Case 1:18-cr-00218-TSC Document 23 Filed 08/24/18 Page 1 of 2 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, v. MARIIA BUTINA, a/k/a MARIA BUTINA, Defendant. ) ) ) ) ) ) ) ) ) Case No.: 1:18-cr-218 (TSC) DEFENDANT MARIA BUTINA’S MOTION FOR BOND REVIEW Pursuant to 18 U.S.C. § 3145(b), Maria Butina moves this Court to review and modify the current pretrial order of detention to allow for her release pending trial into the Pretrial Services Agency High Intensity Supervision Program (HISP) on a home detention basis with electronic monitoring. As grounds for this motion, for which a hearing is requested, counsel directs the Court to the memorandum in support filed herewith. WHEREFORE, for the foregoing reasons and those that the defense may present during a hearing on this matter, Defendant Maria Butina respectfully requests that her motion be granted and that the Court allow for her release pending trial on a home detention basis with electronic monitoring. Dated: August 24, 2018 Respectfully submitted, /s/Robert N. Driscoll Robert N. Driscoll (DC Bar No. 486451) McGlinchey Stafford PLLC 1275 Pennsylvania Avenue NW, Suite 420 Washington, DC 20004 Phone: (202) 802-9999 Fax: (202) 403-3870 rdriscoll@mcglinchey.com 1 Case 1:18-cr-00218-TSC Document 23 Filed 08/24/18 Page 2 of 2 /s/Alfred D. Carry Alfred D. Carry (DC Bar No. 1011877) McGlinchey Stafford PLLC 1275 Pennsylvania Avenue NW, Suite 420 Washington, DC 20004 Phone: (202) 802-9999 Fax: (202) 330-5897 acarry@mcglinchey.com Counsel for Defendant 2 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 1 of 17 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, v. MARIIA BUTINA, a/k/a MARIA BUTINA, Defendant. ) ) ) ) ) ) ) ) ) Case No.: 1:18-cr-218 (TSC) MEMORANDUM IN SUPPORT OF DEFENDANT MARIA BUTINA’S MOTION FOR BOND REVIEW Defendant Maria Butina submits this memorandum in support of her motion for bond review, stating as follows: I. Background Maria Butina was indicted for acting in the United States as an agent of a foreign government without prior notification to the Attorney General (in violation of 18 U.S.C. § 951) and conspiracy to do the same (in violation of 18 U.S.C. § 371). Since her arrest on July 15, 2018, Ms. Butina has been held without bond. At the preliminary detention hearing on July 18, 2018, Magistrate Judge Deborah Robinson denied Ms. Butina’s request for release based on the government’s fear of flight from prosecution. (Mem. of Findings of Fact and Statement of Reasons in Support of Order of Detention, Jul. 24, 2018 [Doc. 15] (Robinson, M.J.)) According to the government’s proffer and a single witness from the State Department’s Diplomatic Security Service, who had no personal knowledge about Ms. Butina’s specific flight risk, the government contended that no combination of conditions could reasonably assure her future appearance in court. After interviewing Ms. Butina and assessing her flight risk, the Pretrial Services Agency (PSA) recommended that the Court release Ms. Butina under general 1 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 2 of 17 supervision and a few conditions.1 Her counsel echoed the PSA’s recommendations, asking the Court to release Ms. Butina with conditions. The magistrate denied that request. In deciding to detain Ms. Butina without bond, Magistrate Judge Robinson rejected the PSA’s independent findings and accepted the government’s proffer as true, principally because “a grand jury has found probable cause” (Doc. 15 at 3) and Ms. Butina “is a national of the Russian Federation, with which the United States has no extradition treaty” (id. at 6). Magistrate Judge Robinson also noted that defense counsel “did not cross examine the witness called by the government.” (Id. at 7, n.3.) II. Standard of Review A person awaiting trial on a federal offense may be released on personal recognizance or bond, conditionally released, or detained. 18 U.S.C. § 3142(a); see United States v. Singleton, 182 F.3d 7, 9 (D.C. Cir. 1999). “Our system of criminal justice embraces a strong presumption against detention. ‘In our society, liberty is the norm and detention prior to trial or without trial is the carefully limited exception.’” United States v. Hanson, 613 F. Supp. 2d 85, 87 (2009) (quoting United States v. Salerno, 481 U.S. 739, 755 (1987)). The Bail Reform Act of 1984 (Act), 18 U.S.C. § 3141 et seq., enumerates the limited circumstances when a defendant may be detained before trial. If a judicial officer finds by clear and convincing evidence that “no condition or combination of conditions will reasonably assure the safety of any other person and the community, such judicial officer shall order the detention of the defendant before trial.” 18 U.S.C. § 3142(e). Alternatively, a finding that no condition or combination of conditions will reasonably assure the appearance of the defendant must be 1 Those conditions were that Ms. Butina report to the PSA weekly by phone, verify her address, not apply for or possess a passport, stay within the Washington, DC area, and surrender all passports to the PSA. (Doc. 5 at 2.) 2 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 3 of 17 supported by a preponderance of the evidence. Id.; United States v. Simpkins, 826 F.2d 94, 96 (D.C. Cir. 1987). The “preponderance must, of course, go to the ultimate issue: that no combination of conditions—either those set out in the Bail Reform Act itself or any others that the magistrate or judge might find useful—can reasonably assure that the defendant will appear for trial.” United States v. Xulam, 84 F.3d 441, 442 (D.C. Cir. 1996). A magistrate judge’s bail determination is reviewed de novo, and a court is free to use any evidence or rationale different from what the magistrate relied upon. United States v. Hudspeth, 143 F. Supp. 2d 32, 35-36 (D.D.C. 2001) (Kennedy, J.); United States v. Bess, 678 F. Supp. 929, 934 n.3 (D.D.C. 1988). Further, both the government and the defendant may present evidence by proffer at a detention hearing, rather than by presenting live testimony. Hanson, 613 F. Supp. 2d at 88. III. Argument The government sought to detain Ms. Butina under section 3142(f)(2)(A), which permits a court to order pretrial detention “in a case that involves . . . a serious risk that such person will flee.” 18 U.S.C. § 3142(f)(2)(A).2 However, the government’s claim that no release conditions will reasonably assure her future appearance in court is an exaggeration. Indeed, many of the government’s assertions find no support among the facts. Instead, the government relies on innuendo and undefined phrases, soundbites and alarmist buzzwords. The assertion that she was arrested for an alleged “role in a covert Russian influence operation in the United States” (Doc. 8 at 2) is a war drum based on pure fiction. Nothing about 2 The government did not argue that Ms. Butina should be detained because she would pose a danger to the public if released. And going to dinners among intellectuals and foreign policy wonks to discuss U.S.-Russia relations, attending two National Prayer Breakfasts, and booking hotel rooms at the Washington Hilton, if true, is anything but an “obvious” danger to the public. (Doc. at 7.) 3 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 4 of 17 her activities in the United States were covert or clandestine. Quite the opposite, Ms. Butina came to the United States for graduate school. She spoke genuinely about peace and positive relations between her home country and the United States. Her personal statement for graduate school addressed the same, and her supposed “handler” Aleksandr Porfiryevich Torshin, who is actually just a friend, wrote her letters of recommendation (attached as Exhibit 1). Maria actually applied to seven universities in the United States (Yale, Columbia, Harvard, Stanford, Georgetown, American, and Tufts). She even considered going to law school in Russia prior to resolving to matriculate at American University. No person from the Russian government instructed her to go to American. Moreover, once there, she considered transferring to Harvard to enroll in their Russia, Eastern Europe, and Central Asia (REECA) Master’s Degree program (see Exhibit 2). These are not the actions of a Russian agent looking to hide among students “as part of the operation” while leaving enough time to collect information, as the government claims. (Doc. 8 at 7.) To the contrary, her academic pursuits were sincere. She sought scholastic rigor, not a “cover occupation.” (Id. at 8.) A. The Nature and Circumstances of the Offense To be sure, the counts alleged in the indictment (acting as a foreign agent without registration and conspiracy) are serious charges that carry ten and five year maximum sentences, respectively. However, they are not offenses that carry a rebuttable presumption that no condition of release or combination of conditions would reasonably assure a defendant’s appearance. See 18 U.S.C. § 3142(e)(3). Furthermore, despite the patina of espionage with which the government tries to color this case, the allegations do not involve spying, tradecraft, classified information, or any other hallmarks of an espionage case. 4 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 5 of 17 Rather, Ms. Butina is alleged to have acted publicly, documenting her activities on blog posts and social media. She traveled openly in the United States with her purported “handler” every time he visited, and she had a “special assistant” business card that she asked him to provide, so she could help with his travel arrangements while not being mistaken for a paid escort. She is accused of arranging dinners to promote better relations between Russia and the United States although the very dinner that is listed as a predicate act for her alleged crimes was written about in Time Magazine and the American Conservative—hardly covert activity—and, in actuality, was initiated, organized, and directed by an American citizen, not the Russian government.3 The gravamen of the government’s case is that Ms. Butina was essentially lobbying on behalf of Russia for better relations with the United States. However for reasons only it is aware, the government has charged Ms. Butina under 18 U.S.C. § 951 rather than the Foreign Agent Registration Act (“FARA”), 22 U.S.C. § 611 et seq., which generally carries civil penalties and much less severe criminal penalties (for circumstances far more egregious than the facts alleged here). Much like a FARA case, the government does not allege that Ms. Butina undertook any independently illegal activities in the United States. The only thing that made her alleged conduct illegal, if true, is that she did not notify the Attorney General prior to undertaking it. Additionally, the government does not allege that Ms. Butina is a member of any Russian intelligence service. Instead, the government relies on a series of isolated Twitter direct messages (that she voluntarily supplied to the U.S. Senate Select Committee on Intelligence in their entirety) to establish that she was somehow operating under the direction or control of a Russian official, even though the 3 Alex Altman and Elizabeth Dias, Moscow Cozies Up to the Right, TIME MAGAZINE, Mar. 10, 2017, http://time.com/4696424/moscow-right-kremlin-republicans/. George D. O’Neill Jr., Why Do We Want a Cooperative Relationship With Russia?, AMERICAN CONSERVATIVE, Apr. 24, 2017, https://www.theamericanconservative.com/articles/why-do-we-want-a-cooperative-relationshipwith-russia/. 5 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 6 of 17 Russian Federation did not pay for her travel to the United States, her tuition, her living expenses, or make any payments to her at all. At bottom, the government’s case appears to be a novel attempt to stretch 18 U.S.C. § 951 to cover the activities of a foreign national student under the theory that her communications (about non-classified public source material) with contacts in her home country made her an “agent” of that country. The serious charges against her should be viewed in that context, which makes this case distinctly different from a typical section 951, “espionage-like or clandestine behavior” case.4 B. Weight of the Evidence With regard to the weight of the evidence, the government claims that its case is “substantial.” (Doc. 8 at 10.) However, behind the curtain of its fanciful assertions that she acted as a Kremlin-agent of influence “to penetrate the U.S. national decision-making apparatus” (Doc. 1-1 at 4 ¶ 14) is no allegation that the Russian Federation actually gave Ms. Butina an order, let alone direction to do anything. She stole no national secrets. She engaged in no confidential information gathering or stealthy procurement-type activities. She never worked for an intelligence operation of the Russian Federation. At most, she networked for her own entrepreneurial gain, took pictures with political celebrities as keepsakes, and shared her memorable events and enthusiasm for American culture and politics with family and friends back home, like hundreds of other foreign students and typical Washingtonian mid-twenty-somethings do. To distract from the frailty of its charges, the government reprises that Ms. Butina is charged under section 951 and not FARA. However, that charging decision alone contradicts the 4 According to the United States Department of Justice, National Security Division, 18 U.S.C. § 951 targets “espionage-like or clandestine behavior.” U.S. DOJ, Office of the Inspector General, Audit of the National Security Division’s Enforcement and Administration of the Foreign Agents Registration Act, at 9 (Sep. 2016), available at https://oig.justice.gov/reports/2016/a1624.pdf (last visited Aug. 24, 2018) 6 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 7 of 17 Justice Department’s own policies, and perhaps was made as an attempt to aggrandize her conduct and mischaracterize her innocent political interest as nefarious. That is, the Department of Justice (“DOJ”) Criminal Resource Manual makes a distinction between section 951 and a FARA violation. It describes FARA under section 611 et seq. as requiring an agent of a foreign principal engaged in political activities to register. See U.S. Dep’t of Justice, United States Attorneys’ Manual 9-90.700 and 9-90.701; and see Criminal Resource Manual at 2062. It also discusses other federal statutes like section 951, which is “aimed at persons loosely called foreign agents” but specifically exempts section 951 from applying to “foreign agents engaged in political activities.” Id. In plain English, DOJ further notes among frequently asked questions that section 951 is only “aimed at foreign government controlled agents engaged in non-political activities.”5 The government’s April, 2018 search warrant sought evidence of a potential violation under FARA. The indictment irrefutably characterizes her actions (Doc. 7 at 3, ¶ 8) as political. The purpose of her so-called conspiracy, the government claims, was to “exploit personal connections with U.S. persons having influence in American politics” and to “establish unofficial lines of communications with U.S. politicians and political organizations.” (Id.) The affidavit in support of the criminal complaint similarly focuses on political activities. (Doc. 1-1.) However, although such allegations are unfounded and untrue, and although the government’s searches revealed no hidden transmitters, wads of cash, counterfeit passports, and plane tickets back to Moscow, the government still decided to paper a case against Ms. Butina under section 951. This 5 See DOJ Comments regarding FARA Related Statutes, available at https://www.justice.gov/nsdfara/fara-related-statutes (last visited Aug. 24, 2018) (emphasis added); see also DOJ Answers to Frequently Asked Questions, available at https://www.justice.gov/nsd-fara/general-farafrequently-asked-questions (last visited Aug. 24, 2018). 7 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 8 of 17 decision shows that the government desired to overcharge and inflate her conduct for tactical advantages versus act with restraint or, at a minimum, be consistent with the DOJ and National Security Division’s own publicized understanding of appropriate charges. It follows that the government states “facts” that distort the truth or are wholly false. For example, the government has deleted sentences, misquoting her messages; truncated conversations, taking them out of context; replaced emoticons with brackets, twisting tone; and mistranslated Russian communications, altering their meaning. The government has also sworn in its affidavit—likely presenting the same false information to a grand jury under oath—that Ms. Butina took certain actions in the United States when immigration records confirm that she was, in fact, overseas. C. History and Character of the Person Ms. Butina is not a criminal. She is not on probation, parole, or on other release pending trial, sentencing, or appeal. See 18 U.S.C. § 3142(g)(3)(B). She has never been arrested or charged with a crime before. Id. Rather, she is a young woman of good character and with genuine ties to the United States through her five-year relationship with Paul Erickson, her academic work, and her desire to pursue a career in the United States. See 18 U.S.C. § 3142(g)(3)(A). The government gratuitously and falsely smeared her character and reputation in its written memorandum and oral proffer made in open court. The government argued that Ms. Butina’s relationship with Mr. Erickson is a “duplicitous relationship” because she “appears to treat it as simply a necessary part of her activities.” (Govt’s Mem. in Support of Detention, Doc. 8 at 8). In particular, AUSA Kenerson alleged that: For example, on at least one occasion, Butina offered an individual other than [Mr. Erickson] sex in exchange for a position within a special interest organization. 8 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 9 of 17 (Id.) The impact of this inflammatory allegation, which painted Ms. Butina as some type of Kremlin-trained seductress, or spy-novel honeypot character, trading sex for access and power, cannot be overstated. The assertion that she used sex to develop her relationships in the United States appeared on the front pages of the New York Times, the Washington Post, CNN’s website, and more. Worse, it also appeared on the television of her parent’s family room TV.  “Maria Butina, Suspected Secret Agent, Used Sex in Covert Plan, Prosecutors Say,” the New York Times wrote.6  “The Russian accused of using sex, lies and guns to infiltrate US politics,” CNN reported. 7  “How Russia’s Mariia Butina Allegedly Used Sex to “Infiltrate” the Republican Party and NRA,” said Slate.8  “Who is Maria Butina? Accused Russian spy allegedly offered sex for power,” USA Today wrote.9  “Russian spy offered sex for role in ‘special interest’ group: feds,” said the New York Post.10  “Maria Butina, 29, . . . offered sex . . . “in exchange for a position within a special interest organization,” the Washington Post wrote.11 6 New York Times, available at https://www.nytimes.com/2018/07/18/us/politics/maria-butinarussia-espionage.html (last visited Aug. 24, 2018). 7 CNN, available at https://www.cnn.com/2018/07/19/politics/maria-butina-paul-ericksonrussian-sex-lies-guns/index.html (last visited Aug. 24, 2018). 8 Slate, available at https://slate.com/news-and-politics/2018/07/mariia-butina-nra-republicanparty-russian-used-sex-to-manipulate-filings-say.html (last visited Aug. 24, 2018). 9 USA Today, available at https://www.usatoday.com/story/news/nation-now/2018/07/19/mariabutina-accused-russian-spy-who-allegedly-offered-sex-power/799333002/ (last visited Aug. 24, 2018). 10 New York Post, available at https://nypost.com/2018/07/18/russian-spy-offered-sex-for-rolein-special-interest-group-feds/ (last visited Aug. 24, 2018). 11 Washington Post, available at https://www.washingtonpost.com/local/public-safety/allegedrussian-agent-maria-butina-had-ties-to-russian-intelligence-agency-prosecutorssay/2018/07/18/a1a4042c-8a01-11e8-a345-a1bf7847b375_story.html?utm_term=.de39df8bb778 (last visited Aug. 24, 2018). 9 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 10 of 17 Defense counsel asked the government for the evidence supporting this proffer the day after it was made. In response, the government stalled for weeks, insisting on the entry of a protective order to safeguard the so-called integrity of ongoing investigations. But the evidence eventually produced shows why the government delayed. The only evidence the government relied on for its explosive claim was an excerpt from an innocuous three-year-old text exchange (attached as Exhibit 3) sent in Russia between Ms. Butina and DK, her longtime friend, assistant, and public relations man for The Right to Bear Arms gun rights group that she founded. DK, who often drove Ms. Butina’s car and thus was listed on the insurance, took the car for its annual government-required inspection and insurance renewal, and upon completion, texted (according to government translators), “I don’t know what you owe me for this insurance they put me through the wringer.” Ms. Butina jokingly replied, “Sex. Thank you so much. I have nothing else at all. Not a nickel to my name.” DK responded: “Ugh . . . ( ”—that is, with a sad face emoticon. Aside from the fact that Maria is friends with DK’s wife and child and treats DK like a brother, the reference to sex is clearly a joke, as he goes on to state that the car “is at the house, the insurance and documents are on the table at your house, winter tires are in the trunk of your car”—hardly the expected response to a serious offer of sex from a coworker. Maria continued her thanks, “[DK], thank you so much‼‼! Ask for anything . . . . . . you want.” (ellipses in original). “That they hire you?” she taunted as a good-humored reminder that he already works for her gun rights organization, as well as advertising agency, Antares. And DK volleyed back, “Think of something‼ Sex with you does not interest me. Think!” There is no indication that the two ever had sex, as the exchange was nothing more than a long-running joke between old friends. Indeed, DK would apparently tease Maria repeatedly about 10 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 11 of 17 the fact that he would never sleep with a redhead, and Mr. Erickson knew of this jovial banter and their ongoing friendship. However, more important is the fact that even under a strained reading of an obvious joke, nowhere does Ms. Butina offer anyone sex in exchange for a job (or any other advantage) for herself (or anyone else). This 2015 exchange does nothing to support the government’s claim that, in 2018, her relationship with Mr. Erickson is “duplicitous” because she was apparently willing to use sex to get a “position with a special interest organization.” (Doc. 8 at 8.) The government’s proffer is a sexist smear, using a three-year-old offhand joking reference to suggest that Ms. Butina is some kind of James Bond spy character, promiscuously using sex to advance her career. The government’s allegation should be withdrawn or stricken and certainly should not weigh in favor of detention. Even worse, the government piled on its disparaging campaign by adding that, “in papers seized by the FBI, Butina complained about living with [Mr. Erickson] and expressed disdain for continuing to cohabitate with him.” (Doc. 8 at 8.) The evidence the government relies on for support, also a text exchange from 2015 (attached as Exhibit 4), is with IS, a girlfriend of Maria’s. It is nothing more than two twenty-something girlfriends chatting about their American boyfriends, exchanging cute cat photos, and figuring out when they will next socialize. It is in this context, in response to her girlfriend’s own complaints about her boyfriend’s failure to call in three weeks (accompanied by an angry face emoji) that Maria responds that her own boyfriend (Mr. Erickson) has been “bugging the sh*t out of me with his mom” and that she has “a feeling that I am residing in a nursing home.” “Send a link to the dating app[,]” Maria encouraged her friend. Maria Butina: And a photo of your cat IS: In AppStore 11 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 12 of 17 IS: [Image of a cat] Maria Butina: Oh my, what a cutie Maria Butina: What’s his name? IS: [Photo of a cat] IS: Elizar. Meet him ) Maria Butina: [image] Maria Butina: Is that it? IS: Yeeeees Given that Mr. Erickson’s mother died in 2017 (Maria flew to the funeral) and this type of casual chitchat between friends is never intended to be public, it was particularly cruel for the government to claim it as the basis for an attack on Ms. Butina’s character or commitment to Mr. Erickson. Three-year old, offhand complaints about one’s romantic partner being too close to their mother should be out of bounds, and certainly not asserted to be proof of a “duplicitous” relationship. Ms. Butina is an attractive young woman who has been in the media spotlight for some time, and, unfortunately, sexist stereotypes about her have proliferated– suggesting without evidence that her connections with certain Americans were made through sex, rather than through her intellect demonstrated by the fact that she, before the age of 30, obtained three Master’s Degrees, founded a significant civil society organization in Russia, and achieved almost a 4.0 in her Master’s Program at American University. There may not be anything that can be done about the media and popular culture’s sexist assumptions about this young woman, but AUSA Kenerson, the United States Attorney’s Office, and the National Security Division should be held to a higher 12 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 13 of 17 standard and not fuel the sexist and misogynistic flames surrounding this case with baseless slurs and indignities. Indeed, after dismissing the government’s false and unsubstantiated claims, Maria’s good character and ties to the United States come into sharp focus. She applied for a lottery green card, meaning she intended to stay in the United States. She formed a new limited liability company, meaning she intended to deepen her roots here. She also applied for and received OPT status (essentially work authorization), not a B1/B2 visa as proffered by the government, meaning she intended to work in the United States for at least the next twelve months and not travel back and forth to Russia, as the government “mistake[nly]” claimed.12 She applied to add herself to the lease for Mr. Erickson’s apartment in South Dakota, and thus had a permanent address. Moreover, her U-Haul rental was one way to South Dakota, with theme park tickets purchased for a park along the route (attached as Exhibits 5 and 6). In short, Ms. Butina was simply like many recent graduates, leaving her student apartment in a U-Haul, degree in hand, for her next residence, where she would seek opportunities to work in the United States. IV. Proposed Conditions of Release Unconditional release is presumed. A defendant “shall” be released “on personal recognizance, or upon execution of an unsecured appearance bond . . . unless the judicial officer determines that such release will not reasonably assure the appearance of the person as required or 12 Despite learning of this “mistake” earlier, the government sat on this information, cavalierly calling it a “clerical error,” and did not disclose it to defense counsel until nearly a month later— unsurprisingly, three days after the protective order. (See Email from AUSA Kenerson to Defense (Aug. 13, 2018), attached as Exhibit 7.) This was not a clerical error. Unlike a B1/B2 visa, the mere grant of OPT status did not permit Ms. Butina to travel freely between the United States and Russia, as the government portrayed. And the fact that the government has also failed to provide any evidence to support its claim that Maria affirmatively lied on her application for a student visa should give this Court pause. (Doc. 8 at 8.) 13 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 14 of 17 will endanger the safety of any other person or the community.” 18 U.S.C. § 3142(b). However, if more is required than personal recognizance or an unsecured appearance bond, the Court must impose the “least restrictive further condition, or combination of conditions” that will reasonably assure appearance or safety. 18 U.S.C. § 3142(c)(1)(B). The government rests its fear of flight primarily on Ms. Butina’s Russian citizenship and the lack of extradition. However, if such factors alone were determinative, release would never be possible in a criminal case against a foreign national from a country with no extradition, and the statutory scheme that Congress established would be nullified completely. “In evaluating the likelihood of flight, the potential penalty has relevance,” but the stability of community ties and an extensive record may also establish reliability in meeting court obligations. The absence of flight, when flight is possible, “is an important indicator of whether a defendant is likely to appear once again.” Wood v. United States, 391 F.2d 981, 984 (D.C. Cir. 1968); Stack v. Boyle, 342 U.S. 1 (1951) (“each accused is entitled to any benefits due to his good record.”). Here, Ms. Butina has an unbroken record of not fleeing when, were the government’s allegations against her true (that she is some kind of Russian agent), she clearly would have fled: First, in February, 2017, the Daily Beast published an article about Maria, her connection to Aleksandr Torshin, her love of guns, and her activities in the United States, essentially alleging that her purpose in the United States might be to “infiltrate” American conservative political groups.13 If the government’s fanciful theory were correct, almost 18 month ago, Maria Butina was exposed, her handler identified, and her purpose in the United States published on the internet. She did not flee, visit the Russian Embassy, or make any effort to change her status as a student. 13 Tim Mak, The Kremlin and GOP Have a New Friend—and Boy, Does She Love Guns, THE DAILY BEAST (Feb. 23, 2017), available at https://www.thedailybeast.com/the-kremlin-and-gophave-a-new-friendand-boy-does-she-love-guns. 14 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 15 of 17 Second, in the fall of 2017, various congressional committees or their members, sent letters, based on media reports, seeking her testimony and even, in at least one instance, threatening a subpoena. She did not flee or discontinue her studies, but rather retained counsel, and eventually testified voluntarily before the Senate Select Committee on Intelligence, producing over 8,000 pages of documents and testifying for 8 hours. Third, on April 25, 2018, over a dozen FBI agents appeared at her door in tactical gear to search her apartment for hours. The search warrant listed 18 U.S.C. §§ 371 and 951 violations as bases for the warrant. Yet she did not flee, did not seek assistance from the Russian Embassy or any Russian contacts, but instead consulted with her American counsel about the matter.14 These facts make this case unique in that, typically, a court must predict whether a defendant will flee because their alleged criminal activity has been exposed. Here, there is no need to guess because Maria Butina has already been tested with plenty of reasons (reasons an actual Russian agent would have acted upon) to bolt for Russia, as the government fears she will do now. Maria Butina had every reason to run. She did not, but instead went to class, finished school, applied to join the American workforce, and packed up her apartment to move in with her boyfriend by renting a U-Haul truck for a one-way trip to Sioux Falls, not Moscow. And any suggestion that the government was surprised by the renting of a U-Haul truck and purchase of packing boxes (Doc. 8 at 2) is belied by the fact that defense counsel informed both AUSA Kenerson and FBI Agent Miller of the pending move to South Dakota well in advance of Ms. Butina’s arrest. (See Email from Attorney Driscoll to AUSA Kenerson (Jun. 29, 2018), attached 14 Finally, the government implies that Ms. Butina has ties to significant means, adding that “FBI surveillance over the past week has confirmed that Butina has access to funds and an intention to move money outside of the United States.” (Doc. 8 at 2.) However, this argument merits little attention because the government has neither produced personal bank records nor statements that are attributable to her to substantiate these claims. 15 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 16 of 17 as Exhibit 8; and see Email from Attorney Driscoll to FBI Agent Miller (Jul. 6, 2018), attached as Exhibit 9.) These facts weigh heavily in favor of her release. This Court has the discretionary authority to release Ms. Butina pretrial pursuant to 18 U.S.C. § 3141(c) upon the least restrictive combination of conditions necessary to reasonably assure her appearance at court. Under these circumstances, if simple release on personal recognizance and general supervision by the PSA will not satisfy the Court’s concerns about Ms. Butina’s risk of flight, the High Intensity Supervision Program (HISP) provides structured programming and close supervision for defendants, and is therefore an alternative to preventive detention. Ms. Butina is eligible for HISP, and because of the nature of this case and likely exclusion of time under the Speedy Trial Act, necessitated by the tremendous volume of information, as well as expected length of pretrial delay and pretrial detention that Ms. Butina is expected to endure, she is a great candidate for HISP. V. Conclusion For the foregoing reasons and those that the defense may present during a hearing on this matter, Defendant Maria Butina requests that she be released pending trial into the PSA High Intensity Supervision Program on a home detention basis with electronic monitoring. 16 Case 1:18-cr-00218-TSC Document 23-1 Filed 08/24/18 Page 17 of 17 Dated: August 24, 2018 Respectfully submitted, /s/Robert N. Driscoll Robert N. Driscoll (DC Bar No. 486451) McGlinchey Stafford PLLC 1275 Pennsylvania Avenue NW, Suite 420 Washington, DC 20004 Phone: (202) 802-9999 Fax: (202) 403-3870 rdriscoll@mcglinchey.com /s/Alfred D. Carry Alfred D. Carry (DC Bar No. 1011877) McGlinchey Stafford PLLC 1275 Pennsylvania Avenue NW, Suite 420 Washington, DC 20004 Phone: (202) 802-9999 Fax: (202) 330-5897 acarry@mcglinchey.com Counsel for Defendant 17 Case 1:18-cr-00218-TSC Document 23-2 Filed 08/24/18 Page 1 of 1 3?8,"? 3091 - ? 2-:"67-8=? 6 !9 8"? ,330?3#? 687? ? -"2 "7 ? 360!? 0 77?92-:"67-8-"7 ? =?8,"-6?2 896" ? 66=?8,"?74" - 0?6"74327- -0-8=?3#?46"4 6-2+?*896"? ;360!?0" !"67 ? ?, :"? ""2?46-:-0"+"!?-2?1=? 6""6?83?;36/?;-8,?1 2=?;360!?0" !"67? 2!? ?, :"? 31"?83?6" 3+2->"?8,"?86 -87?8, 8?1 /"?" ,?32"? ?79 "77 ? 6-- ? 98-2 ?"1 3!-"7?8,"?"77"28- 0? 86 -87?3#?*896"?79 "77? 2!? ? 1?86978-2+?=39?83?*68,"6?6"&2"?,"6?7/-007?73?8, 8?7,"?1 =?32"?! =? 3%"6? 30!?0" !"67,-4?;-8,-2? 38,"6? 977- ? ?; 7? , -61 2?3#?8,"? "!"6 8-32? 392 -0? 8,"?"59-: 0"28?3#? "-2+?46"7-!"28?3#?8,"? 1"6- 2? ? "2 8" ?;,"2? ?&678?1"8? 7 ? 98-2 ?-2? ? ?, :"?1"8?$;?-#? 2=?38,"6?=392+?0" !"67?;,3? ;"6"? 7?59- /?83?0" 62? 2!? ! 48?83?;-0!0=?!-%"6"28?"2:-6321"287? 2!? , 00"2+"7 ? ,"?; 7? -2863!9 "!?83?1"? 7?8,"? 392!-2+? , -61 2?3#? ? 8,"2 ?71 00?49 0- ?36+ 2-> 8-32?!"!- 8"!?83? ,"? -+,8?83? " 6? 617 ? (6? 977- 2? -8->"27 ? ?7, 6"!?,"6? "0-"#?32?8,-7?-779"? 2! ?83+"8,"6? ;-8,? "63?3#?8,"? 38,"60 2!? "2 ? -/, -0? 0 7,2-/3: ?739+,8?; =7?83?7944368?,"6?;36/ ? ,"? ; 7?$ 60"77?;,"2?38,"67?;"6"?8-1-! ? ,"?; 7? ?;31 2?-2? ?;360!?!31-2 8"!? =?1"2 ? 2?(96? =" 67 ?7,"? !!"!? ? -8->"2?1"1 "67?83?,"6?36+ 2-> 8-32 ? 98?,"6?0"+-70 8-:"?!6" 17?, :"?="8? 83? "?*00=?6" 0->"! ? ,"?-7?4 8-"28?;,"2?38,"67? 6"?6 7,? 7,"?/""47? 2?"="?32?8,"?,36->32 ? ,"? 3:-"8? 2!?23;? 977- 2?"!9 8-32 0?7=78"1?!6-007?-87?789!"287?8,3639+,0=? 2!?, 6! ? 98?-8? 2238?8" ,? 48-89!" ? 96-2+?,"6?=" 67? 7?1=? 77-78 28?-2?8,"? 977- 2? "!"6 8-32? 392 -0 ?7,"? 0" 62"!?8,"?!-%"6"2 "? "8;""2?6" !-2+?430-8- 0?7 -"2 "? 2!?6" 0?0-$?430-8- 0?7 -"2 " ? ,"? ! 48"!?59- /0=? 2!?; 7? 0"?83?0" 62?13928 -27?3#?463 "77? 2!?8,"?74" - 0?0 2+9 +"?3#? +3:"621"28? ,"6?8,-6!? )"6? 977- 2? 2!? 2+0-7, ? ,"2?1=?;360!?6 !- 00=? , 2+"!?.978?92!"6? ?=" 6? +3 ?7,"?8 9+,8?,"67"0#?="8? 238,"6?;360!? 7? 4" - 0? 77-78 28?83?1=?2";?437-8-32? 7? "498=? 3:"6236?3#?8,"? 2/?3#? 977- ? "286 0? 2/? &2 2 "?23;? " 1"?136"? "286 0?8, 2?0"+-70 8-32 ? 98?7,"?!-7 3:"6"!?8, 8?/"=?430-8- 0?8698,7? 86 27 "2!?+3:"621"28?-278-898-327? ? 2!?-28"62 8-32 0? 36!"67 ? 00?;,-0"?1 -28 -2-2+?,"6? 0" !"67,-4?3#?,"6?+92?6-+,87?36+ 2-> 8-32 ? ,"?;-00?'396-7,? 8? 3091 - ? ,"?1""87? 2!? , 617?;360!?0" !"67?"%3680"770=? 2!?7, 00?+6""8? ,"6?$003;?789!"287?;-8,?"59 0?" 7" ? , 2/?=39?(6? 327-!"6-2+?,"6? 40" 7"?8" ,?,"6? 2!?6"8962? ,"6?,31"?6" !=?(6?8,"?2"<8? , 48"6?-2? 977- 2 ? ?6"0 8-327 ? -2 "6"0= ? 0"< 2!"6? 367,-2? "498=? 3:"6236 ? 2/?3#? 977- ? 1 Case 1:18-cr-00218-TSC Document 23-3 Filed 08/24/18 Page 1 of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ase 1:18-cr-00218-TSC Document 23-3 Filed 08/24/18 Page 2 of 7 C?!;C:%!$AC<8C$%>8<%C6AC ?285%C53(C<8C"%<<%:371C6AC %?C =;;3!C"AC"%<<%:371C6AC7!<3>%C 3"%:3! C =%C?2%:%C87% <23:$C8&C <2%C =;;3!7C989=5!<387C C!7$C!55C9853<3#!5 C6%$3!C!7$C"=;37%;;C!=<28:3<3%; C53>%$ C 8C!/%:C1:!$=!<371C?3<2C !;<%:;C %1:%%;C37C 9853<3#!5C ;#3%7#%C!7$C <%!#2371 C C;85$C 6AC "=;37%;;C !7$C 68>%$C <8C 8;#8? C C #:%!<%$C !C 7%?C 9="53#C :%5!<387;C #869!7AC 37C 8;#8? C !55C ?235%C #87#%7<:!<371C 87C %@9!7$371C 2%C 312%:AC =;;3!7C;%:C C6%6"%:; C %371C#2!3:6!7C8&C<2%C9="53#C8:1!73B!<387 C C18!;%C;984%7C!"8=%C <2!%:;3%C 37C <2%C =;;3!7C %$%:!<387 C C "%53%>%C <2!%C <2!%7C "311%:C:85%C37C6!37%C <2!%:AC ?3<237C <2%3:C 7!<387;C ?3<2C 5%@!7$%:C C %7$371C ;%:&$86C37C C!7$C 37#857C%7$371C;5!>%:AC37C C !5C37C"8<2C7!<387; C<2%3:C #58;%C#8::%;987$%7#%C#:%!<%$C$39586!<3#C:%5!<387;C<2!% C AC 1%7%:!<387C 2!;C !C 1:%!!5C!7$C37<8C<2%C0<=:% C!7$C C?!7!:$C?355C13>%C6%C<2%C"%; #JPDLO FRP@ Case 1:18-cr-00218-TSC Document +DUYDUG *UDGXDWH 6FKRRO RI $UWV DQG 6FLHQFHV 7XH $0 +DUYDUG *6$6 $SSOLFDWLRQ 6XEPLWWHG 23-3 Filed 08/24/18 Page 3 of 7 'HDU 0DULD %XWLQD #JPDLO FRP@ Case 1:18-cr-00218-TSC Document 23-3 Filed 08/24/18 +DUYDUG *UDGXDWH 6FKRRO RI $UWV DQG 6FLHQFHV :HG $0 2QOLQH 5HFRPPHQGDWLRQ 6XEPLWWHG IRU +DUYDUG *UDGXDWH 6FKRRO 2QOLQH $SSOLFDWLRQ Page 4 of 7 'H D U 0D ULD %XWLQD 7KLV H PD LO LV WR OH W \RX NQRZ WKD W D Q RQOLQH UH FRPPH QGD WLRQ KD V EH H Q V XEPLWWH G E\ $OH [D QGH U 7RUV KLQ IRU \RXU D SSOLFD WLRQ WR +D UYD UG *UD GXD WH 6 FKRRO RI $UWV D QG 6 FLH 7KD QN \RX *UD GXD WH 6 FKRRO $GPLV V LRQV 2IILFH )URP 6HQW 6XEMHFW Case 1:18-cr-00218-TSC 6DW $0 +DUYDUG 5((&$ 6N\SH ,QWHUYLHZ 6LJQ 8S Document 23-3 Filed 08/24/18 Page 5 of 7 Greetings! Thank you for your application to the REECA Master’s Program at Harvard. As part of the application process, our director of studies, , would like to conduct a brief interview with you. She has set aside the following blocks of time for this purpose (all times listed are Eastern Standard Time): Monday, January 30: 12 noon – 1pm, 3:30pm – 5pm Tuesday, January 31: 10:30am – 4:40pm I realize that this is short notice, but I hope that you will be able to find a time that works for you. Each slot is just 10 minutes, so the conversation will be brief. If you have the bandwidth, video is preferred, but we recognize that this may not be possible. To facilitate the interview process, please send a Skype contact request to avacroux well ahead of your appointment. Please sign up for an individual appointment on the Doodle poll at the link below. http://doodle.com/poll Note: by signing up for a slot, you have reserved that appointment. To edit your response, simply follow the link again, and click on the pencil icon to edit your response. If you are not available or do not have internet access during the times listed, please let me know. Thank you! -Student Programs Officer Davis Center for Russian and Eurasian Studies t: Case Document 23-3 Filed 08/24/18 Page 6 of 7 From: Maria Butina [-ngailcom] on behalf of Maria Butina Sent: Friday, January 212017 PM To: Erickson Paul Subject: Fwd: Harvard REECA Skype Interview Sign-Up Best regards, Maria Butina ?(celli Havana nepeaapecoaaHi-ioro coo6u4eHna: OT: fas.harvard.edu> Aa'ra: 27 2017 19:57:18 GMT-5 Tema: Harvard REECA Skype Interview Sign-Up Greetings! Thank you for your application to the REECA Master's Program at Harvard. As part of the application process, our director of studies,_ would like to conduct a brief interview with you. She has set aside the following blocks of time for this purpose [all times listed are Eastern Standard Time]: Monday, January 30: 12 noon 1pm, 3:30pm 5pm Tuesday, January 31: 10:30am 4:40pm I realize that this is short notice, but I hope that you will be able to find a time that works for you. Each slot is just 10 minutes, so the conversation will be brief. If you have the bandwidth, video is preferred, but we recognize that this may not be possible. To facilitate the interview process, please send a Skype contact request to avacroux well ahead of your appointment. Please sign up for an individual appointment on the Doodle poll at the link below. .mtadmsdiesemisetw? Note: by signing up for a slot, you have reserved that appointment. To edit your response, simply follow the link again, and click on the pencil icon to edit your response. If you are not available or do not have internet access during the times listed, please let me know. Thank you! Case Document 23-3 Filed 08/24/18 Page 7 of 7 StudEnt Programs OffiCEr Case Document 23-4 Filed 08/24/18 Page 1 of 1 UNCLASSIFIED +79 Local User 8/26/2015 01:33:27 PM I don?t know what you owe me for this insurance they put me through the wringer. Local User 8/26/2015 01:33:46 PM Sex. Local User 8/26/2015 01 :33:51 PM Thank you so much. Local User +79 8/26/2015 01:34:04 PM I have nothing else at all. Not a nickel to my name. +79_ Local User 8/26/2015 01:37:19 PM +79 Local User 8/26/2015 02:18:52 PM The ?mvshina?[sic, read ?car?] is at the house, the insurance and documents are on the table at your house, winter tires are in the truck of the car! Local User +79_ 8/26/2015 04:09:37 PM thank you so much! Local User +79_ 8/26/2015 04:09:44 PM Ask for Local User +79_ 8/26/2015 04:09:49 PM . .you want. Local User +79_ 8/26/2015 04:09:57 PM That they hire you? +79 Local User 8/26/2015 04:13:39 PM Think of something! Sex with you does not interest me. Think! UNCLASSIFIED 1 USAO_Discovery_005770 Case Document 23-5 Filed 08/24/18 Page 1 of 7 UNCLASSIFIED Conversation (iMessage: +79-Chat) Participants (3) (owner) Mariya Butina +79- (owner) Mariya Butina Conversation Mariya Butina let?s go have fun with Read: 8/19/2015 7:06:24 AM Delivered: 8/ 19/2015 7:06:06 AM 8/19/2015 7:06:06 AM 1s What kind of proposition is this ?rst thing in the morning? Are you drunk? Read: 8/19/2015 7:07:17 AM 8/19/2015 7:07:04 AM Mariya Butina Bored. So there. Read: 8/ 19/2015 7:08:16 AM Delivered: 8/ 19/2015 7:07:22 AM 8/19/2015 7:07:22 AM Is? Got you. Come over for lunch, would you like to? Read: 8/19/2015 7:14:43 AM 8/19/2015 7:08:35 AM Mariya Butina I can?t((. Thursday evening?! Read: 8/ 19/2015 7:15:04 AM Delivered: 8/ 19/2015 7:15:57 AM 8/19/2015 7:14:56 AM UNCLASSIFIED 1 USAO_Discovery_005760 Case Document 23-5 Filed 08/24/18 Page 2 of 7 UNCLASSIFIED Mariya Butina Oh. Shit. There is a gathering there. Lunchtime on Thursday. Read: 8/19/2015 7:15:11 AM Delivered: 8/19/2015 7:15:11 AM 8/19/2015 7:15:11 AM Is? I am going home on Thursday evening. I will come on Sun. In the meantime, look for guys) Read: 8/19/2015 7:15:46 AM 8/19/2015 7:15:46 AM Mariya Butina How is it going with yours! Read: 8/ 19/2015 7:17:09 AM Delivered: 8/ 19/2015 7:17:09 AM 8/19/2015 7:17:09 AM Mariya Butina 17 Read: 8/ 19/2015 7:17:11 AM Delivered: 8/ 19/2015 7:17:11 AM 8/19/2015 7:17:11 AM Is? Nohow. 3 weeks of silence. The hell with him! [angry face emoji] Read: 8/19/2015 7:18:04 AM 8/19/2015 7:17:46 AM Mariya Butina It?s even worse in my case. He?s been bugging the shit out of me with his mom Read: 8/19/2015 7:18:29 AM Delivered: 8/ 19/2015 7:18:21 AM 8/19/2015 7:18:20 AM Mariya Butina I have a feeling that I am residing in a nursing home Read: 8/19/2015 7:18:32 AM Delivered: 8/19/2015 7:18:31 AM UNCLASSIFIED 2 USAO_Discovery_005761 Case Document 23-5 Filed 08/24/18 Page 3 of 7 UNCLASSIFIED 8119/2015 7:13:30 AM (UPC-HI) Mariya Butina Read: 81'191?2015 7:18:35 AM Delivered: 8f19f2015 7:13:35 AM 8/19f2015 7:18:35 AM UNCLASSIFIED 3 USAO_Discovery_005762 Case Document 23-5 Filed 08/24/18 Page 4 of 7 UNCLASSIFIED Mariya Butina Send a link to the dating app Read: 8/31/2015 1:18:36 PM Delivered: 8/31/2015 1:18:22 PM 8/19/2015 1:18:22 PM Is - Tinder Read: 8/31/2015 1:18:48 PM 8/31/2015 1:18:43 PM Mariya Butina And a photo of your cat Read: 8/31/2015 1:18:53 PM Delivered: 8/31/2015 1:18:52 PM 8/31/2015 1:18:48 PM Is In AppStore Read: 8/31/2015 1:18:53 PM 8/31/2015 1:18:52 PM Is [Image of a cat] 8/31/2015 1:19:36 PM Mariya Butina Oh my, what a cutie Read: 8/31/2015 1:20:44 PM Delivered: 8/31/2015 1:20:20 PM 8/31/2015 1:20:05 PM Mariya Butina What?s his name? Read: 8/31/2015 10:20:46 PM Delivered: 8/31/2015 1:20:45 PM UNCLASSIFIED 4 USAO_Discovery_005763 Case Document 23-5 Filed 08/24/18 Page 5 of 7 UNCLASSIFIED 18- [Photo of a cat] 8/31/2015 1:20:51 PM Is Elizar. Meet him 8/31/2015 1:21:02 PM Mariya Butina [image] Read: 8/31/2015 1:21:34 PM Delivered: 8/31/2015 1:21:16 PM 8/31/2015 1:21:00 PM Mariya Butina Is that it? Read: 8/31/2015 1:21:34 PM Delivered: 8/31/2015 1:21:24 PM 8/31/2015 1:21:02 PM 1s? Read: 8/31/2015 1:21:53 PM 8/31/2015 1:21:52 PM Is? Download. Read: 8/31/2015 1:21:05 PM There are lots of foreigners there, and they are the ones most engaged, ours are such slackasses( Read: 8/31/2015 1:22:57 PM 8/31/2015 1:22:48 PM Mariya Butina It is asking for acebook. In other words everyone will know that I am there? UNCLASSIFIED 5 USAO_Discovery_005764 Case Document 23-5 Filed 08/24/18 Page 6 of 7 UNCLASSIFIED Read: 8/31/2015 1:24:51 PM Delivered: 8/31/2015 1:23:57 PM 8/31/2015 1:23:54 PM IS No Read: 8/31/2015 1:24:56 PM 8/31/2015 1:24:55 PM Is? They will not Read: 8/31/2015 1:25:06 PM 8/31/2015 1:24:58 PM (urc+0) 1'5 It is asking for this for identi?cation purposes, that you in fact exist Read: 8/31/2015 1:25:22 PM 8/31/2015 1:25:18 PM Is? It is not going to post anything Read: 8/31/2015 1:25:47 PM 8/31/2015 1:25:29 PM Mariya Butina So it is only searching for those within a radius? Read: 8/31/2015 1:27:42 PM Delivered: 8/31/2015 1:27:41 PM 8/31/2015 1:27:38 PM Is - No, how you give parameters. Read: 8/31/2015 1:28:12 PM 8/31/2015 1:28:11 PM Is? UNCLASSIFIED 6 Case Document 23-5 Filed 08/24/18 Page 7 of 7 UNCLASSIFIED Look in settings. Read: 3819015 1:28:21 PM 88112015 1:23:13 PM (mam) UNCLASSIFIED 7 USAO_Discovery_005766 2018 Paul Amount paid to date: $0.00 -- .. Rental equ?pment cen?rmation Cas_e Page 1 of 1 ereriResewatgen con?rmation - 23316473 warm $53.99;? Eeyeezxurid? -- 1 (Wm-e3 mg (W. Save time at the counter with Express "?n?Line emcee, and experience a?e??ng Made EasierTM on your own personal page This is arse the place to go is View your reservation, make changes as needed and ieam about e?x?r usefui features. Pick up Sunday, Juiy1572018 :7 .. .- ?mum?? 8" U-Hau! Moving 3: Storage of Capital Hill 26 St NE Fe'ashington, DC 20002 {202} 289-5480 {(4:23 1st We) Hate: This Iocaiien is a preference only. Includes up (0 5 days and 1587 miles Item 10? iruck Sa?move?a Additienai rental items Item Quantity U?iity Do?y . 1 Tetaidue - 5, 4'1 9 .5: :57 Drop off Friday, Jufy 20, 2018 U?Haui Moving Storage of Sioux Falls 923 11111 St Sioux Fails. SD 57104 {605) 33%?53 (East of 1-29 on 12?: Before Minnesata} Note: 11135 location is a preference onfy. Tot-a! $1,398.09 $112119 -- Rate Total ma mm em 1H Case Document 513.93} Pit??tied 08/24/18 Page 1 of 4 VOUCHER - NOT FOR RESALE Cedar Point Cedar Point Burrs-IA.? we?" 01419418936697865279 2018 ALL DAY DINING TYPE: Ail-Day Dining PRICE: $34.15 TICKET #01419418936697865279 PURCHASER: Erickson. Paul #?guzgi?? PURCHASE 3 PAYMENT METHOD: 'Visa DESCRIPTION Add food to your fun all day long! Enjoy an entree and side as often as every 90 minutes during 1 visit during the 2018 season. Valid at participating locations at Cedar Point and Cedar Point Shores Waterpark. Drinks are not included. Does not include park admission. TERMS OF USE AND REFUNDS Valid for the entitlementis} and ponds) speci?ed during the 2013 Season only. Not valid in conjunction with a INSTRUCTIONS Redeem this original Voucher at participating locations throughout Cedar Point and Cedar Point Shores Waterpark for an all-day dining wristband. This Voucher contains a unique barcode valid for UNLIMITED USE FOR ONE MAIN AND ONE SIDE EVERY 90 MINUTES. This Voucher becomes INVALID once scanned and may not be re-used. Unauthorized use or duplication is strictly prohibited and will result in revocation without refund and ejection of the individual attempting to enter. in the event that a duplicate ticket appears. the Park reserves the right to refuse entry to all ticket holders. my other discount offer. Not for resale. Cedar Fair reserves the right to refuse admission and control occupancy. Holder assumes all risk of personal injury and loss of property. agrees to the posted conditions of usage. rider safety guidelines and ride admission policies and grants Cedar Fair permission to use hisl'her photograph or video image in any advertising and promotion without payment to holder. No rain checks. refunds. exchanges or replacemenm if lost or stolen. Not valid for separately ticketed events. special events or park buyouts. Some attractions require an additional charge. Height and physical restrictions may apply on some rides. Please visit the park's Website or call the park to con?rm operating dates and hours and learn more about park rules, ride admission polides and guest assistance guidelines. Unauthon?zed resale of this ticket is prohibited. NOT FOR RESALE El El IF. El 01419418936697865279 EX ?Dbl? 4M. Case Document S?j-aiPiE?iled 08/24/18 Page 2 of 4 VOUCHER - NOT FOR RESALE MARIA Cedar Point "is .l?ll . Cedar Point 01419418938697865273 2018 ALL DAY DINING TYPE: All-Day Dining PURCHASER: Erickson, Paul PRICE: $34.15 CONFIRMATION 67377458 Isa?t. ?mm TICKET #01419418938597865273 (. PURC 5E PAYMENT METHOD: Visa DESCRIPTION INSTRUCTIONS Add food to your fun all day long! Enjoy an entree and side as often as every 90 minutes during Redeem this original Voucher at participating locations throughout Cedar Point and Cedar Point 1 visit dun'ng the 2018 season. Valid at participating locations at Cedar Point and Cedar Point Shores Waterpark for an all-day dining wristband. This Voucher contains a unique barcode valid Shores Waterpark. Drinks are not included. Does not include park admission. for UNLIMITED USE FOR ONE MAIN AND ONE SIDE EVERY 90 MINUTES. This Voucher becomes INVALID once scanned and may not be re-used. Unauthorized use or duplication is strictly prohibited and will result in revocation without refund and ejection of the individual attempting to enter. In the event that a duplicate ticket appears. the Park reserves the right to refuse entry to all ticket holders. TERMS OF USE AND REFUNDS Valid for the entitlement(s) and speci?ed during the 2013 Season only. Not valid in conjunction with any other discount otter. Notfor resale. Cedar Fair reserves the right to refuse admission and control oempancy. Holder assumes all risk of personal injury and loss of property. agrees to the posted conditions of usage. rider safety guidelines and ride admission policies and grants Cedar Fair permission to use hislher photograph or video image in any advertising and promotion without payment to holder. No rain checks. refunds, exchanges or replacements if lost or stolen. Not valid for separately ticketed events. special events or park buyouts. Some attractions require an additional charge. Height and physical restrictions may apply on some rides. Please visit the park's website or call the park to oon?n'n operating dates and hours and learn more about park rules, ride admission policies and guest assistance guidelines. Unauthorized resale of this ticket is prohibited. NOT FOR RESALE EIEI 01 419418938697865273 3/4 Case Document 3% ?5i POIFniled 08/24/18 Page 3 of 4 FAST LANE PLUS and ADMISSION COMBO - NOT FOR RESALE Cedar Point Cedar Point . 01419418940697865820 ADMISSION FAST LANE PLUS COMBO valid Date:Tuesday, arm/20%: TYPE: Admission wiFast Lane Plus PRICE: $150.86 TICKET #01419418940697865820 PURCHASER: Erickson. Paul CONFIRMATION 67377458 agiligEi?e?wl 3,201 '8 PAYMENT DESCRIPTION Valid for one admission and one Fast Lane Plus wristband for anyone age 3 or older. Valid on the date chosen. Limited availability. Enjoy the ultimate Cedar Point experience with Fast Lane Plus! Includes all Fast Lane attractions plus unlimited rides on Steel Vengeance. Valravn. Maverick, Top Thrill Dragster and GateKeeper! TERMS OF USE AND REFUNDS INSTRUCTIONS Valid only on the date printed on this ticket. This is your Fast Lane voucher. Present this voucher at any ticket sales window [prior to entering the park) to receive your Fast Lane wristband or at any Fast Lane sales location inside the park. This is also your admission ticket. Present this original E- '?cket at any Cedar Point entrance gate for admission. This E??l'rcket becomes INVALID once scanned for admission and Fast Lane wristband and may not be re-used. Unauthorized use or duplication is strictly prohibited and will result in revocation without refund and ejection of the individual attempting to enter. In the event that a duplicate ticket appears, the Park reserves the right to refuse entry to all ticket holders. GET INTO CEDAR POINT AN HOUR EARLY WITH AN OVERNIGHT Cedar Point Resorts offer the closest accommodations to the amusement park, and resort guests enjoy getting In ONE HOUR EARLY to challenge select rides. Visit cedarpoint.com or call 419-627-2106 for further details. Valid for the entitlement(s) and park(s) speci?ed dudng the 2018 Season Only. Not valid in conjunction with any other discount offer. Not for resale. Cedar Fair reserves the right to refuse admission and control occupancy. Holder assumes all risk of pemonal injury and loss of property. agrees to the posted conditions of usage. rider safety guidelines and ride admission policies and grants Cedar Fair permission to use hislher photograph or video image in any advertising and promotion without payment to holder. No rain checks. refunds. exchanges or replacements if lost or stolen. Not valid for separately ticketed events. special events or park buyouts. Some attractions require an additional charge. Height and physical restrictions may apply on some rides. Please visit the park's website or call the park to con?rm operating dates and hours and learn moreparkihng about park rules, ride admission policies and guest assistance guidelines. UNAUTHORIZED RESALE OF THIS TICKET IS PROHIBITED. NOT FOR RESALE . 01419418940697865320 9&pToken=95f6f99655f6875128b91 e0f02af440f&. .. 214 _7i241201 8 Cedar Point Case Document 23-7 Filed 08/24/18 Page 4 Of 4 FAST LANE PLUS and ADMISSION COMBO - NOT FOR RESALE Cedar Point Cedar Point if 0141941894269?865834 LANE PLUS COMBO ?alid DatezTuesday, am #25153 TYPE: Admission wlFast Lane Plus PRICE: $150.96 TICKET #0141941894269?865834 PURCHASER: Erickson. Paul rogues Puif?i-mss PAYMENT METHOD: Visa DESCRIPTION Valid for one admission and one Fast Lane Plus wristband for anyone age 3 or older. Valid on the date chosen. Limited availability. Enjoy the ultimate Cedar Point experience with Fast Lane Plus! Includes all Fast Lane attractions plus unlimited rides on Steel Vengeance. Valravn, Maverick. Top Thrill Dragster and GateKeeper! TERMS OF USE AND REFUNDS INSTRUCTIONS Valid only on the date printed on this ticket. This is your Fast Lane voucher. Present this voucher at any ticket sales window (prior to entering the park) to receive your Fast Lane wristband or at any Fast Lane sales location inside the park. This is also your admission ticket. Present this original E- '?cket at any Cedar Point entrance gate for admission. This E-Ticket becomes INVALID once scanned for admission and Fast Lane wristband and may not be re-used. Unauthorized use or duplication is strictly prohibited and will result in revocation without refund and ejection of the individual attempting to enter. In the event that a duplicate ticket appears. the Park reserves the right to refuse entry to all ticket holders. GET INTO CEDAR POINT AN HOUR EARLY WITH AN OVERNIGHT Cedar Point Resorts offer the closest accommodations to the amusement park. and resort guests enjoy get?ng in ONE HOUR EARLY to challenge select rides. Visit cedarpointcom or call 419-627-2106 for further detaiis. Valid for the entitlement(s) and park(s) speci?ed during the 2013 Season Only. Not valid in conjunction with any other discount Offer. Not for resale. Cedar Fair reserves the right to refuse admission and control occupancy. Holder assumes all risk of personal injury and loss of property. agrees to the posted conditions of usage. rider safety guidelines and ride admission policies and grants Cedar Fair permission to use hisiher photograph or video image in any advertising and promotion without payment to holder. No rain checks. refunds. exchanges or replacements if lost or stolen. Not valid for separately ticketed events. special events or park buyouts. Some attractions require an additional charge. Height and physical restrictions may apply on some rides. Please visit the park's website or call the park to con?rm operating dates and hours and learn moreparkihng about park rules, ride admission policies and guest assistance guidelines. UNAUTHORIZED RESALE OF THIS TICKET IS PROHIBITED. NOT FOR RESALE Eli 01419418942697865834 arfai ricp.ph p?oToken=74ab4c4t7 BebSCad 551 277fcd11 11 71 e0f02af440f&. . . 114 Case 1:18-cr-00218-TSC Document 23-8 Filed 08/24/18 Page 1 of 2 )URP 6HQW 7R &F 6XEMHFW .HQHUVRQ (ULN 86$'& (ULN .HQHUVRQ#XVGRM JRY! 0RQGD\ $XJXVW 30 'ULVFROO 5REHUW 6DXQGHUV 7KRPDV 86$'& &DUU\ $OIUHG 0DFNLH :LOO 16' -0' 3OXQNHWW 'DQLHO 7 5( 86 Y %XWLQD SURWHFWLYH RUGHU %RE $V WR WKH KDUG GULYH LW LV D JRRG QHZV EDG QHZV SURSRVLWLRQ 7KH JRRG QHZV LV WKDW WKH )%, ZDV DEOH WR LPDJH KHU HOHFWURQLFV IURP WKH -XO\ VHDUFK DV ZHOO DQG LW FDQ SXW WKRVH RQ WKLV LQLWLDO KDUG GULYH DV ZHOO 7KH EDG QHZV LV WKDW WKLV ZRXOG H[WHQG WKH DPRXQW RI WLPH LW WDNHV ± WR DERXW WZR ZHHNV , KDYH EHHQ H[SODLQHG WKH WHFKQLFDO UHDVRQV ZK\ LW VKRXOG WDNH VR ORQJ DQG FDQ UHOD\ WKHP LQ D FDOO LI \RX ZDQW ZLWK WKH FDYHDW WKDW ,¶P QRW WHFKQLFDO P\VHOI VR P\ NQRZOHGJH EDVH LV OLPLWHG ,W VKRXOG EH UHDG\ E\ $XJXVW WKRXJK WKH )%, KRSHV WR KDYH LW VRRQHU 7KH RWKHU RSWLRQ LV WR SURYLGH RQO\ WKH $SULO LPDJHV LQ WKLV LQLWLDO WUDQFKH ZKLFK ZRXOG JHW WKHP WR \RX VRRQHU EXW WKHQ ZH ZRXOG QHHG DQRWKHU KDUG GULYH IRU WKH -XO\ WUDQFKH :H NQRZ RI FRXUVH WKDW \RX DUH HDJHU WR JHW WKH PDWHULDOV :H VKRXOG EH DEOH WR SURYLGH ZLWKLQ D FRXSOH RI GD\V D GLVF FRQWDLQLQJ VFDQQHG YHUVLRQV RI WKH SK\VLFDO GRFXPHQWV VHL]HG IURP \RXU FOLHQW¶V UHVLGHQFH DV ZHOO DV WKH )%, YHUEDWLP WUDQVODWLRQV RI KHU 7ZLWWHU FKDWV :LWK UHJDUGV WR WKH PDWHULDOV XQGHUO\LQJ WKH FRPSODLQW DQG GHWHQWLRQ PHPR , ZLOO LGHQWLI\ WKRVH WRGD\ DQG DVN WKH DJHQWV WR EHJLQ SXOOLQJ FRSLHV RI WKHP VR ZH FDQ SURYLGH WKHP WR \RX VHSDUDWHO\ EHIRUH WKH KDUG GULYH ILQLVKHV FRS\LQJ %\ WKH ZD\ \RXU HPDLO UHPLQGV PH RI D FRUUHFWLRQ ,¶YH EHHQ PHDQLQJ WR PDNH VLQFH , UHFHQWO\ QRWLFHG LW ± WKH % % UHIHUHQFH IURP WKH GHWHQWLRQ PHPR LV D PLVWDNH ± VKH UHFHQWO\ DSSOLHG IRU DQ 237 H[WHQVLRQ LI WKDW¶V WKH SURSHU WHUP RI KHU ) EXW WKH XSVKRW RI WKDW²WKDW VKH FDQ WUDYHO WR DQG IURP XQGHU LW²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± REYLRXVO\ WKLV LV LPSRUWDQW WR XV $OVR JLYHQ WKDW WKH SURWHFWLYH RUGHU LV LQ SODFH FRXOG \RX SOHDVH VHQG VHSDUDWHO\ DOO WKH HYLGHQFH UHOLHG RQ LQ \RXU SURIIHU UHJDUGLQJ GHWHQWLRQ SDUWLFXODUO\ WKH DOOHJDWLRQV WKDW D 0DULD RIIHUHG WR WUDGH VH[ IRU D SRVLWLRQ ZLWK DQ RUJDQL]DWLRQ E WKDW 0DULD H[SUHVVHG GLVVDWLVIDFWLRQ ZLWK OLYLQJ ZLWK 3DXO DQG F WKDW 0DULD DSSOLHG IRU D WRXULVW YLVD % % PDLOWR (ULN .HQHUVRQ#XVGRM JRY@ 6HQW 7KXUVGD\ -XQH 30 7R 'ULVFROO 5REHUW 6XEMHFW 5( %XWLQD EŽƚŚŝŶŐ ŶĞǁ ƚŽ ƌĞƉŽƌƚ &ƌŽŵ͗ ƌŝƐĐŽůů͕ ZŽďĞƌƚ фƌĚƌŝƐĐŽůůΛŵĐŐůŝŶĐŚĞLJ͘ĐŽŵх ^ĞŶƚ͗ dŚƵƌƐĚĂLJ͕ :ƵŶĞ Ϯϭ͕ ϮϬϭϴ Ϯ͗ϯϯ WD dŽ͗ <ĞŶĞƌƐŽŶ͕ ƌŝŬ ;h^ Ϳ ф <ĞŶĞƌƐŽŶΛƵƐĂ͘ĚŽũ͘ŐŽǀх ^ƵďũĞĐƚ͗ ZĞ͗ ƵƚŝŶĂ ŶLJƚŚŝŶŐ ƐŚĂŬŝŶŐ ǁŝƚŚ ƚŚŝƐ͍ ^ĞŶƚ ĨƌŽŵ ŵLJ ŝWŚŽŶĞ KŶ DĂLJ ϭϳ͕ ϮϬϭϴ͕ Ăƚ ϭϭ͗ϰϲ D͕ ƌŝƐĐŽůů͕ ZŽďĞƌƚ фƌĚƌŝƐĐŽůůΛŵĐŐůŝŶĐŚĞLJ͘ĐŽŵх ǁƌŽƚĞ͗ ƌŝŬ͗ 'ƵĞƐƐŝŶŐ Ăƚ LJŽƵƌ ĞŵĂŝů͕ LJŽƵƌ ǀŵĂŝů ŝƐ ĨƵůů͘ ŽƵůĚ LJŽƵ ĐĂůů ŵĞ͍ / ǁĂŶƚĞĚ ƚŽ ƚĂůŬ Ă ůŝƚƚůĞ ĂďŽƵƚ ƚŚĞ :ƵĚŝĐŝĂƌLJ DŝŶŽƌŝƚLJ ZĞƉŽƌƚ ŵĞŶƚŝŽŶŝŶŐ DĂƌŝĂ ƚŚĂƚ ĐĂŵĞ ŽƵƚ LJĞƐƚĞƌĚĂLJ͘ Žď 8 Case 1:18-cr-00218-TSC Document 23-9 Filed 08/24/18 Page 2 of 2 Robert Neil Driscoll GLUHFW ID[ HPDLO UGULVFROO#PFJOLQFKH\ FRP RIILFH 3HQQV\OYDQLD $YHQXH 1: 6XLWH _ :DVKLQJWRQ '& ® LPDJH JLI! ELR _ YFDUG _ ZZZ PFJOLQFKH\ FRP _ ZZZ FDIDODZEORJ FRP $ODEDPD &DOLIRUQLD )ORULGD /RXLVLDQD 0LVVLVVLSSL 1HZ Ğƚ ŵĞ ŬŶŽǁ ǁŚĂƚ ŝƚƐ ůŽŽŬŝŶŐ ůŝŬĞ ĨŽƌ LJŽƵ͘ &ƌŽŵ͗ DŝůůĞƌ͕ DĂƚƚŚĞǁ :͘ ;DWͿ ;& /Ϳ фD:DŝůůĞƌΛĨďŝ͘ŐŽǀх ^ĞŶƚ͗ dŚƵƌƐĚĂLJ͕ :ƵŶĞ Ϯϴ͕ ϮϬϭϴ ϱ͗Ϯϴ WD dŽ͗ ƌŝƐĐŽůů͕ ZŽďĞƌƚ фƌĚƌŝƐĐŽůůΛŵĐŐůŝŶĐŚĞLJ͘ĐŽŵх ^ƵďũĞĐƚ͗ ,ĞLJ Žď͕ :ƵƐƚ ĐŚĞĐŬŝŶŐ ŝŶ ŽŶ DĂƌŝĂ͘ / ŬŶŽǁ ƐŚĞ ŝƐ ŽƵƚ ŽĨ ƐĐŚŽŽů ďLJ ŶŽǁ ƐŽ / ǁĂƐ ǁŽŶĚĞƌŝŶŐ ŝĨ ƐŚĞ ǁĂƐ Ɛƚŝůů ĂƌŽƵŶĚ ĨŽƌ Ă ƉŽƐƐŝďůĞ ƉƌŽĨĨĞƌ ŽŶ ƵŐƵƐƚ ϯƌĚ͘ DĂƚƚ Ͳ 9 Case 1:18-cr-00218-TSC Document 23-11 Filed 08/24/18 Page 1 of 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, v. MARIIA BUTINA, a/k/a MARIA BUTINA, Defendant. ) ) ) ) ) ) ) ) ) Case No.: 1:18-cr-218 (TSC) ORDER Upon consideration of Defendant’s Motion for Bond Review, the memorandum in support filed therewith, and other evidence before the Court, it is this _____ day of _________________, 2018 hereby ORDERED that Defendant Maria Butina be released pending trial into the Pretrial Services Agency High Intensity Supervision Program on a home detention basis with electronic monitoring. SO ORDERED. Judge Chutkan Copies to: All counsel of record 1