Case Document 75 Filed 05/16/19 Page 1 of 7 ATTACHMENT 1 Case Document 75 Filed 05/16/19 Page 2 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. Crim. No. 17-232 (EGS) MICHAEL T. Sentencing: December 18, 2018 Defendant. ADDENDUM TO GOVERNMENTS MEMORANDUM IN AID OF SENTENCING This Addendum to the Government?s Memorandum in Aid of Sentencing describes the signi?cance and usefulness of defendant Michael T. assistance to the government, and the timeliness of that assistance. As described herein, the defendant?s assistance to the government was substantial and merits consideration at sentencing. 1. Signi?cance and Usefulness of the Defendant?s Assistance The defendant has assisted with several ongoing investigations: a criminal investigation in the Eastern District of Virginia. that is likely to result in criminal charges, the Special Counsel?s Office?s investigation concerning any links or coordination between the Russian government and individuals associated with the campaign of President Donald J. Trump, As part of his assistance with these investigations, the defendant participated in 19 interviews with the ECG or attorneys from other Department of. Justice of?ces, provided documents and communications? While this addendum seeks to provide a comprehensive description of the benefit the Case Document 75 Filed 05/16/19 Page 3 of 7 govermnent has thus. far obtained from the defeadant?e substantial assistance, some of that benefit may not be fully realized at this time because the investigations ?11 which he has provided assistance are ongoing. The defendant and the govez'tmleat agree that sentencing at this time is 11011ethe].ess appropriate because suf?cient infomlation is available to allow the Court to determine the import of the defe1.1da11t?e aesistailce to his senteace. A. Eastern District of. Virginia Criminal Investigation The defendaat has provided substantial assistance in a criminal investigation of Bijan Ra?ekian, Ekim Alptekia_ beiag- conducted by the US Attomey?s Of?ce for the Eastern District of Virginia. and the National Security Division for violating the Foreign. Age-ate Registration Act acting as agents of a foreign government: without aotifying the Attorney General (18 USC. 951), and making materially false statements to the federal govemment (18 U.S.C. 1001). Part of the investigation concerned work that the defeadaat, Ra?elciaa, and their company performed with Alptekin for the principal bene?t. of the Republic of Turkey (?Turkey project?). On December 1., 2.017, as part. of his Statement of Offense, the defendant: stipulated and agreed that he violated. FARA by tnaking materially falee statements in the documents that Ra?eleian. and he filed with about that work for the Republic of Turkey. See Statement of Offeaee, matted States v. Flam-1, No. l7werw232 (DBL). Dec. l, 2017) (Doc. 4) at 1] 5. The SCO subsequently referred that investigation to EDVA and. N833. According to prosecutors in EDVA and NSDF the defendant?s cooperation and assistance have beet} critical to their investigation. The EDVA and N813 prosecutors have interviewed the defendant -2- Case Document 75 Filed 05/16/19 Page 4 of 7 B. The Special Counsel?s Office?s Investigation The defendant has also assisted with the SCO investigation concerning links or coordination between the Russian government and individuals associated with the Trump campaign. See Of?ce of the Deputy Att?y Gen, Order No. 3915-20 1. 7, Appointment of Special Counsel to Investigate Russian Interference with the 2016 Presidentiai Election and Related Matters, May 17, 2017 Order?). The defendant assisted the investigation on a range of issues, including interactions between individuals in the Presidential Transition Team and Russia, discussions within the campaign about WikiLeaks? release of emaiis,,and potential efforts to interfere with the investigation. A non-exhaustive summary of the relevant information the defendant provided is described below to aid the Court?s assessment of. the defendant?s assistance. I i. Interactions Between. the Transition and Russia The defendant provided firsthand information about the content and context of interactions between the transition team and Russian government of?cials. For example, after the election, the defendant communicated with the Russian ambassador to the United States as a -3- Case Document 75 Filed 05/16/19 Page 5 of 7 representative of the transition team on two sensitive matters: a United Nations Security Council vote on a resolution calling for Israel to cease settlement activities in Palestinian territory and the Obama Administration?s imposition of sanctions and other measures on Russia for interfering in the 20i6 election. Several senior members of the transition team publicly repeated false information conveyed to them by the defendant about communications between him and the Russian ambassador regarding the sanctions. The defendant provided details on which transition team officials he conferred with before communicating with the Russian ambassador, who on the transition team was aware the communications were occurring, and who on the transition team was informed about what he and the Russian ambassador discussed. it. WikiLeaks Release of Emails During the Presidential Campaign The defendant also provided useful information concerning discussions within the campaign about WikiLeaks? release of emails. WikiLeaks is an important subject of the investigation because a Russian intelligence service used WikiLeaks to release emails the intelligence service stole during the 2016 presidential campaign. On July 22, 2016, WiltiLeaks released emails stolen from the Democratic National Committee. Beginning on October 2016, WikiLeaks released emails stolen from John Podesta, the chairman of Hillary Clinton?s 2016 presidential campaign. The defendant relayed to the government statements made in 2016 by senior campaign of?cials about WikiLeaks to which only a select few people were privy. For example, the defendant recalled conversations with senior campaign officials after the release of the Podesta emails, during which the prospect of reaching out to WikiLeaks was discussed. Potential ?yj?orls to Interfere with. the Special Counsel ?3 O?ice ?3 Investigation The defendant assisted the investigation into potential efforts to interfere with or Case 'Document 75 Filed 05/16/19 Page 6 of 7 otherwise obstruct its investigation. See ODAG Order (authorizing the Special Counsel to investigate ?any other matters within the scope of 28 C.F.R. The defendant informed the government of multiple instances, both before and after his guilty plea, where either he or his attorneys received communications from persons connected to the Administration or Congress that could have affected both his willingness to cooperate and the completeness of that cooperation. The defendant even provided a voicemail recording of one such communication. In some of those instances, the SCO was unaware of the outreach until being alerted to it by the defendant. II. Timeliness of the Defendant?s Assistance The usefulness of the defendant?s assistance is connected to its timeliness. The defendant began providing information to the government not long after the government ?rst sought his cooperation. His early cooperation was particularly valuable because he was one of the few peeple with long-term and firsthand insight regarding events and issues under investigation by the SCO. Additionally, the defendant?s decision to plead guilty and cooperate likely affected the decisions of related ?rsthand witnesses to be forthcoming with the SCO and cooperate. In some instances, individuals whom the SCO interviewed before the defendant?s guilty plea provided -5- Case Document 75 Filed 05/16/19 Page 7 of 7 additional, relevant details about their knowledge of key events after his cooperation became public. By: Respectfully submitted, ROBERT S. MUELLER, 111 Special Counsel Brandon L. Van Grack Zainab N. Ahmad Senior Assistant Special Counsels Special Counsel?s Of?ce US. Department of Justice 950 Avenue NW Washington, DC. 20530 (202) 616-0800