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IN
THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES OF AMERICA
v.
IGOR Y. DANCHENKO,
Defendant.
UNDER SEAL
CR No. I:21-CR-245 (AJT)
COUNTS ONE-FIVE
18 U.S.C. § 1001(a)(2)
False Statements
INDICTMENT
COUNT ONE
102. Paragraphs 1 to 101 are incorporated by reference.
103. On or about June 15, 2017, within the Eastern District of Virginia, IGOR DANCHENKO,
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 June 15, 2017, the defendant denied to agents of the FBI that he had
spoken with PR Executive-1 about any material contained in the Company Reports,
when in truth and in fact, and as the defendant well knew, PR Executive-1 was
the source for an allegation contained in a Company Report dated August 22,
2016 and was
otherwise involved in the events and information described in the reports.
104. Paragraphs 1 to 101 are
incorporated by reference.
105. On or about March 16, 2017,
within the Eastern District of Virginia, IGOR DANCHENKO, 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
March 16, 2017, the defendant stated to agents of the FBI that he received a
late July 2016 telephone call from an individual who DANCHENKO believed was
"probably" Chamber President-1, when in truth and in fact, and as the defendant well knew. Chamber President-1 never called DANCHENKO.
(In violation of Title 18, United States Code, Sections 1001(a)(2))
106.
Paragraphs 1 to 101 are incorporated by reference.
107.
On or about May 18, 2017, within the Eastern District of Virginia, IGOR DANCHENKO,
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 May 18, 2017, the defendant stated to agents of the FBI that he "was
under the impression" that a late July 2016 telephone call that he
received was from Chamber President-1, when in truth and in fact, and as the
defendant well knew. Chamber President-1 never called DANCHENKO.
(In violation of Title 18, United States Code, Sections 1001(a)(2))
COUNT FOUR
108.
Paragraphs 1 to 101 are incorporated by reference.
109.
On or about October 24, 2017, within the Eastern District of Virginia, IGOR DANCHENKO,
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 October
24,2017, the defendant stated to agents of the FBI that he believed that he
spoke to Chamber President-1 on the telephone on more than one occasion, when
in truth and in fact, and as the defendant well knew, DANCHENKO never spoke to
Chamber President-1.
(In violation of Title 18, United States Code, Sections 1001(a)(2))
110,
Paragraphs 1 to 101 are incorporated by reference.
111.
On or about November 16, 2017, within the Eastern District of Virginia, IGOR DANCHENKO, 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 November 16,
2017, the defendant stated to agents of the FBI that he believed that he had spoken to
Chamber President-1 on the telephone, when in truth and in fact, and as the defendant well knew,
DANCHENKO never spoke to Chamber President-1.
(In violation of Title 18, United States Code, Sections 1001(a)(2))
JOHN H. DURHAM
Special Counsel
U.S. Department of Justice
Date: November 3, 2021
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