or
14
14 that would
that would be admissible over
be admissible over 408
408 and
and 410
410 objections.
objections.
15
Honor, we are mindful
we are mindful ofof
16
16 that. Part
that. Part of
of the
the reason
reason we
we want
want to
to do
do some
some very
very quick
quick
17
17 research is
research is just
just make
make sure
sure everything
everything wewe say
say is
is in
in line
line with
with
18
18 Department policy
Department and all
policy and all of
of that.
that.
19
19 THE COURT:
THE COURT: Okay.
Okay. IfIf Mr.
Mr. DeFilippis
DeFilippis confirms
confirms what
what
20
20 he believes
he believes toto be the case,
be the case, that
that it's
it's not
not contrary
contrary toto
21
21 Department policy,
Department how long
policy, how long --
-- just
just in
in terms
terms of
of planning
planning and and
22
22 dealing with
dealing with the
the jury
jury instructions,
instructions, how
how long
long would
would you
you
23
23 anticipate Mr.
anticipate Sussmann's testimony
Mr. Sussmann's testimony to
to be if he
be if he were
were toto
24
24 choose to
choose to testify?
testify?
25
25 MR. BERKOWITZ: Three
MR. BERKOWITZ: Three hours.
hours.
2879
2879
1
1 THE COURT:
THE COURT: Okay.
Okay.
2
2 MR. BERKOWITZ: Or
MR. BERKOWITZ: Or less
less or
or more,
more, but that would
but that would be
be
3
3 our estimate,
our estimate, Judge.
Judge. Obviously subject
Obviously subject to
to
4
4 cross-examination.
cross-examination.
5
5 THE COURT:
THE COURT: I'm just
I'm just doing
doing the
the math
math in
in my
my head
head
6
6 thinking towards
thinking towards Friday
Friday morning.
morning.
7
7 MR. BERKOWITZ: It's
MR. BERKOWITZ: It's to
to conclude
conclude but not to
but not to close,
close,
8
8 II suppose.
suppose.
9
9 THE COURT:
THE COURT: Right.
Right. So closings
So closings would
would then
then likely
likely
10
10 be Tuesday?
be Tuesday?
1
11 MR. BERKOWITZ: Again,
MR. BERKOWITZ: Again, II don't
don't want
want to
to speak
speak
12
12 subject to
subject to any
any rebuttal
rebuttal case,
case, but
but hopefully
hopefully it
it would be
would be
13
13 Tuesday morning,
Tuesday morning, Judge.
Judge.
14
14 THE COURT:
THE COURT: Got it.
Got it.
15
15 ALL right.
All right. Why don't
Why don't we
we bring the jury
bring the jury back,
back, read
read
16
16 in the
in the defense's
defense's excerpts
excerpts from
from the
the HSPCI
HSPCI testimony
testimony and
and then
then
17
17 you're prepared
you're to close
prepared to close --
-- I'm
I'm sorry.
sorry.
18
18 MR. BERKOWITZ: II will
MR. BERKOWITZ: will not
not rest.
rest.
19
19 THE COURT:
THE COURT: ie'll just
We'll just send
send them
them home.
home. Okay.
Okay.
20
20 Perfect.
Perfect.
21
21 MR. BERKOWITZ: And
MR. BERKOWITZ: And just
just one
one issue
issue II can
can raise
raise
22
22 after the
after the jury
jury is
is gone
gone to
to preserve
preserve time
time if
if you
you want.
want.
23
23 THE COURT:
THE COURT: Okay.
Okay.
24
24 (Jury entered
(Jury entered the
the courtroom.)
courtroom.)
25
25 THE COURT:
THE COURT: Please be
Please be seated,
seated, everybody.
everybody.
2880
2880
1
1 MR. BERKOWITZ: Your
MR. BERKOWITZ: Your Honor,
Honor, at
at this
this point,
point, the
the
2
2 defense would
defense would read
read in
in additional
additional portions
portions of
of Government
Government
3
3 Exhibit 56,
Exhibit 56, which
which was
was Mr.
Mr. Sussmann's
Sussmann's testimony
testimony before the
before the
4
4 House Subcommittee
House Subcommittee in,
in, II believe
believe itit was,
was, December
December ofof 2017.
2017.
5
5 If you
If you could
could just
just put
put up
up the
the front
front page and II --
page and -- it
it may have
may have
6
6 been October.
been October. We'll take aa look.
We'll take look.
7
7 So this
So this is
is additional
additional testimony
testimony from
from the
the portions
portions
8
8 that the
that the government
government read
read in
in when
when Mr.
Mr. Sussmann
Sussmann testified
testified on on
9
9 December 18th
December 18th of
of 2017.
2017. OnOn the
the bottom of Page
bottom of Page 56
56 II will
will
10
10 start with.
start with. Just
Just blow
blow that
that up
up for
for me, please?
me, please?
n
11 Q. And
Q. And who in the
who in the FBI
FBI did
did you
you speak
speak with?
with?
12
12 A.
A. (By Michael
(By Sussmann:) It's
Michael Sussmann:) It's general
general
13
13 counsel.
counsel.
14
14 Q. Okay.
Q. Okay. AndAnd that
that would be?
would be?
15
15 A.
A. Jim Baker.
Jim Baker.
16
16 Q. And
Q. And when did that
when did that conversation
conversation occur
occur on
on
17
17 or about?
or about?
18
18 A.
A. Middle
Middle ofof September,
September, 2016.
2016.
19
19 Q. And
Q. And what did Mr.
what did Mr. Baker
Baker advise
advise you
you to
to do?
do?
20
20 A.
A. Advise
Advise meme to
to do?
do?
21
21 Q. Yeah.
Q. Yeah. Or Or what
what was
was --
-- what
what did
did he
he --
== how
how
22
22 did he
did he respond
respond to
to the
the information
information that
that you
you
23
23 conveyed to
conveyed to him?
him?
24
24 A.
A. He said
He said thank
thank you.
you.
25
25 Q. Did
Q. Did he
he offer
offer any
any follow-on
follow-on --
--
2881
2881
1
1 A
A. Yo.
No.
2
2 @. --
Q. -- engagements
engagements oror did
did he
he promise
promise that
that hehe
3
3 would pass
would pass itit on?
on?
1
4 A.
A. But to
But to be
be clear,
clear, II told
told him
him II didn't
didn't
5
5 want any.
want any. II mean,
mean, II was
was sharing
sharing information,
information, and and
6
6 II remember
remember telling
telling him
him at
at the
the outset
outset that
that II was
was
7
7 meeting with
meeting with him
him specifically,
specifically, because
because any
any
8
8 information involving
information involving aa political
political candidate,
candidate, but but
9
9 particularly information
particularly information ofof this
this sort
sort involving
involving
10
10 potential relationship
potential relationship or or activity
activity with
with the
the
n
11 foreign government,
foreign government, was
was highly
highly volatile
volatile and
and
12
12 controversial.
controversial.
13
13 And
And II thought
thought and
and II remember
remember telling
telling him him
14
14 that it
that it would
would be
be aa not-so-nice
not-so-nice thing
thing ---- II probably
probably
15
15 used aa word
used word more
more stronger
stronger than
than "not
"mot so
so nice"
nice" -- -- to
to
16
16 dump some
dump some information
information like
like this
this on
on aa case
case agent
agent
17
17 and create
and create some
some sort
sort of
of aa problem.
problem.
18
18 And so II was
And so was coming
coming to
to him
him mostly
mostly
19
19 because II wanted
because him to
wanted him to be
be able
able to
to decide
decide whether
whether
20
20 or not
or not to
to act
act or
or not
not to
to act,
act, or
or to
to share
share oror not
not toto
21
21 share, with
share, with information
information II was
was bringing him to
bringing him to
22
22 insulate or
insulate or protect
protect the
the Bureau
Bureau or
or --
-- II don't
don't know.
know.
23
23 II just
just thought
thought he
he would know best
would know best what
what toto do
do oror
24
24 not to
not to do,
do, including
including nothing
nothing atat the
the time.
time.
25
25 That if
That if II could
could just
just go
go on,
on, II know
know from
from
2882
2882
1
1 my time
my time as
as aa prosecutor
prosecutor at
at the
the Department
Department of
of
2
2 Justice there
Justice there are
are guidelines about when
guidelines about when you
you can
can
3
3 act on
act on things.
things. When close
When close to
to an
an election,
election, you
you
1
4 wait sort
wait sort of
of until
until after
after the
the election.
election.
5
5 And I didn't
And I didn't know
know what
what the
the appropriate
appropriate
6
6 thing was,
thing was, but
but II didn't
didn't want
want to
to put
put the
the Bureau
Bureau or
or
7
7 hin in
him in an
an uncomfortable
uncomfortable situation
situation by, as II said,
by, as said,
8
8 going to
going to a
a case
case agent
agent or
or sort
sort of
of dumping
dumping it
it in
in the
the
9
9 wrong place.
wrong place. So II met
So with him
met with him briefly
briefly and
and --
--
10
10 Q.
Q. Did you
Did you meet -- was
meet -- it aa personal
was it personal
un
11 meeting or
meeting or aa phone
phone call?
call?
12
12 A.
A. Personal meeting.
Personal meeting.
13
13 Q.
Q. At the FBI?
At the FBI?
14
14 A.
A. At the FBI.
At the FBI.
15
15 And if II could
And if could just
just continue
continue my answer
my answer
16
16 to answer
to answer your
your question,
question, and
and so
so II told
told him
him this
this
17
17 information, but
information, but didn't
didn't want
want any
any follow-up,
follow-up, didn't
didn't
18
18 -- in
-- in other
other words,
words, II wasn't
wasn't looking
looking for
for the
the FBI
FBI to
to
19
19 do anything.
do anything. II had
had no
no ask.
ask. I had
I had no
no requests.
requests.
20
20 And I
And I remember
remember saying,
saying, I'm
I'm not
not --
-- you
you don't need
don't need
2
21 to follow
to follow up
up with
with me.
me. II just
just feel
feel II have
have left
left
22
22 this in
this in the
the right
right hands,
hands, and
and he
he said
said yes.
yes.
23
23 @.
Q. And
And when you chose
when you chose the
the general
general counsel
counsel
24
24 of the
of the FBI,
FBI, is
is it
it because you had
because you had a
a professional
professional
25
25 relationship with
relationship with him?
him? Did you
Did you know
know him
him
2883
2883
1
1 personally?
personally?
2
2 A.
A. II know
know --
-- II mean,
mean, II know
know him
him
3
3 professionally, but
professionally, but just
just from
from having
having been
been at
at the
the
4
4 Department for
Department for aa long
long time,
time, been
been in
in Washington,
Washington, II
5
5 know most
know most --
-- II just
just know
know most
most --
-- II know
know aa lot
lot of
of
6
6 agency general
agency general counsel,
counsel, so
so II don't
don't have
have aa
7
7 particularly closer
particularly closer relationship
relationship with
with him
him than
than
8
8 other people.
other people.
9
9 But II knew,
But knew, in
in his
his role,
role, he
he seemed
seemed like
like
10
10 the right
the right person
person toto go
go to
to with potentially
with potentially
n
11 sensitive information,
sensitive information, andand that
that he
he would
would ---- II had
had
12
12 hoped or
hoped or assumed
assumed hehe would
would know
know what
what to
to do
do or
or what
what
13
13 was in
was in the
the best
best interest
interest ofof the
the Bureau
Bureau and
and our
our
14
14 country so
country so that
that II mean --
mean --
15
15 And then
And then cut
cut off
Off at
at "fair
"fair enough".
enough”. That's
That's the
the
16
16 remainder of
remainder of the
the portion
portion that
that we
we wanted
wanted toto read
read in,
in, Your
Your
17
17 Honor.
Honor.
18
18 THE COURT:
THE COURT: Okay.
Okay. Thank
Thank you.
you.
19
19 All right.
All right. So,So, ladies
ladies and
and gentlemen,
gentlemen, those
those
20
20 excerpts are
excerpts are now
now in
in evidence
evidence as
as well.
well.
21
21 All right.
All right. We We are
are making
making progress.
progress. We are
We are
22
22 basically still
basically still onon schedule,
schedule, but
but the
the lawyers
lawyers and
and II have
have some
some
23
23 legal issues
legal issues to
to take
take care
care of.
of. SoSo we're
we're going
going toto dismiss
dismiss youyou
24
24 early again
early again today
today and
and bring
bring you
you back
back at
at 99 a.m.
a.m. tomorrow
tomorrow
25
25 [| morning.
morning.
2884
2884
1
1 No discussions
No discussions about
about the
the case.
case. No research
No research about
about
2
2 the case.
the case. All right? Have
All right? Have aa good
good day.
day.
3
3 Have aa good
Have good night.
night.
4
4 (Jury exited
(Jury exited the
the courtroom.)
courtroom.)
5
5 THE COURT:
THE COURT: All
All right.
right.
6
6 Have aa seat.
Have seat. What do you
What do you have?
have?
7
7 MR. BERKOWITZ: Judge,
MR. BERKOWITZ: Judge, II regret
regret that
that I'm
I'm going
going
8
8 back to
back to this
this same
same issue
issue that
that we
we started
started the
the day
day with
with where
where
9
9 you admonished
you admonished counsel
counsel to
to be
be careful
careful ofof the
the guardrails
guardrails
10
10 related to
related to evidentiary
evidentiary rulings.
rulings. We We had
had another
another situation
situation
n
11 today that
today that II think
think ran
ran afoul
afoul of
of your
your comments.
comments.
12
12 There was
There was an
an email that was
email that was the
the subject
subject ofof aa
13 || motion
13 related to
motion related to Mr.
Mr. Joffe
Joffe communicating
communicating about
about aa potential
potential
14
14 job. And
job. And in
in the
the cross-examination
cross-examination of of Agent
Agent Grasso
Grasso there
there was
was
15
15 a question
a question about,
about, "He
"He certainly
certainly didn't
didn't know
know he
he was
was working
working
16
16 with folks
with folks affiliated
affiliated with
with aa particular
particular political
political party
party or
or
17
17 campaign when
campaign when hehe brought
brought that
that to
to you.
you. Right?"
Right?"
18
18 Answer: "I
Answer: "I have
have no
no recollection
recollection of of that."
that." II
19
19 didn't object.
didn't object. And then he
And then he followed
followed upup with:
with: "And
"And any
any
20
20 recollection of
recollection of hearing
hearing oror learning
learning that
that he
he was
was expecting
expecting
21
21 any kind
any kind of
of position
position inin aa future
future political
political administration,
administration,
22
22 knowing that
knowing that there
there was nothing in
was nothing in the
the 3500
3500 materials related
materials related
23
23 to that
to that and
and knowing
knowing anan objection
objection that
that was
was sustained
sustained could
could
24
24 elicit aa belief
elicit belief that
that he
he would
would do
do that?"
that?"
25
25 The witness
The witness answered,
answered, "I"I do
do not
not have
have aa
2885
2885
1
1 recollection of
recollection of that
that other
other than
than --
-- let
let me rephrase that.
me rephrase that. I
I
2
2 have aa recollection
have recollection of
of that
that being
being reported
reported in
in the
the media."
media."
3
3 1 objected.
I objected.
4
4 Your Honor,
Your Honor, they
they had
had met
met with this witness
with this witness four
four
5
5 times.
times. They had
They had pretried
pretried him
him twice.
twice. There was
There was nothing
nothing in
in
6
6 the 3500
the 3500 material
material to
to suggest
suggest that
that he
he had
had any
any belief
belief of
of that
that
7
7 or any
or any recollection
recollection or
or any
any connection.
connection.
8
8 And it's
And it's another
another instance
instance in
in aa litany
litany of
of instances
instances
9
9 that's suggesting
that's suggesting to
to the
the jury
jury topics
topics and
and issues
issues that
that were
were
10
10 the subject
the subject of
of your
your ruling.
ruling. And I,
And I, you
you know,
know, particularly
particularly
n
11 with the
with the potential
potential testimony
testimony of
of Mr. Sussmann coming
Mr. Sussmann coming up,
up, II
12
12 don't know
don't know what else to
what else to say
say or
or to
to do,
do, and
and we'll
we'll consider
consider
13
13 filing aa motion.
filing motion. But II wanted
But wanted to
to raise
raise the
the issue,
issue, and
and II
14
14 take no
take no joy
joy in
in continuing
continuing to
to do
do this.
this. But II cannot
But cannot stand
stand by
by
15
15 while it
while it continues
continues to
to go
go on.
on.
16
16 THE COURT:
THE COURT: Counsel?
Counsel?
17
17 MR. DeFILIPPIS: Yes,
MR. DeFILIPPIS: Yes, Your
Your Honor.
Honor. II guess
guess we're
we're
18
18 glad that
glad that Mr.
Mr. Berkowitz
Berkowitz raised
raised it
it in
in the
the sense
sense that,
that, you
you
19
19 know, typically
know, typically the
the rules
rules for
for cross-examination
cross-examination are
are
20
20 different from
different from evidence
evidence presented
presented in
in aa case
case in
in chief.
chief. AndAnd
21
21 if there
if there is
is aa good-faith
good-faith basis
basis to
to ask
ask --
-- inquire
inquire as
as to
to
22
22 knowledge of
knowledge of aa matter, Your Honor,
matter, Your Honor, the
the government
government didn't
didn't
23
23 phrase the
phrase the question
question tethered
tethered toto any
any email
email or
or refer
refer to
to any
any
24
24 hearsay.
hearsay.
25
25 It was
It was just
just inquiring
inquiring as
as to
to knowledge
knowledge and
and then
then
2886
2886
1
1 inquiring as
inquiring as to
to whether
whether that
that fact
fact would
would be
be relevant
relevant to
to what
what
2
2 it is
it is that
that Mr. Grasso's interactions
Mr. Grasso's interactions with
with Mr.
Mr. Joffe
Joffe were.
were.
3
3 So if,
So if, again
again if
if the
the Court
Court wants
wants --
—-
4
4 THE COURT:
THE COURT: Counsel, II don't
Counsel, don't disagree
disagree with
with that,
that,
5
5 but you
but you got
got to
to have
have aa good
good faith
faith basis
basis for
for asking
asking the
the
6
6 question.
question. Right?
Right? And if you
And if you prepped
prepped this
this guy
guy and
and he's
he's
7
7 never said
never said anything
anything about
about it,
it, then
then there's
there's no
no good-faith
good-faith
8
8 basis. Okay?
basis. Okay? HimHim reading
reading it
it in
in The
The New
New York
York Times
Times oror
9
9 whatever is
whatever is not
not aa good-faith
good-faith basis.
basis.
10
10 MR. DeFILIPPIS: Yeah,
MR. DeFILIPPIS: Yeah, and
and to
to be
be clear,
clear, Your
Your
n
11 Honor, the
Honor, the portion
portion where he said
where he said he
he read
read in
in the
the --
-- we didn't
we didn't
12
12 know that,
know that, and
and we wouldn't have
we wouldn't have intentionally
intentionally elicited
elicited
13
13 something from
something from aa press
press account.
account. SoSo we
we will certainly be
will certainly be
14
14 careful.
careful.
15
15 THE COURT:
THE COURT: He He was
was the
the defense's
defense's witness
witness here,
here, but
but
16
16 he was
he on your
was on your witness list. You
witness list. You should
should have
have known.
known. If If
17
17 there was
there was aa basis
basis to
to ask
ask that
that question,
question, you
you should
should have
have
18
18 known what
known what it
it was.
was.
19
19 MR. DeFILIPPIS: Yeah.
MR. DeFILIPPIS: Yeah. Understood,
Understood, Your
Your Honor.
Honor.
20
20 THE COURT:
THE COURT: In In that
that vein,
vein, let's
let's go
go back
back to
to GX-132
GX-132
21
21 the admission
the admission of
of the
the email
email did not sit
did not sit well with me
well with me
22
22 yesterday, and
yesterday, and it
it still
still does
does not
not sit
sit well
well with
with me.
me.
23
23 The Court
The Court ruled
ruled that
that the
the document
document was
was hearsay
hearsay
24
24 originally because
originally it contained
because it contained aa question
question and
and aa request,
request, as as
25
25 opposed to
opposed to an
an assertion.
assertion. ButBut the
the Court
Court made clear in
made clear in its
its
2887
2887
1
1 order that,
order that, in
in order
order to
to be
be admitted,
admitted, it
it would
would still
still need
need aa
2
2 proper foundation.
proper foundation.
3
3 The witness
The witness through
through which
which the
the document
document ultimately
ultimately
4
4 was admitted,
was admitted, albeit
albeit not
not without
without an
an objection
objection from
from the
the
5
5 defense, was
defense, was Mr.
Mr. Heide,
Heide, who,
who, as
as far
far as
as II could
could tell,
tell, had
had no
no
6
6 personal knowledge
personal knowledge whatsoever of the
whatsoever of the email.
email. He didn't
He didn't know
know
7
7 || Mr. Joffe. He
Mr. Joffe. He didn't
didn't know
know the
the researchers
researchers who received it.
who received it.
8
8 He obviously
He obviously was
was not
not aa party to the
party to the email.
email. So So frankly,
frankly, II
9
9 don't see
don't see how
how he
he could
could testify
testify to
to that
that email
email in
in his
his personal
personal
10
10 knowledge as
knowledge as required
required by
by Rule
Rule 602.
602.
n
11 So for
So for that
that reason,
reason, II don't
don't think
think itit was
was properly
properly
12
12 admitted through
admitted through that
that witness.
witness. AsAs II said
said yesterday,
yesterday, wewe had
had
13
13 expected at
expected at least
least two
two of
of the
the researchers
researchers toto testify
testify based
based on
on
14
14 who was
who was on
on the
the government's list.
government's list.
15
15 And II think
And think it
it would
would have
have been
been properly
properly admissible
admissible
16
16 through those
through those people
people to
to explain
explain how
how the
the data
data came
came into
into being
being
17
17 as the
as the Court
Court ruled
ruled prior to trial.
prior to trial. SoSo II am
am going
going to
to exclude
exclude
18
18 that email
that email as
as well
well as
as any
any testimony
testimony byby Mr. Heide describing
Mr. Heide describing
19
19 his interpretation
his interpretation oror views
views or
or thoughts
thoughts onon the
the email.
email. Okay?
Okay?
20
20 Now, obviously,
Now, obviously, big
big sort
sort of
of crossroads
crossroads ofof the
the
21
21 case. When
case. can we
When can we get the defense
get the defense anan answer
answer asas to
to whether
whether
22
22 the government
the government isis going
going to
to object
object toto the
the request
request to
to preclude
preclude
23
23 cross-examination on
cross-examination on the
the preindictment
preindictment negotiations?
negotiations?
2
24 MR. DeFILIPPIS: Yeah.
MR. DeFILIPPIS: Yeah. We We can
can certainly
certainly do that
do that
25
25 by 6:00
by 6:00 if
if that's
that's okay
okay with Your Honor.
with Your Honor.
2888
2888
1
1 THE COURT:
THE COURT: Get them
Get them an
an answer
answer as
as soon
soon as
as you
you can.
can.
2
2 MR. DeFILIPPIS: Okay.
MR. DeFILIPPIS: Okay.
3
3 THE COURT:
THE COURT: So
So that
that we
we know
know whether
whether we're
we're going
going to
to.
4
4 go forward
go forward tomorrow
tomorrow or
or whether the defense
whether the defense is
is going
going to
to rest.
rest.
5
5 Does the
Does the government
government anticipate
anticipate aa rebuttal
rebuttal case
case in
in either
either
6
6 scenario?
scenario?
7
7 MR. DeFILIPPIS: We
MR. DeFILIPPIS: would want
We would want to
to preserve
preserve our
our
8
8 ability to.
ability to. At this
At this point
point we
we don't.
don't.
9
9 THE COURT:
THE COURT: Okay.
Okay.
10
10 MR. DeFILIPPIS: If
MR. DeFILIPPIS: If II could
could just
just ask,
ask, Your
Your Honor,
Honor,
1
11 just for
just for cross-examination
cross-examination going forward, we
going forward, we obviously
obviously want
want
12
12 to be
to very careful
be very careful to
to abide
abide by
by Your
Your Honor's
Honor's orders.
orders. With
With
13
13 the defendant's
the defendant's testimony,
testimony, II think
think we may just
we may just want to think
want to think
14
14 about what
about what emails
emails --
-- knowledge
knowledge we
we may
may have
have gained
gained from
from
15
15 emails that
emails that are
are excluded,
excluded, what's
what's fair
fair game
game for
for the
the
16
16 defendant's cross.
defendant's cross. So II don't
So don't know,
know, Your
Your Honor,
Honor, if
if you
you have
have
17
17 any initial
any initial thoughts.
thoughts.
18
18 THE COURT:
THE COURT: No.
No. If you
If you think
think you
you may be going
may be going
19
19 into areas
into areas that
that are
are subject
subject to
to the
the Court's
Court's rulings,
rulings, and
and that
that
20
20 the rulings
the rulings may be different.
may be different.
21
21 MR. DeFILIPPIS: fe
MR. DeFILIPPIS: will get
We will get on
on --
--
22
22 THE COURT:
THE COURT: --
-- if
if it's
it's the
the defendant's
defendant's statements,
statements,
23
23 then let's
then let's talk
talk about
about that
that either
either tomorrow
tomorrow morning or on
morning or on aa
24
24 sidebar.
sidebar.
25
25 MR. DeFILIPPIS: Okay.
MR. DeFILIPPIS: Understood, Your
Okay. Understood, Your Honor.
Honor.
2889
2889
1
1 Thank you.
Thank you.
2
2 THE COURT:
THE COURT: Anything else?
Anything else?
3
3 MR. BERKOWITZ: Nothing
MR. BERKOWITZ: Nothing else,
else, Your
Your Honor.
Honor.
4
4 THE COURT:
THE COURT: All
All right.
right.
5
5 Okay. We
Okay. We will
will see
see you
you folks
folks in
in the
the morning.
morning.
6
6 DEPUTY CLERK:
DEPUTY CLERK: This
This court
court is
is now
now adjourned.
adjourned. You
You
7
7 may be dismissed.
may be dismissed.
8
8 (Proceedings concluded
(Proceedings concluded at
at 3:30
3:30 p.m.)
p.m.)
9
9
10
10
1
11
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12
13
13
14
14
15
15
16
16
17
17
18
18
19
19
20
20
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2890
2890
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 May 25,
May 25, 2022
2022 Isl
/s/
DATE
DATE Lorraine T.
Lorraine T. Herman
Herman
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BY MR. KEILTY:
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MS. SHAW: [5] 2840/15 2849/23 2850/3 20s [1] 2870/1
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BY MS. RAO:
2874/16 115 [2] 2839/17 145 [5] 2833/14 2231 [1] 2833/15
[11] 2837/2
MS. YAO: [3] 2840/15 2839/24 2848/7 22nd [4] 2847/18
2838/5 2839/9
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THE COURT: [64] 118 [2] 2839/17 147 [1] 2839/25 24/7 [2] 2871/23
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THE WITNESS: 11:47 [1] 2847/25 149 [1] 2840/1 243 [1] 2852/21
BY MS. SHAW:
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BY MS. YAO: [1]
2856/14 2856/17 2846/11 152 [1] 2840/2
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DEPUTY CLERK: 30 [2] 2862/12
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[4] 2836/22 2862/16
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MR. '17 [1] 2853/17 333 [1] 2833/24
2849/5 2840/17
BERKOWITZ: '90s [1] 2859/4 3500 [2] 2884/22
123 [1] 2839/19 165 [2] 2840/4
[17] 2836/3 '96 [1] 2872/10 2885/6
123-125 [1] 2840/17
2854/23 2875/1 '97 [2] 2872/10 354-3187 [1]
2840/16 18th [2] 2851/20
2876/4 2876/17 2872/11 2833/25
124 [1] 2839/19 2880/9
2877/8 2877/24 'Hillary [1] 2846/9 125 [2] 2839/19 3:30 [1] 2889/8
1980 [1] 2865/23
2878/6 2878/24 'Rodney [1] 3rd [3] 2844/13
2840/16 1991 [1] 2866/20
2879/1 2879/6 2848/2 2845/12 2845/14
127 [2] 2839/20 1999 [1] 2868/4
2879/10 2879/17
2840/16 19th [4] 2852/6
2879/20 2879/25 / 4
1271 [1] 2833/19 2852/13 2853/9
2884/6 2889/2 /s [1] 2890/12 408 [2] 2878/10
128 [4] 2839/20 2854/11
MR. DeFILIPPIS: 2878/14
0 2840/16 2845/18 1:21-CR-00582-C
[15] 2875/3 410 [2] 2878/10
2847/4 RC-1 [1] 2833/3
2875/25 2876/8 08/08/2016 [1] 2878/14
12th [1] 2847/13
2876/11 2876/21 2845/4
130 [2] 2839/20 2
2878/14 2885/16 5
1 2840/16 20 [3] 2872/16
2886/9 2886/18 2873/2 2873/5 56 [4] 2876/4
10-minute [1] 132 [3] 2839/21
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2875/7 2840/16 2886/20
2888/6 2888/9 20002 [1] 2833/14 2880/9
134 [2] 2839/21
2888/20 2888/24 10020 [1] 2833/20 2005 [1] 2857/24 58 [2] 2876/4
2840/16
MR. KEILTY: [10] 102 [2] 2839/14 2016 [15] 2842/2 2876/6
136 [1] 2839/22
2840/12 2841/16 2840/15 2842/13 2844/14
2850/16 2851/2 105 [1] 2839/14 136-138 [1] 6
2840/16 2845/4 2846/5
2851/24 2852/10 105-107 [1] 2846/8 2846/12
602 [1] 2887/10
2840/15 137 [1] 2839/22 637-2231 [1]
2852/19 2853/4 2847/18 2847/25
2854/4 2854/14 106 [2] 2839/14 138 [2] 2839/22 2833/15
2840/16 2848/8 2851/20
MS. RAO: [17] 2875/14 66 [2] 2872/17
2853/16 2853/19
2836/8 2836/11 107 [2] 2839/15 14 [1] 2865/17 2872/22
140 [1] 2839/23 2854/12 2880/18
2836/18 2839/4 2840/15 6718 [1] 2833/24
2017 [6] 2853/11
2839/6 2839/12 109 [1] 2839/15 140-142 [1] 6:00 [1] 2887/25
2840/17 2853/15 2853/22
2840/10 2841/14 109-112 [1] 2853/25 2880/4
2840/15 141 [1] 2839/23
2844/5 2845/8
2892
9 2845/6 2872/18 Air [5] 2865/24 2868/20 2869/13

active [1] 2866/1 advanced [1] 2866/2 2866/6 2870/17 2871/16
906-1200 [1]
activity [1] 2866/9 2866/10 2866/11 2872/6
2833/20
2881/10 advise [3] 2871/9 albeit [1] 2887/4 always [3]
9th [2] 2847/25
actual [1] 2880/19 2880/20 Alfa [2] 2838/19 2858/19 2862/22
2849/15
2855/20 advocate [4] 2838/21 2869/19
A actually [3] 2865/24 2865/25 Alfa-Bank [2] am [9] 2838/1
a.m [1] 2883/24 2855/19 2855/21 2866/1 2866/7 2838/19 2838/21 2857/14 2857/17
abbreviated [1] 2864/6 affairs [1] ALGOR [1] 2857/21 2858/3
2842/5 addition [1] 2858/22 2833/12 2861/20 2865/15
abbreviation [1] 2847/10 affiliated [1] all [45] 2836/14 2874/3 2887/17
2842/8 additional [2] 2884/16 2836/17 2838/5 AMERICA [6]
abbreviations [1] 2880/2 2880/7 affirm [3] 2836/23 2839/7 2841/8 2833/2 2841/6
2842/7 additions [1] 2856/11 2865/1 2845/23 2846/19 2842/9 2847/19
abide [1] 2888/12 2875/14 afoul [1] 2884/11 2847/7 2847/8 2848/1 2850/4
ability [2] 2888/8 adjourned [1] after [7] 2866/3 2848/17 2850/8 America' [1]
2890/7 2889/6 2866/6 2870/2 2850/9 2851/1 2846/9
able [5] 2861/15 admin [2] 2859/5 2870/11 2872/16 2855/11 2855/13 Americas [1]
2862/6 2867/5 2859/5 2879/22 2882/4 2855/15 2856/6 2833/19
2876/23 2881/19 administration [3] afternoon [20] 2856/24 2858/5 amusement [1]
about [34] 2858/21 2858/23 2833/5 2836/9 2858/13 2859/23 2860/13
2836/24 2853/8 2884/21 2836/19 2836/21 2867/11 2868/17 ancillary [1]
2854/13 2855/20 admissible [2] 2837/5 2846/3 2868/25 2869/13 2872/13
2856/12 2859/10 2878/14 2887/15 2846/11 2850/20 2869/24 2870/10 Anderson [1]
2859/23 2860/19 admission [1] 2850/21 2856/6 2870/15 2872/4 2853/2
2861/10 2861/11 2886/21 2856/7 2856/22 2873/5 2874/6 ANDREW [1]
2863/24 2864/6 admitted [47] 2857/4 2857/5 2874/10 2874/13 2833/12
2865/2 2867/7 2834/15 2834/15 2863/13 2863/14 2875/6 2875/11 another [4]
2867/8 2867/21 2834/16 2834/16 2864/18 2864/19 2875/12 2876/15 2859/7 2870/3
2868/4 2869/19 2834/17 2834/17 2873/21 2873/22 2877/4 2878/18 2884/10 2885/8
2871/20 2872/18 2834/18 2834/18 again [6] 2849/13 2879/15 2883/19 answer [5]
2874/2 2874/7 2834/19 2834/19 2861/2 2862/23 2883/21 2884/2 2882/15 2882/16
2875/7 2875/21 2834/20 2834/20 2879/11 2883/24 2884/5 2889/4 2884/18 2887/21
2878/10 2880/17 2834/21 2834/21 2886/3 all-economic [1] 2888/1
2882/2 2884/1 2834/22 2834/22 against [1] 2858/5 answered [2]
2884/1 2884/13 2834/23 2834/23 2871/9 allegations [1] 2868/25 2884/25
2884/15 2886/7 2834/24 2834/24 agencies [2] 2838/19 anticipate [2]
2888/14 2888/23 2834/25 2834/25 2866/25 2867/8 allow [1] 2860/13 2878/23 2888/5
above [4] 2842/13 2835/2 2835/2 agency [2] allowed [1] anticipated [2]
2842/24 2890/4 2835/3 2835/3 2858/19 2883/6 2867/13 2868/10 2877/18
2890/6 2835/4 2835/4 agent [5] 2845/20 allowing [1] any [22] 2838/19
above-entitled [1] 2835/5 2835/5 2855/17 2881/16 2870/13 2838/24 2853/8
2890/6 2835/6 2835/6 2882/8 2884/14 almost [3] 2843/9 2855/6 2855/8
academic [1] 2835/7 2835/7 Agent Grasso [1] 2862/12 2862/16 2862/24 2874/16
2858/4 2835/8 2835/8 2884/14 alone [1] 2875/18 2875/20 2879/12
account [1] 2835/9 2835/9 agents [2] along [2] 2863/15 2880/25 2881/5
2886/13 2835/10 2835/10 2867/13 2869/11 2873/24 2881/7 2882/17
accurate [1] 2835/11 2835/11 agree [4] 2851/7 already [1] 2884/19 2884/21
2890/5 2840/17 2841/19 2854/8 2854/11 2839/8 2885/6 2885/7
accurately [1] 2887/1 2887/4 2876/15 also [14] 2840/20 2885/7 2885/23
2841/12 2887/12 agreed [1] 2872/3 2842/24 2848/7 2885/23 2887/18
act [3] 2881/20 admonished [1] Agriculture [1] 2857/17 2858/12 2888/17
2881/20 2882/3 2884/9 2858/21 2859/17 2860/19 anybody [1]
action [2] 2833/2 adopted [1] ahead [1] 2836/3 2861/19 2867/11 2868/24
2893
A 2882/2 2883/20 assist [2] 2840/20 B 2886/13 2887/1

2883/21 2883/21 2872/5 2888/12 2888/18
anyone [1] B-R-A-N-D-O-N
2885/19 2888/15 assistance [2] 2888/20 2889/7
2875/19 [1] 2837/7
2888/19 2848/4 2871/25 beauty [1]
anything [9] back [16] 2836/14
areas [1] 2888/19 assistant [7] 2870/23
2838/20 2855/3 2845/9 2847/1
around [4] 2838/5 2837/15 2859/5 became [5]
2863/24 2868/25 2848/6 2849/4
2866/15 2867/12 2859/6 2859/7 2861/6 2867/23
2869/19 2875/22 2849/12 2849/22
2872/10 2859/9 2859/24 2867/25 2868/8
2882/19 2886/7 2852/8 2852/11
Arsenault [1] 2868/17 2871/13
2889/2 2871/1 2875/9
2852/1 Assistants [1] because [15]
apparent [1] 2877/6 2879/15
as [57] 2838/16 2859/24 2845/17 2847/6
2845/6 2883/24 2884/8
2839/9 2840/25 assisted [1] 2847/8 2849/18
appear [4] 2886/20
2841/16 2843/10 2869/10 2862/16 2863/23
2843/23 2845/14 background [1]
2845/16 2845/16 assisting [2] 2867/8 2867/17
2853/22 2854/2 2865/20
2846/20 2847/21 2837/20 2837/22 2871/16 2872/7
APPEARANCES Baker [3] 2852/16
2853/1 2855/17 assume [3] 2877/21 2881/7
[1] 2833/11 2880/15 2880/19
2859/5 2859/12 2852/25 2854/8 2881/19 2882/24
appears [4] bank [3] 2838/19
2859/15 2860/16 2877/6 2886/24
2843/10 2847/17 2838/21 2873/14
2860/18 2861/4 assumed [1] become [2]
2848/9 2848/10 Banneker [1]
2861/22 2862/19 2883/12 2867/22 2869/13
Apple [1] 2870/18 2858/4
2862/19 2862/19 attachments [1] been [23]
apply [1] 2878/11 based [5] 2841/3
2862/23 2863/24 2877/21 2837/12 2840/24
applying [1] 2849/1 2857/20
2865/24 2866/10 attacks [1] 2845/3 2857/23 2862/16
2861/1 2857/21 2887/13
2866/19 2867/11 attend [1] 2862/17 2862/22
appreciate [2] basically [1]
2867/15 2867/24 2846/16 2862/22 2863/22
2848/4 2851/2 2883/22
2868/5 2868/14 attendee [1] 2864/9 2864/9
appreciated [1] basis [5] 2885/21
2868/15 2869/21 2846/20 2865/16 2867/25
2860/15 2886/5 2886/8
2869/22 2870/2 attendees [1] 2869/23 2870/11
approach [1] 2886/9 2886/17
2871/11 2872/13 2846/19 2870/14 2872/23
2839/5 be [57] 2836/5
2872/21 2874/3 attention [1] 2874/4 2874/8
appropriate [1] 2836/17 2836/18
2877/15 2882/1 2848/4 2874/14 2880/6
2882/5 2836/24 2838/1
2882/7 2883/20 attorney [4] 2883/3 2883/4
are [52] 2836/24 2843/16 2843/23
2885/21 2885/25 2845/1 2848/1 2887/15
2837/8 2837/10 2844/22 2847/4
2886/1 2886/24 2859/24 2868/17 before [11]
2839/7 2840/6 2847/17 2848/9
2887/5 2887/5 Attorney's [1] 2833/8 2836/6
2840/7 2840/8 2848/10 2852/17
2887/10 2887/12 2848/20 2848/6 2850/23
2841/9 2841/25 2853/21 2854/13
2887/17 2887/18 August [15] 2852/23 2853/16
2842/5 2842/14 2854/20 2855/4
2887/18 2887/21 2842/13 2844/13 2858/25 2866/21
2843/5 2843/25 2855/25 2856/10
2888/1 2888/1 2845/12 2845/14 2876/1 2876/17
2845/23 2846/16 2856/12 2865/2
aside [1] 2860/20 2846/2 2846/5 2880/3
2848/21 2849/2 2865/25 2867/3
ask [6] 2863/7 2846/8 2846/11 begin [2] 2844/8
2849/3 2850/6 2867/4 2867/5
2877/2 2882/19 2847/6 2847/11 2872/9
2850/20 2852/15 2867/6 2870/13
2885/21 2886/17 2847/12 2847/13 beginning [6]
2853/14 2854/23 2870/24 2871/21
2888/10 2847/25 2848/18 2841/22 2845/4
2854/24 2855/8 2873/15 2875/11
asked [2] 2870/7 2849/15 2855/16 2860/7
2856/12 2857/20 2877/5 2877/8
2870/10 AUSAs [4] 2867/15 2871/11
2857/22 2863/22 2877/12 2877/24
asking [1] 2886/5 2867/16 2868/25 behalf [1]
2863/23 2863/24 2878/11 2878/13
assertion [1] 2869/2 2869/11 2875/18
2864/3 2864/16 2878/14 2878/20
2886/25 Avenue [2] being [4] 2866/19
2865/2 2872/17 2878/23 2879/2
assigned [3] 2833/19 2833/24 2870/4 2885/2
2872/22 2874/3 2879/10 2879/12
2859/5 2859/7 aware [4] 2852/15 2887/16
2874/5 2874/22 2879/25 2880/14
2860/22 2853/14 2853/24 belief [2] 2884/24
2875/1 2875/18 2881/4 2881/14
assignment [1] 2854/1 2885/6
2876/24 2877/11 2881/19 2884/9
2866/4 believe [12]
2877/21 2878/15 2886/1 2886/10
2894
B BOSWORTH [1] business [2] 2881/8 2867/25 2871/12

2833/17 2848/19 2867/18 cannot [1] Charnov [11]
believe... [12]
both [9] 2843/6 2885/14 2836/20 2837/5
2836/17 2838/11
2843/18 2845/17 C care [1] 2883/23 2837/7 2839/11
2849/2 2849/20 C-H-A-R-N-O-V [1] career [1]
2848/22 2848/25 2840/6 2840/19
2852/24 2855/17 2837/7
2849/23 2862/6 2865/21 2841/1 2844/11
2855/22 2872/10 calendar [1]
2864/3 2868/7 careerwise [1] 2845/19 2850/15
2873/15 2876/5 2847/11
bottom [6] 2861/7 2850/18
2877/25 2880/4 calendars [2]
2843/23 2848/14 careful [3] 2884/9 chart [21]
believes [1] 2842/25 2843/1
2876/4 2876/6 2886/14 2888/12 2840/20 2841/3
2878/20 California [1]
2876/6 2880/9 case [21] 2838/18 2841/11 2841/16
Bench [6] 2848/21
box [3] 2842/16 2854/12 2855/16 2841/25 2843/14
2854/22 2855/14 call [5] 2836/4
2845/15 2845/15 2855/20 2863/24 2844/3 2845/13
2863/5 2863/10 2836/9 2855/23
boxes [6] 2864/7 2874/13 2847/4 2849/25
2874/24 2875/5 2868/15 2882/11 2875/14 2877/16
2842/14 2842/20 2850/1 2851/6
Benjamin [1] called [4] 2855/17 2877/17 2878/6
2843/6 2843/6 2851/23 2852/4
2858/4 2855/22 2861/18 2878/13 2878/20
2843/13 2850/11 2852/7 2852/8
BERKOWITZ [4] 2869/5
brain [1] 2870/4 2879/12 2881/16 2852/13 2853/11
2833/17 2876/2 calls [3] 2836/20 2882/8 2884/1
Brandon [3] 2853/18 2853/22
2876/16 2885/18 2856/3 2864/20
2836/20 2837/7 2884/2 2885/20 2854/2
best [4] 2876/10 came [9] 2859/4 2887/21 2888/5
2850/18 chat [1] 2848/19
2881/23 2883/13 2862/9 2866/13
break [2] 2874/25 cases [4] 2837/20 chief [10]
2890/7 2870/2 2870/12
2875/7 2867/7 2867/17 2857/17 2857/18
between [3] 2872/5 2872/19
briefing [3] 2872/5 2862/5 2866/11
2838/15 2843/1 2875/13 2887/16 CATHERINE [1]
2846/6 2846/10 2867/25 2868/1
2878/12 campaign [9]
2846/13 2833/18 2868/5 2868/7
beyond [4] 2841/7 2842/11
briefings [1] CCIPS [3] 2868/8 2885/20
2855/6 2855/7 2844/14 2845/3
2845/21 2867/24 2868/8 child [1] 2859/20
2861/5 2862/22 2846/10 2846/12 2874/2
briefly [5] 2848/9 children [2]
big [2] 2872/14 2847/20 2848/1
2850/17 2857/25 CCR [1] 2833/23 2870/6 2870/21
2887/20 2884/17
2865/21 2882/9 centered [1] choose [1]
biggest [1] can [42] 2837/5
bring [4] 2859/22 2870/23 2878/24
2871/24 2837/16 2842/14 certainly [6]
2877/6 2879/15 chose [2]
billing [1] 2853/9 2843/7 2844/7
2883/24 2860/14 2871/4 2877/15 2882/23
binder [6] 2844/11 2845/9
bringing [1] 2877/11 2884/15 CHRISTOPHER
2837/22 2839/9 2845/12 2845/15 2886/13 2887/24
2881/21 [1] 2833/8
2839/11 2839/13 2846/1 2846/2
BRITTAIN [1] certify [1] 2890/4 CIA [2] 2853/15
2840/7 2841/9 2846/2 2847/3
2833/13 chain [2] 2844/22 2853/24
bit [8] 2852/2 2847/24 2848/8
Brittany [2] 2845/23 clarify [1]
2856/23 2859/22 2848/13 2848/16 chaired [1]
2863/15 2873/23 2838/18
2861/11 2861/23 2848/24 2849/4
Brittany Shaw [2] 2871/12 clear [6] 2853/21
2862/3 2871/1 2849/13 2851/3
2863/15 2873/23 challenge [1] 2863/21 2874/6
2873/6 2851/25 2852/1
brother [1] 2870/3 2881/4 2886/10
blank [1] 2869/5 2852/6 2852/11
2870/13 chance [1] 2886/25
blow [2] 2849/6 2852/20 2854/20 2877/1
brought [3] Cleaves [1]
2880/10 2856/24 2857/6
2861/18 2861/19 change [1] 2844/6
blue [10] 2843/5 2857/25 2865/20 2863/7
2884/17 client [3] 2843/20
2843/9 2843/11 2871/2 2872/24
buckets [2] changed [1] 2875/19 2875/21
2843/12 2845/15 2874/4 2877/7
2838/13 2839/2 2867/6 clients [9] 2839/3
2845/16 2847/13 2877/13 2877/17 character [6]
building [1] 2841/24 2842/4
2847/14 2850/2 2879/21 2882/2
2867/18 2854/23 2855/3 2842/19 2843/16
2850/4 2887/21 2887/24 2855/9 2855/22
Bureau [4] 2843/18 2848/22
born [1] 2858/3 2888/1
2876/11 2881/22 2855/23 2862/25 2848/25 2849/2
boss [2] 2859/12 candidate [1]
2882/6 2883/13 Charney [2] Clinton's [1]
2859/13
2895
C company [7] 2869/7 2865/10 2866/25 2881/17

2857/15 2861/18 consulted [1] 2867/1 2867/14 created [3]
Clinton's... [1]
2861/19 2862/2 2866/24 2867/16 2880/5 2841/3 2871/23
2846/9
2862/7 2862/7 consulting [1] 2881/25 2882/15 2872/3
close [4] 2877/16
2862/9 2861/8 2884/23 2887/5 credit [1] 2872/25
2879/7 2879/17
complete [3] CONT'D [1] 2887/9 2888/10 crime [7] 2863/8
2882/3
2868/4 2875/16 2835/1 Council [1] 2866/19 2867/2
closely [1]
2890/6 contained [1] 2872/15 2867/9 2867/23
2860/17
completely [1] 2886/24 counsel [16] 2871/10 2872/24
closer [3] 2843/6
2859/23 contains [1] 2838/12 2852/16 criminal [6]
2856/24 2883/7
compliance [1] 2839/12 2857/14 2857/22 2833/2 2845/6
closings [1]
2857/17 contemporaries 2861/16 2861/23 2860/23 2860/24
2879/9
complicated [1] [1] 2870/14 2863/4 2873/24 2868/15 2878/13
Coie [1] 2861/17
2869/12 contest [1] 2874/23 2875/8 criminals [1]
colleagues [3]
computer [6] 2875/25 2880/13 2882/23 2867/12
2848/19 2863/16
2866/19 2867/2 continue [2] 2883/6 2884/9 critical [1]
2873/24
2867/23 2871/10 2860/19 2882/15 2885/16 2886/4 2854/12
college [1]
2872/1 2872/24 continued [1] COUNSEL'S [1] cross [14] 2834/4
2858/7
computer-related 2862/8 2833/13 2834/7 2834/10
colored [2]
[1] 2871/10 continues [1] counterparts [1] 2850/18 2855/2
2842/14 2842/16
conclude [1] 2885/15 2867/14 2863/11 2873/19
colors [3] 2843/8
2879/7 continuing [1] countries [4] 2878/3 2879/4
2843/13 2851/9
concluded [4] 2885/14 2871/8 2872/7 2884/14 2885/19
COLUMBIA [1]
2855/14 2863/10 contrary [1] 2872/17 2872/22 2887/23 2888/11
2833/1
2875/5 2889/8 2878/20 country [3] 2888/16
come [8] 2859/3
conference [6] controversial [1] 2872/3 2876/11 cross-examinatio
2862/20 2862/21
2854/22 2855/14 2881/12 2883/14 n [11] 2834/4
2868/13 2869/7
2863/5 2863/10 convention [1] couple [4] 2836/6 2834/7 2834/10
2875/9 2875/18
2874/24 2875/5 2872/22 2859/8 2865/22 2850/18 2863/11
2878/11
confidant [1] conversation [1] 2876/24 2873/19 2879/4
comfortable [1]
2861/2 2880/16 course [4] 2863/3 2884/14 2885/19
2856/9
confidence [2] conveyed [1] 2867/15 2868/12 2887/23 2888/11
coming [3]
2873/12 2873/12 2880/23 2870/9 cross-examining
2871/17 2881/18
confidential [1] COOPER [1] court [11] 2833/1 [2] 2855/2 2878/3
2885/11
2877/21 2833/8 2833/23 2833/23 crossroads [1]
comments [1]
confirm [1] copied [1] 2839/8 2876/1 2887/20
2884/11
2839/1 2848/21 2886/3 2886/23 current [1]
commissioned [1]
confirms [1] copy [1] 2839/9 2886/25 2887/17 2857/10
2865/23
2878/19 corporation [2] 2889/6 2890/3 currently [5]
Committee [5]
congratulations 2857/13 2857/13 Court's [1] 2837/8 2857/12
2841/6 2841/7
[1] 2851/1 Corps [1] 2858/7 2888/19 2857/20 2857/21
2842/9 2842/11
Congressional [3] correct [16] Courthouse [1] 2865/14
2846/12
2841/7 2842/10 2844/1 2851/9 2833/24 cut [1] 2883/15
communicating
2846/12 2851/12 2853/12 courtroom [7] CY [1] 2845/1
[1] 2884/13
connected [1] 2853/13 2853/20 2836/13 2856/10 cyber [2] 2845/6
communication
2860/17 2854/3 2854/9 2874/9 2874/14 2847/19
[3] 2842/17
connection [3] 2864/2 2864/10 2875/10 2879/24
2842/21 2847/5
2838/8 2840/19 2877/8 2877/9 2884/4 D
communications D.C [1] 2858/3
2885/7 2877/22 2877/24 cover [1] 2875/23
[7] 2841/4 dark [2] 2845/16
consider [1] 2877/25 2878/7 covers [1]
2841/23 2842/4 2847/13
2885/12 could [18] 2851/11
2849/19 2849/25 darkest [1]
Constitution [1] 2843/16 2844/6 CR [1] 2833/3
2850/12 2851/17 2843/12
2833/24 2844/24 2849/6 CRC [1] 2833/3
companies [2] data [3] 2841/3
constructs [1] 2856/8 2864/24 create [2] 2871/8
2861/16 2867/1
2896
D 2886/15 2869/5 2869/10 2889/7 2838/16 2838/20

defer [1] 2877/5 2869/14 2871/22 dispute [1] 2838/23 2838/25
data... [2] 2872/7
DeFILIPPIS [2] 2872/9 2873/12 2875/24 2839/4 2840/20
2887/16
2833/12 2878/19 2874/12 2874/12 DISTRICT [4] 2843/18 2844/2
date [10] 2839/1
definitely [4] 2875/18 2875/20 2833/1 2833/1 2850/8 2851/17
2842/21 2847/6
2854/2 2860/22 2875/21 2876/8 2833/9 2848/20 2875/20
2850/9 2851/20
2861/24 2861/24 2876/22 2877/16 division [2] does [12] 2841/8
2852/6 2853/1
degree [1] 2866/9 2880/11 2880/16 2860/23 2860/24 2841/25 2842/20
2853/18 2854/12
delay [1] 2877/15 2880/19 2880/21 division's [2] 2843/13 2846/15
2890/12
delegation [2] 2880/22 2880/25 2868/15 2868/18 2846/17 2847/21
dated [3] 2844/13
2871/13 2872/12 2881/2 2882/10 divorce [1] 2853/22 2865/25
2847/18 2848/8
delegations [1] 2882/25 2886/21 2860/11 2875/24 2886/22
dates [2] 2843/4
2871/17 didn't [14] 2853/8 DNC [13] 2842/8 2888/5
2852/9
demanding [1] 2861/7 2870/16 2843/11 2845/1 doesn't [1]
day [8] 2842/17
2859/13 2881/4 2882/5 2845/16 2846/6 2854/2
2843/19 2850/12
Democratic [5] 2882/6 2882/17 2846/16 2846/20 doing [4] 2866/16
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2842/8 2842/10 2884/19 2885/22 2848/11 2849/1 2879/5
2884/8
2846/12 2886/11 2887/6 2850/2 2850/7 DOJ [1] 2848/11
days [3] 2848/19
Department [17] 2887/7 do [47] 2836/4 domestically [1]
2851/14 2871/7
2858/14 2858/16 died [1] 2869/25 2836/23 2837/1 2869/11
DC [2] 2833/14
2858/17 2858/18 different [12] 2837/18 2838/3 don't [26] 2836/2
2833/25
2858/21 2858/24 2842/16 2843/6 2838/24 2842/25 2836/5 2846/18
DCCC [10]
2861/11 2865/15 2843/19 2849/25 2849/17 2856/11 2852/24 2854/13
2842/10 2846/12
2866/14 2866/16 2851/16 2851/17 2856/14 2859/1 2854/14 2854/14
2846/16 2846/24
2866/18 2867/22 2860/14 2860/24 2859/2 2862/3 2854/25 2855/8
2847/8 2847/14
2868/5 2878/18 2871/18 2871/18 2862/6 2865/1 2863/7 2863/19
2848/12 2849/2
2878/21 2882/1 2885/20 2888/20 2865/4 2865/5 2864/6 2874/1
2850/2 2850/7
2883/4 differently [1] 2865/14 2865/14 2876/18 2878/11
DDOS [2] 2845/3
dependent [1] 2842/14 2866/3 2866/24 2879/11 2879/15
2848/4
2855/4 differently-colore 2868/10 2868/22 2881/22 2882/20
dealing [1]
deputy [5] d [1] 2842/14 2871/14 2873/17 2883/6 2885/12
2878/22
2856/10 2859/24 diplomatic [1] 2875/22 2876/16 2886/4 2887/9
December [2]
2868/1 2868/7 2871/16 2876/25 2877/1 2887/11 2888/8
2880/4 2880/9
2868/16 direct [4] 2834/4 2877/2 2877/12 2888/16
decide [1]
describe [1] 2834/7 2834/10 2877/13 2877/17 done [1] 2836/5
2881/19
2871/2 2875/21 2878/16 2880/19 down [1] 2852/1
decided [2]
describing [1] direction [2] 2880/20 2881/23 drill [1] 2836/22
2871/8 2871/21
2887/18 2861/4 2877/19 2881/24 2882/19 Drug [1] 2858/20
decision [4]
detailed [1] directions [1] 2883/12 2884/6 dump [1] 2881/16
2877/5 2877/9
2851/6 2838/24 2884/24 2884/25 dumping [1]
2877/10 2877/19
develop [2] disagree [2] 2885/12 2885/14 2882/8
decisions [1]
2859/17 2871/14 2854/14 2886/4 2887/24 2890/3 duty [3] 2866/1
2861/5
developed [1] discovery [1] document [15] 2872/4 2872/4
declare [3]
2870/4 2838/12 2837/22 2839/1 DX [3] 2839/14
2836/24 2856/12
did [41] 2838/19 discuss [1] 2839/1 2843/17 2850/3 2850/6
2865/2
2840/20 2840/22 2874/13 2845/19 2845/20 DX-102 [1]
Defendant [2]
2841/11 2849/24 discussing [1] 2847/16 2847/21 2839/14
2833/6 2833/17
2853/9 2853/16 2861/8 2848/8 2848/24 DX-144 [1] 2850/3
defendant's [3]
2858/12 2858/18 discussions [1] 2849/16 2850/6 DX-145 [1] 2850/6
2888/13 2888/16
2859/3 2859/17 2884/1 2852/4 2886/23
2888/22
2860/4 2860/6 dismiss [1] 2887/3 E
defense [72] E-L-L-I-O-T-T [1]
2860/19 2866/3 2883/23 documents [13]
defense's [3] 2857/9
2868/13 2869/3 dismissed [1] 2838/7 2838/10
2836/18 2879/16
2897
E emails [3] 2860/14 examining [2] extent [1]

2838/13 2888/14 eventually [2] 2855/2 2878/3 2869/18
each [3] 2842/16
2888/15 2860/5 2861/3 example [2] extortion [2]
2843/19 2864/3
employed [2] ever [1] 2870/19 2850/11 2878/12 2844/14 2845/2
earlier [2] 2839/2
2837/8 2837/10 every [3] 2861/7 examples [1]
2840/9
employees [2] 2866/25 2872/3 2844/4 F
early [3] 2859/4 face [1] 2878/10
2845/24 2849/10 everybody [8] except [1]
2870/1 2883/24 fact [2] 2877/22
employment [2] 2869/3 2869/3 2869/25
earnest [1] 2886/1
2858/2 2860/4 2869/7 2869/9 excerpts [5]
2873/11 faculty [1] 2866/7
end [1] 2862/2 2869/10 2869/14 2875/13 2875/17
easy [1] 2867/12 fair [4] 2854/15
ended [1] 2858/8 2869/17 2879/25 2875/23 2879/16
ebullient [1] 2873/5 2883/15
engage [1] everyone [1] 2883/20
2870/19 2888/15
2861/15 2836/16 exclude [1]
economic [1] fairly [3] 2841/11
engagements [1] everything [2] 2887/17
2858/5 2854/11 2871/13
2881/2 2869/14 2878/17 excluded [1]
EDGAR [1] faith [5] 2862/24
engages [1] evidence [55] 2888/15
2833/12 2885/21 2886/5
2857/13 2834/15 2834/15 excused [3]
educational [1] 2886/7 2886/9
England [1] 2834/16 2834/16 2854/20 2864/16
2858/2 fall [1] 2838/2
2858/13 2834/17 2834/17 2874/22
eight [1] 2871/17 family [7] 2862/21
enlisted [1] 2834/18 2834/18 exhibit [69]
either [3] 2843/16 2862/21 2869/22
2858/6 2834/19 2834/19 exhibits [14]
2888/5 2888/23 2869/24 2870/5
enough [2] 2834/20 2834/20 2835/1 2839/7
election [2] 2870/6 2870/8
2854/13 2883/15 2834/21 2834/21 2839/12 2839/14
2882/3 2882/4 far [1] 2887/5
ensure [1] 2834/22 2834/22 2840/6 2840/8
electronic [1] fascinating [1]
2841/11 2834/23 2834/23 2840/8 2840/12
2869/12 2874/2
entered [2] 2834/24 2834/24 2840/15 2840/21
elicit [1] 2884/24 father [1] 2869/25
2836/13 2879/24 2834/25 2834/25 2841/8 2842/18
elicited [1] FBI [29] 2838/11
enterprise [1] 2835/2 2835/2 2843/23 2843/24
2886/12 2838/14 2838/15
2857/18 2835/3 2835/3 existed [1]
Elliott [8] 2856/4 2838/16 2841/23
entire [1] 2857/18 2835/4 2835/4 2866/21
2856/22 2857/4 2843/2 2844/13
entities [1] 2835/5 2835/5 exited [2]
2857/7 2857/8 2844/17 2845/20
2857/16 2835/6 2835/6 2875/10 2884/4
2857/10 2863/1 2845/20 2845/23
entitled [2] 2835/7 2835/7 expected [2]
2863/11 2846/7 2846/11
2877/12 2890/6 2835/8 2835/8 2867/3 2887/13
Elliott-Stevens [4] 2846/13 2847/17
entity [2] 2847/19 2835/9 2835/9 expecting [1]
2856/4 2857/7 2847/25 2848/11
2857/14 2835/10 2835/10 2884/20
2857/8 2863/11 2848/18 2848/19
entity-Hillary [1] 2835/11 2835/11 experience [1]
else [4] 2875/19 2849/9 2849/10
2847/19 2840/12 2841/16 2868/19
2885/12 2889/2 2850/3 2852/16
escaped [1] 2842/18 2855/20 experiences [1]
2889/3 2876/8 2880/11
2869/24 2864/5 2864/8 2871/18
email [27] 2882/13 2882/14
ESQ [7] 2833/12 2867/10 2867/17 expert [2]
2844/13 2844/19 2882/18 2882/24
2833/12 2833/13 2872/5 2874/9 2855/17 2866/25
2844/22 2845/1 FBI's [1] 2841/4
2833/17 2833/17 2874/15 2883/20 experts [4]
2845/12 2845/17 FDA [1] 2858/20
2833/18 2833/18 2885/20 2855/19 2866/22
2845/20 2845/23 February [3]
estimate [1] evidentiary [1] 2866/25 2869/13
2846/2 2846/15 2853/15 2853/22
2879/3 2884/10 explain [8]
2847/7 2847/9 2853/25
Europe [1] examination [14] 2837/16 2841/21
2847/11 2848/1 federal [1]
2872/15 2834/4 2834/4 2842/15 2843/7
2848/2 2848/10 2861/14
even [4] 2860/16 2834/7 2834/7 2844/11 2845/12
2849/7 2849/9 feel [2] 2856/16
2862/6 2862/7 2834/10 2834/10 2847/3 2887/16
2849/18 2884/12 2882/21
2870/16 2850/18 2863/11 extended [1]
2885/23 2886/21 feelings [1]
evening [1] 2873/19 2879/4 2872/21
2887/6 2887/8 2874/7
2877/3 2884/14 2885/19 extensive [1]
2887/9 2887/18 feet [1] 2870/19
events [1] 2887/23 2888/11 2855/4
2887/19
2898
F follow [4] 2874/18 2857/13 2867/8 2879/14 2886/5

2875/20 2880/25 future [1] 2884/21 globally [1] government [19]
fell [2] 2838/12
2882/17 2882/21 2857/18 2850/23 2853/5
2872/2
follow-on [1] G go [19] 2836/2 2858/23 2861/14
fellows [1] G-A-M-M [1]
2880/25 2844/23 2849/4 2866/22 2875/18
2870/19 2865/13
follow-up [2] 2849/12 2849/22 2875/24 2876/21
femoral [1] G7 [3] 2871/7
2875/20 2882/17 2852/1 2852/6 2877/11 2878/3
2867/18 2872/12 2872/19 2852/11 2854/25
followed [1] 2878/4 2878/5
few [4] 2837/24 G8 [5] 2871/6
2884/19 2858/25 2866/8 2878/9 2880/2
2844/4 2861/16 2871/6 2871/20
Food [1] 2858/20 2867/3 2870/7 2880/8 2881/11
2866/21 2872/2 2872/22
Force [4] 2865/24 2878/5 2881/25 2885/22 2887/22
fighting [1] gained [1]
2866/2 2866/6 2883/10 2885/15 2888/5
2872/24 2888/14
2866/10 2886/20 2888/4 government's [5]
figure [2] 2866/24 game [1] 2888/15 Godfather [1]
Forces [1] 2851/25 2852/20
2867/6 Gamm [3]
2866/11 2860/18 2855/16 2875/14
figured [1] 2867/4 2864/20 2865/12 goes [2] 2853/11
foregoing [1] 2887/14
file [1] 2877/16 2873/19
2890/4 2855/12 graduated [1]
filed [3] 2876/17 gather [1] 2872/5 going [21]
foreign [1] 2858/10
2877/21 2878/9 gave [2] 2858/19 2844/22 2845/14
2881/11 Grasso [1]
filing [1] 2885/13 2870/10
forged [1] 2860/3 2858/15 2859/6 2884/14
filings [1] general [6]
form [1] 2843/16 2860/10 2865/20 Grasso's [1]
2837/22 2852/16 2857/14 2867/4 2868/20
formed [1] 2886/2
fills [1] 2836/16 2868/17 2880/12 2875/7 2875/8
2866/20 great [8] 2836/12
final [1] 2877/19 2882/23 2883/6
former [1] 2862/6 2876/10 2876/13 2850/22 2859/13
finally [2] 2843/22 generally [4]
forward [5] 2882/8 2883/23 2864/16 2865/18
2862/12 2838/10 2844/16 2884/7 2887/17
2845/4 2854/25 2871/20 2873/1
find [3] 2866/25 2859/11 2875/15 2887/22 2888/3
2878/5 2888/4 2874/22
2867/14 2867/16 Generals [1]
2888/11 2888/4 2888/11 green [1] 2845/5
finish [1] 2854/6 2859/25
found [2] 2868/14 2888/18 gregarious [1]
finished [2] gentlemen [4]
2869/21 gone [2] 2877/18 2859/23
2858/22 2868/5 2836/15 2855/15 2879/22
foundation [1] grew [1] 2860/16
fire [2] 2869/24 2875/6 2883/19
2887/2 good [31] 2836/9 ground [3]
2869/25 George [1]
FOUO [4] 2836/19 2836/21 2855/2 2863/6
firm [4] 2861/19 2858/11
2844/15 2845/21 2837/5 2844/25 2875/24
2862/2 2862/8 Germany [3]
2845/22 2847/18 2846/3 2850/20 group [2] 2846/5
2862/10 2866/4 2866/5
four [2] 2866/4 2850/21 2850/21 2846/8
firms [2] 2861/17 2866/6
2885/4 2856/6 2856/7 growing [2]
2862/2 get [9] 2836/3
frankly [2] 2855/8 2856/22 2857/4 2867/21 2869/1
first [11] 2844/24 2844/2 2855/8
2887/8 2857/5 2859/16 guardrails [1]
2846/3 2847/5 2868/21 2870/9
free [1] 2856/16 2863/13 2863/14 2884/9
2851/1 2852/17 2877/13 2887/21 2863/22 2863/22
Friday [2] 2846/8 guess [3]
2855/10 2857/7 2888/1 2888/21
2879/6 2864/18 2864/19 2872/10 2875/12
2866/4 2866/19 getting [2]
friend [1] 2863/24 2873/21 2873/22 2885/17
2866/23 2875/12 2869/17 2871/25 2875/2 2876/15
friends [3] guidance [1]
fit [1] 2871/15 give [7] 2836/24 2884/2 2884/3
2860/12 2863/22 2861/4
five [2] 2866/20 2839/9 2856/12
2863/22 2885/21 2886/5 guidelines [1]
2867/21 2858/1 2865/2
friendship [1] 2886/7 2886/9 2882/2
focus [1] 2841/25 2870/8 2877/2
2860/5 good-faith [3] guilty [1] 2863/8
focused [2] given [5] 2838/7 2885/21 2886/7
front [3] 2860/23 guy [2] 2873/11
2838/19 2849/14 2838/23 2838/24 2886/9
2868/14 2880/5 2886/6
focuses [1] 2845/6 2866/8
full [1] 2844/9 goodness [1] GX [1] 2886/20
2842/1 giving [1] 2861/4 2865/17
further [5] GX-132 [1]
folks [4] 2846/5 glad [1] 2885/18 got [5] 2859/23
2850/14 2854/5 2886/20
2846/8 2884/16 global [2]
2854/18 2863/2 2861/5 2866/18
2889/5
2899
H 2846/7 2861/8 2861/11 2880/1 2883/17 2857/1 2857/18

Heads [1] 2871/7 2861/12 2862/9 2885/4 2885/17 2875/8 2879/5
half [2] 2866/5
hear [1] 2856/24 2862/23 2863/7 2885/22 2886/11 2879/17 2882/20
2866/5
heard [1] 2874/16 2868/13 2868/21 2886/19 2887/25 2884/7
hand [4] 2836/22
hearing [2] 2869/16 2870/10 2888/10 2888/16 I've [6] 2854/10
2843/22 2856/9
2852/17 2884/20 2870/15 2870/17 2888/25 2889/3 2862/19 2862/21
2864/24
hearsay [2] 2870/18 2870/23 Honor's [1] 2862/24 2875/13
handling [1]
2885/24 2886/23 2871/2 2872/11 2888/12 2875/23
2849/19
Heide [2] 2887/5 2873/15 2874/8 HONORABLE [1] idea [3] 2836/12
hands [1]
2887/18 2875/22 2878/3 2833/8 2872/18 2872/23
2882/22
held [2] 2833/8 2880/23 2881/4 hop [1] 2867/12 ideas [1] 2869/8
happened [1]
2869/8 2881/6 2881/7 hope [2] 2836/15 identification [2]
2870/1
help [8] 2867/1 2881/13 2881/18 2848/17 2839/12 2840/25
happy [1] 2839/8
2867/14 2867/16 2881/19 2881/21 hoped [1] ill [1] 2870/12
hard [4] 2859/14
2870/6 2870/8 2882/7 2882/9 2883/12 important [6]
2859/14 2862/24
2877/10 2877/14 2882/16 2882/25 hopefully [2] 2871/5 2871/22
2878/11
2877/19 2882/25 2883/2 2873/3 2879/12 2872/6 2872/7
hard-pressed [1]
her [6] 2863/7 2883/7 2885/5 horrible [1] 2872/18 2872/23
2878/11
2863/7 2870/8 2886/8 2869/23 impress [1]
hard-working [1]
2870/9 2870/13 hired [1] 2868/2 hotel [1] 2869/24 2862/5
2862/24
2870/13 his [25] 2850/7 hours [1] 2878/25 impression [2]
HARDWICK [1]
here [13] 2837/21 2860/16 2862/5 House [1] 2880/4 2862/14 2873/9
2833/18
2842/6 2843/25 2862/9 2862/14 how [22] 2837/12 inclined [1]
Harvard [1]
2845/13 2849/14 2862/21 2862/25 2844/3 2845/12 2870/24
2866/8
2849/15 2849/17 2862/25 2868/1 2847/3 2849/24 included [1]
has [15] 2839/8
2863/23 2863/24 2868/20 2869/22 2850/20 2855/11 2850/9
2840/24 2850/2
2864/9 2864/9 2869/22 2869/24 2857/22 2859/3 includes [1]
2850/8 2857/15
2874/9 2886/15 2869/25 2870/1 2859/9 2859/12 2839/13
2862/16 2862/22
hereby [1] 2890/4 2870/3 2870/9 2865/16 2867/7 including [2]
2864/8 2870/22
Herman [3] 2870/14 2870/18 2867/10 2867/20 2838/16 2881/24
2870/22 2870/23
2833/23 2890/3 2870/19 2873/9 2868/13 2876/16 incorporated [1]
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2890/12 2873/13 2883/9 2878/21 2878/22 2872/19
2874/15 2877/18
HFA [11] 2842/9 2887/9 2887/19 2880/21 2887/9 incredibly [2]
have [64]
2843/10 2843/11 history [1] 2858/2 2887/16 2859/21 2861/25
haven't [7]
2845/16 2846/9 holding [1] HQ [3] 2846/11 indicate [1]
2852/25 2863/25
2846/16 2846/22 2857/15 2846/14 2848/18 2846/15
2864/5 2864/9
2847/8 2848/1 home [1] 2879/19 HSPCI [3] indicates [2]
2874/4 2874/14
2850/2 2850/5 honest [4] 2875/13 2877/7 2842/18 2850/7
2874/16
high [5] 2858/1 2852/17 2854/13 2879/16 individual [1]
having [3] 2847/7
2858/5 2858/5 2862/23 2873/15 huh [1] 2871/4 2850/8
2871/24 2883/3
2862/2 2871/2 honesty [2] human [2] individuals [2]
Hawaii [2]
high-end [1] 2862/14 2873/9 2858/13 2867/19 2845/23 2846/15
2866/10 2866/13
2862/2 Honor [34] hyphen [2] industry [2]
Hays [2] 2849/9
highly [1] 2836/9 2836/19 2857/9 2865/13 2858/25 2861/15
2849/17
2881/11 2839/5 2840/11 inform [2]
he [65]
Hillary [7] 2841/6 2840/13 2841/15 I 2877/10 2877/19
he's [4] 2862/20 I'd [2] 2840/24
2842/9 2844/14 2850/17 2854/16 information [13]
2862/21 2873/11 2870/19
2845/3 2847/19 2854/18 2854/24 2844/8 2844/17
2886/6 I'll [1] 2877/6
2848/1 2850/4 2855/1 2855/5 2848/15 2848/21
head [3] 2871/12 I'm [16] 2837/21
him [46] 2836/4 2864/14 2874/18 2875/21 2880/22
2876/9 2879/5 2839/11 2850/21
2843/17 2843/19 2875/3 2875/4 2881/5 2881/8
header [1] 2844/7 2850/22 2852/8
2859/3 2859/5 2876/1 2876/5 2881/9 2881/16
heading [1] 2852/17 2853/5
2859/7 2860/13 2876/12 2876/18 2881/21 2882/17
2837/24 2853/16 2855/3
2860/20 2861/8 2876/22 2878/15 2883/11
headquarters [1]
2900
I 2850/7 June [2] 2842/1 2881/22 2881/23 lay [2] 2855/19

involves [1] 2842/13 2881/25 2882/5 2867/10
initial [1] 2888/17
2841/4 junior [1] 2837/17 2882/25 2883/2 leading [2]
inquire [1]
involving [3] jury [17] 2833/8 2883/2 2883/5 2872/11 2872/12
2885/21
2838/13 2881/8 2836/2 2836/11 2883/5 2883/5 learn [2] 2867/7
inquiring [2]
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Intellectual [1]
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2870/17 Joffe [3] 2884/13 2844/11 2854/13 LATHAM [3] level [4] 2846/7
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2838/15 2860/25 join [1] 2860/13 2855/10 2855/19 2837/14 2871/2
international [6] joke [1] 2861/24 2859/1 2859/3 Laughs [1] life [3] 2860/7
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Lucy [1] 2846/4 2885/22 2890/7 2857/22 2858/16 2843/7 2851/11
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little [8] 2852/1 made [3] 2861/7 2855/24 met [5] 2848/17 most [7] 2870/19
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me [15] 2844/25 2852/16 2870/18 2871/5 2871/22
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LLP [1] 2833/19 2861/7 2869/8
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logistics [1] 2871/9 2878/17 2880/10 2880/20 2848/17 2859/1 mother [1] 2870/9
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long [15] 2837/12 making [1]
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look [15] 2844/4 Marjorie [3]
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2845/13 2849/23 Martha [2]
2882/11 2882/12 middle [4] Mr. [42] 2839/3
looking [4] 2865/12 2873/19 meetings [5] 2842/12 2843/11 2841/5 2841/24
2848/24 2849/16 Martin [1]
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Lorraine [3] Marty [1] 2864/20 2847/10 mike [2] 2850/22 2844/6 2844/11
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lot [16] 2849/19 mask [3] 2836/22
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Ms. 2841/6 2842/9 2876/9 2839/12 2851/16
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Elliott-Stevens nationwide [1] nodding [1] numbers [1]
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Ms. Jimma [1] nature [2] 2845/6 Northeast [1] NY [1] 2833/20
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Ms. Rao [5] need [6] 2836/5 Northern [1] O
2885/18 2886/2 object [4]
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much [9] 2851/2 needed [8] 2851/24 2852/5
Mr. Berkowitz [3] 2885/3
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Mr. Cleaves [1] objections [2]
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2843/16 2843/17 negotiations [2] 2876/13 2876/23
Mr. DeFilippis [1] obtain [1]
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my [38] 2837/15 neither [1] 2850/7 2878/5 2878/20
Mr. Heide [2] obviously [6]
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Mr. Sussmann occasions [1]
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okay [65]
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older [1] 2870/3
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once [2] 2861/6
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one [24] 2836/5
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opened [1]
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opinion [2]
over [5] 2860/7 party [2] 2884/16 2872/16 2874/21 2878/11
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2865/17 2873/2 2887/8 point [4] 2859/17 pretried [1]
opportunity [2]
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overall [2] penalty [3] 2888/8 pretty [5] 2851/6
oppose [1]
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opposed [1]
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order [3] 2872/4
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organization [1]
Oxford [1] 2871/15 2879/20 2880/2 2880/7 privacy [1]
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organizations [1]
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2845/22 P Perkins [1] 2884/21 2845/21 2858/7
organizations-un p.m [3] 2833/4
2861/17 potential [4] 2858/25 2861/15
classified [1] 2847/25 2889/8 permission [2] 2845/5 2881/10 probably [3]
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oriented [1] 2866/11 person [4] potentially [1] 2881/14
2871/21 page [11] 2834/2 2870/25 2873/11 2883/10 problem [4]
originally [1] 2834/14 2835/1 2873/16 2883/10 practically [1] 2867/2 2867/5
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originated [1] 2848/15 2876/4 2859/17 2882/10 practice [1] problems [1]
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other [16] 2880/5 2880/9 2887/9 preclude [3] procedurally [1]
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perspectives [1] preindictment [3] 2889/8 2890/6
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really [8] 2859/14 Regards [2] 2839/3 2862/10
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professionally [2] 2886/17 2886/24
reason [3] relate [1] 2875/15 represents [4]
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program [2] 2850/14 2854/5
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rebuttal [2] 2841/23 2842/4 reproach [1]
progress [2] 2868/25 2874/1
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recall [2] 2868/16 2884/10 2884/13 reputation [2]
project [3] 2874/23 2876/22
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receive [3] 2846/6 relating [1] request [3]
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projects [2] 2877/18
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Street [1] 2833/14 2848/2 2848/11 2857/18 2858/19
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Stansell [3] telling [2] 2881/6 their [4] 2862/4
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us [18] 2847/24 2838/3 2842/6 2858/11 2858/20 2882/5 2883/12
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Understood [4] V Washington [5] 2863/8 2866/16 2838/23 2843/10
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WATKINS [3] 2868/21 2868/24 2873/13 2875/9
UNITED [8] vein [1] 2886/20 2833/19 2837/11 2869/6 2869/19 2880/8 2880/16
2833/1 2833/2 versa [1] 2860/2 2837/14 2870/20 2871/17 2882/2 2882/3
2833/9 2833/12 very [26] 2837/17 ways [2] 2870/15 2871/24 2872/8 2882/23 2884/17
2858/6 2863/16 2848/13 2851/2 2871/16 2877/15 2878/2 2887/21
2865/23 2873/23 2854/19 2859/20
we [116] 2878/4 2878/23 where [13]
universities [1] 2861/3 2864/11 we'd [3] 2877/1 2885/9 2886/2 2837/10 2843/19
2867/1 2864/15 2864/22 2877/2 2877/5 WFO [1] 2845/1 2857/20 2858/8
University [3] 2866/18 2866/19 we'll [6] 2836/4 WFO/CY-3 [1] 2861/20 2862/1
2858/9 2858/12 2866/21 2867/15 2855/7 2855/11 2845/1 2867/2 2867/9
2858/13 2867/17 2868/21 2879/19 2880/6 what [55] 2837/16 2868/1 2875/1
unnecessary [1] 2869/12 2869/17
2885/12 2837/17 2838/10 2875/8 2884/8
2877/15 2871/11 2871/17 we're [9] 2839/8 2838/24 2840/6 2886/11
until [3] 2862/8 2871/18 2872/6 2865/20 2875/7 2840/24 2841/1 whereby [1]
2877/6 2882/4 2872/6 2874/3 2876/13 2876/23 2841/21 2841/25 2862/7
unworkable [1] 2874/19 2878/16 2877/17 2883/23 2842/6 2842/15 whether [8]
2871/13 2888/12 2885/17 2888/3 2842/25 2843/7 2853/14 2863/7
up [26] 2844/6 veterans [1] we've [2] 2839/8 2843/13 2844/7 2876/24 2881/19
2845/9 2849/6 2858/22 2850/23 2844/11 2848/9 2886/1 2887/21
2851/3 2851/25 vice [1] 2860/1 Web [1] 2866/21 2848/24 2851/11 2888/3 2888/4
2852/8 2852/20 vicissitudes [1] welcome [3] 2855/5 2856/24 which [18] 2839/3
2856/5 2856/8 2870/24 2836/14 2864/23 2857/10 2859/11 2842/4 2843/9
2858/8 2858/22 views [1] 2887/19 2874/3 2860/6 2860/19 2848/14 2849/1
2858/22 2864/23 visibility [1]
well [14] 2839/9 2861/10 2861/22 2849/23 2850/3
2869/7 2869/8 2845/5 2845/16 2847/21 2865/14 2865/25 2850/6 2857/15
2870/7 2872/19 volatile [1] 2848/17 2853/1 2866/3 2866/16 2858/5 2860/14
2875/20 2876/16 2881/11
2859/15 2861/24 2866/24 2867/3 2861/18 2869/13
2878/11 2880/5
2864/22 2867/15 2867/6 2868/22 2870/15 2872/3
2880/10 2882/17 W
2873/5 2883/20 2869/15 2871/3 2872/23 2880/3
2882/21 2884/19 wait [4] 2836/11
2886/21 2886/22 2874/6 2874/10 2887/3
2885/11 2836/11 2836/16 2887/18 2876/2 2876/18 while [5] 2858/13
upbringing [1] 2882/4 went [11] 2851/16 2877/17 2878/19 2859/6 2859/19
2860/10 walk [1] 2865/21 2853/14 2853/24 2880/19 2880/21 2864/9 2885/15
upfront [1]
2909
W 2882/18 2886/10 2886/19 Z

work [10] 2887/24
white [1] 2843/10 Zurich [1]
2837/17 2857/12 year [1] 2866/9
who [17] 2846/15 2857/21
2861/12 2861/25 years [15]
2855/19 2855/25
2867/11 2868/18 2837/13 2858/19
2859/23 2867/1
2869/6 2869/14 2859/10 2860/16
2867/14 2867/16
2871/1 2871/14 2862/13 2863/23
2867/25 2868/17
worked [6] 2865/17 2865/22
2869/19 2869/25
2859/14 2859/14 2866/5 2866/8
2870/18 2876/7
2861/11 2862/1 2866/10 2867/21
2880/11 2887/5
2869/4 2871/6 2872/17 2873/2
2887/7 2887/14
working [10] 2873/5
whole [3] 2836/25
2858/14 2859/16 Yep [2] 2844/9
2856/13 2865/3
2860/25 2861/16 2844/22
whose [1]
2862/24 2868/16 yes [37] 2837/2
2862/22
2869/6 2871/3 2837/9 2838/1
why [6] 2836/2
2872/9 2884/15 2838/25 2841/10
2837/21 2838/3
world [3] 2838/3 2841/13 2842/8
2850/4 2854/25
2866/21 2867/13 2842/16 2842/22
2879/15
would [44] 2843/9 2844/18
Wide [1] 2866/21
2837/18 2838/3 2845/14 2845/25
wife [1] 2870/18
2840/11 2841/15 2846/21 2846/23
will [19] 2836/18
2847/4 2848/18 2846/25 2847/5
2836/24 2838/1
2848/22 2854/8 2847/22 2849/1
2845/4 2846/6
2854/11 2855/4 2849/11 2850/13
2846/10 2846/13
2860/3 2860/11 2851/8 2851/10
2846/16 2855/25
2860/13 2861/6 2851/13 2851/15
2856/1 2856/12
2863/7 2867/16 2851/19 2853/21
2865/2 2875/9
2870/13 2870/23 2859/19 2860/22
2877/10 2879/18
2872/10 2872/11 2861/14 2862/16
2880/9 2886/13
2873/14 2877/7 2863/25 2866/15
2888/21 2889/5
2877/14 2877/18 2868/12 2875/4
wings [1] 2858/20
2878/11 2878/11 2882/22 2885/17
without [3]
2878/13 2878/14 yesterday [2]
2861/7 2861/8
2878/22 2879/2 2886/22 2887/12
2887/4
2879/9 2879/12 York [3] 2833/20
witness [16]
2880/2 2880/14 2870/8 2886/8
2834/2 2836/3
2881/3 2881/14 you [203]
2836/18 2839/5
2881/23 2883/11 you'd [3] 2839/9
2855/17 2855/22
2883/12 2884/24 2851/6 2852/8
2855/22 2855/24
2886/1 2887/1 you're [4]
2855/25 2877/8
2887/15 2888/7 2837/24 2849/16
2884/25 2885/4
wouldn't [1] 2856/2 2879/17
2886/15 2886/16
2886/12 you've [7] 2854/8
2887/3 2887/12
wrong [1] 2882/9 2862/13 2863/22
witnesses [5]
wrote [1] 2848/2 2873/2 2873/8
2854/23 2855/3
2874/6 2874/7
2855/9 2855/18 Y young [3]
2855/19 YAO [2] 2833/18 2859/20 2869/21
won't [2] 2876/25 2834/10
2870/5
2877/4 yeah [10] 2837/17 your [75]
wonderful [1] 2859/8 2860/9 yourself [1]
2874/5 2862/11 2873/4 2856/8
word [1] 2881/15 2876/12 2880/21
words [1]

Sussmann Trial 525 Afternoon

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Sussmann Trial 525 Afternoon

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IN THE

May 25, 2022

55 MS. RRO: May

22 MR. BERKOWITZ: II think

2849/5 2850/13 10th [1] 2846/2 142 [2] 2839/23 2880/9

9 2845/6 2872/18 Air [5] 2865/24 2868/20 2869/13

A 2882/2 2883/20 assist [2] 2840/20 B 2886/13 2887/1

B BOSWORTH [1] business [2] 2881/8 2867/25 2871/12

C company [7] 2869/7 2865/10 2866/25 2881/17

D 2886/15 2869/5 2869/10 2889/7 2838/16 2838/20

E emails [3] 2860/14 examining [2] extent [1]

F follow [4] 2874/18 2857/13 2867/8 2879/14 2886/5

H 2846/7 2861/8 2861/11 2880/1 2883/17 2857/1 2857/18

I 2850/7 June [2] 2842/1 2881/22 2881/23 lay [2] 2855/19

L 2861/4 2861/9 2885/6 memos [1] 2869/1

M 2856/2 2856/3 narrowed [1] 2882/19 2884/1 2873/3 2873/8

O 2872/7 2872/13 paragraph [3] persuade [1] 2887/23

P Q Real [1] 2863/4 2845/2 represented [2]

R S-T-E-V-E-N-S [1] 2849/4 2848/18 2858/19 2854/20

S 2876/7 2888/19 swear [1] 2856/15 2887/13

T 2869/2 2869/18 2887/19 2888/17 2841/4 2844/3 truth [9] 2836/25

U 2838/18 want [16] 2836/6 2858/4 2858/7 2880/21 2881/23

W 2882/18 2886/10 2886/19 Z

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