Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 1 of 126 1098 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, : : Criminal Action Plaintiff, : No. 19-CR-018 : : JURY TRIAL - DAY 6 : Afternoon Session vs. : : Washington, D.C. : November 13, 2019 ROGER JASON STONE, JR., : Time: 1:05 p.m. : Defendant. : ______________________________________________________________ TRANSCRIPT OF JURY TRIAL HELD BEFORE THE HONORABLE AMY BERMAN JACKSON UNITED STATES DISTRICT JUDGE ______________________________________________________________ A-P-P-E-A-R-A-N-C-E-S For the Plaintiff: JONATHAN IAN KRAVIS, Esquire MICHAEL JOHN MARANDO, Esquire ADAM C. JED, Esquire AARON SIMCHA JON ZELINSKY, Esquire U.S. Attorney's Office for the District of Columbia 555 Fourth Street, NW Washington, DC 20530 (202) 252-7698 Email: Jonathan.kravis3@usdoj.gov Email: Asjz@usdoj.gov Email: Michael.marando@usdoj.gov Email: Adam.Jed@usdoj.gov For the Defendant: Bruce S. Rogow, Esquire Law Office of Bruce S. Rogow, P.A. 100 NE 3rd Avenue Suite 1000 Fort Lauderdale, FL 33301 (954) 767-8909 Email: brogow@rowlaw.com Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 2 of 126 1 Appearances continued: 2 For the Defendant: 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1099 ROBERT C. BUSCHEL, Esquire TARA A. CAMPION, Esquire Buschel & Gibbons, P.A. 100 S.E. Third Avenue Suite 1300 Ft. Lauderdale, FL 33394 (954) 530-5301 Email: Buschel@bglaw-pa.com Email: Campion@bglaw-pa.com GRANT J. SMITH, Esquire StrategySmith, P.A. 401 East Las Olas Boulevard Suite 130-120 Fort Lauderdale, FL 33301 (954) 328-9064 Email: Gsmith@strategysmith.com CHANDLER PAIGE ROUTMAN, Esquire Law Office of Chandler P. Routman 501 East Las Olas Blvd. Suite #331 Fort Lauderdale, FL 33316 (954) 235-8259 Email: Routmanc@gmail.com _____________________________________________________________ Court Reporter: Crystal M. Pilgrim, RPR, FCRR Official Court Reporter United States District Court District of Columbia 333 Constitution Avenue, NW Room 4700-F Washington, DC 20001 Email: crystalmpilgrim@gmail.com Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 3 of 126 TABLE OF CONTENTS 1 Page 2 3 Closing argument: 4 By Mr. Kravis 1103 5 By Mr. Rogow 1144 6 Rebuttal argument 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 By Mr. Marando 1178 1100 Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 4 of 126 P-R-O-C-E-E-D-I-N-G-S 1 THE DEPUTY CLERK: 2 3 Recalling case number 19-18, United States of America v. Roger J. Stone. 4 THE COURT: 5 MR. KRAVIS: 6 THE COURT: 7 1101 All right, is everybody ready to proceed? Yes, Your Honor. Can I just have counsel who is going to be arguing approach the bench briefly. (Bench conference.) 8 THE COURT: 9 I just wanted to inquire as to whether 10 anyone is intending to ask the jury to draw an inference from a 11 missing witness. 12 MR. ROGOW: From a missing witness? 13 THE COURT: Yes. 14 MR. ROGOW: Only Mr. Corsi. 15 THE COURT: What are you going to say? 16 MR. ROGOW: That he's not here. 17 THE COURT: Are you going to ask them to draw an 18 inference from that or just -- 19 MR. ROGOW: No, just he's not here. 20 THE COURT: In this circuit you have to get the 21 Court's permission to argue that -- to draw some inference from 22 that. 23 24 25 What's your point of view about them saying he's not here? MR. KRAVIS: He's not here is a fact. they're allowed to assert the fact. I think If they ask the jury to Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 5 of 126 1102 1 draw any further inference from it, then I agree they need the 2 Court's permission before making that -THE COURT: 3 There's a whole predicate you have to 4 lay; that he's peculiarly available to one side, you didn't 5 subpoena him either, et cetera, et cetera. 6 MR. ROGOW: I'm not going to ask. 7 THE COURT: Okay, all right. 8 MR. KRAVIS: 9 10 Sorry while we're at the bench, there's one other thing I wanted to ask. Ms. Taylor, the former case agent who testified in trial, 11 asked if she could watch the closing argument. 12 had invoked the rule on witnesses at the start of trial. 13 asked them for their position. 14 objection. 15 16 17 18 I know defense I They said they didn't have any I just want to clear it with the Court. THE COURT: I don't have an objection. She's not going to testify again I don't think, all right. MR. KRAVIS: Correct. (Open court.) 19 THE COURT: 20 (Jury present.) All right, let's bring in the jury. 21 THE DEPUTY CLERK: Jury here. 22 THE COURT: 23 appreciate your being on time. 24 missing seat. 25 be unable to join us this afternoon, but that is why, as you Good afternoon, you guys are all here. As you may notice, we have a We have a juror who is not well and is going to I Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 6 of 126 1 know, there's more jurors in the box than 12. At this point we're about to hear closing arguments in the 2 3 case. 4 or had anyone try to speak to them or has spoken to anyone 5 about the case in our recess. 6 7 1103 I just want to confirm that no one has done any research All right. The government can proceed with its closing argument. CLOSING ARGUMENT BY MR. KRAVIS 8 MR. KRAVIS: 9 That man is Roger Stone. The evidence 10 that you have seen and heard over the past week has established 11 that Mr. Stone obstructed a congressional investigation. 12 The investigation was conducted by the House Permanent 13 Select Committee on Intelligence, or the House Intelligence 14 Committee. 15 was involved -- that Russia had interfered in the 2016 U.S. 16 presidential election. 17 The investigation was about allegations that Russia One of the topics the investigation was looking at was 18 whether Russia was involved in the publication of some 19 documents by an organization called WikiLeaks. 20 obstructed that investigation. 21 before the committee, and he tampered with a witness who could 22 expose his lies, a man named Randy Credico. 23 Mr. Stone He lied in his sworn testimony Why did Roger Stone do these things? Because he knew that 24 if the truth came out about what he had been doing in 2016, it 25 would look terrible. He knew that his emails and text messages Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 7 of 126 1104 1 from that time would show that he was repeatedly trying to get 2 documents and information from WikiLeaks. 3 text messages would also show that he was communicating with 4 the Trump campaign about WikiLeaks' plans every chance he got. 5 Those emails and Roger Stone knew that if this information came out, it 6 would look really bad for his longtime associate Donald Trump, 7 so he lied to the committee. 8 9 Roger Stone told five categories of lies before the committee. He lied about the identity of his intermediary or 10 go-between with WikiLeaks that he was publicly bragging about 11 in August of 2016. 12 get WikiLeaks to do things for him in 2016. 13 telling the Trump campaign about his conversations with the 14 intermediary. 15 the intermediary, and he lied about his other written 16 communications about Assange. 17 He lied about asking his intermediary to He lied about He lied about his written communications with Then after he told these lies, Stone engaged in a 18 relentless campaign to silence the person who could expose 19 those lies to the committee, Randy Credico. 20 walk through now the evidence that shows that Roger Stone did 21 all of these things. 22 We are going to First, we're going to talk for a minute about the 23 investigation itself. Then we're going to talk about Stone's 24 lies to the committee, what he said and the evidence you have 25 seen that shows you that each statement was false. Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 8 of 126 1 Then we are going to talk about the evidence proving that 2 Stone engaged in witness tampering. 3 to talk about how all of these actions affected the 4 committees's investigation. 5 1105 The investigation. And finally, we're going In January of 2017, the House 6 Intelligence Committee announced an investigation. This 7 investigation was about allegations of Russian interference in 8 the 2016 U.S. presidential election. 9 shows what the committee was investigating. This document, Exhibit 3, As the document 10 shows, two of the topics were Russian cyber activity and links 11 between Russia and individuals associated with political 12 campaigns. 13 One of the allegations, one of the topics the committee 14 was exploring, was that the Russians were involved in 15 WikiLeaks' publication of stolen documents from the Democratic 16 National Committee. 17 organization that publishes nonpublic documents, often 18 documents that were hacked or stolen or leaked. 19 WikiLeaks, you remember, is an In 2016, WikiLeaks published some documents that were 20 relevant to the election. 21 July 22nd, 2016, WikiLeaks posted or dumped some emails 22 belonging to the Democratic National Committee. 23 National Committee said it was the Russians who had hacked 24 their system. 25 As you can see in this tweet, on The Democratic The House Intelligence Committee was looking at all of Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 9 of 126 1106 1 this. 2 Russians were involved in the WikiLeaks releases. 3 that because this topic is mentioned in the House Intelligence 4 Committee's final report. 5 The committee was trying to figure out whether the You know This page of the report shows that the relationship 6 between WikiLeaks' publications and the Russians was part of 7 the investigation. 8 Mr. Zelinsky told you at the beginning of this case. 9 is not about whether the Russians were actually involved in the Now, remember what my colleague This case 10 WikiLeaks publications. 11 relevant to the charges in this case, and you are not being 12 asked to decide it. 13 The answer to that question is not The point here is that this is one of the questions that 14 the House Intelligence Committee was trying to answer. 15 question about Russian involvement in the WikiLeaks releases, 16 this was one important topic of the committee's investigation. 17 And because the House Intelligence Committee was looking into 18 WikiLeaks, they wanted to talk to Roger Stone. 19 This In early August of 2016, Mr. Stone started making public 20 statements in which he said: 21 information, I know what they're planning to do, and the reason 22 I know all of this is because I have had communications through 23 a back channel, or an intermediary, or a mutual friend with 24 WikiLeaks, the head of WikiLeaks, Julian Assange. 25 WikiLeaks is coming out with more That's why the House Intelligence Committee wanted to talk Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 10 of 126 1107 1 to Roger Stone. 2 contacts with WikiLeaks as part of the investigation into 3 whether the Russians were involved in the WikiLeaks releases. 4 They wanted more information about his And Roger Stone knew this. Roger Stone knew what the 5 committee was investigating and why they wanted to talk to him. 6 He said it himself in his opening statement right here. 7 8 9 (Audio played.) Now, Roger Stone made clear that he didn't agree with this allegation. He said he didn't think the Russians were involved 10 in the WikiLeaks releases, but that's not the point. 11 not for Roger Stone to decide. 12 decide. 13 That was That was for the committee to The point here is that this portion of the transcript 14 shows that Roger Stone knew exactly why this committee in this 15 investigation wanted to talk to him about WikiLeaks. 16 the committee does start talking to him about WikiLeaks, Roger 17 Stone lies to them, not once, not twice, not three or four or 18 even five times, but over and over and over again. 19 Let's talk about the hearing. 20 (Audio played.) 21 MR. KRAVIS: Here's lie number 1. This is the question, August 8th speech 22 in Broward County, August 12th on InfoWars: 23 some guys talking to Assange. 24 is that person? 25 And when You say you got Who were you talking about? This was important to the committee. You know it was Who Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 11 of 126 1108 1 important because they asked Roger Stone this question over and 2 over and over again. 3 4 5 6 7 Here's Representative Quigley: "The most important question anyone can ask you today is who was the intermediary." Representative Quigley again: "This is the question which has to be on absolutely everyone's mind." Representative Gowdy: "This is someone who can be 8 examined and cross-examined, and we can test and probe the 9 conversation that he may or may not have had with Assange. 10 Whether this person has actually talked to Julian Assange or 11 not, we have a few questions for them." 12 Mr. Schiff: "We need to determine whether your account of 13 affairs is accurate. We need to determine whether we can 14 corroborate that through the intermediary." 15 What is the truthful answer to this question? 16 The truthful answer to this question is: The guy I was 17 talking about in early August of 2016 is a man named Jerome 18 Corsi. 19 Here's how you know. As we saw a moment ago, on 20 July 22nd, 2016, WikiLeaks announced that it was releasing 21 emails from the Democratic National Committee. 22 Now, what's happening with Roger Stone at this time? 23 Roger Stone's longtime associate Donald Trump is running 24 for president of the United States. 25 was employed with the Trump campaign. Back in 2015, Mr. Stone By this time, July 2016, Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 12 of 126 1109 1 he is no longer employed with the Trump campaign, but he is 2 talking regularly with the highest levels of the campaign: 3 Deputy Chairman Rick Gates; CEO Steve Bannon; Campaign Manager 4 Paul Manafort; and even the candidate himself. 5 6 7 So when this Twitter message comes out, Roger Stone sees a chance help the Trump campaign and he jumps at it. On July 25th, 2016, three days after that message we just 8 saw, Roger Stone writes to Jerome Corsi. 9 tells Corsi: In this email, Stone Get to Assange -- remember, Assange is the head 10 of WikiLeaks at this time, he's living at the Ecuadorian 11 embassy in London -- get the pending WikiLeaks emails. 12 A few days later, just to make sure that Corsi got the 13 message, Stone sends another email: 14 Assange. 15 Malloch should see Two days later, Roger Stone gets what he's looking for. 16 This is an email, August 2nd, 2016, from Jerome Corsi, the guy 17 Roger Stone just told to get to Assange. 18 This is about eleven days after WikiLeaks released the 19 Democratic National Committee emails. 20 before Stone started making those early August public testimony 21 statements that he's going to be questioned about at the 22 hearing. 23 In this email Mr. Corsi writes: This is just a few days Word is friend at embassy 24 plans two more dumps, one shortly after I'm back, second in 25 October, impact planned to be very damaging." Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 13 of 126 1110 1 Okay, what is going on here? 2 "Friend in embassy" is Julian Assange, who was living in 3 the Ecuadorian embassy at this time. 4 talking about are releases of more emails by WikiLeaks. 5 Further down, when Corsi says: The dumps that Corsi is "That appears to be the 6 game hackers are about now, would not hurt to start suggesting 7 HRC old, memory bad, has stroke," that's a reference to Hillary 8 Clinton, who is running against Donald Trump for president, and 9 references to her health. 10 "Setting the stage for the foundation debacle," that's a 11 reference to the Clinton Foundation, an organization associated 12 with Hillary Clinton. 13 So in this email dated August 2nd, 2016, Corsi is telling 14 Stone what the, quote, word is about what WikiLeaks plans to do 15 between now and the election with the rest of the documents in 16 their possession. 17 Roger Stone knows exactly what to do with this 18 information. 19 making public statements. 20 over and over again: 21 plans. 22 to be really bad for Hillary Clinton. 23 24 25 After he gets this email from Corsi, Stone starts And in those statements, Stone says He's got information about WikiLeaks' WikiLeaks is going to release more stuff that's going And he gets this information from an intermediary or a back channel or a mutual friend with Julian Assange. Here's Roger Stone in Broward County on August 8th, 2016, Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 14 of 126 1 2 six days after the email from Jerome Corsi. (Audio played.) MR. KRAVIS: 3 4 5 6 1111 "I believe the next tranche of documents may pertain to the Clinton Foundation." Where have we heard that before? It's in Jerome Corsi's August 2nd email. 7 Here's Roger Stone on InfoWars on August 12th, 2016. 8 (Audio played.) MR. KRAVIS: 9 10 11 from later in the same interview. (Audio played.) MR. KRAVIS: 12 13 14 "I have kind of had a foreshadowing," "We have communicated through a trusted mutual friend." These are the statements from early August 2016 that 15 Mr. Stone is asked about in the hearing: 16 to in these statements? 17 But these aren't the only statements from that time. 18 is August 16th, 2016. 19 email: 20 WikiLeaks and Julian Assange." 21 22 23 24 25 Who are you referring This This is like two weeks after the Corsi "I have had some back-channel communication with This is August 16th, same day: "We have a mutual acquaintance who is a fine gentleman." August 18th on C-SPAN: "We communicated through an intermediary." August 18th again, on a recorded conference call: "I Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 15 of 126 1 think Mr. Assange -- I don't think, I know Mr. Assange has 2 those emails. 3 1112 I have had a back-channel communication." These videos are in evidence. You can watch them, listen 4 to them if you want, during your deliberations. 5 I think you will see that between August 8th of 2016 and 6 August 18th of 2016, six different times, Stone keeps repeating 7 the information that he got from Jerome Corsi on August 2nd: 8 WikiLeaks has more stuff to put out. 9 Hillary Clinton. 10 And he keeps saying: And if you do, The stuff is bad for I got this information through an 11 intermediary, a back channel, a mutual friend, a mutual 12 acquaintance. 13 Who is he talking about when he says that? 14 He's talking about the author of the August 2nd email, 15 16 17 18 19 he's talking about Jerome Corsi. So when the committee asked Mr. Stone about these public statements, what does he tell them? Does he tell them, "The guy I was referring to in August is Jerome Corsi"? 20 No. Stone does not want the committee to know about 21 Jerome Corsi. 22 about those emails. He definitely does not want the committee know 23 So what does Stone tell the committee? 24 First, he says he can't answer the question because the 25 intermediary was like a source for him. Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 16 of 126 Stone says: 1 1113 "I'll go back and I'll ask the intermediary 2 if it's okay to reveal his identity." 3 This is another lie, by the way. Roger Stone never does 4 this. And the fact that Roger Stone is lying about this detail 5 shows you what was in his mind the entire time he's testifying 6 before the committee. 7 truthful with the committee on this point. 8 stuff up. 10 says: 11 named Randy Credico." 13 14 He is just making In an October 13th, 2017 letter to the committee, Stone 9 12 Roger Stone had no intention of being "The guy I was talking about in early August is a man This letter, Government's Exhibit 13, never mentions Jerome Corsi. This is a lie. You have seen and heard overwhelming 15 evidence that the person that Stone was talking about in early 16 August 2016, this person he keeps referring to as a back 17 channel or intermediary or mutual friend or mutual 18 acquaintance, this person could not have been Randy Credico. 19 You saw their emails and text messages. 20 August 19th, 2016, this message is sent 11 days after 21 Stone starts making those comments in Broward County. 22 after his appearances on InfoWars. 23 public statements that we just looked at. 24 told you: 25 communicated about Assange. It's This is after all of the And Randy Credico This is the first time that Roger Stone and I ever Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 17 of 126 1 1114 Ms. Taylor, the former FBI agent, told that you she has 2 looked through the emails, she's looked through the text 3 messages, there is no text message, there is no email between 4 Roger Stone and Randy Credico before this one on August 19th, 5 2016, that talks about Assange or WikiLeaks, and this text 6 message was after all of Mr. Stone's public statements from 7 early August about an intermediary. 8 9 You heard from Credico, he explained to you what's going on here. Mr. Credico told you: "I saw the speech in Broward 10 County. 11 about how he's got a back channel to Assange; he's got an 12 intermediary. 13 I'm going to have Assange on my show." 14 I saw this thing where Stone is going around talking So I try to one-up him a little bit. Credico says: I tell him "I don't have him booked yet, but I'm 15 hoping it's going to kind of work out, and this is the first 16 time I mention Assange to Roger Stone," on August 19th of 2016. 17 This document corroborates Credico's account of events. 18 This is the email from the WikiLeaks folks setting up the 19 interview between Assange and Credico, when Assange appears on 20 Credico's show. 21 This is August 25th, 2016, the day of the interview. This 22 shows what Credico was talking about. His first efforts to get 23 in touch with WikiLeaks to get Assange on the show doesn't 24 happen until after Roger Stone had said all of those comments 25 about having an intermediary or a back channel or a mutual Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 18 of 126 1 2 1115 friend with Julian Assange. You also heard about this from Margaret Kunstler, the 3 older woman, the lawyer, Credico's friend. 4 "This was the one and only time that I tried to hook up Randy 5 Credico with people at WikiLeaks." 6 7 8 9 10 11 12 She said, "I did this like a few days before the interview happened, less than a week. getting in touch with Julian Assange. Finally, there's the August 23rd radio interview between Randy Credico and Roger Stone. (Audio played.) MR. KRAVIS: That's Credico. (Audio played.) MR. KRAVIS: 15 Listen to how Credico is talking in this 16 interview. 17 information from WikiLeaks? 18 19 20 21 22 This was the only time I did it." And to her knowledge, Randy Credico had no other way of 13 14 She told you: He's asking Stone, "look are you getting What's going on here?" And Stone says: "I've got this back channel, I've got this mutual friend." Is this how these two men would be talking if Randy Credico was the intermediary? Of course not, of course not. And Roger Stone, Roger Stone knows full well that pinning 23 all of this on Randy Credico is a lie. He knows it's a lie 24 because Randy Credico has been telling him over and over again, 25 since September 2016, you've got this wrong. Check the emails, Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 19 of 126 1116 1 check the text messages, I'm not the guy from early August. 2 Take a look at the documents. Before the hearing, before Roger Stone ever set foot in 3 4 that committee room, Randy Credico told Roger Stone in writing 5 three different times that Randy Credico was not the guy from 6 early August. This is September 18th, 2016. 7 Look at the message at the 8 bottom: "Do not name me as your connection to Assange. 9 had one before that you referred to." This is October 15th, 2016: 10 You "All I did in London is 11 deliver a letter. You got nothing to worry about because no 12 one has communicated with Assange except for on my radio show. 13 All I did was deliver a letter." January 6th, 2017, right around the time the congressional 14 15 investigations are announced, the email is even called, "Back 16 Channel BS," Credico says to Stone: 17 line. 18 than on my radio show. 19 had no back channel or there's the guy you were talking about 20 early August. The guy you were talking about early August," 21 ladies and gentlemen, that's Jerome Corsi. 22 This isn't right. "I put together the time I've never talked to Assange other You may as well tell the truth that you Now, the defense would have you believe that Randy Credico 23 is some sort of Svengali or mastermind, that Randy Credico 24 tricked Roger Stone into giving false testimony before the 25 committee; that Randy Credico somehow fooled Roger Stone into Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 20 of 126 1117 1 believing that Stone's own statements from August 2016 were 2 actually about Credico. That claim is absurd. You saw Randy Credico testify during this trial. 3 I ask 4 you, does anyone who saw and heard that man testify during this 5 trial think for even a moment that he is the kind of person who 6 is going to pull the wool over Roger Stone's eyes. 7 that you saw testify is just not the kind of person who is 8 going to fool Roger Stone. The person And look at the text messages and the email I just showed 9 10 you. 11 Roger Stone's own words meant in August 2016, why is Credico 12 repeatedly texting and emailing Stone to set the record 13 straight, telling him: 14 in early August. 15 If Randy Credico is trying to fool Roger Stone about what I'm not the guy, there was someone else Roger Stone knew perfectly well, when he said had a back 16 channel in early August, he was talking about Jerome Corsi. 17 Roger Stone wasn't tricked. 18 19 He lied. That's lie number 1, who were you talking about in early August. The truth is Corsi. Stone says Credico. 20 Here's lie number 2. 21 (Audio played.) 22 Question 2 -- Question 2, did you ask this guy to do 23 anything on your behalf, what is the truthful answer to this 24 question? 25 The truthful answer to this question is yes. You know Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 21 of 126 1 2 that because you have seen the requests. 1118 They are in writing. This is the email from Roger Stone to Jerome Corsi, 3 July 25th, 2016. This email does not say: 4 confirm Julian Assange's public statements." 5 not say: "Please just This email does "Please just confirm that they got more stuff." 6 This email says: 7 In this very first email, Roger Stone is asking the guy to 8 9 "Get the pending WikiLeaks emails." do something. Now, as we just discussed, the guy the committee is asking 10 him about is the guy he's referring to in early August, and 11 that is Jerome Corsi. 12 statement that this guy is actually Randy Credico, this lie is 13 still a lie because of this. 14 15 16 But even under Roger Stone's false September 18th, 2016, Roger Stone texts Randy Credico: "I'm emailing you a request to pass on to Assange." This is the request. It's Government's Exhibit 50. In 17 this email on September 18th, 2016, Stone asks Credico to try 18 to get from WikiLeaks, emails related to Libya and Hillary 19 Clinton's service in the State Department. 20 Stone did not contact Credico just once about this. He 21 emailed and tested him over and over and over again. 22 Roger Stone texted or emailed Randy Credico with this request 23 for Libya documents from WikiLeaks six times over a one-week 24 period in September of 2016. 25 So what did Stone say to the committee? In total, Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 22 of 126 Does he says: 1 1119 Yes, I asked Jerome Corsi to do some stuff. 2 And if we're counting Randy Credico, I asked him to do some 3 things too. No, he does not tell that to the committee. 4 5 them. He says: He lies to No, I never asked them to do anything. All of the documents you just saw show that statement is a 6 7 lie, and Stone knows it's a lie. 8 he has these emails in his possession at the time he testifies 9 before the committee. 10 He knows it's a lie because In fact, he forwards this one back to Randy Credico in 2018. Take a look at Government's Exhibit 82. 11 The email, the 12 body of the email is the exchange that we just saw where Stone 13 is asking Credico to get WikiLeaks document -- get WikiLeaks 14 documents on Hillary Clinton in Libya. Take a look at the date of the forward, March 10, 2018. 15 16 Roger Stone forwarded this email back to Randy Credico six 17 months after the hearing, six months after his testimony. Now, Mr. Credico told you how he took this email. 18 19 said: 20 with the truth, I'm going to expose your friend Margaret 21 Kunstler." 22 He I took this as kind of a warning like, if you go public And we're going to talk about that in a minute, but what 23 this email shows is that Roger Stone knew full well that his 24 statement to the committee, that he never asked the person to 25 do anything on his behalf, is a lie. Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 23 of 126 1 Let's move on to lie number 3. 2 (Audio played.) MR. KRAVIS: 3 1120 What is the truthful answer to this 4 question? 5 know that because you have seen and heard overwhelming evidence 6 that throughout the 2016 presidential election, Stone was 7 passing information about WikiLeaks from his conversations with 8 his intermediary back to the Trump campaign. 9 The truthful answer to this question is yes. During this trial you heard from deputy campaign manager 10 Richard Gates. 11 he had information on WikiLeaks. 12 June, in July, in August, more material is coming out. 13 You He testified that Stone regularly told him that And Gates said: Stone kept telling Gates in This information that Stone is giving me 14 about WikiLeaks, more material coming out, this was not public 15 information. 16 was giving me. 17 This was nonpublic information that Roger Stone You also heard from the campaign CEO, Stephen Bannon. 18 Bannon said that Stone would boast about his relationship with 19 WikiLeaks and the information he could get. 20 testified that he viewed Stone as the campaign's access point 21 to WikiLeaks. 22 talking about. 23 In fact, Bannon The documents show you what Bannon and Gates are This is June 14, 2016, on the day that the DNC announces 24 that they have been hacked and they think it was the Russians. 25 On the day that announcement comes out, Roger Stone has a phone Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 24 of 126 1 2 1121 conversation with the candidate, Donald Trump. Again on June 30th, on the day that Guccifer 2.0, the 3 entity that claimed credit for the hack, comes out and praises 4 Donald Trump in a WordPress post, Stone has another phone 5 conversation with Donald Trump. 6 One hour before Roger Stone sends this email to Jerome 7 Corsi, "Malloch should see Assange," Roger Stone has a phone 8 conversation first with Rick Gates, and then with the 9 candidate, Donald Trump. 10 Now, Mr. Gates testified that late July, right around the 11 time of these phone records on the screen in front of you, 12 Stone had a phone call with then-candidate Trump. 13 Remember, Gates testified, he said: 14 in a car. 15 LaGuardia Airport. 16 He said: 17 It's a Suburban. We're going from Trump Tower to I'm sitting diagonally. and a half rows not three rows. 18 He says: 19 Gates says: This is really like two I'm sitting diagonal from him. Candidate Trump has a phone call. I can hear it's Roger Stone's voice on the 20 other end of the phone. 21 30 seconds, Trump says to Gates: 22 Mr. Trump and I are Trump hangs up the phone, and within More information is coming. This is an email from Roger Stone to Paul Manafort. It's 23 dated August 3rd, 2016. This is one day after Stone gets the 24 email from Corsi, "Word is friend in embassy plans two more 25 dumps." Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 25 of 126 1 2 On August 3rd, 2016, Stone writes to Manafort: idea to save Trump's ass. 1122 "I have an Call me please." 3 What is Stone's idea to save Trump's ass? 4 It's to use the information about WikiLeaks releases that 5 6 he just got from Jerome Corsi. How do know that's what he had in mind; because that's 7 exactly what he did. As you just saw, just days after Stone 8 sends this email to Paul Manafort, "I have an idea to save 9 Trump's ass," he goes out on TV, on conference calls and starts 10 plotting this information that he's getting from Corsi: 11 WikiLeaks has more stuff coming out, it's really bad for 12 Hillary Clinton. 13 This is October 4th of 2016. Mr. Bannon testified for you 14 about this email. 15 there's supposed to be another release. 16 to announce that more documents are coming out. 17 Mr. Bannon explained: On October 4th, WikiLeaks is supposed The morning of October 4th comes and goes, there's no more 18 release, and Steve Bannon wants to know what's going on. 19 emails Roger Stone. 20 21 Why Roger Stone? He Because Roger Stone is the campaign's WikiLeaks access point. 22 And Bannon asks: What was that this morning? 23 And how does Stone respond? He responds with information 24 about what's going to happen with WikiLeaks: 25 going forward. A load every week Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 26 of 126 1 Stone does the same thing with Eric Prince. 1123 You heard 2 from Bannon, Prince would visit -- he wasn't a salaried 3 employee, but he would visit the Trump campaign offices. 4 would write policy papers, position papers for the campaign on 5 things like foreign policy. 6 On October 3rd, 2016, Stone writes to Gates -- Stone 7 writes to Prince: 8 The payload is still coming." 9 He "Spoke to my friend in London last night. "Friend in London" is a reference to Julian Assange. You 10 heard from Stone's statements about where he gets information 11 from Assange, it's through the intermediary, and this is more 12 information that Stone is passing on to someone involved with 13 the Trump campaign. 14 The result of all of this information that Roger Stone is 15 providing to the campaign is that Stone becomes the Trump 16 campaign's WikiLeaks guy. 17 you this. 18 19 Bannon told you this, and Gates told So when WikiLeaks finally does release more emails on October 7, who asks for credit? Roger Stone. 20 And who gets the credit? Roger Stone. 21 All of this evidence shows that Stone was discussing his 22 conversations with the intermediary, with people involved in 23 the Trump campaign. 24 Is that what Stone tells the committee? 25 No. He lies again. Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 27 of 126 1 Why is Stone lying about this? 2 Ladies and gentlemen, Roger Stone is a political 3 strategist. 4 of the United States House of Representatives is examining 5 whether the Russians were involved in the WikiLeaks releases, 6 and here is Stone giving the campaign inside information on 7 those releases over and over again. 8 terrible for Trump. 9 He knows how this is going to look. 1124 A committee This is going to look And Stone is worried that what he says and does in the 10 hearing is going to reflect back on the president. 11 text message that Stone send to Randy Credico on December 1st, 12 2017, after the hearing. 13 14 Stone writes: This is a "Because of Trump, I could never get away with asserting my Fifth Amendment rights." 15 Roger Stone knows how all of this is going look, and he 16 knows it's going to reflect back on Trump, so he lies to the 17 committee. 18 19 20 Lie number 4. ladies and gentlemen of the jury, this one is a whopper. (Audio played.) MR. KRAVIS: 21 22 Lie number 4 is about documents; and, It's not just asked once. (Audio played.) MR. KRAVIS: 23 What is the truthful answer to this 24 question? The truthful answer to this question is: 25 exchanged emails, we exchanged text messages. Yes, we Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 28 of 126 1125 Now, the honest-to-goodness truthful answer to this 1 2 question is: 3 I said I had an intermediary, that guy is a man named Jerome 4 Corsi. 5 messages with him, including emails and text messages about 6 WikiLeaks. 7 this case. And yes, I have lots of emails and lots of text Here are five examples that are all in evidence in But even in Roger Stone's misshapen world where he wants 8 9 The guy I was talking about in early August, when to pretend that the guy he was talking about in early August 10 was actually Randy Credico, this is still a lie. 11 that world this is an even bigger lie. Anything in writing, no; emails, no; text messages, no. 12 13 In fact, in Emails, he's not an email guy. 14 No text messages, not an email guy, are you kidding me? 15 Roger Stone and Randy Credico exchanged hundreds of 16 written communications. Many of them are in evidence in this 17 case. 18 shows you the number of communications between Roger Stone and 19 Randy Credico between June 2016 and September of 2017. 20 add up all of the numbers on this chart, you will find that 21 these two men exchanged over one thousand five hundred written 22 communications including over one hundred emails. 23 guy indeed. This chart, prepared by former Special Agent Taylor, If you Not an email 24 In fact, on the very day that Roger Stone told the House 25 Intelligence Committee that he had no text messages with this Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 29 of 126 1126 1 intermediary, Roger Stone exchanged 72 text messages with Randy 2 Credico. 3 Lie number 5 is also a whopper. 4 (Audio played.) MR. KRAVIS: 5 6 7 This is lie number 5. Any communications you've had with any third parties about Julian Assange. 8 What is the truthful answer to this question? 9 The truthful answer to this question is yes. It includes 10 all the emails and text messages we just saw with Jerome Corsi, 11 all the emails and text messages we just saw with Randy 12 Credico, plus the emails with Bannon and Prince which were also 13 about Julian Assange. 14 15 16 Why is Stone lying to the committee about these documents? Why is Stone telling these whoppers? It's because the documents expose all of his other lies. 17 Because Roger Stone cannot let the committee see any of the 18 documents that you have seen over the past week. 19 with Corsi; the Credico messages mentioning the guy from early 20 August; the repeated requests for documents from WikiLeaks; the 21 emails and texts with the Trump campaign about WikiLeaks, all 22 of it. 23 to evidence that exposes all of his other lies. The emails Stone has to lie so the committee will not see any of 24 Okay, those are the five lies. 25 Who is the guy you were referring to in early August? Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 30 of 126 1127 1 Truth is Corsi, Stone says Credico. 2 Did you ask an intermediary to do anything on your behalf? 3 Truth is yes, Stone says no. 4 Did you communicate anything about your conversations with 5 the intermediary to the Trump campaign? 6 Truth is yes, Stone says no. 7 Did you communicate with the intermediary in writing? 8 Truth is yes, Stone says no. 9 Do you have any communications with third parties about 10 Julian Assange? 11 The truth is yes, Stone says no. 12 In Counts 2 through 6 of the indictment, Stone is charged 13 with five counts of making a false statement, one count for 14 each of those lies. 15 Where does all of this leave Roger Stone? 16 It leaves him with one big loose end. There is one guy 17 out there who can knock down this whole house of cards. 18 is one guy out there who knows the truth behind the lies that 19 Stone has told the committee. 20 There It's Randy Credico. And as you would you expect, after Stone falsely testifies 21 to the committee that Credico is the guy from early August, 22 well, the committee asks Credico for an interview. 23 Stone, of course, knew that this is exactly what would 24 happen when he sent that letter in October 2017. Stone knew 25 that the committee would try to interview the person that he Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 31 of 126 1 identified in the letter. 2 never happen. 3 because if they did, they would find out that Roger Stone 4 repeatedly lied under oath on September 26th, 2017. 5 1128 And Stone also knew that that could The committee could never talk to Randy Credico, Ladies and gentlemen, that is exactly why Roger Stone 6 picked Randy Credico, because he knew that when the time came, 7 he would be able to bend Randy Credico until Randy Credico 8 broke. 9 Randy Credico testified in this trial, and when he 10 testified, I think you could clearly say why Roger Stone picked 11 him to be the patsy in all of this. 12 Mr. Credico admitted to you that he has had problems with 13 alcohol in his past. 14 take seriously. 15 talked about Dick Tracy and characters in movies that I've 16 never even heard of. 17 He also -- he can be a little hard to He's a comedian. When he was on the stand, he And Randy Credico had a pressure point that Roger Stone 18 knew about. 19 Kunstler is Randy Credico's friend. 20 Credico that Assange interview. 21 forwarded that request to about -- from Stone, about getting 22 documents about Clinton in Libya in September of 2016. 23 24 25 It's Margaret Kunstler. You remember, Margaret She's the person who got She's the person that Credico Margaret Kunstler being dragged into this was a pressure point for Randy Credico, and Roger Stone knew it. I want to remind you about something that happened during Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 32 of 126 1 this trial. 2 you're not going to see it on a PowerPoint slide. 1129 You're not going to find it in an evidence binder, 3 When Randy Credico was on the stand last Friday morning, 4 he was testifying about how, in September of 2017, Stone told 5 him: 6 channel." 7 8 9 "I'm going to go out and say that you're the back And Credico said: "No, you've got this wrong, I'm not the guy from early August." Then Credico testified Stone said to him, I've got an 10 email. 11 It's that email from September 2016. 12 Stone's public statements about an intermediary. 13 where Stone forwards the request for documents. 14 15 I've got an e-mail from Margaret Kunstler about this. This is way after all of It's the one And Mr. Zelinsky asked Mr. Credico, does this concern you that Stone is bringing up this email to Ms. Kunstler? 16 And Randy Credico, a man who otherwise was never at a loss 17 for words, a man who otherwise always had one more thing to say 18 during this trial, stopped. 19 took off his glasses, played with them, he paused for like 20 30 seconds. 21 He smoothed back his hair. And when he finally answered the question he said, she's a 22 close friend. She's an older woman. 23 through this. I wanted to keep her out of it. 24 25 He I didn't want to drag her And Randy Credico, Randy Credico had seen Roger Stone do this before. Credico told you about how, back in 2007, Stone Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 33 of 126 1130 1 had tried to get Credico to take the fall for this voice-mail 2 message on Eliot Spitzer's father's answering machine. 3 Credico told you that when he wouldn't go along with the 4 story, Stone blew him up in the media, got him a whole bunch of 5 bad publicity. 6 to Margaret Kunstler ten years later. 7 Credico did not want the same thing to happen Roger Stone knew all of this. 8 had this pressure point. 9 Kunstler mixed up in all this. He knew that Randy Credico He knew that Credico did not want Stone knew that he had that 10 email, and he knew that if he put pressure on Credico in just 11 the right spot that Credico would go along with the plan. 12 For all of these reasons, Roger Stone knew that if you 13 wanted to hide what he was doing with Jerome Corsi in 2016, 14 Credico was going to be pretty much the perfect cover. 15 starts messing with Credico's head right off the break. Stone 16 On the left is the letter that Roger Stone sent to the 17 committee, falsely identifying the guy from early August as 18 Randy Credico. 19 to Credico six days or so after he sent the letter. 20 see the email that gets forwarded to Credico says, "From our 21 letter to the House." 22 On the right is an email that Stone forwarded You can Stone sends this email to Credico so Credico will know 23 what the cover story is going to be, what the lie is that he's 24 going to have to cover for. 25 days after he sends the letter to the committee so that Credico Stone sends Credico this email six Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 34 of 126 1131 1 will know that Stone has identified Credico to the committee as 2 the guy from early August, even though that's not the truth. 3 And in the email that Stone sends feeding Credico the 4 cover story, Stone starts trying to butter up Credico by 5 including a bunch stuff that's not in the actual letter to the 6 committee. 7 Take a look at the highlighted passages: "Only 8 reluctantly identify his source"; an accomplished entertainer, 9 an impressionist"; a whole paragraph on Credico's work on drug 10 law reform in New York; landmark interviews with Julian 11 Assange. 12 committee. 13 14 15 These words are not in the actual letter to the If they're not in the actual letter, why is Stone trying to make Credico think that they are? It is because Stone is messing with Credico's head. He is 16 trying to get Credico to go along with the lie that's in the 17 email. 18 19 20 On November 9, 2017, the House Intelligence Committee asks Randy Credico for an interview. And Credico told you when he testified, he said: "During 21 this time Roger Stone is telling me, go along with the lie in 22 the email, take the Fifth, or claim that you just don't 23 remember any of this." 24 The documents show you what he's talking about. 25 On November 19th, 2017, just a few days after the Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 35 of 126 1 Credico -- after Credico gets the letter requesting the 2 interview, Credico tells Stone: 3 today." 4 5 6 1132 "My lawyers want to see me Look at how Stone responds: "Stonewall it, plead the Fifth, anything to save the plan." This is a Richard Nixon quote from Watergate, and this is 7 Roger Stone's plan for his loose end. 8 Stone's lies to the committee if the committee never hears from 9 Credico. 10 11 12 Credico cannot expose Again, two days later on November 21st, Credico writes: "I was told I'll be getting a subpoena." Stone responds: "That was the point when your lawyer 13 should have told them you'd assert your Fifth Amendment 14 rights." 15 Here are three more messages from December of 2017, all 16 referencing the Fifth Amendment: 17 Amendment; text message, You can plead the Fifth; text message, 18 So what, all legal, take the Fifth, fuck em. 19 Then there's this: Facebook message, Fifth Randy Credico eventually gets a 20 subpoena from the House Intelligence Committee on November 27th 21 or 28th of 2017. 22 one day later as they're texting about the subpoena: 23 whole thing will be worthless unless you find a place to do 24 your Frank Pentangeli impression, sure, sure, Roger Stone this, 25 Roger Stone that." Take a look at what Roger Stone writes to him "The Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 36 of 126 1 Here it is again, December 1st, 2017: 1133 "Start practicing 2 your Pentangeli," followed by four links to news articles about 3 Credico testifying before the committee. 4 Remember who Frank Pentangeli is. He's a character in the 5 movie The Godfather Part II. 6 where Pentangeli is supposed to testify before a congressional 7 committee. 8 can bring a perjury charge against his associate. 9 this starts to sound familiar. 10 And there's a scene in the movie Pentangeli is called to testify so the committee But Pentangeli lies to the committee. Stop me when He says he doesn't 11 know anything about that criminal activity, and -- and this is 12 the kicker -- the lines, the words that Pentangeli uses in the 13 movie to claim to the committee he doesn't remember, those are 14 the same lines that Roger Stone texted to Randy Credico one day 15 after Credico gets the subpoena. 16 sure, Roger Stone, this, Roger Stone that." 17 Look at the message: Miss Taylor told you about this. "Sure, She told you that in 18 this scene in the movie Pentangeli says to the committee: 19 made all that stuff up. 20 they offered me the deal, I told them, sure, sure, Michael 21 Corleone this, Michael Corleone that." 22 23 24 25 "I The FBI offered me a deal, and when Here's Stone one day after the subpoena, "Sure, Sure, Roger Stone this, Roger Stone that." Credico told you how he understood these text messages. He said: Look, I can't just go in there like Frank Pentangeli Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 37 of 126 1134 1 and say I don't know Roger Stone. 2 when The Godfather was set. 3 that show we know each other, unless of course you lie to the 4 committee about the text messages and emails." 5 This isn't the 1950s, like There's text messages and emails But Credico told you he understood Stone to be telling him 6 you can, quote, throw them off, throw the committee off. 7 can quote, "not recall events that actually transpired." 8 9 You Those are Credico's words about what these messages meant. When Stone told Credico to do a Pentangeli, Credico full-well 10 understood that Stone was telling him to lie to the committee. 11 Ladies and gentlemen of the jury, when you send a witness 12 before a congressional committee, text messages telling him to 13 do a movie character who lies to a congressional committee, 14 that is witness tampering, plain and simple. 15 the committee investigation. 16 17 18 19 20 21 December 1st, 2017: "If you turned over anything to the FBI you're a fool." December 24th, 2017: "I'm not talking to the FBI, and if you are smart you won't either." January 25th, 2018: "Waste of your time, tell him to go fuck himself. 22 Who? 23 Special Counsel Robert Mueller." 24 This is Stone telling Credico: 25 And it's not just Keep your mouth shut. Don't talk to the committee, don't talk to the FBI, don't talk Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 38 of 126 1 2 1135 to the special counsel. When Randy Credico tries to point Roger Stone toward the 3 truth, "I have the email, August 25th, 2016. 4 contact" -- he has it exactly right, by the way, that's the 5 email. 6 response? 7 8 9 10 That was my first It is from exactly August 25th, 2016 -- what's Stone's "No one cares." January 8th, 2018: Introduced to him August 25th, 2016. I have the email. Stone's response: No one cares. These short text messages may perfectly sum up Roger 11 Stone's view of all of this. 12 emails, look the documents, look at the dates. 13 wrong." 14 Stone's response: 15 No one cares? Credico tells him: "Look at the You got it "No one cares." A committee of the United States Congress 16 is investigating allegations that a foreign power interfered in 17 our presidential election, Stone has just been told he gave the 18 committee false information, and his response is: "No one 19 cares." 20 Someone does care. You know who cares? The House 21 Intelligence Committee cares. 22 over and over and over again, when he was under oath in front 23 of the committee. 24 25 They asked him these questions So when the defense gets up here and they start telling you, "Who cares, none of this matters, Roger Stone didn't Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 39 of 126 1136 1 collude with the Russians. Your answer to them is, that's not 2 how this works. 3 which facts he thinks are important and then lie about the rest 4 of them. 5 evidence in its investigation wherever that evidence may lead. 6 And by the way, take a look at who Roger Stone is telling Roger Stone does not get to pick and choose The committee was entitled to the truth and the 7 about Credico pleading the Fifth. 8 author of the August 2nd email. 9 It's Jerome Corsi, the Why is Stone telling Corsi about Credico pleading the 10 Fifth? 11 Stone telling Corsi: 12 know about you because Credico is not going to testify. 13 Credico and Corsi don't even know each other. I got you covered. They're not going to And look, Randy Credico, Randy Credico is not stupid. 14 gets what is going on here. 15 he is desperate for Roger Stone to correct the record. 16 This is He Even after he has pled the Fifth, In the spring of 2018, he tells Stone over and over again: 17 You've got this wrong. I'm not the guy from early August. 18 never had any inside information from WikiLeaks. 19 someone else. I That was Look at the emails. 20 April 6th, 2018: 21 emails and text messages." 22 Stone's response: 23 April 9th, 2018: 24 made-up back channel." 25 Stone's response: "You had no back channel. Check out the "Nice try." "You ratted on someone that was not your "Prepare to die." Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 40 of 126 1 May 21st, 2018, remember that pressure point I mentioned a 2 moment ago: 3 Intel Committee. 4 complaint against your friend Margaret." 5 1137 "You should have just been honest with the House Keep running your mouth and I'll file a bar Every time Randy Credico tries to point Roger Stone toward 6 the truth in 2018 about what really happened, Stone responds 7 with a vulgarity or an insult or a threat. 8 9 Okay, one more set of documents from 2018. email. This is an It's from Stone's lawyer to Stone and Corsi. The date 10 of the email is April 3rd, 2018. 11 testified before the committee. 12 letter falsely identifying Credico as the guy from early 13 August, and Credico has pled the Fifth. 14 At this point Stone has He has sent the committee the In this email from April 3rd, 2018, Roger Stone is 15 forwarded the two emails that he sent Jerome Corsi back in 16 July 2016. 17 Here's the first one: "Get to Assange. Get the pending 18 WikiLeaks emails July 25th, 2016, and Malloch should see 19 Assange July 31st, 2016. 20 These two emails are critical because they show that Corsi 21 and not Credico was the guy from early August. They also show, 22 by the way, that Stone did have written communications about 23 Assange, and he did have written communications with the guy 24 from early August, and he did ask that person to do something 25 on his behalf, three of the other lies to the committee. Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 41 of 126 1 But this email -- these emails conclusively show that 2 Stone got it wrong when he told the committee: 3 Credico, the guy I was talking about in early August 2016. 4 They show that Stone's statement to the committee was 5 6 7 8 9 10 11 12 It was Randy false. What does Stone do with this information? Does he try to correct the record? Does he tell the committee: Hold up, wait, I made a mistake? Does he tell Credico: Funny story, you know what, you were right all along. No, that's not what he does. The next day, one day after 13 these emails are forwarded back to him, Stone writes to 14 Credico: 15 heard from you and can prove it. 16 1138 "Everything I know about the WikiLeaks disclosures, I You lose." Faced with the evidence of the truth, Roger Stone just 17 doubles down on the lie. 18 writing to the committee, "Everything I said was entirely 19 truthful, my test" -- June 2018 -- "my testimony was wholly 20 truthful," December 2018, after those emails are forwarded back 21 to him. 22 doubling down on the lie. 23 And after these emails he keeps Faced with the evidence of the truth, Stone just keeps That's the witness tampering, emails and text messages 24 that show Stone telling Credico: "Go along with the lie", in 25 the October email; or plead the Fifth or say you don't Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 42 of 126 1 remember, do a Pentangeli. 2 charged in Count 7 with one count of witness tampering. 3 1139 Based on that conduct, Stone is Okay, we've talked about Counts 2 through 6, the false 4 statement counts, and we talked about Count 7, the witness 5 tampering count. Let's talk for a minute about Count 1. 6 Count 1 is obstruction of an official proceeding. 7 establish that the defendant committed this crime, the 8 government has to prove that there was a proceeding, that the 9 defendant knew there was a proceeding, and that the defendant 10 11 To tried to corruptly influence the proceeding. In this case, the proceeding was the House Intelligence 12 Committee investigation of Russian election interference. 13 Roger Stone corruptly influenced that investigation by lying to 14 the committee, by misleading the committee about Jerome Corsi, 15 and by tampering with Randy Credico. 16 As the judge will instruct you, the government is not 17 required to prove that Stone's conduct actually affected the 18 committee's investigation. 19 as the government shows that he endeavored or tried to impede 20 the investigation. 21 He's guilty of obstruction as long All of the evidence that we have just discussed certainly 22 shows that Stone tried to impede the investigation. 23 this case Stone did much more than that. 24 25 But in The evidence shows that Stone not only tried, he succeeded in impeding the committee's investigation. Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 43 of 126 1 How? 1140 First, the committee never saw the documents that we 2 have been talking about this afternoon, the emails with Corsi, 3 the texts with Credico, the emails with Bannon, the emails and 4 texts with Prince. 5 because Stone lied to the committee and told the committee that 6 those documents did not exist. 7 The committee never saw those documents But it's not just the documents. 8 heard from Jerome Corsi. 9 Corsi as a relevant person. The committee never The committee report does not mention The committee report does not 10 mention the August 2nd email, "Word is friend in embassy plans 11 two more dumps, one coming out in October reference the Clinton 12 foundation." 13 whole other guy that Stone was using to get information about 14 WikiLeaks in August of 2016. 15 The committee had no idea that there was this The committee also never heard from Randy Credico, the 16 person who could tell them that Stone does have emails and text 17 messages about WikiLeaks; that Stone was talking about another 18 guy, not him in, early August. 19 of that because Credico pleads the Fifth, thanks to Stone's 20 threats and harassment. 21 The committee never hears any The committee never hears about Stone's communications 22 with the campaign about WikiLeaks, Trump, Gates, Bannon, 23 Prince, Stone giving the campaign nonpublic information about 24 the releases. 25 This is something the committee was trying to figure out. Stone taking credit for the October release. The Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 44 of 126 1141 1 WikiLeaks releases in 2016. Any connections with Russia, any 2 connections with the campaign? 3 learns what you have seen and learned over the past week in 4 this trial; that in 2016 Stone was pressing over and over for 5 information about WikiLeaks and feeding that information back 6 to the Trump campaign every chance he got. The committee never sees or Stone's 2017 text messages are gone. 7 You heard from 8 Ms. Taylor that in the course of the special counsel's 9 investigation, the FBI tried to go back and get Stone's text 10 messages from 2017, the time of the hearing. 11 it. 12 They couldn't do Those messages are gone. Now ask yourself, if Roger Stone had told the committee 13 the truth, he said, "Yeah, I've got text messages about 14 Assange; yes, I have written communications with Corsi; I also 15 have written communications with Credico, for that matter; in 16 fact, when we walk out of here, I'm going to text with him like 17 70 more times today," what do you think the committee might 18 have done? 19 They might have asked him for those text messages. 20 might have subpoenaed the messages. 21 them, the committee didn't take that step, and now those 22 messages are gone. 23 They Because Stone lied to And the committee's report contains inaccuracies. Take a 24 look at this passage. The committee did not find any evidence, 25 did not find any evidence contradicting Stone's claim that all Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 45 of 126 1 2 of his information was from publicly available sources. No evidence? Really? How about that August 2nd email 3 from Jerome Corsi, that's not a publicly available source. 4 committee never saw that evidence, and so the committee's 5 report is not accurate. 6 1142 The Now, what's going to happen next is the defense is going 7 to stand up here, and they're going to talk to you for a little 8 bit, and then my colleague Michael Marando he's going to get up 9 and talk to you one last time before you begin your 10 deliberations. 11 When the defense stands up here, they are going to try to 12 convince you that this was all some big misunderstanding, that 13 Roger Stone was acting in good faith when he testified before 14 the committee. 15 When they make that argument, I want you to remember those 16 text messages from December of 2017 and January of 2018, "Fifth 17 Amendment; Frank Pentangeli; Sure, Sure, Roger Stone this, 18 Roger Stone that. 19 smart, you won't either. 20 himself." 21 I'm not talking to the FBI, and if you're Tell Robert Mueller to go fuck Are these the words of a man who believes that he's told 22 the truth? Is this what Roger Stone would be doing if he was 23 trying to be truthful with Congress? 24 Of course not. Of course not. 25 Why is Roger Stone telling Randy Credico to plead the Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 46 of 126 1143 1 Fifth? 2 his Frank Pentangeli, because he wants Congress to know the 3 truth? 4 Why is Roger Stone telling Randy Credico to practice No. A person acting in good faith would not say and do 5 the things that Roger Stone said and did in 2018. And the fact 6 that Stone did say and do all of those things shows you exactly 7 what was in his head all along, to obstruct the committee's 8 investigation. 9 THE COURT: All right. 10 MR. ROGOW: I would like five minutes. 11 THE COURT: I think that's a good idea before we go 12 to the next closing. 13 I think we're going to do it between these two arguments, and 14 then we'll go straight from the defense argument into the 15 rebuttal. 16 We need to take a break at some point, so So members of the jury, we'll take a break and we'll 17 resume at 2:25. The case still has yet to be submitted to you 18 for your decision, so you may not discuss it with each other. 19 Everyone else can remain seated, and we'll resume at 2:25. 20 (Jury excused.) 21 (Recess 2:15) 22 (Proceedings resumed at 2:30 p.m.) 23 24 25 THE COURT: Defense ready? All right, can we bring the jury in? Okay, let's do it. (Jury present.) Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 47 of 126 THE COURT: 1 MR. ROGOW: 3 5 All right, Mr. Rogow, you can proceed. CLOSING ARGUMENT BY MR. ROGOW 2 4 1144 I'm Bruce Rogow, and I'll be doing the closing for Mr. Stone. This is a grave responsibility that you all have. The 6 Constitution has given you this responsibility, and the 7 Constitution is a restraint on governmental power. 8 you have in this case is a situation in which the restraint on 9 governmental power is appropriate for you to consider. 10 The Judge will be giving you instructions. And what One of those 11 instructions is going to be that "reasonable doubt" means that 12 you would not hesitate in the most important of your family 13 matters. 14 Judge will give you. 15 That's the definition of reasonable doubt that the So if you hesitate about your conclusions in this matter, 16 then you have a reasonable doubt. And my job is to create for 17 you the reasons why you should have a reasonable doubt. 18 The government has given a very energetic argument about 19 why they think Mr. Stone is guilty of these various offenses, 20 but it begins from a very flawed purpose, and that flawed 21 purpose actually began in the opening statement when they said 22 the reason for Mr. Stone to have lied was to protect Mr. Trump 23 and the Trump campaign. 24 sense, and I'll tell you why. 25 That is absolutely false. It makes no First of all, he was testifying in September 2017. The Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 48 of 126 1 Trump campaign was long since over. 2 elected. 3 to protect Mr. Trump from? 4 1145 Mr. Trump had been So what was there a need to protect the campaign or Nothing actually. And even beyond that, beyond that, 5 there was nothing illegal about the campaign being interested 6 in information that WikiLeaks was going to be sending out. 7 Mr. Bannon and Mr. Gates told you about that. 8 what happens in campaigns. 9 information. This is They look for opposition It happens every day. It happens in every 10 campaign, be it a city commission campaign or be it a president 11 of the United States campaign. 12 So there was no purpose for Mr. Stone to have to lie about 13 anything to protect the campaign when the campaign was doing 14 nothing wrong in being interested in this information. 15 And of course they were interested in WikiLeaks 16 information. By the same token, Ms. Clinton's campaign would 17 have been interested and was interested obviously in opposition 18 research that would have affected the Trump campaign. 19 So right away, the premise that he lied for that purpose 20 is an absolutely flawed premise, has no basis in common sense 21 even, when one understands the political nature of our society 22 and our democracy. 23 So that's the first thing I want to start with. 24 Everything that they've said here flows from that theory that 25 they have about why Mr. Stone would lie. Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 49 of 126 1146 Before I get to the details of what I want to talk to you 1 2 about, I want to go over their production that they gave you, 3 the PowerPoint, and we have edited that only -- no changes to 4 what they said, but edited that to put in our comments. So, Ms. Routman, if you would put up page 1 from our 5 6 excerpt of what they have put up. This is from the government's PowerPoint presentation a 7 8 few minutes ago. So in red are our comments on it. 9 And the blocked-out 10 part that they started with, we embrace. 11 the committees's inquiry, Russian cyber activity, Russian 12 materials, Russian leaks between the campaigns and Russia, not 13 WikiLeaks, not Assange, because there's nothing illegal about 14 that. 15 So what are they saying? What is the scope of This is the focus of the 16 committee. I'm going to come back to that because one of the 17 problems in this case is the committee itself, and the 18 committee's criteria and the committee's reasons as they 19 stated. 20 investigating. 21 activities. They're publicly stated parameters for what they were They were investigating Russia, Russia 22 And so our comment is that this -- the definition of 23 active measures comes later in the committee report, something 24 that the government has said to you is meaningless because the 25 committee report is not being offered for the truth of anything Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 50 of 126 1 that is said. 2 committee report. 1147 But there's a definition later on in the 3 If you read the excerpts from the committee report, 4 because you will have it, you will see that it's later on, in 5 March of 2018, not in September 2017, when there is some 6 further definition of what they're looking at. 7 This is an important point because this whole problem 8 starts with an issue that's created by the committee when they 9 set their criteria and their parameters and they -- and they 10 11 had Mr. Stone in front of them. And I'll talk to you about how he came in front of them, 12 and what happened before he got in front of them, that sets the 13 stage for Mr. Stone's state of mind, because his state of mind 14 is important here. 15 second, but let's go through what the government has done. And I'll talk to you about that in a 16 Flip the page, the second page that we have. 17 This is their Exhibit 211, and this is the Randy Credico 18 June 17, 2016, Twitter, I think, maybe it's a text, I don't 19 know what it is, but the government provided a tweet from July 20 here, but Credico was tweeting about it back in June. 21 So the government has talked to you about a tweet from 22 Credico in July, but he was talking about it in June. By the 23 way, as I recall the testimony from Credico, it was all public 24 information that he had. 25 information. In fact, everybody here had public Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 51 of 126 1 1148 If you take a look now at the next page, and this comes to 2 the Julian Assange exhibit, Exhibit 1, page 59, Mr. Gowdy's 3 question: 4 cross-examined, and we can test and probe the conversation that 5 he may or may not have had with Julian Assange, and Mr. Stone 6 complied and provided the name Credico so that the committee 7 could examine him and cross-examine him. 8 9 Because this is someone that can be examined and I will talk to you later about why Credico took the Fifth Amendment. It wasn't at his doing. All of this exchange 10 between the two of them, that's out there from the beginning 11 when we did our opening statement. 12 hidden here. 13 dispute about who said what to who. 14 is what conclusions you draw from it. 15 I told you there's nothing All of these words are out there. It's there. There's no The question If we flip the page, the same thing, Exhibit 1, page 81 16 that's showing up now, when the committee followed up and asked 17 Mr. Stone, he provided the name, he provided Credico's name. 18 You are going to hear from me about Credico and what kind of 19 take you should have on Mr. Credico and his testimony. 20 Flip it again, the next page, Exhibit 35. 21 These two people did not testify. 22 23 They're not here. That's all I'm going to say about that. So you can flip to the very next page, but it's an 24 important point. 25 Exhibit 36. Once again, the same fact that's here, Look at what we have shown in terms of -- I think Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 52 of 126 1 I'm on -- I'm missing a page. 2 three of these pages have the same critique from us. 3 1149 Thirty-seven, again, two or You know, sometimes in law a statement is made, and then 4 there's something called a per contra, where the other side 5 makes a statement that controverts what is said. 6 really what we're doing here in showing you these various red 7 comments on what the government's exhibit is. 8 9 Then look at the next one. this say. And that's This is page 8, and what does This says, in looking at the last sentence: As 10 recently confirmed by Assange, a reporter, he, Stone, didn't 11 say anything I hadn't been saying. 12 13 14 15 This is something that's plain words in front of you, and you can draw your own conclusions from that. Exhibit 58, this is the key component of how Credico deceived Mr. Stone. 16 But what is the key component? 17 annoyed Credico was using her name. 18 here, but what does this prove? 19 manipulator, Credico manipulated and annoyed Margaret Kunstler. 20 I'll talk to you more about Margaret Kunstler and Credico. 21 That Ms. Kunstler was Yes, we have this exchange This proves that Credico was a This is page 10 of our assessment of the exhibit that the 22 government has put on: "Please ask Assange for any state or 23 HRC email from August 10 to August 30, particularly on 24 August 20, 2011, that mentions Dr. R.K. Paul. 25 There is no mention of Russia here. This has nothing to Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 53 of 126 1150 1 do with Russia. 2 with Libya. 3 made a big point about, what that exhibit shows is that his 4 question, Mr. Stone's question to Credico, dealt with something 5 that happened years ago, and hoping to get information perhaps 6 on something that would be helpful in terms of what had 7 occurred in Libya and whether or not there had been some 8 actions taken by some people and -- because Credico had said 9 that his friend Margaret Kunstler had this kind of access, this 10 This is about something that happened in 2011 If you take a look at this exhibit which they have was sent to Credico. 11 But there's nothing in here at all about Russia. 12 about Russia, no communication with regard to Russia. 13 The next page 11 from our sequence of it: Nothing Did you discuss 14 your conversations with an intermediary, with anyone involved 15 in the Trump campaign? 16 There's no evidence that Mr. Stone ever discussed -- and 17 this is our red block -- conversations with the Trump campaign, 18 these conversations with the, quote, intermediary. 19 What is in evidence, and we don't run from it, is that 20 yes, he talked to Bannon; yes, he talked to Gates; yes, the 21 campaign was interested in this, but there is not one 22 scintilla, one hint of evidence that there is any kind of 23 mention of the, quote, conversation with intermediary because 24 there were none. 25 And because there were none, what does that make this Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 54 of 126 1151 1 exhibit? 2 to hesitate because it is the heart of one of their counts that 3 he talked to the campaign. 4 did talk to the campaign, but there was no conversation with 5 the intermediary. 6 It makes this exhibit something that should cause you But I've already told you, yes, he So am I holding the government to a high standard in terms 7 of what they said, the words they use, and whether or not they 8 can prove the words they use? 9 Yes, I am. But that's how you have to look at it too. 10 Because this is a situation in which you will make the final 11 decision under those instructions that I've talked to you 12 about. 13 Now, take a look at the next one, Exhibit 101, all of 14 these calls. 15 these calls, no evidence in what was said in any of the calls. 16 Any of the charts which talk about calls, there is no evidence 17 of the content of those calls. 18 There is no evidence of what was said in any of So the government is asking you to draw some kind of an 19 inference from these calls, but how can you draw an inference 20 from these calls when you have no idea of what was said in 21 these calls and there is no evidence at all that suggests what 22 was said in these calls other than the kind of inference they 23 want you to draw from timing of some of the calls. 24 25 If you take a look at the next, this is their Exhibit 148, again, no evidence present -- no evidence presented regarding Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 55 of 126 1 2 1152 the subject matter or content of these calls. So you're being asked, you're being asked in a situation 3 where you have to make an important decision, an important 4 decision that is likened to a decision in the most important 5 matters in your family. 6 have a reasonable doubt, and they're asking you to overcome 7 that by showing you a list of calls and not being able to tell 8 you what those calls were about. 9 10 And if you hesitate, then you would How would anyone make a decision without knowing what the calls were about and what was said. 11 Then take a look at next page, which is our page 14. 12 government provided no evidence as to the meaning of this 13 email. 14 15 16 The This is to save Trump's ass. What does that mean? about that? Why is there something nefarious Why is there something malignant about that? There is nothing malignant about that. It's a campaign. 17 Maybe it's a little crude in terms of the way it is stated, but 18 again, the content of it, the meaning of it, it's not there. 19 So what is the government asking; that you draw some 20 inference from this. 21 you draw an inference from a short statement like this and 22 having no knowledge at all about what it meant because no one 23 knows what it means. 24 25 But again, you have to hesitate before And look at the next page, 15. Exhibit 32: This, this is their A load every week going forward. The government Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 56 of 126 1 put on no evidence to show that this information was not 2 already in the public domain. 3 1153 And if you look at all of the exhibits, if you listen to 4 all of the testimony, if you listen to Margaret Kunstler and 5 you listen to Randy Credico, what you will hear is that no one 6 but Julian Assange knew when he was going to put something out. 7 And so to have this "a load every week going forward" when 8 Julian Assange -- and we went through this interview before in 9 a prior page -- on June 12, 2016 said he had information, after 10 that it was open the door to everybody. 11 make some guesses about what Julian Assange might have, about 12 what WikiLeaks would be putting out. 13 Everybody could then WikiLeaks does not announce these things until they 14 announce these things. And Assange, on June 12, giving the 15 heads-up that they had something, that opened the door. 16 What did it open the door for? 17 It opened the door for a whole host of people to be taking 18 the credit, thinking they knew what was going to happen. 19 it was an easy play for everybody because you just had to wait 20 and see what Assange as was going to do. 21 again, by the way, in the testimony, and you've heard it, you 22 have seen the exhibits, there were things, a dump was going to 23 occur in two weeks. 24 exchange with Bannon, that what happened, then he heckled Stone 25 because nothing happened. It didn't occur. But And over and over There was that one Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 57 of 126 1154 Sure he heckled Stone, because Stone didn't know when 1 2 anything was going to happen. Stone is reading it like 3 everybody is reading it. 4 heckled Stone, all that shows is that Stone doesn't know 5 anything. So when Bannon is disappointed and 6 Now, does the campaign like to think that he did? 7 And did Stone like to think that the campaign thought he 8 did? Sure. Sure. But that doesn't prove anything, and it sure doesn't prove 9 10 anything about the campaign and the Russia connection. 11 was nothing, nothing that Bannon said, nothing that Gates said, 12 that tied Stone to any Russian investigation, that tied the 13 campaign to a Russian investigation. And look at Exhibit 31. 14 There This is Eric Prince, who by the 15 way, one of the counts is that this conversation with Prince 16 was a conversation about -- a conversation with a campaign 17 person. 18 this afternoon too, was not a member of the Trump campaign. Prince -- Eric Prince was not, I think you heard it Was he a supporter? 19 Yes, but he was not on the campaign 20 team. 21 these other people, the two Millers that were mentioned, I 22 think, by Gates or Bannon. 23 He was not a Bannon, he was not a Gates. He was not So Prince is a supporter, so that certainly doesn't 24 establish at all a conversation with the campaign. 25 that, nothing about Russia, nothing about Russia. But beyond Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 58 of 126 1155 And then this last, next to last exhibit, or third to last 1 2 exhibit, Exhibit 34, well done. The government is asking you 3 to take from this snippet, "Well done." 4 who the participants are, and there's no evidence to explain 5 this. 6 author is on this. They don't put the author out. It doesn't even say I don't see who the 7 So what kind of inference can you draw from that? 8 And that is a thread throughout so much of the evidence in 9 10 this case. It is based on surmisal and it's based on inferences, but no content. 11 "Well done," what does that mean? 12 Oh, they're going to say, "Well, it comes after a certain 13 14 time." Could have been they went to a steakhouse and they wanted 15 to order steak well done. 16 means, but that's the difficulty of this. 17 Why would a decision be made based on this kind of thin, 18 very thin evidence? 19 statement, "Well done." 20 There's no way of knowing what this Is it even evidence? Now, look at the charts, R-18. It's just one little All of these charts about 21 the telephone calls, it's impressive when you look at that, 22 communications Roger Stone and Randy Credico, text, twitter, 23 Facebook, SIGNAL, email. 24 But what is it about? 25 It doesn't say what it's about. There's no way of knowing Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 59 of 126 1156 1 that. 2 there's something malignant, something illegal that's going on 3 in that, that's a stretch far to far, and one that's not 4 proper. 5 that you wouldn't hesitate in the most important of your 6 matters. 7 Once again, to take from this an inference and again One that is a concept of you have to be so convinced And so there's the four pillars. I'm going to get to the 8 four pillars because it's an important part of this. It really 9 has to do with the mindset of Roger Stone when he came before 10 the committee. 11 on their chart nothing, it doesn't say anything about Russia, 12 it doesn't have any kind of connection to Russia, and then the 13 written communications between Roger Stone and Randy Credico. 14 But I'm just pointing it out to you here that I don't recall whether or not the government did anything 15 about this footnote that's in red: 16 September 26th. 17 this communication with Credico. All messages sent on They did say that after the hearing he had 18 And what's the matter with that? 19 Look, there's almost nothing beforehand, and then he has 20 these communications with Credico, but it was afternoon -- all 21 messages sent on September 26th, that's the day of the 22 committee hearing, were sent after the hearing concluded. 23 24 25 Doesn't it make sense, now he talks to Credico, nothing wrong with that. Again, nothing malignant about that. Look at the last page, the effect on the proceeding. This Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 60 of 126 1157 1 is the governments putting together in their mind and passing 2 it off to you about what they think the effect on the 3 proceeding was, government's guess as to the effect on the 4 proceeding. There's no evidence about the effect other than the 5 6 inferences that they're asking you to draw. 7 never saw documents. 8 they were not about Russian interference, and the committee 9 never subpoenaed them. 10 September 26th. 11 wanted to do. The committee The documents were not relevant because The committee didn't end on They had the opportunity to do what they Now, of course, the government is saying: 12 Well, Mr. Stone 13 kept them from that opportunity by not revealing certain 14 things. The committee had information. 15 It could have been 16 proceeded any way it wanted. It could have subpoenaed, it 17 could have invited, it could have done a lot of things. 18 this is the government conclusion, not a conclusion that you 19 can draw from the evidence that's in, because there is no 20 evidence really with regard to this. The committee never heard from Corsi. 21 So Mr. Stone did 22 mention his name in the transcript. 23 him. 24 Credico, and I've got to treat Credico separately here because 25 I know a big part of their argument is, they didn't hear from But he wasn't called. They could have called The committee never heard from Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 61 of 126 1158 1 Credico because Mr. Stone threatened him and tampered with him 2 and kept him from testifying. 3 I'm going to address that shortly. That's not going to be so, and The committee never heard about the campaign. 4 Well, you 5 know this goes back to their flawed premise to begin with, that 6 he was trying to hide to protect Trump a year after, while he 7 is the president, from this interest that the campaign had in 8 WikiLeaks in 2016 before the election? Again, where I started, it makes no sense. 9 Mr. Trump had 10 a lot of other things on his mind by the time Mr. Stone was 11 testifying before the committee. 12 States. What is he going to be protected from by Mr. Stone being 13 14 He's president of the United candid about contacts with the campaign? There's no reason not to be, not to be open about it. 15 16 Because, though, the contacts with the campaign had nothing to 17 do, the Gates, the Bannon stuff had nothing to do with Russian 18 interference. And that takes us to where I'm going to have to start with 19 20 you and take a look at the text messages, the next red box on 21 this: 22 within the four pillars, and report contains inaccuracies, 23 that's the March 2018 report, contains inaccuracies. 24 know what the inaccuracies are, but just to say that does not 25 make a compelling case for finding fault with what happened and Stone provided everything that was requested and was I don't Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 62 of 126 1 2 1159 how Mr. Stone came before the committee. And that's where I want to start now, because the question 3 you have to ask yourself: What kind of person -- why would 4 Stone lie; why would he make stuff up; why would he volunteer 5 to testify? 6 Why would he request that the testimony be made public or 7 be in public; why would Stone produce documents as he did; why 8 would Stone offer to look for more documents? 9 What benefit would it be to Stone to testify in a closed 10 hearing? 11 you look -- and I've mentioned them to you before, and I'll 12 mention these exhibit numbers in a moment, because you are 13 going to go back, you are going have all of these exhibits, you 14 can pour through all of this. 15 16 17 18 19 That to me is the starting point of all of this. If Why would he voluntarily go in and testify and go and answer the committee's questions and lie about them? There is no purpose. There is no reason. There is no motive. They've charged him with several crimes. When people 20 commit a crime, they have a motive. If they rob a bank, they 21 want money. 22 save money on their taxes. 23 a motive that someone has to do something, and that something 24 turns out to be illegal. 25 purpose for Mr. Stone to have done this. If they file a false tax return, then they want to All of these things are based upon There is no motive for Mr. Stone, no Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 63 of 126 1160 1 So what happened, how did it begin? 2 Well, it begins with a series of letters from his counsel, 3 writing to the committee, he would voluntarily testify. 4 they accept the offer from Mr. Stone. 5 And But what's critical about it, and when you look at each 6 one of those document, the series of letters from Mr. Buschel 7 to the committee, from Mr. Smith to the committee, it always 8 addresses the publicly announced parameters, the publicly 9 announced criteria. Two of them, the last two have to do with 10 whether or not our American interests were sufficiently 11 protected by our own public agencies, but the first two are the 12 ones that are in play here. 13 Russian activities. Russian activities. And it's true 14 that Mr. Stone acknowledged that there's some people who 15 thought that there are Russian activities. 16 that Russia was behind it. 17 have here. 18 He didn't think But that begs the question that we What we have here is, when he went in with over and over 19 again repeatedly the publicly announced perimeters, the 20 publicly announced criteria, he came into a situation in which 21 he was answering questions with that in mind, did he have 22 information about Russian interference. 23 about Russian interference. He had no information 24 What reason was there to hide? 25 Well, the only reasons, the ones I gave you before, about Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 64 of 126 1161 1 the fact that they thought he wanted to protect the campaign, 2 and that is a nonstarter. 3 makes no sense. As I said two or three times, it 4 So look at the lead in to his September 26th testimony. 5 It is insisted upon and it's confirmed by the committee that 6 they will be asking questions within the confines of the 7 criteria parameters, Russian interference. 8 Mr. Stone's state of mind. 9 questions. 10 So that takes us to That's how he was answering the And I just want to give you an example because I'm not 11 going to run from these questions that were asked, and the 12 various counts. 13 to add the clause that is a critical clause in terms of how 14 Mr. Stone was thinking when he was answered these questions. 15 Here are some of the questions, and I'm going One of the things the government say: Stone testified 16 falsely that he did not have emails with third parties about 17 the head of Organization 1, and that he did not have any 18 documents, emails or text messages that refer to the head of 19 Organization 1. 20 21 22 And the answer to that is: That's true, not about Russia. Not about Russia. Had the committee asked him the question, "do you have any 23 information that's beyond the parameters," he would have said, 24 as he said oftentimes in the transcript and in the audio that 25 you heard: According to the parameters, according to the Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 65 of 126 1 2 1162 criteria. By the way, it wasn't just Mr. Stone that was using those 3 terms. 4 Russian cyber activity and other active measures were directed 5 against the United States and its allies? 6 active measures include links between Russia and individuals 7 associated with political campaigns or any other U.S. persons," 8 Russia, Russia, this whole thing is about Russia. 9 see in their criteria anything about Assange. 10 11 12 If you go back and listen and hear the terms; what Did the Russian You don't And they're going to say, well, Mr. Stone mentioned something about WikiLeaks in his opening statements. Mr. Stone is smart. He understands that there may be 13 somebody out there who makes this connection, and maybe even 14 some members of the committee might make this connection, but 15 that's not what they brought him in for under the parameters 16 that they created. 17 They made it that way. You know, we talked, and I'll talk a little bit later too, 18 about the Godfather. 19 to know Cool Hand Luke. 20 famous lines, I don't see any response and maybe I'm out of my 21 here with that -- one of the famous lines that the prison guard 22 says to Paul Newman is: 23 communicate." 24 25 I don't know if any of you are old enough In Cool Hand Luke, one of the most "What we've got here is a failure to And that's really what we're talking about here, a failure to communicate, a failure by the committee, by virtue of the Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 66 of 126 1163 1 way they set up their criteria, and a failure of the committee 2 to acknowledge and recognize and hue to the criteria that they 3 set. And you heard the audio yesterday, and again, you'll have 4 5 the whole audio to hear. 6 is it, it's over 500 questions, over 500 questions asked in the 7 period of about two and a half hours, and Mr. Stone is 8 responsive to those questions. 9 you. 10 11 It's three hours. By the way, what And we played some them for I don't know if you are going to want to go back and listen to them all. But I think it's interesting, if you are going to make a 12 decision about his truthfulness, if you are going to make a 13 decision about how he responded, there is something to be said 14 for listening to all three hours. 15 The government has plucked out a half a dozen questions 16 and answers. 17 think it was probably closer to 600 questions. 18 cherry-picking they are trying to make the case that Mr. Stone 19 intentionally, corruptly, with some kind of intent to mislead, 20 gave these answers. 21 They have cherry-picked through these 500, I From that But if you see the answers in the context of the criteria, 22 Russian collusion, then I think you would come to a different 23 question -- a different answer. 24 hesitate about what's going on here. 25 At the least would you So what evidence did we have in the case? Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 67 of 126 1 1164 There really wasn't a lot of evidence in terms of the 2 witness testifying. 3 out the exhibits that the government had. 4 was not a factual testimony. 5 Here is what we have, here are the exhibits, that all of them, 6 I think, have been agreed to. 7 Michelle Taylor testified, and she brought What she was testifying to was: Again, nothing was being hidden, nobody was fighting. 8 These exhibits are there. 9 fair game for you to look at them all. 10 11 And her testimony What was said was said, and it's So that was Michelle Taylor's testimony. Then we come to the next witness, which was Randy Credico. 12 I think the government portrayed Mr. Credico properly. He is 13 an interesting character, but there's no question that Randy 14 Credico played Roger Stone. There's no question that Randy 15 Credico misled Roger Stone. There's no question that Randy 16 Credico used his connection to Margaret Kunstler to further 17 play Roger Stone. 18 So what does Credico play in this whole thing? 19 Roger Stone was getting information from Credico that was 20 public information. 21 information, but how much did he play him? 22 23 24 25 And Credico says that now, it was public He was in England. Remember the pictures of Credico before, in front of the Ecuadorian embassy? And he's sending that to Stone, and he's telling Stone the same thing that Corsi is telling Stone, something is going to Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 68 of 126 1 happen. 2 Credico was manipulating Roger Stone. 1165 But none of that proves anything except that Randy 3 Now, the government is going to say: No, Roger Stone is 4 too smooth to be manipulated by Randy Credico. 5 But they have a long history, a long history that began -- 6 and this is an important part -- a long history that began when 7 Randy Credico and Roger Stone worked together on liberal 8 causes. And this becomes important because Roger Stone -- I mean 9 10 Randy Credico, as he said to you, was -- I think he said he was 11 a lefty. 12 going do a Bernie Sanders imitation. 13 not really amusing in the context of serious criminal 14 prosecution like this is. I think when he was going do his imitations, he was It's amusing, but it's So here is Randy Credico, sending these emails to Roger 15 16 Stone, sending him pictures of himself in the Ecuadorian 17 embassy. 18 that's not private information, it's not Julian Assange 19 information. 20 And Roger Stone is getting information from him It's public information. And so here we have Randy Credico being really kind of a 21 lynchpin of the government. So much of what you hear, what the 22 government talking about is Randy Credico. 23 is: 24 kind of inference was Roger Stone drawing from getting these 25 kinds of emails and information from somebody who was very But the bottom line What kind of thing was he telling Roger Stone, and what Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 69 of 126 1 close to Margaret Kunstler, and Margaret Kunstler had a 2 connection to WikiLeaks and a connection to Assange. 3 4 5 1166 So he was the next witness after Michelle Taylor, and what did he add to the case? A confusing kind of picture, one about the kind of person 6 that he was, about the kind of role that he played, about the 7 kind of way he portrayed himself to Roger Stone. 8 9 Yes, I acknowledge all of these emails, texts and things that were in afterwards, but all of those are part of the 10 evidence that you will have to look at and draw some 11 conclusions whether or not Roger Stone had an intent, a need to 12 lie about Credico, when Credico was feeding him all of this 13 stuff. 14 So that was the second witness. And then we had Margaret 15 Kunstler after that. Margaret Kunstler was surprised and 16 shocked that Credico had used her name in sending an email to 17 her and blind copying Roger Stone. 18 Do you remember that? 19 That had to do with the Libya inquiry that Roger Stone has 20 made of Credico. 21 And what does he do? 22 Credico sends an email to Margaret Kunstler, who says: 23 24 25 I'm not doing anything, forget it, there's nothing. She didn't even read beyond the header I think she testified to, but it was a blind copy to Roger Stone. Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 70 of 126 Why? 1 1167 To kind of hook Roger Stone in to thinking that 2 Credico had this connection, and this connection could then be 3 used. 4 What kind of person is that to abuse his friend? 5 And that's what he did, he abused his friends. You heard 6 Margaret Kunstler say that she was annoyed by it, and then she 7 went on and said something else about her annoyance. 8 important thing is, she did not like it, and this was something 9 that Credico did to Margaret Kunstler. 10 But the So we had Credico, and we'll come back to Credico in a few 11 minutes, but that's part of the setting with Credico, joking, 12 making fun of some things, but still an important witness in 13 this case, an important witness who, I think, one would 14 conclude from listening to him and watching him, he's not the 15 kind of person that you would trust with the important matters 16 in your life without hesitation. 17 testimony -- for his testimony and the government's use of it. 18 19 20 That's a problem for their Then what do we have after that, we have Steve Bannon. This takes me to the beginning of where I started. Bannon says, yeah, he thought Roger Stone had the 21 connection, had inside information. There was never any 22 conversation. 23 with Roger Stone about who Roger Stone was talking to. 24 element of the government's case is completely flattened by 25 Bannon's testimony. He never testified that there was conversation So that Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 71 of 126 But again I come back to: 1 1168 So what; so what, that they 2 were interested in this. And he was actually pleased, of 3 course, they wanted to get that information, and Gates, of 4 course, wanted the same information. 5 think Gates said that they were happy. 6 the description that Gates used in terms of this information 7 becoming available. 8 forthcoming when they wanted, but they were pleased with it. Gates was pleased to. I I think happiness was Disappointed when it didn't, it wasn't And now we come to this very, very thin read that the 9 10 government is asking you that is the foundation for their whole 11 theory about why Roger Stone lied, to protect the campaign and 12 to protect Donald Trump. What read is it built on; it's built on Gates saying that 13 14 he -- he heard Roger Stone's voice. 15 description, it was a Suburban, two secret servicemen in the 16 front, Donald Trump in the center, and Gates relegated to the 17 back. 18 call is about. 19 more coming. And there's a telephone call. It was an accurate Nobody knows what that Afterwards, Gates says Trump says there'll be 20 What does that mean? 21 This kind of ambiguity, you didn't hear the conversation, 22 how do you build a case on something that the party whose 23 trying to build it, the government, and I guess Gates through 24 his connection now to the government, how do you build a case 25 on something that nobody knows what was said? Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 72 of 126 1 1169 Nobody knows what was said, and it said in a Suburban, and 2 he's sitting in the back of the Suburban. 3 know Suburbans and driving them from Trump Tower to LaGuardia, 4 it's noisy. 5 kinds of noise. 6 conclusion that it this a call from Stone to Trump. 7 think that's a read that will support anything. 8 9 It's noisy. I don't know if you There's a lot of road noise and all And from that, they are trying to draw some Let me go beyond that: I don't Even if it did, what's the matter with that, what is the matter with that. There is nothing 10 illegal about that. 11 information that was published by WikiLeaks, it was information 12 that was publicly known. 13 This was not information -- if there was So if -- and I'm not saying this happened, I'm doing two 14 things with this. 15 somebody of something when you don't know what the call is, 16 when the person who's telling you that this occurred is the 17 person who has a cooperation agreement with the government, a 18 cooperation agreement with the government that could lead to 19 him getting probation for all the crimes he committed, a person 20 who admitted that he stole money from Manafort and didn't pay 21 the taxes on the money he stole. 22 I'm showing you, one, how can you convince So this is the person on whom the government is imposing 23 its -- or reposing its belief that there is some connection 24 with the campaign. 25 But even as I said, even if so, so what, so what. In Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 73 of 126 1170 1 fact, so much of this case deals with that question that you 2 need ask: So in that situation you have Gates, and then he was the 3 4 So what? last witness before Michelle Taylor, who came back on again. 5 What did she come back and do, something about Guccifer. 6 And I asked her whether or not Guccifer was Russian. 7 And she said: 8 Fine, there's nothing that shows Guccifer is Russian. 9 But beyond that -- Honestly, I don't know. 10 MR. KRAVIS: 11 THE COURT: Sustained. MR. ROGOW: It's not, okay. 12 13 14 15 Objection. That was not an issue in this case. But beyond that, I asked her: Did Roger Stone turn over his emails with Guccifer. 16 And the answer was yes. 17 Did she know of any more information about Guccifer from 18 Stone's materials? 19 The answer was no. 20 And then -- and this will take me back to the Frank 21 Pentangeli -- then she had a transcript of the Pentangeli call, 22 which you can see was -- is a big feature of their case, a big 23 feature of their tampering case with regard to Credico. 24 So she said that -- I think she said that she had watched 25 the movie last night or the night before, and so there she is, Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 74 of 126 1171 1 watching the movie to tell us what is already told to us by 2 Credico about what how he perceived Frank Pentangeli and that 3 portion of the movie. 4 But the government, the government is blowing that up to 5 be some important critical part of their case in terms of 6 whether or not Mr. Stone tampered with Mr. Credico. 7 Tampered, these two guys tampered with one another for 8 20 years. They tampered with one another for 20 years over all 9 kinds of crazy things. And the exchanges between them, and I 10 told you this when we did the opening statements, it was crude, 11 it was odious. 12 but that's the way these two guys operated. 13 And by the way, they remained friends. They used language that is terrible language, I mean, you had 14 Stone on -- on his -- on Credico's show, talking on his show. 15 He thought Stone was a good interview on his show. 16 Stone on his show. 17 The incident that they talk about, the incident from 2011 18 with Spitzer, that didn't get in the way of Credico. 19 had long since been passed that. 20 21 22 He wanted Now he's saying: Credico Oh, well, it kind of reminded me of something like that. This is another thin read. This is the kind of thing that 23 in the most important of your matters you would have no 24 hesitation in coming to a conclusion, and you got a 25 relationship with these two guys that has gone on for so long, Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 75 of 126 1172 1 been so crude, been exchanging all kinds of kibitzing with one 2 another, no. What is the Pentangeli thing, what is this tampering 3 4 thing. Well, here is something: 5 Go look at the tweets. When 6 Credico goes to England -- and he goes for some show, I don't 7 remember the name of the show -- he goes for some show, and 8 then he has these pictures taken of him in front of -- in front 9 of the Ecuadorian embassy. 10 And then he even says, as I recall, that he was delivering a letter to Assange. 11 I thought this was actually a funny part, although I 12 didn't quite understand the connection, but a hand reached out 13 from the door and took the letter, and that's as far as he got 14 with Assange. But the letter was not about anything about WikiLeaks. 15 16 The letter was from the general manager of his radio station, 17 WBAI, I think it is, hoping to get Assange to do a weekly radio 18 show. So now he's playing, he's playing Stone again in another 19 20 way. 21 about Assange, it was not a letter about WikiLeaks, it was 22 completely different. 23 He's there to deliver a letter, but it was not a letter And of course he didn't get in, not even for the letter, 24 not even for this, this kind of neutral thing, offering Assange 25 a what, a job? I don't know what he was offering him, but an Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 76 of 126 1 2 opportunity to be on the radio show. And then Credico flying back, and if you look at the 3 tweets, the first thing that you will see in terms of 4 The Godfather is Credico saying he watched, watched 5 Godfather II. 6 1173 So on the plane he watched Godfather II. This was not something initiated by Stone. Although over 7 the years, of course, Stone and Credico had joked about The 8 Godfather. 9 The Godfather takeoffs happened over and over. It's a comic thing, The Godfather scenes and 10 happening now. 11 publication or even a movie, who knows. 12 And they're I think is another kind of story about it, or But the point is, this was something that was just back 13 and forth between them. 14 nothing corrupt, nothing trying to influence anything other 15 than that Credico invoking The Godfather, telling him about it. 16 I think he said the five families. 17 18 19 There was again nothing malignant, So yes, so later on Stone said: Godfather, Pentangeli, do a Pentangeli. Well, Stone [sic] had done Pentangeli. Stone is an 20 impressionist, he can do Pentangeli. But the issue here is 21 whether or not Stone was tampering with this witness, trying to 22 bring about a result. 23 result was brought about not by Roger Stone, the result was 24 brought by, as Credico says, there were thousands of reasons 25 for him to take the Fifth Amendment. The interesting thing here is, the Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 77 of 126 1 1174 He met with lawyers, he met with reporters, with friends, 2 time after time after time to discuss what to do, whether or 3 not he should take the Fifth Amendment. 4 And he made a decision. He told his lawyer there was no 5 evidence, that he told his lawyer or that he told these people 6 that Roger Stone is the reason why he was taking -- 7 MR. KRAVIS: 8 THE COURT: 9 10 Objection. It is true he was not asked to talk about what he told his lawyer, but there was no evidence that he told anyone else that it was because of Roger Stone. 11 MR. ROGOW: I'm sorry, I didn't hear, Your Honor. 12 THE COURT: I think you can't say there is no 13 evidence what he told his lawyer because we didn't ask him to 14 tell us what he told his lawyers, but you can say there's no 15 evidence that he did it because of Roger Stone. 16 argument, you can make that argument. 17 MR. ROGOW: That's your That is my argument. 18 There's no evidence that he did it because of Roger Stone. 19 So what do we have here? 20 We have no motive to lie because protecting the campaign 21 is a nonissue, in reality, although the government for some 22 reason thinks that it is a reason to lie. 23 We have no intermediaries that have shown up. We have 24 Mr. Credico admitting he was trying to make Stone think that he 25 was a big guy, he was -- I think he used the language Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 78 of 126 1 one-upping: 2 that he was a big man. 3 into the embassy. 4 more than he -- than he knew. 5 6 7 8 9 I was one-upping Mr. Stone, making Stone think He wanted Stone to think that he got He wanted Stone to think that Credico knew He had no knowledge, he had no knowledge of Assange releases. He said that and we agree, now that we know. He told Lugo, David Lugo, who was doing a documentary or something, that he was the connection. How many times did he lie to Stone? 10 Many times. 11 But why did he back out? 12 13 1175 Why was it smart for him to take the Fifth Amendment? Because he did not want to be revealed as having a 14 connection to Donald Trump. 15 didn't like Hillary Clinton either. 16 but he did not want to be outed as somebody who had done stuff 17 that was helpful to Donald Trump. 18 keep himself under cover, because it would ruin his reputation 19 in the liberal community in which he operated. 20 played Stone. 21 You heard that from him. He liked Bernie Sanders, And so that was a reason to So Credico I guess you can say that Stone played the campaign in 22 letting them think that he had some super connection. 23 again, that was their conclusion. 24 he told them: 25 He But There is no testimony that I have an inside to WikiLeaks and Assange. So this is a situation where everybody is drawing their Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 79 of 126 1176 1 own conclusions about things. 2 conclusions, but it doesn't make their conclusions true, it 3 doesn't make their conclusions anything illegal, it doesn't 4 make their conclusions any basis for finding that Roger Stone 5 intentionally lied, intentionally and corruptly lied, 6 intentionally and corruptly tried to get Credico to not 7 testify, when there are all of these other elements surrounding 8 it, all of these things. 9 picture. 10 And they're happy with their It's a huge picture. It's a huge And the government to its credit, because that's its job, 11 has tried to distill it down to this very, very narrow point of 12 five, six acts or so. 13 six hundred questions. 14 Coming out of a transcript with five or And the question for you is: Would you hesitate in the 15 most important of your affairs before you think that Roger 16 Stone did all this with the kind of specific intent that you 17 will be instructed has to be present in order to find Roger 18 Stone guilty. 19 And from the very beginning, when he first made his 20 appearance at the committee, and he made his appearance under 21 the criteria created by the committee, this whole thing went in 22 a fashion that the committee is partially responsible for 23 because of the criteria, because of the questions. 24 25 Go back and listen to these five or six hundred questions, and you'll see how far off base they are in so many ways. And Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 80 of 126 1177 1 you will see and hear -- you will see if you read the 2 transcript, and you will hear if you listen to Roger Stone's 3 voice, this was not the voice of a man who was trying to lie to 4 mislead, to affect the outcome of what the committee was doing. 5 And the committee set the rule, and Roger Stone sought to 6 comply with that rule, over and over again. 7 that transcript, and I mentioned this to you and showed it to 8 you in the opening statement, over and over again you heard the 9 committee say: 10 If you look at Within the criteria, within the parameters set. And those parameters, those two sentences, are critical to 11 your understanding of the case, and your understanding of the 12 relationship between Roger Stone and Credico are critical to 13 your understanding of the case. 14 I think when you put all of that together, they will be 15 critical to your conclusion that you have to hesitate and 16 wonder about what's going on here and why it's going on here. 17 And I'll end with what I started with: There could be no 18 sensible motive in trying to protect the campaign when the 19 campaign was long since over and Mr. Trump was the president of 20 the United States. 21 to lie to cover up. 22 There was no sensible reason at that point The government makes a point about Stone had said 23 something about, "I can't take the Fifth Amendment because of 24 Trump," he didn't say that. 25 committee meeting. He didn't say that in the If you listen to the transcript, and I Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 81 of 126 1178 1 think this is part of what was played yesterday, he said: "I 2 will have to consult with my lawyers. 3 So his idle chatter with Credico about that, they have now 4 blown up to something that they want to convince you, based 5 upon an offhand remarks -- all of these offhand remarks between 6 him and Credico, when under oath when he was asked the question 7 by the committee, he said: 8 lawyer." 9 about that. 10 "I will have to consult with my And the committee never came back and asked him again We think that the evidence is not sufficient, and we don't 11 think that the evidence justifies a finding of guilt against 12 Mr. Stone on any of the counts. 13 based upon the evidence -- you'll have it all there, you can go 14 through it all, you can look at things, and you can look at 15 things in a malevolent way, or you can look at things in a 16 different way, the way I'm suggesting to you, and we think 17 that's the proper way -- you should find Mr. Stone not guilty 18 of all charges. 19 REBUTTAL ARGUMENT BY MR. MARANDO 20 THE COURT: 21 MR. MARANDO: 22 And so what I'm urging you, You can proceed. Thank you, ladies and gentlemen. What you just heard was a lot of smoke and mirrors, a lot 23 of distraction, a lot of introducing issues that aren't really 24 relevant, a lot of ways to make you look over here when you 25 should be looking over there. Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 82 of 126 1 1179 This case is actually much simpler than what was just 2 portrayed to you by Mr. Rogow: 3 congressional committee, did he lie before a congressional 4 committee, did he lie about documents in his possession, did he 5 lie about the existence of Jerome Corsi, did he obstruct that 6 investigation, and did he tamper with a witness? 7 Did Mr. Stone lie in a The evidence here is written down for you. Most of it is 8 written down for you. 9 hear the witnesses, you can assess them, but most of it here is 10 11 12 13 We presented you witnesses. You can in documents. And you know what the great thing about a document is? A document doesn't lie. I'm not going to talk about every single issue that 14 Mr. Rogow brought up, but I'm going to address a few of them. 15 And the first one I want to address is motive. 16 Mr. Rogow spent a lot of time discussing, well, Mr. Stone's 17 motive. 18 need to protect Trump in the campaign. 19 for Mr. Stone to lie. 20 He said, this is Mr. Rogow's words: "There was no There was no purpose Why would Stone lie? Mr. Haley, can I have the overhead projector? 21 THE DEPUTY CLERK: 22 MR. MARANDO: You want Elmo? Yes. 23 As my colleague Aaron Zelinsky said to you when this case 24 first opened a week ago, the reason for Mr. Stone's motive was 25 clear; the truth looked bad for the Trump campaign, and the Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 83 of 126 1 2 3 4 1180 truth looked bad for Donald Trump. Now Mr. Rogow says, well, this all happened after the campaign, after Donald Trump was elected. There was an investigation going on at that time as to 5 whether any nefarious activity occurred during that campaign 6 and whether people that were involved in government or involved 7 in a campaign had colluded or had connections with Russia. 8 9 You don't think if information came out that Mr. Stone, who was a former adviser of Mr. Trump, who was an associate of 10 Mr. Trump, had been spending that time during the campaign 11 trying to fish for information from WikiLeaks, knowing that 12 that information was hacked, possibly by a foreign government, 13 that wouldn't look bad? 14 why he tried to hide it, and the hiding took two forms. 15 16 17 That wouldn't look bad? And that's First, it was hiding the existence of Jerome Corsi. Because Corsi sent him the email, and that email was prescient. Number two, it was finding the perfect patsy who would 18 clam up, who wouldn't talk, who wouldn't go before the 19 committee and tell them what happened. 20 people not talking before the committee, the committee isn't 21 going to find out what campaign was doing regarding WikiLeaks, 22 and that's what this case comes down to. 23 24 25 You got both of those But when it comes to motive, there's an old phrase, a picture's worth a thousand words. Right? Mr. Kravis showed you Government's Exhibit 68; 68 is the Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 84 of 126 1181 1 November 28th email, 2017, where Credico sends his subpoena, 2 where he's been subpoenaed to testify before for the House for 3 Mr. Stone. 4 subpoenaed. 5 So Mr. Stone knows now that Mr. Credico has been Two days later, Mr. Stone sends this text to Mr. Credico, 6 telling Mr. Credico: 7 of Trump, I can never get away asserting my Fifth Amendment 8 rights, but you can. 9 indicted for perjury if you're stupid enough to testify." 10 "If you testify, you're a fool. Because I guarantee you are the one who gets A picture is worth a thousand words. You can begin and 11 end your deliberations here, because what Mr. Stone is telling 12 Mr. Credico right now is: 13 testify; and because of that, I'm going to go have to go, and 14 I'm going to lie; and you can't talk either, because if you 15 talk, my lies will be exposed. I can't go before Congress to 16 Right there, it's written in words for you to see. 17 So Mr. Rogow tries to distract you that there was no 18 motive here to lie. 19 undercuts that. 20 on into Russian active measures in the 2016 presidential 21 election. 22 looking for information that possibly came from Russia, that 23 would look, as Mr. Kravis said, terrible. 24 25 The texts undercut that, your common sense You know that there was an investigation going And if any of this came out, that the campaign was I want to go to the next topic that Mr. Rogow talked about, and that was Russia. Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 85 of 126 1 1182 Mr. Rogow said the whole problem starts -- the whole 2 problem, meaning why we're here, why we're here today in this 3 court -- starts with the committee. 4 not Roger Stone lying about his texts or emails, or tampering 5 with the witness, telling the witness, do a Pentangeli. 6 starts with the committee, because the committee set the 7 parameters. 8 9 10 11 12 He said: Not Roger Stone, mind you, It When my client went in, he came into a situation where he answered questions with the parameters in mind, whether he had information on Russian interference. He even went to far to say that his client, at end of each question, added a clause: Well, not about Russian collusion. 13 Do you have any texts about your intermediary? 14 Well, no, not about Russia. 15 That's nonsense. Mr. Stone knew exactly why he was there 16 that day. Make no mistake. You'll have Exhibit 1. 17 is the transcript of Mr. Stone's hearing. Exhibit 1 18 Mr. Stone was there, in front of the House Intelligence 19 Committee on September 26th, 2017, because of the statements 20 that he made in early August that pretended that he had inside 21 knowledge on drops of information by WikiLeaks, that somehow he 22 knew what was going to happen, and the congressmen asked him to 23 come in, and he came in voluntarily, but he came in because 24 they wanted to know if he had any inside info or if he had a 25 connection that was feeding him inside info. He knew he was Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 86 of 126 1 2 1183 there to answer questions about WikiLeaks. And this idea that somehow Mr. Stone's questions could 3 only be seen as related to Russia is just belied again by the 4 paper here. 5 again, is the paper here doesn't lie. 6 Okay? That's the beautiful thing about this case I'm going to show you Exhibit 6, the HPSCI report. This 7 is the report that HPSCI made -- HPSCI, the House Intelligence 8 Committee made following its hearing. 9 The report states that matters investigated by the 10 committee include allegations pertaining to involvement in, 11 knowledge about the publication of stolen emails, particularly 12 in light of candidate Trump's enthusiasm for WikiLeaks. 13 This was in the report, and I realize that the report came 14 after Mr. Stone testified, but what this does show you is the 15 topics that they covered during their hearing. 16 The report also states, also stresses the importance of 17 WikiLeaks. 18 influence campaign and served as a third-party intermediary for 19 Russian intelligence during the period leading up to the 2016 20 U.S. presidential election, and the report goes on to discuss 21 the global reach of WikiLeaks. 22 WikiLeaks played a key role in Russia's malign But Mr. Stone's knowledge here, his knowledge of why he 23 was there to answer questions, I thought -- he said: 24 they were only asking me about Russia. 25 That's belied by his own statements. I thought This is going to be Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 87 of 126 1184 1 in Exhibit 1, which you will have back in the jury room, which 2 is in the transcript. 3 statement by Roger Stone. 4 piece. 5 The exhibit begins with an opening He's given an opportunity to say his At the beginning he says: "These hearings are largely 6 based on a yet unproven allegation that the Russian State is 7 responsible for the hacking of the DNC and John Podesta, and 8 the transfer of that information to WikiLeaks." 9 "And the transfer of that information to WikiLeaks." He's 10 literally telling the committee that he knows that one of the 11 reasons that they're all there is the transfer of information 12 to WikiLeaks. 13 He goes on to state in that same opening statement, this 14 is page 10: Members of this committee have made three basic 15 assertions against me which must be rebutted here today; that 16 the charge that I knew in advance about the predicted hacking 17 of Clinton campaign chairman John Podesta's e-mails, that I had 18 the advance knowledge of the source or actual content of the 19 WikiLeaks disclosures regarding Hillary Clinton. 20 This is literally the defendant's words telling you that 21 he knows that the topic here is going to be advance knowledge 22 of the source and actual content of the WikiLeaks disclosures 23 regarding Hillary Clinton. 24 25 So to come in here now and say, "Oh, gee, back then I thought they were only asking me about Russia, so when they Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 88 of 126 1185 1 asked me about emails and text messages, I was only thinking 2 that they were asking me about emails and text messages that 3 discussed Russia," that is an argument that you make up after 4 the fact to cover the tracks, all right, because this is what 5 he said there on the date of the hearing, this is what was 6 going on in his mind on the day of the hearing, this is what he 7 knew what the hearing was about, and this is the best evidence 8 of what his knowledge was at the time. But you don't even have to take Mr. Stone's own words for 9 10 11 it. The questions by the members of the committee. Mr. Quigley, one of the congressmen, says: "Perhaps the 12 most important question anyone can ask you today is, who was 13 the intermediary, and you can't answer it. 14 It was clear that the focus of the hearing was, "Who was 15 your intermediary," because again, the focus of this hearing 16 was not just on who hacked the emails, it was the transfer and 17 dissemination of those emails through WikiLeaks. 18 That was it. It would be as if you were only investigating half of a 19 crime, but Congress was investigating the whole thing: 20 hacking and the transfer, and whether anyone in the Trump 21 campaign was connected to any of that, whether they had advance 22 knowledge of that transfer of emails to WikiLeaks. 23 The That's what they were looking at, that's why he was there. 24 He was there because of the statements he made in August of 25 2016, where it looked like and it sounded like, to many people, Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 89 of 126 1 he had a connection, and they wanted to know what that 2 connection was about. 3 1186 And that's why, when the questions were coming and were 4 coming and were coming -- and these were not just five or six 5 questions, as the defense said. 6 Exhibit 1, the transcript, when you're back there in the jury, 7 and take a look at it yourself. 8 as to who was the identity, who was the identity of your 9 intermediary. 10 Mr. Gowdy. I say, go look at the But the questions kept coming He stresses the indispensability of 11 interviewing the original source and whether he's willing -- 12 whether Mr. Stone is willing to go back to ask his intermediary 13 for permission to release his name, which Mr. Kravis noted 14 never happened. 15 Mr. Schiff, this is on page 81 of the transcript: "We 16 will need to determine which is accurate, whether you were in 17 communication with Assange or whether you were in communication 18 through an intermediary, so we'll need to determine whether we 19 can corroborate that through your intermediary." 20 They wanted to know who the intermediary was so they could 21 corroborate it, they could ask, they could potentially subpoena 22 the intermediary, bring them in and find out what their 23 connection was, if any, to WikiLeaks. 24 25 That's why the questions in the hearing focused so much on the intermediary. It was quite clear from those questions Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 90 of 126 1 there wasn't a "about Russia" attached to the end of the 2 question as Mr. Stone argued. 1187 For instance, page 44 of the transcript, Mr. Quigley 3 4 asked: "And was that -- how did you communicate with your 5 intermediary?" 6 Mr. Stone: 7 "And did you have any other means of communicating with 8 "Over the phone. the intermediary. "No. 9 10 "No text messages? 11 "No. 12 "None on the list, right? 13 "No. 14 "Nothing direct? 15 "No." 16 How can you add Russia to the end of any of those 17 questions? They are literally asking this man who his intermediary 18 19 is. 20 guy, he says, "Over the phone." 21 And when they ask him, How do you communicate with this No text messages, none on the list, which is a lie. 22 saw the text messages and you saw the emails. 23 you can look at that and say: 24 through the publicly announced parameters of this 25 investigation. You There's no way Oh, gee, my answer is only given Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 91 of 126 1 2 3 1188 That argument doesn't even comport with what you're seeing here in this transcript. So I want you to take that argument regarding Russia, their 4 whole idea here that everything was viewed through a lens of 5 these four publicly announced parameters, and I want you to put 6 that to the back of your mind. 7 All right? It's meant to distract you. 8 I want to next address Randy Credico. 9 According to Mr. Rogow, and I'll use Mr. Rogow's own words, 10 Credico was a manipulator, Randy Credico played Roger Stone, 11 Randy Credico abused his friend. 12 Please, you were all here. You saw Randy Credico. 13 Are you kidding me? 14 When we presented Mr. Credico to you, we presented the full Are you kidding me? 15 man, works et al. 16 jury system is, we take civilians off the street and put them 17 in these chairs, and they can assess a witness and assess their 18 demeanor. 19 And one of the beautiful things about our I'm going to ask you, did that look like a mastermind to 20 you that was going to manipulate or somehow control Roger 21 Stone? 22 No. But that argument is also meant to confuse you, okay, 23 because even in some strange, crazy world where you believe 24 that that man, Randy Credico, somehow manipulated Mr. Stone, 25 the question here is august of 2016, okay, because that is what Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 92 of 126 1189 1 Stone is asked about is who was your professed intermediary, 2 go-between, back channel, that you were talking about in August 3 of 2016? That is what Stone was asked before Congress. 4 It's in the 5 transcript, page 39. "On August 8th, 2016, you gave remarks at 6 the Southwest Broward Republican Organization." And then Mr. Quigley asks, "And so just to reiterate, in 7 8 August 12th, 2016, you gave an interview and Al Jones where you 9 said you were in communication with Assange." 10 They were asking about August of 2016. 11 Mr. Credico could not have been the intermediary then, for 12 the reasons that Mr. Kravis put forth, the timing, it wouldn't 13 have worked out. Mr. Credico, on Government's Exhibit 48, sends Mr. Stone 14 15 this text message: 16 connection to Assange. 17 to." 18 "Just remember, do not name me as your You had one before that you referred Government's Exhibit 191: "All I did in London is deliver 19 a letter from WBAI station manager to invite them to have their 20 own weekly radio show." 21 Mr. Credico, even at this early stage of this, is telling 22 Mr. Stone: 23 somebody else before I even came into the picture here. 24 25 You got this wrong. You got this wrong. There was I stress this to you because when Mr. Rogow argues that Credico somehow manipulated Mr. Stone, the timing just doesn't Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 93 of 126 1 2 work out. 1190 It literally just doesn't work out. But Mr. Credico goes even further. In January of 2017, 3 more than nine months before Mr. Stone testifies, more than 4 nine months before Mr. Stone testifies before Congress, 5 Mr. Credico says: 6 tell the truth that you had no back channel or there there's 7 the guy you were talking about in early August." 8 9 "I piece it all together, so you may as well Mr. Credico literally puts Mr. Stone on notice that he has this wrong. 10 And nine months go by, and what does Mr. Stone do? 11 He goes in there, and then later on he blames the whole 12 13 14 15 thing on Credico. Then after the testimony, Mr. Credico makes further efforts to try to correct the record. On December 1st, 2017, Mr. Credico tells Mr. Stone: 16 never a back channel." 17 December 24th: 18 year, September 7. 19 20 21 "I met Assange for the first time this Docs prove that, December 7, 2017. January 6th, 2018: "I have the email from his chief of staff," which Mr. Kravis showed you. August 25, 2016: "Responding to an email I sent to 22 WikiLeaks website email address asking if you would do my 23 show." 24 25 "I was January 8th: the email." "Introduced to him on August 25th. I have Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 94 of 126 This is Mr. Credico again telling Mr. Stone after the fact 1 2 1191 that: I wasn't your guy in August. So to claim that Mr. Credico somehow manipulated Mr. Stone 3 4 makes absolutely no sense and flies in the face of the 5 documents where he's telling Mr. Stone in no uncertain terms: 6 I was not your back channel on August of 2016, when you 7 testified that I was before Congress. 8 lie. 9 The documents do not Mr. Rogow also talked about another subject that I want to 10 turn to now. He discussed the reasons, the reasons why 11 Mr. Credico pled the Fifth. 12 saying there were a thousand reasons, there were a thousand 13 reasons for why he would have taken the Fifth. And he quoted Mr. Credico as 14 And he said that, well, the reason why Mr. Credico took the 15 Fifth was he didn't want to be revealed to be helpful to Donald 16 Trump. 17 18 I want to discuss this with you because this is an important point I want to make to you. 19 You are going to get -- after this is all done, you're 20 going to be instructed by the Judge as to what the elements of 21 the witness tampering are, and she'll tell you what law to 22 apply to the facts to determine whether or not Mr. Stone 23 tampered with Mr. Credico. 24 25 One the elements that Judge Jackson is going instruct you on is whether Mr. Stone had the intent to influence the Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 95 of 126 1 1192 testimony, okay? 2 For Mr. Stone to be guilty of committing witness tampering, 3 he had to have the intent to influence Mr. Credico's testimony. 4 One key point of this is, it is not necessary for the 5 government to prove that the witness's testimony was, in fact, 6 changed in any way. So we don't have to prove that Mr. Credico actually was -- 7 8 was actually effectively -- he didn't testify because of what 9 Mr. Stone told him. 10 provided to you. 11 here. That's going to be in the law that's However, we have that here. We have that Mr. Credico, when he was on the stand, said there was one 12 13 of a thousand reasons, but really he goes to the crux of this. 14 And if you remember, he goes to the crux of this, if you 15 remember he goes the crux of this it's all here, was Margaret 16 Kunstler, and that was it. Because Mr. Stone eventually, you know, he told him the 17 18 Frank Pentangeli; he told him, you know: 19 fuck himself. 20 21 He told him, "No one cares. Go tell Mueller to I wouldn't talk to the FBI. You would be smart if you don't talk to them either." But it was when Mr. Stone found Margaret Kunstler that he 22 23 realized that he had the button that was pushed, and when he 24 threatened to refer her to the bar or he threatened to expose 25 her. That was the straw that broke the camel's back, and Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 96 of 126 1 that's what Mr. Credico testified to. 2 and pled the Fifth. 3 4 5 but I want to end with just one point. In Mr. Rogow's closing, he said something that I want to briefly address, and he said: 7 case, you have to ask, so what? 9 10 And he didn't testify, I'm not going to go through everything that Mr. Rogow said, 6 8 So what? So what? Much of this Well, if that's the state of affairs that we're in, I'm pretty shocked. Truth matters. Truth still matters, okay? And I know we live in a world nowadays with Twitter, 11 tweets, social media, where you can find any view, any 12 political view you want. 13 You can find your own truth. However, in our institutions of self-governance, courts of 14 law or committee hearings, where people under oath have to 15 testify, truth still matters. 16 When Mr. Stone came in, he lied to Congress. 17 their investigation, and he tampered with a witness. 18 matters. 19 what. 20 21 22 1193 He obstructed And that And you don't look at that and you don't say, so For those reasons we ask you to find him guilty of the charged offenses. Thank you. THE COURT: All right, the only remaining step left 23 in this trial for the jurors is to be instructed as to what the 24 law is that is going to govern your deliberations. 25 given the time and how long it unfortunately takes to read them I think, Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 97 of 126 1194 1 all out loud, and the fact that you have been sitting and only 2 listening for quite some time, that we are going to give you 3 the instructions first thing tomorrow morning when everybody is 4 fresh. 5 to consider and to deliberate. 6 At that point you'll retire and the case will be yours That means, as I tell you every evening, you have not yet 7 received the case. 8 heard all of the evidence. 9 so you may not discuss the case with anyone else or try to 10 11 Notwithstanding the fact that you have You won't be together this evening, supplement the record by looking things up. We will resume tomorrow at 9:30 a.m., and you will receive 12 the instructions and the exhibits and the case at that time. 13 Thank you very much for all your attention this afternoon. 14 (Jury excused.) 15 THE COURT: Unless anyone has anything further they 16 need to discuss right now, I'll see everyone tomorrow morning. 17 Thank you. 18 19 20 21 22 23 24 25 (Trial adjourned at 3:57 p.m.) -oOo- Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 98 of 126 1 2 1195 CERTIFICATE I certify that the foregoing is a true and correct 3 transcript, to the best of my ability, of the above pages, of 4 the stenographic notes provided to me by the United States 5 District Court, of the proceedings taken on the date and time 6 previously stated in the above matter. 7 I further certify that I am neither counsel for, related 8 to, nor employed by any of the parties to the action in which 9 this hearing was taken, and further that I am not financially 10 nor otherwise interested in the outcome of the action. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 _________________________________ /s/ Crystal M. Pilgrim, RPR, FCRR ________________________ Date: November 13, 2019 1196 1194/18 1120/23 1121/23 1122/1 3:57 [1] 306 Filed 02/14/20 Page 99 of 126 - Case 1:19-cr-00018-ABJ Document 1122/13 1123/6 1125/19 3rd [6] 1098/22 1121/23 -oOo [1] 1194/19 1128/22 1129/11 1130/13 1122/1 1123/6 1137/10 1135/3 1135/5 1135/7 1137/14 / 1137/16 1137/18 1137/19 4 /s [1] 1195/12 1138/3 1140/14 1141/1 401 [1] 1099/8 1141/4 1147/18 1153/9 0 44 [1] 1187/3 1158/8 1181/20 1183/19 018 [1] 1098/4 4700-F [1] 1099/17 1185/25 1188/25 1189/3 48 [1] 1189/14 1189/5 1189/8 1189/10 1 4th [3] 1122/13 1122/14 1190/21 1191/6 10 [4] 1119/15 1149/21 1122/17 2017 [25] 1105/5 1113/9 1149/23 1184/14 1116/14 1124/12 1125/19 5 100 [2] 1098/22 1099/3 1127/24 1128/4 1129/4 1000 [1] 1098/22 50 [1] 1118/16 1131/18 1131/25 1132/15 101 [1] 1151/13 500 [3] 1163/6 1163/6 1132/21 1133/1 1134/16 11 [1] 1150/13 1163/16 1134/18 1141/7 1141/10 11 days [1] 1113/20 501 [1] 1099/12 1142/16 1144/25 1147/5 1103 [1] 1100/4 530-5301 [1] 1099/5 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1111/25 25th [9] 1109/7 1114/21 8259 [1] 1099/13 1112/6 1116/7 1118/14 1118/3 1134/20 1135/3 8909 [1] 1098/23 1118/17 1135/5 1135/7 1137/18 8th [6] 1107/21 1110/25 19-18 [1] 1101/2 1190/24 1112/5 1135/7 1189/5 19-CR-018 [1] 1098/4 26th [6] 1128/4 1156/16 1190/24 191 [1] 1189/18 1156/21 1157/10 1161/4 1950s [1] 1134/1 1182/19 9 19th [4] 1113/20 1114/4 27th [1] 1132/20 9064 [1] 1099/9 1114/16 1131/25 28th [2] 1132/21 1181/1 954 [4] 1098/23 1099/5 1:05 [1] 1098/7 2:15 [1] 1143/21 1099/9 1099/13 1st [4] 1124/11 1133/1 2:25 [2] 1143/17 1143/19 9:30 [1] 1194/11 1134/16 1190/15 2:30 [1] 1143/22 9th [1] 1136/23 2nd [8] 1109/16 1110/13 2 1111/6 1112/7 1112/14 A 2.0 [1] 1121/2 1136/8 1140/10 1142/2 A-P-P-E-A-R-A-N-C-E-S [1] 20 [2] 1149/24 1171/8 1098/13 3 20 years [1] 1171/8 a.m [1] 1194/11 20001 [1] 1099/18 30 [2] 1121/21 1149/23 AARON [2] 1098/15 1179/23 2007 [1] 1129/25 30 seconds [1] 1129/20 ability [1] 1195/3 2011 [3] 1149/24 1150/1 30th [1] 1121/2 able [2] 1128/7 1152/7 1171/17 31 [1] 1154/14 about [239] 2015 [1] 1108/24 31st [1] 1137/19 above [2] 1195/3 1195/6 2016 [67] 1103/15 1103/24 32 [1] 1152/25 absolutely [4] 1108/6 1104/11 1104/12 1105/8 328-9064 [1] 1099/9 1144/23 1145/20 1191/4 1105/19 1105/21 1106/19 331 [1] 1099/12 absurd [1] 1117/2 1108/17 1108/20 1108/25 333 [1] 1099/17 abuse [1] 1167/4 1109/7 1109/16 1110/13 33301 [2] 1098/23 1099/9 abused [2] 1167/5 1188/11 1110/25 1111/7 1111/14 33316 [1] 1099/13 accept [1] 1160/4 1111/18 1112/5 1112/6 33394 [1] 1099/4 access [3] 1120/20 1113/16 1113/20 1114/5 34 [1] 1155/2 1122/21 1150/9 1114/16 1114/21 1115/25 35 [1] 1148/20 accomplished [1] 1131/8 1116/7 1116/10 1117/1 36 [1] 1148/25 according [3] 1161/25 1117/11 1118/3 1118/14 39 [1] 1189/5 1161/25 1188/9 1118/17 1118/24 1120/6 afterwards [2]Filed 1166/9 306 02/14/20 A Case 1:19-cr-00018-ABJ Document 1168/18 account [2] 1108/12 again [41] 1102/16 1114/17 1107/18 1108/2 1108/5 accurate [4] 1108/13 1110/20 1111/25 1115/24 1142/5 1168/14 1186/16 1118/21 1121/2 1123/25 acknowledge [2] 1163/2 1124/7 1132/10 1133/1 1166/8 1135/22 1136/16 1148/20 acknowledged [1] 1160/14 1148/24 1149/1 1151/25 acquaintance [3] 1111/22 1152/18 1152/20 1153/21 1112/12 1113/18 1156/1 1156/1 1156/24 acting [2] 1142/13 1143/4 1158/9 1160/19 1163/4 action [3] 1098/3 1195/8 1164/7 1168/1 1170/4 1195/10 1172/19 1173/13 1175/23 actions [2] 1105/3 1150/8 1177/6 1177/8 1178/8 active [4] 1146/23 1162/4 1183/3 1183/5 1185/15 1162/6 1181/20 1191/1 activities [4] 1146/21 against [6] 1110/8 1133/8 1160/13 1160/13 1160/15 1137/4 1162/5 1178/11 activity [5] 1105/10 1184/15 1133/11 1146/11 1162/4 agencies [1] 1160/11 1180/5 agent [3] 1102/10 1114/1 acts [1] 1176/12 1125/17 actual [5] 1131/5 1131/11 ago [5] 1108/19 1137/2 1131/13 1184/18 1184/22 1146/8 1150/5 1179/24 actually [14] 1106/9 agree [3] 1102/1 1107/8 1108/10 1117/2 1118/12 1175/6 1125/10 1134/7 1139/17 agreed [1] 1164/6 1144/21 1145/4 1168/2 agreement [2] 1169/17 1172/11 1179/1 1192/7 1169/18 1192/8 Airport [1] 1121/15 ADAM [1] 1098/15 al [2] 1188/15 1189/8 Adam.Jed [1] 1098/20 alcohol [1] 1128/13 add [4] 1125/20 1161/13 all [99] 1166/4 1187/16 allegation [2] 1107/9 added [1] 1182/12 1184/6 address [6] 1158/3 allegations [5] 1103/14 1179/14 1179/15 1188/8 1105/7 1105/13 1135/16 1190/22 1193/6 1183/10 addresses [1] 1160/8 allies [1] 1162/5 adjourned [1] 1194/18 allowed [1] 1101/25 admitted [2] 1128/12 almost [1] 1156/19 1169/20 along [7] 1130/3 1130/11 admitting [1] 1174/24 1131/16 1131/21 1138/11 advance [4] 1184/16 1138/24 1143/7 1184/18 1184/21 1185/21 already [3] 1151/3 1153/2 adviser [1] 1180/9 1171/1 affairs [3] 1108/13 also [14] 1104/3 1115/2 1176/15 1193/8 1120/17 1126/3 1126/12 affect [1] 1177/4 1128/1 1128/13 1137/21 affected [3] 1105/3 1140/15 1141/14 1183/16 1139/17 1145/18 1183/16 1188/22 1191/9 after [46] 1104/17 1109/7 although [3] 1172/11 1109/18 1109/24 1110/18 1173/6 1174/21 1111/1 1111/18 1113/20 always [2] 1129/17 1160/7 1113/22 1113/22 1114/6 am [4] 1151/6 1151/9 1114/24 1119/17 1119/17 1195/7 1195/9 1121/23 1122/7 1124/12 ambiguity [1] 1168/21 1127/20 1129/11 1130/19 Amendment [11] 1124/14 1130/25 1131/25 1132/1 1132/13 1132/16 1132/17 1133/15 1133/22 1136/14 1142/17 1148/9 1173/25 1138/12 1138/17 1138/20 1174/3 1175/12 1177/23 1153/9 1155/12 1156/16 1181/7 1156/22 1158/6 1166/3 AMERICA [2] 1098/3 1101/3 1166/15 1167/18 1174/2 American [1] 1160/10 1174/2 1180/2 1180/3 amusing [2] 1165/12 1183/14 1185/3 1190/13 1165/13 1191/1 1191/19 AMY [1] 1098/11 afternoon [7] 1098/5 announce [3] 1122/16 1102/22 1102/25 1140/2 1153/13 1153/14 1154/18 1156/20 1194/13 announced [9] 1105/6 1197 1108/20 1116/15 1160/8 Page 100 of 126 1160/9 1160/19 1160/20 1187/24 1188/5 announcement [1] 1120/25 announces [1] 1120/23 annoyance [1] 1167/7 annoyed [3] 1149/17 1149/19 1167/6 another [12] 1109/13 1113/3 1121/4 1122/15 1140/17 1171/7 1171/8 1171/22 1172/2 1172/19 1173/10 1191/9 answer [24] 1106/10 1106/14 1108/15 1108/16 1112/24 1117/23 1117/25 1120/3 1120/4 1124/23 1124/24 1125/1 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[1] 1101/7 appropriate [1] 1144/9 April [4] 1136/20 1136/23 1137/10 1137/14 are [71] 1101/15 1101/17 1188/19 306 1193/7 1193/20 Filed 02/14/20 A Case 1:19-cr-00018-ABJ Document asked [30] 1102/11 are... 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[17] 1122/18 becoming [1] 1168/7 1122/22 1123/2 1123/16 been [22] 1103/24 1113/18 1126/12 1140/3 1140/22 1115/24 1120/24 1135/17 1145/7 1150/20 1153/24 1137/2 1140/2 1145/1 1154/3 1154/11 1154/20 1145/17 1149/11 1150/7 1154/22 1158/17 1167/18 1155/14 1157/15 1164/6 1167/20 1171/19 1172/1 1172/1 Bannon's [1] 1167/25 1180/10 1181/2 1181/3 bar [2] 1137/3 1192/24 1189/11 1194/1 base [1] 1176/25 before [49] 1098/10 based [8] 1139/1 1155/9 1102/2 1103/21 1104/8 1155/9 1155/17 1159/22 1109/20 1111/5 1113/6 1178/4 1178/13 1184/6 1114/4 1115/6 1116/3 basic [1] 1184/14 1116/3 1116/9 1116/24 basis [2] 1145/20 1176/4 1119/9 1121/6 1129/25 be [71] 1101/7 1102/25 1133/3 1133/6 1134/12 1108/6 1108/7 1109/21 1137/11 1142/9 1142/13 1109/25 1110/5 1110/22 1143/11 1146/1 1147/12 1115/20 1122/15 1128/7 1152/20 1153/8 1156/9 1128/11 1128/13 1130/14 1158/8 1158/11 1159/1 1130/23 1132/11 1132/23 1159/11 1160/25 1164/23 1134/5 1142/22 1142/23 1170/4 1170/25 1176/15 1143/17 1144/3 1144/10 1179/3 1180/18 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1183/25 1126/17 1128/3 1128/6 belief [1] 1169/23 1131/15 1136/12 1137/20 believe [3] 1111/3 1140/5 1140/19 1141/20 1116/22 1188/23 1143/2 1146/13 1146/16 believes [1] 1142/21 1146/24 1147/4 1147/7 believing [1] 1117/1 1147/13 1148/3 1150/8 belonging [1] 1105/22 1150/23 1150/25 1151/2 bench [3] 1101/7 1101/8 1151/10 1152/22 1153/19 1102/8 1153/25 1154/1 1156/8 bend [1] 1128/7 1157/7 1157/19 1157/24 benefit [1] 1159/9 1158/1 1158/16 1159/2 BERMAN [1] 1098/11 1159/12 1161/10 1165/9 Bernie [2] 1165/12 1174/10 1174/13 1174/15 1175/15 1174/18 1174/20 1175/13 best [2] 1185/7 1195/3 1175/18 1176/10 1176/23 between [20] 1104/10 1176/23 1177/23 1180/16 1105/11 1106/6 1110/15 1181/6 1181/11 1181/13 1112/5 1114/3 1114/19 1181/14 1182/6 1182/19 1115/10 1125/18 1125/19 1182/23 1185/4 1185/15 1143/13 1146/12 1148/10 1185/24 1188/23 1188/25 1156/13 1162/6 1171/9 1189/24 1191/17 1192/8 1173/13 1177/12 1178/5 1192/17 1189/2 1199 beyond [8] 1145/4 1145/4 Page 102 of 126 1154/24 1161/23 1166/24 1169/8 1170/9 1170/14 bglaw [2] 1099/5 1099/6 bglaw-pa.com [2] 1099/5 1099/6 big [8] 1127/16 1142/12 1150/3 1157/25 1170/22 1170/22 1174/25 1175/2 bigger [1] 1125/11 binder [1] 1129/1 bit [3] 1114/12 1142/8 1162/17 blames [1] 1190/11 blew [1] 1130/4 blind [2] 1166/17 1166/25 block [1] 1150/17 blocked [1] 1146/9 blocked-out [1] 1146/9 blowing [1] 1171/4 blown [1] 1178/4 Blvd [1] 1099/12 boast [1] 1120/18 body [1] 1119/12 booked [1] 1114/14 both [1] 1180/19 bottom [2] 1116/8 1165/22 Boulevard [1] 1099/8 box [2] 1103/1 1158/20 bragging [1] 1104/10 break [3] 1130/15 1143/12 1143/16 briefly [2] 1101/7 1193/6 bring [5] 1102/19 1133/8 1143/23 1173/22 1186/22 bringing [1] 1129/15 brogow [1] 1098/24 broke [2] 1128/8 1192/25 brought [5] 1162/15 1164/2 1173/23 1173/24 1179/14 Broward [5] 1107/22 1110/25 1113/21 1114/9 1189/6 Bruce [3] 1098/21 1098/21 1144/3 BS [1] 1116/16 build [3] 1168/22 1168/23 1168/24 built [2] 1168/13 1168/13 bunch [2] 1130/4 1131/5 BUSCHEL [4] 1099/2 1099/3 1099/5 1160/6 butter [1] 1131/4 button [1] 1192/23 C C-SPAN [1] 1111/23 call [9] 1111/25 1121/12 1121/18 1122/2 1168/17 1168/18 1169/6 1169/15 1170/21 called [6] 1103/19 1116/15 1133/7 1149/4 1157/22 1157/23 calls [16] 1122/9 1151/14 1151/15 1151/15 1151/16 1151/17 1151/19 1151/20 1151/21 1151/22 1151/23 1152/1 1152/7 1152/8 1152/10 1155/21 1192/20 306 Filed 02/14/20 C Case 1:19-cr-00018-ABJ Document case [39] 1101/2 1102/10 came [18] 1103/24 1104/5 1103/3 1103/5 1106/8 1128/6 1147/11 1156/9 1106/8 1106/11 1125/7 1159/1 1160/20 1170/4 1125/17 1139/11 1139/23 1178/8 1180/8 1181/21 1143/17 1144/8 1146/17 1181/22 1182/8 1182/23 1155/9 1158/25 1163/18 1182/23 1183/13 1189/23 1163/25 1166/4 1167/13 1193/16 1167/24 1168/22 1168/24 camel's [1] 1192/25 1170/1 1170/12 1170/22 campaign [70] 1104/4 1170/23 1171/5 1177/11 1104/13 1104/18 1108/25 1177/13 1179/1 1179/23 1109/1 1109/2 1109/3 1180/22 1183/4 1193/7 1109/6 1120/8 1120/9 1194/4 1194/7 1194/9 1120/17 1123/3 1123/4 1194/12 1123/13 1123/15 1123/23 categories [1] 1104/8 1124/6 1126/21 1127/5 cause [1] 1151/1 1140/22 1140/23 1141/2 causes [1] 1165/8 1141/6 1144/23 1145/1 center [1] 1168/16 1145/2 1145/5 1145/10 CEO [2] 1109/3 1120/17 1145/10 1145/11 1145/13 certain [2] 1155/12 1145/13 1145/16 1145/18 1157/13 1150/15 1150/17 1150/21 certainly [2] 1139/21 1151/3 1151/4 1152/16 1154/23 1154/6 1154/7 1154/10 CERTIFICATE [1] 1195/1 1154/13 1154/16 1154/18 certify [2] 1195/2 1195/7 1154/19 1154/24 1158/4 cetera [2] 1102/5 1102/5 1158/7 1158/14 1158/16 chairman [2] 1109/3 1161/1 1168/11 1169/24 1184/17 1174/20 1175/21 1177/18 chairs [1] 1188/17 1177/19 1179/18 1179/25 chance [3] 1104/4 1109/6 1180/3 1180/5 1180/7 1141/6 1180/10 1180/21 1181/21 CHANDLER [2] 1099/11 1183/18 1184/17 1185/21 1099/11 campaign's [3] 1120/20 changed [1] 1192/6 1122/20 1123/16 changes [1] 1146/3 campaigns [4] 1105/12 channel [19] 1106/23 1145/8 1146/12 1162/7 1110/24 1111/19 1112/2 CAMPION [2] 1099/2 1099/6 1112/11 1113/17 1114/11 can [53] 1101/6 1103/6 1114/25 1115/18 1116/16 1105/20 1108/4 1108/7 1116/19 1117/16 1129/6 1108/8 1108/13 1112/3 1136/20 1136/24 1189/2 1121/19 1127/17 1128/13 1190/6 1190/16 1191/6 1130/19 1132/17 1133/8 character [3] 1133/4 1134/6 1134/7 1138/15 1134/13 1164/13 1143/19 1143/23 1144/1 characters [1] 1128/15 1148/3 1148/4 1148/23 charge [2] 1133/8 1184/16 1149/13 1151/8 1151/19 charged [4] 1127/12 1155/7 1157/19 1159/14 1139/2 1159/19 1193/21 1169/14 1170/22 1173/20 charges [2] 1106/11 1174/14 1174/16 1175/21 1178/18 1178/13 1178/14 1178/14 chart [3] 1125/17 1125/20 1178/15 1178/20 1179/8 1156/11 1179/9 1179/20 1181/7 charts [3] 1151/16 1181/8 1181/10 1185/12 1155/20 1155/20 1186/19 1187/16 1187/23 chatter [1] 1178/3 1188/17 1193/11 1193/12 check [3] 1115/25 1116/1 can't [7] 1112/24 1133/25 1136/20 1174/12 1177/23 1181/12 cherry [2] 1163/16 1181/14 1185/13 1163/18 candid [1] 1158/14 cherry-picked [1] 1163/16 candidate [6] 1109/4 cherry-picking [1] 1121/1 1121/9 1121/12 1163/18 1121/18 1183/12 chief [1] 1190/19 cannot [2] 1126/17 1132/7 choose [1] 1136/2 car [1] 1121/14 circuit [1] 1101/20 cards [1] 1127/17 city [1] 1145/10 care [1] 1135/20 civilians [1] 1188/16 cares [9] 1135/6 1135/9 claim [5] 1117/2 1131/22 1135/14 1135/15 1135/19 1133/13 1141/25 1191/3 1135/20 1135/21 1135/25 claimed [1] 1121/3 1200 clam [1] 1180/18 Page 103 of 126 clause [3] 1161/13 1161/13 1182/12 clear [5] 1102/14 1107/8 1179/25 1185/14 1186/25 clearly [1] 1128/10 client [2] 1182/8 1182/11 Clinton [14] 1110/8 1110/11 1110/12 1110/22 1111/4 1112/9 1119/14 1122/12 1128/22 1140/11 1175/15 1184/17 1184/19 1184/23 Clinton's [2] 1118/19 1145/16 close [2] 1129/22 1166/1 closed [1] 1159/9 closer [1] 1163/17 closing [9] 1100/3 1102/11 1103/2 1103/6 1103/8 1143/12 1144/2 1144/4 1193/5 colleague [3] 1106/7 1142/8 1179/23 collude [1] 1136/1 colluded [1] 1180/7 collusion [2] 1163/22 1182/12 COLUMBIA [3] 1098/1 1098/16 1099/16 come [9] 1146/16 1163/22 1164/11 1167/10 1168/1 1168/9 1170/5 1182/23 1184/24 comedian [1] 1128/14 comes [9] 1109/5 1120/25 1121/3 1122/17 1146/23 1148/1 1155/12 1180/22 1180/23 comic [1] 1173/8 coming [15] 1106/20 1120/12 1120/14 1121/21 1122/11 1122/16 1123/8 1140/11 1168/19 1171/24 1176/12 1186/3 1186/4 1186/4 1186/7 comment [1] 1146/22 comments [5] 1113/21 1114/24 1146/4 1146/9 1149/7 commission [1] 1145/10 commit [1] 1159/20 committed [2] 1139/7 1169/19 committee [160] committee's [10] 1106/4 1106/16 1139/18 1139/25 1141/23 1142/4 1143/7 1146/18 1146/18 1159/16 committees's [2] 1105/4 1146/11 committing [1] 1192/2 common [2] 1145/20 1181/18 communicate [6] 1127/4 1127/7 1162/23 1162/25 1187/4 1187/19 communicated [4] 1111/12 1111/23 1113/25 1116/12 communicating [2] 1104/3 1187/7 contact [2] 306 1118/20 Filed 02/14/20 C Case 1:19-cr-00018-ABJ Document 1135/4 communication [7] 1111/19 contacts [3] 1107/2 1112/2 1150/12 1156/17 1158/14 1158/16 1186/17 1186/17 1189/9 contains [3] 1141/23 communications [16] 1158/22 1158/23 1104/14 1104/16 1106/22 content [6] 1151/17 1125/16 1125/18 1125/22 1152/1 1152/18 1155/10 1126/6 1127/9 1137/22 1184/18 1184/22 1137/23 1140/21 1141/14 CONTENTS [1] 1100/1 1141/15 1155/22 1156/13 context [2] 1163/21 1156/20 1165/13 community [1] 1175/19 continued [1] 1099/1 compelling [1] 1158/25 contra [1] 1149/4 complaint [1] 1137/4 contradicting [1] 1141/25 completely [2] 1167/24 control [1] 1188/20 1172/22 controverts [1] 1149/5 complied [1] 1148/6 conversation [14] 1108/9 comply [1] 1177/6 1121/1 1121/5 1121/8 component [2] 1149/14 1148/4 1150/23 1151/4 1149/16 1154/15 1154/16 1154/16 comport [1] 1188/1 1154/24 1167/22 1167/22 concept [1] 1156/4 1168/21 concern [1] 1129/14 conversations [7] 1104/13 conclude [1] 1167/14 1120/7 1123/22 1127/4 concluded [1] 1156/22 1150/14 1150/17 1150/18 conclusion [6] 1157/18 convince [3] 1142/12 1157/18 1169/6 1171/24 1169/14 1178/4 1175/23 1177/15 convinced [1] 1156/4 conclusions [9] 1144/15 Cool [2] 1162/19 1162/19 1148/14 1149/13 1166/11 cooperation [2] 1169/17 1176/1 1176/2 1176/2 1169/18 1176/3 1176/4 copy [1] 1166/25 conclusively [1] 1138/1 copying [1] 1166/17 conduct [2] 1139/1 Corleone [2] 1133/21 1139/17 1133/21 conducted [1] 1103/12 correct [5] 1102/17 conference [3] 1101/8 1136/15 1138/7 1190/14 1111/25 1122/9 1195/2 confines [1] 1161/6 corroborate [3] 1108/14 confirm [3] 1103/3 1118/4 1186/19 1186/21 1118/5 corroborates [1] 1114/17 confirmed [2] 1149/10 corrupt [1] 1173/14 1161/5 corruptly [5] 1139/10 confuse [1] 1188/22 1139/13 1163/19 1176/5 confusing [1] 1166/5 1176/6 Congress [9] 1135/15 Corsi [51] 1101/14 1142/23 1143/2 1181/12 1108/18 1109/8 1109/9 1185/19 1189/4 1190/4 1109/12 1109/16 1109/23 1191/7 1193/16 1110/3 1110/5 1110/13 congressional [7] 1103/11 1110/18 1111/1 1111/18 1116/14 1133/6 1134/12 1112/7 1112/15 1112/19 1134/13 1179/3 1179/3 1112/21 1113/13 1116/21 congressmen [2] 1182/22 1117/16 1117/19 1118/2 1185/11 1118/11 1119/1 1121/7 connected [1] 1185/21 1121/24 1122/5 1122/10 connection [22] 1116/8 1125/4 1126/10 1126/19 1154/10 1156/12 1162/13 1127/1 1130/13 1136/7 1162/14 1164/16 1166/2 1136/9 1136/10 1136/11 1166/2 1167/2 1167/2 1137/9 1137/15 1137/20 1167/21 1168/24 1169/23 1139/14 1140/2 1140/8 1172/12 1175/8 1175/14 1140/9 1141/14 1142/3 1175/22 1182/25 1186/1 1157/21 1164/25 1179/5 1186/2 1186/23 1189/16 1180/15 1180/16 connections [3] 1141/1 Corsi's [1] 1111/5 1141/2 1180/7 could [26] 1102/11 consider [2] 1144/9 1103/21 1104/18 1113/18 1194/5 1120/19 1124/13 1128/1 Constitution [3] 1099/17 1128/2 1128/10 1140/16 1144/6 1144/7 1148/7 1153/10 1155/14 consult [2] 1178/2 1178/7 1157/15 1157/16 1157/17 1201 1157/17 1157/22 1167/2 Page 104 of 126 1169/18 1177/17 1183/2 1186/20 1186/21 1186/21 1189/11 couldn't [1] 1141/10 counsel [5] 1101/6 1134/23 1135/1 1160/2 1195/7 counsel's [1] 1141/8 count [7] 1127/13 1139/2 1139/2 1139/4 1139/5 1139/5 1139/6 Count 7 [1] 1139/2 counting [1] 1119/2 counts [8] 1127/12 1127/13 1139/3 1139/4 1151/2 1154/15 1161/12 1178/12 County [4] 1107/22 1110/25 1113/21 1114/10 course [13] 1115/21 1115/21 1127/23 1134/3 1141/8 1142/24 1142/24 1145/15 1157/12 1168/3 1168/4 1172/23 1173/7 court [8] 1098/1 1099/15 1099/15 1099/16 1102/14 1102/18 1182/3 1195/5 Court's [2] 1101/21 1102/2 courts [1] 1193/13 cover [7] 1130/14 1130/23 1130/24 1131/4 1175/18 1177/21 1185/4 covered [2] 1136/11 1183/15 CR [1] 1098/4 crazy [2] 1171/9 1188/23 create [1] 1144/16 created [3] 1147/8 1162/16 1176/21 Credico [229] Credico's [11] 1114/17 1114/20 1115/3 1128/19 1130/15 1131/9 1131/15 1134/8 1148/17 1171/14 1192/3 credit [6] 1121/3 1123/19 1123/20 1140/24 1153/18 1176/10 crime [3] 1139/7 1159/20 1185/19 crimes [2] 1159/19 1169/19 criminal [3] 1098/3 1133/11 1165/13 criteria [13] 1146/18 1147/9 1160/9 1160/20 1161/7 1162/1 1162/9 1163/1 1163/2 1163/21 1176/21 1176/23 1177/9 critical [7] 1137/20 1160/5 1161/13 1171/5 1177/10 1177/12 1177/15 critique [1] 1149/2 cross [3] 1108/8 1148/4 1148/7 cross-examine [1] 1148/7 cross-examined [2] 1108/8 1148/4 crude [3] 1152/17 1171/10 description 1168/6 306[2] Filed 02/14/20 C Case 1:19-cr-00018-ABJ Document 1168/15 crude... [1] 1172/1 desperate [1] 1136/15 crux [3] 1192/13 1192/14 detail [1] 1113/4 1192/15 details [1] 1146/1 Crystal [2] 1099/15 determine [5] 1108/12 1195/12 1108/13 1186/16 1186/18 crystalmpilgrim [1] 1191/22 1099/18 diagonal [1] 1121/17 cyber [3] 1105/10 1146/11 diagonally [1] 1121/16 1162/4 Dick [1] 1128/15 did [70] 1103/23 1104/20 D 1115/6 1115/7 1116/10 D.C [1] 1098/6 1116/13 1117/22 1118/20 damaging [1] 1109/25 1118/25 1122/7 1127/2 date [5] 1119/15 1137/9 1127/4 1127/7 1128/3 1185/5 1195/5 1195/12 1130/5 1130/8 1137/22 dated [2] 1110/13 1121/23 1137/23 1137/24 1139/23 dates [1] 1135/12 1140/6 1141/24 1141/25 David [1] 1175/7 1143/5 1143/6 1148/11 day [17] 1098/5 1111/21 1148/21 1150/13 1151/4 1114/21 1120/23 1120/25 1153/16 1154/6 1154/7 1121/2 1121/23 1125/24 1154/8 1156/14 1156/16 1132/22 1133/14 1133/22 1157/21 1159/7 1160/1 1138/12 1138/12 1145/9 1160/21 1161/16 1161/17 1156/21 1182/16 1185/6 1162/5 1163/25 1164/21 days [14] 1109/7 1109/12 1166/4 1167/5 1167/8 1109/15 1109/18 1109/19 1167/9 1169/8 1170/5 1111/1 1113/20 1115/6 1170/14 1170/17 1171/10 1122/7 1130/19 1130/25 1174/15 1174/18 1175/9 1131/25 1132/10 1181/5 1175/11 1175/13 1175/16 DC [2] 1098/17 1099/18 1176/16 1179/2 1179/3 deal [2] 1133/19 1133/20 1179/4 1179/4 1179/5 deals [1] 1170/1 1179/6 1187/4 1187/7 dealt [1] 1150/4 1188/19 1189/18 debacle [1] 1110/10 didn't [28] 1102/4 deceived [1] 1149/15 1102/13 1107/8 1107/9 December [10] 1124/11 1129/22 1135/25 1141/21 1132/15 1133/1 1134/16 1149/10 1153/23 1154/1 1134/18 1138/20 1142/16 1157/9 1157/25 1160/15 1190/15 1190/17 1190/18 1166/24 1168/7 1168/21 decide [3] 1106/12 1169/20 1171/18 1172/12 1107/11 1107/12 1172/23 1174/11 1174/13 decision [10] 1143/18 1175/15 1177/24 1177/24 1151/11 1152/3 1152/4 1191/15 1192/8 1193/1 1152/4 1152/9 1155/17 die [1] 1136/25 1163/12 1163/13 1174/4 different [6] 1112/6 defendant [6] 1098/8 1116/5 1163/22 1163/23 1098/21 1099/2 1139/7 1172/22 1178/16 1139/9 1139/9 difficulty [1] 1155/16 defendant's [1] 1184/20 direct [1] 1187/14 defense [8] 1102/11 directed [1] 1162/4 1116/22 1135/24 1142/6 disappointed [2] 1154/3 1142/11 1143/14 1143/24 1168/7 1186/5 disclosures [3] 1138/14 definitely [1] 1112/21 1184/19 1184/22 definition [4] 1144/13 discuss [7] 1143/18 1146/22 1147/1 1147/6 1150/13 1174/2 1183/20 deliberate [1] 1194/5 1191/17 1194/9 1194/16 deliberations [4] 1112/4 discussed [5] 1118/9 1142/10 1181/11 1193/24 1139/21 1150/16 1185/3 deliver [4] 1116/11 1191/10 1116/13 1172/20 1189/18 discussing [2] 1123/21 delivering [1] 1172/10 1179/16 demeanor [1] 1188/18 dispute [1] 1148/13 democracy [1] 1145/22 dissemination [1] 1185/17 Democratic [5] 1105/15 distill [1] 1176/11 1105/22 1105/22 1108/21 distract [2] 1181/17 1109/19 1188/6 Department [1] 1118/19 distraction [1] 1178/23 deputy [2] 1109/3 1120/9 DISTRICT [7] 1098/1 1202 1098/1 1098/11 1098/16 Page 105 of 126 1099/16 1099/16 1195/5 DNC [2] 1120/23 1184/7 do [60] 1103/23 1104/12 1106/21 1110/14 1110/17 1112/4 1116/8 1117/22 1118/8 1119/1 1119/2 1119/5 1119/25 1122/6 1127/2 1127/9 1129/24 1132/23 1134/9 1134/13 1137/24 1138/6 1139/1 1141/10 1141/17 1143/4 1143/6 1143/13 1143/24 1150/1 1153/20 1156/9 1157/10 1157/11 1158/17 1158/17 1159/23 1160/9 1161/22 1165/11 1165/12 1166/18 1166/19 1166/21 1167/18 1168/22 1168/24 1170/5 1172/17 1173/17 1173/20 1174/2 1174/19 1182/5 1182/13 1187/19 1189/15 1190/10 1190/22 1191/7 Docs [1] 1190/18 document [7] 1105/8 1105/9 1114/17 1119/13 1160/6 1179/11 1179/12 documentary [1] 1175/7 documents [37] 1103/19 1104/2 1105/15 1105/17 1105/18 1105/19 1110/15 1111/3 1116/2 1118/23 1119/6 1119/14 1120/21 1122/16 1124/18 1126/14 1126/16 1126/18 1126/20 1128/22 1129/13 1131/24 1135/12 1137/8 1140/1 1140/4 1140/6 1140/7 1157/7 1157/7 1159/7 1159/8 1161/18 1179/4 1179/10 1191/5 1191/7 does [41] 1107/16 1112/17 1112/18 1112/20 1112/21 1112/23 1113/3 1117/4 1118/3 1118/4 1119/1 1119/4 1122/23 1123/1 1123/18 1124/9 1127/15 1129/14 1135/20 1136/2 1138/6 1138/6 1138/8 1138/10 1138/12 1140/8 1140/9 1140/16 1149/8 1149/18 1150/25 1152/14 1153/13 1154/6 1155/11 1158/24 1164/18 1166/21 1168/20 1183/14 1190/10 doesn't [20] 1114/23 1133/10 1133/13 1154/4 1154/9 1154/9 1154/23 1155/3 1155/25 1156/11 1156/12 1156/23 1176/2 1176/3 1176/3 1179/12 1183/5 1188/1 1189/25 1190/1 doing [12] 1103/24 1130/13 1142/22 1144/3 1145/13 1148/9 1149/6 1166/23 1169/13 1175/7 1177/4 1180/21 domain [1] 1153/2 don't [34] 1102/15 1127/21 306 1129/8 1130/17 Filed 02/14/20 D Case 1:19-cr-00018-ABJ Document 1131/2 1136/17 1137/12 don't... [33] 1102/16 1137/21 1137/24 1138/3 1112/1 1114/14 1131/22 1140/18 1182/20 1189/21 1134/1 1134/25 1134/25 1190/7 1134/25 1136/10 1138/25 East [2] 1099/8 1099/12 1147/18 1150/19 1155/5 easy [1] 1153/19 1155/5 1156/14 1158/23 Ecuadorian [5] 1109/10 1162/8 1162/18 1162/20 1110/3 1164/23 1165/16 1163/9 1169/2 1169/6 1172/9 1169/15 1170/7 1172/6 edited [2] 1146/3 1146/4 1172/25 1178/10 1180/8 effect [4] 1156/25 1157/2 1185/9 1192/7 1192/21 1157/3 1157/5 1193/18 1193/18 effectively [1] 1192/8 Donald [14] 1104/6 efforts [2] 1114/22 1108/23 1110/8 1121/1 1190/13 1121/4 1121/5 1121/9 either [6] 1102/5 1134/19 1168/12 1168/16 1175/14 1142/19 1175/15 1181/14 1175/17 1180/1 1180/3 1192/21 1191/15 elected [2] 1145/2 1180/3 done [13] 1103/3 1141/18 election [10] 1103/16 1147/15 1155/2 1155/3 1105/8 1105/20 1110/15 1155/11 1155/15 1155/19 1120/6 1135/17 1139/12 1157/17 1159/25 1173/19 1158/8 1181/21 1183/20 1175/16 1191/19 element [1] 1167/24 door [5] 1153/10 1153/15 elements [3] 1176/7 1153/16 1153/17 1172/13 1191/20 1191/24 doubles [1] 1138/17 eleven [1] 1109/18 doubling [1] 1138/22 Eliot [1] 1130/2 doubt [5] 1144/11 1144/13 Elmo [1] 1179/21 1144/16 1144/17 1152/6 else [7] 1117/13 1136/19 down [8] 1110/5 1127/17 1143/19 1167/7 1174/10 1138/17 1138/22 1176/11 1189/23 1194/9 1179/7 1179/8 1180/22 em [1] 1132/18 dozen [1] 1163/15 email [77] 1098/18 Dr [1] 1149/24 1098/19 1098/19 1098/20 drag [1] 1129/22 1098/24 1099/5 1099/6 dragged [1] 1128/23 1099/10 1099/14 1099/18 draw [16] 1101/10 1101/17 1109/8 1109/13 1109/16 1101/21 1102/1 1148/14 1109/23 1110/13 1110/18 1149/13 1151/18 1151/19 1111/1 1111/6 1111/19 1151/23 1152/19 1152/21 1112/14 1114/3 1114/18 1155/7 1157/6 1157/19 1116/15 1117/9 1118/2 1166/10 1169/5 1118/3 1118/4 1118/6 drawing [2] 1165/24 1118/7 1118/17 1119/11 1175/25 1119/12 1119/16 1119/18 driving [1] 1169/3 1119/23 1121/6 1121/22 drops [1] 1182/21 1121/24 1122/8 1122/14 drug [1] 1131/9 1125/13 1125/14 1125/22 dump [1] 1153/22 1129/10 1129/11 1129/15 dumped [1] 1105/21 1130/10 1130/18 1130/20 dumps [4] 1109/24 1110/3 1130/22 1130/24 1131/3 1121/25 1140/11 1131/17 1131/22 1135/3 during [11] 1112/4 1117/3 1135/5 1135/8 1136/8 1117/4 1120/9 1128/25 1137/9 1137/10 1137/14 1129/18 1131/20 1180/5 1138/1 1138/25 1140/10 1180/10 1183/15 1183/19 1142/2 1149/23 1152/13 1155/23 1166/16 1166/22 E 1180/16 1180/16 1181/1 e-mail [1] 1129/10 1190/19 1190/21 1190/22 e-mails [1] 1184/17 1190/25 each [7] 1104/25 1127/14 emailed [2] 1118/21 1134/3 1136/10 1143/18 1118/22 1160/5 1182/11 emailing [2] 1117/12 early [32] 1106/19 1118/15 1108/17 1109/20 1111/14 emails [59] 1103/25 1113/10 1113/15 1114/7 1104/2 1105/21 1108/21 1116/1 1116/6 1116/20 1109/11 1109/19 1110/4 1116/20 1117/14 1117/16 1112/2 1112/22 1113/19 1117/18 1118/10 1125/2 1114/2 1115/25 1118/6 1125/9 1126/19 1126/25 1118/18 1119/8 1122/19 1203 1123/18 1124/25 1125/4 Page 106 of 126 1125/5 1125/12 1125/13 1125/22 1126/10 1126/11 1126/12 1126/18 1126/21 1134/2 1134/4 1135/12 1136/19 1136/21 1137/15 1137/18 1137/20 1138/1 1138/13 1138/17 1138/20 1138/23 1140/2 1140/3 1140/3 1140/16 1161/16 1161/18 1165/15 1165/25 1166/8 1170/15 1182/4 1183/11 1185/1 1185/2 1185/16 1185/17 1185/22 1187/22 embassy [10] 1109/11 1109/23 1110/2 1110/3 1121/24 1140/10 1164/23 1165/17 1172/9 1175/3 embrace [1] 1146/10 employed [3] 1108/25 1109/1 1195/8 employee [1] 1123/3 end [10] 1121/20 1127/16 1132/7 1157/9 1177/17 1181/11 1182/11 1187/1 1187/16 1193/4 endeavored [1] 1139/19 energetic [1] 1144/18 engaged [2] 1104/17 1105/2 England [2] 1164/22 1172/6 enough [2] 1162/18 1181/9 entertainer [1] 1131/8 enthusiasm [1] 1183/12 entire [1] 1113/5 entirely [1] 1138/18 entitled [1] 1136/4 entity [1] 1121/3 Eric [3] 1123/1 1154/14 1154/17 Esquire [9] 1098/14 1098/14 1098/15 1098/15 1098/21 1099/2 1099/2 1099/7 1099/11 establish [2] 1139/7 1154/24 established [1] 1103/10 et [3] 1102/5 1102/5 1188/15 et cetera [1] 1102/5 even [31] 1107/18 1109/4 1116/15 1117/5 1118/11 1125/8 1125/11 1128/16 1131/2 1136/10 1136/14 1145/4 1145/21 1155/3 1155/18 1162/13 1166/24 1169/8 1169/25 1169/25 1172/9 1172/23 1172/24 1173/11 1182/11 1185/9 1188/1 1188/23 1189/21 1189/23 1190/2 evening [2] 1194/6 1194/8 events [2] 1114/17 1134/7 eventually [2] 1132/19 1192/17 ever [3] 1113/24 1116/3 1150/16 every [10] 1104/4 1122/24 1137/5 1141/6 1145/9 Exhibit 32 [1]Filed 1152/25 306 02/14/20 E Case 1:19-cr-00018-ABJ Document Exhibit 48 [1] 1189/14 every... [5] 1145/9 Exhibit 68 [1] 1180/25 1152/25 1153/7 1179/13 exhibits [7] 1153/3 1194/6 1153/22 1159/13 1164/3 everybody [8] 1101/4 1164/5 1164/8 1194/12 1147/24 1153/10 1153/10 exist [1] 1140/6 1153/19 1154/3 1175/25 existence [2] 1179/5 1194/3 1180/15 everyone [2] 1143/19 expect [1] 1127/20 1194/16 explain [1] 1155/4 everyone's [1] 1108/6 explained [2] 1114/8 everything [6] 1138/14 1122/14 1138/18 1145/24 1158/21 exploring [1] 1105/14 1188/4 1193/3 expose [6] 1103/22 evidence [54] 1103/9 1104/18 1119/20 1126/16 1104/20 1104/24 1105/1 1132/7 1192/24 1112/3 1113/15 1120/5 exposed [1] 1181/15 1123/21 1125/6 1125/16 exposes [1] 1126/23 1126/23 1129/1 1136/5 eyes [1] 1117/6 1136/5 1138/16 1138/21 F 1139/21 1139/24 1141/24 face [1] 1191/4 1141/25 1142/2 1142/4 1150/16 1150/19 1150/22 Facebook [2] 1132/16 1155/23 1151/14 1151/15 1151/16 Faced [2] 1138/16 1138/21 1151/21 1151/25 1151/25 fact [18] 1101/24 1101/25 1152/12 1153/1 1155/4 1113/4 1119/9 1120/19 1155/8 1155/18 1155/18 1125/10 1125/24 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1182/11 exchanging [1] 1172/1 fashion [1] 1176/22 excused [2] 1143/20 father's [1] 1130/2 1194/14 fault [1] 1158/25 exhibit [34] 1105/8 FBI [8] 1114/1 1133/19 1113/12 1118/16 1119/11 1134/17 1134/18 1134/25 1147/17 1148/2 1148/2 1141/9 1142/18 1192/20 FCRR [2] 1099/15 1195/12 1148/15 1148/20 1148/25 feature [2] 1170/22 1149/7 1149/14 1149/21 1170/23 1150/2 1150/3 1151/1 feeding [4] 1131/3 1141/5 1151/1 1151/13 1151/24 1166/12 1182/25 1152/25 1154/14 1155/1 few [8] 1108/11 1109/12 1155/2 1155/2 1159/12 1109/19 1115/6 1131/25 1180/25 1182/16 1182/16 1146/8 1167/10 1179/14 1183/6 1184/1 1184/2 Fifth [26] 1124/14 1186/6 1189/14 1189/18 1131/22 1132/5 1132/13 Exhibit 1 [4] 1148/15 1132/16 1132/16 1132/17 1182/16 1184/1 1186/6 1132/18 1136/7 1136/10 Exhibit 3 [1] 1105/8 1204 1136/14 1137/13 1138/25 Page 107 of 126 1140/19 1142/16 1143/1 1148/8 1173/25 1174/3 1175/12 1177/23 1181/7 1191/11 1191/13 1191/15 1193/2 fighting [1] 1164/7 figure [2] 1106/1 1140/25 file [2] 1137/3 1159/21 final [2] 1106/4 1151/10 finally [4] 1105/2 1115/10 1123/18 1129/21 financially [1] 1195/9 find [13] 1125/20 1128/3 1129/1 1132/23 1141/24 1141/25 1176/17 1178/17 1180/21 1186/22 1193/11 1193/12 1193/20 finding [4] 1158/25 1176/4 1178/11 1180/17 fine [2] 1111/22 1170/8 first [20] 1104/22 1112/24 1113/24 1114/15 1114/22 1118/7 1121/8 1135/3 1137/17 1140/1 1144/25 1145/23 1160/11 1173/3 1176/19 1179/15 1179/24 1180/15 1190/17 1194/3 fish [1] 1180/11 five [12] 1104/8 1107/18 1125/6 1125/21 1126/24 1127/13 1143/10 1173/16 1176/12 1176/12 1176/24 1186/4 FL [4] 1098/23 1099/4 1099/9 1099/13 flattened [1] 1167/24 flawed [4] 1144/20 1144/20 1145/20 1158/5 flies [1] 1191/4 flip [4] 1147/16 1148/15 1148/20 1148/23 flows [1] 1145/24 flying [1] 1173/2 focus [3] 1146/15 1185/14 1185/15 focused [1] 1186/24 folks [1] 1114/18 followed [2] 1133/2 1148/16 following [1] 1183/8 fool [4] 1117/8 1117/10 1134/17 1181/6 fooled [1] 1116/25 foot [1] 1116/3 footnote [1] 1156/15 foregoing [1] 1195/2 foreign [3] 1123/5 1135/16 1180/12 foreshadowing [1] 1111/9 forget [1] 1166/23 former [4] 1102/10 1114/1 1125/17 1180/9 forms [1] 1180/14 Fort [3] 1098/23 1099/9 1099/13 forth [2] 1173/13 1189/12 forthcoming [1] 1168/8 forward [4] 1119/15 1122/25 1152/25 1153/7 1109/17 306 1114/22 1114/23 Filed 02/14/20 F Case 1:19-cr-00018-ABJ Document 1118/6 1118/18 1119/13 forwarded [7] 1119/16 1119/13 1120/19 1124/13 1128/21 1130/18 1130/20 1130/1 1131/16 1136/2 1137/15 1138/13 1138/20 1137/17 1137/17 1140/13 forwards [2] 1119/9 1141/9 1142/8 1146/1 1129/13 1150/5 1156/7 1168/3 found [1] 1192/22 1171/18 1172/17 1172/23 foundation [5] 1110/10 1176/6 1181/7 1191/19 1110/11 1111/4 1140/12 gets [13] 1109/15 1110/18 1168/10 1110/23 1121/23 1123/10 four [6] 1107/17 1133/2 1123/20 1130/20 1132/1 1156/7 1156/8 1158/22 1132/19 1133/15 1135/24 1188/5 1136/14 1181/8 Fourth [1] 1098/17 getting [9] 1115/9 Frank [8] 1132/24 1133/4 1115/16 1122/10 1128/21 1133/25 1142/17 1143/2 1132/11 1164/19 1165/17 1170/20 1171/2 1192/18 1165/24 1169/19 fresh [1] 1194/4 Gibbons [1] 1099/3 Friday [1] 1129/3 give [3] 1144/14 1161/10 friend [21] 1106/23 1194/2 1109/23 1110/2 1110/24 given [5] 1144/6 1144/18 1111/13 1112/11 1113/17 1184/3 1187/23 1193/25 1115/1 1115/3 1115/19 giving [7] 1116/24 1119/20 1121/24 1123/7 1120/13 1120/16 1124/6 1123/9 1128/19 1129/22 1140/23 1144/10 1153/14 1137/4 1140/10 1150/9 glasses [1] 1129/19 1167/4 1188/11 global [1] 1183/21 friends [3] 1167/5 gmail.com [2] 1099/14 1171/13 1174/1 1099/18 front [11] 1121/11 go [37] 1104/10 1113/1 1135/22 1147/10 1147/11 1119/19 1129/5 1130/3 1147/12 1149/12 1164/23 1130/11 1131/16 1131/21 1168/16 1172/8 1172/8 1133/25 1134/20 1138/24 1182/18 1141/9 1142/19 1143/11 Ft [1] 1099/4 1143/14 1146/2 1147/15 fuck [4] 1132/18 1134/21 1159/13 1159/15 1159/15 1142/19 1192/19 1162/3 1163/9 1169/8 full [4] 1115/22 1119/23 1172/5 1176/24 1178/13 1134/9 1188/14 1180/18 1181/12 1181/13 full-well [1] 1134/9 1181/13 1181/24 1186/5 fun [1] 1167/12 1186/12 1189/2 1190/10 funny [2] 1138/10 1172/11 1192/18 1193/3 further [9] 1102/1 1110/5 go-between [2] 1104/10 1147/6 1164/16 1190/2 1189/2 1190/13 1194/15 1195/7 Godfather [11] 1133/5 1195/9 1134/2 1162/18 1173/4 1173/5 1173/5 1173/8 G 1173/8 1173/9 1173/15 game [2] 1110/6 1164/9 1173/17 Gates [28] 1109/3 1120/10 Godfather II [1] 1173/5 1120/11 1120/13 1120/21 goes [13] 1122/9 1122/17 1121/8 1121/10 1121/13 1158/5 1172/6 1172/6 1121/19 1121/21 1123/6 1172/7 1183/20 1184/13 1123/16 1140/22 1145/7 1190/2 1190/11 1192/13 1150/20 1154/11 1154/20 1192/14 1192/15 1154/22 1158/17 1168/3 going [104] 1168/4 1168/5 1168/6 gone [4] 1141/7 1141/11 1168/13 1168/16 1168/18 1141/22 1171/25 1168/23 1170/3 good [5] 1102/22 1142/13 gave [6] 1135/17 1146/2 1143/4 1143/11 1171/15 1160/25 1163/20 1189/5 goodness [1] 1125/1 1189/8 got [34] 1104/4 1107/22 gee [2] 1184/24 1187/23 1109/12 1110/20 1112/7 general [1] 1172/16 1112/10 1114/11 1114/11 gentleman [1] 1111/22 1115/18 1115/18 1115/25 gentlemen [6] 1116/21 1116/11 1118/5 1122/5 1124/2 1124/19 1128/5 1128/19 1129/7 1129/9 1134/11 1178/21 1129/10 1130/4 1135/12 get [32] 1101/20 1104/1 1136/11 1136/17 1138/2 1104/12 1109/9 1109/11 1141/6 1141/13 1147/12 1205 1157/24 1162/22 1171/24 Page 108 of 126 1172/13 1175/2 1180/19 1189/22 1189/22 govern [1] 1193/24 governance [1] 1193/13 government [40] 1103/6 1139/8 1139/16 1139/19 1144/18 1146/24 1147/15 1147/19 1147/21 1149/22 1151/6 1151/18 1152/12 1152/19 1152/25 1155/2 1156/14 1157/12 1157/18 1161/15 1163/15 1164/3 1164/12 1165/3 1165/21 1165/22 1168/10 1168/23 1168/24 1169/17 1169/18 1169/22 1171/4 1171/4 1174/21 1176/10 1177/22 1180/6 1180/12 1192/5 government's [11] 1113/12 1118/16 1119/11 1146/7 1149/7 1157/3 1167/17 1167/24 1180/25 1189/14 1189/18 governmental [2] 1144/7 1144/9 governments [1] 1157/1 Gowdy [2] 1108/7 1186/10 Gowdy's [1] 1148/2 GRANT [1] 1099/7 grave [1] 1144/5 great [1] 1179/11 Gsmith [1] 1099/10 guarantee [1] 1181/8 guard [1] 1162/21 Guccifer [6] 1121/2 1170/5 1170/6 1170/8 1170/15 1170/17 Guccifer 2.0 [1] 1121/2 guess [3] 1157/3 1168/23 1175/21 guesses [1] 1153/11 guilt [1] 1178/11 guilty [6] 1139/18 1144/19 1176/18 1178/17 1192/2 1193/20 guy [40] 1108/16 1109/16 1112/18 1113/10 1116/1 1116/5 1116/19 1116/20 1117/13 1117/22 1118/7 1118/9 1118/10 1118/12 1123/16 1125/2 1125/3 1125/9 1125/13 1125/14 1125/23 1126/19 1126/25 1127/16 1127/18 1127/21 1129/8 1130/17 1131/2 1136/17 1137/12 1137/21 1137/23 1138/3 1140/13 1140/18 1174/25 1187/20 1190/7 1191/2 guys [5] 1102/22 1107/23 1171/7 1171/12 1171/25 H hack [1] 1121/3 hacked [5] 1105/18 1105/23 1120/24 1180/12 1185/16 hackers [1] 1110/6 hacking [3] 1184/7 1184/16 1185/20 1149/22 306 1149/25 1156/9 Filed 02/14/20 H Case 1:19-cr-00018-ABJ Document 1156/19 1159/23 1163/15 had [90] 1102/12 1103/4 1166/19 1169/17 1171/25 1103/15 1103/24 1105/23 1172/8 1176/11 1176/17 1106/22 1108/9 1111/9 1181/3 1190/8 1194/15 1111/19 1112/2 1113/6 have [141] 1114/24 1115/8 1116/9 having [3] 1114/25 1116/19 1117/15 1120/11 1152/22 1175/13 1121/12 1122/6 1125/3 he [345] 1125/25 1126/6 1128/12 he's [39] 1101/16 1101/19 1128/17 1129/17 1129/24 1101/23 1101/24 1102/4 1130/1 1130/8 1130/9 1109/10 1109/15 1109/21 1136/18 1136/20 1140/12 1110/20 1112/14 1112/15 1141/12 1145/1 1147/10 1113/5 1114/11 1114/11 1147/24 1147/24 1148/5 1115/16 1118/10 1122/10 1150/6 1150/7 1150/8 1125/13 1128/14 1130/23 1150/9 1153/9 1153/15 1131/24 1133/4 1139/18 1153/19 1156/16 1157/10 1142/8 1142/21 1158/11 1157/15 1158/7 1158/9 1164/24 1164/24 1167/14 1158/16 1158/17 1160/22 1169/2 1171/20 1172/19 1161/22 1164/3 1166/1 1172/19 1172/20 1181/2 1166/11 1166/14 1166/16 1184/3 1184/9 1186/11 1166/19 1167/2 1167/10 1191/5 1167/20 1167/21 1170/21 head [7] 1106/24 1109/9 1170/24 1171/13 1171/19 1130/15 1131/15 1143/7 1173/7 1173/19 1175/5 1161/17 1161/18 1175/5 1175/16 1175/22 header [1] 1166/24 1177/22 1180/7 1180/7 heads [1] 1153/15 1180/10 1182/10 1182/20 heads-up [1] 1153/15 1182/24 1182/24 1184/17 health [1] 1110/9 1185/21 1186/1 1189/16 hear [13] 1103/2 1121/19 1190/6 1191/25 1192/3 1148/18 1153/5 1157/25 1192/23 1162/3 1163/5 1165/21 hadn't [1] 1149/11 1168/21 1174/11 1177/1 hair [1] 1129/18 1177/2 1179/9 Haley [1] 1179/20 heard [29] 1103/10 1111/5 half [4] 1121/17 1163/7 1113/14 1114/8 1115/2 1163/15 1185/18 1117/4 1120/5 1120/9 hand [3] 1162/19 1162/19 1120/17 1123/1 1123/10 1172/12 1128/16 1138/15 1140/8 hangs [1] 1121/20 1140/15 1141/7 1153/21 happen [10] 1114/24 1154/17 1157/21 1157/23 1122/24 1127/24 1128/2 1158/4 1161/25 1163/4 1130/5 1142/6 1153/18 1167/5 1168/14 1175/14 1154/2 1165/1 1182/22 1177/8 1178/22 1194/8 happened [15] 1115/7 hearing [22] 1107/19 1128/25 1137/6 1147/12 1109/22 1111/15 1116/3 1150/1 1150/5 1153/24 1119/17 1124/10 1124/12 1153/25 1158/25 1160/1 1141/10 1156/16 1156/22 1169/13 1173/9 1180/2 1156/22 1159/10 1182/17 1180/19 1186/14 1183/8 1183/15 1185/5 happening [2] 1108/22 1185/6 1185/7 1185/14 1173/10 1185/15 1186/24 1195/9 happens [3] 1145/8 1145/9 hearings [2] 1184/5 1145/9 1193/14 happiness [1] 1168/5 hears [3] 1132/8 1140/18 happy [2] 1168/5 1176/1 1140/21 harassment [1] 1140/20 heart [1] 1151/2 hard [1] 1128/13 heckled [3] 1153/24 has [50] 1103/3 1103/4 1154/1 1154/4 1103/10 1108/6 1108/10 HELD [1] 1098/10 1110/7 1112/1 1112/8 help [1] 1109/6 1114/1 1115/24 1116/12 helpful [3] 1150/6 1119/8 1120/25 1121/4 1175/17 1191/15 1121/7 1121/18 1122/11 her [13] 1110/9 1115/8 1126/22 1127/19 1128/12 1129/22 1129/23 1149/17 1131/1 1135/4 1135/17 1164/3 1166/16 1166/17 1136/14 1137/10 1137/11 1167/7 1170/6 1170/14 1137/13 1139/8 1143/17 1192/24 1192/25 1144/6 1144/18 1145/20 here [73] 1101/16 1101/19 1146/24 1147/15 1147/21 1101/23 1101/24 1102/21 1206 1102/22 1106/13 1107/6 Page 109 of 126 1107/13 1110/1 1114/9 1115/17 1124/6 1125/6 1132/15 1133/1 1135/24 1136/14 1141/16 1142/7 1142/11 1145/24 1147/14 1147/20 1147/24 1148/12 1148/21 1148/24 1149/6 1149/18 1149/25 1150/11 1156/10 1157/24 1160/12 1160/17 1160/18 1161/12 1162/21 1162/22 1162/24 1163/24 1164/5 1164/5 1165/15 1165/20 1172/5 1173/20 1173/22 1174/19 1177/16 1177/16 1178/24 1179/7 1179/9 1181/11 1181/18 1182/2 1182/2 1183/4 1183/5 1183/22 1184/15 1184/21 1184/24 1188/2 1188/4 1188/12 1188/25 1189/23 1192/10 1192/11 1192/15 Here's [8] 1107/19 1108/3 1108/19 1110/25 1111/7 1117/20 1133/22 1137/17 hesitate [9] 1144/12 1144/15 1151/2 1152/5 1152/20 1156/5 1163/24 1176/14 1177/15 hesitation [2] 1167/16 1171/24 hidden [2] 1148/12 1164/7 hide [4] 1130/13 1158/6 1160/24 1180/14 hiding [2] 1180/14 1180/15 high [1] 1151/6 highest [1] 1109/2 highlighted [1] 1131/7 Hillary [10] 1110/7 1110/12 1110/22 1112/9 1118/18 1119/14 1122/12 1175/15 1184/19 1184/23 him [71] 1102/5 1104/12 1107/5 1107/15 1107/16 1112/25 1114/12 1114/12 1114/14 1115/24 1117/13 1118/10 1118/21 1119/2 1120/10 1121/17 1125/5 1127/16 1128/11 1129/5 1129/9 1130/4 1130/4 1132/21 1134/5 1134/10 1134/12 1134/20 1135/7 1135/11 1135/21 1138/13 1138/21 1140/18 1141/16 1141/19 1148/7 1148/7 1157/23 1158/1 1158/1 1158/2 1159/19 1161/22 1162/15 1164/21 1165/16 1165/17 1166/12 1167/14 1167/14 1169/19 1172/8 1172/25 1173/15 1173/25 1174/13 1175/11 1175/14 1178/6 1178/8 1180/16 1182/22 1182/25 1187/19 1190/24 1192/9 1192/17 1192/18 1192/20 1193/20 himself [8] 1107/6 1109/4 1134/21 1142/20 1165/16 1166/7 1175/18 1192/19 HPSCI [3]306 1183/6 Filed1183/7 02/14/20 H Case 1:19-cr-00018-ABJ Document 1183/7 hint [1] 1150/22 HRC [2] 1110/7 1149/23 his [82] 1103/20 1103/22 hue [1] 1163/2 1103/25 1104/6 1104/9 huge [2] 1176/8 1176/8 1104/11 1104/13 1104/14 hundred [4] 1125/21 1104/15 1107/1 1107/6 1125/22 1176/13 1176/24 1113/2 1113/5 1113/22 hundreds [1] 1125/15 1114/22 1119/8 1119/17 hurt [1] 1110/6 1119/23 1119/25 1120/7 I 1120/8 1120/18 1123/21 1126/16 1126/23 1128/13 I'll [14] 1113/1 1113/1 1129/18 1129/19 1131/8 1132/11 1137/3 1144/3 1132/7 1133/8 1135/18 1144/24 1147/11 1147/14 1137/25 1142/1 1143/2 1149/20 1159/11 1162/17 1143/7 1147/13 1148/9 1177/17 1188/9 1194/16 1148/19 1150/3 1150/9 I'm [43] 1102/6 1109/24 1157/22 1158/10 1160/2 1114/13 1114/14 1116/1 1161/4 1162/11 1163/12 1117/13 1118/15 1119/20 1164/16 1165/11 1167/4 1121/16 1121/17 1129/5 1167/5 1167/17 1168/24 1129/7 1134/18 1136/17 1170/15 1171/14 1171/14 1141/16 1142/18 1144/3 1171/15 1171/16 1172/16 1146/16 1148/22 1149/1 1174/4 1174/5 1174/9 1149/1 1156/7 1156/10 1174/13 1174/14 1175/18 1158/3 1158/19 1161/10 1176/19 1176/20 1178/3 1161/12 1162/20 1166/23 1179/4 1181/1 1182/4 1169/13 1169/13 1169/14 1182/11 1183/22 1183/25 1174/11 1178/12 1178/16 1184/3 1185/6 1185/8 1179/13 1179/14 1181/13 1186/12 1186/13 1187/18 1181/14 1183/6 1188/19 1188/11 1190/19 1193/3 1193/8 history [3] 1165/5 1165/5 I've [11] 1115/18 1115/18 1165/6 1116/17 1128/15 1129/9 Hold [1] 1138/8 1129/10 1141/13 1151/3 holding [1] 1151/6 1151/11 1157/24 1159/11 honest [2] 1125/1 1137/2 IAN [1] 1098/14 honest-to-goodness [1] idea [8] 1122/2 1122/3 1125/1 1122/8 1140/12 1143/11 Honestly [1] 1170/7 1151/20 1183/2 1188/4 Honor [2] 1101/5 1174/11 identified [2] 1128/1 HONORABLE [1] 1098/11 1131/1 hook [2] 1115/4 1167/1 identify [1] 1131/8 hoping [3] 1114/15 1150/5 identifying [2] 1130/17 1172/17 1137/12 host [1] 1153/17 identity [4] 1104/9 hour [1] 1121/6 1113/2 1186/8 1186/8 hours [3] 1163/5 1163/7 idle [1] 1178/3 1163/14 II [3] 1133/5 1173/5 house [20] 1103/12 1173/5 1103/13 1105/5 1105/25 illegal [6] 1145/5 1106/3 1106/14 1106/17 1146/13 1156/2 1159/24 1106/25 1124/4 1125/24 1169/10 1176/3 1127/17 1130/21 1131/18 imitation [1] 1165/12 1132/20 1135/20 1137/2 imitations [1] 1165/11 1139/11 1181/2 1182/18 impact [1] 1109/25 1183/7 impede [2] 1139/19 how [38] 1105/3 1108/19 1139/22 impeding [1] 1139/25 1114/11 1115/15 1115/20 importance [1] 1183/16 1119/18 1122/6 1122/23 important [25] 1106/16 1124/3 1124/15 1129/4 1107/25 1108/1 1108/3 1129/25 1132/4 1133/24 1136/3 1144/12 1147/7 1136/2 1140/1 1142/2 1147/14 1148/24 1152/3 1147/11 1149/14 1151/9 1152/3 1152/4 1156/5 1151/19 1152/9 1159/1 1156/8 1165/6 1165/9 1160/1 1161/8 1161/13 1167/8 1167/12 1167/13 1163/13 1164/21 1168/22 1167/15 1171/5 1171/23 1168/24 1169/14 1171/2 1176/15 1185/12 1191/18 1175/9 1176/25 1187/4 imposing [1] 1169/22 1187/16 1187/19 1193/25 impression [1] 1132/24 However [2] 1192/10 impressionist [2] 1131/9 1193/13 1207 1173/20 Page 110 of 126 impressive [1] 1155/21 inaccuracies [4] 1141/23 1158/22 1158/23 1158/24 incident [2] 1171/17 1171/17 include [2] 1162/6 1183/10 includes [1] 1126/9 including [3] 1125/5 1125/22 1131/5 indeed [1] 1125/23 indicted [1] 1181/9 indictment [1] 1127/12 indispensability [1] 1186/10 individuals [2] 1105/11 1162/6 inference [12] 1101/10 1101/18 1101/21 1102/1 1151/19 1151/19 1151/22 1152/20 1152/21 1155/7 1156/1 1165/24 inferences [2] 1155/10 1157/6 influence [5] 1139/10 1173/14 1183/18 1191/25 1192/3 influenced [1] 1139/13 info [2] 1182/24 1182/25 information [70] 1104/2 1104/5 1106/21 1107/1 1110/18 1110/20 1110/23 1112/7 1112/10 1115/17 1120/7 1120/11 1120/13 1120/15 1120/15 1120/19 1121/21 1122/4 1122/10 1122/23 1123/10 1123/12 1123/14 1124/6 1135/18 1136/18 1138/6 1140/13 1140/23 1141/5 1141/5 1142/1 1145/6 1145/9 1145/14 1145/16 1147/24 1147/25 1150/5 1153/1 1153/9 1157/15 1160/22 1160/22 1161/23 1164/19 1164/20 1164/21 1165/17 1165/18 1165/19 1165/19 1165/25 1167/21 1168/3 1168/4 1168/6 1169/10 1169/11 1169/11 1170/17 1180/8 1180/11 1180/12 1181/22 1182/10 1182/21 1184/8 1184/9 1184/11 InfoWars [3] 1107/22 1111/7 1113/22 initiated [1] 1173/6 inquire [1] 1101/9 inquiry [2] 1146/11 1166/19 inside [7] 1124/6 1136/18 1167/21 1175/24 1182/20 1182/24 1182/25 insisted [1] 1161/5 instance [1] 1187/3 institutions [1] 1193/13 instruct [2] 1139/16 1191/24 instructed [3] 1176/17 1191/20 1193/23 instructions [5] 1144/10 1105/7 1106/7 1106/16 306 Filed 02/14/20 I Case 1:19-cr-00018-ABJ Document 1107/2 1107/15 1134/15 instructions... [4] 1136/5 1139/12 1139/13 1144/11 1151/11 1194/3 1139/18 1139/20 1139/22 1194/12 1139/25 1141/9 1143/8 insult [1] 1137/7 1154/12 1154/13 1179/6 Intel [1] 1137/3 1180/4 1181/19 1187/25 intelligence [16] 1103/13 1193/17 1103/13 1105/6 1105/25 investigations [1] 1106/3 1106/14 1106/17 1116/15 1106/25 1125/25 1131/18 invite [1] 1189/19 1132/20 1135/21 1139/11 invited [1] 1157/17 1182/18 1183/7 1183/19 invoked [1] 1102/12 intending [1] 1101/10 invoking [1] 1173/15 intent [5] 1163/19 involved [13] 1103/15 1166/11 1176/16 1191/25 1103/18 1105/14 1106/2 1192/3 1106/9 1107/3 1107/9 intention [1] 1113/6 1123/12 1123/22 1124/5 intentionally [4] 1163/19 1150/14 1180/6 1180/6 1176/5 1176/5 1176/6 involvement [2] 1106/15 interest [1] 1158/7 1183/10 interested [8] 1145/5 is [407] 1145/14 1145/15 1145/17 isn't [3] 1116/17 1134/1 1145/17 1150/21 1168/2 1180/20 1195/10 issue [4] 1147/8 1170/11 interesting [3] 1163/11 1173/20 1179/13 1164/13 1173/22 issues [1] 1178/23 interests [1] 1160/10 it [165] interfered [2] 1103/15 it's [59] 1111/5 1113/2 1135/16 1113/21 1114/15 1115/23 interference [8] 1105/7 1118/16 1119/7 1119/7 1139/12 1157/8 1158/18 1121/14 1121/19 1121/22 1160/22 1160/23 1161/7 1122/4 1122/11 1123/11 1182/10 1124/16 1124/21 1126/16 intermediaries [1] 1127/19 1128/18 1129/11 1174/23 1129/12 1134/14 1136/7 intermediary [46] 1104/9 1137/9 1140/7 1147/4 1104/11 1104/14 1104/15 1147/18 1148/13 1148/23 1106/23 1108/4 1108/14 1152/16 1152/17 1152/18 1110/23 1111/24 1112/11 1155/9 1155/18 1155/21 1112/25 1113/1 1113/17 1155/25 1156/8 1160/13 1114/7 1114/12 1114/25 1161/5 1163/5 1163/6 1115/21 1120/8 1123/11 1163/11 1164/8 1165/12 1123/22 1125/3 1126/1 1165/12 1165/18 1165/19 1127/2 1127/5 1127/7 1168/13 1169/4 1169/4 1129/12 1150/14 1150/18 1170/13 1173/8 1176/8 1150/23 1151/5 1182/13 1176/8 1177/16 1181/16 1183/18 1185/13 1185/15 1188/6 1189/4 1192/15 1186/9 1186/12 1186/18 its [8] 1103/6 1136/5 1186/19 1186/20 1186/22 1162/5 1169/23 1169/23 1186/25 1187/5 1187/8 1176/10 1176/10 1183/8 1187/18 1189/1 1189/11 itself [2] 1104/23 interview [14] 1111/10 1146/17 1114/19 1114/21 1115/6 J 1115/10 1115/16 1127/22 1127/25 1128/20 1131/19 JACKSON [2] 1098/11 1132/2 1153/8 1171/15 1191/24 1189/8 January [8] 1105/5 interviewing [1] 1186/11 1116/14 1134/20 1135/7 interviews [1] 1131/10 1142/16 1190/2 1190/19 Introduced [2] 1135/7 1190/24 JASON [1] 1098/7 1190/24 JED [1] 1098/15 introducing [1] 1178/23 Jerome [27] 1108/17 investigated [1] 1183/9 1109/8 1109/16 1111/1 investigating [7] 1105/9 1111/5 1112/7 1112/15 1107/5 1135/16 1146/20 1112/19 1112/21 1113/13 1146/20 1185/18 1185/19 1116/21 1117/16 1118/2 investigation [31] 1118/11 1119/1 1121/6 1103/11 1103/12 1103/14 1122/5 1125/3 1126/10 1103/17 1103/20 1104/23 1130/13 1136/7 1137/15 1105/4 1105/5 1105/6 1208 1139/14 1140/8 1142/3 Page 111 of 126 1179/5 1180/15 job [3] 1144/16 1172/25 1176/10 JOHN [3] 1098/14 1184/7 1184/17 join [1] 1102/25 joked [1] 1173/7 joking [1] 1167/11 JON [1] 1098/15 JONATHAN [1] 1098/14 Jonathan.kravis3 [1] 1098/18 Jones [1] 1189/8 JR [1] 1098/7 judge [6] 1098/11 1139/16 1144/10 1144/14 1191/20 1191/24 Julian [19] 1106/24 1108/10 1110/2 1110/24 1111/20 1115/1 1115/9 1118/4 1123/9 1126/7 1126/13 1127/10 1131/10 1148/2 1148/5 1153/6 1153/8 1153/11 1165/18 July [12] 1105/21 1108/20 1108/25 1109/7 1118/3 1120/12 1121/10 1137/16 1137/18 1137/19 1147/19 1147/22 July 2016 [1] 1137/16 July 22nd [2] 1105/21 1108/20 July 25th [1] 1118/3 jumps [1] 1109/6 June [10] 1120/12 1120/23 1121/2 1125/19 1138/19 1147/18 1147/20 1147/22 1153/9 1153/14 June 17 [1] 1147/18 juror [1] 1102/24 jurors [2] 1103/1 1193/23 jury [17] 1098/5 1098/10 1101/10 1101/25 1102/19 1102/20 1102/21 1124/19 1134/11 1143/16 1143/20 1143/23 1143/25 1184/1 1186/6 1188/16 1194/14 just [54] 1101/6 1101/9 1101/18 1101/19 1102/14 1103/3 1109/7 1109/12 1109/17 1109/19 1113/7 1113/23 1117/7 1117/9 1118/3 1118/5 1118/9 1118/20 1119/6 1119/12 1122/5 1122/7 1122/7 1124/21 1126/10 1126/11 1130/10 1131/22 1131/25 1133/25 1134/14 1135/17 1137/2 1138/16 1138/21 1139/21 1140/7 1153/19 1155/18 1156/10 1158/24 1161/10 1162/2 1173/12 1178/22 1179/1 1183/3 1185/16 1186/4 1189/7 1189/15 1189/25 1190/1 1193/4 justifies [1] 1178/11 K keep [4] 1129/23 1134/24 1184/21 306 Filed 02/14/20 K Case 1:19-cr-00018-ABJ Document KRAVIS [8] 1098/14 1100/4 keep... [2] 1137/3 1103/8 1180/25 1181/23 1175/18 1186/13 1189/12 1190/20 keeps [5] 1112/6 1112/10 Kunstler [24] 1115/2 1113/16 1138/17 1138/21 1119/21 1128/18 1128/19 kept [4] 1120/11 1157/13 1128/23 1129/10 1129/15 1158/2 1186/7 1130/6 1130/9 1149/16 key [4] 1149/14 1149/16 1149/19 1149/20 1150/9 1183/17 1192/4 1153/4 1164/16 1166/1 kibitzing [1] 1172/1 1166/1 1166/15 1166/15 kicker [1] 1133/12 1166/22 1167/6 1167/9 kidding [3] 1125/14 1192/16 1192/22 1188/13 1188/13 kind [31] 1111/9 1114/15 L 1117/5 1117/7 1119/19 ladies [6] 1116/21 1124/2 1148/18 1150/9 1150/22 1124/19 1128/5 1134/11 1151/18 1151/22 1155/7 1178/21 1155/17 1156/12 1159/3 LaGuardia [2] 1121/15 1163/19 1165/20 1165/23 1169/3 landmark [1] 1131/10 1165/24 1166/5 1166/5 1166/6 1166/7 1167/1 language [3] 1171/11 1171/11 1174/25 1167/4 1167/15 1168/21 1171/20 1171/22 1172/24 largely [1] 1184/5 1173/10 1176/16 Las [2] 1099/8 1099/12 kinds [4] 1165/25 1169/5 last [11] 1123/7 1129/3 1142/9 1149/9 1155/1 1171/9 1172/1 knew [30] 1103/23 1103/25 1155/1 1155/1 1156/25 1160/9 1170/4 1170/25 1104/5 1107/4 1107/4 late [1] 1121/10 1107/14 1117/15 1119/23 later [14] 1109/12 1127/23 1127/24 1128/1 1109/15 1111/10 1130/6 1128/6 1128/18 1128/24 1130/7 1130/7 1130/8 1132/10 1132/22 1146/23 1130/9 1130/10 1130/12 1147/1 1147/4 1148/8 1139/9 1153/6 1153/18 1162/17 1173/17 1181/5 1175/3 1175/4 1182/15 1190/11 1182/22 1182/25 1184/16 Lauderdale [4] 1098/23 1185/7 1099/4 1099/9 1099/13 knock [1] 1127/17 law [8] 1098/21 1099/11 know [51] 1102/11 1103/1 1131/10 1149/3 1191/21 1106/2 1106/21 1106/22 1192/9 1193/14 1193/24 1107/25 1108/19 1112/1 lawyer [8] 1115/3 1132/12 1112/20 1112/21 1117/25 1137/9 1174/4 1174/5 1120/5 1122/6 1122/18 1174/9 1174/13 1178/8 1130/22 1131/1 1133/11 lawyers [4] 1132/2 1174/1 1134/1 1134/3 1135/20 1174/14 1178/2 1136/10 1136/12 1138/10 lay [1] 1102/4 1138/14 1143/2 1147/19 lead [3] 1136/5 1161/4 1149/3 1154/1 1154/4 1169/18 1157/25 1158/5 1158/24 leading [1] 1183/19 1162/17 1162/18 1162/19 leaked [1] 1105/18 1163/9 1169/2 1169/3 leaks [1] 1146/12 1169/15 1170/7 1170/17 learned [1] 1141/3 1172/25 1175/6 1179/11 learns [1] 1141/3 1181/19 1182/24 1186/1 least [1] 1163/23 1186/20 1192/17 1192/18 leave [1] 1127/15 1193/10 leaves [1] 1127/16 left [2] 1130/16 1193/22 knowing [4] 1152/9 lefty [1] 1165/11 1155/15 1155/25 1180/11 legal [1] 1132/18 knowledge [12] 1115/8 lens [1] 1188/4 1152/22 1175/5 1175/5 less [1] 1115/7 1182/21 1183/11 1183/22 let [2] 1126/17 1169/8 1183/22 1184/18 1184/21 let's [6] 1102/19 1107/19 1185/8 1185/22 1120/1 1139/5 1143/24 known [1] 1169/12 1147/15 knows [17] 1110/17 letter [24] 1113/9 1115/22 1115/23 1119/7 1113/12 1116/11 1116/13 1119/7 1124/3 1124/15 1127/24 1128/1 1130/16 1124/16 1127/18 1152/23 1130/19 1130/21 1130/25 1168/17 1168/25 1169/1 1131/5 1131/11 1131/13 1173/11 1181/3 1184/10 1209 1132/1 1137/12 1172/10 Page 112 of 126 1172/13 1172/15 1172/16 1172/20 1172/20 1172/21 1172/23 1189/19 letters [2] 1160/2 1160/6 letting [1] 1175/22 levels [1] 1109/2 liberal [2] 1165/7 1175/19 Libya [7] 1118/18 1118/23 1119/14 1128/22 1150/2 1150/7 1166/19 lie [52] 1107/19 1113/3 1113/14 1115/23 1115/23 1117/18 1117/20 1118/12 1118/13 1119/7 1119/7 1119/7 1119/25 1120/1 1124/18 1124/18 1125/10 1125/11 1126/3 1126/5 1126/22 1130/23 1131/16 1131/21 1134/3 1134/10 1136/3 1138/17 1138/22 1138/24 1145/12 1145/25 1159/4 1159/16 1166/12 1174/20 1174/22 1175/9 1177/3 1177/21 1179/2 1179/3 1179/4 1179/5 1179/12 1179/19 1179/19 1181/14 1181/18 1183/5 1187/21 1191/8 lied [17] 1103/20 1104/7 1104/9 1104/11 1104/12 1104/14 1104/15 1117/17 1128/4 1140/5 1141/20 1144/22 1145/19 1168/11 1176/5 1176/5 1193/16 lies [19] 1103/22 1104/8 1104/17 1104/19 1104/24 1107/17 1119/4 1123/25 1124/16 1126/16 1126/23 1126/24 1127/14 1127/18 1132/8 1133/10 1134/13 1137/25 1181/15 life [1] 1167/16 light [1] 1183/12 like [22] 1111/18 1112/25 1115/6 1119/19 1121/16 1123/5 1129/19 1133/25 1134/1 1141/16 1143/10 1152/21 1154/2 1154/6 1154/7 1165/14 1167/8 1171/21 1175/15 1185/25 1185/25 1188/19 liked [1] 1175/15 likened [1] 1152/4 line [2] 1116/17 1165/22 lines [4] 1133/12 1133/14 1162/20 1162/21 links [3] 1105/10 1133/2 1162/6 list [3] 1152/7 1187/12 1187/21 listen [10] 1112/3 1115/15 1153/3 1153/4 1153/5 1162/3 1163/10 1176/24 1177/2 1177/25 listening [3] 1163/14 1167/14 1194/2 literally [5] 1184/10 1184/20 1187/18 1190/1 1190/8 made-up [1] 306 1136/24 Filed 02/14/20 L Case 1:19-cr-00018-ABJ Document mail [2] 1129/10 1130/1 little [6] 1114/12 mails [1] 1184/17 1128/13 1142/7 1152/17 make [24] 1109/12 1131/14 1155/18 1162/17 1142/15 1150/25 1151/10 live [1] 1193/10 1152/3 1152/9 1153/11 living [2] 1109/10 1110/2 1156/23 1158/25 1159/4 load [3] 1122/24 1152/25 1162/14 1163/11 1163/12 1153/7 1163/18 1174/16 1174/24 London [5] 1109/11 1176/2 1176/3 1176/4 1116/10 1123/7 1123/9 1178/24 1182/16 1185/3 1189/18 1191/18 long [9] 1139/18 1145/1 makes [9] 1144/23 1149/5 1165/5 1165/5 1165/6 1151/1 1158/9 1161/3 1171/19 1171/25 1177/19 1162/13 1177/22 1190/13 1193/25 1191/4 longer [1] 1109/1 making [9] 1102/2 1106/19 longtime [2] 1104/6 1109/20 1110/19 1113/7 1108/23 1113/21 1127/13 1167/12 look [61] 1103/25 1104/6 1175/1 1115/16 1116/2 1116/7 malevolent [1] 1178/15 1117/9 1119/11 1119/15 malign [1] 1183/17 1124/3 1124/7 1124/15 malignant [5] 1152/15 1131/7 1132/4 1132/21 1152/16 1156/2 1156/24 1133/15 1133/25 1135/11 1173/13 1135/12 1135/12 1136/6 Malloch [3] 1109/13 1136/13 1136/19 1141/24 1121/7 1137/18 1145/8 1148/1 1148/25 man [14] 1103/9 1103/22 1149/8 1150/2 1151/9 1108/17 1113/10 1117/4 1151/13 1151/24 1152/11 1125/3 1129/16 1129/17 1152/24 1153/3 1154/14 1142/21 1175/2 1177/3 1155/20 1155/21 1156/19 1187/18 1188/15 1188/24 1156/25 1158/20 1159/8 Manafort [5] 1109/4 1159/11 1160/5 1161/4 1121/22 1122/1 1122/8 1164/9 1166/10 1172/5 1169/20 1173/2 1177/6 1178/14 manager [4] 1109/3 1120/9 1178/14 1178/15 1178/24 1172/16 1189/19 1180/13 1180/13 1181/23 manipulate [1] 1188/20 1186/5 1186/7 1187/23 manipulated [5] 1149/19 1188/19 1193/18 1165/4 1188/24 1189/25 looked [6] 1113/23 1114/2 1191/3 1114/2 1179/25 1180/1 manipulating [1] 1165/2 1185/25 manipulator [2] 1149/19 looking [10] 1103/17 1188/10 1105/25 1106/17 1109/15 many [5] 1125/16 1175/9 1147/6 1149/9 1178/25 1175/10 1176/25 1185/25 1181/22 1185/23 1194/10 MARANDO [4] 1098/14 loose [2] 1127/16 1132/7 1100/7 1142/8 1178/19 lose [1] 1138/15 March [3] 1119/15 1147/5 loss [1] 1129/16 1158/23 lot [9] 1157/17 1158/10 Margaret [22] 1115/2 1164/1 1169/4 1178/22 1119/20 1128/18 1128/18 1178/22 1178/23 1178/24 1128/23 1129/10 1130/6 1179/16 1137/4 1149/19 1149/20 lots [2] 1125/4 1125/4 1150/9 1153/4 1164/16 loud [1] 1194/1 1166/1 1166/1 1166/14 Lugo [2] 1175/7 1175/7 1166/15 1166/22 1167/6 Luke [2] 1162/19 1162/19 1167/9 1192/15 1192/22 lying [5] 1113/4 1124/1 mastermind [2] 1116/23 1126/14 1139/13 1182/4 1188/19 lynchpin [1] 1165/21 material [2] 1120/12 1120/14 M materials [2] 1146/12 machine [1] 1130/2 1170/18 made [18] 1107/8 1133/19 matter [7] 1141/15 1136/24 1138/8 1149/3 1144/15 1152/1 1156/18 1150/3 1155/17 1159/6 1169/8 1169/9 1195/6 1162/16 1166/20 1174/4 matters [11] 1135/25 1176/19 1176/20 1182/20 1144/13 1152/5 1156/6 1183/7 1183/8 1184/14 1167/15 1171/23 1183/9 1185/24 1193/9 1193/9 1193/15 1210 1193/18 Page 113 of 126 may [14] 1102/23 1108/9 1108/9 1111/4 1116/18 1135/10 1136/5 1137/1 1143/18 1148/5 1148/5 1162/12 1190/5 1194/9 maybe [4] 1147/18 1152/17 1162/13 1162/20 me [25] 1116/8 1120/13 1120/16 1122/2 1125/14 1131/21 1132/2 1133/8 1133/19 1133/20 1148/18 1159/10 1167/19 1169/8 1170/20 1171/20 1183/24 1184/15 1184/25 1185/1 1185/2 1188/13 1188/13 1189/15 1195/4 mean [5] 1152/14 1155/11 1165/9 1168/20 1171/13 meaning [3] 1152/12 1152/18 1182/2 meaningless [1] 1146/24 means [5] 1144/11 1152/23 1155/16 1187/7 1194/6 meant [5] 1117/11 1134/8 1152/22 1188/6 1188/22 measures [4] 1146/23 1162/4 1162/6 1181/20 media [2] 1130/4 1193/11 meeting [1] 1177/25 member [1] 1154/18 members [4] 1143/16 1162/14 1184/14 1185/10 memory [1] 1110/7 men [2] 1115/20 1125/21 mention [7] 1114/16 1140/8 1140/10 1149/25 1150/23 1157/22 1159/12 mentioned [6] 1106/3 1137/1 1154/21 1159/11 1162/10 1177/7 mentioning [1] 1126/19 mentions [2] 1113/12 1149/24 message [14] 1109/5 1109/7 1109/13 1113/20 1114/3 1114/6 1116/7 1124/11 1130/2 1132/16 1132/17 1132/17 1133/15 1189/15 messages [43] 1103/25 1104/3 1113/19 1114/3 1116/1 1117/9 1124/25 1125/5 1125/5 1125/12 1125/14 1125/25 1126/1 1126/10 1126/11 1126/19 1132/15 1133/24 1134/2 1134/4 1134/8 1134/12 1135/10 1136/21 1138/23 1140/17 1141/7 1141/10 1141/11 1141/13 1141/19 1141/20 1141/22 1142/16 1156/15 1156/21 1158/20 1161/18 1185/1 1185/2 1187/10 1187/21 1187/22 messing [2] 1130/15 1131/15 met [3] 1174/1 1174/1 1190/17 MICHAEL [4] 1098/14 1133/20 1133/21 1142/8 Mr [24] 1100/4 1100/5 306 Filed 02/14/20 M Case 1:19-cr-00018-ABJ Document 1100/7 1112/1 1112/1 Michael.marando [1] 1121/13 1144/2 1144/22 1098/19 1145/1 1145/3 1158/9 Michelle [4] 1164/2 1177/19 1179/2 1179/20 1164/9 1166/3 1170/4 1180/2 1180/9 1180/10 might [5] 1141/17 1141/19 1182/15 1182/18 1183/14 1141/20 1153/11 1162/14 1186/15 1190/20 1192/22 Millers [1] 1154/21 1193/1 mind [13] 1108/6 1113/5 Mr. [140] 1122/6 1147/13 1147/13 Mr. Bannon [3] 1122/13 1157/1 1158/10 1160/21 1122/14 1145/7 1161/8 1182/3 1182/9 Mr. Buschel [1] 1160/6 1185/6 1188/6 Mr. Corsi [2] 1101/14 mindset [1] 1156/9 1109/23 minute [3] 1104/22 Mr. Credico [29] 1114/9 1119/22 1139/5 1119/18 1128/12 1129/14 minutes [3] 1143/10 1148/19 1164/12 1171/6 1146/8 1167/11 1174/24 1181/3 1181/5 mirrors [1] 1178/22 1181/6 1181/12 1188/14 mislead [2] 1163/19 1189/11 1189/14 1189/21 1177/4 1190/2 1190/5 1190/8 misleading [1] 1139/14 1190/13 1190/15 1191/1 misled [1] 1164/15 1191/3 1191/11 1191/11 Miss [1] 1133/17 1191/14 1191/23 1192/7 Miss Taylor [1] 1133/17 1192/12 misshapen [1] 1125/8 Mr. Credico's [1] 1192/3 missing [4] 1101/11 Mr. Gates [2] 1121/10 1101/12 1102/24 1149/1 1145/7 mistake [2] 1138/9 Mr. Gowdy [1] 1186/10 1182/16 Mr. Gowdy's [1] 1148/2 misunderstanding [1] MR. KRAVIS [5] 1103/8 1142/12 1180/25 1181/23 1186/13 mixed [1] 1130/9 1189/12 moment [4] 1108/19 1117/5 MR. MARANDO [1] 1178/19 1137/2 1159/12 Mr. Quigley [3] 1185/11 money [4] 1159/21 1159/22 1187/3 1189/7 1169/20 1169/21 Mr. Rogow [11] 1144/1 months [5] 1119/17 1179/2 1179/14 1179/16 1119/17 1190/3 1190/4 1181/17 1181/24 1182/1 1190/10 1188/9 1189/24 1191/9 more [30] 1103/1 1106/20 1193/3 1107/1 1109/24 1110/4 Mr. Rogow's [3] 1179/17 1110/21 1112/8 1118/5 1188/9 1193/5 1120/12 1120/14 1121/21 Mr. Schiff [1] 1108/12 1121/24 1122/11 1122/16 Mr. Smith [1] 1160/7 1122/17 1123/11 1123/18 Mr. Stone [63] 1103/11 1129/17 1132/15 1137/8 1103/19 1106/19 1108/24 1139/23 1140/11 1141/17 1111/15 1112/16 1144/4 1149/20 1159/8 1168/19 1144/19 1144/22 1145/12 1170/17 1175/4 1190/3 1145/25 1147/10 1148/5 1190/3 1148/17 1149/15 1150/16 morning [5] 1122/17 1157/12 1157/21 1158/1 1122/22 1129/3 1194/3 1158/10 1158/13 1159/1 1194/16 1159/24 1159/25 1160/4 most [10] 1108/3 1144/12 1160/14 1161/14 1162/2 1152/4 1156/5 1162/19 1162/10 1162/12 1163/7 1171/23 1176/15 1179/7 1163/18 1171/6 1175/1 1179/9 1185/12 1178/12 1178/17 1179/19 motive [11] 1159/18 1180/8 1181/3 1181/3 1159/20 1159/23 1159/24 1181/5 1181/11 1186/12 1174/20 1177/18 1179/15 1187/2 1187/6 1188/24 1179/17 1179/24 1180/23 1189/14 1189/22 1189/25 1181/18 1190/3 1190/4 1190/8 mouth [2] 1134/24 1137/3 1190/10 1190/15 1191/1 move [1] 1120/1 1191/3 1191/5 1191/22 movie [9] 1133/5 1133/5 1191/25 1192/2 1192/9 1133/13 1133/18 1134/13 1192/17 1193/16 1170/25 1171/1 1171/3 Mr. Stone's [10] 1114/6 1173/11 1147/13 1150/4 1161/8 movies [1] 1128/15 1179/16 1179/24 1182/17 1211 1183/2 1183/22 1185/9 Page 114 of 126 Mr. Zelinsky [2] 1106/8 1129/14 Ms. [7] 1102/10 1114/1 1129/15 1141/8 1145/16 1146/5 1149/16 Ms. Clinton's [1] 1145/16 Ms. Kunstler [2] 1129/15 1149/16 Ms. Routman [1] 1146/5 Ms. Taylor [3] 1102/10 1114/1 1141/8 much [10] 1130/14 1139/23 1155/8 1164/21 1165/21 1170/1 1179/1 1186/24 1193/6 1194/13 Mueller [3] 1134/23 1142/19 1192/18 must [1] 1184/15 mutual [10] 1106/23 1110/24 1111/13 1111/21 1112/11 1112/11 1113/17 1113/17 1114/25 1115/19 my [23] 1106/7 1114/13 1116/12 1116/18 1123/7 1124/14 1132/2 1135/3 1138/19 1138/19 1142/8 1144/16 1162/20 1174/17 1178/2 1178/7 1179/23 1181/7 1181/15 1182/8 1187/23 1190/22 1195/3 N name [10] 1116/8 1148/6 1148/17 1148/17 1149/17 1157/22 1166/16 1172/7 1186/13 1189/15 named [4] 1103/22 1108/17 1113/11 1125/3 narrow [1] 1176/11 National [5] 1105/16 1105/22 1105/23 1108/21 1109/19 nature [1] 1145/21 NE [1] 1098/22 necessary [1] 1192/4 need [11] 1102/1 1108/12 1108/13 1143/12 1145/2 1166/11 1170/2 1179/18 1186/16 1186/18 1194/16 nefarious [2] 1152/14 1180/5 neither [1] 1195/7 neutral [1] 1172/24 never [31] 1113/3 1113/12 1116/17 1119/5 1119/24 1124/13 1128/2 1128/2 1128/16 1129/16 1132/8 1136/18 1140/1 1140/4 1140/7 1140/15 1140/18 1140/21 1141/2 1142/4 1157/7 1157/9 1157/21 1157/23 1158/4 1167/21 1167/22 1178/8 1181/7 1186/14 1190/16 New [1] 1131/10 Newman [1] 1162/22 news [1] 1133/2 next [19] 1111/3 1138/12 1142/6 1143/12 1148/1 1148/20 1148/23 1149/8 1178/6 1193/14 306 Filed 02/14/20 N Case 1:19-cr-00018-ABJ Document objection [4] 1102/14 next... [11] 1150/13 1102/15 1170/10 1174/7 1151/13 1151/24 1152/11 obstruct [2] 1143/7 1152/24 1155/1 1158/20 1179/5 1164/11 1166/3 1181/24 obstructed [3] 1103/11 1188/8 1103/20 1193/16 Nice [1] 1136/22 obstruction [2] 1139/6 night [3] 1123/7 1170/25 1139/18 1170/25 obviously [1] 1145/17 nine [3] 1190/3 1190/4 occur [2] 1153/23 1153/23 1190/10 occurred [3] 1150/7 Nixon [1] 1132/6 1169/16 1180/5 no [107] October [12] 1109/25 nobody [4] 1164/7 1168/17 1113/9 1116/10 1122/13 1168/25 1169/1 1122/14 1122/17 1123/6 noise [2] 1169/4 1169/5 1123/19 1127/24 1138/25 noisy [2] 1169/4 1169/4 1140/11 1140/24 none [6] 1135/25 1150/24 odious [1] 1171/11 1150/25 1165/1 1187/12 off [7] 1129/19 1130/15 1187/21 1134/6 1134/6 1157/2 nonissue [1] 1174/21 1176/25 1188/16 nonpublic [3] 1105/17 offenses [2] 1144/19 1120/15 1140/23 1193/21 nonsense [1] 1182/15 offer [2] 1159/8 1160/4 nonstarter [1] 1161/2 offered [3] 1133/19 not [162] 1133/20 1146/25 noted [1] 1186/13 offering [2] 1172/24 notes [1] 1195/4 1172/25 nothing [30] 1116/11 offhand [2] 1178/5 1178/5 1145/4 1145/5 1145/14 Office [3] 1098/16 1146/13 1148/11 1149/25 1098/21 1099/11 1150/11 1150/11 1152/16 offices [1] 1123/3 1153/25 1154/11 1154/11 official [2] 1099/15 1154/11 1154/25 1154/25 1139/6 1156/11 1156/19 1156/23 often [1] 1105/17 1156/24 1158/16 1158/17 oftentimes [1] 1161/24 1164/7 1166/23 1169/9 Oh [4] 1155/12 1171/20 1170/8 1173/13 1173/14 1184/24 1187/23 1173/14 1187/14 okay [13] 1102/7 1110/1 notice [2] 1102/23 1190/8 1113/2 1126/24 1137/8 Notwithstanding [1] 1139/3 1143/24 1170/13 1194/7 1183/4 1188/22 1188/25 November [7] 1098/7 1192/1 1193/9 1131/18 1131/25 1132/10 Olas [2] 1099/8 1099/12 1132/20 1181/1 1195/12 old [3] 1110/7 1162/18 now [37] 1104/20 1106/7 1180/23 1107/8 1108/22 1110/6 older [2] 1115/3 1129/22 1110/15 1116/22 1118/9 once [5] 1107/17 1118/20 1119/18 1121/10 1125/1 1124/21 1148/24 1156/1 1141/12 1141/21 1142/6 one [79] 1102/4 1102/9 1148/1 1148/16 1151/13 1103/3 1103/17 1105/13 1154/6 1155/20 1156/23 1105/13 1106/13 1106/16 1157/12 1159/2 1164/20 1109/24 1114/4 1114/12 1165/3 1168/9 1168/24 1115/4 1116/9 1116/12 1171/20 1172/19 1173/10 1118/23 1119/9 1121/6 1175/6 1178/3 1180/2 1121/23 1124/19 1125/21 1181/3 1181/12 1184/24 1125/22 1127/13 1127/16 1191/10 1194/16 1127/16 1127/18 1129/12 nowadays [1] 1193/10 1129/17 1132/22 1133/14 number [11] 1101/2 1133/22 1135/6 1135/9 1107/19 1117/18 1117/20 1135/14 1135/15 1135/18 1120/1 1124/18 1124/18 1137/8 1137/17 1138/12 1125/18 1126/3 1126/5 1139/2 1140/11 1142/9 1180/17 1144/10 1145/21 1146/16 number 1 [1] 1107/19 1149/8 1150/21 1150/22 numbers [2] 1125/20 1151/2 1151/13 1152/22 1159/12 1153/5 1153/23 1154/15 NW [2] 1098/17 1099/17 1155/18 1156/3 1156/4 1160/6 1161/15 1162/19 O 1162/21 1166/5 1167/13 oath [4] 1128/4 1135/22 1212 1169/14 1171/7 1171/8 Page 115 of 126 1172/1 1175/1 1175/1 1179/15 1181/8 1184/10 1185/11 1188/15 1189/16 1191/24 1192/4 1192/12 1192/20 1193/4 one-up [1] 1114/12 one-upping [2] 1175/1 1175/1 one-week [1] 1118/23 ones [2] 1160/12 1160/25 only [16] 1101/14 1111/17 1115/4 1115/7 1131/7 1139/24 1146/3 1160/25 1183/3 1183/24 1184/25 1185/1 1185/18 1187/23 1193/22 1194/1 oOo [1] 1194/19 open [4] 1102/18 1153/10 1153/16 1158/15 opened [3] 1153/15 1153/17 1179/24 opening [8] 1107/6 1144/21 1148/11 1162/11 1171/10 1177/8 1184/2 1184/13 operated [2] 1171/12 1175/19 opportunity [4] 1157/10 1157/13 1173/1 1184/3 opposition [2] 1145/8 1145/17 order [2] 1155/15 1176/17 organization [6] 1103/19 1105/17 1110/11 1161/17 1161/19 1189/6 original [1] 1186/11 other [22] 1102/9 1104/15 1115/8 1116/17 1121/20 1126/16 1126/23 1134/3 1136/10 1137/25 1140/13 1143/18 1149/4 1151/22 1154/21 1157/5 1158/10 1162/4 1162/7 1173/14 1176/7 1187/7 otherwise [3] 1129/16 1129/17 1195/10 our [18] 1103/5 1130/20 1135/17 1145/21 1145/22 1146/4 1146/5 1146/9 1146/22 1148/11 1149/21 1150/13 1150/17 1152/11 1160/10 1160/11 1188/15 1193/13 out [47] 1103/24 1104/5 1106/1 1106/20 1109/5 1112/8 1114/15 1120/12 1120/14 1120/25 1121/3 1122/9 1122/11 1122/16 1127/17 1127/18 1128/3 1129/5 1129/23 1136/20 1140/11 1140/25 1141/16 1145/6 1146/9 1148/10 1148/12 1153/6 1153/12 1155/5 1156/10 1159/24 1162/13 1162/20 1163/15 1164/3 1172/12 1175/11 1176/12 1180/8 1180/21 1181/21 1186/22 1189/13 1190/1 1190/1 1194/1 outcome [2] 1177/4 party [2]306 1168/22 1183/18 Filed 02/14/20 O Case 1:19-cr-00018-ABJ Document pass [1] 1118/15 outcome... [1] 1195/10 passage [1] 1141/24 outed [1] 1175/16 passages [1] 1131/7 over [52] 1103/10 1107/18 passed [1] 1171/19 1107/18 1107/18 1108/1 passing [3] 1120/7 1108/2 1108/2 1110/20 1123/12 1157/1 1110/20 1115/24 1115/24 past [4] 1103/10 1126/18 1117/6 1118/21 1118/21 1128/13 1141/3 1118/21 1118/23 1124/7 patsy [2] 1128/11 1180/17 1124/7 1125/21 1125/22 Paul [5] 1109/4 1121/22 1126/18 1134/16 1135/22 1122/8 1149/24 1162/22 1135/22 1135/22 1136/16 paused [1] 1129/19 1136/16 1141/3 1141/4 pay [1] 1169/20 1141/4 1145/1 1146/2 payload [1] 1123/8 1153/20 1153/20 1160/18 peculiarly [1] 1102/4 1160/18 1163/6 1163/6 pending [3] 1109/11 1170/14 1171/8 1173/6 1118/6 1137/17 1173/9 1173/9 1177/6 Pentangeli [23] 1132/24 1177/6 1177/8 1177/8 1133/2 1133/4 1133/6 1177/19 1178/24 1178/25 1133/7 1133/10 1133/12 1187/6 1187/20 1133/18 1133/25 1134/9 overcome [1] 1152/6 1139/1 1142/17 1143/2 overhead [1] 1179/20 1170/21 1170/21 1171/2 overwhelming [2] 1113/14 1172/3 1173/17 1173/18 1120/5 1173/19 1173/20 1182/5 own [10] 1117/1 1117/11 1192/18 1149/13 1160/11 1176/1 people [13] 1115/5 1183/25 1185/9 1188/9 1123/22 1148/21 1150/8 1189/20 1193/12 1153/17 1154/21 1159/19 1160/14 1174/5 1180/6 P 1180/20 1185/25 1193/14 P-R-O-C-E-E-D-I-N-G-S [1] per [1] 1149/4 1101/1 perceived [1] 1171/2 P.A [3] 1098/21 1099/3 perfect [2] 1130/14 1099/7 1180/17 p.m [3] 1098/7 1143/22 perfectly [2] 1117/15 1194/18 1135/10 pa.com [2] 1099/5 1099/6 perhaps [2] 1150/5 page [24] 1100/2 1106/5 1185/11 1146/5 1147/16 1147/16 perimeters [1] 1160/19 1148/1 1148/2 1148/15 period [3] 1118/24 1163/7 1148/15 1148/20 1148/23 1183/19 1149/1 1149/8 1149/21 perjury [2] 1133/8 1181/9 1150/13 1152/11 1152/11 Permanent [1] 1103/12 1152/24 1153/9 1156/25 permission [3] 1101/21 1184/14 1186/15 1187/3 1102/2 1186/13 1189/5 person [26] 1104/18 page 10 [1] 1184/14 1107/24 1108/10 1113/15 page 81 [1] 1148/15 1113/16 1113/18 1117/5 pages [2] 1149/2 1195/3 1117/6 1117/7 1119/24 PAIGE [1] 1099/11 1127/25 1128/19 1128/20 paper [2] 1183/4 1183/5 1137/24 1140/9 1140/16 papers [2] 1123/4 1123/4 1143/4 1154/17 1159/3 paragraph [1] 1131/9 1166/5 1167/4 1167/15 parameters [13] 1146/19 1169/16 1169/17 1169/19 1147/9 1160/8 1161/7 1169/22 1161/23 1161/25 1162/15 persons [1] 1162/7 1177/9 1177/10 1182/7 pertain [1] 1111/4 1182/9 1187/24 1188/5 pertaining [1] 1183/10 part [12] 1106/6 1107/2 phone [10] 1120/25 1121/4 1133/5 1146/10 1156/8 1121/7 1121/11 1121/12 1157/25 1165/6 1166/9 1121/18 1121/20 1121/20 1167/11 1171/5 1172/11 1187/6 1187/20 1178/1 phrase [1] 1180/23 partially [1] 1176/22 pick [1] 1136/2 participants [1] 1155/4 picked [3] 1128/6 1128/10 particularly [2] 1149/23 1163/16 1183/11 picking [1] 1163/18 parties [4] 1126/6 1127/9 picture [5] 1166/5 1176/8 1161/16 1195/8 1176/9 1181/10 1189/23 1213 picture's [1] 1180/24 Page 116 of 126 pictures [3] 1164/22 1165/16 1172/8 piece [2] 1184/4 1190/5 Pilgrim [2] 1099/15 1195/12 pillars [3] 1156/7 1156/8 1158/22 pinning [1] 1115/22 place [1] 1132/23 plain [2] 1134/14 1149/12 Plaintiff [2] 1098/4 1098/14 plan [3] 1130/11 1132/5 1132/7 plane [1] 1173/5 planned [1] 1109/25 planning [1] 1106/21 plans [6] 1104/4 1109/24 1110/14 1110/21 1121/24 1140/10 play [5] 1153/19 1160/12 1164/17 1164/18 1164/21 played [21] 1107/7 1107/20 1111/2 1111/8 1111/11 1115/12 1115/14 1117/21 1120/2 1124/20 1124/22 1126/4 1129/19 1163/8 1164/14 1166/6 1175/20 1175/21 1178/1 1183/17 1188/10 playing [2] 1172/19 1172/19 plead [4] 1132/4 1132/17 1138/25 1142/25 pleading [2] 1136/7 1136/9 pleads [1] 1140/19 please [5] 1118/3 1118/5 1122/2 1149/22 1188/12 pleased [3] 1168/2 1168/4 1168/8 pled [4] 1136/14 1137/13 1191/11 1193/2 plotting [1] 1122/10 plucked [1] 1163/15 plus [1] 1126/12 Podesta [1] 1184/7 Podesta's [1] 1184/17 point [29] 1101/23 1103/2 1106/13 1107/10 1107/13 1113/7 1120/20 1122/21 1128/17 1128/24 1130/8 1132/12 1135/2 1137/1 1137/5 1137/10 1143/12 1147/7 1148/24 1150/3 1159/10 1173/12 1176/11 1177/20 1177/22 1191/18 1192/4 1193/4 1194/4 pointing [1] 1156/10 policy [2] 1123/4 1123/5 political [5] 1105/11 1124/2 1145/21 1162/7 1193/12 portion [2] 1107/13 1171/3 portrayed [3] 1164/12 1166/7 1179/2 position [2] 1102/13 1123/4 possession [3] 1110/16 properly 306 [1] Filed 1164/12 02/14/20 P Case 1:19-cr-00018-ABJ Document prosecution [1] 1165/14 possession... [2] 1119/8 protect [10] 1144/22 1179/4 1145/2 1145/3 1145/13 possibly [2] 1180/12 1158/6 1161/1 1168/11 1181/22 1168/12 1177/18 1179/18 post [1] 1121/4 protected [2] 1158/13 posted [1] 1105/21 1160/11 potentially [1] 1186/21 protecting [1] 1174/20 pour [1] 1159/14 prove [10] 1138/15 1139/8 power [3] 1135/16 1144/7 1139/17 1149/18 1151/8 1144/9 1154/9 1154/9 1190/18 PowerPoint [3] 1129/2 1192/5 1192/7 1146/3 1146/7 proves [2] 1149/18 1165/1 practice [1] 1143/1 provided [8] 1147/19 practicing [1] 1133/1 1148/6 1148/17 1148/17 praises [1] 1121/3 1152/12 1158/21 1192/10 predicate [1] 1102/3 1195/4 predicted [1] 1184/16 providing [1] 1123/15 premise [3] 1145/19 proving [1] 1105/1 1145/20 1158/5 public [19] 1106/19 Prepare [1] 1136/25 1109/20 1110/19 1112/16 prepared [1] 1125/17 1113/23 1114/6 1118/4 prescient [1] 1180/16 1119/19 1120/14 1129/12 present [4] 1102/20 1147/23 1147/24 1153/2 1143/25 1151/25 1176/17 1159/6 1159/7 1160/11 presentation [1] 1146/7 1164/20 1164/20 1165/19 presented [4] 1151/25 publication [4] 1103/18 1179/8 1188/14 1188/14 1105/15 1173/11 1183/11 president [7] 1108/24 publications [2] 1106/6 1110/8 1124/10 1145/10 1106/10 1158/7 1158/11 1177/19 publicity [1] 1130/5 presidential [6] 1103/16 publicly [11] 1104/10 1105/8 1120/6 1135/17 1142/1 1142/3 1146/19 1181/20 1183/20 1160/8 1160/8 1160/19 pressing [1] 1141/4 1160/20 1169/12 1187/24 pressure [5] 1128/17 1188/5 1128/23 1130/8 1130/10 published [2] 1105/19 1137/1 1169/11 pretend [1] 1125/9 publishes [1] 1105/17 pretended [1] 1182/20 pull [1] 1117/6 pretty [2] 1130/14 1193/9 purpose [7] 1144/20 previously [1] 1195/6 1144/21 1145/12 1145/19 Prince [11] 1123/1 1123/2 1159/17 1159/25 1179/18 1123/7 1126/12 1140/4 pushed [1] 1192/23 1140/23 1154/14 1154/15 put [14] 1112/8 1116/16 1154/17 1154/17 1154/23 1130/10 1146/4 1146/5 prior [1] 1153/9 1146/6 1149/22 1153/1 prison [1] 1162/21 1153/6 1155/5 1177/14 private [1] 1165/18 1188/5 1188/16 1189/12 probably [1] 1163/17 puts [1] 1190/8 probation [1] 1169/19 putting [2] 1153/12 probe [2] 1108/8 1148/4 1157/1 problem [4] 1147/7 Q 1167/16 1182/1 1182/2 problems [2] 1128/12 question [39] 1106/10 1146/17 1106/15 1107/21 1108/1 proceed [4] 1101/4 1103/6 1108/4 1108/5 1108/15 1144/1 1178/20 1108/16 1112/24 1117/22 proceeded [1] 1157/16 1117/22 1117/24 1117/25 proceeding [8] 1139/6 1120/4 1120/4 1124/24 1124/24 1125/2 1126/8 1139/8 1139/9 1139/10 1126/9 1129/21 1148/3 1139/11 1156/25 1157/3 1148/13 1150/4 1150/4 1157/4 1159/2 1160/16 1161/22 proceedings [2] 1143/22 1163/23 1164/13 1164/14 1195/5 1164/15 1170/1 1176/14 produce [1] 1159/7 1178/6 1182/12 1185/12 production [1] 1146/2 1187/2 1188/25 professed [1] 1189/1 questioned [1] 1109/21 projector [1] 1179/20 proper [2] 1156/4 1178/17 questions [29] 1106/13 1214 1108/11 1135/21 1159/16 Page 117 of 126 1160/21 1161/6 1161/9 1161/11 1161/12 1161/14 1163/6 1163/6 1163/8 1163/15 1163/17 1176/13 1176/23 1176/24 1182/9 1183/1 1183/2 1183/23 1185/10 1186/3 1186/5 1186/7 1186/24 1186/25 1187/17 Quigley [5] 1108/3 1108/5 1185/11 1187/3 1189/7 quite [3] 1172/12 1186/25 1194/2 quote [6] 1110/14 1132/6 1134/6 1134/7 1150/18 1150/23 quoted [1] 1191/11 R R-18 [1] 1155/20 R.K [1] 1149/24 radio [7] 1115/10 1116/12 1116/18 1172/16 1172/17 1173/1 1189/20 Randy [78] 1103/22 1104/19 1113/11 1113/18 1113/23 1114/4 1115/4 1115/8 1115/11 1115/20 1115/23 1115/24 1116/4 1116/5 1116/22 1116/23 1116/25 1117/3 1117/10 1118/12 1118/14 1118/22 1119/2 1119/10 1119/16 1124/11 1125/10 1125/15 1125/19 1126/1 1126/11 1127/19 1128/2 1128/6 1128/7 1128/7 1128/9 1128/17 1128/19 1128/24 1129/3 1129/16 1129/24 1129/24 1130/7 1130/18 1131/19 1132/19 1133/14 1135/2 1136/13 1136/13 1137/5 1138/2 1139/15 1140/15 1142/25 1143/1 1147/17 1153/5 1155/22 1156/13 1164/11 1164/13 1164/14 1164/15 1165/1 1165/4 1165/7 1165/10 1165/15 1165/20 1165/22 1188/8 1188/10 1188/11 1188/12 1188/24 ratted [1] 1136/23 reach [1] 1183/21 reached [1] 1172/12 read [8] 1147/3 1166/24 1168/9 1168/13 1169/7 1171/22 1177/1 1193/25 reading [2] 1154/2 1154/3 ready [2] 1101/4 1143/24 reality [1] 1174/21 realize [1] 1183/13 realized [1] 1192/23 really [15] 1104/6 1110/22 1121/16 1122/11 1137/6 1142/2 1149/6 1156/8 1157/20 1162/24 1164/1 1165/13 1165/20 1178/23 1192/13 reason [12] 1106/21 1144/22 1158/15 1159/17 1178/24 306 Filed 02/14/20 R Case 1:19-cr-00018-ABJ Document reluctantly [1] 1131/8 reason... [8] 1160/24 remain [1] 1143/19 1174/6 1174/22 1174/22 remained [1] 1171/13 1175/17 1177/20 1179/24 remaining [1] 1193/22 1191/14 remarks [3] 1178/5 1178/5 reasonable [5] 1144/11 1189/5 1144/13 1144/16 1144/17 remember [17] 1105/16 1152/6 1106/7 1109/9 1121/13 reasons [13] 1130/12 1128/18 1131/23 1133/4 1144/17 1146/18 1160/25 1133/13 1137/1 1139/1 1173/24 1184/11 1189/12 1142/15 1164/22 1166/18 1191/10 1191/10 1191/12 1172/7 1189/15 1192/14 1191/13 1192/13 1193/20 1192/15 rebuttal [3] 1100/6 remind [1] 1128/25 1143/15 1178/19 reminded [1] 1171/20 rebutted [1] 1184/15 repeated [1] 1126/20 recall [4] 1134/7 1147/23 repeatedly [4] 1104/1 1156/14 1172/9 1117/12 1128/4 1160/19 Recalling [1] 1101/2 repeating [1] 1112/6 receive [1] 1194/11 report [19] 1106/4 1106/5 received [1] 1194/7 1140/8 1140/9 1141/23 recently [1] 1149/10 1142/5 1146/23 1146/25 recess [2] 1103/5 1143/21 1147/2 1147/3 1158/22 recognize [1] 1163/2 1158/23 1183/6 1183/7 record [5] 1117/12 1183/9 1183/13 1183/13 1136/15 1138/7 1190/14 1183/16 1183/20 1194/10 reporter [3] 1099/15 recorded [1] 1111/25 1099/15 1149/10 records [1] 1121/11 reporters [1] 1174/1 red [5] 1146/9 1149/6 reposing [1] 1169/23 1150/17 1156/15 1158/20 Representative [3] 1108/3 refer [2] 1161/18 1192/24 1108/5 1108/7 reference [4] 1110/7 Representatives [1] 1110/11 1123/9 1140/11 1124/4 references [1] 1110/9 Republican [1] 1189/6 referencing [1] 1132/16 reputation [1] 1175/18 referred [2] 1116/9 request [6] 1118/15 1189/16 1118/16 1118/22 1128/21 referring [5] 1111/15 1129/13 1159/6 1112/18 1113/16 1118/10 requested [1] 1158/21 1126/25 requesting [1] 1132/1 reflect [2] 1124/10 requests [2] 1118/1 1124/16 1126/20 reform [1] 1131/10 required [1] 1139/17 regard [3] 1150/12 research [2] 1103/3 1157/20 1170/23 1145/18 regarding [5] 1151/25 respond [1] 1122/23 1180/21 1184/19 1184/23 responded [1] 1163/13 1188/3 Responding [1] 1190/21 regularly [2] 1109/2 responds [4] 1122/23 1120/10 1132/4 1132/12 1137/6 reiterate [1] 1189/7 response [7] 1135/6 related [3] 1118/18 1135/9 1135/14 1135/18 1183/3 1195/7 1136/22 1136/25 1162/20 relationship [4] 1106/5 responsibility [2] 1144/5 1120/18 1171/25 1177/12 1144/6 release [6] 1110/21 responsible [2] 1176/22 1122/15 1122/18 1123/18 1184/7 1140/24 1186/13 responsive [1] 1163/8 released [1] 1109/18 rest [2] 1110/15 1136/3 releases [11] 1106/2 restraint [2] 1144/7 1106/15 1107/3 1107/10 1144/8 1110/4 1122/4 1124/5 result [4] 1123/14 1124/7 1140/24 1141/1 1173/22 1173/23 1173/23 1175/6 resume [3] 1143/17 releasing [1] 1108/20 1143/19 1194/11 relegated [1] 1168/16 resumed [1] 1143/22 relentless [1] 1104/18 retire [1] 1194/4 relevant [5] 1105/20 return [1] 1159/21 1106/11 1140/9 1157/7 reveal [1] 1113/2 1215 revealed [2] 1175/13 Page 118 of 126 1191/15 revealing [1] 1157/13 Richard [2] 1120/10 1132/6 Rick [2] 1109/3 1121/8 right [26] 1101/4 1102/7 1102/16 1102/19 1103/6 1107/6 1116/14 1116/17 1121/10 1130/11 1130/15 1130/18 1135/4 1138/11 1143/9 1143/23 1144/1 1145/19 1180/24 1181/12 1181/16 1185/4 1187/12 1188/7 1193/22 1194/16 rights [3] 1124/14 1132/14 1181/8 road [1] 1169/4 rob [1] 1159/20 ROBERT [3] 1099/2 1134/23 1142/19 ROGER [154] Rogow [17] 1098/21 1098/21 1100/5 1144/1 1144/2 1144/3 1179/2 1179/14 1179/16 1180/2 1181/17 1181/24 1182/1 1188/9 1189/24 1191/9 1193/3 Rogow's [3] 1179/17 1188/9 1193/5 role [2] 1166/6 1183/17 room [3] 1099/17 1116/4 1184/1 ROUTMAN [3] 1099/11 1099/11 1146/5 Routmanc [1] 1099/14 rowlaw.com [1] 1098/24 rows [2] 1121/17 1121/17 RPR [2] 1099/15 1195/12 ruin [1] 1175/18 rule [3] 1102/12 1177/5 1177/6 run [2] 1150/19 1161/11 running [3] 1108/23 1110/8 1137/3 Russia [36] 1103/14 1103/15 1103/18 1105/11 1141/1 1146/12 1146/20 1146/20 1149/25 1150/1 1150/11 1150/12 1150/12 1154/10 1154/25 1154/25 1156/11 1156/12 1160/16 1161/20 1161/21 1162/6 1162/8 1162/8 1162/8 1180/7 1181/22 1181/25 1182/14 1183/3 1183/24 1184/25 1185/3 1187/1 1187/16 1188/3 Russia's [1] 1183/17 Russian [27] 1105/7 1105/10 1106/15 1139/12 1146/11 1146/11 1146/12 1154/12 1154/13 1157/8 1158/17 1160/13 1160/13 1160/15 1160/22 1160/23 1161/7 1162/4 1162/5 1163/22 1170/6 1170/8 1181/20 1182/10 1182/12 1183/19 1184/6 Russians [10] 1105/14 1112/13 306 1112/24 1113/1 Filed 02/14/20 R Case 1:19-cr-00018-ABJ Document 1113/10 1114/14 1115/18 Russians... [9] 1105/23 1116/16 1117/19 1118/6 1106/2 1106/6 1106/9 1119/1 1119/5 1121/18 1107/3 1107/9 1120/24 1121/19 1121/21 1124/9 1124/5 1136/1 1127/1 1127/3 1127/6 1127/8 1127/11 1130/20 S 1133/10 1133/18 1149/9 S.E [1] 1099/3 1162/22 1164/20 1166/22 said [77] 1102/13 1104/24 1167/20 1168/18 1168/18 1105/23 1106/20 1107/6 1172/9 1173/24 1180/2 1107/9 1114/24 1115/6 1184/5 1185/11 1187/20 1117/15 1119/19 1120/13 1190/5 1120/18 1121/13 1121/16 scene [2] 1133/5 1133/18 1125/3 1129/7 1129/9 scenes [1] 1173/8 1129/21 1131/20 1133/25 Schiff [2] 1108/12 1138/18 1141/13 1143/5 1186/15 1144/21 1145/24 1146/4 scintilla [1] 1150/22 1146/24 1147/1 1148/13 scope [1] 1146/10 1149/5 1150/8 1151/7 screen [1] 1121/11 1151/14 1151/15 1151/20 seat [1] 1102/24 1151/22 1152/10 1153/9 seated [1] 1143/19 1154/11 1154/11 1161/2 second [4] 1109/24 1161/23 1161/24 1163/13 1147/15 1147/16 1166/14 1164/8 1164/8 1165/10 seconds [2] 1121/21 1165/10 1167/7 1168/5 1129/20 1168/25 1169/1 1169/1 secret [1] 1168/15 1169/25 1170/7 1170/24 see [23] 1105/20 1109/13 1170/24 1173/16 1173/17 1112/5 1121/7 1126/17 1175/6 1177/22 1178/1 1126/22 1129/2 1130/20 1178/7 1179/17 1179/23 1132/2 1137/18 1147/4 1181/23 1182/1 1182/8 1153/20 1155/5 1162/9 1183/23 1185/5 1186/5 1162/20 1163/21 1170/22 1189/9 1191/14 1192/12 1173/3 1176/25 1177/1 1193/3 1193/5 1193/6 1177/1 1181/16 1194/16 salaried [1] 1123/2 seeing [1] 1188/1 same [12] 1111/10 1111/21 seen [10] 1103/10 1104/25 1123/1 1130/5 1133/14 1113/14 1118/1 1120/5 1145/16 1148/15 1148/24 1126/18 1129/24 1141/3 1149/2 1164/25 1168/4 1153/22 1183/3 1184/13 sees [2] 1109/5 1141/2 Sanders [2] 1165/12 Select [1] 1103/13 1175/15 self [1] 1193/13 save [6] 1122/2 1122/3 self-governance [1] 1122/8 1132/5 1152/13 1193/13 1159/22 send [2] 1124/11 1134/11 saw [20] 1108/19 1109/8 sending [5] 1145/6 1113/19 1114/9 1114/10 1164/24 1165/15 1165/16 1117/3 1117/4 1117/7 1166/16 1119/6 1119/12 1122/7 sends [11] 1109/13 1121/6 1126/10 1126/11 1140/1 1122/8 1130/22 1130/24 1140/4 1142/4 1157/7 1130/25 1131/3 1166/22 1187/22 1187/22 1188/12 1181/1 1181/5 1189/14 say [37] 1101/15 1107/22 sense [7] 1144/24 1145/20 1118/3 1118/5 1118/25 1156/23 1158/9 1161/3 1128/10 1129/5 1129/17 1181/18 1191/4 1134/1 1138/25 1143/4 sensible [2] 1177/18 1143/6 1148/22 1149/9 1177/20 1149/11 1155/3 1155/12 sent [12] 1113/20 1127/24 1155/25 1156/11 1156/16 1130/16 1130/19 1137/11 1158/24 1161/15 1162/10 1137/15 1150/10 1156/15 1165/3 1167/6 1174/12 1156/21 1156/22 1180/16 1174/14 1175/21 1177/9 1190/21 1177/24 1177/24 1182/11 sentence [1] 1149/9 1184/3 1184/24 1186/5 sentences [1] 1177/10 1187/23 1193/18 separately [1] 1157/24 saying [10] 1101/23 September [18] 1115/25 1112/10 1146/15 1149/11 1116/7 1118/14 1118/17 1157/12 1168/13 1169/13 1118/24 1125/19 1128/4 1171/20 1173/4 1191/12 1128/22 1129/4 1129/11 says [39] 1110/5 1110/19 1144/25 1147/5 1156/16 1216 1156/21 1157/10 1161/4 Page 119 of 126 1182/19 1190/18 September 26th [1] 1157/10 sequence [1] 1150/13 series [2] 1160/2 1160/6 serious [1] 1165/13 seriously [1] 1128/14 served [1] 1183/18 service [1] 1118/19 servicemen [1] 1168/15 Session [1] 1098/5 set [10] 1116/3 1117/12 1134/2 1137/8 1147/9 1163/1 1163/3 1177/5 1177/9 1182/6 sets [1] 1147/12 setting [3] 1110/10 1114/18 1167/11 seven [1] 1149/1 several [1] 1159/19 she [20] 1102/11 1114/1 1115/3 1115/6 1133/17 1164/2 1164/4 1166/24 1166/24 1167/6 1167/6 1167/8 1170/5 1170/7 1170/17 1170/21 1170/24 1170/24 1170/24 1170/25 she'll [1] 1191/21 she's [6] 1102/15 1114/2 1128/19 1128/20 1129/21 1129/22 shocked [2] 1166/16 1193/9 short [2] 1135/10 1152/21 shortly [2] 1109/24 1158/3 should [11] 1109/13 1121/7 1132/13 1137/2 1137/18 1144/17 1148/19 1151/1 1174/3 1178/17 1178/25 show [30] 1104/1 1104/3 1114/13 1114/20 1114/23 1116/12 1116/18 1119/6 1120/21 1131/24 1134/3 1137/20 1137/21 1138/1 1138/4 1138/24 1153/1 1171/14 1171/14 1171/15 1171/16 1172/6 1172/7 1172/7 1172/18 1173/1 1183/6 1183/14 1189/20 1190/23 showed [4] 1117/9 1177/7 1180/25 1190/20 showing [4] 1148/16 1149/6 1152/7 1169/14 shown [2] 1148/25 1174/23 shows [18] 1104/20 1104/25 1105/9 1105/10 1106/5 1107/14 1113/5 1114/22 1119/23 1123/21 1125/18 1139/19 1139/22 1139/24 1143/6 1150/3 1154/4 1170/8 shut [1] 1134/24 sic [1] 1173/19 side [2] 1102/4 1149/4 SIGNAL [1] 1155/23 silence [1] 1104/18 SIMCHA [1] 1098/15 sources [1] 306 1142/1 Filed 02/14/20 S Case 1:19-cr-00018-ABJ Document Southwest [1] 1189/6 simple [1] 1134/14 SPAN [1] 1111/23 simpler [1] 1179/1 speak [1] 1103/4 since [4] 1115/25 1145/1 special [4] 1125/17 1171/19 1177/19 1134/23 1135/1 1141/8 single [1] 1179/13 specific [1] 1176/16 sitting [4] 1121/16 speech [2] 1107/21 1114/9 1121/17 1169/2 1194/1 spending [1] 1180/10 situation [7] 1144/8 spent [1] 1179/16 1151/10 1152/2 1160/20 Spitzer [1] 1171/18 1170/3 1175/25 1182/8 Spitzer's [1] 1130/2 six [11] 1111/1 1112/6 Spoke [1] 1123/7 1118/23 1119/16 1119/17 spoken [1] 1103/4 1130/19 1130/24 1176/12 spot [1] 1130/11 1176/13 1176/24 1186/4 spring [1] 1136/16 slide [1] 1129/2 staff [1] 1190/20 smart [5] 1134/19 1142/19 stage [3] 1110/10 1147/13 1162/12 1175/11 1192/21 1189/21 SMITH [2] 1099/7 1160/7 stand [4] 1128/14 1129/3 smoke [1] 1178/22 1142/7 1192/12 smooth [1] 1165/4 standard [1] 1151/6 smoothed [1] 1129/18 stands [1] 1142/11 snippet [1] 1155/3 start [8] 1102/12 1107/16 so [102] 1110/6 1133/1 1135/24 social [1] 1193/11 1145/23 1158/19 1159/2 society [1] 1145/21 started [6] 1106/19 some [34] 1101/21 1103/18 1109/20 1146/10 1158/9 1105/19 1105/21 1107/23 1167/19 1177/17 1111/19 1116/23 1119/1 starting [1] 1159/10 1119/2 1142/12 1143/12 starts [10] 1110/18 1147/5 1150/7 1150/8 1113/21 1122/9 1130/15 1151/18 1151/23 1152/19 1131/4 1133/9 1147/8 1153/11 1160/14 1161/12 1182/1 1182/3 1182/6 1162/14 1163/8 1163/19 state [8] 1118/19 1147/13 1166/10 1167/12 1169/5 1147/13 1149/22 1161/8 1169/23 1171/5 1172/6 1184/6 1184/13 1193/8 1172/7 1174/21 1175/22 stated [4] 1146/19 1188/23 1194/2 1146/19 1152/17 1195/6 somebody [5] 1162/13 statement [17] 1104/25 1165/25 1169/15 1175/16 1107/6 1118/12 1119/6 1189/23 1119/24 1127/13 1138/4 somehow [7] 1116/25 1139/4 1144/21 1148/11 1182/21 1183/2 1188/20 1149/3 1149/5 1152/21 1188/24 1189/25 1191/3 1155/19 1177/8 1184/3 someone [8] 1108/7 1184/13 1117/13 1123/12 1135/20 statements [19] 1106/20 1136/19 1136/23 1148/3 1109/21 1110/19 1110/19 1159/23 1111/14 1111/16 1111/17 something [36] 1118/8 1112/17 1113/23 1114/6 1128/25 1137/24 1140/25 1117/1 1118/4 1123/10 1146/23 1149/4 1149/12 1129/12 1162/11 1171/10 1150/1 1150/4 1150/6 1182/19 1183/25 1185/24 1151/1 1152/14 1152/15 states [15] 1098/1 1098/3 1153/6 1153/15 1156/2 1098/11 1099/16 1101/3 1156/2 1159/23 1159/23 1108/24 1124/4 1135/15 1162/11 1163/13 1164/25 1145/11 1158/12 1162/5 1167/7 1167/8 1168/22 1177/20 1183/9 1183/16 1168/25 1169/15 1170/5 1195/4 1171/21 1172/5 1173/6 station [2] 1172/16 1173/12 1175/8 1177/23 1189/19 1178/4 1193/5 steak [1] 1155/15 sometimes [1] 1149/3 steakhouse [1] 1155/14 sorry [2] 1102/8 1174/11 stenographic [1] 1195/4 sort [1] 1116/23 step [2] 1141/21 1193/22 sought [1] 1177/5 Stephen [1] 1120/17 sound [1] 1133/9 Steve [3] 1109/3 1122/18 sounded [1] 1185/25 1167/18 source [6] 1112/25 1131/8 still [7] 1118/13 1123/8 1142/3 1184/18 1184/22 1125/10 1143/17 1167/12 1186/11 1193/9 1193/15 1217 stole [2] 1169/20 1169/21 Page 120 of 126 stolen [3] 1105/15 1105/18 1183/11 STONE [367] Stone's [40] 1104/23 1108/23 1114/6 1117/1 1117/6 1117/11 1118/11 1121/19 1122/3 1123/10 1125/8 1129/12 1132/7 1132/8 1135/5 1135/9 1135/11 1135/14 1136/22 1136/25 1137/9 1138/4 1139/17 1140/19 1140/21 1141/7 1141/9 1141/25 1147/13 1150/4 1161/8 1168/14 1170/18 1177/2 1179/16 1179/24 1182/17 1183/2 1183/22 1185/9 Stonewall [1] 1132/4 Stop [1] 1133/8 stopped [1] 1129/18 story [5] 1130/4 1130/23 1131/4 1138/10 1173/10 straight [2] 1117/13 1143/14 strange [1] 1188/23 strategist [1] 1124/3 StrategySmith [1] 1099/7 strategysmith.com [1] 1099/10 straw [1] 1192/25 street [2] 1098/17 1188/16 stress [1] 1189/24 stresses [2] 1183/16 1186/10 stretch [1] 1156/3 stroke [1] 1110/7 stuff [13] 1110/21 1112/8 1112/8 1113/8 1118/5 1119/1 1122/11 1131/5 1133/19 1158/17 1159/4 1166/13 1175/16 stupid [2] 1136/13 1181/9 subject [2] 1152/1 1191/9 submitted [1] 1143/17 subpoena [8] 1102/5 1132/11 1132/20 1132/22 1133/15 1133/22 1181/1 1186/21 subpoenaed [5] 1141/20 1157/9 1157/16 1181/2 1181/4 Suburban [4] 1121/14 1168/15 1169/1 1169/2 Suburbans [1] 1169/3 succeeded [1] 1139/24 sufficient [1] 1178/10 sufficiently [1] 1160/10 suggesting [2] 1110/6 1178/16 suggests [1] 1151/21 Suite [4] 1098/22 1099/4 1099/8 1099/12 sum [1] 1135/10 super [1] 1175/22 supplement [1] 1194/10 support [1] 1169/7 supporter [2] 1154/19 1154/23 supposed [3] 1122/15 tampered 306 [8] Filed 1103/21 02/14/20 S Case 1:19-cr-00018-ABJ Document 1158/1 1171/6 1171/7 supposed... [2] 1122/15 1171/7 1171/8 1191/23 1133/6 1193/17 sure [15] 1109/12 1132/24 tampering [12] 1105/2 1132/24 1133/15 1133/16 1134/14 1138/23 1139/2 1133/20 1133/20 1133/22 1139/5 1139/15 1170/23 1133/22 1142/17 1142/17 1172/3 1173/21 1182/4 1154/1 1154/6 1154/8 1191/21 1192/2 1154/9 TARA [1] 1099/2 surmisal [1] 1155/9 tax [1] 1159/21 surprised [1] 1166/15 taxes [2] 1159/22 1169/21 surrounding [1] 1176/7 Taylor [8] 1102/10 1114/1 Sustained [1] 1170/11 1125/17 1133/17 1141/8 Svengali [1] 1116/23 1164/2 1166/3 1170/4 sworn [1] 1103/20 Taylor's [1] 1164/10 system [2] 1105/24 team [1] 1154/20 1188/16 telephone [2] 1155/21 1168/17 T tell [20] 1112/17 1112/18 TABLE [1] 1100/1 1112/23 1114/12 1116/18 take [32] 1116/2 1119/11 1119/4 1134/20 1138/8 1119/15 1128/14 1130/1 1138/10 1140/16 1142/19 1131/7 1131/22 1132/18 1144/24 1152/7 1171/1 1132/21 1136/6 1141/21 1174/14 1180/19 1190/6 1141/23 1143/12 1143/16 1191/21 1192/18 1194/6 1148/1 1148/19 1150/2 telling [31] 1104/13 1151/13 1151/24 1152/11 1110/13 1115/24 1117/13 1155/3 1156/1 1158/20 1120/11 1126/15 1131/21 1170/20 1173/25 1174/3 1134/5 1134/10 1134/12 1175/11 1177/23 1185/9 1134/24 1135/24 1136/6 1186/7 1188/3 1188/16 1136/9 1136/11 1138/24 taken [5] 1150/8 1172/8 1142/25 1143/1 1164/24 1191/13 1195/5 1195/9 1164/25 1165/23 1169/16 takeoffs [1] 1173/9 1173/15 1181/6 1181/11 takes [4] 1158/19 1161/7 1182/5 1184/10 1184/20 1167/19 1193/25 1189/21 1191/1 1191/5 taking [3] 1140/24 tells [6] 1109/9 1123/24 1153/17 1174/6 1132/2 1135/11 1136/16 talk [33] 1104/22 1104/23 1190/15 1105/1 1105/3 1106/18 ten [1] 1130/6 1106/25 1107/5 1107/15 terms [12] 1148/25 1150/6 1107/19 1119/22 1128/2 1151/6 1152/17 1161/13 1134/25 1134/25 1134/25 1162/3 1162/3 1164/1 1139/5 1142/7 1142/9 1168/6 1171/5 1173/3 1146/1 1147/11 1147/14 1191/5 1148/8 1149/20 1151/4 terrible [4] 1103/25 1151/16 1162/17 1171/17 1124/8 1171/11 1181/23 1174/8 1179/13 1180/18 test [3] 1108/8 1138/19 1181/14 1181/15 1192/20 1148/4 1192/21 tested [1] 1118/21 talked [13] 1108/10 testified [19] 1102/10 1116/17 1128/15 1139/3 1120/10 1120/20 1121/10 1139/4 1147/21 1150/20 1121/13 1122/13 1128/9 1150/20 1151/3 1151/11 1128/10 1129/9 1131/20 1162/17 1181/24 1191/9 1137/11 1142/13 1161/15 talking [36] 1107/16 1164/2 1166/25 1167/22 1107/23 1107/23 1108/17 1183/14 1191/7 1193/1 1109/2 1110/4 1112/13 testifies [4] 1119/8 1112/14 1112/15 1113/10 1127/20 1190/3 1190/4 1113/15 1114/10 1114/22 testify [20] 1102/16 1115/15 1115/20 1116/19 1117/3 1117/4 1117/7 1116/20 1117/16 1117/18 1133/6 1133/7 1136/12 1120/22 1125/2 1125/9 1148/21 1159/5 1159/9 1131/24 1134/18 1138/3 1159/15 1160/3 1176/7 1140/2 1140/17 1142/18 1181/2 1181/6 1181/9 1147/22 1162/24 1165/22 1181/13 1192/8 1193/1 1167/23 1171/14 1180/20 1193/15 1189/2 1190/7 testifying [8] 1113/5 talks [2] 1114/5 1156/23 1129/4 1133/3 1144/25 tamper [1] 1179/6 1158/2 1158/11 1164/2 1218 1164/4 Page 121 of 126 testimony [22] 1103/20 1109/20 1116/24 1119/17 1138/19 1147/23 1148/19 1153/4 1153/21 1159/6 1161/4 1164/3 1164/4 1164/10 1167/17 1167/17 1167/25 1175/23 1190/13 1192/1 1192/3 1192/5 text [45] 1103/25 1104/3 1113/19 1114/2 1114/3 1114/5 1116/1 1117/9 1124/11 1124/25 1125/4 1125/5 1125/12 1125/14 1125/25 1126/1 1126/10 1126/11 1132/17 1132/17 1133/24 1134/2 1134/4 1134/12 1135/10 1136/21 1138/23 1140/16 1141/7 1141/9 1141/13 1141/16 1141/19 1142/16 1147/18 1155/22 1158/20 1161/18 1181/5 1185/1 1185/2 1187/10 1187/21 1187/22 1189/15 texted [2] 1118/22 1133/14 texting [2] 1117/12 1132/22 texts [8] 1118/14 1126/21 1140/3 1140/4 1166/8 1181/18 1182/4 1182/13 than [12] 1103/1 1115/7 1116/18 1139/23 1151/22 1157/5 1173/15 1175/4 1175/4 1179/1 1190/3 1190/3 Thank [4] 1178/21 1193/21 1194/13 1194/17 thanks [1] 1140/19 that [583] that's [67] 1106/25 1107/10 1110/7 1110/10 1110/21 1115/13 1116/21 1117/18 1122/6 1122/6 1131/2 1131/5 1131/16 1135/4 1136/1 1138/12 1138/23 1142/3 1143/11 1144/13 1145/23 1147/8 1148/10 1148/16 1148/22 1148/24 1149/5 1149/12 1151/9 1155/16 1156/2 1156/3 1156/3 1156/15 1156/21 1157/19 1158/2 1158/23 1159/2 1161/8 1161/20 1161/23 1162/15 1162/24 1165/18 1167/5 1167/11 1167/16 1169/7 1171/12 1172/13 1174/15 1176/10 1178/17 1180/13 1180/22 1182/15 1183/4 1183/25 1185/23 1185/23 1186/3 1186/24 1192/9 1192/9 1193/1 1193/8 The Godfather [2] 1173/4 1173/9 their [35] 1102/13 1105/24 1110/16 1113/19 1146/2 1147/9 1147/9 1147/17 1151/2 1151/24 1152/24 1156/11 1157/1 1185/23 306 1185/24 1186/6 Filed 02/14/20 T Case 1:19-cr-00018-ABJ Document 1187/1 1189/22 1190/6 their... [22] 1157/25 1190/11 1191/12 1191/12 1158/5 1159/22 1162/9 1192/12 1163/1 1167/16 1168/10 there'll [1] 1168/18 1170/22 1170/23 1171/5 there's [38] 1102/3 1175/23 1175/25 1176/1 1102/8 1103/1 1115/10 1176/2 1176/3 1176/4 1116/19 1122/15 1122/17 1183/15 1186/22 1188/3 1132/19 1133/5 1134/2 1188/17 1189/19 1193/17 1146/13 1147/1 1148/11 their Exhibit [1] 1151/24 1148/12 1149/4 1150/11 them [47] 1101/17 1101/23 1150/16 1155/4 1155/15 1102/13 1103/4 1107/17 1155/25 1156/2 1156/7 1108/11 1112/3 1112/4 1156/19 1157/5 1158/15 1112/17 1112/18 1119/5 1160/14 1164/13 1164/14 1119/5 1125/16 1129/19 1164/15 1166/23 1168/17 1132/13 1133/20 1134/6 1169/4 1170/8 1174/14 1136/1 1136/4 1140/16 1174/18 1180/23 1187/22 1141/21 1147/10 1147/11 1190/6 1147/12 1148/10 1157/9 these [69] 1103/23 1157/13 1159/11 1159/16 1104/17 1104/21 1105/3 1160/9 1163/8 1163/10 1111/14 1111/16 1111/17 1164/5 1164/9 1169/3 1112/3 1112/16 1115/20 1171/9 1173/13 1175/22 1119/8 1121/11 1125/21 1175/24 1179/9 1179/14 1126/14 1126/15 1130/12 1180/19 1186/22 1188/16 1131/11 1133/24 1134/8 1189/19 1192/21 1193/25 1135/10 1135/21 1137/20 then [39] 1102/1 1104/17 1138/1 1138/13 1138/17 1104/23 1105/1 1121/8 1142/21 1143/13 1144/19 1121/12 1129/9 1132/19 1148/12 1148/21 1149/2 1136/3 1142/8 1143/14 1149/6 1150/18 1151/14 1144/16 1149/3 1149/8 1151/15 1151/19 1151/20 1152/5 1152/11 1153/10 1151/21 1151/22 1152/1 1153/24 1155/1 1156/12 1153/13 1153/14 1154/21 1156/19 1159/21 1163/22 1155/20 1156/20 1159/12 1164/11 1166/14 1167/2 1159/13 1159/22 1161/11 1167/6 1167/18 1170/3 1161/14 1163/16 1163/20 1170/20 1170/21 1172/8 1164/8 1165/15 1165/24 1172/9 1173/2 1184/24 1166/8 1171/7 1171/12 1189/7 1189/11 1190/11 1171/25 1172/8 1174/5 1190/13 1176/7 1176/8 1176/24 then-candidate [1] 1178/5 1184/5 1186/4 1121/12 1188/5 1188/17 theory [2] 1145/24 they [109] 1168/11 they're [16] 1101/25 there [87] 1114/3 1114/3 1106/21 1131/13 1132/22 1117/13 1127/16 1127/17 1136/11 1142/7 1146/19 1127/17 1127/18 1133/25 1147/6 1148/21 1152/6 1139/8 1139/9 1140/12 1155/12 1157/6 1162/10 1145/2 1145/5 1145/12 1173/9 1176/1 1184/11 1147/5 1148/10 1148/12 they've [2] 1145/24 1148/13 1149/25 1150/7 1159/19 1150/21 1150/22 1150/24 thin [4] 1155/17 1155/18 1150/25 1151/4 1151/14 1168/9 1171/22 1151/16 1151/21 1152/14 thing [26] 1102/9 1114/10 1152/15 1152/16 1152/18 1123/1 1129/17 1130/5 1153/22 1153/23 1154/10 1132/23 1145/23 1148/15 1157/19 1159/17 1159/17 1162/8 1164/18 1164/25 1159/17 1159/24 1160/15 1165/23 1167/8 1171/22 1160/24 1162/12 1162/13 1172/3 1172/4 1172/24 1163/13 1164/1 1164/8 1173/3 1173/8 1173/22 1167/21 1167/22 1169/9 1176/21 1179/11 1183/4 1169/10 1169/23 1170/25 1185/19 1190/12 1194/3 1172/20 1173/13 1173/24 things [26] 1103/23 1174/4 1174/9 1174/12 1104/12 1104/21 1119/3 1175/23 1176/7 1177/17 1123/5 1143/5 1143/6 1177/20 1178/13 1178/25 1153/13 1153/14 1153/22 1179/17 1179/18 1180/4 1157/14 1157/17 1158/10 1181/16 1181/17 1181/19 1159/22 1161/15 1166/8 1182/15 1182/18 1183/1 1167/12 1169/14 1171/9 1183/23 1184/11 1185/5 1176/1 1176/8 1178/14 1219 1178/15 1178/15 1188/15 Page 122 of 126 1194/10 think [53] 1101/24 1102/16 1107/9 1112/1 1112/1 1112/5 1117/5 1120/24 1128/10 1131/14 1141/17 1143/11 1143/13 1144/19 1147/18 1148/25 1154/6 1154/7 1154/17 1154/22 1157/2 1160/15 1163/11 1163/17 1163/22 1164/6 1164/12 1165/10 1165/11 1166/24 1167/13 1168/5 1168/5 1169/7 1170/24 1172/17 1173/10 1173/16 1174/12 1174/24 1174/25 1175/1 1175/2 1175/3 1175/22 1176/15 1177/14 1178/1 1178/10 1178/11 1178/16 1180/8 1193/24 thinking [4] 1153/18 1161/14 1167/1 1185/1 thinks [2] 1136/3 1174/22 third [6] 1099/3 1126/6 1127/9 1155/1 1161/16 1183/18 third-party [1] 1183/18 Thirty [1] 1149/1 Thirty-seven [1] 1149/1 this [360] those [36] 1104/2 1104/19 1109/20 1110/19 1112/2 1112/22 1113/21 1114/24 1124/7 1126/24 1127/14 1133/13 1134/8 1138/20 1140/4 1140/6 1141/11 1141/19 1141/21 1142/15 1143/6 1144/10 1151/11 1151/17 1152/8 1160/6 1162/2 1163/8 1166/9 1177/10 1177/10 1180/19 1185/17 1186/25 1187/16 1193/20 though [2] 1131/2 1158/16 thought [9] 1154/7 1160/15 1161/1 1167/20 1171/15 1172/11 1183/23 1183/23 1184/25 thousand [6] 1125/21 1180/24 1181/10 1191/12 1191/12 1192/13 thousands [1] 1173/24 thread [1] 1155/8 threat [1] 1137/7 threatened [3] 1158/1 1192/24 1192/24 threats [1] 1140/20 three [11] 1107/17 1109/7 1116/5 1121/17 1132/15 1137/25 1149/2 1161/2 1163/5 1163/14 1184/14 through [24] 1104/20 1106/22 1108/14 1111/12 1111/23 1112/10 1114/2 1114/2 1123/11 1127/12 1129/23 1139/3 1147/15 1153/8 1159/14 1163/16 1168/23 1178/14 1185/17 1186/18 1186/19 1187/24 1188/4 1193/3 T Case 1:19-cr-00018-ABJ throughout [2] 1120/6 1155/8 throw [2] 1134/6 1134/6 tied [2] 1154/12 1154/12 time [37] 1098/7 1102/23 1104/1 1108/22 1108/25 1109/10 1110/3 1111/17 1113/5 1113/24 1114/16 1115/4 1115/7 1116/14 1116/16 1119/8 1121/11 1128/6 1131/21 1134/20 1137/5 1141/10 1142/9 1155/13 1158/10 1174/2 1174/2 1174/2 1179/16 1180/4 1180/10 1185/8 1190/17 1193/25 1194/2 1194/12 1195/5 times [8] 1107/18 1112/6 1116/5 1118/23 1141/17 1161/2 1175/9 1175/10 timing [3] 1151/23 1189/12 1189/25 today [6] 1108/4 1132/3 1141/17 1182/2 1184/15 1185/12 together [6] 1116/16 1157/1 1165/7 1177/14 1190/5 1194/8 token [1] 1145/16 told [50] 1104/8 1104/17 1106/8 1109/17 1113/24 1114/1 1114/9 1115/3 1116/4 1119/18 1120/10 1123/16 1123/16 1125/24 1127/19 1129/4 1129/25 1130/3 1131/20 1132/11 1132/13 1133/17 1133/17 1133/20 1133/24 1134/5 1134/9 1135/17 1138/2 1140/5 1141/12 1142/21 1145/7 1148/11 1151/3 1171/1 1171/10 1174/4 1174/5 1174/5 1174/9 1174/9 1174/13 1174/14 1175/7 1175/24 1192/9 1192/17 1192/18 1192/20 tomorrow [3] 1194/3 1194/11 1194/16 too [5] 1119/3 1151/9 1154/18 1162/17 1165/4 took [7] 1119/18 1119/19 1129/19 1148/8 1172/13 1180/14 1191/14 topic [4] 1106/3 1106/16 1181/24 1184/21 topics [4] 1103/17 1105/10 1105/13 1183/15 total [1] 1118/21 touch [2] 1114/23 1115/9 toward [2] 1135/2 1137/5 Tower [2] 1121/14 1169/3 tracks [1] 1185/4 Tracy [1] 1128/15 tranche [1] 1111/3 transcript [17] 1098/10 1107/13 1157/22 1161/24 1170/21 1176/12 1177/2 1177/7 1177/25 1182/17 1184/2 1186/6 1186/15 1187/3 1188/2 1189/5 Document 306 Filed 02/14/20 1195/3 transfer [6] 1184/8 1184/9 1184/11 1185/16 1185/20 1185/22 transpired [1] 1134/7 treat [1] 1157/24 trial [13] 1098/5 1098/10 1102/10 1102/12 1117/3 1117/5 1120/9 1128/9 1129/1 1129/18 1141/4 1193/23 1194/18 tricked [2] 1116/24 1117/17 tried [10] 1115/4 1130/1 1139/10 1139/19 1139/22 1139/24 1141/9 1176/6 1176/11 1180/14 tries [3] 1135/2 1137/5 1181/17 true [5] 1160/13 1161/20 1174/8 1176/2 1195/2 Trump [59] 1104/4 1104/6 1104/13 1108/23 1108/25 1109/1 1109/6 1110/8 1120/8 1121/1 1121/4 1121/5 1121/9 1121/12 1121/13 1121/14 1121/18 1121/20 1121/21 1123/3 1123/13 1123/15 1123/23 1124/8 1124/13 1124/16 1126/21 1127/5 1140/22 1141/6 1144/22 1144/23 1145/1 1145/1 1145/3 1145/18 1150/15 1150/17 1154/18 1158/6 1158/9 1168/12 1168/16 1168/18 1169/3 1169/6 1175/14 1175/17 1177/19 1177/24 1179/18 1179/25 1180/1 1180/3 1180/9 1180/10 1181/7 1185/20 1191/16 Trump's [5] 1122/2 1122/3 1122/9 1152/13 1183/12 trust [1] 1167/15 trusted [1] 1111/12 truth [27] 1103/24 1116/18 1117/19 1119/20 1127/1 1127/3 1127/6 1127/8 1127/11 1127/18 1131/2 1135/3 1136/4 1137/6 1138/16 1138/21 1141/13 1142/22 1143/3 1146/25 1179/25 1180/1 1190/6 1193/9 1193/9 1193/12 1193/15 truthful [15] 1108/15 1108/16 1113/7 1117/23 1117/25 1120/3 1120/4 1124/23 1124/24 1125/1 1126/8 1126/9 1138/19 1138/20 1142/23 truthfulness [1] 1163/12 try [9] 1103/4 1114/12 1118/17 1127/25 1136/22 1138/6 1142/11 1190/14 1194/9 trying [19] 1104/1 1106/1 1106/14 1117/10 1131/4 1131/13 1131/16 1140/25 1142/23 1158/6 1163/18 1220 1168/23 1169/5 1173/14 Page 123 of 126 1173/21 1174/24 1177/3 1177/18 1180/11 turn [2] 1170/14 1191/10 turned [1] 1134/16 turns [1] 1159/24 TV [1] 1122/9 tweet [3] 1105/20 1147/19 1147/21 tweeting [1] 1147/20 tweets [3] 1172/5 1173/3 1193/11 twice [1] 1107/17 twitter [4] 1109/5 1147/18 1155/22 1193/10 two [32] 1105/10 1109/15 1109/24 1111/18 1115/20 1121/16 1121/24 1125/21 1132/10 1137/15 1137/20 1140/11 1143/13 1148/10 1148/21 1149/1 1153/23 1154/21 1160/9 1160/9 1160/11 1161/2 1163/7 1168/15 1169/13 1171/7 1171/12 1171/25 1177/10 1180/14 1180/17 1181/5 U U.S [4] 1098/16 1103/15 1105/8 1183/20 U.S. [1] 1162/7 U.S. persons [1] 1162/7 unable [1] 1102/25 uncertain [1] 1191/5 under [9] 1118/11 1128/4 1135/22 1151/11 1162/15 1175/18 1176/20 1178/6 1193/14 undercut [1] 1181/18 undercuts [1] 1181/19 understand [1] 1172/12 understanding [3] 1177/11 1177/11 1177/13 understands [2] 1145/21 1162/12 understood [3] 1133/24 1134/5 1134/10 unfortunately [1] 1193/25 UNITED [13] 1098/1 1098/3 1098/11 1099/16 1101/3 1108/24 1124/4 1135/15 1145/11 1158/11 1162/5 1177/20 1195/4 unless [3] 1132/23 1134/3 1194/15 unproven [1] 1184/6 until [3] 1114/24 1128/7 1153/13 up [34] 1113/8 1114/12 1114/18 1115/4 1121/20 1125/20 1129/15 1130/4 1130/9 1131/4 1133/19 1135/10 1135/24 1136/24 1138/8 1142/7 1142/8 1142/11 1146/5 1146/6 1148/16 1148/16 1153/15 1159/4 1163/1 1171/4 1174/23 1177/21 1178/4 1179/14 1180/18 1183/19 1185/3 1194/10 upon [4] 1159/22 1161/5 1098/17 306 1099/18 Filed 02/14/20 U Case 1:19-cr-00018-ABJ Document wasn't [9] 1117/17 1123/2 upon... [2] 1178/5 1148/9 1157/23 1162/2 1178/13 1164/1 1168/7 1187/1 upping [2] 1175/1 1175/1 1191/2 urging [1] 1178/12 Waste [1] 1134/20 us [7] 1102/25 1149/2 watch [2] 1102/11 1112/3 1158/19 1161/7 1171/1 watched [4] 1170/24 1171/1 1174/14 1173/4 1173/4 1173/5 usdoj.gov [4] 1098/18 watching [2] 1167/14 1098/19 1098/19 1098/20 1171/1 use [5] 1122/4 1151/7 Watergate [1] 1132/6 1151/8 1167/17 1188/9 way [28] 1113/3 1115/8 used [6] 1164/16 1166/16 1129/11 1135/4 1136/6 1167/3 1168/6 1171/11 1137/22 1147/23 1152/17 1174/25 1153/21 1154/15 1155/15 uses [1] 1133/12 1155/25 1157/16 1162/2 using [3] 1140/13 1149/17 1162/16 1163/1 1163/5 1162/2 1166/7 1171/12 1171/13 1171/18 1172/20 1178/15 V 1178/16 1178/16 1178/17 various [3] 1144/19 1187/22 1192/6 1149/6 1161/12 ways [2] 1176/25 1178/24 very [14] 1109/25 1118/7 WBAI [2] 1172/17 1189/19 1125/24 1144/18 1144/20 we [77] 1102/23 1102/24 1148/23 1155/18 1165/25 1104/19 1105/1 1108/8 1168/9 1168/9 1176/11 1108/11 1108/12 1108/13 1176/11 1176/19 1194/13 1108/13 1108/19 1109/7 videos [1] 1112/3 1111/5 1111/12 1111/21 view [4] 1101/23 1135/11 1111/23 1113/23 1118/9 1193/11 1193/12 1119/12 1124/24 1124/25 viewed [2] 1120/20 1188/4 1126/10 1126/11 1134/3 virtue [1] 1162/25 1139/4 1139/21 1140/1 visit [2] 1123/2 1123/3 1141/16 1143/11 1143/12 voice [5] 1121/19 1130/1 1143/23 1146/3 1146/10 1168/14 1177/3 1177/3 1147/16 1148/4 1148/11 voice-mail [1] 1130/1 1148/15 1148/25 1149/17 voluntarily [3] 1159/15 1150/19 1153/8 1160/16 1160/3 1182/23 1160/18 1162/17 1163/8 volunteer [1] 1159/4 1163/25 1164/5 1164/11 vulgarity [1] 1137/7 1165/20 1166/14 1167/10 1167/18 1167/18 1168/9 W 1171/10 1174/13 1174/19 wait [2] 1138/8 1153/19 1174/20 1174/23 1174/23 walk [2] 1104/20 1141/16 1175/6 1175/6 1178/10 want [36] 1102/14 1103/3 1178/10 1178/16 1179/8 1112/4 1112/20 1112/21 1186/15 1186/18 1188/14 1128/25 1129/22 1130/5 1188/14 1188/16 1192/7 1130/8 1132/2 1142/15 1192/10 1192/10 1193/10 1145/23 1146/1 1146/2 1193/20 1194/2 1194/11 1151/23 1159/2 1159/21 we'll [6] 1143/14 1143/16 1159/21 1161/10 1163/9 1143/16 1143/19 1167/10 1175/13 1175/16 1178/4 1186/18 1179/15 1179/21 1181/24 we're [14] 1102/8 1103/2 1188/3 1188/5 1188/8 1104/22 1104/23 1105/2 1191/9 1191/15 1191/17 1119/2 1119/22 1121/14 1191/18 1193/4 1193/5 1143/13 1149/6 1162/24 1193/12 1182/2 1182/2 1193/8 wanted [22] 1101/9 1102/9 we've [2] 1139/3 1162/22 1106/18 1106/25 1107/1 website [1] 1190/22 1107/5 1107/15 1129/23 week [9] 1103/10 1115/7 1130/13 1155/14 1157/11 1118/23 1122/24 1126/18 1157/16 1161/1 1168/3 1141/3 1152/25 1153/7 1168/4 1168/8 1171/15 1179/24 1175/2 1175/3 1182/24 weekly [2] 1172/17 1186/1 1186/20 1189/20 wants [3] 1122/18 1125/8 weeks [2] 1111/18 1153/23 1143/2 well [28] 1102/24 1115/22 warning [1] 1119/19 1116/18 1117/15 1119/23 was [305] 1127/22 1134/9 1155/2 Washington [3] 1098/6 1155/3 1155/11 1155/12 1221 1155/15 1155/19 1157/12 Page 124 of 126 1158/4 1160/2 1160/25 1162/10 1171/20 1172/5 1173/19 1179/16 1180/2 1182/12 1182/14 1190/5 1191/14 1193/8 went [7] 1153/8 1155/14 1160/18 1167/7 1176/21 1182/8 1182/11 were [56] 1105/10 1105/14 1105/18 1105/19 1106/2 1106/9 1107/3 1107/9 1107/23 1116/19 1116/20 1117/1 1117/18 1124/5 1126/12 1126/25 1138/11 1145/15 1146/19 1146/20 1150/24 1150/25 1152/8 1152/10 1153/22 1154/21 1156/22 1157/7 1157/8 1160/10 1161/11 1162/4 1166/9 1168/2 1168/5 1168/8 1173/24 1180/6 1183/24 1184/25 1185/2 1185/18 1185/23 1186/3 1186/3 1186/4 1186/4 1186/16 1186/17 1188/12 1189/2 1189/9 1189/10 1190/7 1191/12 1191/12 what [186] what's [13] 1101/23 1108/22 1114/8 1115/17 1122/18 1122/24 1135/5 1142/6 1156/18 1160/5 1163/24 1169/8 1177/16 when [80] 1107/15 1109/5 1110/5 1112/13 1112/16 1114/19 1117/15 1123/18 1125/2 1127/24 1128/6 1128/9 1128/14 1129/3 1129/21 1130/3 1131/20 1132/12 1133/8 1133/19 1134/2 1134/9 1134/11 1135/2 1135/22 1135/24 1138/2 1141/16 1142/11 1142/13 1142/15 1144/21 1145/13 1145/21 1147/5 1147/8 1148/11 1148/16 1151/20 1153/6 1153/7 1154/1 1154/3 1155/21 1156/9 1159/19 1160/5 1160/18 1161/14 1165/6 1165/11 1166/12 1168/7 1168/8 1169/15 1169/16 1171/10 1172/5 1176/7 1176/19 1177/14 1177/18 1178/6 1178/6 1178/24 1179/23 1180/23 1182/8 1184/25 1186/3 1186/6 1187/19 1188/14 1189/24 1191/6 1192/12 1192/22 1192/23 1193/16 1194/3 where [24] 1111/5 1114/10 1119/12 1123/10 1125/8 1127/15 1129/13 1133/6 1149/4 1152/3 1158/9 1158/19 1159/2 1167/19 1175/25 1181/1 1181/2 1182/9 1185/25 1188/23 1189/8 1191/5 1193/11 1193/14 wherever [1] 1136/5 1175/11 306 1177/16 1179/19 Filed 02/14/20 W Case 1:19-cr-00018-ABJ Document 1180/14 1182/2 1182/2 whether [30] 1101/9 1182/15 1183/22 1185/23 1103/18 1106/1 1106/9 1186/3 1186/24 1191/10 1107/3 1108/10 1108/12 1191/13 1191/14 1108/13 1124/5 1150/7 WikiLeaks [91] 1103/19 1151/7 1156/14 1160/10 1104/2 1104/10 1104/12 1166/11 1170/6 1171/6 1105/16 1105/19 1105/21 1173/21 1174/2 1180/5 1106/2 1106/10 1106/15 1180/6 1182/10 1185/20 1106/18 1106/20 1106/24 1185/21 1186/11 1186/12 1106/24 1107/2 1107/3 1186/16 1186/17 1186/18 1107/10 1107/15 1107/16 1191/22 1191/25 1108/20 1109/10 1109/11 which [21] 1106/20 1108/5 1109/18 1110/4 1110/14 1126/12 1136/3 1144/8 1110/21 1111/20 1112/8 1150/2 1151/10 1151/16 1114/5 1114/18 1114/23 1152/11 1160/20 1164/11 1115/5 1115/17 1118/6 1170/22 1175/19 1184/1 1118/18 1118/23 1119/13 1184/1 1184/15 1186/13 1119/13 1120/7 1120/11 1186/16 1187/21 1190/20 1120/14 1120/19 1120/21 1195/8 1122/4 1122/11 1122/15 while [2] 1102/8 1158/6 1122/21 1122/24 1123/16 who [67] 1101/6 1102/10 1123/18 1124/5 1125/6 1102/24 1103/21 1104/18 1126/20 1126/21 1136/18 1105/23 1107/23 1107/23 1137/18 1138/14 1140/14 1108/4 1108/7 1110/2 1140/17 1140/22 1141/1 1110/8 1111/15 1111/22 1141/5 1145/6 1145/15 1112/13 1117/4 1117/5 1146/13 1153/12 1153/13 1117/7 1117/18 1123/19 1158/8 1162/11 1166/2 1123/20 1126/25 1127/17 1169/11 1172/15 1172/21 1127/18 1128/19 1129/16 1175/24 1180/11 1180/21 1129/17 1133/4 1134/13 1182/21 1183/1 1183/12 1134/22 1135/20 1135/25 1183/17 1183/17 1183/21 1136/6 1140/16 1142/21 1184/8 1184/9 1184/12 1148/13 1148/13 1154/14 1184/19 1184/22 1185/17 1155/4 1155/5 1160/14 1185/22 1186/23 1190/22 1162/13 1165/25 1166/22 WikiLeaks' [4] 1104/4 1167/13 1167/23 1169/17 1105/15 1106/6 1110/20 1169/20 1170/4 1173/11 will [32] 1112/5 1125/20 1175/7 1175/16 1177/3 1126/22 1130/22 1131/1 1180/9 1180/9 1180/17 1132/23 1139/16 1144/10 1180/18 1180/18 1181/8 1144/14 1147/4 1147/4 1185/12 1185/14 1185/16 1148/8 1151/10 1153/5 1186/8 1186/8 1186/20 1161/6 1166/10 1169/7 1187/18 1189/1 1170/20 1173/3 1176/17 who's [1] 1169/16 1177/1 1177/1 1177/2 whole [18] 1102/3 1127/17 1177/14 1178/2 1178/7 1130/4 1131/9 1132/23 1181/15 1184/1 1186/16 1140/13 1147/7 1153/17 1194/4 1194/11 1194/11 1162/8 1163/5 1164/18 willing [2] 1186/11 1168/10 1176/21 1182/1 1186/12 1182/1 1185/19 1188/4 within [5] 1121/20 1190/11 1158/22 1161/6 1177/9 wholly [1] 1138/19 1177/9 whom [1] 1169/22 without [2] 1152/9 whopper [2] 1124/19 1167/16 1126/3 witness [24] 1101/11 whoppers [1] 1126/15 1101/12 1103/21 1105/2 whose [1] 1168/22 1134/11 1134/14 1138/23 why [49] 1102/25 1103/23 1139/2 1139/4 1164/2 1106/25 1107/5 1107/14 1164/11 1166/3 1166/14 1117/11 1122/20 1124/1 1167/12 1167/13 1170/4 1126/14 1126/15 1128/5 1173/21 1179/6 1182/5 1128/10 1131/13 1136/9 1182/5 1188/17 1191/21 1142/25 1143/1 1144/17 1192/2 1193/17 1144/19 1144/24 1145/25 witness's [1] 1192/5 1148/8 1152/14 1152/15 witnesses [3] 1102/12 1155/17 1159/3 1159/4 1179/8 1179/9 1159/4 1159/6 1159/7 woman [2] 1115/3 1129/22 1159/7 1159/15 1167/1 won't [3] 1134/19 1142/19 1168/11 1174/6 1175/11 1194/8 1222 wonder [1] 1177/16 Page 125 of 126 wool [1] 1117/6 word [4] 1109/23 1110/14 1121/24 1140/10 WordPress [1] 1121/4 words [17] 1117/11 1129/17 1131/11 1133/12 1134/8 1142/21 1148/12 1149/12 1151/7 1151/8 1179/17 1180/24 1181/10 1181/16 1184/20 1185/9 1188/9 work [4] 1114/15 1131/9 1190/1 1190/1 worked [2] 1165/7 1189/13 works [2] 1136/2 1188/15 world [4] 1125/8 1125/11 1188/23 1193/10 worried [1] 1124/9 worry [1] 1116/11 worth [2] 1180/24 1181/10 worthless [1] 1132/23 would [54] 1103/25 1104/1 1104/3 1104/6 1110/6 1115/20 1116/22 1120/18 1123/2 1123/3 1123/4 1127/20 1127/23 1127/25 1128/3 1128/7 1130/11 1142/22 1143/4 1143/10 1144/12 1145/16 1145/18 1145/25 1146/5 1150/6 1152/5 1152/9 1153/12 1155/17 1159/3 1159/4 1159/4 1159/6 1159/7 1159/8 1159/9 1159/15 1160/3 1161/23 1163/22 1163/23 1167/13 1167/15 1171/23 1175/18 1176/14 1179/19 1180/17 1181/23 1185/18 1190/22 1191/13 1192/21 wouldn't [8] 1130/3 1156/5 1180/13 1180/13 1180/18 1180/18 1189/12 1192/20 write [1] 1123/4 writes [9] 1109/8 1109/23 1122/1 1123/6 1123/7 1124/13 1132/10 1132/21 1138/13 writing [6] 1116/4 1118/1 1125/12 1127/7 1138/18 1160/3 written [12] 1104/14 1104/15 1125/16 1125/21 1137/22 1137/23 1141/14 1141/15 1156/13 1179/7 1179/8 1181/16 wrong [10] 1115/25 1129/7 1135/13 1136/17 1138/2 1145/14 1156/24 1189/22 1189/22 1190/9 Y yeah [2] 1141/13 1167/20 year [2] 1158/6 1190/18 years [5] 1130/6 1150/5 1171/8 1171/8 1173/7 yes [24] 1101/5 1101/13 1117/25 1119/1 1120/4 1124/24 1125/4 1126/9 1223 Y Case 1:19-cr-00018-ABJ Document 306 Filed 02/14/20 Page 126 of 126 yes... [16] 1127/3 1127/6 1127/8 1127/11 1141/14 1149/17 1150/20 1150/20 1150/20 1151/3 1151/9 1154/19 1166/8 1170/16 1173/17 1179/22 yesterday [2] 1163/4 1178/1 yet [4] 1114/14 1143/17 1184/6 1194/6 York [1] 1131/10 you [390] you'd [1] 1132/13 you'll [5] 1163/4 1176/25 1178/13 1182/16 1194/4 you're [12] 1129/1 1129/2 1129/5 1134/17 1142/18 1152/2 1152/2 1181/6 1181/9 1186/6 1188/1 1191/19 you've [5] 1115/25 1126/6 1129/7 1136/17 1153/21 your [52] 1101/5 1101/23 1102/23 1108/12 1112/4 1116/8 1117/23 1119/20 1127/2 1127/4 1132/12 1132/13 1132/24 1133/2 1134/20 1134/24 1136/1 1136/23 1137/3 1137/4 1142/9 1143/18 1144/12 1144/15 1149/13 1150/14 1152/5 1156/5 1167/16 1171/23 1174/11 1174/15 1176/15 1177/11 1177/11 1177/13 1177/15 1181/11 1181/18 1182/13 1185/15 1186/8 1186/19 1187/4 1188/6 1189/1 1189/15 1191/2 1191/6 1193/12 1193/24 1194/13 yours [1] 1194/4 yourself [3] 1141/12 1159/3 1186/7 Z ZELINSKY [4] 1098/15 1106/8 1129/14 1179/23