Paul Manafort sues DOJ, Mueller and Rosenstein

Paul Manafort, the former campaign chairman for Trump, filed a lawsuit Wednesday challenging the jurisdiction of Special Counsel Robert S. Mueller III. Manafort challenges his indictment in Russia probe by filing lawsuit against Mueller

Case 1:18-cv-00011 Document 1 Filed 01/03/18 Page 1 of 17

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
__________________________________________
)
PAUL J. MANAFORT, JR.
)
10 St. James Drive
)
Palm Beach Gardens, FL 33418
)
)
Civ. No. 1:18-cv-00011
Plaintiff,
)
)
v.
)
COMPLAINT FOR
)
DECLARATORY AND
UNITED STATES DEPARTMENT
)
INJUNCTIVE RELIEF
OF JUSTICE,
)
950 Pennsylvania Avenue, N.W.
)
Washington, D.C. 20004,
)
)
ROD J. ROSENSTEIN,
)
in his official capacity as
)
ACTING ATTORNEY GENERAL,
)
United States Department of Justice
)
950 Pennsylvania Avenue, N.W.
)
Washington, D.C. 20004,
)
)
and
)
)
ROBERT S. MUELLER III,
)
in his official capacity as
)
SPECIAL COUNSEL
)
Office of Special Counsel
)
395 E Street, S.W.
)
Washington, D.C. 20024,
)
and
)
950 Pennsylvania Avenue, N.W.
)
Washington, D.C. 20004
)
Defendants.
)
_________________________________________ )
Plaintiff Paul J. Manafort, Jr., brings this Complaint against defendants the United States
Department of Justice; Rod J. Rosenstein, in his official capacity as Acting Attorney General;
and Robert S. Mueller III, in his official capacity as Special Counsel, alleging as follows:

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NATURE OF THE ACTION
1.

This is a civil action under the Administrative Procedure Act, 5 U.S.C. ASSASS 701 et

seq.; the Declaratory Judgment Act, 28 U.S.C. ASS 2201; and for injunctive relief to restrict public
officers to their lawful authority, against the United States Department of Justice (aDOJa),
Acting Attorney General Rod J. Rosenstein, and Robert S. Mueller III.
BACKGROUND
2.

The principle that government must be both limited in power and accountable to

the people lies at the core of our constitutional traditions. That principle must be zealously
guarded against creeping incursions. One of the most notorious violationsathe awolf a that
famously came aas a wolf aawas the now-defunct independent counsel law from the Ethics in
Government Act of 1978, Pub. L. No. 95-521, 92 Stat. 1824. Morrison v. Olson, 487 U.S. 654,
699 (1988) (Scalia, J., dissenting). That law gave expansive prosecutorial authority to lawyers
who were outside the Justice Department and thus lacked political accountability for their
choices.
3.

The independent counsel law is now widely seen as amisguideda because it

created aunaccountable prosecutors wielding infinite resources whenever there is a plausible
allegation of a technical crime.a Gerard E. Lynch, The Problem Isnat in the Starrs But in a
Misguided Law, WASH. POST, Feb. 22, 1998, at C3. Because it permitted delegations of almost
unbridled prosecutorial authority, the independent counsel regime is broadly recognized today as
autter[ly] incompatib[le] . . . with our constitutional traditions.a Morrison, 487 U.S. at 709
(Scalia, J., dissenting).
4.

The independent counsel statute expired in 1999 when Congress refused to

reauthorize it. That refusal reflected a abipartisan judgment . . . that the Independent Counsel

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was a kind of constitutional Frankensteinas monster, which ought to be shoved firmly back into
the ice from which it was initially untombed.a Adrian Vermeule, Morrison v. Olson Is Bad Law,
LAWFARE (June 9, 2017).
5.

Kenneth Starr, after serving as an independent counsel under the statute, urged

Congress in testimony before the Senate to abandon the independent counsel project, calling it a
astructurally unsounda and aconstitutionally dubiousa effort ato cram a fourth branch of
government into [a] three-branch system.a Attorney General Janet Reno put her criticism of the
independent counsel system in her testimony before the Senate even more bluntly: aIt canat get
any worse.a
6.

DOJ responded to Congressas decision not to re-authorize the independent

counsel statute by promulgating regulations that give the Attorney General authority to appoint
aspecial counsela in connection with matters that may present a conflict of interest for the
Department of Justice or the Executive Branch. Given the constitutionally problematic nature of
unlimited grants of investigatory and prosecutorial authorityaand Congressas resulting decision
to abolish the independent counsel regimeathe Justice Department regulations carefully
circumscribe that appointment authority and the scope of any appointments under it.
7.

This case arises from an appointment in excess of that limited authoritya

specifically, Acting Attorney General Rod J. Rosensteinas order appointing Robert S. Mueller III
as Special Counsel in May 2017 (athe Appointment Ordera), attached hereto as Exhibit A.
8.

Consistent with DOJas special counsel regulations, the Appointment Order gives

Mr. Mueller authority to investigate a specific matter: alinks and/or coordination between the
Russian government and individuals associated with the campaign of President Donald Trump.a
But the Appointment Order then purports to grant Mr. Mueller the additional authority to pursue

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aany matters that arose or may arise directly froma that investigation. As explained below, that
exceeds the scope of Mr. Rosensteinas authority to appoint special counsel as well as specific
restrictions on the scope of such appointments. Indeed, the Appointment Order in effect purports
to grant Mr. Mueller carte blanche to investigate and pursue criminal charges in connection with
anything he stumbles across while investigating, no matter how remote from the specific matter
identified as the subject of the Appointment Order.
9.

As a result of the ultra vires Appointment Order, Mr. Muelleras investigation of

Mr. Manafort has extended far beyond alinks and/or coordination between the Russian
government and individuals associated with the campaign of President Donald Trump.a The
investigation has focused on Mr. Manafortas offshore business dealings that date back to as early
as 2005aabout a decade before the Trump presidential campaign launchedaand have been
known to the United States government for many years.
10.

On October 27, 2017, the Office of the Special Counsel caused an indictment

against Mr. Manafort to be returned. The indictment does not charge any links between Mr.
Manafort and the Russian government.

Instead, the Special Counsel has constructed an

indictment that, at its essence, concerns failing to file certain informational reports of offshore
bank accounts and failing to register as a foreign agent. None of the charges relate to Mr.
Manafortas activities during his brief stint in 2016 as the campaign manager for the Trump
presidential campaign.
11.

The actions of DOJ and Mr. Rosenstein in issuing the Appointment Order, and

Mr. Muelleras actions pursuant to the authority the Order granted him, were arbitrary, capricious,
and not in accordance with the law under 5 U.S.C. ASS 706. By this action, Mr. Manafort asks this
Court to hold those actions ultra vires and set them aside. Id. Like the independent counsel

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statute that came before it, this Appointment Order aought to be shoved firmly back into the ice
from which it was initially untombed.a
THE PARTIES
12.

Plaintiff Paul J. Manafort, Jr., is a United States citizen and natural person who

resides in Palm Beach Gardens, Florida. From late March 2016 until early August 2016, he
served as the campaign manager for then-presidential candidate Donald J. Trump.
13.

Defendant United States Department of Justice is an executive agency of the

United States responsible for the enforcement of federal civil and criminal laws.
14.

Defendant Rod J. Rosenstein is the current Deputy Attorney General of the

United States. At all times relevant to the facts alleged herein, Mr. Rosenstein served as the
Acting Attorney General of the Department of Justice. Mr. Rosenstein is sued in his official
capacity.
15.

Defendant Robert S. Mueller III is the Special Counsel appointed in the May 17,

2017 Appointment Order. Mr. Mueller is sued in his official capacity.
JURISDICTION AND VENUE
16.

This is an action seeking relief under the APA, 5 U.S.C. ASSASS 701 et seq., and the

Declaratory Judgment Act, 28 U.S.C. ASS 2201. Because this action arises under the laws of the
United States, this Court has subject-matter jurisdiction pursuant to 28 U.S.C. ASS 1331.
17.

This Court has personal jurisdiction over all defendants pursuant to D.C. Code

ASS 13-423(a)(1) because they transact substantial business in this district.
18.

Venue is proper in this Court pursuant to 28 U.S.C. ASS 1391(e) because this is an

action against an agency and officers of the United States, and a substantial part of the events
giving rise to the claims alleged herein occurred in this district.

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STATUTORY AND REGULATORY BACKGROUND
19.

Section 515(a) of Title 28 of the U.S. Code provides that all attorneys who

conduct legal proceedings under the Attorney Generalas authorization must be aspecially
appointed by the Attorney General under lawa and aspecifically directed by the Attorney
General.a
20.

DOJ has promulgated regulations implementing that provisionaand restricting

the scope of appointment authorityato protect against the excesses the Nation experienced
under the independent counsel regime. Those DOJ special counsel regulations appear at 28
C.F.R. ASSASS 600.1-600.10.
21.

DOJas special counsel regulations specify (a) the scope of the original jurisdiction

the Attorney General or Acting Attorney General (hereinafter aAttorney Generala) may grant to
a special counsel, and (b) the mechanism by which that jurisdiction may be extended later on.
22.

With respect to the aoriginal jurisdictiona of special counsel, DOJas special

counsel regulations provide as follows:
(a)

Original jurisdiction. The jurisdiction of a Special Counsel shall
be established by the Attorney General. The Special Counsel will
be provided with a specific factual statement of the matter to be
investigated. The jurisdiction of a Special Counsel shall also
include the authority to investigate and prosecute federal crimes
committed in the course of, and with intent to interfere with, the
Special Counselas investigation, such as perjury, obstruction of
justice, destruction of evidence, and intimidation of witnesses; and
to conduct appeals arising out of the matter being investigated
and/or prosecuted.

28 C.F.R. ASS 600.4(a).
23.

With respect to aadditional jurisdiction,a DOJas special counsel regulations

provide:

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(b)

Additional jurisdiction. If in the course of his or her investigation
the Special Counsel concludes that additional jurisdiction beyond
that specified in his or her original jurisdiction is necessary in
order to fully investigate and resolve the matters assigned, or to
investigate new matters that come to light in the course of his or
her investigation, he or she shall consult with the Attorney
General, who will determine whether to include the additional
matters within the Special Counselas jurisdiction or assign them
elsewhere.

28 C.F.R. ASS 600.4(b).
24.

DOJas special counsel regulations thus carefully limit the a[o]riginal jurisdictiona

the Attorney General can give special counsel, requiring aa specific factual statementa by the
Attorney General of athe matter to be investigated.a 28 C.F.R. ASS 600.4(a) (emphasis added). The
regulations automatically provide further aauthority to investigate and prosecute federal crimes
committed in the course of, and with intent to interfere with, the Special Counselas
investigationa such as obstruction, perjury, etc. Id. (emphasis added). But any aadditional
jurisdictiona beyond thatato investigate or prosecute matters outside the aspecific factual
statement of the matter to be investigateda or obstruction and perjury designed to interfere with
the investigationacan be granted only after the special counsel aconsult[s] with the Attorney
General, who will determine whether to include the additional matters within the Special
Counselas jurisdiction or assign them elsewhere.a Id. ASS 600.4(a), (b).
25.

Those carefully crafted jurisdictional limitations serve critical values.

They

ensure that the scope of an investigation is limited to specific matters identified in advance by a
politically accountable officialathe Attorney General. They ensure that any additional matters
beyond that are specifically approved by a politically accountable officialathe Attorney
General. Those limitations prevent the special counsel from becoming an unaccountable roving

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commission, with virtually unlimited resources, that can delve into citizensa lives in search of
criminality unrelated to the specific matters the special counsel was appointed to address.
26.

This suit arises from an appointment and the exercise of authority in defiance of

those jurisdictional limitations. Whether DOJas special counsel regulations themselves acreate
any rights,a 28 C.F.R. ASS 600.10, they bind DOJ and the officers within DOJ. DOJ and its
officials cannot grant a special counsel jurisdiction where DOJ regulations, such as 28 C.F.R.
ASS 600.4, deny DOJ and its officials power to do so. Nor can the special counsel exercise
jurisdiction that otherwise binding DOJ regulations prohibit. Those, however, are precisely the
circumstances here.
FACTUAL ALLEGATIONS
The Appointment Order
27.

By early 2017, DOJ had publicly revealed that it was investigating allegations that

President Trumpas campaign colluded with Russian government officials and/or representatives
to sway the outcome of the 2016 presidential election.
28.

Attorney General Jeff Sessions recused himself from the matter in March 2017.

29.

With the Attorney Generalas recusal, Deputy Attorney General Rod J. Rosenstein

became the highest-ranking DOJ official with authority over the investigation.
30.

Rather than have DOJ itself continue the investigation, on May 17, 2017, Mr.

Rosenstein issued the Appointment Order authorizing Mr. Muellerathen an attorney in private
practiceato conduct an investigation as special counsel.
31.

Providing the required aspecific factual statement of the matter to be

investigated,a 28 C.F.R. ASS 600.4(a), paragraph (b)(i) of the Appointment Order gives Mr. Mueller

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original jurisdiction to investigate aany links and/or coordination between the Russian
government and individuals associated with the campaign of President Donald Trump.a
32.

Consistent with 28 C.F.R. ASS 600.4(a)awhich provides that special counsels ashall

alsoa have aauthority to investigate and prosecute federal crimes committed in the course of, and
with intent to interfere with,a their investigationsaparagraph (b)(iii) of the Appointment Order
provides that Mr. Mueller may also pursue aany other matters within the scope of 28 C.F.R.
ASS 600.4(a).a
33.

But paragraph (b)(ii) of the Appointment Order purports to grant Mr. Mueller

further authority to investigate and prosecute aany matters that arose or may arise directly from
the investigation.a

That grant of authority is not authorized by DOJas special counsel

regulations. It is not a aspecific factual statement of the matter to be investigated.a Nor is it an
ancillary power to address efforts to impede or obstruct investigation under 28 C.F.R. ASS 600.4(a).
34.

DOJas special counsel regulations do address anew matters that come to light in

the course of a the special counselas ainvestigation,a but not by authorizing a grant of original
jurisdiction to pursue them. 28 C.F.R. ASS 600.4(b). To the contrary, DOJas special counsel
regulations specify that, whenever the special counsel aconcludes that additional jurisdictiona is
required to address anew matters that come to light in the course of a an investigation, the special
counsel must aconsult with the Attorney General,a who must then adetermine whether to include
the additional matters within the Special Counselas jurisdiction or assign them elsewhere.a Id.
35.

The effort to convey that aadditionala authority to pursue any matters that might

come to light, as part of the grant of original jurisdiction, without the required consultation and
decision by the Attorney General, exceeds the scope of appointment authority under 28 C.F.R.
ASS 600.4. It also defies the principles of limited power and accountability that animate those limits

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on the Attorney Generalas appointment authority. Under the Appointment Order, the Special
Counselas authority is not confined to the specific matters identified by politically accountable
officials: The Appointment Order purports to grant authority to the Special Counsel to expand
the scope of his investigation to new matters without the consent ofaindeed, without even
consultingaany politically accountable officer of the United States.
Mr. Muelleras Investigation of Matters Beyond His Original Jurisdiction
36.

Early in the process, Mr. Muelleras investigation diverged from its focus on

alleged collusion between the Russian government and President Trumpas campaign toward Mr.
Manafort, who served as President Trumpas campaign manager for a few months in 2016.
37.

The investigation of Mr. Manafort is completely unmoored from the Special

Counselas original jurisdiction to investigate aany links and/or coordination between the Russian
government and individuals associated with the campaign of President Donald Trump.a It has
instead focused on unrelated, decade-old business dealingsaspecifically, Ukraine political
campaign consulting activities of Mr. Manafort.
38.

The Special Counsel has paid particular attention to the involvement of Mr.

Manafortas company in a lobbying campaign that ended in 2014, Mr. Manafortas bank accounts
and tax filings through 2014, and the personal expenditures Mr. Manafort allegedly made using
funds earned from his political consulting work.
39.

Those alleged dealings had no connection whatsoever to the 2016 presidential

election or even to Donald Trump. Nor were they uncovered in the course of the Special
Counselas probe into President Trumpas campaign. On the contrary, those allegations had been
widely known since at least 2007, when prominent news outlets reported that, in 2005, Mr.
Manafort had begun working for Viktor Yanukovych, a Ukrainian politician, to reinvent his

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public image. Other reports around the same time claimed that Mr. Manafortas company never
registered as a lobbying entity for Mr. Yanukovych even though Mr. Manafort met with the
United States Ambassador on Mr. Yanukovychas behalf.
40.

On July 30, 2014, Mr. Manafort voluntarily met with DOJ prosecutors and FBI

agents to discuss his offshore political consulting activities. During the interview, Mr. Manafort
provided a detailed explanation of his activities in Ukraine, including his frequent contact with a
number of previous U.S. Ambassadors in Kiev and his efforts to further U.S. objectives in
Ukraine on their behalf.

He further discussed his offshore banking activity in Cyprus.

Throughout the process, DOJ maintained that they were assisting the Ukrainian government in
locating stolen assets. The investigation focused on the activities of a former Ukraine President
and was closed soon after Mr. Manafortas interview.
41.

The Office of the Special Counsel charged Mr. Manafort with the very conduct he

voluntarily disclosed to DOJ almost three years prior to the appointment of Mr. Mueller as
Special Counsel. The charged conduct does not relate to the specific matter designated in the
Appointment Order, nor did it arise from the Special Counselas investigation. The Special
Counselas investigation and indictment resulted from a violation of numerous DOJ policies and
procedures and otherwise far exceeds any lawful authority to investigate links between
individuals associated with the Trump campaign and the Russian government.
42.

Again pursuing conduct with no relationship to the 2016 election, or collusion

with Russians, in July 2017, Mr. Mueller applied for, obtained, and caused to be executed a
search warrant of Mr. Manafortas home in Alexandria, Virginia. The Special Counsel justified
that search by asserting that the Appointment Order grants him jurisdiction and authority to
obtain materials that purportedly evidence potential criminal tax and white-collar crimes

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committed on or after January 1, 2006. In August 2017, Mr. Mueller issued more than one
hundred subpoenas related to Mr. Manafort, requesting records dating back to January 1, 2005.
43.

Prosecutors in Mr. Muelleras office have admitted that the Special Counselas

investigation of Mr. Manafort concerns conduct that has nothing to do with the charges in the
Appointment Orderas original jurisdiction clause. On August 3, 2017, a lead prosecutor in Mr.
Muelleras office represented to then-counsel for Mr. Manafort that the Special Counsel was
authorized to prosecute Mr. Manafort for crimes committed during the tax year 2010afive years
before Mr. Trump launched his campaign on June 16, 2015.
44.

On September 12, 2017, undersigned counsel for Mr. Manafort sent a letter to Mr.

Rosenstein requesting that he confirm or deny that, prior to July 26, 2017, he granted Mr.
Mueller additional jurisdiction to investigate Mr. Manafort for potential tax crimes and other
white-collar criminal offenses dating back to January 1, 2006, and that prior to August 3, 2017,
he authorized Mr. Mueller to prosecute Mr. Manafort for tax crimes related to the 2010 tax year.
Mr. Rosenstein has not responded; nor has anyone else from his office.
Mr. Manafortas Indictment
45.

On October 27, 2017, Mr. Mueller signed an indictment, attached hereto as

Exhibit B, charging Mr. Manafort and a business associate with several offenses pertaining to
business dealings that, with limited exceptions, predate Mr. Trumpas campaign.
46.

The indictment charged Mr. Manafort with the following offenses, many of which

began nearly a decade before the Trump campaign launched:
i*

one count of conspiracy against the United States between 2006 and 2017;

i*

one count of conspiracy to launder money between 2006 and 2016;

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i*

four counts of failure to file reports of foreign bank and financial accounts for
calendar years 2011-2014;

i*

one count of being an unregistered agent of a foreign principal (i.e., athe
Government of Ukraine, the Party of Regions, and Yanukovycha) between 2008
and 2014;

i*

one count of making a false and misleading Foreign Agents Registration Act
statement in 2016 and 2017 in a document furnished to the Attorney General; and

i*
47.

one count of making a false statement in 2016 and 2017.
The indictment centers on an alleged scheme that began in 2006 when Mr.

Manafort and a business associate started a company that engaged principally in political
consulting and lobbying work on behalf of foreign clients, including the Government of Ukraine.
According to the indictment, Mr. Manafort wired sums of money from offshore accounts into the
United States, failed to report that money as income from his business, and failed to pay taxes on
that money. Those allegations have nothing to do with the 2016 presidential election or any
alleged collusion with Russian officials.
48.

The indictment also alleged that from 2006 until 2014, Mr. Manafort and his

company engaged in a lucrative lobbying campaign in the United States at the direction of the
Government of Ukraine, a Ukrainian political party, and Mr. Yanukovych, without registering
that they had acted as agents of those entities, as required by law. That charge likewise has
nothing to do with the 2016 presidential campaign or alleged collusion with Russian officials.
49.

To date, Mr. Manafort has suffered economic injury, reputational harm, and

invasion of his privacyaincluding unconsented entry into his homeaas a result of those ultra
vires acts. Mr. Manafort has also been forced to expend substantial sums of money defending

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against the investigation and indictment.

Those harms will continue unabated unless Mr.

Manafort obtains the relief requested herein.
COUNT ONE
(Ultra Vires Appointment Order
Against DOJ and Mr. Rosenstein Only)
50.

Plaintiff re-alleges the allegations set forth in paragraphs 1-49 above as if fully set

forth herein.
51.

This action challenges the Appointment Order Mr. Rosenstein issued in his

capacity as Acting Attorney General. The issuance of that order constitutes final agency action
that is reviewable under the APA.
52.

The Appointment Order exceeds the Deputy Attorney Generalas authority under

DOJas special counsel regulations. Specifically, DOJ and Acting Attorney General Rod J.
Rosenstein exceeded the authority provided by 28 C.F.R. ASS 600.4 by purporting to give Special
Counsel Robert S. Mueller III original jurisdiction to address any new matters that come to his
attention during the course of the investigation, without consulting or obtaining approval from
the Attorney General or Acting Attorney General. The Appointment Order is thus arbitrary and
capricious, an abuse of discretion, and otherwise not in accordance with law. It must be set aside
under the APA.
53.

Because the Appointment Order itself exceeds the DOJas authority, insofar as it

purports to authorize an investigation beyond links between the Trump campaign and the
Russian government, all actions taken pursuant to the authority it purports to grant the Special
Counsel are likewise ultra vires and must be set aside.
54.

This action satisfies all procedural requirements for an APA claim.

55.

DOJ constitutes an aagencya whose actions are reviewable under the APA.

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56.

The Appointment Order constitutes afinal agency actiona that is subject to judicial

review because it is a final order through which Mr. Rosenstein consummated his selection and
appointment of Mr. Mueller as Special Counsel and in which he fully set out the Special
Counselas jurisdiction.
57.

Other than the relief requested, there is no adequate remedy in a court for the

harm caused Mr. Manafort by the ultra vires Appointment Order.
58.

Mr. Manafort is aadversely affected or aggrieveda and damaged in his legal rights

by the Appointment Order because it subjects him to an ultra vires exercise of authority and has
caused him to suffer significant reputational harm, financial expense, and invasion of his
personal privacy.
59.

As a target of the ultra vires investigation, Mr. Manafort is within the zone of

interests protected by the special counsel regulations and the relevant statutory provisions
governing DOJ.
COUNT TWO
(Conduct Beyond Original Jurisdiction
Against Mr. Mueller Only)
60.

Plaintiff re-alleges the allegations set forth in paragraphs 1-59 above as if fully set

forth herein.
61.

This action challenges the conduct of Mr. Mueller as beyond his jurisdiction

under the Appointment Order. The actions of the Special Counsel are reviewable under the
Declaratory Judgment Act and under the long-recognized authority of the federal courts to grant
equitable relief to prevent injurious acts by public officers.
62.

The Appointment Order purports to give Mr. Mueller jurisdiction over conduct

unrelated to and predating the Trump campaign if it aarose . . . directly from the investigationa

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into alinks and/or coordination between the Russian government and individuals associated with
the [Trump] campaign.a
63.

Even if that grant of authority were lawful, Mr. Muelleras investigation and the

resulting indictment exceed it. The indictment raises stale allegations DOJ must have been
aware of for nearly a decade; they are not matters that aarose . . . from the investigationa into the
2016 election and alleged collusion with the Russian government. By ignoring the boundaries of
the jurisdiction granted to the Special Counsel in the Appointment Order, Mr. Mueller acted
beyond the scope of his authority. Mr. Muelleras actions must be set aside.
64.

For the same reasons, Mr. Mueller should be enjoined from further investigating

any alleged conduct by Mr. Manafort that is unrelated to and predates his involvement with the
Trump campaign, as well as any conduct that does not arise directly from the limited
investigation authorized by the original jurisdiction clause of the Appointment Order.
65.

Mr. Manafort has been injured by Mr. Muelleras actions in excess of the

jurisdiction conferred by the Appointment Order, which have caused him significant reputational
harm, have exposed him to invasions of his personal privacy, and have forced him to incur
substantial costs and expenses to defend himself.
66.

Other than the relief requested, there is no adequate remedy at law for the harm

caused Mr. Manafort by the Special Counselas ultra vires conduct.
67.

For the reasons set forth above, Mr. Manafort should be awarded injunctive relief

should he prevail on the merits:

He has suffered irreparable injury, remedies at law are

inadequate to compensate for that injury, the balance of hardships warrants injunctive relief, and
the public interest would not be disserved by a permanent injunction.

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PRAYER FOR RELIEF
WHEREFORE, judgment should be entered in favor of Plaintiff and against Defendants,
jointly and severally, and the Court should grant the following relief:
a.

an order and judgment setting aside the Appointment Order and declaring it
invalid, arbitrary and capricious, an abuse of discretion, and otherwise not in
accordance with law;

b.

an order and judgment declaring ultra vires and setting aside all actions taken
against Mr. Manafort pursuant to the Appointment Order;

c.

an order and judgment declaring that Mr. Mueller lacks authority to investigate
business dealings not arising from the original jurisdiction set out in the
Appointment Order;

d.

an order and judgment enjoining Mr. Mueller from investigating matters beyond
the scope of the grant of jurisdiction in the Appointment Order; and

e.

any other relief as may be just and proper.

Dated: January 3, 2018

Respectfully submitted,
/s/ Kevin M. Downing
Kevin M. Downing
(D.C. Bar #1013894)
815 Connecticut Ave., N.W.,
Suite 730
Washington, D.C. 20006
Thomas E. Zehnle
(D.C. Bar #415556)
Frank P. Cihlar
(D.C. Bar #102459)

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Exhibit A

Case 1:18-cv-00011 Document 1-1 Filed 01/03/18 Page 2 of 2

(A(c)ffice of tqe g}cput J iortte}:J A(r)eneral
l!lu.sl1ington, .<!!. 20530
ORDER NO. 3915-2017
APPOINTMENT OF SPECIAL COUNSEL
TO INVESTIGATE RUSSIAN INTERFERENCE WITH THE
2016 PRESIDENTIAL ELECTION AND RELATED MATTERS
By virtue of the authority vested in me as Acting Attorney General, including 28 U.S.C.
ASSASS 509, 510, and 515, in order to discharge my responsibility to provide supervision and
management of the Department of Justice, and to ensure a full and thorough investigation of the
Russian govemmenfs efforts to interfere in the 2016 presidential election, I hereby order as
follows:
(a)

Robert S. Mueller III is appointed t() serve as Specia] Counsel for the United States

Department of Justice.
(b)

The Special Counsel is authorized to conduct the investigation confinned by then-FBI

Director James 8. Corney in testimony before the House Permanent Select Committee on
Intelligence on March 20, 2017, including:
(i)

any links and/or coordination bet ween the Russian government and individuals
associated with the campaign of President Donald Trump; and

(c)

(ii)

any matters that arose or may arise directly from the investigation; and

(iii)

any other matters within the scope of 28 C.F.R. ASS 600.4(a).

If the Special Counsel believes it is necessary and appropriate, the Special Counsel is

authorized to prosecute federal crimes arising from the investigation of these matters.
(d)

Sections 600.4 through 600. l 0 of Title 28 of the Code of Federal Regulations are

applicable to the Special Counsel.

Date '
1

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 1 of 32

Exhibit

Case 1:18-cv-0001l Document 1-2 Filed 01/03/18 Page 2 of 32

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA
CRIMINAL N0.
4:
v. (18 U.S.C. 2, 371, 982,
and 3551 elm; 22
PAUL J. MANAFORT, JR. and U.S.C. 612(a), 618(a)(1), and
RICHARD W. GATES 618(a)(2); 28 U.S.C. 2461(0); 31 U.S.C.
5314 and 5322(b))
Defendants.

INDICTMENT

The Grand Jury for the District of Columbia charges:

ase: 1:17?cr?00201
issigned To Judge Jackson, Amy Berman

MM Assign. Date: 10/27/2017

At all times relevant to this Indictment:

Description: INDICTMENT (B)

l. Defendants PAUL J. MANAFORT, JR, (MANAFORT) and RICHARD W. GATES Ill

(GATES) served for years as political consultants and lobbyists. Between at least 2006 and 2015,

and GATES acted as unregistered agents of the Government of Ukraine, the Party

of Regions (a Ukrainian political party whose leader Victor Yanukovych was President from 2010

to 2014), Yanukovych, and the Opposition Bloc (a successor to the Party of Regions that formed

in 2014 when Yanukovych ?ed to Russia). MANAFORT and GATES generated tens ofmillions

of dollars in income as a result of their Ukraine work. In order to hide Ukraine payments from

United States authorities, from approximately 2006 through at least 2016, and

GATES laundered the money through scores of United States and foreign corporations,

partnerships, and bank accounts.

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 3 of 32

2. In furtherance of the scheme, MANAFORT and GATES funneled millions of dollars in
payments into foreign nominee companies and bank accounts, opened by them and their
accomplices in nominee names and in various foreign countries, including Cyprus, Saint Vincent
the Grenadines (Grenadines), and the Seychelles. MANAFORT and GATES hid the existence
of the foreign companies and bank accounts, falsely and repeatedly reporting to their tax preparers
and to the United States that they had no foreign bank accounts.

3. In furtherance of the scheme, MANAFORT and GATES concealed from the United States
their work as agents of, and millions of dollars in payments from, Ukraine and its political parties
and leaders. Because MANAFORT and GATES, among other things, directed a campaign to
lobby United States officials on behalf of the Government of Ukraine, the President of Ukraine,
and Ukrainian political patties, they were required by law to report to the United States their work
and fees. MANAFORT and GATES did not do so. Instead, when the Department of Justice sent
inquiries to MANAFORT and GATES in 2016 about their activities, MANAFORT and GATES
responded with a series of false and misleading statements.

4. In furtherance of the scheme, MANAFORT used his hidden overseas wealth to enjoy a
lavish lifestyle in the United States, without paying taxes on that income. MANAFORT, without
reporting the income to his tax preparer or the United States, spent millions of dollars on luxury
goods and services for himself and his extended family through payments wired from offshore
nominee accounts to United States vendors. MANAFORT also used these offshore accounts to
purchase multi-million dollar properties in the United States. MANAFORT then borrowed
millions of dollars in loans using these properties as collateral, thereby obtaining cash in the United
States without reporting and paying taxes on the income. In order to increase the amount of money
he could access in the United States, MANAFORT defrauded the institutions that loaned money

2

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 4 of 32

on these properties so that they would lend him more money at more favorable rates than he would
otherwise be able to obtain.
5. GATES aided MANAFORT in obtaining money from these offshore accounts, which he
was instrumental in opening. Like MANAFORT, GATES used money from these offshore
accounts to pay for his personal expenses, including his mortgage, children?s tuition, and interior
decorating of his Virginia residence.
6. In total, more than $75,000,000 flowed through the offshore accounts. MANAFORT
laundered more than $18,000,000, which was used by him to buy property, goods, and services in
the United States, income that he concealed from the United States Treasury, the Department of
Justice, and others. GATES transferred more than $3,000,000 from the offshore accounts to other
accounts that he controlled.

Relevant Individuals And Entities
7. MANAFORT was a United States citizen. He resided in homes in Virginia, Florida, and
Long Island, New York.
8. GATES was a United States citizen. He resided in Virginia.
9. In 2005, MANAFORT and another partner created Davis Manafort Partners, Inc. (DMP) to
engage principally in political consulting. DMP had staff in the United States, Ukraine, and
Russia. In 2011, MANAFORT created DMP International, LLC (DMI) to engage in work for
foreign clients, in particular political consulting, lobbying, and public relations for the Government
of Ukraine, the Party of Regions, and members of the Party of Regions. DMI was a partnership
solely owned by MANAFORT and his spouse. GATES worked for both DMP and DMI and
served as right-hand man.
10. The Party of Regions was a pro-Russia political party in Ukraine. Beginning in

3

Case DoCument 1-2 Filed 01/03/18 Page 5 of 32

approximately 2006, it retained MANAFORT, through DMP and then DMI, to advance its
interests in Ukraine, including the election of its slate of candidates. In 2010, its candidate for
President, Yanukovych, was elected President of Ukraine. In 2014, Yanukovych fled Ukraine for
. Russia in the wake of popular protests of widespread governmental corruption. Yanukovych, the
Party of Regions, and the Government of Ukraine were MANAFORT, DMP, and DMI clients.
11. The European Centre for a Modern Ukraine (the Centre) was created in or about 2012 in
Belgium as a mouthpiece for Yanukovych and the Party of Regions. The Centre was used by
MANAFORT, GATES, and others in order to lobby and conduct a public relations campaign in
the United States and Europe on behalf of the existing Ukraine regime. The Centre effectively
ceased to operate upon the downfall of Yanukovych in 2014.

12. MANAFORT and GATES owned or controlled the following entities, which were used in

the scheme (the entities):

Domestic Entities


Bade LLC (RG) . January 2012 Delaware

August 2008 Virginia
Daisy Manafort, LLC (PM)

March 2011 Florida
Davis Manafort International LLC March 2007 Delaware
(PM)

March 2005 Virginia
DMP (PM)

March 201 1 Florida

October 1999 Delaware
Davis Manafort, Inc. (PM)

November 1999 Virginia

4

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 6 of 32

June 2011 Delaware
DMI (PM)

March 2012 Florida
Global Sites LLC (PM, RG) July 2008 Delaware
emina LLC (RG) July 2008 Delaware
esand Investment Corporation (PM) April 2002 Virginia
esand Investments Corporation (PM) March 2011 Florida

- April 2006 Virginia

John Hannah, LLC (PM)

. March 201 1 Florida
Jupiter Holdings Management, LLC January 2011 Delaware
(RG)

Lilred, LLC (PM) December 2011 Florida
LOAV Ltd. (PM) April 1992 Delaware
MC Brooklyn Holdings, LLC (PM) November 2012 New York
January 2012 Florida
MC Soho Holdings, LLC (PM)
April 2012 New York
LLC (also known as July 2008 Delaware

LLC) (PM, RG)

Cypriot Entities

Entity Name Date Created Incorporation Location
Actinet Trading Limited (PM, RG) May 2009 Cyprus
Black Sea View Limited (PM, RG) August 2007 Cyprus

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 7 of 32

Entity Name Date Created Incorporation Location
Bletilla Ventures Limited (PM, RG) October 2010 Cyprus
Cavenari Investments Limited (RG) December 2007 Cyprus
Global Highway Limited (PM, RG) August 2007 Cyprus
Leviathan Advisers Limited (PM, RG) August 2007 Cyprus
LOAV Advisers Limited (PM, RG) August 2007 Cyprus
Lucicle Consultants Limited (PM, RG) December 2008 Cyprus
Marziola Holdings Limited (PM) March 2012 Cyprus
Olivenia Trading Limited (PM, RG) March 2012 Cyprus
Peranova Holdings Limited (PM, RG) June 2007 Cyprus
Serangon Holdings Limited (PM, RG) January 2008 Cyprus
Other Foreign Entities
Entity Name Date Created Incorporation Location
Global Endeavour Inc. (also known as Unknown Grenadines
Global Endeavor Inc.) (PM)
eunet Ltd. (PM) August 2011 Grenadines
Pompolo Limited (RG) April 2013 United Kingdom

13. The Internal Revenue Service (IRS) was a bureau in the United States Department of the

I Treasury responsible for administering the tax laws of the United States and collecting taxes owed

to the Treasury.

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 8 of 32

The Scheme
14. Between in or around 2008 and 2017, both dates being approximate and inclusive, in the
District of Columbia and elsewhere, MANAFORT and GATES devised and intended to devise,
and executed and attempted to execute, a scheme and arti?ce to defraud, and to obtain money and
property by means of false and fraudulent pretenses, representations, and promises from the United
States, banks, and other ?nancial institutions. As part of the scheme, MANAFORT and GATES
repeatedly provided false information to ?nancial bookkeepers, tax accountants, and legal counsel,

among others.

MANAFORT And Wiring Of Money From Offshore Accounts Into The United States
15. In order to use the money in the offshore nominee accounts of the
entities without paying taxes on it, MANAFORT and GATES caused millions of dollars in wire
transfers from these accounts to be made for goods, services, and real estate. They did not report
these transfers as income to DMP, DMI, or MANAFORT.

16. From 2008 to 2014, MANAFORT caused the following wires, totaling over $12,000,000,
to be sent to the vendors listed below for personal items. MANAFORT did not pay taxes on this

income, which was used to make the purchases.

Payee I'lgmatmgAccount I of Amount 1-. Holder Origination Transaction
Vendor A 6/10/2008 LOAV Advisers Limited Cyprus $107,000
(Home 6/25/2008 LOAV Advisers Limited Cyprus $23,500
Improvement 7/7/2008 LOAV Advisors Limited Cyprus $20,000
Company in the 8/5/2008 Yiakora Ventures Limited - Cyprus $59,000
Hamptons, New 9/2/2008 Yiakora Ventures Limited Cyprus $272,000
York) 10/6/2008 Yiakora Ventures Limited Cyprus $109,000

7

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 9 of 32

Payee Originating Account Country .Of . Amountof133'Dat "-z?Holder . 1. -. . . Origination Transaction
1 0/ 24/ 2008 Yiakora Ventures Limited Cyprus $107,800
11/20/2008 Yiakera Ventures Limited Cyprus $77,400
1 2/ 22/ 200 8 Yiakora Ventures Limited Cyprus 1 00,000
1/14/2009 Yiakora Ventures Limited Cyprus $9,250
1/29/2009 Yiakera Ventures Limited Cyprus $97,670
2/25/2009 Yiakora Ventures Limited Cyprus $108,100
4/ 16/2009 Yiakera Ventures Limited Cyprus $94,394
5/7/2009 Yiakora Ventures Limited Cyprus $54,000
5/12/2009 Yiakora Ventures Limited Cyprus $9,550
6/1/2009 Yiakora Ventures Limited Cyprus $86,650
6/18/2009 Yiakera Ventures Limited Cyprus $34,400
7/31/2009 Yiakora Ventures Limited Cyprus $106,000
8/28/2009 Yiakera Ventures Limited Cyprus $37,000
9/23/2009 Yiakera Ventures Limited Cyprus $203,500
1 0/ 26/ 2009 Yiakora Ventures Limited Cyprus $3 8,800
1 1/18/2009 Global Highway Limited Cyprus $130,906
3/8/2010 Global Highway Limited Cyprus $124,000
5/1 1/2010 Global Highway Limited Cyprus $25,000
7/8/2010 Global Highway Limited Cyprus $28,000
7/23/2010 Leviathan Advisers Limited Cyprus $26,500
8/ 12/2010 Leviathan Advisers Limited Cyprus $138,900
9/2/2010 Yiakora Ventures Limited Cyprus $31,500
10/6/2010 Global Highway Limited Cyprus $67,600
10/14/2010 Yiakera Ventures Limited Cyprus $107,600
10/18/2010 Leviathan Advisers Limited Cyprus $3 1,500
12/16/2010 Global Highway Limited Cyprus $46,160
2/7/2011 Global Highway Limited Cyprus $36,500
3/22/2011 Leviathan Advisers Limited Cyprus $26,800
4/ 4/ 201 1 Leviathan Advisers Limited Cyprus $195 ,000
5/3/2011 Global Highway Limited Cyprus $95,000
5/16/2011 Leviathan Advisers Limited Cyprus $6,500
5/31/2011 Leviathan Advisers Limited Cyprus $70,000
6/27/2011 Leviathan Advisers Limited Cyprus $39,900
7/27/2011 Leviathan Advisers Limited Cyprus $95,000
10/ 24/ 201 1 Global Highway Limited Cyprus $22,000
10/25/201 1 Global Highway Limited Cyprus $9,300
1 1/ 15/201 1 Global Highway Limited Cyprus $74,000
11/23/201 1 Global Highway Limited Cyprus $22,3 00

8

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 10 of 32


Payee - . Transact 11 Originating Account Country of: Amountof
.. Date HOIder .- - Transaction
1 1/29/201 1 Global Highway Limited Cyprus $6,100
12/12/201 1 Leviathan Advisors Limited Cyprus $17,800
1/17/2012 Global Highway Limited Cyprus $29,800
1/20/2012 Global Highway Limited Cyprus $42,600
2/9/2012 Global Highway Limited Cyprus $22,300
2/23/2012 Global Highway Limited Cyprus $75,000
2/28/2012 Global Highway Limited Cyprus $22,300
3/28/2012 Peranova Holdings Limited Cyprus $37,500
4/18/2012 Lucicle Consultants Limited Cyprus $50,000
5/15/2012 Lucicle Consultants Limited Cyprus $79,000
6/5/2012 Lucicle Consultants Limited Cyprus $45,000
6/19/2012 Lucicle Consultants Limited Cyprus $1 1,860
7/ 9/ 201 2 Lucicle Consultants Limited Cyprus 1 0, 800
7/ 18/2012 Lucicle Consultants Limited Cyprus $88,000
8/7/2012 Lucicle Consultants Limited Cyprus $48,800
9/27/2012 Lucicle Consultants Limited Cyprus $100,000
11/20/2012 Lucicle Consultants Limited Cyprus $298,000
12/20/2012 Lucicle Consultants Limited Cyprus $55,000
1/29/2013 Lucicle Consultants Limited Cyprus $149,000
3/12/2013 Lucicle Consultants Limited Cyprus $375,000
8/29/2013 Global Endeavour Inc. Grenadines $200,000
1 1/13/2013 Global Endeavour Inc. Grenadines $75,000
11/26/2013 Global Endeavour Inc. Grenadines $80,000
12/ 6/ 201 3 Global Endeavour Inc. Grenadines - $1 3 0,000
12/12/2013 Global Endeavour Inc. Grenadines $90,000
4/22/2014 Unknown Unknown $56,293
8/18/2014 Global Endeavour Inc. Grenadines $34,660
Vendor A Total $5,434,793
Vendor 3/22/201 1 Leviathan Advisors Limited Cyprus $12,000
(Home 3/28/2011 Leviathan Advisors Limited Cyprus $25,000
Automation, . 4/27/201 1 Leviathan Advisers Limited Cyprus $12,000
Lighting and 5/16/201 1 Leviathan Advisors Limited Cyprus $25,000
Home . 1 1/ 15/201 1 Global Highway Limited Cyprus $17,006
Entertalmtem 1 1/23/201 1 Global Highway Limited Cyprus $1 1,000
Ef?gy 1? 2/28/2012 Global Highway Limited Cyprus $6,200
10/31/2012 Lucicle Consultants Limited Cyprus $290,000
12/17/2012 Lucicle Consultants Limited Cyprus $160,600
1/15/2013 Lucicle Consultants Limited Cyprus $194,000

9

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 11 of 32


payee . i I lnatmgAccount Country/0f. Amount of
- . .. -. . '22? EOriginatien Transaction .-
1/24/2013 Lucicle Consultants Limited Cyprus $6,300
2/12/2013 Luciole Consultants Limited Cyprus $51,600
2/26/2013 Lueiole Consultants Limited Cyprus $260,000
7/15/2013 Pompolo Limited U?fnted $175,575
Kingdom
1 1/5/2013 Global Endeavour Inc. Grenadines $73,000
Vendor Total $1,319,281
Vendor 10/7/2008 Yiakora Ventures Limited Cyprus $15,750
(Antique Rug 3/ 17/2009 Yiakora Ventures Limited Cyprus $46,200
Store in 4/16/2009 Yiakora Ventures Limited Cyprus $7,400
Alexandria, 4/27/2009 Yiakora Ventures Limited Cyprus $65,000
V1rgm1a) 5/7/2009 Yiakora Ventures Limited Cyprus $210,000
7/15/2009 Yiakora Ventures Limited Cyprus $200,000
3/3 1/2010 Yiakora Ventures Limited Cyprus $140,000
6/16/2010 Global Highway Limited Cyprus $250,000
Vendor Total $934,350
Vendor
(Related to 2/ 2 8/201 2 Global Highway Limited Cyprus $100,000
Vendor C)
Vendor Total $100,000
Vendor 11/7/2008 Yiakora Ventures Limited Cyprus $32,000
(Men?s Clothing 2/5/2009 Yiakora Ventures Limited Cyprus $22,750
Store in New 4/27/2009 Yiakora Ventures Limited Cyprus $13,500
York) 10/26/2009 Yiakora Ventures Limited Cyprus $32,500
3/3 0/201 0 Yiakora Ventures Limited Cyprus $15,000
5/11/2010 Global Highway Limited Cyprus $39,000
6/28/2010 Leviathan Advisers Limited Cyprus $5,000
8/12/2010 Leviathan Advisers Limited Cyprus $32,500
11/17/2010 Global Highway Limited Cyprus $1 1,500
2/7/2011 Global Highway Limited Cyprus $24,000
3/22/2011 Leviathan Advisers Limited Cyprus $43,600
3/28/2011 Leviathan Advisers Limited Cyprus $12,000
4/27/2011 Leviathan Advisers Limited Cyprus $3,000
6/3 0/2011 Global Highway Limited Cyprus $24,500 -
9/26/2011 Leviathan Advisers Limited Cyprus $12,000
11/2/2011 Global Highway Limited Cyprus $26,700
12/12/2011 Leviathan Advisers Limited Cyprus $46,000
2/9/2012 Global Highway Limited Cyprus $2,800

10

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page -Holderr Origination Transaction
2/28/2012 Global Highway Limited Cyprus $16,000

3/ 14/2012 Lueiele Consultants Limited Cyprus $8,000

4/18/2012 Lueicle Consultants Limited Cyprus $48,550

5/ 15/2012 Lucicle Consultants Limited Cyprus $7,000

6/ 1 9/201 2 Lucicle Consultants Limited Cyprus $2 1 ,6 00

8/7/2012 Lucicle Consultants Limited Cyprus $15,500

1 1/ 20/ 201 2 Luoicle Consultants Limited Cyprus $10,900

12/20/2012 Lucicle Consultants Limited Cyprus $7,500

1/15/2013 Luciele Consultants Limited Cyprus $3 7,000

2/12/2013 Luciele Consultants Limited Cyprus $7,000

2/26/2013 Lucicle Consultants Limited Cyprus $39,000

9/3/2013 Global Endeavour Ino. Grenadines $81,500

10/ 15/201 3 Global Endeavour Inc. Grenadines $5 3 ,000

1 1/2 6/201 3 Global Endeavour Inc. Grenadines 1 3 ,200

4/24/2014 Global Endeavour Ine. Unknown $26,680

9/ 1 1/2014 Global Endeavour Inc. Grenadines $5 8 ,43 5

Vendor Total $849,215

Vendor 4/27/2009 Yiakora Ventures Limited Cyprus $34,000
(Landscaper in 5/12/2009 Yiakora Ventures Limited Cyprus $45,700
the Hamptons, 6/1/2009 Yiakora Ventures Limited Cyprus $21,500
New York) 6/18/2009 Yiakora Ventures Limited Cyprus $29,000
9/ 2 1/ 2009 Yiakera Ventures Limited Cyprus $21,800

5/1 1/2010 Global Highway Limited Cyprus $44,000

6/28/2010 Leviathan Advisers Limited Cyprus $50,000

7/23/2010 Leviathan Advisers Limited Cyprus $19,000

9/ 2/ 201 0 Yiakora Ventures Limited Cyprus $21,000

1 0/ 6/ 201 0 Global Highway Limited Cyprus $57,700

10/18/2010 Leviathan Advisers Limited Cyprus $26,000

12/16/2010 Global Highway Limited Cyprus $20,000

3/22/2011 Leviathan Advisers Limited Cyprus ?ss 0,000

5/3/2011 Global Highway Limited Cyprus $40,000

6/1/201 1 Leviathan Advisers Limited Cyprus $44,000

7/27/2011 Leviathan Advisers Limited Cyprus $27,000

8/16/201 1 Leviathan Advisers Limited Cyprus $13,450

9/ 1 9/ 201 1 Leviathan Advisers Limited Cyprus $12,000

10/24/201 1 Global Highway Limited Cyprus $42,000

I 1 1/2/201 1 Global Highway Limited Cyprus $37,350

Vendor Total $655,500

ll

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 13 of 32

Payee, i I. i" Trans on Originating Account Country of Amountof

. Date - Holder Origination Transaction
Vendor 9/2/2010 Yiakera Ventures Limited Cyprus $165,000
(Antique Dealer 10/18/2010 Leviathan Advisers Limited Cyprus $165,000
in New York) 2/28/2012 Global Highway Limited Cyprus $190,600
3/14/2012 Luciole Consultants Limited Cyprus $75,000

2/26/2013 Lueicle Consultants Limited Cyprus $28,310

Vendor Total $623,919

Vendor 6/25/2008 LOAV Advisers Limited Cyprus $52,000
(Clothing 510113 in 12/ 16/2008 Yiakera Ventures Limited Cyprus $49,000
Beverly Hills, 12/22/2008 Yiakera Ventures Limited Cyprus $10,260
California) 8/ 12/2009 Yiakera Ventures Limited Cyprus $76,400
5/11/2010 Global Highway Limited Cyprus $85,000

1 1/17/2010 Global Highway Limited Cyprus $128,280

5/31/2011 Leviathan Advisers Limited Cyprus $64,000

11/15/201 1 Global Highway Limited Cyprus $48,000

12/ 17/2012 Lueiele Consultants Limited Cyprus $7,500

Vendor Total $520,440

Vendor I
(Investment 9/3/2013 Global Endeavour Inc. Grenadines $500,000
Company)

Vendor I Total $500,000

Vendor 11/15/201 1 Global Highway Limited Cyprus $8,000
(Contractor in 12/ 5/ 201 1 Leviathan Advisers Limited Cyprus $1 1,237
Florida) 12/21/2011 Black Sea View Limited Cyprus $20,000
2/9/2012 Global Highway Limited - Cyprus $51,000

5/ 17/2012 Lueicle Consultants Limited Cyprus $68,000

6/19/2012 Lucicle Consultants Limited Cyprus $60,000

7/18/2012 Lucicle Consultants Limited Cyprus $32,250

9/19/2012 Lucicle Consultants Limited Cyprus $112,000

11/ 3 0/2012 Lueiele Consultants Limited Cyprus $39,700

1/9/2013 Lucicle Consultants Limited Cyprus $25,600

2/28/2013 Lueicle Consultants Limited Cyprus $4,700

Vendor Total $432,487

Vendor 12/5/2011 Leviathan Advisers Limited Cyprus $4,115
(Landscaper in 3/1/2012 Global Highway Limited Cyprus $50,000
the Hamptons, 6/6/2012 Lueiele Consultants Limited Cyprus $47,800
New York) 6/25/2012 Lueiole Consultants Limited Cyprus $17,900
6/27/2012 Lucicle Consultants Limited Cyprus $18,900

l2

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 14 of 32

.- - Date Holder Origination Transaction
2/12/2013 Lucicle Consultants Limited Cyprus $3,300
7/15/2013 Pompolo Limited Uimed $13,325
Kingdom
11/26/2013 Global Endeavour Inc. Grenadines $9,400
Vendor Total $164,740
Vendor 4/12/2012 Luciele Consultants Limited Cyprus $83,525
(Payments 5/2/2012 Luciele Consultants Limited Cyprus $12,525
Relating to three . . .
Range Rovers) 6/29/2012 Luoicle Consultants Limited Cyprus $67,655
Vendor Total $163,705
Vendor 11/20/2012 Lucicle Consultants Limited Cyprus $45,000
(Contractor in 12/7/2012 Lucicle Consultants Limited Cyprus $21,000
Virginia) 12/17/2012 Luciole Consultants Limited Cyprus $21,000
1/ 17/2013 Lucicle Consultants Limited Cyprus $18,750
1/29/2013 Lucicle Consultants Limited Cyprus $9,400
2/12/2013 Lucicle Consultants Limited Cyprus $10,500
Vendor Total $125,650
Vendor 1/29/2009 Yiakora Ventures Limited Cyprus $10,000
(Audio, Video, 3/17/2009 Yiakora Ventures Limited Cyprus $21,725
311d Control 4/16/2009 Yiakora Ventures Limited Cyprus $24,650
System Home 12/2/2009 Global Highway Limited Cyprus $10,000
Integration and 3/3/2010 Global Highway Limited Cyprus $20,300
Installation 4/23/2010 Yiakora Ventures Limited Cyprus $8,5 00
Company in the
New 7/29/2010 Leviathan Advisors Limited Cyprus $17,650
Vendor Total $112,825
Vendor 0
(Purchase of 10/5/2012 Lucicle Consultants Limited Cyprus $62,750
Mercedes Benz)
. Vendor 0 Total $62,750
Vendor
(Purchase of 12/30/2008 Yiakora Ventures Limited Cyprus $47,000
Range Rover)
Vendor Total $47,000
Vendor 9/2/2010 Yiakora Ventures Limited Cyprus $10,000
10/6/2010 Global Highway Limited Cyprus $10,000

13

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 15 of 32

Payee Trans-actions: .. Originating Account Country of Amount of
Date Holder Origination Transaction
(Property 10/18/2010 Leviathan Advisors Limited Cyprus $10,000
Management 2/8/2011 Global Highway Limited Cyprus $13,500
Company in
South Carolina) 2/9/2012 Global Highway Limited Cyprus $2,500
Vendor Total $46,000
Vendor 2/9/2011 Global Highway Limited Cyprus $17,900
(Art Gallery in
Florida) 2/ 14/2013 Luelcle Consultants Cyprus $14,000
Vendor Total $31,900
Vendor 9/26/2011 Leviathan Advisors Limited Cyprus $5,000
(Housekeeping in 9/ 19/2012 Lucicle Consultants Limited Cyprus $5,000
New York)
10/9/2013 Global Endeavour Inc. Grenadines $10,000
Vendor Total $20,000
17. In 2012, MANAFORT caused the following Wires to be sent to the entities listed below to

purchase the real estate also listed below. MANAFORT did not report the money used to make

these purchases on his 2012 tax return.

Property Originating Country of
Purchased Payee Date Account Origin Amount
Howard Street DMP Peranova Holdin
Condominium International 2/1/2012 Limited Cyprus $1,5 00,000
(New York) LLC .
. Attorney Aetinet Trading
:1:ng; 33:: Account 0 11/29/2012 Limited Cyprus $1,800,000
. [Real Estate Actinet Trading
(New York) Attorney] 11/29/2012 Limited Cyprus $1,200,000
Arlington Real Estate Lucicle Consultants
House 8/31/2012 . . Cyprus $1,900,000
. . . Trust anted
(V 1rg1n1a)

14

Case 1:18-cv-00011 Document 1-2 Filed 01/03/18 Page 16 of 32

MANAFORT And Hiding Of Ukraine Lobbying And Public Relations Work

18. It is illegal to act as an agent of a foreign principal engaged in certain United States in?uence
activities without registering the af?liation. Speci?cally, a person who engages in lobbying or
public relations work in the United States (hereafter collectively referred to as lobbying) for a
foreign principal such as the Government of Ukraine or the Party of Regions is required to provide
a detailed written registration statement to the United States Department of Justice. The ?ling,
made under oath, must disclose the name of the foreign principal, the ?nancial payments to the
lobbyist, and the measures undertaken for the foreign principal, among other information. A
person required to make such a ?ling must further make in all lobbying material a ?conspicuous
statement? that the materials are distributed on behalf of the foreign principal, among other things.
The ?ling thus permits public awareness and evaluation of the activities of a lobbyist who acts as
an agent of a foreign power or foreign political party in the United States.

19. In furtherance of the scheme, from 2006 until 2014, both dates being approirimate and
inclusive, MANAFORT and GATES engaged in a multi~rnillion dollar lobbying campaign in the
United States at the direction of Yanukovych, the Party of Regions, and the Government of
Ukraine. MANAFORT and GATES did so without registering and providing the disclosures
required by law.

20. As part of the scheme, in February 2012, MANAFORT and GATES solicited two
Washington, D.C., ?rms (Company A and Company B) to lobby in the United States on behalf of
Yanukovych, the Party of Regions, and the Government of Ukraine. For instance, GATES wrote
to Company A that it would be ?representing the Government of Ukraine in [Washington,]
21. MANAFORT repeatedly communicated in person and in writing with Yanukovych, and

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GATES passed on directions to Company A and Company B. For instance, MANAFORT wrote
Yanukovych a memorandum dated April 8, 2012, in which he provided Yanukovych an update on
the lobbying firms? activities ?since the inception of the project a few weeks ago. It is my intention
to provide you with a weekly update moving forward.? Toward the end of that first year, in
November 2012, GATES wrote to Company A and Company that the ?rms needed to prepare
an assessment of their past and prospective lobbying efforts so the ?President? could be briefed by
?Paul? ?on what Ukraine has done well and what it can do better as we move into 2013

22. At the direction of MANAFORT and GATES, Company A and Company engaged in
extensive lobbying. Among other things, they lobbied multiple Members of Congress and their
staffs about Ukraine sanctions, the validity of Ukraine elections, and the propriety of
Yanukovych?s imprisoning his presidential rival, Yulia Tymoshenko (who had served as Ukraine
President prior to Yanukovych). MANAFORT and GATES also lobbied in connection with the
roll out of a report concerning the Tymoshenko trial commissioned by the Government of Ukraine.
MANAFORT and GATES used one of their offshore accounts to funnel $4 million to pay secretly
for the report.

23. To minimize public disclosure of their lobbying campaign, MANAFORT and GATES
arranged for the Centre to be the nominal client of Company A and Company B, even though in
fact the Centre was under the ultimate direction of the Government of Ukraine, Yanukovych, and
the Party of Regions. For instance, MANAFORT and GATES selected Company A and Company
B, and only thereafter did the Centre sign contracts with the lobbying ?rms without ever meeting
either company. Company A and Company were paid for their services not by their nominal
client, the Centre, but Solely through off-shore accounts associated with the MANAFORT-GATES
entities, namely Bletilla Ventures Limited (in Cyprus) and Jeunet Ltd. and Global Endeavour Inc.

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(in Grenadines). In total, Company A and Company were paid more than $2 million from these

accounts between 2012 and 2014.

24. To conceal the scheme, MANAFORT and GATES developed a false and misleading cover

story that would distance themselves and the Government of Ukraine, Yanukovych, and the Party

of Regions from the Centre, Company A, and Company B. For instance, in the wake of extensive

press reports on MANAFORT and his connections with Ukraine, on August 16, 2016, GATES

communicated false talking points to Company in writing, including:

Q: ?Can you describe your initial contact with [Company and the lobbying goals
he discussed with them?? A: ?We provided an introduction between the [Centre]
and [Company B/Company in 2012. The [Centre] was seeking to retain
representation in Washington, DC to support the mission of the

A: ?Our and task was to assist the [Centre] find
representation in Washington, but at no time did our ?rm or members provide any
direct lobbying support.?

A: ?The structure of the arrangement between the [Centre] and [Company A and
Company was worked out by the two parties.?

Q: ?Can you say where the funding from for [sic] the [Centre] came from? (this
amounted to well over a million dollars between 2012 and 2014).? A: ?This is a
question better asked of the [Centre] who contracted with the two ?rms.?

Q: ?Can you describe the lobbying work speci?cally undertaken by [Company
on behalf of the Party of Regionsithe [Centre]?? A: ?This is a question better asked
to Company and/ or the [Centre] as the agreement was between the parties. Our

?rm did not play a role in the structure, nor were we registered lobbyists.?

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Company through a principal replied to GATES the same day that ?there?s a lot of email traf?c
that has you much more involved than this suggests[.] We will not disclose that but heaven knows
what former employees of [Company or [Company might say.?

25. In September 2016, after numerous recent press reports concerning MANAFORT, the
Department of Justice informed MANAFORT, GATES, and DM1 that it sought to determine
Whether they had acted as agents of a foreign principal under the Foreign Agents Registration Act
(FARA), without registering. In November 2016 and February 2017, MAN AFORT, GATES, and
DM1 caused false and misleading letters to be submitted to the Department of Justice, which
mirrored the false cover story set out above. The letters, both of which Were approved by
MANAFORT and GATES before they were submitted, represented, among other things, that:

0 ?efforts on behalf of the Party of Regions? ?did not include meetings or
outreach within the

a MANAFORT and GATES did not ?recall meeting with or conducting outreach
to U. S. government of?cials or US. media outlets on behalf of the [Centre], nor
do they recall being party to, arranging, or facilitating any such
communications. Rather, it is the recollection and understanding of Messrs.
Gates and Manafort that such communications would have been facilitated and
conducted by the [Centre?s] U.S. consultants, as directed by the [Centre]. . .

MANAFORT and GATES had merely served as a means of introduction of
Company A and Company to the Centre and provided the Centre with a list
of ?potential U.S.-based consultants?including [Company and [Company
B]?fpr the [Centre?s] reference and further consideration.?

0 DMI ?does not retain communications beyond thirty days? and as a result of

18

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this policy, a ?search has returned no responsive documents.? The November

2016 letter attached a one?page, undated document that purported to be a DMI

?Email Retention Policy.?
26. In fact, MANAFORT and GATES had: selected Company A and Company engaged in
weekly scheduled calls and frequent emails with Company A and Company to provide them
directions as to specific lobbying steps that should be taken; sought and received detailed oral and
written reports from these ?rms on the lobbying work they had performed; communicated with
Yanukovych to brief him on their lobbying efforts; both congratulated and reprimanded Company
A and Company on their lobbying work; communicated directly with United States officials in
connection with this work; and paid the lobbying ?rms over $2 million from offshore accounts
they controlled, among other things. In addition, court?authorized searches of MANAFORT and
DMI email accounts and Virginia residence in July 2017 revealed
numerous documents, including documents related to lobbying, which were more than thirty?days

old at the time of the November 2016 letter to the Department of Justice.

MANAFORT And Hiding Of Foreign Bank Accounts And False Filings

27. United States citizens who have authority over certain foreign bank accounts -- whether or
not the accounts are set up in the names of nominees who act for their principals -- have reporting
obligations to the United States.

28. First, the Bank Secrecy Act and its implementing regulations require United States citizens
to report to the United States Treasury any ?nancial interest in, or signatory authority over, any
bank account or other financial account held in foreign countries, for every calendar year in which

the aggregate balance of all such foreign accounts exceeds $10,000 at any point during the year.

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This is commonly known as a foreign bank account report or The Bank Secrecy Act
requires these reports because they have a high degree of usefulness in criminal, tax, or regulatory
investigations or proceedings. The United States Treasury?s Financial Crimes Enforcement
Network is the custodianlfor FBAR ?lings, and provides access to its BAR
database to law enforcement entities, including the Federal Bureau of Investigation. The reports
?led by individuals and businesses are used by law enforcement to identify, detect, and deter
money laundering that furthers criminal enterprise activity, tax evasion, and other unlawful
activities.

29. Second, United States citizens also are obligated to report information to the IRS regarding
foreign bank accounts. For instance, in 2010 Form 1040, Schedule had a ?Yes? or ?No? box to
record an answer to the question: ?At any time during [the calendar year], did you have an interest
in or a signature or other authority over a ?nancial account in a foreign country, such as a bank
account, securities account, or other ?nancial account?? If the answer was ?Yes,? then the form
required the taxpayer to enter the name of the foreign country in which-the ?nancial account was
located.

30. For each year in or about and between 2008 through at least 2014, MANAFORT had
authority over foreign accounts that required an FBAR report. Speci?cally, MANAFORT was
required to report to the United States Treasury each foreign bank account held by the foreign
MANAFORT-GATES entities noted above in paragraph 12 that bear the initials PM. No FEAR
reports were made by MANAFORT for these accounts.

31. For each year in or about and between 2008 through at least 2013, GATES had authority
over foreign accounts that required an FEAR report. Speci?cally, GATES was required to report
to the United States Treasury each foreign bank account held by the foreign MANAFORT-GATES

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entities noted above in paragraph 12 that bear the initials RG, as well as three other accounts in
the United Kingdom. No FBAR reports were made by GATES for these accounts.

32. Furthermore, in each of tax ?lings for 2008 through 2014, MANAFORT
represented falsely that he did not have authority over any foreign bank accounts. MANAFORT
and GATES had repeatedly and falsely represented in writing to preparer that
MANAFORT had no authority over foreign bank accounts, knowing that such false
representations would result in false MANAFORT tax ?lings. For instance, on October 4, 2011,
tax preparer asked MANAFORT in writing: ?At any time during 2010, did you
[or your wife orchildren] have an interest in or a signature or other authority over a ?nancial
account in a foreign country, such as a bank account, securities account or other ?nancial
account?? On the same day, MANAFORT falsely responded MANAFORT responded the
same way as recently as October 3, 2016, when tax preparer again emailed the
question in connection with the preparation of tax returns: ?Foreign bank accounts

eta?? MANAFORT responded on or about the same day:

MANAFORT And Fraud To Increase Access To Offshore Money

33. After MANAFORT used his offshore accounts to purchase real estate in the United States,
he took out mortgages on the properties thereby allowing MANAFORT to have the benefits of
liquid income without paying taxes on it. Further, MANAFORT defrauded the banks that loaned
him the money so that he could withdraw more money at a cheaper rate than he otherwise would
have been permitted.

34. In 2012, MANAFORT, through a corporate vehicle called Soho Holdings,
owned by him and his family, bought a? condominium on Howard Street in the Soho neighborhood

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in Manhattan, New York. He paid approximately $2,850,000. All the money used to purchase
the condominium came from MANAFORT entities in Cyprus. MANAFORT used the property
from at least January 2015 through 2016 as an income-generating rental property, charging
thousands of dollars a week on Airbnb, among other places. In his tax returns, MANAFORT took
advantage of the bene?cial tax consequences of owning this rental property.

35. In late 2015 through early 2016, MANAFORT applied for a mortgage on the condominium.
Because the bank would permit a greater loan amount if the property were owner-occupied,
MANAFORT falsely represented to the bank and its agents that it was a secondary home used as
such by his daughter and son-in?law and was not a property held as a rental property. For instance,
on January 26, 2016, MANAFORT wrote to his son-in?law to advise him that when the bank
appraiser came to assess the condominium his son?in?law should ?[r]ernember, he believes that
you and daughter] are living there.? Based on a request from MANAFORT,
GATES caused a document to be created which listed the Howard Street property as the second
home of daughter and son-in?law, when GATES knew this fact to be false. As a
result of his false representations, in March 2016 the bank provided MANAFORT a loan for
approximately $3 ,1 85,000.

36. Also in 2012, MANAFORT -- through a corporate vehicle called Brooklyn Holdings,
similarly owned by him and his family -- bought a brownstone on Union Street in the Carroll
Gardens section of Brooklyn, New York. He paid approximately $3,000,000 in cash for the
property. All of that money came from a MAN AFORT entity in Cyprus. After purchase of the
property, MANAFORT began renovations to transform it from a multi~family dwelling into a
single family home. In late 2015 through early 2016, MANAFORT sought to borrow cash against
the property. The institution MANAFORT went to for the loan provided greater loan amounts for

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?construction loans? -- that is, loans that required the loan amounts to be used to pay solely for
construction of the property and thus increase the value of the property serving as the loan?s
collateral. The institution would thus loan money against the expected completed value of the
property, which in the case of the Union Street property was estimated to be $8,000,000. In early
2016, MANAFORT was able to obtain a loan of approximately $5,000,000, after promising the
bank that approximately $1,400,000 of the loan would be used solely for construction of the Union
Street property. However, MANAFORT never intended to limit use of the proceeds to
construction as required by the loan contracts. In December 2015, before the loan was made,
MANAFORT wrote his tax preparer, among others, that the construction loan ?will allow me to
pay back the [another Manafort apartment] mortgage in full. . . Further, when the construction
loan closed, MANAFORT used hundreds of thousands of dollars from the construction loan to

make a down payment on another property in California.

Statutory Allegations

COUNT ONE
(Con3piracy Against The United States)

37. Paragraphs 1 through 30 and 32 through 36 are incorporated here. I

38. From in or about and between 2006 and 2017, both dates being approximate and inclusive,
in the District of Columbia and elsewhere, the defendants PAUL J. MANAFORT, JR., and
RICHARD W. GATES together with others, knowingly and intentionally conspired to defraud
the United States by impeding, impairing, obstructing, and defeating the lawful governmental
functions of a government agency, namely the Department of Justice and the Department of the

Treasury, and to commit offenses against the United States, to wit, the violations of law charged

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in Counts Three through Six and Ten through Twelve.

39.

In furtherance of the conspiracy and to effect its illegal object, MANAFORT and GATES

committed the overt acts noted in Count Eleven and the overt acts, among others, in the District of

Columbia and elsewhere as set forth in paragraphs 9, 16, 17, 20-25, 32, and 34-36, which are

incorporated herein.

40.

41.

(18 U.S.C. 371)
COUNT TWO
(Conspiracy To Launder Money)
Paragraphs 1 through 30 and 32 through 36 are incorporated here.

In or around and between 2006 and 2016, both dates being approximate and inclusive,

within the District of Columbia and elsewhere, the defendants PAUL J. MANAFORT, JR., and

RICHARD W. GATES together with others, did knowingly and intentionally conspire to:

transport, transmit, and transfer monetary instruments and funds from places outside
theUnited States to and through places in the United States and from places in the United
States to and through places outside the United States, with the intent to promote the
carrying on of specified unlawful activity, to wit: a felony violation of the FARA, in
violation of Title 22, United States Code, Sections 612 and 618 (the ?Specified Unlawful
Activity?), contrary to Title 18, United States Code, Section 1956(a)(2)(A); and

conduct ?nancial transactions, affecting interstate and foreign commerce, knowing that
the property involved in the financial transactions would represent the proceeds of some
form of unlawful activity, and the transactions in fact would involve the proceeds of
Specified Unlawful Activity, knowing that such ?nancial transactions were designed in
whole and in part to engage in conduct constituting a violation of sections 7201 and

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7206 of the Internal Revenue Code of 1986, and (ii) to conceal and disguise the nature,

location, source, ownership, and control of the proceeds of the Speci?ed Unlawful

Activity, contrary to Title 18, United States Code, Section 1956(a)(1)(A)(ii) and

(18 U.S.C. 1956(h))
COUNTS THREE THROUGH SIX
(Failure To File Reports Of Foreign Bank And Financial
Accounts For Calendar Years 2011-2014)

42. Paragraphs 1 through 30 and 32 through 36 are incorporated here.
43. On the ?ling due dates listed below, in the District of Columbia and elsewhere, the
defendant PAUL J. MANAFORT, JR., unlawfully, willfully, and knowingly did fail to ?le with
the Department of the Treasury an FBAR disclosing that he has a ?nancial interest in, and signature
and other authority over, a bank, securities, and other ?nancial account in a foreign country, which
had an aggregate value of more than $10,000, while Violating another law of the United States and
as part of pattern of illegal activity involving more than $100,000 in a 12-rnonth period, during the

years listed below:

3 2011 June 29, 2012
4 2012 June 30, 2013
5 2013 June 30, 2014
6 2014 June 30, 2015

(31 U.S.C. 5314 and 5322(b); 13 U.S.C. 2)

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COUNTS SEVEN THROUGH NINE
(Failure To File Reports Of Foreign Bank And Financial
Accounts For Calendar Years 201 1-2013)
44. Paragraphs 1 through 29 and 31 through 36 are incorporated here.
45. On the ?ling due dates listed below, in the District of Columbia and elsewhere, the
defendant RICHARD W. GATES unlawfully, willfully, and knowingly did fail to ?le with the
Department of the Treasury an FBAR disclosing that he has a ?nancial interest in, and signature
and other authority over, a bank, securities, and other ?nancial account in a foreign country, which
had an aggregate value of more than $10,000, while violating another law of the United States and

as part of pattern of illegal activity involving more than $100,000 in a 12-month period, during the

years listed below:

June 29, 201 2
8 2012 June 30, 2013
9 2013 June 30, 2014

(31 U.S.C. 5314 and 5322(b); 18 U.S.C. 2)
COUNT TEN
(Unregistered Agent Of A Foreign Principal)
46. Paragraphs 1 through 36 are incorporated here.
47. From in or about and between 2008 and 2014, both dates being approximate and inclusive,
within the District of Columbia and elsewhere, the defendants PAUL J. MANAFORT, JR., and
RICHARD W. GATES knowingly and willfully, without registering with the Attorney General

as required by law, acted as agents of a foreign principal, to wit, the Government of Ukraine, the

26

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Party of Regions, and Yanukovych.

(22 U.S.C. 612 and 618(a)(1); 18 U.S.C. 2)

COUNT ELEVEN
(False and Misleading FARA Statements)

48. Paragraphs 1 through 36 are incorporated here.

49. On or about November 23, 2016 and February 10, 2017, within the District of Columbia

and elsewhere, the defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES Ill

knowingly and willfully caused to be made a false statement of a material fact, and omitted a

material fact necessary to make the statements therein not misleading, in a docurirent ?led with

and furnished to the Attorney General under the provisions of FARA, to wit the underlined

statements:

efforts on behalf of the Party of Regions and Opposition Bloc did not
include meetings or outreach within the US

?INleither nor Messrs. Manafort or Gates had any agreement with the

[Centre] to provide services.?

did provide the [Centre], at the request of members of the Party of Regions,

with a list of potential U.S.-based consultants?including [Company A and
Company the [Centre] ?5 reference and further consideration. [The Centre]
then contracted directly with [Company A and Company to provide services

within the United States for which these entities registered under the Lobbying

Disclosure Act.?
?To Gates? recollection, these efforts included providing policy brie?ngs to the

[Centre] and its consultants on key initiatives and political developments in

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Ukraine, including participation in and/or coordination of related conference calls

and meetings. Although Gates recalls interacting with [the Centrel's consultants

regarding efforts in the Ukraine and Europe, neither Gates nor Mr. Manafort recall

meeting with or conducting outreach to US. government of?cials or US. media
outlets on behalf of the [the Centre], nor do they recall being party to, arranging, or
facilitating any such communications. Rather, it is the recollection and
understanding of Messrs. Gates and Manafort that such communications would

have been facilitated and conducted by the [Centrel?s U.S. consultants, as directed

by the [Centre], pursuant to the agreement reached between those parties to which
was not a party).?

0 search has been conducted for correspondence containing additional
information related to the matters described in [the government?s] Letters.
However, as a result of Email Retention Policy, which does not retain

communications beyond thirty days, the search has returned no responsive

communications.?

(22 U.S.C. 612, 618(a)(2); 18 U.S.C. 2)

COUNT TWELVE
(False Statements)

50. Paragraphs 1 through 36 and paragraph 49 are incorporated here.
51. On or about November 23, 2016 and February 10, 2017, within the District of Columbia
and elsewhere, in a matter within the jurisdiction of the executive branch of the Government of

the United States, the defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES

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- knowingly and willfully did cause another: to falsify, conceal, and cover up by a scheme and device
a material fact; to make a materially false, fictitious, and fraudulent'statement and representation;
and to make and use a false writing and document knowing the same to contain a materially false,
?ctitious, and fraudulent statement, to wit, the statements in the November 23, 2016 and February
10, 2017 submissions to the Department of Justice quoted in paragraph 49.

(13 U.S.C.

FORFEITURE ALLEGATION

52. Pursuant to Fed. R. Crim. P. 32.2, notice is hereby given to the defendants that the United
States will seek forfeiture as part of any sentence in accordance with Title 18, United States Code,
Sections 981(a)(1)(C) and 982(a)(l) and and Title 28, United States Code, Section 2461(0),
in the event of the defendants? convictions under Count Two of this Indictment. Upon conviction
of the offense charged in Count Two, the defendants PAUL J. MANAFORT, JR., and RICHARD
W. GATES 111 shall forfeit to the United States any property, real or personal, involved in such
offense, and any property traceable to such property. Upon conviction of the offenses charged in .-
Counts Ten and Eleven, the defendants PAUL J. MANAFORT, R., and RICHARD W. GATES
shall forfeit to the United States any property, real or personal, which constitutes or is derived
from proceeds traceable to the offense(s) of conviction. Notice is further given that, upon
conviction, the United States intends to seek a judgment against each defendant for a sum of money
representing the property described in this paragraph, as applicable to each defendant (to be offset
by the forfeiture of any speci?c property),

53. The grand jury ?nds probable cause to believe that the property subject to forfeiture by
PAUL J. MANAFORT, JR., includes, but is not limited to, the following listed assets:

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a. The real property and premises commonly known as 377 Union Street, Brooklyn,
New York, 11231 (Block 429, Lot 65), including all appurtenances, improvements, and
attachments thereon, and any property traceable thereto;

b. The real property and premises commonly known as 29 Howard Street, New
York, New York, 10013 (Block 209, Lot 1104), including all appurtenances,
improvements, and attachments thereon, and any property traceable thereto;

0. The real property and premises commonly known as 1046 Ed gewood Street,
Arlington, Virginia, 22201, including all appurtenances, improvements, and attachments
thereon, and any property traceable thereto;

d. The real property and premises commonly known as 174 Jobs Lane, Water Mill,
New York 11976, including all appurtenances, improvements, and attachments thereon,
and any property traceable thereto; and

e. Northwestern Mutual Universal Life Insurance Policy 18268327.

Substitute Assets
54. If any of the property described above as being subject to forfeiture, as a result of any act or

omission of any defendant --

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

c. has been placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or

c. has been commingled with other property that cannot be subdivided Without
dif?culty;

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it is the intent of the United States of America, pursuant to Title 18, United States Code, Section
982(b) and Title 28, United States Code, Section 2461(c), incorporating Title 21, United States
Code, Section 853, to seek Forfeiture of any other property of said defendant.

(18 use. 981(a)(1)(C) and 982; 28 "use. 24610;?

Robert S. Mueiler, Ill
Special Counsel
Department of ustiee

A TRUE BILL:


or pension

Date? October 27, 2017

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Case 1:18-cv-00011 Document 1-3 Filed 01/03/18 Page 1 of 3
CIVIL COVER SHEET
JS-44 (Rev. 6/17 DC)

I. (a) PLAINTIFFS

DEFENDANTS

Paul J. Manafort, Jr.
10 St. James Drive
Palm Beach Gardens, FL 33418

United States Department of Justice
Rod J. Rosenstein
Robert S. Mueller III

88888

11001
COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _____________________
(IN U.S. PLAINTIFF CASES ONLY)

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF _____________________
(EXCEPT IN U.S. PLAINTIFF CASES)
(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED

ATTORNEYS (IF KNOWN)

Kevin M. Downing
815 Connecticut Ave., N.W. Suite 730
Washington, D.C. 20006
(202) 754-1992
II. BASIS OF JURISDICTION

o
o

III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX FOR

(PLACE AN x IN ONE BOX ONLY)

1 U.S. Government
Plaintiff
2 U.S. Government
Defendant

o
o

3 Federal Question
(U.S. Government Not a Party)
4 Diversity
(Indicate Citizenship of
Parties in item III)

PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!
PTF
DFT

Citizen of this State
Citizen of Another State
Citizen or Subject of a
Foreign Country

o1 o1
o2 o2
o3 o3

Incorporated or Principal Place
of Business in This State
Incorporated and Principal Place
of Business in Another State
Foreign Nation

PTF

DFT

o4 o4
o5 o5
o6 o6

IV. CASE ASSIGNMENT AND NATURE OF SUIT
(Place an X in one category, A-N, that best represents your Cause of Action and one in a corresponding Nature of Suit)

o

A. Antitrust
410 Antitrust

o

o

o

B. Personal Injury/
Malpractice
310 Airplane
315 Airplane Product Liability
320 Assault, Libel & Slander
330 Federal Employers Liability
340 Marine
345 Marine Product Liability
350 Motor Vehicle
355 Motor Vehicle Product Liability
360 Other Personal Injury
362 Medical Malpractice
365 Product Liability
367 Health Care/Pharmaceutical
Personal Injury Product Liability
368 Asbestos Product Liability

E. General Civil (Other)

Real Property
210 Land Condemnation
220 Foreclosure
230 Rent, Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
Personal Property
370 Other Fraud
371 Truth in Lending
380 Other Personal Property
Damage
385 Property Damage
Product Liability

C. Administrative Agency
Review
151 Medicare Act

Social Security
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
Other Statutes
891 Agricultural Acts
893 Environmental Matters
890 Other Statutory Actions (If
Administrative Agency is
Involved)

OR
Bankruptcy
422 Appeal 27 USC 158
423 Withdrawal 28 USC 157
Prisoner Petitions
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Conditions
560 Civil Detainee a Conditions
of Confinement
Property Rights
820 Copyrights
830 Patent
835 Patent a Abbreviated New
Drug Application
840 Trademark

o

o

D. Temporary Restraining
Order/Preliminary
Injunction

Any nature of suit from any category
may be selected for this category of
case assignment.
*(If Antitrust, then A governs)*

F. Pro Se General Civil
Federal Tax Suits
870 Taxes (US plaintiff or
defendant)
871 IRS-Third Party 26 USC
7609
Forfeiture/Penalty
625 Drug Related Seizure of
Property 21 USC 881
690 Other
Other Statutes
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
430 Banks & Banking
450 Commerce/ICC
Rates/etc.
460 Deportation

462 Naturalization
Application
465 Other Immigration
Actions
470 Racketeer Influenced
& Corrupt Organization
480 Consumer Credit
490 Cable/Satellite TV
850 Securities/Commodities/
Exchange
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of State
Statutes
890 Other Statutory Actions
(if not administrative agency
review or Privacy Act)

Case 1:18-cv-00011 Document 1-3 Filed 01/03/18 Page 2 of 3

o

G. Habeas Corpus/
2255

o

K. Labor/ERISA
(non-employment)
710 Fair Labor Standards Act
720 Labor/Mgmt. Relations
740 Labor Railway Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Empl. Ret. Inc. Security Act

*(If pro se, select this deck)*

*(If pro se, select this deck)*

o

o

L. Other Civil Rights
(non-employment)
441 Voting (if not Voting Rights
Act)
443 Housing/Accommodations
440 Other Civil Rights
445 Americans w/Disabilities a
Employment
446 Americans w/Disabilities a
Other
448 Education

V. ORIGIN

o 1 Original o 2 Removed o 3 Remanded
Proceeding

from State
Court

from Appellate
Court

o

I. FOIA/Privacy Act
895 Freedom of Information Act
890 Other Statutory Actions
(if Privacy Act)

442 Civil Rights a Employment
(criteria: race, gender/sex,
national origin,
discrimination, disability, age,
religion, retaliation)

530 Habeas Corpus a General
510 Motion/Vacate Sentence
463 Habeas Corpus a Alien
Detainee

o

o

H. Employment
Discrimination

152 Recovery of Defaulted
Student Loan
(excluding veterans)

o

M. Contract
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of
Judgment
153 Recovery of Overpayment
of Veteranas Benefits
160 Stockholderas Suits
190 Other Contracts
195 Contract Product Liability
196 Franchise

J. Student Loan

N. Three-Judge
Court
441 Civil Rights a Voting
(if Voting Rights Act)

o 4 Reinstated o 5 Transferred o 6 Multi-district o 7 Appeal to
or Reopened

from another
district (specify)

Litigation

District Judge
from Mag.
Judge

o 8 Multi-district
Litigation a
Direct File

VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)

Action under the APA, 5 U.S.C. ASSASS 701 et seq., to set aside ultra vires agency action.
VII. REQUESTED IN
COMPLAINT

CHECK IF THIS IS A CLASS
ACTION UNDER F.R.C.P. 23

DEMAND $
JURY DEMAND:

VIII. RELATED CASE(S)
IF ANY

(See instruction)

YES

01/03/2018
DATE: _________________________

NO

Check YES only if demanded in complaint

YES

a

NO

a

If yes, please complete related case form

- see attached

/s/ Kevin M. Downing
SIGNATURE OF ATTORNEY OF RECORD _________________________________________________________
INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44
Authority for Civil Cover Sheet

The JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and services of pleadings or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the
Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed.
Listed below are tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the cover sheet.
I.

COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff if resident
of Washington, DC, 88888 if plaintiff is resident of United States but not Washington, DC, and 99999 if plaintiff is outside the United States.

III.

CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction
under Section II.

IV.

CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the category you select that best
represents the primary cause of action found in your complaint. You may select only one category. You must also select one corresponding
nature of suit found under the category of the case.

VI.

CAUSE OF ACTION: Cite the U.S. Civil Statute under which you are filing and write a brief statement of the primary cause.

VIII.

RELATED CASE(S), IF ANY: If you indicated that there is a related case, you must complete a related case form, which may be obtained from
the Clerkas Office.

Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form.

Case 1:18-cv-00011 Document 1-3 Filed 01/03/18 Page 3 of 3
CIVIL COVER SHEET ADDENDUM
Paul J. Manafort v. United States Department of Justice et al.

There is a pending criminal case in this court against Plaintiff Paul J. Manafort: United States v.
Manafort et al., 1:17-cr-00201-ABJ, although we do not believe that it qualifies as a arelated
casea under this Courtas Rule 40.5.

Case 1:18-cv-00011 Document 1-4 Filed 01/03/18 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Paul J. Manafort, Jr.

Plaintiff(s)

v.
United States Department of Justice
Rod J. Rosenstein
Robert S. Mueller III
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) United States Department of Justice
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: Kevin M. Downing
815 Connecticut Ave. N.W.
Suite 730
Washington, D.C. 20006

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:

01/03/2018
Signature of Clerk or Deputy Clerk

Case 1:18-cv-00011 Document 1-4 Filed 01/03/18 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

0.00

.

Case 1:18-cv-00011 Document 1-5 Filed 01/03/18 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Paul J. Manafort, Jr.

Plaintiff(s)

v.
United States Department of Justice
Rod J. Rosenstein
Robert S. Mueller III
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) Jessie K. Liu
United States Attorney for the District of Columbia
555 4th Street, N.W.
Suite 300
Washington, D.C. 20530

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: Kevin M. Downing
815 Connecticut Ave. N.W.
Suite 730
Washington, D.C. 20006

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:

01/03/2018
Signature of Clerk or Deputy Clerk

Case 1:18-cv-00011 Document 1-5 Filed 01/03/18 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

0.00

.

Case 1:18-cv-00011 Document 1-6 Filed 01/03/18 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Paul J. Manafort, Jr.

Plaintiff(s)

v.
United States Department of Justice
Rod J. Rosenstein
Robert S. Mueller III
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) Robert S. Mueller III
Office of Special Counsel
395 E Street, S.W.
Washington, D.C. 20024
and
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20004

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: Kevin M. Downing
815 Connecticut Ave. N.W.
Suite 730
Washington, D.C. 20006

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:

01/03/2018
Signature of Clerk or Deputy Clerk

Case 1:18-cv-00011 Document 1-6 Filed 01/03/18 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

0.00

.

Case 1:18-cv-00011 Document 1-7 Filed 01/03/18 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Paul J. Manafort, Jr.

Plaintiff(s)

v.
United States Department of Justice
Rod J. Rosenstein
Robert S. Mueller III
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) Rod J. Rosenstein
United States Department of Justice
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: Kevin M. Downing
815 Connecticut Ave. N.W.
Suite 730
Washington, D.C. 20006

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:

01/03/2018
Signature of Clerk or Deputy Clerk

Case 1:18-cv-00011 Document 1-7 Filed 01/03/18 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

0.00

.

Case 1:18-cv-00011 Document 1-8 Filed 01/03/18 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Paul J. Manafort, Jr.

Plaintiff(s)

v.
United States Department of Justice
Rod J. Rosenstein
Robert S. Mueller III
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) Honorable Jeff Sessions
Attorney General
United States Department of Justice
950 Pennsylvania Ave., N.W.
Washington, D.C. 20530

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: Kevin M. Downing
815 Connecticut Ave. N.W.
Suite 730
Washington, D.C. 20006

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:

01/03/2018
Signature of Clerk or Deputy Clerk

Case 1:18-cv-00011 Document 1-8 Filed 01/03/18 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

0.00

.