Case 1:18-cr-00850-ALC Document 2 Filed 11/29/18 Page 1 of 10

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

- - -

x
INFORMATION

UNITED STATES OF AMERICA
18 Cr .
- v. -

50

8

MICHAEL COHEN ,
Defendant.

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The Special Counsel charges :
Background

The Defendant
1.

From in or around 2007 through in or around January 2017 ,

MICHAEL COHEN ,

the defendant ,

was an attorney and employee of a
COHEN held

Manhattan - based real estate company (the " Company " ) .

the title of " Executive Vice President " and "Special Counsel " to
the owner of the Company (" Individual 1 " ) .
False Statements to the U. S . Congress
2.

On or about January 13 ,

2017 ,

the U.S.

Senate Select

Committee on Intelligence ( " SSCI " ) announced that it would conduct
an investigation into Russian election interference and possible
links

between Russia

campaigns .

On

Representatives

or

and

individuals

about

Permanent

January
Select

associated with political
25 ,

the

2017 ,

Committee

on

House

of

Intelligence

("HPSCI " ) announced that it also was conducting an investigation

 Case 1:18-cr-00850-ALC Document 2 Filed 11/29/18 Page 2 of 10

into

Russian

election

interference

and

possible

links

between

Russia and individuals associated with political campaigns .
3.

On or about August

28 ,

201 7 ,

COHEN caused a two - page
The letter

letter to be sent on his behalf to SSCI and HPSCI .

addressed his efforts at the Company to pursue a branded property
in

Moscow ,

Russia

(the

" Moscow

COHEN

Project " ) .

stated

the

purpose of the letter was " to provide the Cammi ttee with additional
information

regarding

the

proposal ,"

referring

to

the

Moscow

Project .
4.

In the letter to SSCI and HP SCI ,

COHEN knowingly and

deliberately made the following false representations :
a . The Moscow Project ended in January 20 1 6 and was not
discussed

extensively

with

others

in

the

Company.

" The proposal was under consideration at the [Company]
from September 2015 until the end of January 2016 .
By the end of January 2016 ,

I

determined that

the

proposal was not feasible for a variety of business
reasons and should not be pursued further .
my business determinations ,

the

[Company]

the [Moscow Project] proposal .

Based on
abandoned

To the best of

my knowledge , [Individual l] was never in contact with
anyone

about

occasions .

this

proposal

other

than me

on three

I did not ask or brief [Individual
2

 Case 1:18-cr-00850-ALC Document 2 Filed 11/29/18 Page 3 of 10

l] , or any of his family , before I made the decision
to terminate further work on the proposal ."
b . COHEN never agreed to travel to Russia in connection
with the Moscow Project and "never considered" asking

"I primarily

Individual 1 to travel for the project.

communicated

with

company .

through

intermediary ,

[Individual 2] .

the
a

Moscow - based

development

U. S .

third - party

citizen

[ Individual 2]

constantly asked me to travel to Moscow as part of
his

efforts

proposal .

I

to push

forward

the

discussion of

the

ultimately determined that the proposal

was not feasible and never agreed to make a trip to
Russia .

Despite overtures by [Individual 2] , I

never considered asking

[Individual l]

to travel to

Russia in connection with this proposal ."
c . COHEN did not recall any Russian government response
or contact about the Moscow Project.

2016 ,

[Individual 2]

" In mid - January

suggested that I

send an email

to [Russian Official l] , the Press Secretary for the
President of Russia , since the proposal would require
approvals within the Russian government that had not
been issued .

Those permissions were never provided .

I decided to abandon the proposal less than two weeks
3

 Case 1:18-cr-00850-ALC Document 2 Filed 11/29/18 Page 4 of 10

later

for

business

reasons

response to my email ,

and

do

not

recall

any

nor any other contacts by me

with [Russian Official l] or other Russian government
officials about the proposal ."
5.

On or about September 19 , 2017 , COHEN was scheduled to

appear before SSCI accompanied by counsel .
released to the public ,

COHEN stated ,

the rejected proposal to build a
Moscow

that

was

terminated

In prepared remarks

"I assume we will discuss

[Company-branded]

in January of

2016 ;

property in

which occurred

before the Iowa caucus and months before the very first primary.
This was solely a real estate deal and nothing more .
my job .

I was doing

I would ask that the two - page statement about the Moscow

proposal that I sent to the Committee in August be incorporated
into and attached to this transcript. "
6.

On or about October 25 ,

2017 ,

COHEN gave testimony to

SSCI , which included testimony about the Moscow Project consistent
with his prepared remarks and his two - page statement .
7.

In truth and in fact ,

and as COHEN well knew ,

COHEN ' s

representations about the Moscow Project he made to SSCI and HPSCI
were false and misleading .

COHEN made the false statements to (1)

minimize links between the Moscow Project and Individual 1 and (2)
give the false

impression that the Moscow Project ended before

" the Iowa caucus and .

the very first primary ," in hopes of
4

 Case 1:18-cr-00850-ALC Document 2 Filed 11/29/18 Page 5 of 10

limiting the ongoing Russia investigations.
conceal or minimize through his

false

COHEN attempted to

statements

the

following

facts :
a . The Moscow Project was discussed multiple times within

Instead ,

the Company and did not end in January 2016.

as

late

as

Individual

approximately

2

discussed

June

efforts

2016 ,
to

COHEN

obtain

Russian

governmental approval for the Moscow Project .
discussed
Project

with

occasions
briefed

the

status

and

Individual

COHEN

family

1

claimed
members

progress

to
of

on

more

the

of
than

the
the

Committee ,

Individual

1

and

COHEN
Moscow
three
and

within

he
the

Company about the project .
b. COHEN agreed to travel to Russia in connection with
the Moscow Project and took steps in contemplation of
Individual l ' s possible travel to Russia.

COHEN and

Individual

occasions

2

discussed

on

multiple

traveling to Russia to pursue the Moscow Project .
i .

COHEN asked Individual 1 about the possibility
of

Individual

1

traveling

to

Russia

in

connection with the Moscow Project , and asked a
senior

campaign

official

business travel to Russia.
5

about

potential

 Case 1:18-cr-00850-ALC Document 2 Filed 11/29/18 Page 6 of 10

ii .

On or about May 4 , 2016 , Individual 2 wrote to
COHEN, "I had a chat with Moscow .

ASSUMING the

trip does happen the question is before or after
the convention

. Obviously the pre - meeting

trip (you only) can happen anytime you want but
the
said

big guys where

2

I

would

responded ,

[sic]

confirm

"My

trip

and

the question .
revert ."

before

I

COHEN

Cleveland.

[Individual l] once he becomes the nominee after
the convention. "
iii.

On or about May 5, 2016 , Individual 2 followed
up with COHEN and wrote , "[Russian Official l]
would like to invite you as his guest to the
St .

Petersburg Forum which is Russia ' s

it ' s June 16- 19.

Davos

He wants to meet there with

you and possibly introduce you to either

[the

President of Russia] or [the Prime Minister of
Russia] , as they are not sure if 1 or both will
be there.

He said anything you want to

discuss including dates and subjects are on the
table to discuss. "

6

 Case 1:18-cr-00850-ALC Document 2 Filed 11/29/18 Page 7 of 10

iv .

On or about May

6,

2016 ,

Individual

2 asked

COHEN to confirm those dates would work for him
to travel .
v.

From

on

COHEN wrote back , "Works for me ."

or

Individual

about

June

9

to

June

14 ,

2016 ,

sent numerous messages to COHEN

2

about the travel , including forms for COHEN to
complete.

However , on or about June 14 , 2016 ,

COHEN met

Individual

in

2

the

lobby

of

the

Company ' s headquarters to inform Individual 2
he would not be traveling at that time .
c . COHEN did recall that in or around January 2016, COHEN
received

a

response

from

the

office

of

Russian

Official 1, the Press Secretary for the President of
Russia,

and spoke to a member of that office about

the Moscow Project .
i.

On or about
Russian

Official

assistance
Project .

January

in

14 ,
l's

2016 ,

COHEN

office

connection

with

On or about January 16 ,

emailed

asking
the

for

Moscow

2016 , COHEN

emailed Russian Official l ' s office again , said
he

was

Russian

trying

to

official ,

reach
and

another

asked

spoke English to contact him .
7

for

high - level
someone

who

 Case 1:18-cr-00850-ALC Document 2 Filed 11/29/18 Page 8 of 10

ii.

On or about January 20 , 2016 , COHEN received an
email

from the personal assistant to

Official 1

("Assistant

1" ) ,

Russian

stating that

she

had been trying to reach COHEN and requesting
that

he

call

her

using

a

Moscow-based phone

number she provided .
lll .

Shortly after receiving the email , COHEN called
Assistant 1 and spoke to her for approximately
20 minutes.
position

at

On that call , COHEN described his
the

Company

and

outlined

the

proposed Moscow Project , including the Russian
development company with which the Company had
partnered .

COHEN

moving the project

requested
forward ,

assistance

in

both in securing

land to build the proposed tower and financing
the construction .

Assistant 1 asked detailed

questions and took notes , stating that she would
follow up with others in Russia.
iv .

The day after COHEN ' s

call with Assistant 1 ,

Individual 2 contacted him , asking for a call .
Individual 2 wrote to COHEN ,

"It ' s about

President of Russia] they called today. "

8

[the

 Case 1:18-cr-00850-ALC Document 2 Filed 11/29/18 Page 9 of 10

COUNT 1
(False Statements)

8.

Paragraphs

1

through

7

of

this

Information

are

re -

alleged and incorporated by reference as if fully set forth herein.
9.

On or about August 28 , 2017 , the defendant MICHAEL COHEN ,

in the District of Columbia and elsewhere , in a matter within the
jurisdiction of the legislative branch of the Government of the
United States ,

knowingly and willfully made a materially false ,

fictitious , and fraudulent statement and representation ,

to wit ,

COHEN caused to be submitted a written statement to SSCI containing
material
false

false

statements

statements

about

about
the

the

timing

Moscow
of

Project ,

the

Moscow

including
Project ,

discussions with people in the Company and in Russia about the
Moscow Project ,

and contemplated travel to Russia in connection

with the Moscow Project .
(Title 18 , United States Code , Section 1001 (a) (2) . )

Special Counsel

9

 Case 1:18-cr-00850-ALC Document 2 Filed 11/29/18 Page 10 of 10

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA
-

v.

-

MICHAEL COHEN,
Defendant.

INFORMATION

18 Cr.

ROBERT S . MUELLER , III
SPECIAL COUNSEL