DELIVERED TO PRESIDENT TRUMP ON 12/31/23 - Parnas - Stockton - Executive Summary

Peter T.
Santilli
Talk Show Host • America First Advocate
(513)
12/31/23
Dear
Per our conversation this week, attached is an executive summary regarding the information I
received from former Congressman Steve Stockman. The “Salient Points” is a one-page
summary that will be a helpful tool in understanding the true gravity of the PARNAS
revelations.
As I mentioned, the reason Mr. Stockman's information has recently become relevant, and in
my opinion, urgently so for President Trump, is due to recent remarks about Rudy Giuliani's
former associate Lev Parnas, presented by Jamie Raskin during the Biden impeachment
inquiry hearing on December 26, 2023. (see excerpt of Raskin remarks:
https://www.loom.com/share/012de1c2340548e5b902be132b3046b4?sid=647beeee-8a58-
42c4-b636-dbf4116065ee )
In the attached summary, you will discover that Lev Parnas was used as a surveillance
tool by the deep state to spy on communications between President Trump and his
attorney Rudy Giuliani. Within days after I personally presented and delivered
Congressman Steve Stockman's documented evidence of Obama/Biden/Hillary Clinton's
shipment of highly specialized steel to Iran (specifically for building nuclear centrifuges) via
Ukrainian oligarch Victor Pinchuk's company Interpipe, Lev Parnas was suddenly indicted and
arrested by the Department of Justice.
Although Lev Parnas, a Ukrainian-born American businessman, has claimed he was not
aware of any evidence of crimes committed by Biden (allegedly conspiring with
Obama/Clinton), I have personal, firsthand knowledge and documentation which contradicts
his claims.
I am also aware that prior to his indictment, arrest, conviction, and incarceration, Lev Parnas
was a valuable resource for Mr. Giuliani. However, he is now “singing a very different tune”
about President Trump and Rudy Giuliani. In my well-informed opinion, I believe Lev
Parnas's suspicious demeanor and conduct since his release from prison indicate that he is
now working for the opposition.
P.O. Box 30122 Cincinnati, Ohio 45230

Peter T. Santilli
Talk Show Host • America First Advocate
Lev Parnas's 10-page letter to Congress fits the pattern of his public messaging since being
released from incarceration, calling for Congress to stop their investigation of the Bidens
because he was a close associate of Rudy Giuliani. Throughout his involvement with
Giuliani's Ukraine investigations, he falsely claims he never saw any evidence of criminal
wrongdoing by the Bidens.
If Lev Parnas is allowed to testify before Congress, I believe the attached documentation
should serve as very valuable information to challenge Parnas's credibility as a witness
against President Trump and Rudy Giuliani.
Additionally, I am delivering this information to you, as I no longer trust members of Congress
or President Trump's legal team gatekeepers. Based on my past experience in delivering
important evidence pertaining to national security matters to the appropriate legal authorities
in Congress, as well as to President Trump's attorneys, I believe the individuals who have
received my information have willfully and knowingly covered up crimes against the United
States of America.
Best Regards,
Peter T. Santilli
Constitutional Advocate
Host of The Pete Santilli Show
Cell: (513)
P.O. Box 30122 Cincinnati, Ohio 45230

LEV PARNAS - Executive Summary
SALIENT POINTS
1. On December 26, 2023, during the Biden Impeachment inquiry hearing, Jamie Raskin
discussed a letter received from Lev Parnas, a "witness" who agreed to testify that
President Trump and his attorney found no evidence of Biden committing crimes in
Ukraine. [Attachment G]
2. In 2019, Parnas represented himself as Rudy Giuliani's Ukraine Investigator, a role
within the legal team assembled to assist in President Trump's legal defense.
3. Court filings reveal that the Department of Justice acknowledged Lev Parnas was
under a FISA surveillance warrant. They refused to disclose potentially exculpatory
evidence collected during surveillance, asserting it would not be used in his
prosecution. The prosecution and defense attorneys did not acknowledge Parnas as a
member of Giuliani's legal team. I personally delivered and confirmed the receipt and
conveyance of Steve Stockman's information for President Trump's legal defense.
This situation raises concerns about the DOJ potentially obtaining attorney-client
privileged communications in violation of President Trump's Constitutional rights.
4. Evidence provided by Steve Stockman included detailed documentation submitted to
the Department of Treasury regarding the Obama Administration's contravention of
Iran sanctions. This involved the delivery of highly specialized steel to Iran for their
nuclear centrifuge program. The steel, manufactured by Ukrainian oligarch Victor
Pinchuk's company Interpipe, was facilitated by Hillary Clinton and then-Vice President
Joe Biden, who were Obama's representatives in Ukraine.
5. The Department of Justice, along with the FBI, used FISA surveillance to monitor
President Trump's legal team. This is not a conjecture but an admission by the DOJ.
My personal experience with the DOJ suggests that FISA surveillance of President
Trump's legal team likely allowed bad actors to obtain critical evidence of national
security breaches and treason against the United States by Obama/Biden & Clinton.
The DOJ then suppressed this evidence, making them complicit in the crime.
6. When Steve Stockman developed evidence and potential whistleblower testimony, the
DOJ, prompted by FISA surveillance, quickly indicted and arrested him for “campaign
finance violations.” Similarly, when Lev Parnas, also under FISA surveillance, obtained
the same information and allegedly conveyed it to Rudy Giuliani as a member of his
legal team, he too was swiftly indicted and arrested for “campaign finance violations.”
The difference is that Parnas is now allegedly committing perjury, while Congressman
Stockman is a patriot willing to testify truthfully under oath.
7. I have recently been in contact with Congressman Stockman, who has agreed to
cooperate as President Trump deems necessary. Mr. Stockman has also indicated
that he has more information to share than what has already been made public.
Prepared By Peter T. Santilli, Investigative Journalist

• In or around October 2019, I sought to contact former Congressman Steve

Stockman. My aim was to thank him for his advocacy following the Bundy Ranch
protest in Bunkerville, Nevada, in April 2014. Additionally, I wished to discuss his
crucial role in exposing the Department of the Interior's Bureau of Land
Management's (BLM) violations of their law enforcement policies. This was
particularly evident during the military-style impoundment of Rancher Cliven Bundy's
cattle. [See ATTACHMENT A - Stockman Letter regarding 43 USC 1733, dated
April 15, 2014]
• During our series of conversations, Congressman Stockman's wife, Patti, informed

me that her husband, Steve, had been indicted, convicted, and was, at that time,
incarcerated after what she described as being railroaded by the Department of
Justice. She requested my assistance in bringing public awareness to his case.
Additionally, she mentioned that Steve was keen to speak with me about signi cant
ndings from his investigations.
• Starting from October 3, 2019, I engaged in several secure conversations with

Congressman Stockman. In these discussions, he expressed his belief that he was
maliciously prosecuted by the Department of Justice. He emphasized the urgency of
delivering critical documents to President Trump. These documents purportedly
contained evidence of the Obama/Biden administration's breach of Iran sanctions,
facilitated by Secretary of State Hillary Clinton and Ukrainian Oligarch Victor
Pinchuk. [See ATTACHMENT B - Stockman's "Interpipe/Iran Letter to the US
Treasury," submitted during the 113th Congress]
• Congressman Stockman also disclosed that he was in communication with a

Ukrainian intelligence official and whistleblower. This individual was allegedly
involved in efforts to gather damaging information on Trump for Hillary Clinton's
presidential campaign. Specifically, the whistleblower was reportedly engaged in
crafting elements of the Russia Collusion narrative.
• Mr. Stockman informed me that on the day of his sentencing in federal court,
the judge ordered his immediate incarceration instead of setting a future
surrender date. This decision was made due to a planned meeting between
Stockman and the Ukrainian intelligence whistleblower, aimed at further
uncovering evidence of Clinton's involvement in the Russia Collusion story. The

whistleblower, overwhelmed with fear for his and his family's safety, was
reportedly on the run and is now assumed missing.
• From September 21st to October 5th, 2019, our team facilitated direct contact
between Lev Parnas and Patti Stockman, ensuring follow-through on this
matter. I managed to establish communication with a member of Rudy Giuliani's
team, who informed me that Lev Parnas would vet the information before I
could discuss it with Giuliani. Despite my reservations about Parnas as an
intermediary, he convinced me of his direct involvement with Giuliani,
suggesting urgent delivery of the information to him. [See ATTACHMENT C -
Copy of Confirming Text Messages to Parnas, September 21 - December 8,
2019]
• On October 10, 2019, Parnas and two others were arrested and charged with
conspiracy to defraud the United States. Currently, Parnas is free on bond
pending trial, unlike Steve Stockman. A GatewayPundit.com report on January
3, 2020, indicated that Parnas was likely under FISA surveillance due to his
foreign contacts. The U.S. Government, while confirming the surveillance,
stated that none of the obtained information would be used, hence not requiring
disclosure to the defendants. [See ATTACHMENT E - DOJ FISA 1-19-cr-
00725-JPO Document 61 Filed 01/03/20]
• Court documents revealed that Parnas was under a subpoena from Adam
Schiff's U.S. House of Representatives' Permanent Select Committee on
Intelligence. He was required to submit all communication to the HPSCI to
validate his testimony. The materials he provided contained all evidence and
correspondence related to the Stockman Ukraine investigation, intended for
Rudy Giuliani.
• These documents suggest that Schiff had access to the information we
facilitated for delivery to President Trump's attorney, specifically regarding
Ukraine corruption and the Ukrainian whistleblower's role in fabricating
evidence for the Russia Collusion narrative, purportedly on behalf of the Clinton
Presidential campaign.
• For more on this topic, see the article and podcast: "Hillary Clinton & Ukrainian
Oligarch Shipped Steel To Iran, Potentially Used For Enrichment Of Nuclear
Centrifuges" – The Pete Santilli Show [http://ow.ly/JU5G30q77H9]

LEV PARNAS - ATTACHMENTS
ATTACHMENT A
Stockman Letter re: 43 USC 1733
April 15, 2014

ATTACHMENT B
Stockman “Interpipe/Iran Letter To US Treasury
Submitted during 113th Congress

Note: Draft letter copy. Original letter was sent during the 113th Congress.
Original letter is held by the Treasury Department
David S. Cohen
Under Secretary for Terrorism and Financial Intelligence
Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, D.C. 20220
Dear Secretary Cohen:
I am writing to seek your assistance in reviewing evidence that Ukrainian steelmaker

Interpipe Group has violated the Iran Threat Reduction and Syria Human Rights Act of
2011. A body of evidence has come into my possession – which I have attached here --
details exports from Interpipe to Iranian entities. I am concerned that Interpipe, which
operates in the U.S. as North American Interpipe, Inc. of Houston, Texas, may have
contravened U.S. sanctions on Iran.
I would call your attention specifically to the business dealings of an obscure company
called Ferrotec Steel LLP. According to the enclosed evidence, Ferrotec is based in
Tehran.
As the Act makes clear, the Interpipe Group is beholden to U.S. sanctions due to its
U.S. subsidiary. The law is straightforward: “All U.S. persons must comply with OFAC
regulations, including all U.S. citizens and permanent resident aliens regardless of
where they are located, all persons and entities within the United States, all U.S.
incorporated entities and their foreign branches.”
As you know, the U.S. Congress has worked to ensure the U.S. Treasury has the
means to support U.S. national security and foreign policy goals, such as the sanctions
provided under the Iran Threat Reduction and Syria Human Rights Act of 2011. Having
said this, I am appreciative of your careful and timely review of the matter raised here.
Document Summary
Documentary Evidence
i. ‘Contract 235-11, June 16th, 2011’ – signed on June 16, 2011, the contract is
between LLC Interpipe Ukraine and Interpipe M.E. FZE, Dubai. In the contract,
Interpipe Ukraine is the seller and Interpipe M.E. the buyer. According to clause
2.2., the total value of the contract is €8,000,000. The contract indicates that the
value of the specific goods would be contained in the appendices to the contract.
Consignors of the goods under the contract were listed as: LLC Interpipe
Ukraine, OJSC Interpipe NTRP (Interpipe Nizhnedneprovsky Tube Rolling Plant,
also known as Interpipe NTZ) and, curiously, ‘PJSC Lugtsentrokuz N.A.S.
Monyatovskogo’ (more commonly referred to as: ‘S. S. Monyatovskiy
Lugtsentrokuz” PJSC1 ). Registered at 91005, Lugansk, St Fronzc2 107, k.14,3
the owners of Lugtsentrokuz N.A.S. Monyatovskogo are unknown.
The reasoning for Interpipe to use this obscure seemingly unrelated third
company is unknown. One possible explanation could be that Interpipe wished
to distance itself from certain shipments. According to the English language
version of the Lugcentrokuz N.A.S. Monyatovsky website it has exported
products to, amongst others, North Korea and Cuba.4 Meanwhile, the Russian
and Ukrainian language versions of the website add Iran to this list.5
ii. ‘Contract 235-11 - Additional agreement’ – this prolongs contract 235-11 until
November 30th, 2012 while leaving everything else unchanged.
iii. ‘Contract 235-11 - Appendix 2 - October 3rd, 2011’, this is the second appendix
out of the original contract No. 235-11. It specifies the consignment of 500
‘Rough tyres’, for rail usage. Each of the 500 units in the delivery is priced at
€411.00, bringing a total cost, for products delivered to Bandar Abbas, of
€205,000.00. It specifies a sale to be made between October and November
2011.
The consignee is given as Ferrotec Steel LLP; 92, Negin Chokhak Trade Tower
#1535; Kolahduz Ave Tehrane-Iran; Zip Code 1939613149.
iv. ‘Contract 235-11 - Appendix 3 - March 12th, 2012’ – the document is the third
appendix to Contract 235-11. It specifies a sale to be made in May-June of 2012
and again names Ferrotec Steel as the consignee. The seller is Interpipe M.E.
and the consignment consists of 200 monoblock wheels with dimensions of
957mm x 190mm. Each of these wheels weighs 401kg and is valued at €530.00.
The consignment was for 200 wheels, giving a total price of €106,000.00.
1 A companyprofile can be found at: Orbis - LUGTSENTROKUZ IM S S MONYATOVSKOGO ZAO for a

company profile.
2 “Frunze” from the company website.
3 Page 3 of the contract. The company website provides the following address and telephone number for
the company in Ukraine: 91005, Lugansk, st. Frunze 107, housing 14.
Reception: Phone/fax +38 (0642) 58 42 18
Sales department: Phone/fax + 38 (0642) 50 13 37 ; Phone/fax +38 (0642) 50 13 82
4 http://lck.com.ua/en/history.html
5 http://lck.com.ua/ru/istoriya.html ; http://lck.com.ua/uk/istoriya.html
This price appears to be artificially low considering that it includes freight to
Bandar Abbas and the total weight of the products in the consignment was
80,200kg which together with its volume would incur substantial shipping costs.
v. Ministry of Taxation and Revenue of Ukraine letter - August 2014 - The

authenticity of contract 234-11 and Appendix 3 has been verified by the
Ukrainian Ministry of Taxation and Revenue. In a letter dated August 20th, 2014,
and signed by O.V. Mirza, Acting First Deputy Head of Customs, it stated
(translated Ukrainian to English):
“The Dnipropetrovsk Customs Office of the Ministry confirms the
processing through customs on 23 June 2012 of the export of goods
“[wheels]” under contract dated 16 June 2011 (supplement #3 of 12 March
2012) between the seller TOV Interpipe Ukraine and buyer Interpipe ME
FZE, recipient of shipment Ferrotec Steel LLP, Iran. Electronic copies of
the customs declaration are available from PIK Inspector 2006 and EAIC
of the State Customs Service.”
vi. ‘Commission Agreement 653090049 - Dec 26th, 2008’ – the fifth document is a
commission agreement in Russian, numbered 653090049, between OJSC
Interpipe Nizhnedneprovsky Tube Rolling Plant (Interpipe NTRP) and Interpipe
Ukraine.6 This stipulates that Interpipe Ukraine will act as a sales agent for the
former. Clause 3.4.a of the agreement states “In the event that goods provided
by principal for sale are sold by Agent…at a price higher that the commission
indicated in the corresponding appendix to the present contract, the difference in
its entirety is to be transferred to the account of Principal”. The document also
contains the banking details of both parties involved, listing multiple different
banks including some in the US (see Section C below).
vii. ‘Appendix 712 of March 12th 2012 to Commission Agreement 65090049’7 –

written in Ukrainian, this details the products shipped under Appendix 3 and
names which entity is responsible for the products at the various stages of their
transport until they pass into the hands of Ferrotec Steel LLP. It also firmly ties
the Commission Agreement to Contract 235-11. NB. Appendix 712 also appears
at the end of the Commission Agreement document.
6 AnEnglish translation is also available; see: Commission Agreement 653090049 - Dec 26th,
2008_ENG
7 See also the English translation: Appendix 712 of 12.03.12 to Commission Agreement 65090049’
ATTACHMENT C
Copy of Confirming Text Messages to Parnas
September 21 - December 8, 2019

ATTACHMENT D
Parnas Letter To Congress
July 18, 2023

July 18, 2023
The Honorable James Comer

Chairman
Committee on Oversight and Accountability
U.S. House of Representatives
Washington, D.C. 20515
Dear Chairman Comer,
As I have been closely following the developments in Congress’s investigations into both Donald
Trump and Joe Biden, I believe I can place the facts in context for you. I write to you as a concerned
American, who wishes only to share the information that I know to be true, so that we can lay to
rest the conspiracy theories about Biden’s supposed corruption in Ukraine once and for all.
I feel I have a responsibility to remind you, our representatives, and the American people of what
actually happened during Rudy Giuliani and Donald Trump’s efforts to uncover information about
the Bidens and Ukraine. From November 2018 to October 2019, I was a key participant in and
witness to these efforts; in every event described below, I was either physically present in the room
with the people involved, on phone calls with Guiliani and the individuals in question, often
interpreting between the Ukrainian and English languages, or communicating directly with
Giuliani about the situation. Please consider that the facts I state here have never changed from
when I first submitted to Congress everything I knew in November 2019. It has always been my
intention to tell the truth, because I love this country with my whole heart, and I want our
government to unite for the greater good instead of chasing false stories that divide us.
By reading the information below, you will understand the full extent of the campaign orchestrated
by Giuliani and Trump to dig up dirt on the Bidens, and to spread misinformation about them
through various networks including government officials, journalists, and FOX News personnel.
You will also see clearly that there is no evidence of Joe or Hunter Biden interfering with Ukrainian
politics, and there never has been. Statements suggesting otherwise have been debunked again and
again. I hope that the breadth of my experiences, which are all backed up by the materials I
previously shared with Congress, will prove that no stone has been unturned in this investigation.
Here are the facts as I know them to be true:
In November 2018, I was approached by Rudy Giuliani, who asked me about my contacts in
Ukraine and if I could verify some information he had received about Joe Biden. A video had
recently been shared online in which Biden, being interviewed by the Council on Foreign
Relations, said that in 2016 he had pressured Ukraine’s president Petro Poroshenko to fire his
Prosecutor General Viktor Shokin. Giuliani told me he had discussed with then-President Trump
not only Biden’s statements in the video, but also his discovery that Biden’s son Hunter was on the
1
board of the Ukrainian energy company Burisma and that Shokin was supposedly looking into
possible corruption in the company. When Giuliani spoke to me, he got very excited and said,
“This is the smoking gun [he’d] been looking for” – meaning he saw it as a way to discredit the
Bidens.
Later that month, I attended a Hanukkah celebration at the White House where Giuliani and Trump
were both present. Trump approached me briefly to say, “Rudy told me good things. Keep up the
good work.” Then he gave me a thumbs-up in approval.
I met with Shokin for the first time in Ukraine in December 2018. Guiliani had instructed me to
relay a message to him, which was essentially that if he wanted to be reinstated as Prosecutor
General – a goal he expressed very openly – that the Trump administration could help him get his
position back, but only if he provided hard evidence of Joe Biden’s corruption. Initially Shokin
said he had decided not to investigate Burisma further, but when I gave him Giuliani’s message,
he became shifty in his answers, admitting that his team was “looking into it” without giving
further details.
I returned from Ukraine, Giuliani told me to ask Shokin to fly to the States to meet up with Senator
Lindsey Graham, and when he was speaking to the visa authorities, he should tell them he was
only going to California to see his daughter, not that he would then travel to Washington, D.C. to
meet Graham. However, when Shokin applied for his visa, then-Ambassador Marie Yovanovitch
denied him.
Communications ensued where Giuliani continued to pressure Shokin into helping him get
information on Biden, although Shokin was being skeptical because Giuliani could not get him a
visa approved, and he didn’t understand how the President of the United States and his personal
representative could not achieve something like that. Eventually they had a 45-minute Skype call
in January 2019, where I served as an interpreter between the two of them, and of which there was
a recording that I later submitted to Congress. The recording shows Giuliani aggressively asking
Shokin for details on the Bidens. Even though Shokin was trying to push the narrative that he had
lost his job because of the pressure Joe Biden had put on President Poroshenko to fire him, when
asked directly by Giuliani, he conceded that there was no evidence of either Hunter or Joe Biden
doing anything that interfered with Ukrainian law.
Giuliani continued to receive conspiracy theories from different sources, and remained insistent
that there must be some data on the Bidens’ corruption. In late January 2019, my business partner
Igor Fruman got word that Yuri Lutsenko, Shokin’s replacement as Ukraine’s Prosecutor General,
was in New York and wanted to meet with Giuliani to discuss some legal matters. We set up the
meeting in Giuliani’s office on Park Avenue. There, Lutsenko explained he’d requested the meeting
because he wanted to sit down with Bill Barr and, Attorney General to Attorney General, discuss
the overall problem of Ukrainian and American corruption, including the funneling of Ukrainian
money into American institutions. Giuliani stopped Lutsenko and said he wasn’t interested in that,
only in information concerning Joe and Hunter Biden. He then added statements to the effect that
2
if Lutsenko wanted a conversation with Barr, he would need to offer a give and take, and Giuliani
was interested in details about the Bidens.
Even though Lutsenko protested that he hadn’t come to discuss the Bidens, he agreed to see what
he could find for Giuliani. The next day, we all met again in Giuliani’s office and Lutsenko brought
a folder containing purported wire transfers from Burisma to Hunter Biden, and documents from
the Prosecutor General’s office outlining the company’s hierarchy and organization from its CEO,
Mykola Zlochevsky, on down. These documents did show what the Prosecutor General’s office
was doing in its investigation into Burisma, but again, there was no evidence in any of these
materials that pointed to any criminal activity from Hunter Biden.
During the meeting, Giuliani stopped to call President Trump for about 3-5 minutes to update him
on how the meeting was going with Lutsenko, and told Lutsenko that Trump was very happy with
the help he was giving. He gave Lutsenko the thumbs-up.
Lutsenko then promised that if we went to Ukraine, he would help us meet President Poroshenko
and other officials who were dealing directly with the Burisma investigation. After the first
meeting, Lutsenko kept pressuring Giuliani that he needed to meet Bill Barr. However, Giuliani
eventually told Lutsenko he hadn’t provided enough information, and that the only way he could
meet Bill Barr was if he retained Giuliani for $200,000. He then gave Lutsenko a “contract”. (It
should be noted that Lutsenko refused to pay and to this day has never met Bill Barr.)
A few days later, Giuliani told me that he had decided that it might not be a good look for him to
represent Ukrainian officials while representing Donald Trump, and introduced me to attorneys
Victoria Toensing and Joseph DiGenova, who he said would represent Lutsenko instead. Later on,
Giuliani told me that Toensing and DiGenova had agreed to split the $200,000 retainer fee in some
part with him. In subsequent calls with Giuliani, Lutsenko was still upset and complaining about
the whole situation, arguing that he shouldn’t have to pay anything to meet one Attorney General
to another, particularly because they had to discuss criminal matters between their respective
countries.
In February 2019, Giuliani and I met Lutsenko in Poland, where the Prosecutor General was now
more favorable to the idea of helping the Trump team investigate the Bidens. He said President
Poroshenko would meet with us, so Giuliani decided I should go straight from Poland to Ukraine
on his behalf. I then had a three-hour meeting with Poroshenko. Giuliani’s message to the
president, who was running for reelection, was that Trump would support him and help him win if
he made an official announcement of an investigation against Joe Biden.
Poroshenko was taken aback and relayed to me that he didn’t trust Trump based on a bad deal they
had made in 2018. At the time, he and Trump had met at the White House, and after the meeting
one of Trump’s aides suggested that Poroshenko should buy coal from a Pennsylvania coal
company. The reason, they explained, was that Trump was about to have a rally in that part of the
state and the purchase would be good for the relationship between the two countries. Poroshenko
3
bought the coal, which was more expensive than Ukraine had paid for the same product from other
sources, and he ended up having issues with the Ukrainian Parliament over the cost. After Trump
had the rally, there were no further interactions between the two of them. So according to
Poroshenko, he now had no reason to trust Trump, but he did tell me that he would wait to see
what happened since the lines of communication had been opened.
Arriving back in the States, I began a series of regular meetings at the Trump International Hotel
with Giuliani and what I later called the “BLT Team,” because we always met at the BLT Steak
restaurant in the hotel. The BLT Team included Toensing, DiGenova, and John Solomon, an
investigative reporter who was then working for The Hill and had many contacts at FOX News
and the State Department, as well as having Trump on his speed dial. Solomon gave us information
at the meetings that he said various sources had shared with him about the Bidens’ dealings in
Ukraine. Giuliani tasked me with traveling to Ukraine throughout March, April, and May 2019 to
interview different people who had promised to give us information and evidence including
records of bribes, bank records, and incriminating tapes.
Yet every time I went on these trips and conducted these interviews, I came up with nothing.
Lutsenko kept assuring me that they would announce an investigation into the Bidens, but that
never happened either.
Around the same time as the BLT Team began meeting, I was introduced by phone to Congressman
Devin Nunes, who was leading his own separate investigation into the Bidens. His team decided
to work with the BLT Team, and I was told to keep in contact with Nunes’s staff member Derek
Harvey. While I was in Ukraine on these assignments, Nunes and Harvey asked me to help set up
interviews that would facilitate their investigation. With my assistance, Harvey conducted
numerous interviews with Ukrainian prosecutors and officials via Skype.
During this process, the prosecutors initially expressed an interest in meeting Nunes directly and
having him conduct in-person interviews in Ukraine. But Nunes declined, explaining to me again
by phone that because Republicans did not have control of the House, they would have to report
any travel they were doing. Therefore, he believed it was better to have Derek Harvey conduct the
interviews on Skype so the Democrats wouldn’t know what was going on. On one occasion I even
tried to set up an interview with Viktor Shokin for Harvey, but Shokin told me there was no need
because the two had already spoken.
At one point, Victoria Toensing said that Senator Ron Johnson would also work as the BLT Team’s
“guy in the Senate” to push all the information that we were getting – which still amounted to the
same unverified conspiracy theories.
In March 2019, John Solomon had the idea to set up FOX News interviews with Poroshenko,
Lutsenko and Nazar Kholodnytsky, the head prosecutor for the National Anti-Corruption Bureau
of Ukraine (NABU). Shortly before his interview, Kholodnytsky had gotten caught up in some
criminal activities and Marie Yovanovitch called for him to be ousted from his position. During
4
the taping of his interview, instead of talking about the Bidens as planned, Kholodnytsky
complained about Yovanovitch interfering in Ukrainian politics. However, during his taping, he
never validated nor confirmed that any illegal activities had been committed by either Hunter or
Joe Biden. This statement upset Solomon and Giuliani, so the interview never aired on FOX.
Ten minutes before Poroshenko’s interview was to take place, he decided not to participate. There
was an intense phone conversation that I translated between Lutsenko and Giuliani, which ended
with Giuliani telling Lutsenko that if he couldn’t get Poroshenko to do the interview, not to call
anymore.
During the argument with Giuliani, Lutsenko sent me an expletive-ridden text. I read the original
in Russian, but the translation into English is essentially as follows, accommodating for language
and context: “Sorry, but I didn’t get a visit. But first, my president didn’t get a damn thing. I’m
ready to destroy your competitor, but you want more and more. You expect us to do everything,
and everything we ask of you is ‘Later.’ It’s not right. It’s not fair.”
Finally, Lutsenko then said he would do the interview and give us a big bombshell about the
situation in Ukraine, which Giuliani expected to be about the Bidens. But during the interview,
instead of talking about the Bidens, Lutsenko spoke about Yovanovitch’s newly uncovered “Do
Not Prosecute” list of names. It became a big scandal, but not long after that announcement, he
retracted his statements. Giuliani was incredibly angry.
Every time Giuliani and Lutsenko had spoken about the Bidens, he would answer that nothing had
been found to incriminate them. Neither Joe nor Hunter Biden had done anything against the
Ukrainian constitution or local laws; there was no evidence of bribery or extortion that anyone
could find. At the same time, Lutsenko was worried he wouldn’t be able to stay in office if
Poroshenko lost his bid for reelection, so he did what he could to stay on Trump and Giuliani’s
good side. To appease them, he would sometimes make vague statements to the media about
Hunter and Joe Biden, but he never said they had committed acts of corruption or that an
investigation was being opened. There was simply nothing he had to substantiate those claims.
By that point, the BLT Team were watching the Ukrainian presidential elections and realized
Volodymyr Zelenskyy was probably going to win. The conversations shifted from Poroshenko and
Lutsenko to getting a promise from Zelenskyy that he would announce an investigation into the
Bidens following his win. Giuliani assumed that because Zelenskyy was an actor and comedian,
not a politician, he would naturally want to do anything he could to establish a good relationship
with the U.S.
I was tasked in April 2019 to go to Ukraine and get in contact with Zelenskyy. Yet my attempts to
contact him were consistently blocked by Ihor Kolomoyskyi, a Ukrainian oligarch who was
backing Zelenskyy financially. Eventually I flew to Israel, where Kolomoyskyi was living in exile,
and explained Giuliani and Trump’s stance on the matter and why we needed Zelenskyy to
5
commence an investigation into the Bidens. Giuliani had also instructed me to tell Kolomoyskyi
that he would help with his legal problems in the U.S. if he would help us with Zelenskyy.
As you see, these are flagrant examples of Giuliani interfering in Ukrainian politics. Ironically, the
very thing he was desperate to prove that the Bidens were doing in Ukraine – and for which he
could find no evidence at all – was what he was guilty of.
By the end of April 2019, it was clear Zelenskyy would win in a landslide. We were preparing to
set up a meeting between Zelenskyy and Giuliani, who was supposed to come to Ukraine on May
10th with Victoria Toensing. Giuliani had given me a letter which I handed over on May 9th to
Arsen Avakov, the Minister of the Interior; the letter was to communicate to Zelenskyy that
Giuliani wanted to discuss private matters pertaining to Trump, as he represented Trump in his
personal capacity.
However, this meeting never occurred. On May 11th, Giuliani called me frantically in the middle
of the night, saying he’d been approached by Kash Patel, a member of Devin Nunes’s team and
staffer for Trump’s National Security Council. Patel informed him that people in Zelenskyy’s inner
circle were Trump’s enemies and that Giuliani could not meet him in Ukraine now because it would
be “a set-up.”
Instead I was once again assigned to be the man on the ground, to meet with Zelenskyy myself on
Giuliani and Trump’s behalf and deliver a precise message in very strict words. Unless Zelenskyy
announced an investigation into the Bidens, the U.S. would not deliver on certain promises: 1)
Trump would tell Mike Pence not to attend Zelenskyy’s inauguration, and 2), the U.S. would not
send any aid to Ukraine, military or otherwise.
It would be Zelenskyy’s Chief of Staff Sergei Shafer, and not the president himself, who met with
me on that trip. After sharing a copy of the letter with Shafer via WhatsApp, I reiterated Giuliani’s
message for Zelenskyy to Shafer. Though he initially told me that Zelenskyy wanted a good
relationship with the U.S. and would cooperate, we never heard from them after that. A few days
later, I was told by Avakov, Minister of the Interior, that Zelenskyy was told not to speak to Giuliani
or his team and that he should only go through proper channels with people at the U.S. Embassy.
When I reiterated that message to Giuliani, he became enraged.
On May 13th, Ukrainian officials got confirmation from the U.S. that Mike Pence would not attend
Zelenskyy’s inauguration, which caused turmoil inside the Ukrainian government. They didn’t
want their people to realize that the U.S. were essentially pulling out of its promise to provide aid.
When Kolomoyskyi found out, he returned to Ukraine, and was furious about the situation. He
went to the media, calling Fruman and me grifters, stating that we were trying to force Zelenskyy
to do unethical things, and threatening our lives. On his end, Giuliani then began sending bullying
and threatening messages to Zelenskyy on Twitter and disparaging him on FOX News. He would
question Zelenskyy’s power as president, he would insist that Zelenskyy arrest Kolomoyskyi
6
immediately, and repeat that Zelenskyy’s inner circle was comprised of Trump’s enemies, among
other such statements.
It was then decided that Giuliani and I should fly to Paris to discuss next steps for Ukraine. While
in Paris, Giuliani received a call from Rick Perry, then the Secretary of Energy. Perry was calling
from Air Force Two, explaining that Trump had assigned him to represent the U.S. at Zelenskyy’s
inauguration and that he was “supposed to call Rudy” for his exact instructions. The call was on
speaker, so I heard every word. Giuliani outlined to Perry that he needed to relay the same message
to Zelenskyy after the inauguration ceremony: Announce an investigation into the Bidens, or the
U.S. will pull its aid. Right after the inauguration, Perry called Giuliani to say he had delivered the
message and Zelenskyy was willing to play ball.
But when Zelenskyy did make an announcement the following day, it was a statement about
addressing general corruption in Ukraine, and never mentioned the Bidens. Giuliani was angry,
communicating with Trump that the Ukrainians were playing games. We knew that at the same
time, Trump was also making several attempts to deliver messages to Zelenskyy through other
members of his team outside of Giuliani, and all with the same theme: Investigate Joe Biden or
else.
Near the end of our trip to Paris, we were introduced to one of Igor Fruman’s associates, a friend
who happened to be an employee of a Ukrainian oligarch named Dmitry Firtash, who had many
political and business connections, including with the head of Burisma, Zlochevsky. When we
returned to the U.S., we met with the BLT Team and John Solomon said Firtash’s help would be
key because of his relationship with Zlochevsky.
The problem was that Firtash would prove nearly impossible to contact. He was also facing a
serious extradition case to the U.S. for a number of bribery, racketeering and other charges since
2014. Solomon and Giuliani put together a package of documents regarding confidential
information in Firtash’s case, and had me travel to Vienna in June 2019 to meet with Firtash, letting
him know that Giuliani and our whole team were serious and that we could help him if he helped
us. From June until the time of my arrest in October 2019, we had ongoing communications with
Firtash.
In a meeting with the BLT Team, Solomon relayed to Giuliani that he had information that Robert
Mueller’s lead prosecutor Andrew Weissman offered Firtash a deal to cancel his extradition if he
would testify against Trump and Putin. Firtash didn’t want to get involved with the Biden versus
Trump situation, but was open to helping us with Mueller’s investigations into Trump. Thereafter,
as I became an interpreter between Firtash’s new legal team and Firtash, most of the conversations
in which I participated were potentially privileged; however, I believe this information may be
made available to the House Oversight Committee through a Congressional subpoena.
But the true purpose of dangling this carrot in front of Firtash was to get him to use his contacts to
pressure Zlochevsky to cooperate with the BLT Team. Eventually, Giuliani proposed a $1 million
7
contract to represent Firtash. Later, similar to the Lutsenko situation, he took it back and had
Firtash sign a contract with Victoria Toensing. Giuliani, however, would continue to oversee
everything and remain in charge of matters related to Firtash. Then later Giuliani and Toensing had
several phone calls that I was privy to with Bill Barr, leading to an unofficial meeting in the lobby
at the Trump International Hotel, and then an official meeting at the Department of Justice.
At the same time, the BLT Team was exploring many different angles to get information on the
Bidens. In June, Giuliani asked me to accompany him to a lunch in New York with Vitaly Pruss, a
Russian businessman who claimed to have deep connections to Burisma, including with Hunter
Biden’s business partner Devon Archer, and had recommended powerful people to Zlochevsky
that he should put on the company’s board. During this meeting, Pruss shared a story with us: He
said earlier that year, while doing business related to Burisma, he had taken Hunter Biden to meet
Kazakhstan’s minister of foreign affairs, and that Biden had gotten substantially intoxicated with
drugs and alcohol on this trip. While he was incapacitated, his laptop was compromised and copied
by a representative of FSB (Russia’s secret police) and members of Zlochevsky’s team.
It's important to note that certain aspects of Pruss’s story are verifiably true. This trip with Hunter
Biden did happen, and his computer hard drives were taken and duplicated. But Pruss specified
that while the contents of the laptop were personally embarrassing to Hunter Biden – pictures of
him doing drugs and surrounded by girls -- there was no evidence of financial crimes or any data
on his laptop that suggested illegal activities of any other kind, which is the sort of proof that
Giuliani desperately needed. Pruss never mentioned anything about the hard drives containing
criminal information, only the embarrassing images. It was not until Giuliani began disseminating
the story of Hunter Biden’s laptop that the idea of proof of financial and political crimes was
introduced.
Giuliani continued the simultaneous efforts to reach Zlochevsky through Firtash and Pruss. I
specifically recall that Giuliani told me to tell Pruss to pressure Zlochevsky by saying that he could
be “an enemy or a friend of Trump.” At a meeting of the BLT Team, Giuliani and Solomon came
up with a series of 12-14 questions about the Bidens that we would propose to Zlochevsky.
Eventually, we managed to get Zlochevsky’s answers back. But his answers gave us nothing –
because there was nothing. On reading Zlochevsky’s reply, Giuliani turned red and yelled, “What
is this shit? This is bullshit. Make sure nobody sees this. Bury this.”
I will remind you that Zlochevsky’s answers are in the report that the House Oversight Committee
published. In this document, he stated that Hunter Biden was never asked or assigned to speak
with anybody in the U.S. on behalf of Burisma, that there were no political or lobbying efforts on
behalf of Burisma, that nobody from the company had ever spoken to Joe Biden, and that Hunter
Biden was essentially innocent of what people had been implying. His letter debunked all the
conspiracy theories.
In August 2019, Kurt Volker, Trump’s Special Envoy to Ukraine, approached Giuliani. He said
that Trump had written Zelenskyy off and wasn’t talking to him, but wanted Giuliani to emphasize
8
to Trump that the relationship with Zelenskyy was crucial. He stressed that Zelenskyy needed to
get support from the U.S. in Ukraine’s ongoing war with Russia. While at a meeting that I was
present at with Giuliani and Volker at the Trump International Hotel in Washington, it was agreed
that if Giuliani opened the communication channels with Zelenskyy and Trump, as well as invited
Zelenskyy to the White House, then Zelenskyy would announce an investigation into the Bidens.
A later meeting with Volker, Giuliani, then U.S. ambassador to the European Union Gordon
Sondland, and Rick Perry took place to discuss the details of the investigation announcement in a
phone call with Zelenskyy’s chief of staff Andriy Yermak.
I was then tasked with traveling to Spain to attend a meeting with Yermak and Giuliani. In that
meeting, Giuliani pressured Yermak to tell Zelenskyy to make the announcement about the Bidens.
Giuliani also brought up Vitali Klitschko, the mayor of Kyiv, who he had met with several times
in New York. He informed Yermak that he knew Zelenskyy wanted to fire Klitschko and
emphasized that this would be a bad idea, because Klitschko was well liked by Trump and the
American people.
Again, this is a blatant example of Giuliani interfering in foreign politics. Zelenskyy’s aim was to
clear out corruption in the Ukrainian government. Unfortunately, the war has limited Zelenskyy’s
opportunities to address this. However, there was no possible reason why Giuliani should have
been suggesting who should play any role in the Ukrainian government.
In the early part of October 2019, I got a call telling me to go to Vienna with Giuliani, where the
former Chief Financial Officer of Burisma, Alexander Gorbunenko, would meet Giuliani and give
us Hunter Biden’s hard drive and answer any questions we had. My Ukrainian contacts also told
me they would have Viktor Shokin in Vienna to give an interview to Sean Hannity of FOX News,
because Shokin was supposed to appear in a Viennese court on behalf of Dmitry Firtash, giving
sworn testimony in court that would basically be saying what Giuliani wanted him to say – that he
was fired because of Joe Biden. (As mentioned earlier, Biden did make statements that he had
helped to get Shokin fired, but Ukrainian investigations into the matter some years later concluded
that Shokin had been terminated because of multiple cases of corruption while in office.)
I have text messages confirming all these plans, and all are among the materials I submitted to
Congress during the first impeachment inquiry. These include messages from Hannity setting up
the interview, and messages coordinating that Giuliani, Toensing, and I would go to Vienna to meet
Burisma’s ex-CFO Gorbunenko. Just before we were to fly to Austria, there was a meeting at FOX
News in Washington, because Solomon was appearing that night on Hannity’s show and Giuliani
was appearing on Laura Ingraham’s. The BLT Team got together in a FOX conference room and
discussed how we would blow up the story once we got Hunter Biden’s hard drive in Vienna.
The next morning, Giuliani met me for breakfast and said that Trump needed him at the White
House; he would be unable to go to Vienna. He insisted Fruman and I should go and set everything
up and he would join us later. Toensing then contacted me to say that she would not go to Vienna
9
either because her husband had a cold. Shortly afterward, on October 9, 2019, Fruman and I were
arrested at the Dulles International Airport while trying to make the first leg of our flight to Vienna.
Throughout all these months of work, the extensive campaigns and networking done by Trump
allies and Giuliani associates, including the enormously thorough interviews and assignments that
I undertook, there has never been any evidence that Hunter or Joe Biden committed any crimes
related to Ukrainian politics. Never, during any of my communications with Ukrainian officials or
connections to Burisma, did any of them confirm or provide concrete facts linking the Bidens to
illegal activities. In fact, they asked me multiple times why our team was so concerned with this
idea. The truth is that everyone, from Giuliani and the BLT Team to Devin Nunes and his
colleagues, to the people at FOX News, knew that these allegations against the Bidens were false.
There has never been any factual evidence, only conspiracy theories spread by people who knew
exactly what they were doing.
With all due respect, Chairman Comer, the narrative you are seeking for this investigation has been
proven false many times over, by a wide array of respected sources. There is simply no merit to
investigating this matter any further. I hope my letter has provided you with additional clarity on
this point.
Please know that in my sharing this information with you, I am not looking for any sympathy for
myself. I take full responsibility for my own actions in this matter, and I am extremely remorseful
for my participation. In explaining the full context to you here, I can only hope that my truth can
be used for the greater good. Please abandon this effort to investigate the Bidens, which is nothing
more than a wild goose chase, and let our elected officials return to the issue at hand of uniting our
great country to be stronger and better than ever before.
I am willing to testify under oath in Congress regarding any of these matters, and answer any
questions that you might have, or provide you with any texts or correspondence in these situations
I have described in this letter. You may contact me through my attorney Joseph A. Bondy, who can
be reached by phone at 212-219-3572 and by email at jab@josephabondy.com
Thank you for your consideration.
Sincerely,
Lev Parnas
10
ATTACHMENT E
DOJ FISA 1-19-cr-00725-JPO Document 61
Filed 01/03/20

Case 1:19-cr-00725-JPO Document 61 Filed 01/03/20 Page 1 of 5
U.S. Department of Justice
[Type text]
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
January 3, 2020
BY ECF
Hon. J. Paul Oetken

United States District Judge
40 Foley Square
New York, NY 10007
Re: United States v. Andrey Kukushkin, No. 19 Cr. 725 (JPO)
Dear Judge Oetken:
The Government writes in response to defendant Andrey Kukushkin’s December 12, 2019
letter motion, which is made “on behalf of all defendants,” seeking the Court to direct the
Government to affirm or deny, under 18 U.S.C. § 3504, whether the defendants were the subject
of any Government surveillance, including under Executive Order 12333 or the Foreign
Intelligence Surveillance Act (“FISA”), and if so, to “identify such evidence and delineate all fruits
thereof.” (Dkt. 45). Kukushkin’s motion, which is based only on speculation, is procedurally and
substantively improper.
More importantly, as the Government has repeatedly informed the defendants, it does not
intend to use any information that was obtained or derived from FISA or other forms of
surveillance identified by Kukushkin, nor does the Government anticipate having any classified
discovery or the need to file a Classified Information Procedures Act (“CIPA”) motion. That is
sufficient to meet the Government’s obligations under the applicable laws, and there is no basis
identified in Kukushkin’s motion or otherwise to require anything more. For those reasons, and
the reasons set forth below, Kukushkin’s motion should be denied. 1
1. Applicable Law
While styled as a motion brought pursuant to 18 U.S.C. § 3504, where as a here a defendant
seeks notice of or other information about FISA intercepts, such a request is governed by a
different provision of law, 50 U.S.C. § 1806. See, e.g., United States v. Thomas, 201 F. Supp. 3d
643, 648 (E.D. Pa. 2016) (section 3504 does not apply to FISA information, since Section 1806
“is the procedure clearly contemplated by the foreign intelligence statutes for resolving allegations
of unlawful surveillance”); United States v. Aziz, 228 F. Supp. 3d 363, 370 (M.D. Pa. 2017)
1
The Government is separately submitting a supplemental letter to the Court ex parte and under
seal.
Page 2
(“FISA’s particularized notice, disclosure, and suppression procedures supplant the requirements
of § 3504.”). Pursuant to 50 U.S.C. §1806(c), the Government’s notice obligations regarding the
use of FISA information apply only if the Government (i) “intends to enter into evidence or
otherwise use or disclose” (ii) against any “aggrieved person” 2 (iii) in a “trial, hearing, or other
proceeding in or before any court, department, officer, agency, regulatory body, or other authority
of the United States” (iv) any “information obtained or derived from” (v) an “electronic
surveillance [or physical search] of that aggrieved person.” 50 U.S.C. §1806(c); see id. § 1825(d).
Where all five criteria are met, the Government will notify the defendant and the Court that the
United States intends to use or disclose such information.
With respect to Section 3504, which applies to other forms of recordings made outside of
the context of Title III or FISA, if in a “trial, hearing, or other proceeding in or before any court
[or] grand jury,” an aggrieved party claims that “evidence is inadmissible because it is the primary
product of an unlawful act or because it was obtained by the exploitation of an unlawful act, the
opponent of the claim shall affirm or deny the occurrence of the unlawful act.” 18 U.S.C.
§ 3504(a)(1). The statute provides that an “unlawful act” includes “the use of any electronic,
mechanical, or other device . . . in violation of the Constitution or laws of the United States or any
regulation or standard promulgated pursuant thereto.” Id. § 3504(b). Section 3504 was “intended
to place an additional check on the government’s use of illegally seized evidence” and “provide
aggrieved parties with a means of determining whether . . . they could properly challenge questions
propounded to them in adjudicatory proceedings.” In re Millow, 529 F.2d 770, 773 (2d Cir. 1976).
This makes sense: 3504 is limited, by its terms, to court or grand jury proceedings in which a
proponent introduces evidence, and the opponent wants to challenge that evidence as inadmissible.
See 18 U.S.C. § 3504(a)(1). “[Section 3504] was not intended, however, to transform an
investigation by the government into an investigation of the government where claims of illegality
lack substantial support.” Millow, 529 F.2d at 773.
2. Discussion
The Government has complied with its discovery and disclosure obligations, and
Kukushkin’s motion fails to set forth any legal basis to require anything more.
With respect to FISA, the Government has complied with its obligations under Section
1806 in this case. On December 1, 2019, the Government notified defense counsel that it did not
intend to use any FISA-obtained or FISA-derived information against the defendants at trial. 3
2
An “aggrieved person” is defined as the target of electronic surveillance or “any other person
whose communications or activities were subject to electronic surveillance,” 50 U.S.C. § 1801(k),
as well as “a person whose premises, property, information, or material is the target of physical
search,” or “whose premises, property, information, or material was subject to physical search.”
Id. § 1821(2).
3
Kukushkin incorrectly states that the Government has “denied procuring evidence pursuant to
Title III or FISA warrants.” Dkt. 45 at n.1. The Government has told the defense that it did not
obtain or use Title III intercepts in this investigation. The Government has not made any
representations about the use of FISA warrants. (See Kukushkin Ex. B at 1).
Page 3
Consistent with the statutory requirements, this notice gave the defendants all the information to
which they are entitled.
Because the Government does not intend to introduce any FISA-obtained or FISA-derived
information at trial, the defendants have no standing to challenge the lawfulness of any underlying
surveillance. Kukushkin argues that he is entitled to learn about “the existence of such evidence
and the manner by which it was obtained” before he can move to suppress any evidence, but that
argument is flatly wrong. (Dkt. 45 at 5). Kukushkin is simply not entitled to notice of evidence
that the Government does not intend to introduce, and which Kukushkin does not have standing to
suppress. See United States v. Saipov, No. 17 Cr. 722 (VSB) (Dkt. 212) (denying defense motion
to obtain “notice of the specific surveillance methods the Government employed so that he can
then challenge the lawfulness of that surveillance,” and noting that because the Government did
not intend to introduce any such surveillance or evidence derived from the surveillance at trial, the
defense’s motion was “moot”) (collecting cases); United States v. Alimehmeti, No. 16 Cr. 398
(PAE) (S.D.N.Y.) (Dkt. 68) (denying motion for additional notice of surveillance techniques and
holding that “the Court understands the government to have complied with its notice and discovery
obligations and declines to impose additional obligations at this time”). Indeed, beyond the FISA
context, it is well-settled that defendants have no standing to challenge electronic surveillance that
is not being introduced at trial and which has not been used to derive evidence against them. See,
e.g., United States v. Gibson, 500 F.2d 854, 855 (4th Cir. 1974) (“The clear implication of [Title
III] is that [a person with standing to challenge the wire] should not include one who is not
implicated and against whom no one has made a proffer of information derived from the
defectively authorized wiretap.”); see also United States v. Gallo, 963 F.2d 185, 192 (2d Cir. 1988)
(construing Title III standing in accordance with standing requirements applied to suppression
claims under the Fourth Amendment (citing Alderman v. United States, 394 U.S. 165, 175-76 &
n.9 (1969))).
Kukushkin’s reliance on Section § 3504 is similarly misplaced. As an initial matter,

Kukushkin’s motion under Section 3504 is procedurally improper. Section 3504 provides a
procedural vehicle for a witness or a defendant to challenge evidence when it is introduced on the
basis that it was unlawfully obtained. See, e.g., Millow, 529 F.2d at 773 (witness refused to answer
questions before grand jury); United States v. Pacella, 622 F.2d 640, 643 (2d Cir. 1980) (same).
By contrast, here the Court has not yet set a trial date and no hearing has been scheduled. The
Government has not introduced a single piece of evidence. Indeed, because the Government does
not intend to introduce any evidence obtained or derived from any of the types of government
surveillance Kukushkin identifies, there is no evidence for Kukushkin to challenge under Section
3504.
Moreover, Kukushkin has failed to establish a colorable basis to believe that he (or any of
the defendants) have been aggrieved by unlawful surveillance of any kind. See Pacella, 622 F.2d
at 643 (“Although the claim need not be particularized, it may not be based upon mere suspicion
but must at least appear to have a ‘colorable’ basis before it may function to trigger the
government’s obligation to respond under § 3504” (quoting United States v. Yanagita, 522 F.2d
770, 774 (2d Cir. 1976))); see also Millow, 529 F.2d at 774 (where “assertions of misconduct are
so obviously frivolous and lack even a colorable basis there is no ‘claim’”). Kukushkin’s claim
rests solely on the fact that the case involves “foreign nationals, foreign government officials,
Page 4
foreign communications [and] foreign travel,” which hardly places this case outside of the norm
for criminal cases in this District. (Dkt. 45 at 7; Ex. A at 1). His suspicions and conjecture are
wholly insufficient to require a response under Section 3504. See, e.g., United States v. Dien, 598
F.2d 743, 746 (2d Cir. 1979) (deeming “frivolous” a request for information under § 3504 when
the request lacked “any substantial support for the claim of illegality,” and holding that such
request “triggered no obligation” for the government to respond); United States v. Aref, 285 F.
App’x 784, 793 (2d Cir. 2008) (finding insufficient defendant’s showing that consisted of
statements “by unnamed sources in a newspaper article”). The cases cited by Kukushkin for the
proposition that his claim need only be “colorable” are inapposite and do not support his argument.
(See Dkt. 45 at 6 (citing Pacella, 622 F.2d 640 (affirming denial of Section 3504 motion where
defendant did not have a colorable claim, even where defendant was the subject of a lawful
surveillance order); In re Evans, 452 F.2d 1239, 1242-43 (D.C. Cir. 1971) (defendants stated
colorable basis where they submitted sworn affidavits stating their belief that “wiretapping and
electronic surveillance had been directed against them and that the grand jury’s subpoenas and
questions were the fruit of that wiretap.”)). 4
Courts within this District and nationwide routinely reject similar efforts by defendants to
use mere speculation as a basis under Section 3504 to gain access to information to which they are
simply not entitled. See United States v. El Gammal, No. 15 Cr. 588 (ER) (S.D.N.Y.) (Dkt. 150)
(denying motion under 18 U.S.C. § 3504, FRCP 12(b)(3)(c), 16(a)(1)(E)(i), and the Fourth and
Fifth Amendments to gain additional notice of surveillance where defendant had a “suspicion” that
he was also surveilled under E.O. 12333); United States v. Alimehmeti, No. 16 Cr. 398 (PAE)
(S.D.N.Y.) (Dkt. 68) (denying motion for additional notice of surveillance techniques as
speculative); see also Aziz, 228 F. Supp. 3d 363 at 370 (denying motion under Section 3504 for
notice and disclosure of surveillance techniques because FISA’s notice procedures “supplant[ed]
the requirements of § 3504”); Thomas, 201 F. Supp. 3d at 648 (holding that “speculat[ion] that
Defendant could have been subject to illegal surveillance” was insufficient to trigger the
Government’s response requirement under Section 3504). Kukushkin’s motion is even more
speculative than the motions denied by Judge Engelmayer in Alimehmeti and Judge Ramos in El
Gammal: in both of those cases, the Government had provided notice pursuant to Section 1806,
and in Alimehmeti, the Government intended to use that information at trial. By contrast, here the
Government has not provided notice pursuant to Section 1806, and to the contrary, has notified
the defendants that it does not intend to rely on any FISA-obtained or FISA-derived evidence in
its case in chief. Just as in Alimehmeti, Gammal, Saipov, and the other precedent cited above, the
4
On December 19, 2019, Kukushkin supplemented his December 12, 2019 motion with a letter
enclosing the Second Circuit’s decision in United States v. Hasbajrami, 15-2687-L, 17-2669-
CON, for the purpose of providing “background information” and to show why the defense
“need[s] to discern whether evidence” was the product of unlawful surveillance or interception.
(Dkt. 50). In Hasbajrami, the Second Circuit held that the “collection of the communications of
United States persons incidental to the lawful surveillance [under Section 702 of FISA] of non-
United States persons located abroad does not violate the Fourth Amendment,” (Slip op. 2), but
remanded for further factual development on the question of whether any queries that may have
occurred in that case were reasonable. Hasbajrami—which considered an as-applied challenge to
certain aspects of Section 702 collection—is irrelevant to the legal issues implicated by
Kukushkin’s motion.
Page 5
Court should reject Kukushkin’s efforts to use an insufficient and improper claim under Section
3504 to embark on a fishing expedition through the Government’s files. The Government has
complied with its disclosure obligations, and there is no basis to require more.
3. The Government Intends to Comply With Its Discovery Obligations
More generally, as the Government has repeatedly informed the defendants and the Court,
the Government is aware of and intends to comply fully with its discovery obligations. The
Government’s discovery obligations “are defined by Rule 16, Brady [v. Maryland, 373 U.S. 83
(1983)], Giglio [v. United States, 405 U.S. 150, 154 (1972)], and the Jencks Act.” United States
v. Griebel, 312 F. App’x 93, 96 (10th Cir. 2008); see also United States v. Coppa, 267 F.3d 132
(2d Cir. 2001) (generally discussing the government’s discovery and disclosure obligations).
While the Government does not dispute that its discovery obligations extend to classified
information where such information exists and is within the scope of Rule 16, Brady or Giglio,
see, e.g., United States v. Abu Jihad, 630 F.3d 102, 140-41 (discussing CIPA), here the
Government has already represented that it does not intend to produce classified discovery or file
a CIPA motion.
Finally, Kukushkin asks the Court to order the Government to “conduct an inquiry of its
agencies,” but cites no statutory or legal authority for this request. (Dkt. 45 at 5). Nor is there
any. As set forth above, the Government’s discovery and disclosure obligations are defined by
Rule 16, Brady, and Giglio; the Government is aware of its discovery and disclosure obligations,
has complied with those obligations, and will continue to do so.
In sum, neither Section 3504 nor Section 1806 entitles a defendant to inspect the
Government’s files to assure himself that he was not the subject of unlawful surveillance. The
Government has complied and will continue to comply with its discovery and disclosure
obligations, and Kukushkin’s effort to impose additional obligations on the Government runs
contrary to the case law and the applicable statutes. Kukushkin’s motion should be denied.
Respectfully submitted,
GEOFFREY S. BERMAN
United States Attorney for the
By: _____/s/_______________________
Rebekah Donaleski
Nicolas Roos
Douglas Zolkind
Assistant United States Attorneys
(212) 637-2423/2421/2418
Cc: All Defense Counsel (by ECF)

ATTACHMENT F
Parnas Docket Report
Case Filed 10/09/19

1/4/2020 SDNY CM/ECF NextGen Version 1.2
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ECF
U.S. District Court

Southern District of New York (Foley Square)
CRIMINAL DOCKET FOR CASE #: 1:19-cr-00725-JPO All Defendants
Case title: USA v. Parnas Date Filed: 10/09/2019
Assigned to: Judge J. Paul Oetken
Defendant (1)
Lev Parnas represented by Edward Brian MacMahon , Jr.
also known as Edward B. MacMahon, Jr., Plc
Sealed Defendant 1 P.O. Box 25
Middleburg, VA 20118
(540)-687-3902
Fax: (540)-687-6366
Email: ebmjr@macmahon-law.com
TERMINATED: 01/03/2020
ATTORNEY TO BE NOTICED
Designation: Retained
Joseph Aaron Bondy

Law Offices of Joseph A. Bondy
401 Greenwich Street, 5th Floor
New York, NY 10014
(212) 219-3572
Fax: (212) 219-8456
Email: josephbondy@mac.com
Pending Counts Disposition

18:371.F CONSPIRACY TO DEFRAUD THE UNITED
https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?140351911789148-L_1_0-1 1/15
STATES
(1)
18:1001.F STATEMENTS OR ENTRIES GENERALLY
(FALSE STATEMENTS)
(2)
18:1519.F DESTRUCTION, ALTERATION OR
FALSIFICATION OF RECORDS IN FEDERAL
INVESTIGATIONS (FALSIFICATIONS OF RECORDS)
(3)
STATES
(4)
Highest Offense Level (Opening)

Felony
Terminated Counts Disposition

None
Highest Offense Level (Terminated)

None
Complaints Disposition
None
Defendant (2)
Igor Fruman represented by Todd Blanche
also known as Cadwalader Wickersham & Taft LLP
Sealed Defendant 2 200 Liberty Street
New York, NY 10281
212-504-6000
Fax: 212-504-6666
Email: todd.blanche@cwt.com
LEAD ATTORNEY

STATES
(1)
18:1001.F STATEMENTS OR ENTRIES GENERALLY
(FALSE STATEMENTS)
(2)
18:1519.F DESTRUCTION, ALTERATION OR
FALSIFICATION OF RECORDS IN FEDERAL
INVESTIGATIONS (FALSIFICATIONS OF RECORDS)
(3)
STATES
(4)

Felony

None

None
None
Defendant (3)
David Correia represented by Jeffrey Marcus

also known as Marcus Neiman & Rashbaum, LLP
Sealed Defendant 3 2 South Biscayne Blvd.
Suite 1750
Miami, FL 33131
305-400-4260
Email: jmarcus@mnrlawfirm.com
LEAD ATTORNEY
William Joseph Harrington

Goodwin Procter, LLP (NYC)
The New York Times Building
620 Eighth Avenue
New York, NY 10018-1405
(212)-813-8800
Fax: (212)-355-3333
Email: wharrington@goodwinlaw.com

STATES
(4)

Felony

None

None
None
Defendant (4)
Andrey Kukushkin represented by Faith Alison Friedman
also known as Gerald B. Lefcourt, P.C.
Sealed Defendant 4 1776 Broadway
Suite 2000
New York, NY 10019
212-737-0400
Fax: 212-988-6192
Email: ffriedman@lefcourtlaw.com
Gerald B. Lefcourt
Gerald B. Lefcourt, P.C.
1776 Broadway
Suite 2000
New York, NY 10019
212-737-0400
Email: lefcourt@lefcourtlaw.com

STATES
(4)

Felony

None

None
None
Plaintiff
USA represented by Douglas Samuel Zolkind
U.S. Attorney's Office, SDNY (St Andw's)
One St. Andrew's Plaza
New York, NY 10007
(212) 637-2418
Email: douglas.zolkind@usdoj.gov
LEAD ATTORNEY
Nicolas Tyler Landsman Roos

United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212)-637-2421
Email: nicolas.roos@usdoj.gov
LEAD ATTORNEY
Designation: Assistant US Attorney
Rebekah Allen Donaleski

United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
212-637-2423
Fax: 212-637-2443
Email: Rebekah.Donaleski@usdoj.gov
LEAD ATTORNEY
Designation: Assistant US Attorney
Date Filed # Docket Text

10/09/2019 1 SEALED INDICTMENT as to Sealed Defendant 1 (1) count(s) 1, 2, 3, 4, Sealed Defendant 2 (2) count(s) 1, 2, 3, 4, Sealed
Defendant 3 (3) count(s) 4, Sealed Defendant 4 (4) count(s) 4. (jm) (Entered: 10/10/2019)
10/10/2019 2 Order to Unseal Indictment as to Sealed Defendant 1, Sealed Defendant 2, Sealed Defendant 3, Sealed Defendant 4. (Signed by
Magistrate Judge Ona T. Wang on 10/10/19)(jm) (Entered: 10/10/2019)
10/10/2019 INDICTMENT UNSEALED as to Lev Parnas, Igor Fruman, David Correia, Andrey Kukushkin. (jm) (Entered: 10/10/2019)
10/10/2019 Case Designated ECF as to Lev Parnas, Igor Fruman, David Correia, Andrey Kukushkin. (jm) (Entered: 10/10/2019)
10/10/2019 Case as to Lev Parnas, Igor Fruman, David Correia, Andrey Kukushkin ASSIGNED to Judge J. Paul Oetken. (jm) (Entered:
10/10/2019)
10/10/2019 Attorney update in case as to Lev Parnas, Igor Fruman, David Correia, Andrey Kukushkin. Attorney Rebekah Allen
Donaleski,Nicolas Tyler Landsman Roos for USA added. (jm) (Entered: 10/10/2019)
10/10/2019 Arrest of Lev Parnas in the United States District Court - Eastern District of Virginia. (jm) (Entered: 10/23/2019)
10/15/2019 7 ORDER as to Lev Parnas, Igor Fruman, David Correia, Andrey Kukushkin ( Arraignment set for 10/17/2019 at 03:30 PM
before Judge J. Paul Oetken.)It is hereby ORDERED that all parties shall appear for an arraignment and initial conference on
Thursday, October 17, 2019, at 3:30 p.m., in Courtroom 318 of the Thurgood Marshall United States Courthouse, 40 Foley
Square, New York, New York 10007. (Signed by Judge J. Paul Oetken on 10/15/2019)(jw) (Entered: 10/15/2019)
10/16/2019 8 ORDER as to Lev Parnas, Igor Fruman, David Correia, Andrey Kukushkin: The arraignment and initial conference as to
Defendants Parnas and Fruman is hereby adjourned to Wednesday, October 23, 2019, at 11:30 a.m., and will be held in
Courtroom 506 of the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY 10007. The arraignment
and initial conference as to Defendants Correia and Kukushkin will take place as previously scheduled on Thursday, October 17,
2019, at 3:30 p.m., in Courtroom 318 of the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY
10007. (Signed by Judge J. Paul Oetken on 10/16/2019) (ap) (Entered: 10/16/2019)
10/16/2019 Set/Reset Hearings as to David Correia, Andrey Kukushkin: Arraignment set for 10/17/2019 at 03:30 PM in Courtroom 318, 40
Centre Street, New York, NY 10007 before Judge J. Paul Oetken. (ap) (Entered: 10/16/2019)
10/16/2019 Set/Reset Hearings as to Lev Parnas, Igor Fruman: Arraignment set for 10/23/2019 at 11:30 AM in Courtroom 506, 40 Centre
Street, New York, NY 10007 before Judge J. Paul Oetken. (ap) (Entered: 10/16/2019)
10/16/2019 Arrest of David Correia (3). (bw) (Entered: 10/17/2019)
10/16/2019 9 NOTICE OF ATTORNEY APPEARANCE: William Joseph Harrington appearing for (19-Cr-725-03) David Correia. (bw)
(Entered: 10/17/2019)
10/16/2019 10 Minute Entry for proceedings held before Magistrate Judge Stewart D. Aaron: Initial Appearance as to (19-Cr-725-03) David
Correia held on 10/16/2019. Date of Arrest: 10/16/2019, Vol. Surr. AUSA Rebekah Donaleski. Defense Counsel Jeffrey Marcus
(Retained). Proceeding: Rule 9. BAIL DISPOSITION: Agreed conditions of release; $250,000 PRB; 3 FRP; Travel restricted to
SDNY/EDNY/SDFL (and D. Mass. with approval of PTS); Surrender travel documents (& no new applications); Pretrial
supervision as directed by Pretrial Services; Drug testing/treatment as directed by PTS; Defendant to be released on own
signature; Remaining conditions to be met by: 2 FRPs by 10/23/2019 and 3rd FRP by 11/6/2019. No contact with co-defendants
outside presence of counsel. ADDITIONAL PROCEEDINGS: Conference before District Judge on 10/17/2019 at 3:30 p.m.
(bw) (Entered: 10/17/2019)
10/16/2019 ORAL ORDER as to (19-Cr-725-03) David Correia. Status Conference set for 10/17/2019 at 03:30 PM before Judge J. Paul
Oetken. (By Magistrate Judge Stewart D. Aaron on 10/16/2019) (bw) (Entered: 10/17/2019)
10/16/2019 11 Appearance Bond Entered as to (19-Cr-725-03) David Correia in amount of $250,000.00. $250,000.00 PRB, co-signed by 3
financially responsible persons; Travel limited to SDNY/EDNY & SDFL (and D. Mass. with approval of PTS); Surrender of
travel documents (and no new applications); Pretrial supervision as directed by PTS; Drug testing/treatment as directed by PTS;
Defendant to be released on own signature; Remaining conditions to be met by: 2 FRPs by 10/23/2019, and 3rd FRP by
11/6/2019; No contact with co-defendants outside presence of counsel. [Advice of Penalties and Sanctions dated 10/16/2019
attached. Defendant Released.] *** BAIL CONDITIONS MODIFIED BY USDJ OETKEN ON 10/23/2019: Adjourned Mr.
Correia's deadline to obtain a second co-signor from October 23, 2019 to November 6, 2019. (bw); Modified on 10/23/2019
(bw). (Main Document 11 replaced on 10/23/2019) (bw). (Entered: 10/17/2019)
10/17/2019 12 Minute Entry for proceedings held before Judge J. Paul Oetken: Initial Appearance as to (19-Cr-725-04) Andrey Kukushkin
held on 10/17/2019. AUSA Doneleski & Landsman-Roos. Defense Counsel: Gerald Lefcourt (Retained). Proceeding:
Arraignment. Defendant arraigned; pleads Not Guilty. BAIL DISPOSITION: Agreed conditions of release; $1,000,000 PRB; 3
FRP; Secured by $100,000 cash/property: $900,000 Property in Livermore, California. Travel restricted to
SDNY/EDNY/Northern, Central and Southern Districts of California; Surrender travel documents (& no new applications);
Regular pretrial supervision; Home detention; Electronic monitoring. Defendant to be released on own signature, plus the
following conditions: Cosigners by 10/24/2019, property posted by 10/31/2019. No contact with co-defendants without counsel.
Pretrial Supervision in the Northern District of California. ADDITIONAL PROCEEDINGS: Conference before District Judge
on 12/2/2019 at 2 p.m. Speedy Trial Time excluded under 18 U.S.C. Section 3161(h)(7) until 12/2/2019. (bw) (Entered:
10/18/2019)
10/17/2019 Minute Entry for proceedings held before Judge J. Paul Oetken: Arraignment as to Andrey Kukushkin (4) Count 4 held on
10/17/2019. Plea entered by Andrey Kukushkin (4) Count 4 -- Not Guilty. (bw) (Entered: 10/18/2019)
10/17/2019 ORAL ORDER as to (19-Cr-725-04) Andrey Kukushkin. Time excluded from 10/17/2019 until 12/2/2019. Status Conference
set for 12/2/2019 at 02:00 PM before Judge J. Paul Oetken. (bw) (Entered: 10/18/2019)
10/17/2019 Minute Entry for proceedings held before Judge J. Paul Oetken:Status Conference as to David Correia, Andrey Kukushkin held
on 10/17/2019. Defendant David Correia present with attorney William Harrington and Jeffrey Marcus; Defendant Andrey
Kukushkin present with attorney Gerald Lefcourt and Faith Friedman; AUSA Rebekah Donaleski and Nicolas Landsman Roos;
Court Reporter present. Next pretrial conference scheduled for 12/2/19 at 2:00 pm. Time is excluded to 12/2/19 as to all
defendants. Bail continued. (See transcript for complete details.) (Pretrial Conference set for 12/2/2019 at 02:00 PM before
Judge J. Paul Oetken) (lnl) (Entered: 10/18/2019)
10/17/2019 13 Appearance Bond Entered as to (19-Cr-725-04) Andrey Kukushkin in amount of $1,000,000.00. Agreed conditions of release;
$1,000,000.00 PRB, co-signed by 3 FRP; Secured by $100,000.00 and $900,000 Property in Livermore, California; Travel
restricted to SDNY/EDNY/Northern, Central, and Southern Districts of California; Surrender of travel documents (and no new
applications); Regular pretrial supervision; Home detention with electronic monitoring; Defendant to be released on own
signature, plus the following conditions: Cosigners by 10/24/2019, property posted by 10/31/2019; No contact with co-
defendants without counsel; Pretrial supervision in the Northern District of California. [Advice of Penalties and Sanctions dated
10/17/2019 attached. Defendant Released.] (bw) (Entered: 10/18/2019)
10/21/2019 14 NOTICE OF ATTORNEY APPEARANCE Douglas Samuel Zolkind appearing for USA. (Zolkind, Douglas) (Entered:
10/21/2019)
10/22/2019 15 NOTICE OF ATTORNEY APPEARANCE: Edward Brian MacMahon, Jr appearing for Lev Parnas. Appearance Type:
Retained. (MacMahon, Edward) (Entered: 10/22/2019)
10/22/2019 16 NOTICE OF ATTORNEY APPEARANCE: Joseph Aaron Bondy appearing for Lev Parnas. Appearance Type: Retained.
(Bondy, Joseph) (Entered: 10/22/2019)
10/22/2019 17 NOTICE OF ATTORNEY APPEARANCE: Todd Blanche appearing for Igor Fruman. Appearance Type: Retained. (Blanche,
Todd) (Entered: 10/22/2019)
10/23/2019 18 Rule 5(c)(3) Documents Received as to Lev Parnas from the United States District Court - Eastern District of Virginia. (jm)
(Entered: 10/23/2019)
10/23/2019 19 LETTER MOTION addressed to Judge J. Paul Oetken from William J. Harrington dated October 23, 2019 re: request for
adjournment of deadline to obtain a second co-signor . Document filed by David Correia. (Harrington, William) (Entered:
10/23/2019)
10/23/2019 20 ENDORSED LETTER as to David Correia addressed to Judge J. Paul Oetken from Attorney William J. Harrington dated
October 23, 2019 re: I write to request that the Court adjourn Mr. Correia's deadline to obtain a second co-signor from October
24, 2019 to November 6, 2019. ENDORSEMENT: Granted. So Ordered. (Signed by Judge J. Paul Oetken on 10/23/2019)(bw)
(Entered: 10/23/2019)
10/23/2019 21 Minute Entry for proceedings held before Judge J. Paul Oetken: Initial Appearance as to (19-Cr-725-01) Lev Parnas held on
10/23/2019. Date of Arrest: 10/9/2019. AUSA Rebekah Donaleski & Nicolas Roos. Defense Counsel: Edward MacMahon &
Joseph Bondy (Retained). BAIL DISPOSITION: Agreed conditions of release; $1,000,000 PRB; 2 FRP; Secured by $200,000
cash/property; Travel restricted to SDNY/EDNY/SDFL. Travel to EDVA and DDC only for legal visits approved by PTS;
Surrender travel documents (& no new applications); Regular pretrial supervision; Home detention; GPS; Defendant to be
released on own signature. $200,000 in cash to be transferred from EDVA by November 1, 2019. The bond is to be cosigned by
Aaron Parnas and Svetlana Parnas by November 1, 2019. Defendant is to provide a signed financial affidavit by 10/25/2019.
Defendant is to have no contact with co-defendants outside presence of counsel. Defendant is to be supervised in the Southern
District of Florida. ADDITIONAL PROCEEDINGS: Defendant arraigned; pleads Not Guilty. Conference before District Judge
on 12/2/2019 at 2 pm. Speedy Trial Time excluded under 18 U.S.C. Section 3161(h)(7) until 12/2/2019. (bw) (Entered:
10/23/2019)
10/23/2019 Minute Entry for proceedings held before Judge J. Paul Oetken: Arraignment as to Lev Parnas (1) Count 1,2,3,4 held on
10/23/2019. Plea entered by Lev Parnas (1) Count 1,2,3,4 -- Not Guilty. (bw) (Entered: 10/23/2019)
10/23/2019 ORAL ORDER as to Lev Parnas (1). Time excluded from 10/23/2019 until 12/2/2019. Status Conference set for 12/2/2019 at
02:00 PM before Judge J. Paul Oetken. (bw) (Entered: 10/23/2019)
10/23/2019 22 Appearance Bond Entered as to (19-Cr-725-01) Lev Parnas in amount of $1,000,000.00. Agreed conditions of release;
$1,000,000 Personal Recognizance Bond; To be cosigned by two financially responsible persons; Secured by $200,000 cash or
property; Travel restricted to SDNY/EDNY/SDFL; Travel to EDVA and DDC only for legal visits approved by PTS; Surrender
travel documents and no new applications; Regular pretrial supervision; Home detention; GPS; Defendant to be released on own
signature; $200,000 cash to be transferred from EDVA by November 1, 2019; The bond is to be cosigned by Aaron Parnas and
Svetlana Parnas by November 1, 2019; Defendant is to provide a signed financial affidavit by 10/25/2019; Defendant is to have
no contact with co-defendants outside the presence of counsel; Defendant is to be supervised in the Southern District of Florida.
[Advice of Penalties and Sanctions dated 10/23/2019 attached. Defendant Released.] (bw) (Main Document 22 replaced on
10/31/2019) (dif). (Main Document 22 replaced on 10/31/2019) (dif). (Main Document 22 replaced on 11/6/2019) (bw).
(Entered: 10/23/2019)
10/23/2019 23 Minute Entry for proceedings held before Judge J. Paul Oetken: Initial Appearance as to (19-Cr-725-02) Igor Fruman held on
10/23/2019. Date of Arrest: 10/9/2019. AUSA Rebekah Donaleski & Nicolas Roos. Defense Counsel: Todd Blanche (Retained).
BAIL DISPOSITION: Agreed conditions of release; $1,000,000 PRB; 3 FRP; Secured by $100,000 cash/property: $900,000 in
property in Sunny Isles Beach, Florida; Travel restricted to SDNY/EDNY/Southern District of Florida; Surrender travel
documents (& no new applications); Regular pretrial supervision; Home detention; GPS; Defendant to be released on own
signature; $100,000 in cash to be transferred from EDVA and property is to be posted by November 1, 2019. The bond is to be
cosigned by Artur Fruman, Steven Fruman, and a third financially responsible person by November 1, 2019. Defendant is to
have no contact with co-defendants outside presence of counsel. Defendant is to be supervised in the Southern District of
Florida. ADDITIONAL PROCEEDINGS: Defendant arraigned; pleads Not Guilty. Conference before District Judge on
12/2/2019 at 2 pm. Speedy Trial Time excluded under 18 U.S.C. Section 3161(h)(7) until 12/2/2019. (bw) (Entered:
10/23/2019)
10/23/2019 Minute Entry for proceedings held before Judge J. Paul Oetken: Arraignment as to Igor Fruman (2) Count 1,2,3,4 held on
10/23/2019. Plea entered by Igor Fruman (2) Count 1,2,3,4 -- Not Guilty. (bw) (Entered: 10/23/2019)
10/23/2019 ORAL ORDER as to Igor Fruman (2). Time excluded from 10/23/2019 until 12/2/2019. Status Conference set for 12/2/2019 at
02:00 PM before Judge J. Paul Oetken. (bw) (Entered: 10/23/2019)
10/23/2019 24 Appearance Bond Entered as to (19-Cr-725-02) Igor Fruman in amount of $1,000,000.00. Agreed conditions of release;
$1,000,000 Personal Recognizance Bond; To be cosigned by three financially responsible persons; Secured by $100,000 cash or
property; $900,000 in property in Sunny Isles Beach, Florida; Travel restricted to SDNY/EDNY/SDFL; Surrender travel
documents and no new applications; Regular pretrial supervision; Home detention; GPS; Defendant to be released on own
signature; $100,000 cash to be transferred from EDVA and property is to be posted by November 1, 2019; The bond is to be
cosigned by Artur Fruman, Steven Fruman, and a third financially responsible person by November 1, 2019; Defendant is to
have no contact with co-defendants outside presence of counsel; Defendant is to be supervised in the Southern District of
Florida. [Advice of Penalties and Sanctions dated 10/23/2019 attached. Defendant Released.] (bw); (Main Document 24
replaced on 11/13/2019) (bw). (Entered: 10/23/2019)
10/28/2019 25 TRANSCRIPT of Proceedings as to Lev Parnas, Igor Fruman re: Conference held on 10/23/19 before Judge J. Paul Oetken.
Court Reporter/Transcriber: Steven Griffing, (212) 805-0300, Transcript may be viewed at the court public terminal or
purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it
may be obtained through PACER. Redaction Request due 11/18/2019. Redacted Transcript Deadline set for 11/29/2019. Release
of Transcript Restriction set for 1/27/2020. (McGuirk, Kelly) (Entered: 10/28/2019)
10/28/2019 26 NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Lev Parnas, Igor Fruman. Notice is hereby given that an official
transcript of a Conference proceeding held on 10/23/19 has been filed by the court reporter/transcriber in the above-captioned
matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript.
If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90
calendar days.... (McGuirk, Kelly) (Entered: 10/28/2019)
10/30/2019 27 TRANSCRIPT of Proceedings as to David Correia, Andrey Kukushkin re: Arraignment held on 10/17/19 before Judge J. Paul
Oetken. Court Reporter/Transcriber: Kelly Surina, (212) 805-0300, Transcript may be viewed at the court public terminal or
purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it
may be obtained through PACER. Redaction Request due 11/20/2019. Redacted Transcript Deadline set for 12/2/2019. Release
of Transcript Restriction set for 1/28/2020. (McGuirk, Kelly) (Entered: 10/30/2019)
10/30/2019 28 NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to David Correia, Andrey Kukushkin. Notice is hereby given that an
official transcript of a Arraignment proceeding held on 10/17/19 has been filed by the court reporter/transcriber in the above-
captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this
transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction
after 90 calendar days.... (McGuirk, Kelly) (Entered: 10/30/2019)
10/30/2019 29 ENDORSED LETTER as to Igor Fruman addressed to Judge J. Paul Oetken from Todd Blanche, dated 10/30/2019, re: Defense
counsel writes to request a bail modification hearing beforeYour Honor, tentatively scheduled for Friday, November 1, 2019 at
11:15 a.m. ENDORSEMENT: A bail modification hearing is scheduled for November 1, 2019, at 11:15 a.m., in Courtroom 706,
40 Foley Square. Defendant Fruman's presence at the hearing is hereby waived. So Ordered. (Signed by Judge J. Paul Oetken on
10/30/2019) (lnl) (Entered: 10/31/2019)
10/30/2019 Set/Reset Hearings as to Igor Fruman: Bail Modification Hearing set for 11/1/2019 at 11:15 AM in Courtroom 706, 40 Centre
Street, New York, NY 10007 before Judge J. Paul Oetken. (lnl) (Entered: 10/31/2019)
11/01/2019 Minute Entry for proceedings held before Judge J. Paul Oetken:Bail Modification Hearing as to Igor Fruman held on 11/1/2019.
Defendant Igor Fruman not present. Attorney Todd Blanche present; AUSA Rebekah Donaleski, Nicolas Landsman Roos and
Douglas Zolkin present; Court Reporter present.Bail Modification Hearing held: The bail conditions previously set are
continued without modification. (See transcript for complete details.) (jw) (Entered: 11/04/2019)
11/05/2019 30 ENDORSED LETTER as to Igor Fruman addressed to Judge J. Paul Oetken, from Todd Blanche dated 11/5/2019 re: Defense
counsel writes to request two modifications to defendant's bail conditions. ENDORSEMENT: Granted. So ordered. (Signed by
Judge J. Paul Oetken on 11/5/2019) (ap) (Entered: 11/05/2019)
11/07/2019 31 ORDER as to Lev Parnas: It is hereby ORDERED that the defendant's bail is modified to include: Surrender firearms and
fireann permit to the local authorities, or otherwise directed by Pretrial Services, and provide proof of such. SO ORDERED.
(Signed by Judge J. Paul Oetken on 11/7/2019) (lnl) Modified on 11/7/2019 (lnl). (Entered: 11/07/2019)
11/12/2019 32 LETTER by USA as to Lev Parnas, Igor Fruman, David Correia, Andrey Kukushkin addressed to Judge J. Paul Oetken from
Rebekah Donaleski dated November 12, 2019 re: Proposed Protective Order Document filed by USA. (Donaleski, Rebekah)
(Entered: 11/12/2019)
11/12/2019 33 NOTICE OF ATTORNEY APPEARANCE: Gerald B. Lefcourt appearing for Andrey Kukushkin. Appearance Type: Retained.
(Lefcourt, Gerald) (Entered: 11/12/2019)
11/12/2019 34 NOTICE OF ATTORNEY APPEARANCE: Faith Alison Friedman appearing for Andrey Kukushkin. Appearance Type:
Retained. (Friedman, Faith) (Entered: 11/12/2019)
11/13/2019 35 PROTECTIVE ORDER as to Lev Parnas, Igor Fruman, David Correia, Andrey Kukushkin...regarding procedures to be
followed that shall govern the handling of confidential material.... (Signed by Judge J. Paul Oetken on 11/13/2019) (lnl)
(Entered: 11/13/2019)
11/13/2019 36 ORDER as to Lev Parnas: It is hereby ORDERED that, in light of the writ of attachment, the Clerk of Court shall not release the
funds posted by or on behalf of Defendant Parnas in this matter absent further order of this Court.SO ORDERED. (Signed by
Judge J. Paul Oetken on 11/13/2019) (lnl) (Entered: 11/13/2019)
11/18/2019 37 TRANSCRIPT of Proceedings as to Igor Fruman re: Hearing held on 11/1/19 before Judge J. Paul Oetken. Court
Reporter/Transcriber: Jennifer Thun, (212) 805-0300, Transcript may be viewed at the court public terminal or purchased
through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be
obtained through PACER. Redaction Request due 12/9/2019. Redacted Transcript Deadline set for 12/19/2019. Release of
Transcript Restriction set for 2/18/2020. (McGuirk, Kelly) (Entered: 11/18/2019)
11/18/2019 38 NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Igor Fruman. Notice is hereby given that an official transcript of a
Hearing proceeding held on 11/1/19 has been filed by the court reporter/transcriber in the above-captioned matter. The parties
have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is
filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....
(McGuirk, Kelly) (Entered: 11/18/2019)
11/20/2019 39 NOTICE of Change of Address as to Lev Parnas. New Address: The Law Offices of Joseph A. Bondy, 1776 Broadway, Suite
2000, New York, New York, USA 10019, (212) 219-3572. (Bondy, Joseph) (Entered: 11/20/2019)
11/22/2019 40 ENDORSED LETTER as to Igor Fruman addressed to Judge J. Paul Oetken, from Todd Blanche dated 11/22/2019 re: Defense
counsel writes to request Defendant be excused from attending conference. ENDORSEMENT: Granted. So ordered. (Signed by
Judge J. Paul Oetken on 11/22/2019) (ap) (Entered: 11/22/2019)
11/25/2019 NOTICE: THE PRETRIAL CONFERENCE SCHEDULED FOR DECEMBER 2, 2019 AT 2:00 PM BEFORE JUDGE
OETKEN WILL BE HELD IN COURTROOM 110 OF THE THURGOOD MARSHALL UNITED STATES COURTHOUSE,
40 FOLEY SQUARE, NEW YORK, NEW YORK 10007. (bh) (Entered: 11/25/2019)
12/02/2019 Minute Entry for proceedings held before Judge J. Paul Oetken: Pretrial Conference as to Lev Parnas, Igor Fruman, David
Correia, Andrey Kukushkin held on 12/2/2019. Defendant Lev Parnas present with attorney Edward MacMahon and Joseph
Bondy; defendant Igor Fruman not present, attorney Todd Blanche present; defendant David Correia not present, attorney
William Harrington present; defendant Andrey Kukushkin not present, attorney Gerald Lefcourt and Faith Friedman present.
AUSA Rebekah Donaleski, Nicolas Landsman Roos and Douglas Zolkind present. Court Reporter present. Pretrial conference
held: Next conference scheduled for 2/3/2020. Time is excluded to 2/3/2020. Bail continued as to each defendant. (See
transcript for complete details.) (jbo) Modified on 12/3/2019 (jw). (Entered: 12/03/2019)
12/04/2019 41 FIRST LETTER MOTION addressed to Judge J. Paul Oetken from Joseph A. Bondy, Esq. dated December 4, 2019 re:
Modification of the Terms of Pre-Trial Release . Document filed by Lev Parnas. (Bondy, Joseph) (Entered: 12/04/2019)
12/10/2019 42 TRANSCRIPT of Proceedings as to Lev Parnas re: Conference held on 12/2/19 before Judge J. Paul Oetken. Court
Reporter/Transcriber: Sonya Ketter Moore, (212) 805-0300, Transcript may be viewed at the court public terminal or purchased
12/10/2019 43 NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Lev Parnas. Notice is hereby given that an official transcript of a
Conference proceeding held on 12/2/19 has been filed by the court reporter/transcriber in the above-captioned matter. The
parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such
Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar
days.... (McGuirk, Kelly) (Entered: 12/10/2019)
12/11/2019 44 LETTER by USA as to Lev Parnas addressed to Judge J. Paul Oetken from Rebekah Donaleski dated December 11, 2019 re:
Opposition to Parnas Bail Modification Request Document filed by USA. (Donaleski, Rebekah) (Entered: 12/11/2019)
12/12/2019 45 LETTER MOTION addressed to Judge J. Paul Oetken from Gerald B. Lefcourt dated 12/12/19 re: surveillance . Document filed
by Andrey Kukushkin. (Attachments: # 1 Exhibit A - 2019-11-26 to government re surveillance, # 2 Exhibit B - 2019-12-01
Kukushkin Response Letter, # 3 Exhibit C - 2005-12-23 letter and transcript)(Lefcourt, Gerald) (Entered: 12/12/2019)
12/12/2019 46 ORDER as to Lev Parnas. A bail review hearing for Defendant Lev Parnas will be held on December 17, 2019, at 12:15 p.m. in
Courtroom 318 of the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY 10007. In anticipation of
that hearing, counsel for Defendant Lev Parnas is directed to file a response to the Government's letter dated December 11,
2019, on or before December 16, 2019, at 12:00 p.m. SO ORDERED. (Signed by Judge J. Paul Oetken on 12/12/19)(jbo)
(Entered: 12/12/2019)
12/12/2019 Set/Reset Deadlines/Hearings as to Lev Parnas: Responses due by 12/16/2019. Bond Hearing set for 12/17/2019 at 12:15 PM
before Judge J. Paul Oetken. (jbo) (Entered: 12/12/2019)
12/16/2019 47 LETTER REPLY TO RESPONSE to Motion by Lev Parnas addressed to Judge J. Paul Oetken from Joseph A. Bondy, Esq.
dated December 16, 2019 re 41 FIRST LETTER MOTION addressed to Judge J. Paul Oetken from Joseph A. Bondy, Esq.
dated December 4, 2019 re: Modification of the Terms of Pre-Trial Release .. (Bondy, Joseph) (Entered: 12/16/2019)
12/16/2019 NOTICE AS TO LEV PARNAS: THE DECEMBER 17, 2019 BAIL REVIEW HEARING WILL BE HELD IN
COURTROOM 12B OF THE DANIEL PATRICK MOYNIHAN UNITED STATES COURTHOUSE, 500 PEARL STREET,
NEW YORK NEW YORK, 10007. (bh) (Entered: 12/16/2019)
12/17/2019 Minute Entry for proceedings held before Judge J. Paul Oetken: Bond Hearing as to Lev Parnas held on 12/17/2019. Defendant
Lev Parnas present with attorney Joseph Bondy and Stephanie Schuman; AUSA Rebekah Donaleski, Nicolas Roos and Douglas
Zolkind present; Court Reporter present. Bail Review Hearing Held: Bail conditions to continue as previously set. Bail
Continued. (See transcript for complete details.) (jbo) (Entered: 12/18/2019)
12/18/2019 48 LETTER by USA as to Andrey Kukushkin addressed to Judge J. Paul Oetken from Rebekah Donaleski dated December 18,
2019 re: Response Deadline Document filed by USA. (Donaleski, Rebekah) (Entered: 12/18/2019)
12/18/2019 49 LETTER by USA as to Lev Parnas addressed to Judge J. Paul Oetken from Rebekah Donaleski dated December 18, 2019 re:
Bail Hearing Exhibits Document filed by USA. (Donaleski, Rebekah) (Entered: 12/18/2019)
12/19/2019 50 LETTER by Andrey Kukushkin addressed to Judge J. Paul Oetken from Gerald B. Lefcourt dated 12/19/19 re: providing
decision of United States Court of Appeals for the Second Circuit in U.S. v. Hasbajrami, Dkt. No. 15-2684-L; 17-2669-CON
(Attachments: # 1 Second Circuit Decision)(Lefcourt, Gerald) (Entered: 12/19/2019)
12/19/2019 51 MEMO ENDORSEMENT as to Andrey Kukushkin on re: 48 LETTER by USA as to Andrey Kukushkin addressed to Judge J.
Paul Oetken from Rebekah Donaleski dated December 18, 2019 re: Response Deadline. ENDORSEMENT: Granted. So
ordered. (Responses due by 1/3/2020) (Signed by Judge J. Paul Oetken on 12/19/2019) (ap) (Entered: 12/19/2019)
12/20/2019 52 TRANSCRIPT of Proceedings as to Lev Parnas re: Oral Argument held on 12/17/19 before Judge J. Paul Oetken. Court
Reporter/Transcriber: Pamela Utter, (212) 805-0300, Transcript may be viewed at the court public terminal or purchased
12/20/2019 53 NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Lev Parnas. Notice is hereby given that an official transcript of a
Oral Argument proceeding held on 12/17/19 has been filed by the court reporter/transcriber in the above-captioned matter. The
parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such
Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar
days.... (McGuirk, Kelly) (Entered: 12/20/2019)
12/20/2019 54 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Jeffrey E. Marcus to Appear Pro Hac Vice . Filing fee $
200.00, receipt number ANYSDC-18333271. Motion and supporting papers to be reviewed by Clerk's Office staff.
Document filed by David Correia. (Attachments: # 1 Affidavit Affidavit of Jeffrey Marcus, # 2 Exhibit Certificate of Good
Standing, # 3 Text of Proposed Order Text of Proposed Order)(Marcus, Jeffrey) Modified on 12/20/2019 (bcu). (Entered:
12/20/2019)
12/20/2019 >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice as to David Correia to RE-
FILE Document No. 54 MOTION for Jeffrey E. Marcus to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number
ANYSDC-18333271. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the
following reason(s): missing Certificate of Good Standing from Supreme Court of Florida;. Re-file the motion as a
Corrected Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach
valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (bcu) (Entered: 12/20/2019)
12/20/2019 55 ENDORSED LETTER as to Lev Parnas addressed to Judge J. Paul Oetken, from Joseph A. Bondy dated 12/20/2019 re:
Counsel writes regarding redacted items. ENDORSEMENT: Granted. Defendant's counsel is directed to file on ECF the exhibits
with the proposed redactions. (Signed by Judge J. Paul Oetken on 12/20/2019) (ap) (Entered: 12/20/2019)
12/20/2019 56 LETTER by Lev Parnas addressed to Judge J. Paul Oetken from Joseph A. Bondy, Esq. dated December 20, 2019 re:
Submission of Redacted Exhibits from Bail Review Hearing of December 17, 2019 (Attachments: # 1 Exhibit SunTrust
Banking Records (Redacted), # 2 Exhibit Chase Bank Records (Redacted), # 3 Exhibit E-Mail Correspondence (Redacted), # 4
Exhibit Accountant Letter (Redacted))(Bondy, Joseph) (Entered: 12/20/2019)
12/24/2019 57 MOTION for Edward B. MacMahon, Jr. to Withdraw as Attorney . Document filed by Lev Parnas. (Attachments: # 1
Affirmation of Counsel)(MacMahon, Edward) (Entered: 12/24/2019)
12/30/2019 58 LETTER MOTION addressed to Judge J. Paul Oetken from Joseph A. Bondy, Esq. dated December 30, 2019 re: Unopposed
Modification of the Protective Order Governing Discovery, to allow production of materials seized from Mr. Parnas's home and
the contents of his iPhone 11 to the United States House of Representatives' Permanent Select Committee on Intelligence, in
connection with the impeachment inquiry of President Donald J. Trump . Document filed by Lev Parnas. (Bondy, Joseph)
(Entered: 12/30/2019)
01/03/2020 59 ORDER as to Lev Parnas (1). On December 24, 2019, Attorney Edward B. MacMahon, Jr., counsel of record for Defendant Lev
Parnas, moved to withdraw from this case. (Dkt. No. 57.) That request is hereby GRANTED. The Clerk of Court is directed to
terminate Mr. MacMahon from the case and close the motion at Docket Number 57. SO ORDERED. (Signed by Judge J. Paul
Oetken on 1/3/20) (jbo) (Entered: 01/03/2020)
01/03/2020 60 MEMO ENDORSED granting 58 LETTER MOTION Unopposed Modification of the Protective Order Governing Discovery,
to allow production of materials seized from Mr. Parnas's home and the contents of his iPhone 11 to the United States House of
Representatives' Permanent Select Committee on Intelligence, in connection with the impeachment inquiry of President Donald
J. Trump as to Lev Parnas (1)...ENDORSEMENT: Granted. Defendant Lev Parnas may produce the materials referenced herein
to the United States House of Representatives Permanent Select Committee on Intelligence. SO ORDERED. (Signed by Judge
J. Paul Oetken on 1/3/20) (jbo) (Entered: 01/03/2020)
01/03/2020 61 LETTER by USA as to Lev Parnas, Igor Fruman, David Correia, Andrey Kukushkin addressed to Judge J. Paul Oetken from
Rebekah Donaleski dated January 3, 2020 re: Kukushkin Surveillance Motion Document filed by USA. (Donaleski, Rebekah)
(Entered: 01/03/2020)
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ATTACHMENT G
Transcript of Raskin's Remarks re: Parnas
12/26/23

00:00:00:00 - 00:00:28:09
Unknown
And now we can finally definitively say why the committee's efforts
have run dry. Time and again, just yesterday, Mr. Chairman, you and I
got a letter from Lev Parnas, the Ukrainian born American businessman
who is at Rudy Giuliani's side as his right hand man for a year
between November 2018 to October 2019, as Giuliani and then President
Trump tried to smear Joe Biden before the 2020 election with the very
same allegations.
00:00:28:12 - 00:00:55:14
Unknown
We're still running through the political spin cycle every week in
this committee. I request unanimous consent to enter the PARNAS letter
into the record without objection. Now, in this extraordinary ten page
letter, Parnas painstakingly describes the campaign orchestrated by
Giuliani and Trump to, quote, dig up dirt on the Bidens and spread
misinformation about them through various networks, including
government officials, journalists and Fox News personnel.
00:00:55:16 - 00:01:21:12
Unknown
After explaining this campaign to fabricate corruption charges against
Biden, Parnas concludes his letter by saying, Throughout all these
months of work, the extensive campaigns and networking done by Trump
allies and Giuliani associates, including the enormously thorough
interviews and assignments that I undertook, quote, There has never
been any evidence that Hunter or Joe Biden committed any crimes
related to Ukrainian politics.
00:01:21:13 - 00:01:47:28
Unknown
Never during any of my communications with Ukrainian officials or
connections to Burisma. Did any of them confirm or provide concrete
facts linking the Bidens to illegal activities. As Mr. Parnas
concludes, there has never been any factual evidence, only conspiracy
theories spread by people who knew exactly what they were doing. And
then he calls on this committee to end its wild goose chase and offers
to come and testify.
00:01:48:02 - 00:02:14:24
Unknown
Remember this is Mr. Giuliani's guy. This is his interpreter and right
hand man who spent a year out there trying to cook the books against
Joe Biden. And he offers to come testify. So if anyone doubts anything
he's saying, let's bring him in as a witness. And let's hear about
that crusade that they were on to smear President Biden by promoting
the same baseless conspiracy theories that this committee serves up as
moldy leftovers every day.
00:02:14:27 - 00:02:41:28
Unknown
At today's hearing, we're going to hear about wrongdoing by Hunter
Biden, who's pleading guilty on two tax charges and a gun charge. Next
week, we'll hear about the back and forth among investigators,
prosecutors and a Trump appointed U.S. attorney. Over a dozen people
who spent four years investigating the president's son. We'll hear
about how they disagreed on investigative steps and what criminal
charges to bring on normal stuff in government investigations.
00:02:41:28 - 00:02:53:22
Unknown
That doesn't usually lead to a congressional hearing. But one thing
you will not hear today is any evidence of wrongdoing by President Joe
Biden or his administration.
ATTACHMENT H
Links to audio & video exhibits
1. Dec 26, 2023 Raskin Remarks re: Parnas:

https://www.loom.com/share/012de1c2340548e5b902be132b30
46b4?sid=84e71c00-dab0-4e74-a178-b7d55c11ea6f
2. The Pete Santilli Show – Original PARNAS Article

https://thepetesantillishow.com/archives/14302
3. Oct 3, 2019 - Stockman Call 1:

https://www.loom.com/share/93d805cd003e43eda6d79b439a67
719f?sid=e2c5b49f-f92e-4b4d-93b4-9aa2f389aada

https://www.loom.com/share/dbd32a63c2a14501a39c0b05bc7f
2bb2?sid=3978f566-5677-427c-aa1f-b7abadd31ae5

https://www.loom.com/share/9157816e53524cf0b61617065733
bac6?sid=114fefe8-be2c-472c-b15f-c1cc1878838c

https://www.loom.com/share/dc923bf0fd624762ad054e37c6a3
00a1?sid=3aacd58d-47dc-4b8c-ae2d-3122e48fe474

DELIVERED TO PRESIDENT TRUMP ON 12/31/23 - Parnas - Stockton - Executive Summary

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Peter T.

P.O. Box 30122 Cincinnati, Ohio 45230

P.O. Box 30122 Cincinnati, Ohio 45230

Prepared By Peter T. Santilli, Investigative Journalist

• In or around October 2019, I sought to contact former Congressman Steve

• During our series of conversations, Congressman Stockman's wife, Patti, informed

• Starting from October 3, 2019, I engaged in several secure conversations with

• Congressman Stockman also disclosed that he was in communication with a

Prepared By Peter T. Santilli, Investigative Journalist

Prepared By Peter T. Santilli, Investigative Journalist

Prepared By Peter T. Santilli, Investigative Journalist

Prepared By Peter T. Santilli, Investigative Journalist

Dear Secretary Cohen:

I am writing to seek your assistance in reviewing evidence that Ukrainian steelmaker

1 A companyprofile can be found at: Orbis - LUGTSENTROKUZ IM S S MONYATOVSKOGO ZAO for a

2 “Frunze” from the company website.

v. Ministry of Taxation and Revenue of Ukraine letter - August 2014 - The

vii. ‘Appendix 712 of March 12th 2012 to Commission Agreement 65090049’7 –

Prepared By Peter T. Santilli, Investigative Journalist

Prepared By Peter T. Santilli, Investigative Journalist

The Honorable James Comer

Dear Chairman Comer,

Here are the facts as I know them to be true:

Thank you for your consideration.

Prepared By Peter T. Santilli, Investigative Journalist

Hon. J. Paul Oetken

Re: United States v. Andrey Kukushkin, No. 19 Cr. 725 (JPO)

Dear Judge Oetken:

Kukushkin’s reliance on Section § 3504 is similarly misplaced. As an initial matter,

3. The Government Intends to Comply With Its Discovery Obligations

Cc: All Defense Counsel (by ECF)

Prepared By Peter T. Santilli, Investigative Journalist

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U.S. District Court

Case title: USA v. Parnas Date Filed: 10/09/2019

Assigned to: Judge J. Paul Oetken

Joseph Aaron Bondy

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Assigned to: Judge J. Paul Oetken

David Correia represented by Jeffrey Marcus

William Joseph Harrington

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Assigned to: Judge J. Paul Oetken

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Nicolas Tyler Landsman Roos

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Prepared By Peter T. Santilli, Investigative Journalist