Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 1 of 47
AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT
for the
District of Columbia
In the Matter of the Search of
(Rriejly describe the property to be searched
or identify the person by name and address)

INFORMATION ASSOCIATED WITH THREE
ACCOUNTS STORED AT PREMISES
CONTROLLED BY FACEBOOK

)
)
)

)
)
)

Case: 1:18-sc-02570
Assigned To: Howell, Beryl A.
Assign. Date : 8/2/2018
Description: Search & Seizure Warrant

SEARCH AND SEIZURE WARRANT
To:

Any authorized law enforcement officer

An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Northern
District of
California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):
See Attachment B

YOU ARE COMMANDED to execute this warrant on or before
August 15, 2018
(nottoexceed /4 days)
~ in the daytime 6:00 a.m. to 10:00 p.m.
CJ at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by Jaw and promptly return this warrant and inventory to
Hon. Beryl A. Howell, Chief U.S. District Judge
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, wiJJ be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) l'.:J until, the facts justifying, the later specific date of

Date and time issued:

City and state :

Washington, DC

Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 2 of 47
AO 93 (Rev. I 1/13) Search and Seizure Warrant (Page 2)

Return

Case No.:

Date and time warrant executed:

Copy of warrant and inventory left with:

Inventory made in the presence of:
Inventory of the property taken and name of any person(s) seized:

11

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer 's signature

PrinJed name and title

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 3 of 47

ATTACHMENT A
Property to be Searched

This warrant applies to information associated with the following Facebook accounts,
which are stored at premises owned, maintained, controlled, or operated by Facebook, lnc.
("Facebook"), a company headquartered at 1 Hacker Way, Menlo Park, California 94025:

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 4 of 47

ATTACHMENT B
I.

Information to be disclosed by Facebook

To the extent that the infonnation described in Attachment A is within the possession,
custody, or control of Facebook Inc. ("Face book"), including any messages, records, files, logs, or
information that have been deleted but are still available to Facebook, or have been preserved
pursuant to a request made under 18 U.S.C. § 2703(f), Facebook is required to disclose the
following infonnation to the government for each user ID listed in Attachment A:
(a)

All contact and personal identifying infonnation, including full name, user
identification number, birth date, gender, contact e-mail addresses, physical address
(including city, state, and zip code), telephone numbers, screen names, websites,
and other personal identifiers.

(b)

All activity logs for the account and all other documents showing the user's posts
and other Facebook activities;

(c)

All photos and videos uploaded by that user ID and all photos and videos uploaded
by any user that have that user tagged in them, including Exchangeable Image File
("EXIF") data and any other metadata associated with those photos and videos;

(d)

All profile information; News Feed information; status updates; videos,
photographs, articles, and other items; Notes; Wall postings; friend lists, including
the friends' Facebook user identification numbers; groups and networks of which
the user is a member, including the groups' Facebook group identification numbers;
future and past event postings; rejected "Friend" requests; comments; gifts; pokes;
tags; and information about the user's access and use of Facebook applications;

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 5 of 47

(e)

All other records of communications and messages made or received by the user,
including all private messages, chat history, video calling history, and pending
"Friend" requests;

(f)

All records relating to machine cookies;

(g)

All "check ins" and other location information, including records of the user's
latitude and longitude;

(h)

All IP logs, including all records of the IP addresses that logged into the account;

(i)

All records of the account's usage of the "Like" feature, including all Facebook
posts and all non-Facebook webpages and content that the user has "liked";

(j)

All information about the Facebook pages that the account is or was a "fan" of;

(k)

All past and present lists of friends created by the account;

(l)

All records of Facebook searches performed by the account;

(m)

All information about the user's access and use ofFacebook Marketplace;

(n)

The types of service utilized by the user;

(o)

The length of service (including start date) and the means and source of any
payments associated with the service (including any credit card or bank account
number);

(p)

Group identification numbers; a list of users currently registered to the group; a list
of users who like the page; group or page contact information, including all contact
information for the creator and/or administrator of the group and a PDF of the
current status of the group profile page;

(q)

All past and present Admins for the group;

(r)

The "Creator" of the group;

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 6 of 47

(s)

All privacy settings and other account settings, including privacy settings for
individual Facebook posts and activities, and all records showing which Facebook
users have been blocked by the account;

(t)

All records pertaining to communications between Facebook and any person
regarding the user or the user's Facebook account, including contacts with support
services and records of actions taken;

(u)

All records related to advertisements and advertising conducted through the
accounts, including advertisements purchased, advertising parameters (search
terms, groups, geographic areas) selected and queried.

II.

Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S .C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1030 (unauthorized access of a protected computer); 18
U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud),
and 52 U.S.C. § 30121 (foreign contributions ban) for the period from June 2015 to the present,
including:
a.

All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications
with persons or entities associated with WikiLeaks, including but not limited to
Julian Assange, or communications regarding disinformation, denial, dissembling
or other obfuscation about knowledge of, or access to, hacked material;

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 7 of 47

b.

All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone,

Jerome

Corsi, Julian Assange, and individual associated with WikiLeaks and/or with the
Trump Campaign;
c.

Communications, records, documents, and other files related to any expenditure,
independent expenditure, or disbursement for an electioneering communication;

d.

Records of any funds or benefits disbursed by or offered on behalf of any foreign
government, foreign officials, foreign entities, foreign persons, or foreign
principals;

e.

Communications, records, documents, and other files that reveal efforts by any
person to conduct activities on behalf of, for the benefit of, or at the direction of
any foreign government, foreign officials, foreign entities, foreign persons, or
foreign principals;

f.

Evidence indicating how and when the account was accessed or used, to determine
the geographic and chronological context of account access, use, and events relating
to the crimes under investigation and to the account owner;

g.

Evidence indicating the account user's state of mind as it relates to the crimes under
investigation;

h.

The source of all funds used to purchase advertisements or make other expenditures
or disbursements in these accounts;

1.

The identity of the person(s) who created or used the account, including records
that help reveal the whereabouts of such person(s);

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 8 of 47

J.

The identity of any non-U.S. person(s)- including records that help reveal the
whereabouts of the person(s)-who made any expenditure, independent
expenditure, or disbursement for an electioneering communication; and

k.

The identity of any person(s)-including records that help reveal the whereabouts
of the person(s)-who communicated with the account about any matters relating
to activities conducted by on behalf of, for the benefit of, or at the direction of any
foreign government, foreign officials, foreign entities, foreign persons, or foreign
principals.

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 AO 106 (Rev . 04/10)
Application
for a Search Warrant
Case
1:19-mc-00029-CRC

Document 29-12 Filed 04/28/20 Page 9 of 47

UNITED STATES DISTRICT COURT
for the

AUG - 2 2018

District of Columbia

/lark, U.S. District & Bankruptcy
ourts for the District of Cil/!!mb/a

In the Matter of the Search of

)

(Br iefly describe the p roperty to be Searched
or ;aentify 1he person by name and address)

Case: 1: 18-sc-02570
Ass!gned To : Howell, Beryl A.
Assign. Date : 8/2/2018
Description: Search & Seizure Warrant

)
)

INFORMATION ASSOCIATED WITH THREE ACCOUNTS
STORED AT PREMISES CONTROLLED BY FACEBOOK

)
,

APPLICATION FOR A SEARCH WARRANT
I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A

located in the

Northern

- - - -- - - -

District of

California
, there is now concealed (identify the
------

- - -- --

person or describe the property to be seized):

See Attachment B

The basis for the search under Fed. R. Crim. P. 41 ( c) is (check one or more):

~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
rif property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:

Offense Description

Code Section
18 U.S.C. §§ 2, 3, 4, 371
18 u.s.c. §§ 1030, 1343, 1349
52 U.S.C. § 30121

Aiding & Abetting, Accessory after the Fact, Misprision of a Felony, Conspiracy
Unauthorized Access of Protected Computer, Wire Fraud, Wire Fraud Conspiracy
Foreign Contribution Ban

The application is based on these facts:
See attached Affidavit.
~ Continued on the attached sheet.

0 Delayed notice of
days (give exact ending date if more than 30 days:
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

) is requested

~___-/
Reviewed by AUSA/SAUSA:
!Kyle R. Freeny (ASC)

Applicant's signature

Andrew Mitchell, Special Agent, FBI
Printed name and title

Sworn to before me and signed in my presence.
Date:
City and state: Washington, D.C.

Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title

·

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 10 of 47

I
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
IN THE MATTER OF THE SEARCH OF
INFORMATION ASSOCIATED WITH
THREE FACEBOOK ACCOUNTS
STORED AT PREMISES CONTROLLED
BY FACEBOOK, INC.

AUG - 2 2018
Clerk, U.S. District & Bankruptc
Courts for the District of Co/umbra

Case: 1:18-sc- 02570
Ass!gned To: Howell, Beryl A
Assign. Date: 8/2/2o 18
Description : Search & Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:
INTRODUCTION AND AGENT BACKGROUND

1.

I make this affidavit in support of an application for a search warrant for

information associated with the Facebook accounts associated with the following user IDs:

which are stored at premises owned, maintained, controlled or operated by Facebook Inc., a social
networking company headquartered in Menlo Park, California ("Facebook"). The information to
be disclosed by Facebook and searched by the government is described in the following paragraphs
and in Attachments A and B.
2.

I am a Special Agent with the Federal Bureau of Investigation (FBI), and have

been since 2011. As a Special Agent of the FBI, I have received training and experience in
investigating criminal and national security matters.
3.

The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 11 of 47

intended to show merely that there is sufficient probable cause for the requested warrant and
does not set forth all of my knowledge about this matter.
4.

Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Accounts contain evidence, fruits, or
instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision ofa felony), 18
U.S.C. § 1030 (unauthorized access of a protected computer), 18 U.S.C. § 1343 (wire fraud), and
18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud), and 52 U.S.C.
§ 30121(a)(l)(C) (foreign expenditure ban). There also is probable cause to search the
information described in Attachment A for evidence, contraband, fruits, and/or instrumentalities
of the Subject Offenses, further described in Attachment B.

JURISDICTION
5.

This Court has jurisdiction to issue the requested warrant because it is "a court of

competentjurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &
(c)(l)(A). Specifically, the Court is "a district court of the United States (including a magistrate
judge of such a court) . .. that has jurisdiction over the offense being investigated." 18 U.S.C.
§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

PROBABLE CAUSE
A. Background on Relevant Individuals

i. Roger STONE
6.

Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of
Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 12 of 47

relationship with the Campaign thereafter, STONE maintained his support for Trump and
continued to make media appearances in support of Trump's presidential campaign. As
described further below, STONE also maintained contact with individuals employed by the
Campaign, including then-campaign chairman Paul MANAFORT and deputy chairman Rick
GATES.
ii. Jerome CORSI

7.

Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According
to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"
for the website "World Net Daily" a/k/a "WNO.com." CORSI has also written a number of
books regarding Democratic presidential candidates. As described further below, CORSI was in
contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of
hacked information by WikiLeaks, and appears to have obtained information regarding
upcoming disclosures which he relayed to STONE.

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 13 of 47

B.

Russian Government-Backed Hacking Activity During the 2016 Presidential
Election
9.

On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,
"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC
assessed the following:
[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Government developed a clear preference for President-elect Trump.
10.

In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts
as a "Russian messaging strategy that blends covert intelligence operations-such as cyber
activity-with overt efforts by Russian Government agencies, state-funded media, third-party
intermediaries, and paid social media users or 'trolls.'"
11.

With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential
election, including targets associated with both major US political parties." Further, "[i]n July
2015, Russian intelligence gained access to _Democratic National Committee (DNC) networks
and maintained that access until at least June 2016." The USIC attributed these cyber activities
to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted
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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 14 of 47

in the compromise of the personal e-mail accounts of Democratic Party officials and political
figures. By May, the GRU had exfiltrated large volumes of data from the DNC."
12.

With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to
release US victim data obtained in cyber operations publicly and in exclusives to media outlets."
13.

Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.
14.

The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at
least November 1, 2016.
15.

For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late
September, these individuals stole data from these cloud-based computers by creating backups of
, the DNC's cloud-based systems using the cloud provider's own technology. The individuals
used three new accounts with the same cloud computing service to move the "snapshots" to
those accounts.
16.

On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These
emails were later post on DCLeaks.
17.

On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering
elections in numerous Florida counties.

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 15 of 47

18.

On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016
presidential election, including conspiracy to comrriit authorized access to protected computers.
(Case No. 1: 18-cr-OO 125).
C. STONE's Public Interactions with Guccifer 2.0 and WikiLeaks
19.

On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to
Russian government actors and the media reported on the announcement. On June 15, 2016, the
persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated
on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part
of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."
In that post, Guccifer 2.0 also began releasing hacked DNC documents.
20.

On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.
21.

On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem
to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer
2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article
and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and
why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise
decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would
see for themselves how the Democrats had rigged the game."
22.

On August 8, 2016, STONE addressed the Southwest Broward Republican

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 16 of 47

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian
ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"
aimed at the Hillary Clinton presidential campaign. Specifically, Stone was asked: "With regard
to the October surprise, what would be your forecast on that given what Julian Assange has
intimated he's going to do?" STONE responded: "Well, it could be any number of things. I
actually have communicated with AS SAN GE. I believe the next tranche of his documents
pertain to the Clinton Foundation but there's no telling what the October surprise may be." A
few days later, STONE clarified that while he was not personally in touch with ASSANGE, he
had a close friend who served as an intermediary.
23.

On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone
numbers and email addresses from the files of the DCCC.
24.

On August 13, 2016, STONE posted a tweet using @RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,
Guccifer 2.0's Twitter account was reinstated.
25.

On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r
great man. please tell me if I can help u anyhow. it would be a great pleasure to me."
26.

On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated
that MANAFORT had worked with a Washi1;1gton D.C.-based lobbying firms to influence U.S.
policy toward Ukraine.
27.

On August 21, 2016, using@RogerJStoneJR, STONE tweeted stating: "Trust me,

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 17 of 47

it will soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview
that same day, STONE reiterated that because of the work of a "'mutual acquaintance' of both
his and [Assange], the public [could] expect to see much more from the exiled whistleblower in
the form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think
Julian Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat.
I believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the
Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."
28.

On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly
basis fairly soon. And that of course will answer the question as to what exactly what was erased
on that email server."
29.

On Saturday, October 1, 2016, using @RogerJStoneJr, STONE tweeted,

"Wednesday @ HillaryClinton is done. #WikiLeaks."
30.

On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement ASSANGE had scheduled for the next day from the balcony
of the Ecuadoran Embassy in London. On the day of the ASSANGE announcement-which was
part of WikiLeaks' 10-year anniversary celebration - STONE told Infowars that his intermediary
described this release as the "mother load." On October 5, 2016, STONE used @RogerJStoneJr
to tweet: "Payload coming. #Lockthemup."
31.

On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in
which Mr. Trump had made a series of lewd remarks.
32.

Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 18 of 47

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link
to approximately 2,050 emails that had been hacked from John Podesta's personal email account.
33.

WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, John Podesta-referring back to STONE's
August 21, 2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable
assumption to - or at least a reasonable conclusion - that [STONE] had advanced warning [of the
release of his emails] and the Trump campaign had advanced warning about what Assange was
going to do. I think there's at least a reasonable belief that [Assange] may have passed this
information on to [STONE]." Commenting to the NBC News, STONE indicated that he had
never met or spoken with Assange, saying that "we have a mutual friend who's traveled to
London several times, and everything I know is through that channel of communications. I'm not
implying I have any influence with him or that I have advanced knowledge of the specifics of
what he is going to do. I do believe he has all of the e-mails that Hu'ma Abedin and Cheryl Mills,
the Clinton aides, thought were deleted. I hear that through my emissary."
34.

On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel
communication during the Campaign between STONE and WikiLeaks. The same article quoted
STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of
charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing
or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the
limited things I did predict (Oct disclosures) all came true."

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE
35.

On October 13, 2016, while WikiLeaks was in the midst ofreleasing the hacked

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 19 of 47

Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter
account @wikileaks. 1 The latter account is the official Twitter account of WikiLeaks and has
been described as such by numerous news reports. The message read: "Since I was all over
national TV, cable and print defending WikiLeaks and assange against the claim that you are
Russian agents and debunking the false charges of sexual assault as trumped up bs you may want
to rexamine the strategy of attacking me- cordially R."
36.

Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the
impact of our publications. Don't go there if you don't want us to correct you."
37.

On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your
operation leaks like a sieve. You need to figure out who your friends are."
38.

On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"
@wikileaks immediately followed up with another message less than a minute later: "We are
now more free to communicate."
39.

In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE,

the founder of WikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged
@JulianAssange, an address associated with Julian Assange in numerous public reports, stating:
"Still nonsense. As a journalist it doesn't matter where you get information only that it is accurate
and authentic. The New York Times printed the Pentagon Papers which were indisputably stolen

1

On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
-10-

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 20 of 47

from the government and the courts ruled it was legal to do so and refused to issue an order
restraining the paper from publishing additional articles. If the US government moves on you I
will bring down the entire house of cards. With the trumped-up sexual assault charges dropped I
don't know of any crime you need to be pardoned for - best regards. R." That same day,
@JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the DoJ side
that's coming most strongly from those obsessed with taking down Trump trying to squeeze us
into a deal."
40.

On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@wikileaks, reading: "I am doing everything possible to address the issues at the highest level of
Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in this
forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE,
Forthcoming Leaks
41.

and Others Regarding

On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's

address,

On October

17, 2017, Chief Judge Beryl A. Howell issued a search warrant for one of STONE's
addresses,

. On or about December 19, 2017, Chief Judge Beryl A.

Howell issued a search warrant for

email account. On or about March 14, 2018,

Chief Judge Beryl A. Howell issued a search warrant for STONE's iCloud account. Information
recovered pursuant to those search warrants indicated the following:
42.

On or about May 15, 2016,

emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger
Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

-11-

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 21 of 47

appears to have forwarded the message to STONE at

who replied to

CORSI that, "May meet Manafort -guarantee nothing."
43.

On or about May 18, 2016, CORSI emailed STONE at

with the title, "Roger -- why don't you look this over before I send it

I believe that
CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were
waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and
was very cordial. He would look for this memo from you this afternoon."
44.

On July 25, 2016, STONE, using

sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange
[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with
Foundation, allegedly."
45.

On or about July 31, 2016, STONE, using

CORSI with the subject line, "Call me MON." The body of the email read: "
Assange[.]
Trump[.]
46.

, emailed
should see

should find Bernie [S]anders brother who called Bill a Rapist-tum him for
should find

or more proof of Bill getting kicked out."

On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at
"Word is friend in embassy plans 2 more dumps. One shortly after I'm
back. 2nd in Oct. Impact planned to be very damaging. Signs are Fox will have me on mid-Aug.
more post Ailes shakeup underway. Expect Shine to surface victor, for now. Post-DNC bump for
HRC an artifact of rigged polling. Won't last. I expect presidential campaign to get serious
starting Sept. Still in pre-season games. Time to let more than Podesta to be exposed as in bed w

-12-

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 22 of 47

enemy if they are not ready to drop HRC. That appears to be the game hackers are now about.
Would not hurt to start suggesting HRC old, memory bad, has stroke -- neither he nor she well. I
· expect that much of next dump focus, setting stage for Foundation debacle." Investigators
believe that CORSI's reference to a "friend in embassy [who] plans 2 more dumps" refers to
Julian AS SAN GE, the founder of WikiLeaks, who resided in Ecuador's London Embassy in
2016.
47.

On or about August 5, 2016,

STONE at

an associate of STONE's, emailed

The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal
Julian Assange last night."

subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet AS SAN GE.
that in 2018,

also stated

told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SAN GE. STONE told

he was joking and

had not actually met ASSANGE.
48.

On or about August 15, 2016, CORSI emailed STONE at
: "Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started
until after Labor Day. I'm in NYC this week. Jerry."
49.

On or about August 31, 2016, CORSI emailed STONE at
: "Did you get the PODESTA writeup." STONE replied "yes."

50.

On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI
investigation - tied to Ukraine Yanukovych - Panama papers reveals Podesta hired by

-13-

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 23 of 47

S [b ]erbank, Russia's largest financial institution - Podesta $$$ ties to Russia undermine Clinton
false narrative attempting to tie Trump to Putin."
51.

On or about September 6, 2016, CORSI emailed STONE at
: "Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

52.

On or about September 24, 2016,

emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have
secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about
it again today."

wrote back, "Awaiting secret file. Explosive ... Hope you are well.

Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted
about file[.]" In a subsequent meeting with investigators,

indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.
53.

On or about October 3, 2016, an associate of STONE emailed STONE at
and asked: "Assange-what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will
be out in Jan. Many scores will be settled." The associate forwarded the email to Steve
BANNON and wrote: "You should call Roger. See below. You didn't get from me." BANNON
wrote back, "I've got important stuff to worry about." The associate responded, "Well clearly he
knows what Assange has. I'd say that's important."
54.

On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that
ASSANGE would release information damaging to then-candidate Clinton, but WikiLeaks did
not make any new releases. Instead, ASSANGE promised more documents, including
information "affecting three powerful organizations in three different states, as well as, of course,

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 24 of 47

information previously referred to about the U.S. election process." ASSANGE also stated that
WikiLeaks would publish documents on various subjects every week for the next ten weeks, and
vowed that the U.S. election-related documents would all come out before Election Day.
55.

On or about October 4, 2016, CORSI messaged STONE at his iClciud account:

"Assange made a fool of himself. Has nothing or he would have released it. Tota! BS hype."
56.

That same day, BANNON emailed STONE a

"What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going
to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't
cut deal w/ clintons???" Stone replied, "Don't think so BUT his lawyer

is a big

democrat."
57.

When BANNON spoke with investigators during a voluntary proffer on February

14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE was about
WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking STONE
about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and
BANNON had been hoping for releases of damaging information that morning.
F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.
58.

According to a publicly available news article, 2 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from
a source regarding a previously unaired video of candidate Trump. According to the same
article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

2

https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trumpthen-the-race-was-on/2016/10/07/3 ld74714-8ce5-1 le6-875e-2cl bfe943b66_story.html
-15-

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 25 of 47

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,
calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."
59.

According to phone records

at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.
60.

At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.
61.

At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.
62.

At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.
63.

At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.
64.

At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.
On or about August 2, 2016, when CORSI emailed STONE on

, he

wrote, "I expect that much of next dump focus, setting stage for Foundation debacle."
65.

At approximately 6:27PM

sent STONE an email titled,

"WikiLeaks -The Podesta Emails," with a link to the newly-released Podesta emails.
Approximately ten minutes later, STONE, using

, forwarded

message to CORSI without comment. STONE does not appear to have forwarded the email to
any other individual.

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 26 of 47

G. STONE Requests to CORSI for "SOMETHING" to Post About Podesta After
STONE Is Accused of Advance Knowledge of the Leak

66.

On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed -

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty
minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T
attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job
numbers."
67.

On or about Wednesday, October 12, 2016, at approximately 8: 17 AM, STONE,

using

emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."
CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on
Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in
Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"
68.

On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI
emailed STONE at both

, with a subject line

"Podesta talking points." Attached to the email was a file labeled, "ROGER STONE podesta
talking points Oct 12 2016.docx." The "talking points" included the statement that "Podesta is at
the heart of a Russian-government money laundering operation that benefits financially Podesta
personally and the Clintons through the Clinton Foundation."
69.

CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed
CORSI back via the Hotmail Account, "Got them and used them."

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 27 of 47

70.

On or about Thursday, October 13, 2016, CORSI emailed STONE at
: "PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could
post under my by-line since I am the one under attack by Podesta and now Mook." CORSI
wrote back to STONE, "I'll give you one more like

NOBODY YET HAS THIS[:] It looks to me

skimmed maybe billions off Skolkovo -

Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once
had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's
Clinton Fund account, there's no telling how much money he laundered, or where it ended up.
Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via
Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me
SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"
71.

On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at

with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and
JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own
name." That same day, STONE posted a blog post with the title, "Russian Mafia money
laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I
have had some back-channel communications with Wikileaks I had no advance notice about the
hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post
then asked, "Just how much money did

a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through
Metcombank, a Russian regional bank owned 99.978 percent by

-18-

with the money

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 28 of 47

transferred via Deutsche Bank and Trust Company Americas in New York City, with the money
ending up in a private bank account in the Bank of America that is operated by the Clinton
Foundation?"
72.
a..:..:uuul, 'Tm

On or about October 14, 2016, CORSI sent a message to STONE at his iCloud
iu NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."
73.

On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now- before 2pm[.]" STONE responded, "Missed u - just
landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important
intel to share."
74.

On or about October 17, 2016, CORSI emailed STONE at
with the subject, "Fwd:

AS SANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email
with the header information stripped out, showing only the body text. The email read, "Yes[.] I
figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if
they move to extradite him. My guess is that he has a set of dead man files that include Hillary.
It's what they used to call a 'Mexican stand off[.]' Only hope is that if Trump speaks out to save
him[.] Otherwise he's dead anyway, once he's dropped what he has. IfHRC wins, Assange can
kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and
raised him the election."
75.

On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 29 of 47

76.

On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice of Wikileaks' hacking of Podesta' s e-mails."
STONE stated that, "I predicted that Podesta's business dealings would be exposed. I didn't hear
it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on
my website." STONE linked to the story he had asked CORSI to write for him on October 13,
2016 discussed above.
77.

On or about November 8, 2016, the United States presidential election took place.

78.

On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."
79.

On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'1? in
London. Have some interesting news for you."

-20-

 Case Document 29-12 Filed 04/28/20 Page 30 of 47

 

Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 31 of 47

I.

Statements Regarding STONE's Use of Facebook

86.

On or about Friday, May 18, 2016,

was voluntarily interviewed

by investigators from the Special Counsel's Office.

told investigators that he became

STONE's assistant in Florida in 2015, and that during the summer of 2016, he acted as STONE's
right-hand man.
87.

According to

STONE utilized the services of several individuals to

post social media content to Facebook and Twitter, and that he
instructed these individuals about what to post.

and STONE both

stated that he purchased a couple

hundred fake Facebook accounts as part of this work (including both new and existing accounts),
and that bloggers working for STONE would try to build what looked like real Facebook
accounts. 3 According to

one of the individuals who did work for STONE on

Facebook in 2016 was Everett WILKINSON, a social media marketer and IT expert.
88.

further stated that STONE wanted to push out WikiLeaks content

through his Facebook and Twitter accounts, and that content related to the stolen Podesta emails
was pushed out through STONE's Facebook and Twitter accounts.

3

Facebook requires that all users of Facebook accounts use their actual name while registering
and operating their accounts. The terms of service explicitly require that "Facebook users
provide their real names and information .... You will not provide any false personal
information on Facebook, or create an account for anyone other than yourself without
permission."
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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 32 of 47

J. The Target Accounts
89.

According to subscriber records obtained from Facebook, Target Account 1,

with Facebook user ID

, is registered with the vanity name "rogerstone" and

the email address

Target Account 1 is associated with

. Based on search warrant returns for STONE's

account

, between on or about October 31, 2016 and November 3, 2016,
received receipts from Facebook for the purchase of a number of
advertisements associated with the Target Account, including advertisements with the following
excerpted titles (as set forth in the receipts):
•

"BREAKING: New #Wikileaks emails prove that Team ... "

•

"Roger Stone talked about WikiLeaks, Donald Trump, ... "

90.

Additionally, on or about March 31, 2017, STONE received a Facebook receipt at

his Hotmail account for advertisements associated with Target Account 1, with the following
excerpted titles (as set forth in the receipt):

91.

•

"Stone Rebuts Charge of Russian Collusion"

•

"I am not in touch with any Russians, don't have ... ,"

•

"The charge that I am working for Russian ... ,"

•

"In fullest statement yet on DNC hacking ... "

•

"ROGER STONE - NO consensus that Guccifer 2.0 is a ... "
Target Account 2, with Facebook user ID

with the vanity name "rogerstone," using the email account

, is registered
. On or

about August 13, 2017, STONE received a receipt from Facebook for several advertisements

-23-

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 33 of 47

associated with Target Account 2, including an advertisement with the excerpted title, "I am not
in touch with any Russians ... "
92.

Target Account 3 has the Facebook user ID

and was created

on or about October 27, 2015. The account is registered in the name of
the email address

using

and the verified telephone number

According to a public records database, the telephone number
Search warrant returns for STONE's
Google indicating that

is linked to

account contain a notification from

is listed as the recovery email for
Search warrant returns for STONE's

contain a number of emails from Facebook to

account also
relating to Target

Account 3, which may have bee.n auto-forwarded to STONE's Hotmail account. These emails

include a notification of a password change to Target Account 3 and at least one receipt for a
Facebook advertisement associated with Target Account 3, sent on or about June 30, 2016. At
least one of these emails was then forwarded to
93.

account

.4

As explained further below, in my training and experience, I know that, in

addition to posting content and purchasing advertisements, Facebook accounts can be used to
communicate privately and directly with other users through Facebook's messaging function.
This function is similar to the direct messaging function of Twitter, which STONE used to
communicate with WikiLeaks and ASSANGE in 2016 and 2017.
BACKGROUND CONCERNING FACEBOOK

94.

Facebook owns and operates a free-access social networking website of the same

name that can be accessed at http://www.facebook.com. Facebook allows its users to establish

4

told investigators that he would sometimes send emails from STONE's account.
-24-

 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 34 of 47

accounts with Facebook, and users can then use their accounts to share written news, photographs,
videos, and other information with other Facebook users, and sometimes with the general public.
95.

Facebook asks users to provide basic contact and personal identifying information

to Facebook, either during the registration process or thereafter. This information may include the
user's full name, birth date, gender, contact e-mail addresses, Facebook passwords, Facebook
security questions and answers (for password retrieval), physical address (including city, state, and
zip code), telephone numbers, screen names, websites, and other personal identifiers. Facebook
also assigns a user identification number to each account.
96.

Facebook users may join one or more groups or networks to connect and interact

with other users who are members of the same group or network. Facebook assigns a group
identification number to each group. A Facebook user can also connect directly with individual
Facebook users by sending each user a "Friend Request." If the recipient of a "Friend Request"
accepts the request, then the two users will become "Friends" for purposes of Facebook and can
exchange communications or view information about each other. Each Facebook user's account
includes a list of that user's "Friends" and a "News Feed," which highlights information about the
user's "Friends," such as profile changes, upcoming events, and birthdays.
97.

Facebook users can select different levels of privacy for the communications and

information associated with their Facebook accounts. By adjusting these privacy settings, a
Facebook user can make information available only to himself or herself, to particular Facebook
users, or to anyone with access to the Internet, including people who are not Facebook users. A
Facebook user can also create "lists" of Facebook friends to facilitate the application of these
privacy settings. Facebook accounts also include other account settings that users can adjust to
control, for example, the types of notifications they receive from Facebook.

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 35 of 47

98.

Facebook users can create profiles that include photographs, lists of personal

interests, and other information.

Facebook users can also post "status" updates about their

whereabouts and actions, as well as links to videos, photographs, articles, and other items available
elsewhere on the Internet. Facebook users can also post information about upcoming "events,"
such as social occasions, by listing the event's time, location, host, and guest list. In addition,
Facebook users can "check in" to particular locations or add their geographic locations to their
Facebook posts, thereby revealing their geographic locations at particular dates and times. A
particular user's profile page also includes a "Wall," which is a space where the user and his or
her "Friends" can post messages, attachments, and links that will typically be visible to anyone
who can view the user's profile.
99.

Facebook allows users to upload photos and videos, which may include any

metadata such as location that the user transmitted whens/he uploaded the photo or video. It also
provides users the ability to "tag" (i.e., label) other Facebook users in a photo or video. When a
user is tagged in a photo or video, he or she receives a notification of the tag and a link to see the
photo or video. For Facebook's purposes, the photos and videos associated with a user's account
will include all photos and videos uploaded by that user that have not been deleted, as well as all
photos and videos uploaded by any user that have that user tagged in them.
100.

Facebook users can exchange private messages on Facebook with other users.

These messages, which are similar to e-mail messages, are sent to the recipient's "Inbox" on
Facebook, which also stores copies of messages sent by the recipient, as well as other information.
Facebook users can also post comments on the Facebook profiles of other users or on their own
profiles; such comments are typically associated with a specific posting or item on the profile. In
addition, Facebook has a Chat feature that allows users to send and receive instant messages

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 36 of 47

through Facebook. These chat communications are stored in the chat history for the account.
Facebook also has a Video Calling feature, and although Facebook does not record the calls
themselves, it does keep records of the date of each call.
101.

If a Facebook user does not want to interact with another user on Facebook, the

first user can "block" the second user from seeing his or her account.
102.

Facebook has a "like" feature that allows users to give positive feedback or connect

to particular pages. Facebook users can "like" Facebook posts or updates, as well as webpages or
content on third-party (i.e., non-Facebook) websites. Facebook users can also become "fans" of
particular Facebook pages.
103.

Facebook has a search function that enables its users to search Facebook for

keywords, usemames, or pages, among other things.
104.

Each Facebook account has an activity log, which is a list of the user's posts and

other Facebook activities from the inception of the account to the present. The activity log includes
stories and photos that the user has been tagged in, as well as connections made through the
account, such as "liking" a Facebook page or adding someone as a friend. The activity log is
visible to the user but cannot be viewed by people who visit the user's Facebook page.
105.

Facebook Notes is a blogging feature available to Facebook users, and it enables

users to write and post notes or personal web logs ("blogs"), or to import their blogs from other
services, such as Xanga, LiveJoumal, and Blogger.
106.

The Facebook Gifts feature allows users to send virtual "gifts" to their friends that

appear as icons on the recipient's profile page. Gifts cost money to purchase, and a personalized
message can be attached to each gift. Facebook users can also send each other "pokes," which are

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 37 of 47

free and simply result in a notification to the recipient that he or she has been "poked" by the
sender.
107.

Face book also has a Marketplace feature, which allows users to post free classified

ads. Users can post items for sale, housing, jobs, and other items on the Marketplace.
108.

In addition to the applications described above, Facebook also provides its users

with access to thousands of other applications ("apps") on the Facebook platform. When a
Facebook user accesses or uses one of these applications, an update about that the user's access or
use of that application may appear on the user's profile page.
109.

Some Facebook pages are affiliated with groups of users, rather than one individual

user. Membership in the group is monitored and regulated by the administrator or head of the
group, who can invite new members and reject or accept requests by users to enter. Facebook can
identify all users who are currently registered to a particular group and can identify the
administrator and/or creator of the group. Facebook uses the term "Group Contact Info" to
describe the contact information for the group's creator and/or administrator, as well as a PDF of
the current status of the group profile page.
110.

Facebook uses the term "Neoprint" to describe an expanded view of a given user

profile. The "Neoprint" for a given user can include the following information from the user' s
profile: profile contact information; News Feed information; status updates; links to videos,
photographs, articles, and other items; Notes; Wall postings; friend lists, including the friends'
Facebook user identification numbers; groups and networks of which the user is a member,
including the groups' Facebook group identification numbers; future and past event postings;
rejected "Friend" requests; comments; gifts; pokes; tags; and information about the user's access
and use of Facebook applications.

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 38 of 47

111.

Facebook also retains Internet Protocol ("IP") logs for a given user ID or IP address.

These logs may contain information about the actions taken by the user ID or IP address on
Facebook, including information about the type of action, the date and time of the action, and the
user ID and IP address associated with the action. For example, if a user views a Facebook profile,
that user's IP log would reflect the fact that the user viewed the profile, and would show when and
from what IP address the user did so.
112.

Social networking providers like Facebook typically retain additional information

about their users' accounts, such as information about the length of service (including start date),
the types of service utilized, and the means and source of any payments associated with the service
(including any credit card or bank account number).

In some cases, Facebook users may

communicate directly with Facebook about issues relating to their accounts, such as technical
problems, billing inquiries, or complaints from other users. Social networking providers like
Facebook typically retain records about such communications, including records of contacts
between the user and the provider's support services, as well as records of any actions taken by
the provider or user as a result of the communications.
113.

As explained herein, information stored in connection with a Facebook account

may provide crucial evidence of the "who, what, why, when, where, and how" of the criminal
conduct under investigation, thus enabling the United States to establish and prove each element
or alternatively, to exclude the innocent from further suspicion. In my training and experience, a
Facebook user's "Neoprint," IP log, stored electronic communications, and other data retained by
Facebook, can indicate who has used or controlled the Facebook account. This "user attribution"
evidence is analogous to the search for "indicia of occupancy" while executing a search warrant
at a residence. For example, profile contact information, private messaging logs, status updates,

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 39 of 47

and tagged photos (and the data associated with the foregoing, such as date and time) may be
evidence of who used or controlled the Facebook account at a relevant time. Further, Facebook
account activity can show how and when the account was accessed or used. For example, as
described herein, Facebook logs the Internet Protocol (IP) addresses from which users access their
accuunls along with the time and date. By determining the physical location associated with the
logged IP addresses, investigators can understand the chronological and geographic context of the
account access and use relating to the crime under investigation.

Such .information allows

investigators to understand the geographic and chronological context ofFacebook access, use, and
events relating to the crime under investigation. Additionally, Facebook builds geo-location into
some of its services. Geo-location allows, for example, users to "tag" their location in posts and
Facebook "friends" to locate each other. This geographic and timeline information may tend to
either inculpate or exculpate the Facebook account owner. Last, Facebook account activity may
provide relevant insight into the Facebook account owner's state of mind as it relates to the offense
under investigation. For example, information on the Facebook account may indicate the owner's
motive and intent to commit a crime (e.g., information indicating a plan to commit a crime), or
consciousness of guilt (e.g., deleting account information in an effort to conceal evidence from
law enforcement).
114.

Therefore, the computers of Facebook are likely to contain all the material

described above, including stored electronic communications and information concerning
subscribers and their use of Facebook, such as account access information, transaction information,
and other account information.

FILTER REVIEW PROCEDURES

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 40 of 47

115.

Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent
with professional responsibility requirements concerning the maintenance of attorney-client and
other operative privileges. The procedures include use, if necessary, of a designated "filter
kaa1," separate aml apart from the investigative team, in order to address potential privileges.
CONCLUSION

116.

Based on the forgoing, I request that the Court issue the proposed search warrant.

117.

Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.
REQUEST FOR SEALING

118.

I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These
documents discuss an ongoing criminal investigation, the full nature and extent of which is not
known to all of the targets of the investigation. Accordingly, there is good cause to seal these
documents because their premature disclosure may seriously jeopardize that investigation.

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 41 of 47

Respectfully submitted,

~

Andrew Mitchell
Special Agent
Federal Bureau of Investigation

8uhscrihecl flnd sworn to before me on this

·?!of August, 2018.
_Ld-ay

The Honorable eryl A. Howell
Chief United States District Judge

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 42 of 47

ATTACHME NT A
Property to be Searched

This warrant applies to information associated with the following Facebook accounts,
which are stored at premises owned, maintained, controlled, or operated by Facebook, Inc.
("Facebook"), a company headquartered at 1 Hacker Way, Menlo Park, California 94025:

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 43 of 47

ATTACHMENT B

I.

Information to be disclosed by Facebook

To the extent that the information described in Attachment A is within the possession,
custody, or control of Facebook Inc. ("Facebook"), including any messages, records, files, logs, or
information that have been deleted but are slill available lo Facebook, or have been preserved
pursuant to a request made under 18 U.S.C. § 2703(:t), Facebook is required to disclose the
following information to the government for each user ID listed in Attachment A:
(a)

All contact and personal identifying information, including full name, user
identification number, birth date, gender, contact e-mail addresses, physical address
(including city, state, and zip code), telephone numbers, screen names, websites,
and other personal identifiers.

(b)

All activity logs for the account and all other documents showing the user's posts
and other Facebook activities;

(c)

All photos and videos uploaded by that user ID and all photos and videos uploaded
by any user that have that user tagged in them, including Exchangeable Image File
("EXIF") data and any other metadata associated with those photos and videos;

(d)

All profile information; News Feed information; status updates; videos,
photographs, articles, and other items; Notes; Wall postings; friend lists, including
the friends' Facebook user identification numbers; groups and networks of which
the user is a member, including the groups' Facebook group identification numbers;
future and past event postings; rejected "Friend" requests; comments; gifts; pokes;
tags; and information about the user's access and use of Facebook applications;

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 44 of 47

(e)

All other records of communications and messages made or received by the user,
including all private messages, chat history, video calling history, and pending
"Friend" requests;

(f)

All records relating to machine cookies;

(g)

All "check ins" and other location information, including records of the user's
lalitude and longitude;

(h)

All IP logs, including all records of the IP addresses that logged into the account;

(i)

All records of the account's usage of the "Like" feature, including all Facebook
posts and all non-Facebook webpages and content that the user has "liked";

G)

All information about the Facebook pages that the account is or was a "fan" of;

(k)

All past and present lists of friends created by the account;

(1)

All records of Facebook searches performed by the account;

(m)

All information about the user's access and use of Facebook Marketplace;

(n)

The types of service utilized by the user;

(o)

The length of service (including start date) and the means and source of any
payments associated with the service (including any credit card or bank account
number);

(p)

Group identification numbers; a list of users currently registered to the group; a list
of users who like the page; group or page contact information, including all contact
information for the creator and/or administrator of the group and a PDF of the
current status of the group profile page;

(q)

All past and present Admins for the group;

(r)

The "Creator" of the group;

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 45 of 47

(s)

All pnvacy settings and other account settings, including privacy settings for
individual Facebook posts and activities, and all records showing which Facebook
users have been blocked by the account;

(t)

All records pertaining to communications between Facebook and any person
regarding the user or the user's Facebook account, including contacts with support
services and records of actions taken;

(u)

All records related to advertisements and advertising conducted through the
accounts, including advertisements purchased, advertising parameters (search
terms, groups, geographic areas) selected and queried.

II.

Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision ofa felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1030 (unauthorized access of a protected computer); 18
U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud),
and 52 U.S.C. § 30121 (foreign contributions ban) for the period from June 2015 to the present,
including:
a.

All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications
with persons or entities associated with WikiLeaks, including but not limited to
Julian Assange, or communications regarding disinformation, denial, dissembling
or other obfuscation about knowledge of, or access to, hacked material;

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 46 of 47

b.

All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone,

Jerome

Corsi, Julian Assange, and individual associated with WikiLeaks and/or with the
Trump Campaign;
c.

Communications, records, documents, and other files related to any expenditure,
independent expenditure, or disbursement for an electioneering communication;

d.

Records of any funds or benefits disbursed by or offered on behalf of any foreign
government, foreign officials, foreign entities, foreign persons, or foreign
principals;

e.

Communications, records, documents, and other files that reveal efforts by any
person to conduct activities on behalf of, for the benefit of, or at the direction of
any foreign government, foreign officials, foreign entities, foreign persons, or
foreign principals;

f.

Evidence indicating how and when the account was accessed or used, to determine
the geographic and chronological context of account access, use, and events relating
to the crimes under investigation and to the account owner;

g.

Evidence indicating the account user's state of mind as it relates to the crimes under
investigation;

h.

The source of all funds used to purchase advertisements or make other expenditures
or disbursements in these accounts;

i.

The identity of the person(s) who created or used the account, including records
that help reveal the whereabouts of such person(s);

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 Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 47 of 47

J.

The identity of any non-U.S. person(s)-including records that help reveal the
whereabouts of the person(s)-who made any expenditure, independent
expenditure, or disbursement for an electioneering communication; and

k.

The identity of any person(s)-including records that help reveal the whereabouts
of the person(s)-who communicated with the account about any matters relating
to activities conducted by on behalf of, for the benefit of, or at the direction of any
foreign government, foreign officials, foreign entities, foreign persons, or foreign
principals.

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