ReedSmith Suite 1000 East Tower Washington, D.C. 20005-3373 A. Scott Bolden +1 202 414 9200 Direct Phone: +1 202 414 9266 Fax +1 202 414 9299 Email: abolden@reedsmith.com reedsmith_com April 23, 2019 By Hand Delivery The Honorable William P. Barr Attorney General US. Department of Justice 950 Avenue, NW Washington, DC 20530?0001 In re: Giorgi he Mueller Investigation and Report Dear Mr. Attorney General: Attached herein, please accept a modi?ed version of the letter sent to you yesterday regarding my client Giorgi Accordingly, please discard the prior letter dated, April 22, 2019, and use the letter attached for future reference. Many thanks for your time and attention to this matter. Sincerely, I am, a Sarawak? A. Scott Bolden Reed Smith LLP Enclosure ABU DHABI ATHENS AUSTIN 0 BEIJING CENTURY CITY 0 CHICAGO DUBAI FRANKFURT HONG KONG HOUSTON KAZAKHSTAN 9 LONDON 9 LOS ANGELES 9 MIAMI MUNICH NEW YORK PARIS PHILADELPHIA PITTSBURGH PRINCETON RICHMOND 9 SAN FRANCISCO SHANGHAI SILICON VALLEY SINGAPORE TYSONS 0 WASHINGTON, D.C. WILMINGTON 041231?2019 1:52 PM Reed smith 1301 Street. NW. Suite 1000 - East Tower Washington, DC. 20005-3373 A. Scott Bolden +1 202 414 9200 Direct Phone: +1 202 414 9266 Fax +1 202 414 9299 Email: abolden@reedsmith.com reedsmith com April 23, 2019 By Hand Delivery The Honorable William P. Barr Attorney General US. Department of Justice 950 Avenue, NW Washington, DC 20530-0001 In re: Giorgi Mueller Investigation and Report Dear Mr. Attorney General: This ?rm represents Giorgi (?Mr in connection with the above?referenced matter. Please direct all further communications regarding his case to the undersigned. In this regard, I write to address certain glaring inaccuracies and misrepresentations concerning Mr. set forth in the Report on the Investigation into Russian Interference in the 2016 Presidential Election, submitted by Special Counsel Robert S. Mueller, pursuant to 28 C.F.R. 600.8(0) (hereinafter, ?Mueller Report?) on March 22, 2019. I refer speci?cally to the wholly misleading and salacious account of communications between Messrs. Michael Cohen and about alleged ?compromising? tapes of President Donald J. Trump when he was a private citizen, described in footnote 112 on pages 27 and 28 of the Volume II of the Mueller Report (hereinafter, ?Footnote 112?). On behalf of Mr. we strongly demand that a full and immediate retraction of these falsehoods should be issued forthwith to restore his good name. In the alternative, we would strongly urge your of?ce to include this letter and exhibits contained herein, to the Mueller ?le and/or any appendixes to the Mueller Report. Accordingly, we submit the following objections to Footnote 112: I. Allegation Mr. is a ?Russian businessman.? Rebuttal Mr. was born in the former Soviet Republic of Georgia. Since 1991, Georgia an independent country, is an important US. ally in the region and has had a strained relationship with Russia due to the latter?s military invasion in 2008 and unlawful occupation of 20% of Georgian territory. The mere suggestion that Mr. is cavorting with Russian associates belittles his personal identity and integrity, tarnishes his reputation and impedes his ability to do business in his native country. ABU DHABI ATHENS 9 AUSTIN 9 BEIJING CENTURY CITY 9 CHICAGO DUBAI FRANKFURT HONG KONG 0 HOUSTON KAZAKHSTAN 0 LONDON 0 LOS ANGELES MIAMI MUNICH NEW YORK PARIS PHILADELPHIA PITTSBURGH PRINCETON RICHMOND 9 SAN FRANCISCO SHANGHAI SILICON VALLEY SINGAPORE TYSONS 9 WASHINGTON, D.C. WILMINGTON 0412312019 3:33 PM The Honorable William P. Barr April 23, 2019 Page 2 Moreover, Mr. has been an upstanding American citizen since 2017 and a permanent resident for 23 years. He fully cooperated with the Mueller probe?wmeeting with prosecutors on two separate occasions and appearing before the Special Prosecutor?s grand jury. He dedicated considerable time and ?nancial resources ensuring that his testimony was complete and truthful. Casting him as a ?Russian businessman? implies that he participated in a conspiracy to collude or interfere with the 2016 US. presidential is patently false. The transcript of grand jury testimony will clearly show that my client made it abundantly clearand went to great to clearly explain his Georgian and American allegiances when the prosecuting attorney attempted to paint him as ?Russian businessman?. The fact that after Mr. extensive clarifying testimony the Special Counsel nevertheless decided to describe my client as same in the ?nal Report released to the public is just incredulous. II. Allegation ?On October 30, 201.6, Michael Cohen received a text from Russian businessman Giorgi that said, ?Stopped flow of tapes from Russia but not sure if there?s anything else. Just so you know. Rebuttal Mr. is a successful businessman who takes pride in his heritage by supporting the economic stability and prosperity of his natiVe country of Georgia and invests a great deal of time and resources in strengthening the US Georgian relationships. It is in this context that he met Mr. Cohen in 2011, when the Trump Organization expressed interest in building a residential Trump Towers in Batumi, Georgia. This relationship continued in 2015, when the failed Trump Towers Moscow development was first proposed. After negotiating these transactions, Messrs. Cohen and developed a rapport. The excerpts of texts cited in Footnote 112 conveys the friendly banter between business colleagues. In stark black and white, the isolated texts are suggestive of nefarious undertakings and, as such, defame Mr. character. Viewing the texts in their entirety against the backdrop of Messrs. Cohen and cordial relationship places them in their proper context. Also, ?Stopping the ?ow? gives the impression that you are referencing the alleged salacious content of the alleged acts viewed on the tapes. To the contrary, this was colloquialism by Mr. indicating that there was nothing to the rumors of the tapes, and that he did not believe there were any tapes, nor had he seen what was on the tapes, even if they existed. Although this may have been a poor choice of words, he was trying to convey the same to Mr. Cohen. Furthermore, the word ?some? has been intentionally removed from the Footnote; the original text message reads ?some tapes? and the word ?some? is crucial as it establishes the fact that Mr. had no knowledge of the tapes? content. The footnote also omits the dialogue that follows, which is key to understanding Mr. intentions. See Attachment 1. The Honorable William P. Barr ReedSlnith April 23, 2019 Page 3 Stopped ?ow of some tapes from Russia but not sure if there?s anything else. Just so know. Cohen: Tapes of what? Not sure of the content but person in Moscow was bragging [that he] had tapes from Russia trip. Will try to dial you tomorrow but wanted to be aware. I?m sure it?s not a big deal but there are lots of stupid people. Cohen: You have no idea. I do trust me.1 Both the Federal Bureau of Investigations and attorneys that authored the Mueller Report are in possession of the entire series of texts between Messrs. Cohen and but they spliced the dialogue to produce the ugly insinuations and allegations of Footnote 112 to attract publicity?all the while impugning Mr. character. They are also aware of what ?Stop the meant coming from my client to Mr. Cohen, but have failed to explain this in the subject Report. This must be corrected immediately before any further reprehensible damage to my client?s character and reputation can occur. Alleg ation said ?tapes? referred to compromising tapes of Trump rumored to be held by persons associated with the Russian real estate conglomerate Crocus Group, which had helped host the 2013 Miss Universe Pageant in Russia.? Rebuttal The texts that were excised from the Mueller Report clearly indicate that Mr. does not have direct knowledge of what was said at the party in Moscow, which he did not attend. Mr. also does not know and cannot identify who allegedly made the statements about the tapes. Furthermore, Mr. has never seen the tapes and cannot opine on whether they actually exist. All of the above was communicated to Mueller?s investigative team on multiple occasions by Mr. In a similar vein, Mr. has not had contact or dealings with the Crocus Group in 14 years, although he considers Crocus a reputable and successful business group. It is inaccurately stated that Mr. had a licensing deal with the Croous Group. 1 See attached Exhibit A. The Honorable William P. Barr April 23, 2019 Page 4 IV. Allegation said he was told the tapes were fake, but he did not communicate that to Cohen.? Rebuttal The suggestion that Mr. tried to curry favor with Mr. Cohen, the Trump Organization and possibly President Trump himself by allegedly texting that he had ?stopped the ?ow of tapes from Russia??l