INDICTMENT: UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA, UNITED STATES OF AMERICA v.MICHAEL A. SUSSMANN, Defendant., CRIMINAL NO. 21-cr-00582-CRC, VIOLATIONS: 18 U.S.C. § 1001(a)(2) (Making A False Statement)

 

 

https://drive.google.com/file/d/1HeOsgWPOniJX5ZsKZ1tEXq0YQXqeCcA0/view?usp=sharing  

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
MICHAEL A. SUSSMANN, Defendant.
CRIMINAL NO. 21-cr-------
VIOLATIONS:
18 U.S.C. § 1001(a)(2)
(Making A False Statement)
INDICTMENT

 

On or about August 22, 2016, Researcher-1 emailed the aforementioned recipients, expressing continued doubt regarding the Russian Bank-1 allegations that SUSSMANN would later convey to the FBI, and raising concerns about the researchers' bias against Trump:

Let[']s for a moment think of the best case scenario, where we are able

to show (somehow) that DNS [] communication exists between Trump

and R[ussia]. How do we plan to defend against the criticism that

this is not spoofed [] traffic we are observing? There is no answer to

that. Let's assume again that they are not smart enough to refute our

"best case" scenario. [Tech Executive- 1], you do realize that we will

have to expose every trick we have in our bag to even make a very

weak association? Let[']s all reflect upon that for a moment. Sorry

folks, but unless we get combine net1ow and DNS traffic collected at

critical points between suspect organizations, we cannot technically

make any claims that would fly public scrutiny.

 

The only thing that drive[s] us at this point is that we just do not

like [Trump]. This will not fly in eyes of public scrutiny. Folks, I

am afraid we have tunnel vision. Time to regroup?

(emphasis added).

 

SUSSMANN and His Client Prepare a White Paper Summarizing the Russian Bank-1

Allegations

24. Despite the aforementioned views that the Russian Bank Data and allegations were a "red herring" that should be "ignored," SUSSMANN, Tech Executive-1, Originator- 1, and the University-1 researchers began to draft, review, and revise a "white paper" summarizing the Russian Bank-1 allegations that SUSSMANN would later provide to the FBI. SUSSMANN continued to bill time on these matters to the Clinton Campaign.

 

COUNT ONE

45. Paragraphs 1 to 44 are incorporated by reference.

46. On or about September 19, 2016, within the District of Columbia, MICHAEL A. SUSSMANN, the defendant, did willfully and knowingly make a materially false, fictitious, and fraudulent statement or representation in a matter before the jurisdiction of the executive branch of the Government of the United States, to wit, on or about September 19, 2016, the defendant stated to the General Counsel of the FBI that he was not acting on behalf of any client in conveying particular allegations concerning a Presidential candidate, when in truth, and in fact, and as the defendant well knew, he was acting on behalf of specific clients, namely, Tech Executive-1 and the Clinton Campaign. 

(In violation of Title 18, United States Code, Section 1001(a)(2))

 

JOHN H. DURHAM
Special Counsel
U.S. Department of Justice

A TRUE BILL:

Foreperson
Date: September 16, 2021