Read the full transcript of Glenn Simpson's Senate testimony

Glenn R. Simpson, founder of research firm Fusion GPS, spoke to investigators with the Senate Judiciary Committee for 10 hours in August. As the partisan fight over Russian interference in the 2016 election has intensified, Simpson has urged that his testimony be released, and a copy of the transcript was made public Tuesday. It was released by the ranking Democrat on the Senate Judiciary Committee, Sen. Dianne Feinstein of California. Feinstein releases testimony of Glenn Simpson, whose research firm Fusion GPS was behind Trump dossier.

Glenn Simpson

August 22, 2017
Washington, DC
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SENATE JUDICIARY COMMITTEE

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U.S. SENATE

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WASHINGTON, D.C.

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INTERVIEW OF:

GLENN SIMPSON

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TUESDAY, AUGUST 22, 2017

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WASHINGTON, D.C.

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The interview in this matter was held at the
Hart Senate Office Building, commencing at 9:34 a.m.

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Glenn Simpson

August 22, 2017
Washington, DC
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APPEARANCES:

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SENATE JUDICIARY COMMITTEE:

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Patrick Davis, Deputy Chief Investigative Counsel,

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Chairman Grassley
Jason Foster, Chief Investigative Counsel,
Chairman Grassley
Samantha Brennan, Investigative Counsel,
Chairman Grassley
Daniel Parker, Investigative Assistant,
Chairman Grassley
Joshua Flynn-Brown, Investigative Counsel,
Chairman Grassley
Scott Graber, Legislative Assistant/Counsel,
Senator Graham
Heather Sawyer, Chief Oversight Counsel,
Senator Feinstein
Jennifer Duck, Staff Director,

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Senator Feinstein

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Molly Claflin, Counsel,

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Senator Feinstein

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Lara Quint, Chief Counsel,
Senator Whitehouse

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August 22, 2017
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APPEARANCES:

(Cont'd)

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FOR THE WITNESS:

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Joshua Levy, Cunningham Levy Muse

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Robert Muse, Cunningham Levy Muse

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Rachel Clattenburg, Cunningham Levy Muse

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August 22, 2017
Washington, DC
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I N D E X

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EXAMINATION

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PAGE

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By Mr. Davis

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By Ms. Sawyer

52

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By Mr. Davis

95

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By Ms. Sawyer

138

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By Mr. Davis

180

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By Ms. Sawyer

227

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By Mr. Davis

260

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By Ms. Sawyer

290

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EXHIBITS

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EXHIBIT

PAGE

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Exhibit 1
8/3/17 letter agreement

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Exhibit 2
Privilege log

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Exhibit 3
BuzzFeed memos

138

Exhibit 4
Filing in UK litigation

196

Exhibit 5
(Not described)

205

Exhibit 6
Meeting notes

261

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August 22, 2017
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MR. DAVIS:

Good morning.

This is the

2

transcribed interview of Glenn Simpson.

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Grassley and Ranking Member Feinstein requested

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this interview as part of the Senate Judiciary

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Committee's investigation of Fusion GPS's

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activities related to the dossier compiled by

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Christopher Steele, the Prevezon case, and the

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Magnitsky Act.

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10

Chairman

Would the witness please state your name for
the record.

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MR. SIMPSON:

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MR. DAVIS:

Glenn Simpson.
On behalf of the Chairman I want

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to thank Mr. Simpson for appearing here today.

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name is Patrick Davis.

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Investigative Counsel with the committee's majority

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staff.

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I'm the Deputy Chief

I'll ask everyone else from the committee who
is here to introduce themselves as well.
MR. FOSTER:

Jason Foster, I'm the Chief

Investigative Counsel for Chairman Grassley.
MS. BRENNAN:

Samantha Brennan, Investigative

Counsel, Chairman Grassley.

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MR. GRABER:

Scott Graber, Senator Graham.

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MR. PARKER:

Daniel Parker, Investigative

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My

Assistant for Senator Grassley.

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August 22, 2017
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MR. BROWN:

Counsel for Senator Grassley.

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4

MS. DUCK:

MS. QUINT:

MS. SAWYER:

Heather Sawyer, Chief Oversight

Counsel, Senator Feinstein.

9
10

Lara Quint, Chief Counsel,

Senator Whitehouse.

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8

Jennifer Duck, Staff Director for

Senator Feinstein.

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6

Joshua Flynn-Brown, Investigative

MS. CLAFLIN:

Molly Claflin, Counsel, Senator

Feinstein.

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MR. DAVIS:

The Federal Rules of Civil

12

Procedure do not apply to any of the committee's

13

investigative activities, including transcribed

14

interviews.

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and I'll go over those now.

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There are some guidelines we follow,

Our questioning will proceed in rounds.

The

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majority staff will ask questions first for one

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hour, then the minority staff will have an

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opportunity to ask questions for an equal amount of

20

time.

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more questions and the interview is over.

We will go back and forth until there are no

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We typically take a short break at the end of

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each hour, but should you need a break at any other

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time, please just let us know.

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taking a break for lunch whenever you're ready to

And we can discuss

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August 22, 2017
Washington, DC
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do so.

2

We have an official reporter taking down

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everything we say to make a written record.

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ask that you give verbal responses to all

5

questions.

So we

Do you understand?

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MR. SIMPSON:

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MR. DAVIS:

Yes.
So that the court reporter can

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take down a clear record, we'll do our best to

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limit the number of people directing questions at

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you during any given hour to those whose turn it

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is.

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one another or interrupt each other to the extent

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we can help it.

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today's interview.

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It's also important that we don't talk over

That goes for everybody present at

We encourage witnesses who appear before the

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committee to freely consult with counsel if they

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should choose.

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counsel.

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for the record.

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MR. LEVY:

Josh levy.

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MR. MUSE:

I'm Bob Muse and I represent Glenn

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You are appearing here today with

Counsel, could you please state your name

Simpson.

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MS. CLATTENBURG:

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MR. DAVIS:

25

I'm Rachel Clattenburg.

We want you to answer our

questions in the most complete and truthful manner

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August 22, 2017
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possible.

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any questions or if you don't understand any of our

3

questions, please let us know.

4

don't know the answer to a question or don't

5

remember, it's best not to guess.

6

your best recollection.

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So we will take our time.

If you have

If you honestly

Just give us

It's okay to tell us if you learned

8

information from somewhere else if you indicate how

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you came to know the information.

If there are

10

things that you don't know or can't remember, we

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ask that you inform us to the best of your

12

knowledge who might be able to provide a more

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complete answer to the question.

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This interview is unclassified.

So if any

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question calls for information that you know to be

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classified, please state that for the record as

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well as the reason for the classification.

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once you've clarified that to the extent possible,

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please respond with as much unclassified

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information as you can.

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classified session later, that can be arranged.

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Then

If we need to have a

It is this committee's practice to honor

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valid common law privilege claims as an

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accommodation to a witness or party when those

25

claims are made in good faith and accompanied by

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August 22, 2017
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sufficient explanation so that the committee can

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evaluate the claim.

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a privilege the committee weighs its need for the

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information against any legitimate basis for

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withholding it.

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honor contractual confidentiality agreements.

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When deciding whether to honor

The committee typically does not

The committee and Mr. Simpson have agreed

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that this interview is occurring without prejudice

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to any future discussions with the committee and we

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reserve the right to request Mr. Simpson's

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participation in future interviews or to compel his

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testimony.

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agreed that participation in this interview does

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not constitute a waiver of his ability to assert

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any privileges in response to future appearances

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before this committee.

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The committee and Mr. Simpson have also

Mr. Simpson, you should understand that

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although the interview is not under oath, by law

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you are required to answer questions from Congress

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truthfully.

Do you understand that?

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MR. SIMPSON:

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MR. DAVIS:

Yes.
Specifically 18 U.S.C. Section

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1001 makes it a crime to make any materially false,

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fictitious, or fraudulent statement or

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representation in the course of a congressional

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August 22, 2017
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investigation.

That statute applies to your

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statements in this interview.

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that?

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MR. SIMPSON:

5

MR. DAVIS:

Do you understand

Yes, I do.
Witnesses who knowingly provide

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false statements could be subject to criminal

7

prosecution and imprisonment for up to five years.

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Do you understand this?

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MR. SIMPSON:

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11

MR. DAVIS:

Yes, I do.
Is there any reason you're unable

to provide truthful answers to today's questions?

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MR. SIMPSON:

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MR. DAVIS:

No.
Finally, we ask that you not

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speak about what we discuss in this interview with

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anyone else outside of who's here in the room today

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in order to preserve the integrity of our

17

investigation.

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exhibits or other committee documents from the

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interview.

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We also ask that you not remove any

Once again, the Chairman and Ranking Member

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withdrew their subpoena of you due to your

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willingness to provide information in this

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voluntary interview and document production.

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However, the extent to which the committee deems

25

further compulsory process necessary will likely

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August 22, 2017
Washington, DC
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depend on your level of cooperation and candor.

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Is there anything else that my colleagues

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4

from the minority would like to add?
MS. SAWYER:

Thank you.

We appreciate it.

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And we appreciate you being here as part of the

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investigation into the Russian interference into

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the 2016 election.

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9

I did want to, with agreement of my
colleagues, just enter into the record the letter

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agreement regarding the interview that was sent to

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your counsel on August 3, 2017.

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colleague has gone over a number of the parameters

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that we agreed to, but I think it would be helpful

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to have this in the record.

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mark it as Interview Exhibit No. 1 just for

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identification purposes.

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21
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marked for identification.)
MS. SAWYER:

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With that, again, thank you for

being here.
MR. DAVIS:

The time is now 9:40 and we will

get started with the first hour of questions.

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24

So we'll go ahead and

(Interview Exhibit 1 was

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I think my

EXAMINATION
BY MR. DAVIS:
Q. Mr. Simpson, what is your professional

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Glenn Simpson

August 22, 2017
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background?
A. I have a degree in journalism from George

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Washington University and I've spent most of my

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working adult life as a journalist, much of it as

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an investigative reporter for the Wall Street

6

Journal.

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investigative reporter at Roll Call Newspaper

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writing about political corruption, financial

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crime, terrorism, tax evasion, stock fraud,

Prior to that I worked as an

10

financial scandals, congressional investigations,

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government prosecutions, money laundering,

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organized crime.

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14

Q. And when did you leave the Wall Street
Journal?

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A. In 2009.

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Q. And did you found SNS Global after leaving

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the Wall Street Journal?

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A. That's right.

19

Q. And how many employees and associates did

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SNS Global have?
A. There were two partners and in the first

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part of the time I think we had one employee.

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I'm sorry.

No,

We had two employees.

24

Q. And who were they?

25

A. We had a research assistant named Margot

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August 22, 2017
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Williams, M-A-R-G-O-T Williams, and another

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administrative assistant whose name I don't recall

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right now.

4

Q. And who was the other partner?

5

A. Susan Schmidt was my other partner, former

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colleague from the Wall Street Journal, and prior

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to that was an investigative reporter at the

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Washington Post.

9
10

Q. And what was the nature of SNS Global's
business?

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A. Research, business intelligence.

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Q. And what types of clients did SNS Global

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have?

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A. It's a while ago, so it's not fresh in my

15

mind.

Other consulting firms, lawyers.

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specifically remember a lot of them.

I don't

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Q. And is SNS Global still in business?

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A. No.

19

Q. When did it cease operations?

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A. I believe at the end of 2010.

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Q. And why did it -- why did SNS Global cease

22
23

operations?
A. Basically my partner and I had different

24

ambitions for what we wanted to do.

I wanted to

25

have a brick and mortar office with more resources

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and staff.

Basically I concluded that the work

2

that we were doing required more infrastructure and

3

resources.

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to have access to a lot of different databases and

5

there's a lot of aspects of the work that are

6

administrative in nature that require things that I

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wasn't able to do.

8

the research.

9

infrastructure where I could focus on that.

Basically in modern research you need

I prefer to spend my time doing

So I wanted to have more of an

10

Q. What is Bean, LLC?

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A. That's the LLC that is my current

12

company.

13

Q. And what is your role in Bean, LLC?

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A. I'm the majority owner.

I guess, you

15

know, we don't have official titles, but I'm

16

generally referred to as the CEO.

17
18

Q. Bean, LLC registered Fusion GPS as a trade
name in the District of Columbia; is that correct?

19

A. Yes, it's a DBA.

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Q. Why did you choose to use a trade name for

21

Bean, LLC rather than directly name the company

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Fusion GPS?

23

A. Because at the time that I was deciding

24

what I wanted to do I was recruiting a new partner

25

and I just needed to set up a holding company while

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I organized my new business.

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name.

3

I picked that name to begin the process of

4

organizing a new business and didn't want to select

5

an actual DBA, you know, a brand name until I

6

consulted with my new partner.

7

mutually -- I actually had two partners in the

8

beginning, so there were three of us, and I wanted

9

to make it a group decision.

10

So I just picked a

You know, a bean is a seed, a new thing.

So

We wanted to

Q. Is Bean, LLC currently registered in D.C.

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to conduct business under the trade name Fusion

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GPS?

13

A. To my knowledge it is.

It should be.

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Q. Have any other LLC's or business entities

15

conducted business as Fusion GPS?

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A. I don't think so.

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Q. Have any other LLC's or business entities

18

received payments for work conducted by Fusion GPS,

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its employees, or its associates?

20
21

MR. LEVY:

subcontractors or are you --

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MR. DAVIS:

23

MR. LEVY:

24

subcontractors?

25

Are you asking to include

MR. DAVIS:

Sure.
Does Fusion GPS have

Right.

I think that would be

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part of it, but the other part is: are there other

2

LLC's associated with Bean direct- -- with Bean or

3

Fusion directly, not just subcontractors?

4

BY THE WITNESS:

5

A. Yes.

I mean, the one I think that has

6

come up in some of the correspondence or somewhere,

7

I can't remember where, is another one called

8

Kernel, K-E-R-N-E-L, and that was an LLC that was

9

set up for a book project that never -- we never

10

finished -- we never did the book.

So it's

11

inactive with the current time.

12

another one that one of my partners manages that's

13

for different types of work, technology, policy,

14

and that type of thing.

Then there's

15

Q. What's the name of that one?

16

A. I think it's Caudex, C-A-U-D-E-X.

17

Q. And are any other LLC's or types of

18

business entities otherwise associated with Fusion

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GPS?

20

A. Those are the only ones I can think of.

21

Q. And have you been a registered agent,

22

owner, or beneficial owner of any other LLC's or

23

business entities?

24
25

A. I own an LLC in Maryland that holds some
property that I own.

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Q. And what's the name of that LLC?

2

A. As we sit here, I wasn't prepared for this

3

question, I don't remember the name of it.

4

registered fairly recently.

5

that to you.

6
7

Obviously we can get

Q. So is it correct that Fusion has at times
worked with different LLC's based on by project?

8
9

It was

A. For most of the history of the company
Bean, LLC was the primary entity through which we

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did business.

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your question.

12

that's fairly recent and there may be other

13

entities, but nothing that I, myself set up, at

14

least not that I can think of.

15
16

I'm not sure I totally understand
There's this other LLC I mentioned

Q. Anything that your partners would have set
up?

17

A. Not that I can think of.

18

Q. Does Fusion GPS, Bean, LLC, Kernel, LLC,

19

or any of these other related business entities

20

have any bank accounts outside of the United

21

States?

22

A. No.

23

Q. Domestically does Bean, LLC have an

24
25

account at

?

A. Yes.

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2

MR. LEVY:

into bank accounts.

3
4

MR. DAVIS:

Are you offering a basis for that

objection?

5
6

I don't know that we need to get

MR. LEVY:

It's outside the scope of the

interview.

7

MR. DAVIS:

Part of the questions we've asked

8

are actions Fusion has taken -- interactions Fusion

9

has had and we're trying to define the scope of

10

what Fusion is as a predicate to understanding

11

those answers.

12
13

MR. LEVY:
questions.

14
15

MR. FOSTER:

He answered yes to the question.

BY MR. DAVIS:

16
17

Yeah, and he's answering those

Q. Where is Fusion GPS's physical office, if
any?

18

A. DuPont Circle.

19

Q. Is it, if I recall correctly, 1700

20

Connecticut Avenue, Northwest?

21

A. That's the address, yes.

22

Q. Is it Suite 400?

23

A. It is.

24

Q. How many employees and associates does

25

Fusion GPS currently have?

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A. Roughly a dozen.
2 Q. Who are they?
3 A. Do you want their names?
4 Q. Yes, their names.
5 A. is a partner in the

6 business; is a partner in the
7 business; is a partner in

8 the bUSineSS-

I

10
I Another one of our managers is
is end he
- We have several whose

is meesm

is

l6 whose previous position I don't recall;
I whose former position I don't recall;

l8 who previously was with I think

who's our administrative

20 person. There may be one or two others whose names

Cl I don't recall.

:2 Q. Is anyone who was an employee or assvciate
23 of Fusion GPS in 20l5 or 2016 no longer with the

24 company? And if so, who?

25 A. Not that I can think of.

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Q. In general, what is Fusion GPS's business?

2

A. We primarily are a research, strategy,

3

consulting firm.

4
5

Q. And what types of clients has Fusion GPS
had?

6

A. It runs the gamut from corporations to law

7

firms, various investment funds, people involved in

8

litigation.

9
10
11
12
13
14
15
16
17
18

Q. And roughly how many active clients -MR. LEVY:

Did you finish?

I don't know if

he finished.
MR. DAVIS:

I'm sorry.

BY THE WITNESS:
A. It's hard to categorize them all.

Those

are some of the main types of clients we have.
Q. And roughly how many active clients did
Fusion GPS have in 2016?
A. That's difficult for me to answer.

You

19

know, over ten I would say, but it's hard for me --

20

beyond that I would be guessing.

21

Q. Does part of Fusion GPS's business involve

22

attempting to have media outlets publish articles

23

that further the interests of your clients?

24

A. Yeah, you could -- I mean, generally

25

speaking, we are -- generally we tend to respond to

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inquiries more than try to push things, but, you

2

know, we work with the press frequently.

3

Q. And has Fusion GPS ever provided

4

information to journalists in order to encourage

5

them to publish articles or air stories that

6

further your client's interests?

7

A. Yes.

8

Q. And has Fusion GPS provided information to

9

journalists or editors in order to discourage them

10

from publishing or airing stories that are contrary

11

to your client's interests?

12

A. Well, what we -- we're a research company.

13

So generally what we do is provide people with

14

factual information.

15

record information.

16

a story and some of the information that a

17

reporter's presuming is incorrect and we give them

18

correct information, that may cause them to not

19

write the story.

20

Our specialty is public
So if we get an inquiry about

Q. Has Fusion GPS ever had arrangements with

21

clients in which the amount of Fusion's

22

compensation was dependent on getting articles

23

published or stories aired?

24

A. Not that I can recall.

25

Q. Has Fusion GPS ever had arrangements with

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August 22, 2017
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clients in which the amount of Fusion's

2

compensation was dependent upon preventing articles

3

from being published or stories from being aired?

4
5

A. No, I don't think so, not to my
recollection.

6

Q. To the best of your knowledge, has anyone

7

associated with Fusion GPS ever told clients or

8

prospective clients that the company could find and

9

distribute information or take other actions in

10

order to encourage government agencies to initiate

11

an investigation?

12

A. Could you restate that?

13

Q. To the best of your knowledge, has anyone

14

associated with Fusion GPS ever told clients or

15

prospective clients that the company could find and

16

distribute information or take other actions in

17

order to encourage government agencies to initiate

18

an investigation?

19
20

MR. LEVY:

Within the scope of this

interview?

21

MR. DAVIS:

In general.

22

any particular case.

23

MR. LEVY:

Hold on.

I'm not asking about

Let's -- let me just

24

talk to my client about that and get back to you on

25

that.

I just want to understand the facts so we

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can evaluate whether it's appropriate to discuss

2

that here if such a predicate for the answer

3

exists.

4

MR. FOSTER:

5

MR. LEVY:

6

MR. FOSTER:

7

Sure.

MR. DAVIS:

10

It's 10:02.

11

BY MR. DAVIS:

12

We'll go back on the record.

Q. After conferring with your counsel, are
you able to answer the question?

14

16

It's

(A short break was had.)

9

15

Let's go off the record.

9:55.

8

13

Do you want to take a break?

A. Yes.

Could you just state it one more

time.
Q. Sure.

To the best of your knowledge, has

17

anyone associated with Fusion GPS ever told clients

18

or prospective clients that the company could find

19

and distribute information or take other actions in

20

order to encourage government agencies to initiate

21

an investigation?

22

A. The word "associated" is really vague.

23

I'm not sure I know what you mean by that.

I can

24

speak to my own practices and the practices of the

25

people who work at my company.

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Generally speaking, when we do a research

2

project for a new client and they ask us -- you

3

know, they explain, you know, what situation

4

they're involved in, if it's a lawsuit, for

5

example, or some other dispute, a lot of what we do

6

is related to disputes, they say -- you know, we

7

say we will conduct an open-ended inquiry that's

8

not goal directed and the results of the research

9

will guide whatever decision you want to make about

10
11

how to use it.
So the range of possibilities with, you know,

12

research are you could file a lawsuit, you could

13

put it in a court filing, you could take it to a

14

government agency, you could give it to Congress,

15

you could give it to the press, but you don't

16

really prejudge, you know, how you're going to use

17

information until you know what you've got.

18

So we generally don't let our clients dictate

19

sort of the -- you know, the end result of things

20

because we don't think that's an intelligent way of

21

trying to do research and, you know, a lot of what

22

we do is decision support.

23

frequently trying to make a decision about how they

24

want to proceed, whether they want to -- you know,

25

if someone thinks they've been defrauded, you can

Your clients are

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file a lawsuit, you can go to the police.

You

2

would decide that based on what you find out about

3

the, you know, evidence of a fraud.

4

generally the way we do it.

So that's

5

Q. To the best of your knowledge, has Fusion

6

GPS ever had an arrangement with a client in which

7

the company was specifically tasked with getting

8

government agencies to initiate an investigation?

9

A. I would -- to the best of my recollection,

10

we don't have any agreements like that we would put

11

into writing generally for the reasons I stated in

12

answer to the previous question.

13

you know, dealing with a client we might talk about

14

whether, you know, something was worthy of a

15

government investigation and talk about how that

16

could be done.

17

there that might come under discussion, but, as I

18

say, that's generally not how we frame a project.

19

In the course of,

There's any number of scenarios

Q. Has Fusion GPS ever had arrangements with

20

clients in which the amount of Fusion's

21

compensation was dependent on government agencies

22

initiating an investigation?

23

A. We've been in business since 2010, so

24

seven years is a fairly long time, but as I say,

25

not to my recollection.

I just can't be

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categorical because we've done a lot of work over

2

the last seven years.

3

Q. So I'm going to move on now to some

4

questions about Prevezon Holdings and the Magnitsky

5

Act.

6

when I refer to you or to Fusion, I mean not just

7

you personally, but all employees and associates of

8

Fusion GPS and its component LLC's and legal

9

entities as well as any contractors or

I want to sort of generally make it clear

10

subcontractors.

11

referring to in the question, please just ask and

12

I'll clarify.

13

If it's not clear to you who I'm

Similarly, I'm going to refer to Prevezon and

14

Magnitsky, M-A-G-N-I-T-S-K-Y.

When I refer to

15

those together, I mean all matters related to the

16

Justice Department's lawsuit against Prevezon

17

Holdings Limited, as well as all matters related to

18

efforts with the media, government officials, and

19

campaigns to overturn the Magnitsky Act, prevent

20

the passage of the global Magnitsky Act, remove the

21

word Magnitsky from either law, the Russian ban on

22

U.S. adoptions of Russian children, research on Mr.

23

Magnitsky himself or Mr. Browder, Hermitage Capital

24

Management and its affiliated companies.

25

generally putting those under that umbrella.

So I'm
If

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you need me to clarify for any specific question,

2

just ask.

3

MR. LEVY:

4

MR. DAVIS:

5

MR. LEVY:

You obviously said a lot there.
I did.
And so on a question-by-question

6

basis out of fairness to the witness, I just want

7

to make sure that he has the ability to ask

8

clarification, of course, as questions arise.

9
10
11

MR. DAVIS:

Right.

That's what I would be

asking you to do.
MR. LEVY:

Even now, quite frankly, I'm not

12

sure I can recall everything that you baked into

13

the term that you're going to use.

14
15
16
17
18

MR. DAVIS:

Feel free to raise questions

about any particular question we ask.
MR. LEVY:

Okay.

BY MR. DAVIS:
Q. Mr. Simpson, what was Fusion GPS's role in

19

the Justice Departments's litigation against

20

Prevezon Holdings?

21

A. We were retained by Baker Hostetler in the

22

spring of 2014 to do litigation support, and under

23

the heading of litigation support was things

24

related to discovery, locating witnesses, answer

25

questions from the press, gathering documents,

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pretty much, you know, a conventional understanding

2

of litigation support.

3
4
5

Q. And to whom did Fusion GPS report in the
course of this work?
A. Baker Hostetler.

The partner in charge

6

was Mark Cymrot, C-Y-M-R-O-T, who's a partner in

7

the Washington office and former Justice Department

8

prosecutor.

9
10
11

Q. Did Mr. Cymrot provide instructions to
Fusion GPS during the course of the work?
A. Mr. Cymrot regularly instructed us in how

12

we were to go about doing discovery and various

13

other tasks, yes.

14

Q. And for a portion of that case at least

15

Mr. Cymrot was the attorney of record for Prevezon

16

Holdings; is that correct?

17

A. For the entirety of the time that I worked

18

on the case he was -- I believe he was the attorney

19

of record.

20

Q. And did you understand the instructions

21

you received from him to be originating from his

22

client, from Prevezon Holdings?

23

A. The ultimate direction, of course, would

24

have been from the ultimate client, but the client

25

was outside the United States for most of its time.

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So, you know, a lot of instruction came from him

2

and he was the person who formulated the legal

3

strategy, undertook all of the legal efforts to

4

work the case.

5
6

Q. And when did Fusion GPS cease working on
the Prevezon Holdings case?

7
8
9
10
11

A. I can't say exactly.

It was mid to late

2016.
Q. Which of Fusion's associates and employees
have worked on the Prevezon or Magnitsky issues?
A. For the most part it was myself and one of

12

my analysts,

13

time to time issues may have come up about trying

14

to find records or other issues where I conferred

15

with or enlisted someone else in the office, but I

16

don't specifically recall.

17

.

MR. FOSTER:

There may have -- from

To follow up on the previous

18

answer, you said mid to late 2016 is when the

19

investigation ended, generally speaking.

20

have any records that could refresh your

21

recollection about the exact date at a later time?

22

MR. SIMPSON:

I'm sure we do, yes.

Do you

I am --

23

we have a division of labor and I don't do a lot of

24

things like invoicing.

25

my strong suit.

So this is not going to be

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2

MR. FOSTER:

But you could figure it out

later for us?

3

MR. SIMPSON:

4

MR. FOSTER:

We maintain books and records.
Could you maybe just describe

5

quickly what kind of record would constitute the

6

end of the engagement?

7

MR. SIMPSON:

That's a good question.

You

8

know, in some cases there's no specific termination

9

letter.

So I don't know whether there's a

10

termination agreement or termination letter in this

11

case.

12

we stop billing the case is over.

I mean, generally speaking, you know, when

13

(Exhibit 2 was marked for

14
15
16

identification.)
BY MR. DAVIS:
Q. I'd like to introduce an exhibit.

It's

17

one of two privilege logs that your attorneys

18

provided us.

19

This will be Exhibit 2.

Mr. Simpson, on the third page of this

20

document, the last two entries appear to be e-mails

21

sent on October 27, 2016 from Peter Fritsch to Mark

22

Cymrot CC'g you.

23

was Fusion GPS still working for Mr. Cymrot on --

24

still working for Baker Hostetler on the Prevezon

25

case as of the date of this e-mail?

To the best of your recollection,

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A. I don't know.

2

Q. The privilege asserted was attorney work

3

product.

Do you know what the basis of that was?

4

A. Well, it was a legal --

5

MR. LEVY:

This is a judgment that his

6

lawyers made and any knowledge he would have about

7

whether it was attorney work product or not likely

8

would come from communications with counsel, which

9

obviously are privileged.

10
11
12

BY MR. DAVIS:
Q. Did Fusion ever work with subcontractors
on its Prevezon or Magnitsky efforts?

13

A. Yes.

14

Q. Who were they?

15

MR. LEVY:

Just to clarify that, your

16

question was -- can you repeat the question,

17

please?

18

MR. DAVIS:

Sure.

Did Fusion ever work with

19

subcontractors on its Prevezon or Magnitsky

20

efforts?

21
22
23

MR. LEVY:

What do you mean by "Magnitsky

efforts"?
MR. DAVIS:

I mean all matters related to the

24

efforts with the media, government officials, and

25

campaigns -- or campaigns to overturn the Magnitsky

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Act, prevent the passage of the global Magnitsky

2

Act, remove the word Magnitsky from the law -- from

3

either law, as well as the Russian ban on U.S.

4

adoptions of Russian children.

5
6

MR. LEVY:

And you were also asking about

subcontractors for Prevezon as well?

7

MR. DAVIS:

I'm asking whether Fusion ever

8

worked with subcontractors on those issues.

9

BY THE WITNESS:

10

A. Well, I object to the question the way the

11

question is framed.

You've sort of built into the

12

question the sort of inference that we were doing

13

something other than working on a legal case, and

14

there's extensive public record, documentation in

15

Pacer of the work that we did and it was a legal

16

case.

17

because it's really hard for me to answer questions

18

where you lump in all these things that other

19

people were doing and impute them to me.

So I don't -- it's going to be difficult

20

Q. Let's break them down by category.

21

A. Let's do that.

22

Q. Did Fusion ever work with

23

subcontractors -- did Fusion ever hire

24

subcontractors as part of its legal work on the

25

Prevezon case?

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A. Yes.

2

Q. And whom did you hire?

3

A. I think the primary, possibly only one was

4

a guy named Edward Baumgartner.

5

been others.

6
7

I just don't recall.

Q. And what type of work did Mr. Baumgartner
undertake for Fusion?

8
9

There may have

A. Discovery mostly, helping locate
witnesses.

He speaks Russian.

So he would work

10

with the lawyers on gathering Russian language

11

documents, gathering Russian language media

12

reports, talking to witnesses who speak Russian,

13

that sort of thing.

14

press.

15
16

He may have dealt with the

I just don't remember.
MR. FOSTER:

What is his professional

background?

17

MR. SIMPSON:

He has a degree in Russian.

18

MR. FOSTER:

So his primary role was as a

19

Russian speaker?

20

What does he do?

21

Is he a private investigator?

MR. SIMPSON:

He runs a consulting firm like

22

me and deals with issues more in Ukraine than

23

Russia, but in both.

24

language things.

25

centered on events in Russia.

Yeah, he was doing Russian

The case revolved around,
So a lot of what we

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needed to find out were things that were in Russia

2

or there were documents in the Russian language.

3

don't speak Russian, I've never been to Russia.

4

it would be ordinary course of business for me to

5

identify a specialist who could supply me with that

6

kind of specialized expertise.

7

BY MR. DAVIS:

8
9
10

engagement?
A. I met him on a previous engagement and I
was impressed by his knowledge of the region and

12

his general abilities.

13

MR. FOSTER:

15
16

What was the previous

engagement?
MR. LEVY:
engagements.

We're not going to get into prior

It's outside the scope.

17

MR. FOSTER:

18

MR. SIMPSON:

19
20
21
22

Generally speaking, what was it?
It was something involving

Russia.
MR. FOSTER:

A little more specifically

speaking.
MR. SIMPSON:

It's my understanding that I

23

was not required to talk about my other cases at

24

this interview.

25

So

Q. And how did you come to hire him for this

11

14

I

MR. DAVIS:

Again, it's a voluntary interview

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and you are not under compulsion to answer any

2

questions, but, again, the extent to which you

3

cooperate will help the committee members evaluate

4

whether further compulsory process is necessary.

5
6
7
8
9

MR. LEVY:

He's been answering questions and

we're here all day for you.
MR. SIMPSON:

I'm here to cooperate.

BY MR. DAVIS:
Q. Did anyone from Fusion ever work with

10

other subcontractors hired by Baker Hostetler for

11

the Prevezon case?

12

A. That would have been ordinary.

I don't

13

specifically remember doing that, but it wouldn't

14

have been out of the ordinary.

15

particularly noteworthy.

16

Hostetler since 2009 on a number of legal cases.

17

This is the only one that involved Russia.

18

the course of any legal case, you know, various

19

people are retained by a law firm to perform

20

various services.

21

subcontractors in the course of doing legal work.

22

That's common.

23
24
25

It's not

I've worked with Baker

And in

So you would meet other

Q. What types of services would they tend to
be providing?
A. Translators would be common, in this case

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particularly.

2

people, all those services are facets of modern

3

litigation.

4

Forensic people, accountants, PR

Q. And to the best of your knowledge, did

5

Fusion ever work with any other contractors hired

6

by Prevezon Holdings?

7

A. I'm sorry.

8

Q. Sure.

9

Could you repeat that?

I asked if Fusion had hired any

subcontractors that you worked with on the Prevezon

10

matter, whether Baker hired anyone that you worked

11

with.

12

hired directly through Prevezon on this as opposed

13

to Baker Hostetler?

14

Now I'm wondering did you work with anyone

A. It's difficult to give a yes or no answer

15

to that.

I would have to say I think so, but when

16

you're a subcontractor to a law firm, you know,

17

you're sort of in a lane and, you know, my lane was

18

research, discovery, William Browder's business

19

practices, his activities in Russia, his history of

20

avoiding taxes.

21

So people -- other people, you know, in a big

22

case come and go and it's not really my position to

23

ask, you know, who hired them and why.

24

if I'm introduced to somebody they'll explain, you

25

know, why there were other lawyers who worked for

Generally

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Prevezon who were part of the case.

2

were brought in -- you know, were brought in either

3

by Prevezon or by the lawyers and I didn't always

4

try to pin that down.

5

Other people

Q. In general would the decision whether you

6

would share Fusion's information with them be

7

dependent then upon the attorneys introducing you

8

to them?

9

A. It would be dependent on the direction of

10

the attorneys.

11

these cases for reasons of privilege and simply

12

just professionalism you work at the direction of

13

the lawyers and you do what they instruct you to

14

do.

15

I basically -- you know, in all

Q. Did anyone from Fusion ever help arrange

16

for other entities to be hired by Prevezon or Baker

17

Hostetler for the Prevezon case?

18

A. I don't think you could say we arranged

19

for others to be hired.

20

made referrals, we would refer -- you know, we made

21

quite extensive -- fairly extensive efforts to get

22

a PR firm hired for the trial that we were

23

expecting and we made a number of referrals in that

24

case, in that matter.

25

If you're asking me if we

Q. What was the name of that PR firm?

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A. There were several.

We actually, you

2

know, had a series of screening sessions.

3

Weber Shandwick was the one we ended up with.

4

I think

Q. You mentioned that Fusion was conducting

5

litigation support in regard to the Prevezon case.

6

Could you expand a little more about what type of

7

litigation support activities you undertook?

8

MR. LEVY:

9

MR. DAVIS:

10
11

Beyond what he's already told you?
With a little more detail.

BY THE WITNESS:
A. Yes.

In the original period of the case

12

the question -- the client's explanation for or

13

response to the government's allegations was that

14

they originated with an organized crime figure in

15

Russia who had been extorting them and who they had

16

reported to the police and who had been jailed and

17

convicted for blackmailing them, and they claimed

18

that that was where these allegations originated,

19

which, you know, seemed remarkable because it was

20

in a Justice Department complaint.

21

So the first thing, you know, in any case

22

really is to sort of try and figure out whether

23

your own client's story can be supported or whether

24

it's not true, and the lawyers -- you know, we work

25

with a lot of prominent law firms and in many cases

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the first thing the lawyers need to know is whether

2

their client's story is real, whether it can be

3

supported, you know, because in any new case you

4

don't know whether your own client is telling you

5

the truth.

6

So originally one of the first things we were

7

hired to do was to check out whether this was, in

8

fact, the case.

9

allegations originated with a mobster named Demetri

So they claimed that the

10

Baranovsky, B-A-R-A-N-O-V-S-K-Y, who was, in fact,

11

jailed for running a shake-down operation in which

12

he posed as an anticorruption campaigner for the

13

purpose of extorting money from people by

14

threatening to accuse them of some kind of corrupt

15

activities.

16

corruption and there's a lot of anger over

17

corruption.

18

As you know, Russia is rife with

We were able to ascertain that Mr. Baranovsky

19

was, in fact, associated with Russia's biggest

20

organized crime family, the Solntsevo Brotherhood,

21

S-O-L-N-T-S-E-V-O brotherhood, which is the major

22

dominant mafia clan in Moscow.

23

went, the client seemed to be telling the truth.

24

You know, there was extensive record of these

25

events and we found some indications from western

So as far as it

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law enforcement that western law enforcement did

2

consider Baranovsky to be a lieutenant in this

3

organized crime family.

4

while.

5

because of his Russian language skills and his

6

ability to interface with the court system in

7

Russia.

8
9

So we did that for a

Edward Baumgartner helped a lot with that

And, you know, around the -- similarly, there
was a deposition of a customs agent by one of the

10

lawyers who -- you know, in this initial effort to

11

trace the origin of these allegations, where they

12

came from, how they could have ended up with the

13

Justice Department, the first thing we did was

14

interview the client, got their story, and

15

interviewed the agent who worked on the case for

16

the DOJ and that agent said he got all his

17

information from William Browder.

18

So at that point I was asked to help see if

19

we could get an interview with William Browder.

20

They wrote a letter to Browder and asked him to

21

answer questions and he refused.

22

wanted to know, you know, whether he could be

23

subpoenaed.

24

help them figure out whether he could be subpoenaed

25

in the United States to give a deposition, and the

Then the lawyers

So a lot of what I did in 2014 was

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first thing that we did was we researched the

2

ownership and registration of his hedge fund, which

3

was registered in Delaware and filed documents with

4

the Securities and Exchange Commission.

5

So we subpoenaed his hedge fund.

A lot of

6

the early work I did was just documenting that his

7

hedge fund had presence in the United States.

8

we subpoenaed his hedge fund.

9

hedge fund registration, took his name off, said it

So

He then changed the

10

was on there by accident, it was a mistake, and

11

said that he had no presence in the United States

12

and that, you know -- as you may know, he

13

surrendered his citizenship in 1998 and moved

14

outside the United States.

15

time he started making all the money in Russia.

16

he's never had to pay U.S. taxes on his profits

17

from his time in Russia, which became important in

18

the case later.

19

That was around the
So

In any case, he said he never came to the

20

United States, didn't own any property here, didn't

21

do any business here, and therefore he was not

22

required to participate in the U.S. court system

23

even though he admitted that he brought the case to

24

the U.S. Justice Department.

25

be a frustrating and somewhat curious situation.

So we found this to

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He was willing to, you know, hand stuff off to the

2

DOJ anonymously in the beginning and cause them to

3

launch a court case against somebody, but he wasn't

4

interesting in speaking under oath about, you know,

5

why he did that, his own activities in Russia.

6

So looking at the public record we determined

7

that he did come to the United States frequently,

8

and I discovered through public records that he

9

seemed to own a house in Aspen, Colorado, a very

10

expensive mansion, over $10 million, which he had

11

registered in the name of a shell company in a

12

clear attempt to disguise the ownership of the

13

property.

14

use that property because he registered cars to

15

that property with the Colorado DMV in the name of

16

William Browder.

We were able to ascertain that he does

17

So we began looking for public information

18

about when he might be in Aspen, Colorado, and I

19

found a listing on the Aspen Institute Website

20

about an appearance he was going to make there in

21

the summer of 2014.

22

subpoena in the parking lot of the Aspen Institute

23

in the summer of 2014 using two people -- two

24

subcontractors.

25

subcontractors were -- their names escape me, but I

So we -- I served him a

Actually, those other

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forgot about those.

2

all in the Pacer court record, the public court

3

record.

4

We can get you that.

This is

In any event, the three of us served -- there

5

was another subcontractor working for the law firm

6

whose name I also forget.

7

but I was asked to work with him on this.

8

private investigator and we can get you his name.

9

In any event, we served him the subpoena and he ran

I did not retain him,
He is a

10

away.

11

He jumped in his car and went back to his mansion.

12

He dropped it on the ground and he ran away.

At that point he tried to suppress -- tried

13

to quash the subpoena on the grounds it hadn't been

14

properly served.

15

are sworn affidavits from my servers in the court

16

record about the service.

17

a number of grounds.

18

had nothing to do with the United States and didn't

19

come here very often even, though we caught him

20

here, clearly has cars in Colorado.

21

that you can't serve a subpoena for a case in

22

New York in the state of Colorado, it's outside the

23

primary jurisdiction.

24

questions about whether Baker Hostetler had a

25

conflict of interest because of some previous work

We didn't get a video, but there

But he objected to it on

A, he continued to insist he

He also said

He also began to raise

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he did with one of the Baker lawyers.

2

This led to a long, drawn-out discovery

3

battle that I was in the center of because I served

4

the subpoenas and I helped find the information for

5

the first set of subpoenas that lasted, you know,

6

through 2014.

7

did.

8

get William Browder to testify under oath about his

9

role in this case and his activities in Russia.

10

This was, you know, a lot of what I

This was -- the main focus was on trying to

All of this -- his determined effort to avoid

11

testifying under oath, including running away from

12

subpoenas and changing -- frequently changing

13

lawyers and making lurid allegations against us,

14

including that, you know, he thought we were KGB

15

assassins in the parking lot of Aspen, Colorado

16

when we served the subpoena, all raised questions

17

in my mind about why he was so determined to not

18

have to answer questions under oath about things

19

that happened in Russia.

20

I'll add that, you know, I've done a lot of

21

Russia reporting over the years.

I originally met

22

William Browder back when I was a journalist at the

23

Wall Street Journal when I was doing stories about

24

corruption in Russia.

25

him he lectured me about -- I was working on a

I think the first time I met

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story about Vladimir Putin corruption and he

2

lectured me about how have Vladimir Putin was not

3

corrupt and how he was the best thing that ever

4

happened to Russia.

5

that he published himself, interviews he gave

6

singing the praises of Vladimir Putin.

7

time I was already investigating corruption in

8

Putin's Russia.

9

There are numerous documents

At that

So this made me more curious about the

10

history of his activities in Russia and what that

11

might tell me about corruption in Russia, and as

12

part of the case we became curious about whether

13

there was something that he was hiding about his

14

activities in Russia.

15

we were attempting to get him under oath we were

16

also investigating his business practices in Russia

17

and that research -- and I should add when I say

18

"we," I mean the lawyers were doing a lot of this

19

work and it wasn't -- I can't take responsibility

20

or pride of place on having done all this work.

21

were doing it all together.

22

there were a number of lawyers involved, other

23

people.

24
25

So through this period while

We

It was a -- you know,

In the course of doing this research into
what he might not want to be asked about from his

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history in Russia we began to learn about the

2

history of his tax avoidance in Russia and we began

3

to deconstruct the way that his hedge fund

4

structured its investments in Russia and, you know,

5

we gradually accumulated through public records,

6

not all from Russia, that he set up dozens of shell

7

companies in Cyprus and other tax havens around the

8

world to funnel money into Russia and to hold

9

Russian securities.

10

He also set up shell companies inside of

11

Russia in order to avoid paying taxes in Russia and

12

he set up shell companies in a remote republic

13

called Kalmykia, K-A-L-M-Y-K-I-A, which is next to

14

Mongolia.

15

Russia and there's nothing much there, but if you

16

put your companies there you can lower your taxes.

17

They were putting their companies in Kalmykia that

18

were holding investments from western investors and

19

they were staffing these companies -- they were

20

using Afghan war veterans because there's a tax

21

preference for Afghan war veterans, and what we

22

learned is that they got in trouble for this

23

eventually because one of Putin's primary rules for

24

business was you can do a lot of things, but you've

25

got to pay your taxes.

It's the only Buddhist republic in

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In fact, William Browder famously said in

2

2005 at Davos everybody knows under Putin you have

3

to pay your taxes, which is ironic because at the

4

time he was being investigated for not paying

5

taxes.

6

companies were prosecuted, and he was forced to

7

make an enormous tax payment to the government of

8

Russia in 2006.

9

Ultimately they were caught, some of these

I will add that Sergei Magnitsky was working

10

for him at this time and all of this happened prior

11

to the events that you are interested in involving

12

the Russian treasury fraud and his jailing.

13

precedes all that.

14

This

But returning to the detailed discussion of

15

my work, we investigated William Browder's business

16

practices in Russia, we began to understand maybe

17

what it was he didn't want to talk about, and as we

18

looked at that we then began to look at his

19

decision to surrender his American citizenship in

20

1998.

21

papers came out and we discovered that he had

22

incorporated shell companies offshore in the mid

23

1990s, in 1995 I believe it was in the British

24

Virgin Islands, and that at some point his hedge

25

fund's shares had been transferred to this offshore

At that point somewhere in there the Panama

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company.

2

This offshore company was managed -- several

3

of his offshore companies were managed by the

4

Panamanian law firm called Mossack Fonseca,

5

M-O-S-S-A-C-K, Fonseca, F-O-N-S-E-C-A, which is

6

known now for setting up offshore companies for

7

drug kingpins, narcos, kleptos, you name it.

8

were servicing every bad guy around.

9

familiar with them from other money laundering and

They

And I'm

10

corruption and tax evasion investigations that I've

11

done.

12

I'll note parenthetically that William

13

Browder talks a lot about the Panama papers and the

14

Russians who are in the Panama papers without ever

15

mentioning that he's in the Panama papers.

16

is, again, a public fact that you can check

17

on-line.

18

This

So that's an overview of the sort of work I

19

was doing on this case.

In the course of that I

20

also began reaching back, I read his book Red

21

Notice to understand his story and the story of his

22

activities in Russia.

23

extremely sympathetic for what happened to Sergei

24

Magnitsky and I told him that myself and I tried to

25

help him.

I'll add also that I was

It was only later from this other case

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that I began to be curious and skeptical about

2

William Browder's activities and history in Russia.

3

MR. FOSTER:

Can I ask you a follow-up

4

question.

I appreciate the narrative answer, but

5

at the very beginning of the narrative you talked

6

about beginning this journey by interviewing --

7

conducting an interview of the case agent who said

8

he'd gotten all of his information -- the case

9

agent or the attorney, the primary person at the

10

DOJ, you said they got all their information from

11

Bill Browder.

12

conducted the interview?

Can you tell us who that was and who

13

MR. LEVY:

14

answer that question.

15

the record that he hadn't finished his answer.

16

can talk more extensively about the litigation

17

support that he provided for Baker --

18

MR. FOSTER:

Mr. Simpson should definitely
I just want to make sure for
He

We're happy to get into that if

19

he wants to do that.

20

end of our hour.

21

MR. LEVY:

22

MR. FOSTER:

23

follow-up in before --

24

MR. LEVY:

25

BY THE WITNESS:

We're just coming up at the

No problem.
and I wanted to get that

No problem.

No problem at all.

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1
2

A. I'll just finish with one last thing and
I'm happy to answer that question.

3

So in the course of this, you know -- I mean,

4

one of my interests or even obsessions over the

5

last decade has been corruption in Russia and

6

Russian kleptocracy and the police state that was

7

there.

I was stationed in Europe from 2005 to 2007

8

or '8.

So I was there when Putin was consolidating

9

power and all this wave of power was coming.

So

10

it's been a subject that I've read very widely on

11

and I'm very interested in the history of Putin's

12

rise.

13

You know, in the course of all this I'll tell

14

you I became personally interested in where Bill

15

Browder came from, how he made so much money under

16

Vladimir Putin without getting involved in anything

17

illicit.

18

other research and I found filings at the SEC

19

linking him quite directly and his company, Salomon

20

Brothers at the time, to a company in Russia called

21

Peter Star, and I had, as it happens, vetted Peter

22

Star and I knew that Peter Star was, you know, at

23

the center of a corruption case that I covered as a

24

reporter at the Wall Street Journal.

25

back into the history of Peter Star I realized that

So I read his book and I began doing

When I went

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Bill Browder did business with the mayor's office

2

in Saint Petersburg when Vladimir Putin was the

3

deputy mayor and was responsible for dealing with

4

western businessmen and corporations.

5

I then went and looked in Red Notice, this

6

was a large deal, it was the biggest deal ever for

7

Salomon at that time, they sold $98 million worth

8

of stock on NASDAQ.

9

Browder's deal with Peter Star in Red Notice.

There's no mention of William
I

10

can't tell you why, but I can tell you that Peter

11

Star later became the subject of a massive

12

corruption investigation, Pan-European, that I

13

exposed a lot of and that led to the resignation of

14

Putin's telecoms minister.

15

not have -- this is kind of a pattern with Browder,

16

which is he tends to omit things that aren't

17

helpful to him, and I think we've seen a good bit

18

of that lately in his allegations against me, which

19

I'm sure you're going to ask me about.

20

So I assume he might

So your question about the ICE agent, he was

21

deposed by John Moscow of the New York office of

22

Baker Hostetler.

23

from my days as a journalist.

24

tax evasion and money laundering.

25

of the rackets bureau for the district attorney's

John is an old associate of mine
John's an expert on
He was the head

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1

office in New York.

2
3

MR. FOSTER:

You're talking about a formal

deposition in the litigation?

4

MR. SIMPSON:

5

MR. FOSTER:

6

MR. SIMPSON:

Yeah.
I just wanted to clarify that.
Again, it's in the court

7

record.

One of the frustrating things about this

8

whole issue for me is everything I'm talking about

9

or most of it is in the court record.

You know, I

10

don't take a lot of credit for my work.

11

won't see my name scattered through the court

12

record, but a lot of this is what I did.

13

MR. DAVIS:

14

first hour.

15

begin a new one.

So you

I think that's concludes our

Let's take a short break before we

16

MR. FOSTER:

Let's go off the record.

17

MR. DAVIS:

We'll go off the record at

18

10:45.

19
20

(A short break was had.)
MS. SAWYER:

21
22
23

It's about 10:55.
EXAMINATION

BY MS. SAWYER:
Q. Mr. Simpson, again, I'm Heather Sawyer, I

24

work as counsel for Senator Feinstein, and I have

25

with me two of my colleagues.

I will primarily be

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asking the questions.

2

follow-up.

3

They may have some

We want to make sure we're clear.

So

4

certainly if I ask you a question, anything that's

5

unclear, let me know and I will clarify it.

6

we appreciate you being here today to answer our

7

questions.

8
9

Again,

You had talked with my colleagues a bit about
the work that Fusion GPS does in general and I

10

wanted to ask you some follow-up on that.

What

11

would you describe as kind of the key expertise of

12

your firm, Fusion GPS?

13

A. Public information is our specialty.

14

generally are all ex-journalists and specific type

15

of journalists, investigative reporters, and, you

16

know, being a journalist is all about finding

17

public information.

18

of journalism I practiced was based on documents.

19

I'm a document hound and so are my colleagues.

20

We

At least, you know, the kind

So essentially we gather up large quantities

21

of public information and we process that.

We've

22

sort of more recently branched into data science

23

and, you know, digital data, obtaining databases

24

through FOIA.

25

Information Act work.

We do a lot of Freedom of
We work with court records

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a lot, corporate records a lot.

2

employees do a lot of financial crime and money

3

laundering and fraud investigations, tax evasion,

4

that sort of thing.

5

Some of my

Those are my specialties.

I was also a political reporter and covered

6

campaigns and elections.

I know a lot about how

7

campaigns work and how, you know, Washington works

8

generally.

9

one industry versus another, one company versus

So we do things like policy disputes,

10

another.

11

but every four years for the last couple of cycles

12

we've done some presidential work.

13

We don't do a lot of campaign consulting,

Generally speaking, the way our business is

14

structured most campaigns don't have the budget for

15

the kind of services that we provide.

16

would do things where people have the resources to

17

pay for a serious piece of research.

18

things like a California initiative or

19

presidential.

20

So we only

So we do

Q. And how would you describe like how would

21

you pitch and why would a client need your

22

services?

23

A. Generally speaking, people tend to get

24

referred to us when they have a sort of undefined

25

need, like they feel like they don't know what

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happened or they don't know what happened, they

2

don't know what's going on.

3

I referred to earlier as the decision support part

4

of our work.

So I think that's what

5

You know, a client will come to us and

6

they'll say I'm being sued and they're accusing me

7

of X and, you know, not only did I not do it, but I

8

don't even understand why they're suing me.

9

mean, that's a kind of typical thing.

I

Also another

10

example would be I think I've been defrauded, but I

11

can't figure out how or why.

12

know, I run the best company in my industry and,

13

you know, we make the best widgets and we keep

14

losing out on the Pentagon contract to this other

15

guy and we think something fishy's going on and we

16

want you to help us figure it out.

17
18
19

Or I keep -- you

Q. So in some ways it's fact gathering and
due diligence for clients?
A. Well, it is certainly fact gathering and I

20

certainly am around the due diligence industry and

21

I am essentially part of it, but we don't really do

22

a lot of classic due diligence, which has become a

23

commoditized product in the business intelligence

24

field that is conducted, you know, at a fairly sort

25

of low level.

it's become sort of a mass product

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1
2

like a McDonald's cheeseburger.
Q. I think when you were speaking with my

3

colleagues you described your work as open ended

4

and not results directed.

5

more what you mean by that?

6

A. Sure.

Can you explain a little

Another thing we say about our work

7

is it's custom information, it's a customized

8

product.

9

customize a research solution.

You tell us what your problem is and we
In general when

10

people come to us and they tell us what their

11

challenge is, we stipulate that they retain us for

12

30 days, they agree to pay our fee, they don't tell

13

us what to do, they don't tell us, you know, what

14

result to get.

15

methodology.

I like to call it a holistic

16

The reason we do it that way, you know, A, we

17

are professionals and we feel like it's not helpful

18

to have someone dictating how you do things, but,

19

B, if you predetermine the result that you're

20

looking for you tend to miss things.

21

better -- you know, it's pure versus applied

22

science, right?

23

things work before you understand what you might

24

need to address a particular problem.

25

So it's

You're looking to understand how

What happens after you've done open-ended

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research is then, of course, you try to apply it to

2

the specific issues at hand.

3

to get a government contract and you think the

4

other guy is up to something and we find out, you

5

know, indeed he's been making, you know, payments

6

to somebody, you know, then we would, you know,

7

advise them on how to address that.

So if you're not able

8

Q. So the way it's structured you are

9

certainly free to follow the facts wherever they

10
11

may lead you in the course of research?
A. That's right.

You know, it's a little

12

different in litigation where you're working for an

13

attorney and he's got specific things he needs,

14

like serving a witness or something like that, but

15

on the research side of it it's -- I have the

16

professional -- basically I reserve for myself the

17

professional freedom to find out the answers.

18

Q. A January 11, 2017 New York Times article

19

described your firm, Fusion GPS, as a firm that

20

"Most often works for business clients, but in

21

presidential elections the firm is sometimes hired

22

by candidates, party organizations, or donors to do

23

political oppo work, short for opposition research

24

on the side."

25

Is that an accurate description of the firm?

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1

A. In a shorthand way, yeah.

I mean, it's

2

consistent with the description I think I gave you.

3

We don't do a lot of campaign work, but, you know,

4

every few years we do.

5

not trying to win an election.

6

win a lawsuit or, you know, find out who ripped

7

them off.

8
9

And most of our clients are
They're trying to

Q. With regard to the political or campaign
work that you do, the same principles you've talked

10

about in terms of how the relationship is

11

structured, how the research is done, do those same

12

principles apply to that political or campaign

13

research as well?

14

A. Yes.

There's a limited number of examples

15

because we don't do a lot of it, but, again, my

16

specialty is really sort of financial

17

investigations and business practices.

18

last -- you know, in a current example we have a

19

businessman who had a far-flung business empire all

20

around the world.

21

subject for me.

22

multinational enterprises on a frequent basis.

23
24
25

In the

So, you know, that was a natural
So we do, we investigate

Q. Just to be clear, when you say "in the
current example," what are you referring to?
A. 2016 presidential election.

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Q. And then, by extension, when you're

2

talking about an international businessman, I

3

presume you're talking about then candidate now

4

President Trump?

5

A. Yes.

6

Q. I do want to ask you more about that, but

7

before we get to that, in general, when you do the

8

political or campaign work you're equally free to

9

follow the facts wherever they lead you and the

10

firm Fusion GPS?

11

A. Yes, that's right.

12

Q. Now, certainly it sounds like you handle

13

business for multiple clients, not just one client

14

at one time.

15

have work for more than one client in terms of

16

protecting confidentiality in general and

17

ensuring -- well, first of all, I presume that you

18

take steps so that work for one client is not

19

shared with another client?

How do you handle the fact that you

20

MR. LEVY:

What's the question?

21

MS. SAWYER:

Do you take steps to ensure that

22

work that you're doing for one client is not shared

23

with another client?

24

BY THE WITNESS:

25

A. Yes.

My partners and I don't talk

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about -- it's like a lawyer wouldn't talk about one

2

client to another client.

3

exceptions when things become public.

4

working on a public matter and someone else asks us

5

about it, I mean, obviously if it's public it's not

6

-- it doesn't need to be protected.

7

systems to segregate our cases and clients and, you

8

know, we deal with them individually and we operate

9

in that sense, you know, like a lawyer would.

10

You know, there's some
If we're

But we have

As the business has grown, you know, we've

11

taken on more and more matters.

12

know, I generally do about a half a dozen cases at

13

a time on all range of subjects in all parts of the

14

world, and the same is true of my partners and we

15

divide them up.

16

frequently each of them will be doing three, four,

17

five cases at a time.

18

So I don't -- you

So sometimes we work together, but

Q. With regard to subcontractors who work

19

with the firm, do you have a policy that is shared

20

with them about how they are to treat the

21

information that they're doing on behalf of one of

22

your clients vis-a-vis some of your other clients?

23

A. Well, our subcontractors are governed by

24

NDA's to start with.

In most cases that I can

25

think of we don't have one subcontractor working on

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more than one matter, but to the extent that would

2

happen, we don't really -- when you're dealing with

3

subcontractors you're giving them generally very

4

specific assignments, find out what you can about

5

this company or this businessman or this court

6

case, whatever, and a lot of that you never get

7

into who the client is.

It's irrelevant.

8

I'd say more often than not the

9

subcontractors don't know who the client is.

We

10

would not volunteer that information to them unless

11

they were what we would call a super sub, which is

12

someone who, you know, has worked with us for a

13

long time and has enough trust and confidence to be

14

involved.

15

need-to-know basis.

16

subcontractor to know who a client is unless it's

17

for, you know, KYC, know your customer kind of due

18

diligence purposes.

19

to prevent conflicts.

20

like that or because they need to meet with the

21

client, you know, we generally wouldn't tell them

22

who the client is.

23

Again, it would also be on a kind of
There's no need for a

Sometimes we identify clients
So unless there's a reason

Q. So you had mentioned a few minutes ago

24

that you had done some political or campaign

25

research in the course of the 2016 presidential

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election and you clarified that that was work

2

related to then Candidate and now President Trump.

3

What can you tell us about that work?

4

describe it first generally and then I'll ask you

5

some follow-up.

6

Can you just

A. It was, broadly speaking, a kind of

7

holistic examination of Donald Trump's business

8

record and his associations, his bankruptcies, his

9

suppliers, you know, offshore or third-world

10

suppliers of products that he was selling.

11

know, it evolved somewhat quickly into issues of

12

his relationships to organized crime figures but,

13

you know, really the gamut of Donald Trump.

14

You

What we generally do at the beginning of a

15

case if it's possible is to order all the books

16

about the subject from Amazon so we're not

17

reinventing the wheel and we know what's been

18

written and said before.

19

ordered every Donald Trump book and, to my

20

surprise, that's a lot of books.

21

interested in Donald Trump.

22

political figure that I'd ever had any exposure to.

23

He's a New York figure really.

24
25

So this was typical.

We

I was never very

He was not a serious

So anyway, we read everything we could read
about Donald Trump.

Those books cover his

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divorces, his casinos, his early years dealings

2

with labor unions and mafia figures.

3

think what else.

4

been a big issue.

5

unlimited look at his -- you know, his business and

6

finances and that sort of thing.

I'm trying to

His taxes certainly have always
Again, it was sort of an

7

Q. And when did this work begin?

8

A. It was either September or October of

9

2015.

I recall being in London on other business

10

and hearing somebody wanted for us to take a look

11

at it.

12
13

Q. And what can you tell us about who engaged
you initially to do that work?

14

MR. LEVY:

15

implicate privilege.

16

BY MS. SAWYER:

17

The answer to that question might

Q. So it has been publicly reported that the

18

initial engagement of September to October 2015 was

19

by someone with ties -- with Republican ties.

20

you confirm whether that is accurate or not?

21

MR. LEVY:

22

identity of clients.

23

BY MS. SAWYER:

24
25

Can

We're not going to talk about the

Q. So with regard to this engagement in
September -- that began initially in September or

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October 2015, what were you asked specifically to

2

do by the client?

3

A. I don't have specific recollection of

4

there being a specific tasking.

5

why don't you take a look at Donald Trump, it looks

6

like he may, you know, be more successful than

7

people think, something -- there was some level of

8

insight that he had a better shot than people were

9

giving him at the time, but it was on open-ended

10
11

I believe it was

request like most of the things that we get.
Q. And, again, on that one was the work

12

directed at all by the client?

Did they ask you to

13

look at any particular aspects of Candidate Trump's

14

background?

15

A. I don't -- I know there was --

16

MR. LEVY:

17

communications.

18

BY MS. SAWYER:

We're not going to get into client
It's privileged.

19

Q. Were you in any way limited in the

20

research that you did or the facts that you wanted

21

to pursue?

22
23

A. Can I talk generally about my practices
and the history?

24

Q. Sure.

25

A. I mean, in general it's very rare for

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someone to tell me look here, don't look there.

2

For the most part we are looking at -- you know,

3

we're trying to understand something big.

4

really counterproductive for somebody to tell you

5

look here, don't look there, I'm interested in X

6

but not Y.

7

that happens, but I have to say we sort of set the

8

rules at the beginning and people, you know,

9

accepted those terms.

So it's

So we generally sort of push back when

So generally that's what we

10

explain to people in the beginning of our

11

engagements, you know, let us do our jobs and

12

that's the way it works best.

13

Q. And did that -- can you tell us whether

14

that general practice and rule applied to the

15

engagement that you took on in September or October

16

2015 with regard to Candidate Trump?

17

MR. LEVY:

You can answer that without

18

getting into client communications.

19

BY THE WITNESS:

20

A. I mean, we were -- it was regular order.

21

As, you know, various people will tell you, I'm --

22

you know, it would be like herding a cat, right?

23

We're going to do what we do.

24

order.

25

So it was regular

Q. And then when you spoke with my colleagues

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earlier you had indicated that sometimes when facts

2

are gathered you present options to a client and

3

you articulated kind of four options, a potential

4

lawsuit, take it to a government agency, give it to

5

Congress, give it to the press.

6

those the general options on the table with regard

7

to this engagement as well?

8
9

MR. LEVY:

Did you -- were

If you can discuss it without

talking about client communications.

10

you can't.

11

BY THE WITNESS:

12

If you can't,

A. I'm just trying to -- because it evolved

13

it's a little bit hard to -- I mean, in the

14

beginning of this case like pretty much every case

15

there was no -- there was no range of options --

16

there weren't -- it was a request to see what we

17

could find out about Donald Trump and the, you

18

know, goal or sort of reason, there wasn't really

19

one.

20

this guy.

21

getting press inquiries and at that point, you

22

know, the sort of press element enters the

23

equation, but I can't really get into what they

24

told me or didn't tell me to do.

25

It was tell me what we need to know about
So later on, you know, we started

Q. And are you free today to talk to us about

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any of the actual findings from that research and

2

that engagement?

3

A. Yes.

4

Q. Okay.

So with regard to that initial

5

engagement because you had talked a bit about some

6

of the research you had done -- I think you said it

7

was holistic, financials, potential ties to

8

organized crime.

9

engagement that started in October, September, can

10
11

With regard to this initial

you just explain for us what your findings were.
A. I guess I'll just give you the caveat

12

that, you know, it's a group effort.

13

you, you know, as the person that was, you know,

14

running the project, you know, I had my fingers in

15

various things, but there were also the things that

16

I was directly focused on.

17

So I can tell

In the early -- the very first weekend that I

18

started boning up on Donald Trump, you know, I

19

found various references to him having connections

20

to Italian organized crime and later to a Russian

21

organized crime figure named Felix Sater,

22

S-A-T-E-R.

23

great achievement, it was in the New York Times,

24

but as someone who has done a lot of Russian

25

organized crime investigations as a journalist

It wasn't hard to find, it wasn't any

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originally that caught my attention and became

2

something that, you know, I focused on while other

3

people looked at other things.

4

So from the very beginning of this organized

5

crime was -- Russian organized crime was a focus of

6

interest.

7

this is a subject that I covered extensively at the

8

Wall Street Journal.

9

page articles about various corrupt politicians

I guess I should just repeat, you know,

I wrote a series of front-

10

from Russia, oligarchs, and one of the things that

11

I wrote about was the connections between western

12

politicians and Russian business figures.

13

know, I was sort of an amateur student of the

14

subject and I had written about some of these same

15

Russian crime figures, you know, years earlier in

16

the U.S. and various frauds and things they were

17

involved in.

18

So, you

As it happens, Felix Sater was, you know,

19

connected to the same Russian crime family that was

20

at issue in the Prevezon case, which is the

21

dominant Russian crime family in Russia and has a

22

robust U.S. presence and is involved in a lot of

23

crime and criminal activity in the United States

24

and for many years was the -- the leader of this

25

family was on the FBI most wanted list and lives

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openly in Moscow as a fugitive from U.S. law for a

2

very elaborate stock fraud.

3

Q. Who is that individual and family?

4

A. The first name is Semyon, S-E-M-Y-O-N, the

5

last name is Mogilevich, M-O-G-I-L-E-V-I-C-H.

6

Mogilevich is sometimes referred to as the brainy

7

Don because he runs very sophisticated schemes

8

including, according to the FBI, involving natural

9

gas pipelines in Europe, and he's wanted in

10

connection with an elaborate stock fraud called YBM

11

Magnex that was took place in the Philadelphia

12

area.

13

You know, Russian organized crime is very

14

different from Italian organized crime.

15

more sort of a hybrid kind of thing where they're

16

involved in politics and banking and there's even a

17

lot of connections between the mafia and the KGB or

18

the FSB and cyber crime, things that the Italians

19

sort of never figured out.

20

particular was the big thing in the U.S.

21

event, all of that entered into my thinking when I

22

saw that Donald Trump was in business with Felix

23

Sater in the Trump Soho project and a number of

24

other controversial condo projects.

25

It's much

Stock fraud in
In any

Q. And what, if anything, did you conclude

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about the connection between and in the business

2

dealings that then Candidate Trump had had with

3

Mr. Sater?

4

A. Well, somewhat analogous to the Browder

5

situation I found it notable this was something he

6

didn't want to talk about and testified under oath

7

he wouldn't know Felix if he ran into him in the

8

street.

9

in fact, continued to associate with him long after

That was not true.

He knew him well and,

10

he learned of Felix's organized crime ties.

11

you know, that tells you something about somebody.

12

So I concluded that he was okay with that and that

13

was a troubling thing.

14

to -- I keep saying I, but we as a company began to

15

look at where his money came from and, you know,

16

that raised a lot of questions.

17

that some of the money came from Kazakhstan, among

18

other places, and that some of it you just couldn't

19

account for.

20

So,

I also, you know, began

We saw indications

You know, we also conducted a much broader

21

sort of look at his entire career and his overseas

22

investments in places like Europe and Latin

23

America.

24

focused investigation for the first half of it.

25

That was just one component of a broader look at

You know, it wasn't really a Russia

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his business career, his finances.

2

of time trying to figure out whether he's really as

3

rich as he says he is because that was the subject

4

of a libel case that he filed against a journalist

5

named Tim O'Brien for which there was quite a lot

6

of discovery and litigation filings detailing

7

O'Brien's allegation that he was worth, you know,

8

maybe a fifth to a third of what he claims and

9

Trump's angry retort that he was worth far more

10
11

We spent a lot

than that.
So we did things like we looked at the golf

12

courses and whether they actually ever made any

13

money and how much debt they had.

14

bankruptcies, how could somebody go through so many

15

bankruptcies, you know, and still have a billion

16

dollars in personal assets.

17

of things.

We looked at a lot of things like his

18

tax bills.

Tax bills are useful because you can

19

figure out how much money someone is making or how

20

much they're worth or how much their properties are

21

worth based on how much they have to pay in taxes.

22

One of the things we found out was that, you

We looked at the

So those are the kinds

23

know, when it comes to paying taxes, Donald Trump

24

claims to not have much stuff.

25

organization.

At least the Trump

So they would make filings with

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various state and local authorities saying that

2

their buildings weren't worth much.

3

Q. And this information that you gathered,

4

was it shared with the client that you had for that

5

September, October engagement?

6

A. I can't answer that.

7

MS. QUINT:

When you said you looked at the

8

golf courses and bankruptcies, just to clarify,

9

everything you're talking about was for that 2015

10

engagement?

When you say it wasn't Russia focused

11

at first, I'm unclear of the time.

12

MS. SAWYER:

13

engagement ended?

14
15
16

MR. LEVY:

Yeah.

Can you tell us when that

Which question is pending?

Can

you repeat the question?
MS. QUINT:

I think they're related.

I lost

17

track when you said you looked at golf courses,

18

bankruptcies, tax bills and it was not initially

19

Russia centric.

20

make sure we're all on the same page.

21

I'm wondering the time frame to

MR. SIMPSON:

It's difficult to specifically

22

recall when we did exactly what.

For example, the

23

specific issue of the golf courses I think did come

24

up later, much later, but these things run in

25

stages.

For instance, in the early stage of an

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investigation, you know, particularly of Donald

2

Trump you want to get every lawsuit the guy's ever

3

been in.

4

around the country and the world.

5

remember one of the earlier things we did was we

6

collected a lot of documents from Scotland because

7

he'd been in a big controversy there about land

8

use.

9

was a lot of Freedom of Information Act requests

10

So, you know, we collected lawsuits from
And I do

There had been another one in Ireland.

There

and that sort of thing.

11

So in the early phases of something you're

12

collecting lots of paper on every subject

13

imaginable.

14

litigation we would follow up on things that were

15

interesting, such as a libel case against a

16

journalist that he settled, which, in other words,

17

he didn't prevail in his attempts to prove that he

18

was a billionaire.

19

BY MS. SAWYER:

20

So in the course of reading that

Q. So one way to help clarify this is just

21

to -- you know, we had been talking about an

22

engagement that began in September or October of

23

2015.

24

engagement ended?

25

Can you tell us when that particular

A. I can only estimate it.

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2

Q. And in general when do you think that
ended?

3

A. Spring of 2016.

4

MR. LEVY:

5

MR. SIMPSON:

6

BY MS. SAWYER:

7

Q. Okay.

Don't guess.
I'm sorry.

But that engagement did come to an

8

end and it came to an end before November 8th, the

9

election, November 8, 2016?

10

A. It did end before the election, yes.

11

Q. And then did you continue doing opposition

12

work on Candidate Trump -- then Candidate Trump,

13

now President Trump for a different client?

14

A. Yes.

15

Q. And can you tell us generally when that

16

engagement began?

17

A. It was in the first half of 2016.

18

Q. And what, if anything, can you tell us

19

about that client?

20

A. Nothing.

21

MR. LEVY:

22

Not nothing as a factual matter,

but he's going to decline to answer that question.

23

MS. SAWYER:

24

declining that question?

25

MR. LEVY:

And the basis again for

Privilege.

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MS. SAWYER:

2

MR. LEVY:

3

And other obligations of

confidentiality.

4
5

Okay.

MS. SAWYER:

Just to be clear for the record,

specifically what privilege?

6

MR. LEVY:

The privileges that we previously

7

asserted with the committee.

8

April 7 and June 23 letters.

9
10

MS. SAWYER:

They're in our

Okay.

BY MS. SAWYER:

11

Q. With regard to the engagements, both of

12

these engagements to do opposition research on

13

Candidate Trump, were you paid directly by each of

14

the clients or was there an intermediary paying

15

you?

16
17
18

A. I think I'd like to confer with my lawyer
about this.
MR. LEVY:

Sure.

19

(Whereupon a discussion was had

20
21
22
23
24
25

sotto voce.)
MR. SIMPSON:

I'm going to decline to answer

that question.
MS. SAWYER:

And, again, the grounds for

declining?
MR. LEVY:

It's a voluntary interview and it

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would implicate privileges and obligations that

2

we've set forth with the committee potentially.

3
4
5

MS. SAWYER:

Sure.

BY MS. SAWYER:
Q. At a news briefing on August 1, 2017 White

6

House Press Secretary Sarah Huckabee Sanders

7

described Fusion GPS as a democratic linked firm.

8

Is that an accurate description?

9

A. I would not agree with that description.

10

I was a journalist for most of my adult life and a

11

professional at not taking sides, and I'm happy and

12

proud to say I have lots of Republican clients and

13

friends and I have lots of Democratic clients and

14

friends.

15

so and I know a lot of people on both sides and we

16

have a long proud history of not being partisan.

17

And the same is true for my colleagues.

18

intentionally don't hire people who have strong

19

partisan affiliations.

20

don't see things through ideological prisms and

21

ideological prisms are not helpful for doing

22

research.

23

I've lived in this city for 30 years or

We

We prefer journalists who

Q. So it has been widely reported that you

24

engaged Christopher Steele to do part of the

25

research, the opposition research on Candidate

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Trump.

Is that accurate?

2

A. Yes.

3

Q. And he was working in that capacity as a

4

subcontractor for you?

5

mean Fusion GPS.

And when I say "you" here I

6

A. Yes.

7

Q. And when did you engage Mr. Steele to

8

conduct opposition research on Candidate Trump?

9

A. I don't specifically recall, but it would

10

have been in the -- it would have been May or June

11

of 2016.

12
13
14

Q. And why did you engage Mr. Steele in May
or June of 2016?
A. That calls for a somewhat long answer.

We

15

had done an enormous amount of work on Donald Trump

16

generally at this point in the project and we began

17

to drill down on specific areas.

18

only subcontractor that we engaged.

19

the world required other people.

20

were interested in the fact that the Trump family

21

was selling merchandise under the Trump brand in

22

the United States that was made in sweat shops in

23

Asia and South America -- or Latin America.

24

needed someone else for that.

25

things.

He was not the
Other parts of

For example, we

So we

So there were other

We were not totally focused on Russia at

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that time, but we were at a point where we were --

2

you know, we'd done a lot of reading and research

3

and we were drilling down on specific areas.

4

Scotland was another one.

5

So that's the answer.

What happens when you

6

get to this point in an investigation when you've

7

gathered all of the public record information and

8

you've begun to exhaust your open source, you know,

9

resources is that you tend to find specialists who

10

can take you further into a subject and I had known

11

Chris since I left the Wall Street Journal.

12

the lead Russianist at MI6 prior to leaving the

13

government and an extremely well-regarded

14

investigator, researcher, and, as I say, we're

15

friends and share interest in Russian kleptocracy

16

and organized crime issues.

17

broadly why I asked him to see what he could find

18

out about Donald Trump's business activities in

19

Russia.

He was

I would say that's

20

Q. So in May or June 2016 you hired

21

Christopher Steele to, as you've just indicated,

22

find out what he could about Donald Trump's

23

business activities in Russia.

24

particular trigger that assignment?

25

Did something in

A. No, I don't think I could point to

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something in particular as a trigger.

2

basis for the request was he had made a number of

3

trips to Russia and talked about doing a number of

4

business deals but never did one, and that struck

5

me as a little bit odd and calling for an

6

explanation.

7

I mean, the

You know, in the background of all

8

international business is questions about

9

corruption.

The Trump organization had branched

10

out all over the world in like the four to eight

11

years prior to 2016.

12

investigation you would naturally want to know

13

whether there was some issue with improper business

14

relationships.

15

So in any kind of

I'll just stress that we weren't looking

16

for -- at least it wasn't at the forefront of my

17

mind there was going to be anything involving the

18

Russian government per se, at least not that I

19

recall.

20

Q. So at the time you first hired him had it

21

been publicly reported that there had been a cyber

22

intrusion into the Democratic National Convention

23

computer system?

24
25

A. I don't specifically remember.

What I

know was that there was chatter around Washington

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about hacking of the Democrats and Democratic think

2

tanks and other things like that and there was a

3

site that had sprung up called D.C. Leaks that

4

seemed to suggest that somebody was up to

5

something.

6

we were particularly focused on -- well, I don't

7

specifically remember.

8
9

I don't think at the time at least that

Q. So you hired Mr. Steele.

Had you worked

with him before?

10

A. Yes.

11

Q. And can you generally describe what he had

12

done in the capacity of working with you and your

13

firm, what kind of projects?

14

A. Generally speaking, like me, Chris tends

15

to work for lawyers who are attempting to assist

16

clients in litigation or an asset recovery-type

17

situation.

18

Union throws off an enormous number of disputes

19

about who owns what because of the history of state

20

ownership of everything and the transfers of

21

property into private hands following the collapse

22

of the Soviet Union was a murky process.

23

particularly in Europe there's a lot of disputes

24

over who really owns what.

25

And so, you know, the former Soviet

So

And so we would collaborate on those kinds of

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investigations.

2

spill over into the United States and, you know, I

3

would be asked to see if I could find a company

4

here or there or run director searches on

5

individuals who might be associated with people we

6

were interested in, that sort of thing.

7

interesting work, but it's kind of plain vanilla

8

business intelligence, litigation support stuff.

9

Sometimes a controversy would

It's

Q. And roughly how many years -- over how

10

many years, like when do you first recall working

11

with him?

12
13

A. I believe we met in 2009.
together since 2009.

14
15

We've worked

Q. And how did you find the quality of his
work over that period of time?

16

A. Quality is a really important issue in the

17

business intelligence industry.

18

poor quality work and a lot of people make a lot of

19

promises about what they can do and who they know

20

and what they can find out and then there's just a

21

lot of people who operate in sort of improper

22

questionable ways.

23

who delivered quality work in very appropriate

24

ways.

25

There's a lot of

Chris was, you know, a person

So -- I mean, I hope you won't be insulted,

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but he's basically a Boy Scout.

2

worked for the government for a very long time.

3

lives a very modest, quiet life, and, you know,

4

this is his specialty.

5

because my speciality is public information.

6

was comfortable working with me and I was

7

comfortable working with him and, you know, we've

8

both been around a lot of criminal investigations

9

and national security stuff.

10

You know, he
He

We got along very well
So he

When I was at the Journal I spent many years

11

investigating the financing of Al-Qaeda.

12

get introduced to sort of national security law and

13

national security operations and wrote a lot about

14

that and was dragged into court over that a few

15

times for things I wrote about people suspected of

16

funding terrorism.

17

interests and background.

18

So I did

So we had a lot of common

Q. And specific to the engagement with regard

19

to the research on Candidate Trump, why did you

20

specifically ask Mr. Steele to do that work?

21

A. The way our firm runs we pursue things,

22

you know, somewhat out of curiosity.

So we didn't

23

know -- it was opaque what Donald Trump had been

24

doing on these business trips to Russia.

25

know what he was doing there.

We didn't

So I gave Chris --

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we gave Chris a sort of assignment that would be

2

typical for us which was pretty open ended.

3

said see if you can find out what Donald Trump's

4

been doing on these trips to Russia.

5

and I worked together over the years there's a lot

6

that didn't need to be said.

7

who is he doing business with, which hotels does he

8

like to stay at, you know, did anyone ever offer

9

him anything, you know, the standard sort of things

We

Since Chris

That would include

10

you would look at.

11

specific instructions beyond the general find out

12

what he was up to.

13
14

I don't think I gave him any

Q. And was anyone else -- did you engage
anyone else to do that particular research?

15

A. In Russia?

16

Q. Yes.

17

A. So we had other people like Ed Baumgartner

18

who, you know, by this time -- I guess Prevezon was

19

still winding down, but who would do Russian

20

language research which didn't involve going to

21

Russia.

22

accounts and that sort of thing.

23
24
25

It just involves reading Russian newspaper

Q. So was Mr. Baumgartner also working on
opposition research for Candidate Trump?
A. At some point, I think probably after the

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end of the Prevezon case we asked him to help with

2

I think -- my specific recollection is he worked on

3

specific issues involving Paul Manafort and

4

Ukraine.

5
6

Q. With regard to the presidential election
of 2016?

7

A. Yes.

8

Q. We had talked about work for multiple

9

clients.

What steps were taken, if any, to make

10

sure that the work that Mr. Baumgartner was doing

11

for Prevezon was not shared across to the clients

12

you were working for with regard to the

13

presidential election?

14

A. He didn't deal with them.

He didn't deal

15

with the clients.

16

reason to -- he operates under the same rules that

17

I do.

18

There wouldn't have been any

Q. And with regard to Mr. Steele, did he ever

19

do any work for Fusion GPS on the Prevezon

20

litigation matter?

21

A. No.

22

Q. It's my understanding that Mr. Steele

23

works with a company called Orbis & Associates.

24

Did anyone else at Orbis, to the best of your

25

knowledge, work with Mr. Steele on the engagement

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that you had with him related to Candidate Trump?

2

A. I mean, I don't know their names.

3

Q. So do you know whether anyone else worked

4
5
6

with him?
A. Yes.

I mean, do you mean as

subcontractors or within his company?

7

Q. First within his company.

8

MR. LEVY:

9

BY THE WITNESS:

10

If you know.

A. I mean, I just don't remember their names.

11

I remember meeting somebody in London who I think

12

worked on it, but I just don't remember.

13

Q. Somebody else associated with Orbis?

14

A. Yes.

15

Q. With regard to the assignment that you

16

gave to Mr. Steele to do Russia-related research

17

for Candidate Trump, is that an accurate way to

18

describe it?

19

regard to Candidate Trump.

20

way to describe the assignment?

I said Russia-related research with
Would that be a fair

21

A. Yes.

22

Q. Did you have any input into the actual

23

work that he did?

24

to what to research specifically?

25

Did you give him directions as

A. I don't recall giving him specific

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instructions.

2

areas of interest.

3

was elevated to running the campaign, we talked

4

about Paul Manafort and his long history of

5

dealings with Russian oligarchs.

6

collaboration than, you know, sort of manager-

7

employee kind of relationship.

8

talk about things that were interesting to us and

9

that seemed to be -- you know, needed to be

10
11

We spoke on the phone about various
For example, when Paul Manafort

So it's more of a

You know, we would

(indecipherable).
Q. So is it fair to describe it as you would

12

collaboratively discuss potential topics to

13

explore?

14

A. Yes, I think that's fair.

15

Q. And did you conduct any of the actual

16

research yourself?

17

A. Well, I think it's important to understand

18

we were doing in my company, you know, all kinds of

19

research, including lots of Russia research, and

20

part of what you do when you get information from

21

someone outside the company who's specifically

22

looking at a discrete set of questions or issues is

23

you add it to the stuff you've already gathered.

24

So we did all kinds of stuff on public information

25

about Donald Trump's business trips to Russia and

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business dealings with Russians.

2

role was specifically to do the thing that we

3

couldn't do, which was to arrange to talk to

4

people.

5

interviewing.

6

focused.

7

I mean, Chris's

Generally speaking, we don't do a lot of
Our research is very document

Q. So to the extent you can describe, when

8

you say he was doing something you could not do and

9

that was he was arranging to talk to people, can

10

you describe who it was he was reaching out to,

11

what you knew about that?

12

A. I don't think for security reasons, among

13

other things, it's an area I'm not going to be able

14

to go into in terms of sources and things like

15

that.

16

a large diaspora of Russians around the world and

17

people in Moscow that, you know, are talking to

18

each other all the time.

19

forget about what was going on in June of 2016 was

20

that no one was really focused on sort of this

21

question of whether Donald Trump had a relationship

22

with the Kremlin.

23

I think speaking broadly, you know, there's

The thing that people

So, you know, when Chris started asking

24

around in Moscow about this the information was

25

sitting there.

It wasn't a giant secret.

People

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were talking about it freely.

2

know, later that it became a subject of great

3

controversy and people clammed up, and at that time

4

the whole issue of the hacking was also, you know,

5

not really focused on Russia.

6

eventually converged into, you know, a major issue,

7

but at the time it wasn't one.

8
9

It was only, you

So these things

Q. I have five or so more minutes and I know
that I have a lot more questions just about some of

10

that work, but I do want to just pin down a couple

11

things about the engagement in particular before we

12

end this hour.

13

So with regard to selecting Mr. Steele

14

specifically to do the Russia -- to do work on

15

Candidate Trump's ties to Russia, do you believe

16

based on his experience and background that

17

Mr. Steele would have been aware of the potential

18

in his discussions with these people that he could

19

be fed this information?

20

A. When Chris -- I don't believe it, I know

21

it.

When Chris briefs in a sort of more formal

22

setting, which I've seen, you know, when he

23

introduces himself -- you know, he was the lead

24

Russianist for MI6.

25

of that is he says, you know, I've worked on this

So the first sort of beginning

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issue all my life and when you're trained in

2

Russian intelligence matters the fundamental

3

problem of your profession is disinformation.

4

the number one issue.

5

It's

In any collection of field -- you know,

6

information from the field you should assume that

7

there will be possibly some disinformation and

8

that, you know, as a professional who has dedicated

9

my life to this, you know, I am trained to spot

10

possible or likely disinformation.

11

and center when you gather information in Russia.

12

So it's front

Q. And when you hired him to do the work, did

13

the client -- were you still working for -- at any

14

time did you work for two clients on this

15

opposition research?

16

clients?

17

Did they overlap, the two

A. I just don't know.

I can just tell you

18

that it was -- I mean, things follow the political

19

cycle.

20

Republican primaries were fundamentally over and

21

the Democrats hadn't really begun yet.

22

was some transition period.

23

I don't keep the books at my place.

24

feel -- I'm afraid to give you a wrong answer that.

25

I just don't know.

So there was a point at which the

So there

That's all I can say.
So I would

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2

Q. Did either client know that you had hired
Mr. Steele specifically?

3

A. I don't think I can answer that.

4

Q. And on what basis can you not answer that?

5

MR. LEVY:

The answer to that question

6

would -- could require the disclosure of client

7

communications which might implicate privileges and

8

obligations that we've previously set forth to the

9

committee.

10

BY MS. SAWYER:

11

Q. Okay.

Maybe you can answer this question,

12

then.

Did either client ever direct Mr. Steele

13

themselves, directly engage and have conversations

14

with Mr. Steele?

15

A. I don't think I can answer that.

16

MR. LEVY:

17

MR. SIMPSON:

18

MR. LEVY:

19

MR. SIMPSON:

20

MS. SAWYER:

21
22

Do you want to take a break?
Sure.

Let's take a break and confer.
That's fine.
Sure.

We'll go off the record

for a few minutes.
MR. FOSTER:

23

It's 11:51.
(A short break was had.)

24

MR. FOSTER:

It's 11:53.

25

MS. SAWYER:

I think the question pending was

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just whether or not the clients specifically spoke

2

with or directed Mr. Steele's work?

3

MR. LEVY:

So he can't talk about client

4

communications, directions to the client --

5

directions to Mr. Steele as those communications

6

might implicate privilege or obligations, but if

7

you want to ask him whether the clients directed

8

Mr. Steele to go to the FBI, that's a question he

9

can answer.

That's in the scope of the interview

10

today.

11

BY MS. SAWYER:

12

Q. All right.

So we'll get to that.

We'll

13

talk about that a little bit later.

Let me just

14

follow up on a couple other things that came up and

15

then we'll conclude for our hour and turn it back

16

to our colleagues.

17

So one of the things that came up in the

18

course of our conversation and when I had asked you

19

specifically about work being done for one client

20

and rules and procedures in place to ensure that

21

that work is not shared with another, can you just

22

specifically describe those rules.

23

point you indicated that you and Mr. Baumgartner

24

had operated under the same rules?

25

A. Right.

I think at one

We're both professionals and we

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both deal with multiple clients.

2

about a case with one client with another client.

3

So we don't talk

I think since you raised this I should be

4

clear, Mr. Baumgartner did not know about

5

Mr. Steele, the work I was doing with Mr. Steele

6

or, you know, the memos he was writing.

7
8
9

MR. FOSTER:

Can you speak up a little bit.

BY THE WITNESS:
A. Mr. Baumgartner did not know about the

10

work that we were doing with Mr. Steele.

11

the ways that we avoid bleeding between one case

12

and another is compartmentalization.

13

people -- we don't tell one subcontractor what

14

we're doing with another subcontractor.

15

even tell them, you know, that they exist.

16

One of

We don't tell

We don't

Q. What about Mr. Steele, what rules was he

17

operating under when he was doing the work on

18

Candidate Trump?

19

A. Every subcontractor signs an NDA at the

20

beginning of the discussion before even there's an

21

engagement.

22

So he was operating under an NDA.

Q. And in general what does that NDA provide?

23

And by NDA I assume you mean nondisclosure

24

agreement?

25

A. Right.

Again, the paperwork side of the

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business is not my strong suit, but it's a general

2

strict prohibition on sharing information about the

3

nature of the work you're doing, your findings with

4

anyone outside of, you know -- we're the client in

5

this case.

6

information with anyone outside the case.

7

So they're not allowed to share

Q. And you had talked a bit about prior work

8

and Mr. Steele's performance in prior work and

9

being satisfied by that work.

Did you do anything

10

to kind of test and make sure that information he

11

was giving you was accurate?

12

A. So in the sort of -- I know I'm repeating

13

myself, but generally we do public records work.

14

So we deal in documents and things that are very

15

hard and that are useful in court or, you know,

16

other kinds of proceedings.

17

Chris deals in a very different kind of

18

information, which is human intelligence, human

19

information.

20

whether something is accurate isn't really asked.

21

The question that is asked generally is whether

22

it's credible.

23

you know, filing lawsuits.

24

decisions and trying to understand what's going on

25

and that's a really valuable thing, but it's not

So by its very nature the question of

Human intelligence isn't good for,
It's good for making

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the same thing.

2

So when you evaluate human intelligence,

3

human reporting, field reporting, source reporting,

4

you know, it's sort of like when you're a

5

journalist and you're trying to figure out who's

6

telling the truth, right.

7

who's telling the truth.

8

person is credible, right, whether they know what

9

they're talking about, whether there's other

You don't really decide
You decide whether the

10

reasons to believe what they're saying, whether

11

anything they've said factually matches up with

12

something in the public record.

13

So, you know, we would evaluate his memos

14

based on whether he told us something we didn't

15

know from somewhere else that we were then able to

16

run down.

17

wrote a memo about a Trump campaign advisor named

18

Carter Page and his mysterious trip to Moscow.

19

So, you know, for example, he, you know,

Q. I'm just going to stop you for a moment

20

because I hadn't yet gotten to the specific stuff

21

of the Trump assignment.

22

a sense of the specific ways in which you assessed

23

his performance in determining to hire him.

24
25

I was just trying to get

A. That's how we did it.

We would assess it

based on the content and the credibility of -- we'd

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try to determine the credibility of what we were

2

reading.

3
4

MR. MUSE:
example.

His reference was to give you an

I think that's where he was going.

5

MR. SIMPSON:

6

MS. SAWYER:

Yeah.
I understand and I appreciate

7

that and we'll get to that.

I just didn't want

8

to -- in light of the time I didn't want to get you

9

started down that road.

If I could just have a

10

second because I want to make sure we finish our

11

questions on this topic and we'll resume our next

12

hour with some of the others.

13

MR. SIMPSON:

Okay.

14

MS. SAWYER:

15

It's high noon, 12:00.

So we'll go off the record.

16
17
18

(A short break was had.)
MR. DAVIS:

We're back on the record.

21

It's

12:06 p.m.

19
20

So let's go off the record.

EXAMINATION
BY MR. DAVIS:
Q. All right.

Mr. Simpson, I'm going to

22

return to the topic of Prevezon.

Let me know if

23

I'm accurately summarizing the scope of work you're

24

describing.

25

areas so far.

I think you've described three main
First is that you were investigating

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Prevezon's side of the story to see if it was

2

credible; the second is you were investigating Bill

3

Browder's ties to the U.S. and related subpoena

4

issues; and the third is that you were

5

investigating Bill Browder's Russian businesses.

6

Is that correct?

7
8
9
10
11

MR. LEVY:

I think he said a lot more than

that, but go ahead.
MR. DAVIS:

I listed the main topics.

where we left off.
MR. LEVY:

I don't think that's the main

12

topics either, but go ahead.

13

BY THE WITNESS:

14

That's

A. Is that a yes-or-no question?

I think

15

those are three things I covered, but I covered a

16

lot of stuff.

17

Q. With the information that you gathered in

18

those and related efforts, what did you do with the

19

information once you obtained it?

20

A. Well, the first thing you do is you give

21

it to the lawyers and, you know, when appropriate

22

you give it to reporters, you know, put it in court

23

filings.

24

Q. So is it correct, then, people associated

25

with Fusion did communicate with journalists about

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the Prevezon case and the information you found out

2

about Mr. Browder?

3

A. Yes.

4

Q. And did Fusion engage in these

5

communications with the media on its own accord or

6

were you directed or authorized to do so?

7

A. In litigation support, you know, basically

8

the cases that we work on frequently get some media

9

attention.

So it's always part of a litigation

10

engagement that if you're the guy that does the

11

research, you're going to end up talking to

12

reporters because they're going to ask questions

13

about, you know, information from the case.

14

MR. LEVY:

15

question.

16

BY THE WITNESS:

17

Just make sure you answer his

Was it done?

A. That's part of what the lawyers hire you

18

to do and that's what they instruct you to do.

19

way it generally happens is the lawyer gets a call

20

from a reporter who wants to write a story about

21

the case and he answers the questions or gives them

22

a quote and then he instructs me to give him

23

background information.

24
25

The

Q. So then was it typically done on a
case-by-case basis or did you have blanket

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authorization regardless of specific interactions

2

with the attorneys?

3

A. These things evolved over time.

So in the

4

beginning of the case when you're new to a subject

5

you're generally fielding -- you generally get

6

requests from the lawyers to answer a specific

7

question that a reporter has.

8

call and they'll want to know whatever, where the

9

house was in Colorado, and he'll say somewhere in

So the reporter will

10

Aspen, ask Glenn.

11

he'll send me to them.

12

you've gathered a mass of information that covers a

13

whole wide range of topics and, you know, if

14

there's more coverage, you know, they will direct

15

you to answer questions for the reporters covering

16

the case.

17

basis talk to so-and-so.

18
19

Then he'll send him to me or
Later on when you get where

They won't tell you on an individual
It's a little of both.

Q. Was Fusion then paid for these
communications with the media?

20

A. We were compensated for our litigation

21

support and as part of that we were directed to

22

talk to the media.

23

yes, we were.

24

conversations, I don't think so.

25

So in the fundamental sense

Specifically paid for individual

MR. FOSTER:

Do you bill hourly?

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MR. SIMPSON:

2

MR. FOSTER:

3

MR. SIMPSON:

4

MR. FOSTER:

5

It depends on the case.
On this case?
I think we did on this case.
So did you bill for

conversations with the press on this case?

6

MR. SIMPSON:

I'm sorry to say I don't know.

7

I probably did not.

Generally speaking, what I

8

would bill for would be to attend events where

9

there would be press.

So if I was at a court

10

hearing -- most of the press was around court

11

hearings.

12

the lawyers and there would be reporters there.

13

part of what I was billing for was answering their

14

questions.

15

BY MR. DAVIS:

So I would go to a court hearing with

16

Q. And with which news organizations did

17

Fusion communicate in relation to the Prevezon

18

case?

19

A. I will try to remember them.

So

It was the

20

major news organizations that were covering the

21

litigation.

22

legal reporters.

23

Times, Wall Street Journal, probably Reuters, Legal

24

360.

25

Usually it was their courthouse or
So it was Bloomberg, New York

I'm sure there were a handful of others.
Q. Was the Financial Times possibly one of

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them?

2

A. Yes.

3

Q. Politico?

4

A. They approached us with -- they had been

5

getting information from Bill Browder.

He had

6

alleged to them that we were part of a big campaign

7

on Capitol Hill and that we were engaged in

8

lobbying and that it was all designed to affect

9

legislation or smear him or Sergei Magnitsky.

So

10

eventually we did end up dealing with that, but I

11

don't remember whether we dealt with them prior to

12

that.

13

that.

I don't think they covered the case prior to

14

Q. What about NBC?

15

A. We would have -- I'm sorry.

16

Q. And the New Republic?

17

A. I think so.

18

Q. And do you recall what information you

19

provided to each or is that too into the weeds?

20

A. I don't know if it's in the weeds, but

Yes.

21

generally speaking, the work -- we provided

22

information about the work that I had done about

23

William Browder's credibility.

24

ended up -- when I said when he declined to appear

25

voluntarily as I am here and explain things, you

The whole case

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know, it ended up being an issue of why he didn't

2

want to talk.

3

credibility, about his account of his activities in

4

Russia, about his history of tax avoidance, all

5

these things.

6

So a lot of it was about his

Q. Did Fusion provide the media information

7

alleging that Browder had illicitly engineered the

8

purchase of 133 million shares of Gazprom?

9
10

A. I don't know for sure, but we certainly
did research on that issue.

11

Q. And you described investigating these

12

series of issues.

13

information in the course of this investigate?

14

How did you acquire the

A. We used the methods that I've described

15

here today.

We pulled court records, we pulled

16

corporate records, we, you know, pulled real estate

17

records, SEC securities filings, that sort of

18

thing.

19

Q. And was any of the information you

20

provided to the media information that wasn't the

21

result of your own research but that had been

22

passed along to you by Baker Hostetler or Prevezon?

23

A. I think the answer to that is yes, but I'm

24

struggling to think of a specific example.

As I

25

was saying earlier, the lawyers did a lot of the

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research too.

2

research where, you know, we were feeding research

3

to them and they were housing a central repository

4

of research and then the research would become

5

memoranda and given in court filings.

6

these cases we were giving people court filings.

7

So the information was mixed together from various

8

sources.

9

So there was obviously a sharing of

In a lot of

Q. Did Fusion independently verify the

10

information provided by Baker Hostetler or Prevezon

11

or in this circumstance was it assumed to be

12

reliable given your work with them?

13

A. We certainly did not independently verify

14

everything that the lawyers generated in the case.

15

That would have been an enormous task and it would

16

have made no sense.

17

I just want to stress that I've worked with

18

Baker Hostetler for -- you know, since 2009, so I

19

guess going on over eight years, and they're very

20

good lawyers and very conservative.

21

provided me with information that they had

22

gathered, I would have been confident -- I was

23

confident in the quality of their work.

24
25

So if they

Q. And did Prevezon or Baker Hostetler ever
direct Fusion to relay to the media information

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that they had provided to Fusion?

2

A. I'm sorry.

Can you say that again.

3

Q. Did Baker Hostetler or Prevezon direct

4

Fusion to relay to the media information that they

5

had provided to you?

6

A. I don't specifically recall an example of

7

that, but I think as a general sort of operating

8

principle we were working at their direction and

9

they were providing us with, you know, case

10

information.

11

an idea.

12

So I think so, but I just don't have

Q. And did anyone at Fusion or perhaps

13

Mr. Baumgartner review Russian documents related to

14

the Prevezon matter?

15

A. Yes.

16

Q. Do any --

17

A. Most of them were Russian court

18
19
20
21

documents.
Q. Do any Fusion employees or associates
speak Russian?
A. No.

I'll qualify that.

Depends on how

22

you define associate.

23

the company, but he speaks Russian.

24

subcontractor.

25

Edward isn't an employee of
He's a

Q. Aside from Mr. Baumgartner, do you have

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any other support from Russian-speaking individuals

2

in reviewing the Russian documents?

3

A. Not in my company, at least not that I can

4

recall.

5

that were engaged by Baker Hostetler in various

6

situations, like translators, Russian bilingual

7

lawyers, that sort of thing.

8
9
10

There was other Russian speakers I think

Q. Do you remember the names of any of those
people?
A. Anatoli, whose last name I can't really

11

pronounce, was a New York-based English-Russian

12

court translator.

13

translator.

14

don't know the extent of their other involvement

15

with other people in these things.

He was mostly a courtroom

So I don't know whether he -- I really

16

MR. FOSTER:

17

too far afield of this.

18

answer that you gave earlier.

19

interactions with the press as primarily being

20

directed to answer questions, in other words, the

21

contact as being initiated by the press.

22

understanding of how you described it.

23

MR. LEVY:

Can I just back up before we get
I want to follow up on an
You described your

That's my

I don't think that's a complete

24

summary of what he said.

25

MR. FOSTER:

Feel free to correct me if I'm

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wrong.

2

you were initiating contact with the press or

3

pitching stories to the press?

4

My question is were there instances where

MR. SIMPSON:

Sure.

I mean, the range of

5

things that you would do, you know, again, it would

6

evolve.

7

of hearings and a lot of legal reporters are

8

showing up and you're mostly answering their

9

questions.

In the beginning you were going to a lot

Depending on the setting, you know, you

10

might get a question for the lawyers like is anyone

11

from Reuters going to be there and you would reach

12

out to Reuters and say are you guys sending someone

13

to this hearing.

14

reach out like that.

15

reporters, you know, generally covering issues of

16

corruption or law or Russia or whatever and say,

17

you know, we're involved in a really weird court

18

case, you might be interested in this.

19

So there was definitely some

MR. FOSTER:

Then we would also talk to

So is it fair to say that part

20

of your job, then, was to locate reporters who

21

would write about these matters from a point of

22

view that was advantageous to your client?

23

MR. SIMPSON:

Yes, but I think we should note

24

here that William Browder is an especially

25

aggressive media self-promoter and promoter of his

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story.

2

and we were constantly besieged with reporters

3

pursuing negative stories about Prevezon, the

4

events of the Prevezon case that had been given to

5

them by William Browder.

6

I would say, you know, a lot of what we were doing

7

was simply responding to his wild allegations,

8

unsupported wild allegations.

9

So for much of this case it was reactive

So, you know, unhappily,

There were certainly moments, particularly

10

concerning his unwillingness to appear for a

11

deposition, where we said to some reporters, hey,

12

guy, you know, he's just dodged his third subpoena,

13

you might want to write about this, it's pretty

14

funny.

15

down a street in Manhattan in the middle of a

16

blizzard to get away from our process servers, but

17

that one we actually had them film it.

In fact, you know, the third one he ran

18

So, you know, did we want to get that

19

covered, did we think it was important that people

20

know that this guy was unwilling to appear in court

21

in public under oath to talk about the story that

22

he'd been selling for years about his activities in

23

Russia?

24

BY MR. DAVIS:

25

Yeah, we wanted people to know that.

Q. Other than the media and Baker Hostetler,

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did Fusion provide any information regarding the

2

Prevezon matter to any other third parties?

3

A. I don't have a specific recollection of

4

doing so.

If there's a specific incident that

5

you'd like to ask about I'd be happy to try and

6

answer that.

I don't remember.

7

Q. We'll get into that a little bit more.

8

Also to go back to the translator you

9
10

mentioned, you said Anatoli and that you didn't
know how to pronounce --

11

A. Samochornov I think is his --

12

Q. Okay.

13

A. I'm massacring it.

14

Again, it's something

that's in the public record.

15

Q. Do you know Rinat Akhmetshin?

16

A. Yes, I do.

17

MR. MUSE:

18

MR. DAVIS:

Spell it.
Sure.

19

A-K-H-M-E-T-S-H-I-N.

20

BY MR. DAVIS:

R-I-N-A-T,

21

Q. When did you first meet Mr. Akhmetshin?

22

A. When I was a reporter at the Wall Street

23
24
25

Journal.
Q. And as far as you know, what is his
business?

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2

A. Some kind of PR consulting lobbyist.

I

think he's a registered lobbyist.

3

Q. Have you ever worked with Mr. Akhmetshin?

4

A. I've been -- in the Prevezon case I

5

interacted with him.

I think -- again, this has

6

unhelpfully been distorted by William Browder into

7

some sort of economic relationship or conspiracy or

8

something.

9

with him.

I don't have any economic relations
You know, I've bumped into him over the

10

years around town.

11

that I specifically recall having done with him was

12

interacting for a brief period on the Prevezon

13

case.

14
15

So, you know, the only thing

Q. You don't recall working with him for any
other clients or cases?

16

A. Let's be clear, I'm sure we did not do

17

business together, but I do work on areas of the

18

world where he's from, Central Asia, former Soviet

19

Union, and he is, as I'm sure you've seen, a guy

20

around town who knows lots of people who cover this

21

stuff.

22

was doing on Kazakhstan at the Wall Street Journal.

23

That's the kind of context I've bumped into him

24

over the years.

25

think I even met one of his clients at one point,

I met him in connection with some stories I

He's told me various things and I

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but it wasn't a business thing.

2

was doing any work.

3
4
5

I don't think I

I was just networking.

Q. You said he told you various things.

Do

you mean he would pass along information to you?
A. The information that I remember was about

6

his Kyrgyzstan stuff.

There was a congressional

7

investigation into Kyrgyzstan that he claimed

8

credit for having started and he told me about it

9

for some reason, but it wasn't because we were

10

doing business together.

11

something.

12
13
14
15
16
17
18
19

It was coffee or

Q. You said he claimed credit for having
started the congressional investigation?
A. That's my recollection, but this was some
years ago.
Q. And you said you met one of his clients.
Do you remember which client?
A. A former Kazakh politician whose name
escapes me.

20

Q. Do you remember when you met that client?

21

A. Years ago in London.

22

Q. Has Mr. Akhmetshin ever been paid by

23

Fusion GPS?

24

A. Not to my knowledge.

25

Q. Has he ever provided information to Fusion

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GPS for use in your work?

2

A. I don't have a specific recollection of

3

him having done so.

4

categorically because I've been running this

5

business now for a number of years and I would have

6

interacted with him at various times and ways that

7

I probably don't remember, but not that I

8

specifically recall.

9
10

I would hesitate to say so

Q. Has Mr. Akhmetshin ever paid Fusion GPS
for work?

11

A. Not to my knowledge.

12

Q. You mentioned interacting with him in the

13

Prevezon matter.

14

to be in the Prevezon work?

15

What did you understand his role

A. I did not have a clear understanding of

16

his role initially.

He started attending meetings

17

sometime in 2016, just a handful of things, and

18

it's -- you know what?

19

saying to me you're not doing X, Y, or Z.

20

have.

21

was the court case and this fight over whether

22

Browder would have to testify, which morphed then

23

into this fight over whether -- you know, his

24

allegations that John Moscow had a conflict of

25

interest.

I don't recall anyone ever

I just don't recall.

They may

The lane that I was in

So I was very focused on that.

These

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other issues came up two plus years into the case

2

and he was clearly dealing with them, but I don't

3

recall anyone sort of giving me a specific

4

explanation, you know, of what he was doing.

5

MR. FOSTER:

What other issues?

6

MR. SIMPSON:

The issues of the -- what do

7

you call it, HRAGI, the foundation and the

8

congressional stuff.

9

BY MR. DAVIS:

10

Q. You mentioned he started showing up at

11

meetings in 2016.

12

meetings?

13

Who else attended these

A. I don't specifically remember.

I mean, Ed

14

Lieberman I think was at a meeting.

15

think it was -- it wasn't a lot of meetings, just

16

one or two, but it was at Baker Hostetler.

17
18
19

MR. FOSTER:

Again, I don't

Can you explain briefly who Ed

Lieberman is.
MR. SIMPSON:

Ed Lieberman is a lawyer in

20

Washington who has a specialty in international tax

21

who worked for Baker Hostetler on some of the

22

analysis of the alleged tax evasion by Hermitage

23

Capital and William Browder.

24

also he knows Rinat from I guess, I don't know,

25

college or something and subsequently the two of

And then subsequently

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them were working on the -- I don't know what to

2

call it, the congressional stuff.

3

MR. FOSTER:

4

MR. SIMPSON:

5

lobby Congress.

6

BY MR. DAVIS:

7

Lobbying Congress?
I believe they registered to

Q. Did Fusion provide any of its research to

8

Mr. Akhmetshin whether directly or through an

9

intermediary such as Baker Hostetler?

10
11
12

A. Yes.

We were directed to do so by Baker

Hostetler.
Q. And do you know or have reason to believe

13

whether Mr. Akhmetshin used that information when

14

he spoke with people on the Hill?

15

A. I have reason to believe that.

I don't

16

have specific knowledge of his discussions with

17

people on the Hill.

18

told me what he did.

19

focus of my work.

20

I don't remember.

He may have

As I say, it was not the

Q. Has Mr. Akhmetshin ever said anything to

21

you indicating or implying that he had worked with

22

the Russian government?

23

A. Well, I knew he had been a soldier, I knew

24

he had been in the Soviet military, and I also knew

25

that he went to Moscow a fair bit because he said

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on several occasions I'm in Moscow or I'm going to

2

Moscow.

3

mentioned having worked with the Russian

4

government.

5

He may have -- I don't recall whether he

Q. Has he ever said anything to you

6

indicating or implying that he had worked for

7

Russian intelligence more specifically?

8

A. Well, as I said, I'm sure that he had

9

mentioned to me maybe back in, you know, the time

10

when I was at the Wall Street Journal that he was

11

in the Soviet military and he had some kind of

12

low-level intelligence position, but I don't

13

remember anything beyond that.

14

say anything in recent years about having any

15

current connections with Russian intelligence.

16

Q. Has he ever said anything to you

17

indicating or implying that he has contacts or

18

connections with Russian government officials?

19

A. Not that I specifically recall.

20

Q. Do you have reason to believe that he has

21
22

He certainly didn't

ties to the Russian government?
A. I have reason to wonder whether he has

23

ties to the Russian government, but, you know, in

24

the course of my work for Baker Hostetler the

25

question of whether he had some connection to the

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Russian government wasn't germane really.

2

didn't come up.

3

meeting at Trump Tower and the allegations in the

4

media that there's some relationship there I share

5

everyone's interest in the answer to that

6

question.

Obviously with the news of this

7

Q. Do you know Natalia Veselnitskaya?

8

A. Yes.

9

Q. When did you first interact with

10

Ms. Veselnitskaya?

11

A. I believe it was sometime in 2014.

12

Q. Has Fusion ever worked with

13
14

It just

Ms. Veselnitskaya?
A. Didn't I just answer that?

Yes.

I mean,

15

she was the lawyer, the Russian lawyer who retained

16

Baker Hostetler who retained us.

17

"worked with," I don't know that as a technical

18

meaning, but we interacted with her as part of the

19

Prevezon litigation.

So when you say

20

Q. Has Fusion ever been paid by her?

21

A. Well, she arranged -- as the lawyer for

22

Prevezon she would have arranged for Prevezon to

23

pay Baker Hostetler which paid us.

24

what your question is, then the answer is yes, but

25

I mean, I don't think the money came from her.

So if that's

It

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2
3

came from Prevezon.
Q. Were there any direct payments that didn't
go through Baker Hostetler?

4

A. No.

5

Q. So what did you understand her role to be

6

in the litigation?

7

for Prevezon.

8

Prevezon?

9

You said she was the attorney

Was she managing the case for

A. I was not introduced to her originally.

10

The original way that she was -- it came up in my

11

conversations with Mark Cymrot and other Baker

12

lawyers was as the person who had hired them who

13

had the information about the extortion case

14

against Demetri Baranovsky.

15

me by Mark Cymrot that she handled that matter and

16

was familiar with the prosecution of Demetri

17

Baranovsky and very well versed in the events of

18

the extortion.

19

of her and I think that's probably -- our first

20

interactions were probably about that subject.

21

Q. Did she provide Fusion with the

22
23

It was represented to

So, you know, that's how I learned

information about that extortion case?
A. Well, I certainly discussed it with her at

24

some point, but it was all in Russian.

You know,

25

the bulk of the Russian-English translating just

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for, you know, chain of evidence reasons went from

2

her to Baker Hostetler.

3

analyzed and translated and then they would -- I

4

don't read a word of Russian.

5

certified translations of stuff from Baker.

They would have materials

So I would get the

6

Q. And beyond your interactions with her

7

about the extortion issue, what type of interaction

8

did you have with her in the course of the Prevezon

9

work?

10

A. In the early period it was I believe

11

largely about this extortion case.

12

we would appear in court it would -- you know, she

13

would come to some of the Court hearings and the

14

issue of Browder's efforts to avoid having to

15

testify were front and center, sort of the main

16

issue for quite a while.

17

specific conversations with her about that, but

18

that's what we would have discussed.

19
20
21
22
23
24
25

Later on when

So I don't remember

Q. Have you met in person with her on other
occasions besides court hearings?
A. I attended a couple client dinners and I
think that's about it.
Q. Do you recall when and where those would
have been?
A. I recall some of the when and the where.

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There were a couple of dinners in New York and a

2

couple of dinners in D.C.

3

they started.

4

was some in 2016 in both cities.

I don't remember when

I think probably 2015.

And there

5

Q. Were any in June 2016?

6

A. Yes.

7

Q. Were those in New York or in D.C.?

8

A. I believe that one was in New York and one

9

Two.

was in D.C.

10

Q. Do you recall the specific date of either?

11

A. I didn't until we tried to piece these

12

things together, but June 8th I think was the

13

dinner in New York and I think the 10th was the

14

dinner in D.C., something like that.

15
16

Q. And what were the purposes of these
dinners?

17

A. Well, the first one was just an obligatory

18

client dinner which, you know, when you work on a

19

legal case you get invited to dinner with the

20

clients.

21

thing.

22

really about the case.

23

Cymrot's friends.

24

Washington Post book section was there and his wife

25

who's a well-known author were also there.

The one in D.C. was more of a social
It wasn't -- she was at it, but it wasn't
It was just a bunch of Mark

You know, the editor of the

I can't

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remember who else was there.

2

at the other end of the table from me and, you

3

know, as I said, she doesn't really speak English

4

and I don't speak Russian.

5

chit-chat.

6

But anyway, she sat

So not a lot of

Q. Was it your understanding that the

7

research you provided to Baker Hostetler would then

8

be passed on to Ms. Veselnitskaya?

9
10
11

A. To the extent that it was useful and
interesting to her I'm sure they did, yes.
Q. Has she ever said anything to you,

12

presumably via a translator, indicating or implying

13

she had worked with the Russian government?

14

A. No, but Mark Cymrot told me when he told

15

me of her existence that she was a former

16

prosecutor.

17

Q. And has she ever said anything to you more

18

specifically indicating or implying that she had

19

worked for Russian intelligence?

20

A. No.

21

Q. Do you have any reasons to believe that

22

Ms. Veselnitskaya has ties to the Russian

23

government?

24

A. I know what I've read in the newspaper.

25

Q. Beyond that?

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A. Beyond that my impression of her was of

2

someone who, you know, was a very smart and

3

ambitious lawyer, but not like a big political

4

player in the Kremlin.

5

given all the recent events and disclosures that I

6

was unaware of whether my assessment of her was

7

right or wrong.

8

kind of out.

9

she didn't seem to be a heavy hitter in the Kremlin

10

when did you first meet Ed Lieberman?
A. I don't remember specifically, but it was
years ago.

15
16

I honestly can tell you all I knew is

Q. This might be a little repetitive, but

13
14

As we sit here today, the jury's

world.

11
12

Of course given to wonder

Q. I believe you described his business.
Have you ever worked with Mr. Lieberman?

17

A. I don't think so.

18

Q. Or Fusion more broadly?

19

A. Not that I can recall.

20

Q. Have you ever paid him or been paid by

21

him?

22

A. No.

23

Q. And what exactly did you understand his

24
25

role to be in the Prevezon issue?
A. Well, the initial issue that we worked on

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together was the issues about alleged tax evasion

2

by Hermitage Capital in Russia and William

3

Browder's decision to surrender his citizenship

4

shortly before the tax rules on surrendering your

5

citizenship changed, which tended to make us

6

suspect that it was motivated by tax

7

considerations.

8

the offshore companies in BVI.

9

At that time we didn't know about

Q. And what type of interactions did you have

10

with Mr. Lieberman in the course of the Prevezon

11

work?

12

A. Collegial, I guess professional I would

13

say.

Ed's, you know, got a background in tax.

14

we talked about tax stuff.

15

after a couple years had gone by, you know, he and

16

Rinat embarked on this other project, but I don't

17

have a specific recollection of whether I dealt

18

with him directly on any of that.

Later on, much later on

19

Q. Did Fusion provide its research to

20

Mr. Lieberman either directly or through an

21

intermediary such as Baker Hostetler?

22

So

A. Not that I recall, but if the lawyers

23

asked me to send them something, I would send them

24

something.

25

Q. Do you have any reason to believe that

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Mr. Lieberman has ties to the Russian government?

2

A. No.

3

Q. Do you know Mr. Robert Arakelian,

4
5

A-R-A-K-E-L-I-A-N?
A. There was a guy at a lunch or dinner or

6

something named Robert and he was introduced to me

7

as Robert.

8

client meals or things like that, you know, we

9

didn't get into a lot of details of who he was.

Again, when you're going to like these

I

10

just remember he was introduced as a friend Denis

11

Katsyv, K-A-T-S-Y-V.

12

may be that he's a friend of Rinat's.

13

really know.

14
15

That's my recollection.
I don't

Q. As far as you know, what is Mr. -- what is
Robert's business?

16

A. I don't know.

17

Q. So presumably, then, has Fusion ever

18

It

worked with him?

19

A. Not to my knowledge.

20

Q. What did you understand Mr. Arakelian's

21
22

role to be in the Prevezon work?
A. I didn't know he had a role.

If someone

23

told me I've forgotten, but, again, I was pretty

24

narrowly focused on a few things and he wasn't

25

involved in those things.

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Q. Were you aware that he was a registered

2

lobbyist for HRAGI?

3

A. No.

4

Q. Other than meeting him at that dinner, did

5

you have any other interactions with him in the

6

course of the Prevezon work?

7

A. Not that I can recall.

8

Q. Did Fusion provide any research to him

9
10
11

directly or through an intermediary such as Baker
Hostetler?
A. I don't know.

I mean, if Baker Hostetler

12

gave him information from my research or my

13

company's research, they didn't tell me.

14
15

Q. Do you have any reason to believe he has
ties to the Russian government?

16

A. No.

17

Q. But you said he is friends with the

18
19

Katsyvs?
A. I shouldn't speculate.

I recall he was

20

introduced to me as a friend of someone and I don't

21

remember whether it was Rinat or Denis Katsyv, but

22

it was one or the other.

23

Q. Do you know Howard Schweitzer?

24

A. I don't, not that I can recall.

25

Q. So you've never done any business with

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him; is that correct?

2

A. I don't think so.

3

Q. Do you know if he had any role in the

4
5

Prevezon work?
A. I've read that his firm was involved in

6

the lobbying, but it's just something I read.

7

don't believe I had any personal interactions.

8

Q. Do you know who Denis Katsyv is?

9

A. He's the owner of Prevezon.

I

10

Q. Did you have any interactions with him?

11

A. Again, I sat in a few meetings, a couple

12

of client meals, but it was limited by his limited

13

English and my limited Russian.

14

Q. In your interactions with

15

Ms. Veselnitskaya did she claim to be acting as the

16

attorney for Prevezon Holdings and the Katsyv

17

family or just for Prevezon Holdings?

18
19
20

A. She was introduced to me as the lawyer for
Prevezon.

I never --

MR. LEVY:

When you say "the Katsyv family,"

21

Denis Katsyv is the only person named in the

22

lawsuit.

I'm just wondering what you mean by that.

23

MR. DAVIS:

24

MR. SIMPSON:

25

Denis or Pyotr.
As I said, she was introduced

to me as the lawyer for Prevezon.

So -- and I

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think the lawyer for Denis.

2

don't know.

3

BY MR. DAVIS:

So beyond that I

4

Q. Do you know who Pyotr Katsyv is?

5

A. I do now.

I mean, I knew a little bit

6

about him at the time, but now that it's become an

7

issue, at least in the mind of William Browder,

8

obviously I know who he is.

9

Q. Did you have any interactions with him?

10

A. No.

11

Q. Do you know Chris Cooper?

12

A. Yes.

13

Q. How long have you known Mr. Cooper?

14

A. Probably ten years, maybe longer.

15

Q. As far as you know, what is his

16

business?

17

A. Public relations.

18

Q. Is he associated with the Potomac Square

19

Group?

20

A. I believe he is the Potomac Square Group.

21

Q. Has Fusion ever worked with Mr. Cooper or

22

the Potomac Square Group?

23

A. Yes.

24

Q. Have you paid him or been paid by him?

25

A. I believe we've paid him.

I don't know if

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he's paid us.

2
3

Q. What did you understand his role to be in
the Prevezon work?

4

A. He worked on his movie doing --

5

essentially as I understand it and recall it, he

6

was asked to help find a place where they could

7

show this movie.

8

press, but he doesn't like anyone talking freely

9

about him or raising questions about the story of

William Browder likes to use the

10

his activities in Russia.

11

together they were going to screen it in Europe and

12

he hired the meanest libel firm in London which has

13

previously sued me on behalf of Saudi billionaires

14

and -- unsuccessfully I might add, and he

15

threatened to file libel cases against the people

16

who were daring to offer to host a showing of this

17

film.

18

So when this movie came

So, as you know, they don't have the First

19

Amendment in Europe.

So he was able to

20

successfully suppress the showings of this film

21

which questioned his credibility and whether -- the

22

truth of his story and his activities in Russia.

23

So Chris came up with the idea of showing it at the

24

Newseum which is dedicated to the First Amendment

25

and where they don't have much time for libel

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2
3

lawyers and people trying to suppress free speech
Q. And was the showing arranged for Prevezon,
for HRAGI?

Who was arranging this?

4

A. I don't know.

5

Q. Did Fusion have any role in that showing?

6

A. We supplied some names of people.

7

wanted to round up people who would be interested

8

in coming, journalists, friends, people interested

9

in Russia, and we supplied names for them.

10

They

Q. Did Fusion contact any journalists to

11

inform them about the film or the showing or to

12

encourage them to write about it?

13

A. I believe that I mentioned it to some

14

journalists in terms of showing up.

15

believe I -- I just don't remember whether I tried

16

to get anyone to write anything about it, but if I

17

did I would have had good reason to because it was

18

all about William Browder's credibility which was

19

the subject that we were hotly litigating in

20

New York and I had been on this -- you know, we had

21

been on this, you know, multi-year effort to get

22

him to answer questions about his activities in

23

Russia.

24

Prevezon case.

25

I don't

So it was the central issue in the

Q. So you mentioned Mr. Cooper was involved

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in establishing this screening.

2

came to be hired by Prevezon or HRAGI or whoever?

3

A. I know a little.

Do you know how he

As I was saying earlier,

4

I've known Chris from Wall Street Journal days and

5

I refer business to him.

6

with the Browder theory of the case, but I don't do

7

a lot of public relations work and I refer, you

8

know, public relations jobs to other people,

9

friends.

10

I know this doesn't fit

So when the trial was approaching in the

11

Prevezon case I kept telling the lawyers you guys

12

have to hire a PR guy, I'm not going to do this,

13

it's just too much work.

14

PR people and he was one of the people that I

15

recommended as a trial PR guy.

16

have a clear sense of how he ended up working on

17

the movie, but it wouldn't be surprising if they

18

had his name from the previous referral.

19
20
21

creating HRAGI?
A. I would be guessing.
remember.

23

remember.

25

From there I don't

Q. Do you know who came up with the idea of

22

24

So we were trying to find

I just don't

Someone may have told me.

I don't

Q. What kind of interaction did Fusion have
directly or indirectly with HRAGI?

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A. I remember hearing about it.

I remember

2

Rinat talking about it and maybe others.

3

very peripheral to this stuff and I don't remember

4

if I had any specific interactions with it.

5

don't know if they had an office, I don't know if

6

they had a bank account.

7

know they registered to lobby.

8
9
10

We were

I just don't know.

I

I do

Q. Do you know Lanny Wiles, L-A-N-N-Y,
W-I-L-E-S?
A. I know him a little bit.

I met him

11

originally when I was a journalist.

He was

12

introduced to me as a well-connected Republican

13

consultant type and I bumped into him once or twice

14

over the years.

15

Q. Has Fusion ever worked with him?

16

A. I don't think so, no.

17

Q. What did you understand his role to be in

18

the Prevezon-HRAGI work?

19

A. Again, my understanding of people's

20

roles on -- he was involved in the lobbying.

21

a lobbyist.

22

Beyond that I really couldn't say.

23

He's

He was involved in the lobbying.

Q. Did you have any involvement with him in

24

the course of your work on the Prevezon?

25

A. I think we had lunch once.

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2

Q. Do you have any reason to believe that
Mr. Wiles has ties to the Russian government?

3

A. No.

4

Q. So as you mentioned, in 2016 people

5

associated with HRAGI met and attempted to meet

6

with people in a number of congressional offices.

7

Were you aware of any of these meetings?

8
9

A. The meeting that I was aware of that I
remember hearing about was a meeting that actually

10

didn't happen which was some meeting that Mark

11

Cymrot was supposed to have.

12

was going to meet some Congressman.

13

that I was told about other meetings by some of

14

these people that we're discussing, but I don't

15

specifically remember hearing about other meetings.

16

I was generally aware that there was stuff going on

17

on the Hill.

18

It's possible that he
It's possible

Q. If I could refer back to Exhibit 2, the

19

partial privilege log.

20

document lists a 5/13/16 e-mail from Rinat

21

Akhmetshin to Mark Cymrot with the subject/

22

description "Appointment with Cong. Hill."

23

believe that to be a reference Congressman French

24

Hill?

25

A. I don't know.

The first page of that

Do you

I believe it was a

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Congressman named Hill.

2

Congressman named French Hill.

3

I don't know if it was a

Q. And do you recall any other mentions of

4

meetings with any particular congressional offices

5

or committees?

6

A. I'm sure -- I'm sorry.

I believe I recall

7

Rinat telling me that he was talking to Paul

8

Behrends, B-E-H-R-E-N-D-S.

9

Mark Cymrot or maybe both about some of these

It was either Rinat or

10

issues, but, again, I don't have a great

11

recollection for the specifics.

12
13

Q. Did Fusion have any role in these
meetings?

14

A. I mean, I think we were asked for

15

information, and to the extent that the lawyers

16

wanted me to give somebody information I would hand

17

it over to them.

18

It's their information.

Q. To the best of your knowledge, was that

19

information referenced in the meetings with

20

congressional staff members?

21

A. I don't know.

22

Q. You mentioned you had dinner with

23

Ms. Veselnitskaya on June 8th and 10th of 2016.

24

Were you generally aware of her trip to the United

25

States in June?

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A. I was.

She had trouble getting a visa and

2

the lawyers -- there was some drama over whether

3

she could get a visa.

4

recurring issue in the case.

5

believed that the Justice Department was

6

interfering with her visas because they wanted to

7

inhibit her from collaborating with us on the case,

8

but I don't have any independent knowledge of her

9

visa issues.

10

This would have been a
You know, our lawyers

I just remember that was an issue.

I remember that at the last minute she got a

11

visa to come to this Appellate Court hearing on

12

June 9th in New York, and that was the way that she

13

persuaded them to give her a visa was that she

14

needed to attend a hearing which was on an appeal

15

of a District Court ruling related to the

16

disqualification motion that had been filed by

17

William Browder against Baker Hostetler after he

18

was ordered to give testimony.

19

So that's the history of that court hearing,

20

which was after the Court said he couldn't get out

21

of the subpoena and he had to give testimony, he

22

then triggered a new delay in his testimony by

23

filing a disqualification motion.

24
25

Q. And that hearing was on June 8th; is that
correct?

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A. I believe it was June 9th.

2

Q. Did you have any other information about

3

Ms. Veselnitskaya's itinerary or intended

4

activities on this trip?

5

A. No.

I mean, I can tell you what I knew.

6

I knew she was coming in I guess on the 8th.

7

don't have a clear recollection of the dinner, but

8

I know -- I believe we had a dinner.

9

is I had more than one.

10
11

I

The problem

So I don't have a clear

recollection of it.
Anyway, I saw her the next day in court at

12

this hearing and I'm sure we exchanged greetings,

13

but, as I say, she speaks Russian and I speak

14

English.

15

afterwards.

16

plans she had.

17
18

I think she was with Anatoli and she left
I know she didn't tell me any other

Q. So you had dinner the 8th, saw her in
court on the 9th; is that correct?

19

A. Yes.

20

Q. And dinner again on the 10th?

21

A. In D.C.

22

Q. Did you see her any other time?

23

A. Not that I recall.

24

Q. Did Fusion play any role assisting

25

Ms. Veselnitskaya during that trip?

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A. Not that I recall.

2

Q. It has widely been reported

3

Ms. Veselnitskaya and Mr. Akhmetshin and others met

4

with Donald Trump, Junior, Paul Manafort, and Jared

5

Kushner on June 9th, 2016.

6

meeting beforehand?

7

A. No.

8

Q. It didn't come up at the dinner the night

9

Were you aware of this

before?

10

A. No.

11

Q. When did you first become aware of the

12

meeting?

13
14
15
16
17

A. Around the time it broke in the New York
Times.

I was stunned.
Q. Is it correct that that means it wasn't

discussed at the dinner on the 10th?
A. No, but, again, you know, the dinner on

18

the 10th was I was at one end of the table talking

19

to a woman about her biography on Simon Bolivar and

20

she was at the other end with Rinat and she doesn't

21

really speak much English.

22

fortunately I was not going to do a lot of

23

entertaining.

So, you know,

24

Q. I should clarify, discussed with you.

25

A. Yeah.

So if she discussed with somebody

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else, I wouldn't --

2

Q. Right.

3

Do you have any knowledge of the purpose of

4
5

the meeting other than what you read in the media?
A. No.

No.

Well, I mean, I read she wanted

6

to give them some information and I wondered

7

whether it was information from the Prevezon case

8

and I've seen speculation to that effect, but I

9

don't have any knowledge.

10

Q. If we had the specifics of the

11

information, would you be able to clarify whether

12

it had come from Fusion?

13
14
15

A. I think so.

If it's, you know, stuff I

worked on I obviously will recognize it, yes.
Q. As far as you know, how was this meeting

16

arranged or do you have any information beyond

17

what's in the public --

18

A. I don't.

19

Q. Other than recent media reports, do you

20

have any reason to believe that the meeting was an

21

attempt by the Russian government to make contact

22

with the Trump campaign?

23

A. I mean, that's kind of an analytical

24

question.

I don't have any factual reason to

25

believe that.

I don't have possession of any

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information about this that would allow me to say

2

one way or the other.

3

question of counterintelligence and just general

4

investigation of Russian methods and that sort of

5

thing, I think that's a reasonable interpretation.

6

Q. Have you had any communications about the

7

You know, as a sort of

meeting at any time with Rinat Akhmetshin?

8

A. No.

9

Q. Have you had any communications about the

10

No.

meeting, again, at any time with Ms. Veselnitskaya?

11

A. No.

12

Q. Have you had any communications about the

13

meeting with anyone you worked with on the Prevezon

14

matter?

15

A. Probably.

16

expressions of surprise.

17

Levine, a lawyer at Baker Hostetler.

18

discussed it with Ed Baumgartner, Mark Cymrot.

19

know, if anyone knew about it they certainly didn't

20

confess it to me.

21
22

I think we all exchanged mutual
I think I talked to Paul

You

Q. Do you know -- I'm going to butcher this
name -- Irakle Kaveladze?

23

A. I know who he is.

24

Q. I'll spell it.

25

I'm sure I

I-R-A-K-L-E, last name

K-A-V-E-L-A-D-Z-E.

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A. No, I don't know.

2

Q. Has Fusion ever worked with him?

3

A. No, not to my knowledge.

4

Q. To the best of your knowledge, did he have

5
6

any role in the Prevezon or Magnitsky work?
A. My knowledge is primarily of the Prevezon

7

case and, to my knowledge, he was not involved in

8

the Prevezon case in any way.

9

Q. Do you have any reason to believe beyond

10

public reporting that he has ties to the Russian

11

government?

12

A. I've been told by a source that --

13

actually, I was told by a source that there was

14

some reason to believe he had ties to the Russian

15

government, and he directed me to a newspaper

16

article which said that he had connections to a guy

17

on the West Coast named Boris Goldstein who has

18

been linked historically to Soviet Russian

19

intelligence.

20

don't have any information.

Beyond that I don't have any -- I

21

Q. And who was the source that told you that?

22

A. I'm not going to talk about my source.

23

Q. I think you've already addressed this a

24

little bit, but do you know Anatoli Samochornov?

25

A-N-A-T-O-L-I, S-A-M-O-C-H-O-R-N-O-V.

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A. I met him in connection with this case.

2

We've never had any kind of social or other

3

relations beyond chatting in courthouses and that

4

sort of thing, sitting in restaurants waiting for a

5

hearing to start.

6
7

Q. Has Fusion ever worked with him other than
on the Prevezon case?

8

A. No.

9

Q. And to the best of your knowledge, what

10

was his role in the Prevezon case?

11

A. As I understood it, he was recruited off

12

the rack basically as a certified -- a translator

13

who had courtroom experience in New York who was

14

qualified to do sort of technical-legal type

15

translation work.

16

a pre-existing relationship with Ms. Veselnitskaya

17

or Prevezon.

18
19

He, to my knowledge, didn't have

That's my understanding to this day.

MR. DAVIS:
hour.

I think that's the end of our

It is 1:04.

Let's go off the record.

20

(Whereupon, at 1:05 p.m., the

21

interview was recessed, to

22

reconvene at 1:45 p.m., this

23

same day.)

24

AFTERNOON SESSION

25

MS. SAWYER:

We'll go back on the record.

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It's 1:55.

2
3

EXAMINATION
BY MS. SAWYER:

4

Q. I'm going to return you back to discussing

5

the work at Fusion that Christopher Steele had done

6

during the Presidential election of 2016.

7

been widely reported and Mr. Steele has

8

acknowledged that he created 16 memos before the

9

election between the time period of June of 2016

10

and October of 2016.

11
12

It has

Is that accurate?

A. To the best of my knowledge, that's
accurate.

13

Q. And then he also has acknowledged --

14

Mr. Steele also has acknowledged and it's been

15

reported that there was one additional memo that

16

came after the election in December of 2016.

17

that also accurate?

18

Is

A. I think what he has said is that -- yeah,

19

that's basically accurate.

20

the series of memos that were published by

21

BuzzFeed, that's the package that you're talking

22

about.

23

(Exhibit 3 was marked for

24
25

What he said was that

identification.)
BY MS. SAWYER:

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Q. And so I'm going to show you what we will

2

just mark as Exhibit 3 for identification purposes.

3

So Exhibit 3 that I've just given you is a document

4

that was produced to the committee by your lawyers,

5

and they had explained to us that this was a

6

document originally posted by BuzzFeed in January

7

of 2017 and it has Bates numbers down in the

8

right-hand corner.

9

CLMS-JC-00041391 and then the last one is number

The first one is

10

41425.

If you could just take a look at that.

Is

11

that what we were just discussing as the series of

12

memos posted by BuzzFeed and created by Mr. Steele?

13

A. Yes, it is.

14

Q. Can you explain for us just what -- does

15

this represent the 16 memos that would have

16

occurred between June and October of 2016 that

17

Mr. Steele created?

18

A. These are the memos that he created under

19

the engagement and then this extra one that is

20

appended.

21

them up, but these are the ones I'm familiar

22

with.

I never actually numbered -- totaled

23

Q. And does this represent the entire

24

universe of memos that Mr. Steele created as part

25

of this particular engagement for you?

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2

A. To the best of the my knowledge as part of
this engagement, this is it.

3

Q. And can you just explain to us so that we

4

understand the document, it has a heading "Company

5

Intelligence Report."

6

first page.

7

Report 2016/080."

8
9

I'm just looking at the

That one says "Company Intelligence
What would that have signified?

A. Company Intelligence Report is just a way
of saying it's not a government document.

In the

10

event that, you know, someone stole it or it leaked

11

or there was some sort of breach, you know, they're

12

not going to have their own name on it, but they

13

want to make sure that no one mistakes it for a

14

government document.

15

That's my understanding.

080 is their internal numbering system for,

16

you know, their production of memoranda, and the

17

reason it jumps from 80 to 86 is -- I never

18

actually asked him, but there aren't five memos in

19

between this.

20

an internal numbering system for maybe Russia stuff

21

or maybe it's just -- I'm sorry.

22

the internal numbering system is, but there isn't

23

five memos in this project between these two.

24

Q. So the company referenced in Company

25

So the interpretation is that it's

I don't know what

Intelligence Report, your understanding is that

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would be Orbis, not Fusion GPS?

2

A. I can't answer that.

I think it's, as I

3

said, meant to denote that it's not a government

4

report.

5

Q. Were they producing -- as you noted, the

6

next apparent report 086 would be five, presumably,

7

reports later.

8

reports that were being generated for Fusion GPS

9

or --

10

A. No.

11

MR. LEVY:

12

ahead.

13

BY THE WITNESS:

14

Were those other five reports

I don't think he said that.

Go

A. I mean, there aren't five reports that he

15

did for us between these two.

16

and second.

This is the first

17

Q. So, again, when we look at that first one

18

that we discussed briefly, 2016/080, it appears to

19

be a three-page memorandum and it's dated 20 June

20

2016 and that shows up on the last page.

21

have received it around that time that it's dated,

22

June 20, 2016?

Would you

23

A. Within a couple days, yeah.

24

Q. And not every single discrete memo has a

25

date, but a number of them do.

Yes.

To the extent they

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had dates, would you have been receiving them

2

around the time they were dated?

3
4
5
6
7

A. Yeah.

I believe so, yes.

There might be

some lag, transition lag.
Q. And what was -- what use did you make of
these memos?
A. These memos -- I mean, I guess I'd like to

8

back up a little bit and explain, you know, what

9

led to the memos, which was -- as I said, I mean,

10

you know, we started looking at -- first we started

11

looking at Trump's business affairs generally with

12

some of the emphasis on associations with organized

13

crime and in particular Russian organized crime.

14

As the project progressed towards the end of 2015

15

and into 2016 we became interested in his overseas

16

business dealings particularly because they were so

17

opaque and seemed to involve, you know, to say the

18

least, colorful characters.

19

So as we got into 2016 we were looking

20

broadly at -- one of the things we were looking at,

21

broadly speaking, was Donald Trump's international

22

business dealings and, you know, through the spring

23

of 2016, as I mentioned, we were -- you know, we

24

looked in various places, Latin America.

25

worked on projects all over the world, but in

He has

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particular, you know, several in the former Soviet

2

Union, Georgia, Azerbaijan, both former Soviet

3

republics.

4

say -- and Russia -- we gradually began to exhaust

5

the public record, the open source about these

6

topics in various places.

7

of run short on public record or open source

8

information, you know, you need to get -- if you

9

still want to go deeper you need to get human

10
11

So over the course of the spring I'd

As you, you know, sort

source.
So the purpose of this was to see if we could

12

learn more, generally speaking, about his business

13

dealings in Russia.

14

you know, very different and obviously more

15

alarming, which had to do with -- you know, which

16

outlined a political conspiracy and a much broader

17

set of issues than the ones that we basically went

18

looking for.

19

what do with this.

20

What came back was something,

You know, initially we didn't know

The main thing we did with it, the use we

21

made of it was as intelligence, which is to

22

understand what's happening.

23

the first indicators were starting to float around

24

that there was something bigger going on, the

25

government of Russia or someone was doing some

So when this arrived

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hacking.

I don't really remember the precise

2

details.

I just remember there were rumblings at

3

that time about whether there had been lot of

4

hacking and there was going to be -- political

5

digital espionage was going to be a component of

6

the campaign.

7

So when this arrived it was also right around

8

the time I think -- Trump had said weird things

9

about the Russians and Putin and things that are

10

very atypical for a Republican and that people

11

found to be odd.

12

we made no immediate use of it at all in terms of,

13

you know, giving it to anybody.

14

used to inform our other researcher, but because it

15

was -- and because it was human source intelligence

16

and some of it was of a personal nature, it was not

17

particularly useful for the kind of things that

18

are, you know, useful in politics, which are things

19

that you can prove, things that you can say, things

20

that people will believe.

21

So when this arrived, you know,

It was essentially

So we used it as intelligence to try and

22

understand what was going on and, you know,

23

obviously, as we talked about earlier, we tried to

24

analyze this to see if it was credible.

25

I did -- you know, in the initial round of this

You know,

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2

that was the big question, was this credible.
Q. Okay.

So let me stop you there for a

3

second before we get too far because you've

4

referred a number of times to "this" and you have a

5

35-page document in front of you.

6

clarify when you said "this," in the context of

7

answering that I assumed you were talking about the

8

first --

9

So I want to

A. The first memo.

10

Q. That's the report 2016/080?

11

A. Correct.

12

Q. And that's the one that has the date of 20

13
14

June 2016?
A. Correct.

To be totally clear, you know,

15

what people call the dossier is not really a

16

dossier.

17

field interviews, a collection that accumulates

18

over a period of months.

19

intermittently, there was no schedule.

20

he'd reach a point in the reporting where he had

21

enough to send a new memo; so he'd send one.

22

you won't find any real rhythm or chronological

23

sort of system to the way they came in.

24
25

It's a collection of field memoranda, of

MR. MUSE:

You know, they came in
You know,

So

Just for clarification of "this,"

there are bates numbers I think that could be

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2

identified here.
MS. SAWYER:

Right.

So that first document,

3

the one that we've just been talking about, has

4

Bates Nos. 49391 to 41393.

5

the record for a moment?

6

for a moment.

7
8
9

Do we need to go off
Let's go off the record

(A short break was had.)
BY MS. SAWYER:
Q. With regard to this document, you

10

characterized this document as representing field

11

interviews, I think you talked about it as human

12

source information.

13

role with regard to the project primarily

14

conducting these types of interviews, gathering

15

this type of what I think you referred to as human

16

intelligence for Fusion?

17
18

A. Yes.

I mean, in other cases we did other

things.

19

MR. LEVY:

20

BY THE WITNESS:

21

So was Mr. Steele's kind of

Don't get into other cases.

A. I can't remember specifically what I had

22

in mind to get from him.

This form of reporting

23

was, in fact, the form that the rest of the project

24

took, which was, you know -- I've done other kinds

25

of research in Russia, but something this sensitive

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I don't think I've ever been involved in.

2

ordinary case you would try to gather public

3

records and you would conduct yourself in a much

4

more open fashion.

5

So in an

You know, Russia is a dangerous place, it's a

6

kleptocracy and a police state, but it's also a

7

giant bureaucracy and in some ways it's a much more

8

open society, much more open than the Soviet Union

9

ever was.

10

You can pull records for companies and

that sort of thing.

11

Anyway, so this was unusual in what we were

12

doing here and it's not what I had in mind when I

13

asked him to begin collecting information on this.

14

My expectation was of something a lot less

15

interesting than this, more along the lines of a

16

typical corruption investigation.

17

Q. You had indicated that when you received

18

it you found it unusual, it was sensitive

19

information.

20

the information?

21

Did you take steps to verify any of

A. We assessed it for credibility, whether it

22

was credible.

The question of the credibility of

23

the information is obviously a big question here,

24

can this be believed.

25

questions that would follow on from that, can it

There's other secondary

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somehow be used, does it have any use and that sort

2

of thing, but the threshold question is is it

3

credible information.

4

You know, there were two background factors

5

to that.

One was who is it coming from.

It's

6

coming from Chris Steele who's a guy that I've

7

worked with for, you know, about eight or nine

8

years and Chris, as I say, has a Sterling

9

reputation as a person who doesn't exaggerate,

10

doesn't make things up, doesn't sell baloney.

In

11

my business, I mean, there are a lot of people who

12

make stuff up and sell baloney.

13

that you get good at if you do this for a while is

14

finding reliable sources, finding reliable people

15

who have a record of giving it to you straight and

16

not making stuff up and not making mistakes.

17

from that perspective, you know, this was alarming

18

because Chris is a credible person, he's well

19

respected in his field, and, as I say, everyone I

20

know who's ever dealt with him thinks he's quite

21

good.

22

government.

So the one thing

So

That would include people from the U.S.

23

So the issue is where is it coming from and

24

then the other issue is does it make sense or are

25

there events in there that can be externally, you

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know, reviewed or backed up.

On the question of

2

whether it makes sense -- well, let me stay on the

3

question of some of the events that are described.

4

We were aware of some of these trips and we were

5

obviously aware of the hostility toward Hillary

6

Clinton and, you know, there was a lot of general

7

knowledge that we had that fit with this just in

8

terms of dates and places and roles of people in

9

the Kremlin.

So on a surface level, you know, it

10

was credible too, but the thing that, you know,

11

most concerned me at this point was my own

12

familiarity with foreign meddling in American

13

elections, which is a subject that I've dealt with

14

for a long time.

15

In the 1990s I was working at the Wall Street

16

Journal and I wrote some of the very first stories

17

about the Chinese government's interference in the

18

1996 presidential election which triggered a

19

massive national security investigation, numerous

20

prosecutions, lots of business for Bob Muse, and a

21

lot of congressional hearings, congressional

22

inquiries.

23

dug out by congressional investigations that the

24

fundraisers, the Asian fundraisers were Chinese

25

intelligence assets.

And in that episode it was eventually

So there's ample recent

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historical precedent for a foreign government to

2

interfere in American elections in a really big way

3

and for it to be an intelligence operation.

4

knew all of that while reading this and digesting

5

it for the first time.

6

So I

I also knew because I've done a lot of

7

reporting on Russia about the Kremlin's interest in

8

American politics, European politics, disrupting

9

the politics of other countries, and, in fact, one

10

of the last things I did when I was a reporter at

11

the Wall Street Journal was report on several

12

stories of government investigations, FBI

13

investigations into American politicians who had

14

been corrupted allegedly by the Russians.

15

Sort of my departure point from journalism

16

was a series of stories and conferences I attended

17

where a lot of American and European intelligence

18

officials were expressing great alarm at the

19

resurfacing of Russian intelligence operations in

20

western capitals and the new twist on it which

21

seemed to be that these guys seemed to be getting

22

involved in politics in ways that they hadn't

23

previously.

24
25

So I knew all that when I read this.

Q. Okay.

So if I can stop you there.

It

sounds like the components -- you can tell me if

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there were more -- that you considered in assessing

2

the credibility of this was Mr. Steele, his

3

background, his reputation, overall the fact that

4

you had information and knowledge of Russia

5

meddling in other countries' elections, and then

6

the broader work of Russia to disrupt political

7

systems of other countries?

8
9

A. I covered that.

I also would add that the

China case was for me in my journalistic career a

10

formative event that took -- you know, consumed

11

years of my reporting and was about, you know, a

12

Chinese intelligence operation to swing the '96

13

election to the Democrats.

14

The only other thing I'd add to all that is,

15

again, in the mid 2000s one of the stories I

16

wrote -- actually, I wrote a couple different

17

stories about a Russian oligarch having a meeting

18

with Senator John McCain shortly before the 2008

19

presidential election and another story or set of

20

stories about Paul Manafort and his involvement

21

with some Russian and Ukrainian oligarchs who were

22

considered to be suspicious or corrupt.

23

So I also knew -- or I formed an opinion or

24

impression that the Russians were interested in

25

making friends with the Republicans and that Paul

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Manafort, you know, there was this previous episode

2

involving Paul Manafort, John McCain.

3

that was in my head when this came in which, as I

4

say, tended to support the credibility -- the

5

possibility that this information was credible.

6

Q. You mentioned a Russian oligarch who had

7

met with Senator McCain.

8

that?

9

So all of

Who specifically was

A. Oleg Deripaska, O-L-E-G,

10

D-E-R-I-P-A-S-K-A.

He's not able to travel to the

11

United States because he's banned for suspicion of

12

ties to organized crime.

13

the Kremlin, or at least he was, and is -- I broke

14

the story of him being banned from the United

15

States which caused him a lot of embarrassment and

16

trouble with his business and led to him hiring a

17

lobbyist and trying to get involved with getting a

18

visa to the U.S.

He's extremely close to

19

Q. And you had also mentioned your background

20

knowledge of Paul Manafort and his involvement with

21

Russian oligarchs.

22

individuals were and the basis of that knowledge?

23

Can you identify who those

A. The issue I specifically wrote about I

24

believe was his work for the Party of Regions and

25

Victor Yanukovych, Y-A-N-U-K-O-V-Y-C-H, I think,

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and that's the Pro-Russia party or was the

2

Pro-Russia party in Ukraine, and all that work sort

3

of grew out of work I had done about the Kremlin

4

working with the Russian mafia to siphon money off

5

the gas trade between Russia and Ukraine.

6
7

Q. Was that work you had done while still a
reporter with the Wall Street Journal?

8

A. Yes.

9

Q. So any conclusions you had reached from

10

that, would that be material that we would be able

11

to obtain and may already have in your public

12

reporting?

13

MR. LEVY:

We'd have to talk to the Wall

14

Street Journal about that probably.

15

BY THE WITNESS:

16
17
18
19
20
21

A. My articles about this are available on
the Internet.
MR. LEVY:

Some of them we've produced to you

already because it was responsive to your request.
MS. SAWYER:

Understood.

BY MS. SAWYER:

22

Q. And there's potentially additional work

23

product related to the work that you had done on

24

Mr. Manafort?

25

A. For the Wall Street Journal or later?

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2
3

Q. Let's start with the Wall Street
Journal?
A. I collected lots of information on

4

Mr. Manafort during my years at the Journal.

5

Q. And then we'll get into the work on

6

Mr. Manafort more recently.

7

So this particular memo that we've been

8

talking about, this first one doesn't specifically

9

mention, as far as I can see, any efforts to

10

interfere by Russia.

11

potential -- as it's called in here, a dossier of

12

compromising material on Hillary Clinton.

13

take any steps to verify whether that dossier of

14

compromising material existed on Hillary Clinton?

15

It does talk about

Did you

A. I will answer that, but can I just back

16

you up a little bit.

I think your observation it

17

doesn't mention anything about interfering I

18

wouldn't agree with.

19

Q. Okay.

20

A. I mean, one of the key lines here in the

21

second paragraph says "However, he and his inner

22

circle have accepted a regular flow of intelligence

23

from the Kremlin, including on his democratic and

24

other political rivals."

25

So the issue with the Trump Tower meeting, as

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I understand it, is that the Trump people were

2

eager to accept intelligence from a foreign

3

government about their political rivals and that

4

is, you know, I would say, a form of interference.

5

If you're getting help from a foreign government

6

and your help is intelligence, then the foreign

7

government's interfering.

8

think that also -- of course, in retrospect we now

9

know this was pretty right on target in terms on

10
11
12
13

what it says.

I mean, you know, I

So anyway --

Q. In reference to you think that particular
sentence?
A. I mean, it clearly refers to, you know,

14

them being interested in and willing to -- it

15

depicts them as accepting information.

16

have seen to date with the disclosures this year is

17

they were at a minimum super interested in getting

18

information.

19

What we

Q. And when you're referencing the

20

"disclosures this year," could you just be specific

21

about that.

22

A. The Trump Tower meeting.

23

Q. So with reference to the June 9th Trump

24
25

Tower meeting?
A. Yes.

Yes.

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Q. Okay.

2

A. I will go back to your question, but,

3

again, it says "Source B asserted the Trump

4

operating was both supported and directed by Putin

5

aimed to sew discord within the U.S.," and, you

6

know, basically -- you know, there's a number of

7

different ways that it seems they're trying to

8

intervene in our politics in this memo.

9

What was your question?

10

Q. I appreciate that clarification.

11

actually clarifying a statement I made, which I

12

appreciate.

13

You were

So you had testified a little earlier that at

14

the point in time in which you received this first

15

memo you used it a little more as background to

16

inform your thinking on it, but you didn't take

17

discrete steps.

18

editing this memo in any way?

Had you -- were you involved in

19

A. No.

20

Q. Did you give Mr. Steele any specific

21

direction on, you know, next steps based on this

22

memo?

23

A. Not that I can recall, no.

24

Q. So at this point in time was he still

25

operating with the understanding that he was just

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2

to engage in an open-ended research project?
A. Actually it wasn't really an open-ended

3

research project -- well, it was open-ended in

4

scope, it wasn't open-ended in time.

5

few weeks, see if there's anything there that's

6

interesting, notable, important, and if we think

7

there's reason to go on we'll make that decision at

8

that time.

9

the beginning.

10

It was take a

So it was a short-term engagement in

Q. And to the best you can explain to us, did

11

the client that you were working for know that he

12

was engaged in this particular research or what his

13

findings were at that point in time?

14

MR. LEVY:

The answer to that question might

15

implicate privilege or obligations.

16

BY MS. SAWYER:

17

Q. Did you interfere in any way with

18

Mr. Steele's research, tell him not to pursue any

19

particular avenues?

20

A. No.

21

Q. To the best of your knowledge, did anyone

22

else give him that direction, either directly or

23

through you, and tell him not to --

24

A. No.

25

Q. If I could just finish.

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A. I'm sorry.

2

Q. -- and tell him not to pursue any

3

particular avenues of research?

4

A. No.

5

Q. Do you know -- if we could just move on to

6

kind of the next memo, which begins with Bates

7

No. 41394 and it ends with 41396.

8

be -- it's three pages and it has a date of 26 July

9

2015 and it has "Company Intelligence Report

It appears to

10

2016/086."

11

this the second memo you had received from

12

Mr. Steele?

13
14

A. To the best of my recollection, this is
the second memo.

15
16

To the best of your recollection, was

Q. And how did you kind of use this
information?

17

A. Well, I think the context of external

18

events is important here.

I believe -- it's my

19

recollection that what prompted this memo was, in

20

fact, the beginning of public reporting on the

21

hack.

22

it's 26 July.

23

Schultz has been the subject of a very aggressive

24

hacking campaign, weaponized hack, the likes of

25

which, you know, have never really been seen.

I think -- what is the date again?

Yeah,

So by this time Debbie Wasserman

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We've seen hacking in politics before, but this

2

kind of, you know, mass theft of e-mail and then to

3

dump it all into, you know, the public sphere was

4

extraordinary and it was criminal.

5

So the question by now of whether this was

6

Russia and whether this might have something to do

7

with the other information that we'd received was,

8

you know, the immediate question, and I think this

9

is also -- by the time this memo was written Chris

10

had already met with the FBI about the first memo.

11

So he's -- if I can interpret a little bit here.

12

In his mind this is already a criminal matter,

13

there's already a potential national security

14

matter here.

15

I mean, this is basically about a month later

16

and there's a lot of events that occurred in

17

between.

18

Chris said he was very concerned about whether this

19

represented a national security threat and said he

20

wanted to -- he said he thought we were obligated

21

to tell someone in government, in our government

22

about this information.

23

perspective there was an issue -- a security issue

24

about whether a presidential candidate was being

25

blackmailed.

You know, after the first memo, you know,

He thought from his

From my perspective there was a law

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enforcement issue about whether there was an

2

illegal conspiracy to violate the campaign laws,

3

and then somewhere in this time the whole issue of

4

hacking has also surfaced.

5

So he proposed to -- he said we should tell

6

the FBI, it's a national security issue.

I didn't

7

originally agree or disagree, I just put it off and

8

said I needed to think about it.

9

again with me.

Then he raised it

I don't remember the exact sequence

10

of these events, but my recollection is that I

11

questioned how we would do that because I don't

12

know anyone there that I could report something

13

like this to and be believed and I didn't really

14

think it was necessarily appropriate for me to do

15

that.

16

that, I know the perfect person, I have a contact

17

there, they'll listen to me, they know who I am,

18

I'll take care of it.

19

agreed, it's potentially a crime in progress.

20

you know, if we can do that in the most appropriate

21

way, I said it was okay for him to do that.

22

In any event, he said don't worry about

Q. Okay.

I said okay.

You know, I

So let me just stop you there and

23

let's just make sure we get the sequencing

24

accurate.

25

So,

A. Sure.

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Q. So after Mr. Steele had found out the

2

information that he put in the very first of these

3

memos, the one dated June 20, 2016, he approached

4

you about taking this information to specifically

5

the FBI, the Federal Bureau of Investigation?

6

A. That's my recollection.

7

Q. So to the best of your recollection, that

8

request or idea came directly from Mr. Steele, not

9

anyone else?

10

A. That's right.

11

Q. And who was involved in discussions about

12

whether it was appropriate to take either the memo

13

or the information in the memo to the FBI?

14

A. It was Chris and me.

15

only ones I remember, the two of us.

16

I know of.

17

I mean, that's the
The only ones

Q. You said you had asked for some time to

18

think it over.

19

articulate to you was of significant national

20

security concern to indicate that it should be

21

taken to the FBI?

22

What in particular did he

A. His concern, which is something that

23

counterintelligence people deal with a lot, is

24

whether or not there was blackmail going on,

25

whether a political candidate was being blackmailed

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or had been compromised.

2

compromise of western businessmen and politicians

3

by the Russians is an essential part of -- it's

4

like disinformation, it's something they worry

5

about a lot and deal with a lot and are trained to

6

respond to.

7

officer can spot disinformation that you or I might

8

not recognize, certainly that was Chris's skill,

9

and he honed in on this issue of blackmail as being

10
11

And the whole problem of

So, you know, a trained intelligence

a significant national security issue.
Chris is the professional and I'm not.

So I

12

didn't agree with that -- it wasn't that I

13

disagreed with it.

14

qualified to be the arbitrar of whether this is a

15

national security expert.

16

ex-journalist.

It was that I didn't feel

He's the pro and I'm the

17

Q. In that regard when you say he's a

18

professional and you're not, I take that to mean

19

that he was the intelligence expert?

20

A. He was -- yes, he was the national

21

security guy.

22

a good bit about financial crime, but, you know, my

23

specialty was journalism and his was security.

24
25

I know a lot about politics, I know

Q. And with specific regard to the issue of
blackmail, what was the -- what were the facts that

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he had gathered that made him concerned about the

2

possibility of blackmail and who did he think was

3

going to be blackmailed?

4

A. Well, the facts are -- beyond what's here

5

I don't have any additional facts.

The alleged

6

incident that's described here is the one that he

7

was referring to.

8

any additional information beyond this except

9

that -- I mean, it's probably in here somewhere

As I say, I don't have really

10

actually, but it's well known in intelligence

11

circles that the Russians have cameras in all the

12

luxury hotel rooms and there are memoirs written

13

about this by former Russian intelligence agents I

14

could quote you.

15

kompromating is just endemic to east-west

16

intelligence work.

17

to.

18

So the problem of kompromat and

So that's what I'm referring

That's what he's referring to.
Q. Got it.

So that would be in the summary

19

the kind of third dash point down where it

20

mentions --

21

A. Yes, that's right.

22

Q. -- that FSB -- what is your understanding

23
24
25

of who or what FSB is?
A. It's a successor to the KGB.

I mean,

nominally it's the domestic intelligence agency on

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the domestic side of what was the KGB.

2

it's sort of the preeminent intelligence organ of

3

the Russian state, government.

4

In practice

Q. And do you recall when you -- when you and

5

Mr. Steele decided kind of that he could or should

6

take this to the FBI, approximately the time frame

7

of that?

8
9
10
11

A. I believe it was sometime around the turn
of the month.

It would have been in late June or

at latest early July.

That's my recollection.

Q. And Mr. Steele was the one who was then

12

responsible for doing the initial outreach to them

13

and making that contact?

14

A. Yes.

Well, I mean, let's be clear, this

15

was not considered by me to be part of the work

16

that we were doing.

17

like, you know, you're driving to work and you see

18

something happen and you call 911, right.

19

wasn't part of the -- it wasn't like we were trying

20

to figure out who should do it.

21

professionally obligated to do it.

22

a lawyer and, you know, you find out about a crime,

23

in a lot of countries you must report that.

24

was like that.

25

obligation, then you should fulfill your

This was -- to me this was

It

He said he was
Like if you're

So it

So I just said if that's your

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2

obligation.
Q. And were you a part of those conversations

3

with -- that Mr. Steele had with whoever his

4

contact was at the FBI?

5

A. No.

6

Q. Do you have any knowledge of when that

7
8
9

first conversation actually then took place?
A. Over the last several months that this has
become a public controversy I've learned the

10

general date and I believe it was if first week of

11

July, but I don't believe he told me -- if he told

12

me the time, I don't remember when he told me.

13
14
15

Q. And that information about that time, that
first week of July, where does that come from?
A. It comes from news accounts of these

16

events and conversations between Chris and I and

17

some of my -- presumably my business partners too.

18

Generally speaking, we have, as you know, not been

19

eager to discuss any of this in public and there's

20

been a lot of speculation and guessing and stories,

21

many of which are wrong.

22

story comes out we would, you know, talk about it.

23

So, you know, in the course of those kinds of

24

things I generally obtained a sense of when things

25

occurred that I might otherwise not be able to

So when an incorrect

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2
3
4

provide you.
Q. And do you know who it is that Mr. Steele
contacted and talked with at the FBI?
A. I did not know at the time.

I believe I

5

know now, but I don't have authoritative

6

information on that.

7

know who it was in July.

I didn't -- yeah.

I didn't

8

Q. And do you now know who that was?

9

A. I think I know, but Chris never told me.

10

I figured it out eventually based on other sources

11

and other information, but that was not until

12

December or November.

13

Q. December of -- November or December 2016?

14

A. November, December 2016.

15
16

It was after the

election.
Q. And what is your understanding from what

17

you've been able to put together of who that would

18

have been?

19

A. My understanding of?

20

Q. Of who Mr. Steele would have talked to at

21
22

the FBI.
A. I believe it was a
, an official named

24
25

.
Q. And we had talked about that discussion

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that you had with Mr. Steele about potentially

2

going to the FBI.

3

just the two of you having those conversations and

4

coming to that decision.

5

made, did you share that decision with anyone, that

6

he was going to go to the FBI with this

7

information?

You had indicated that it was

Once the decision was

8

A. I think we're not able to answer that.

9

MR. LEVY:

10

that question.

11

BY MS. SAWYER:

12
13

He's going to decline to answer

Q. Did you seek anyone else's approval for
him to go to the FBI?

14

A. No.

15

Q. Did anyone ever encourage you to ask him

16

on to go to the FBI?

17

A. No.

18

Q. Did anyone discourage you from having him

19

go to the FBI?

20

A. No.

21

Q. Do you know whether Mr. Steele when he had

22

that first meeting, which you said occurred in the

23

first week of July, do you know whether Mr. Steele

24

actually gave the FBI this document that we've been

25

talking about, the intelligence report 2016/080?

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A. I don't know.

2

Q. With regard to providing -- what was the

3

goal -- as you understood it, what was the purpose

4

of the kind of goal in taking this to the FBI from

5

Mr. Steele's perspective?

6

MR. LEVY:

7

MS. SAWYER:

8

Beyond what he's said already?
Yes.

BY THE WITNESS:

9

A. I mean, for him it was professional

10

obligations.

I mean, for both of us it was

11

citizenship.

You know, people report crimes all

12

the time.

13

Q. So beyond reporting -- certainly if I'm

14

mischaracterizing please let me know, but beyond

15

reporting what he believed was an issue of national

16

security and a potential crime, I think you had

17

said kind of a potential crime in progress, do you

18

know whether he requested that the FBI open an

19

investigation?

20

A. I don't know that.

I mean, all he told me

21

in the immediate aftermath was that he filled him

22

in.

23

happens when you give them information because I

24

know that from years of experience, but generally,

25

you know, you don't ask them to do it.

I can talk generally about the FBI and what

There's no

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2

ask.
Q. But you don't know what concrete steps

3

they may have taken once they got the information

4

from him?

5

A. I do not.

Of course we know now that

6

shortly thereafter they got a vice award on one of

7

the people who's dealt with in here.

8

dealt with in this memo, but he's dealt with in the

9

later memos.

He's not

I don't know there's any connection

10

between these events.

11

Comey's testimony he said -- I'm sorry.

12

skipping ahead.

13

don't know what they did.

14

I do know in Director
Maybe I'm

As far as I know, they didn't -- I

Q. So then with regard to Mr. Steele's

15

ongoing work, I presume that his work then

16

continued after you got this first memo because we

17

have additional memos between June?

18

A. Yes.

19

Q. Was there a discussion about whether and

20
21

when he would take information to the FBI?
A. Not that I recall.

After the initial memo

22

he told me that he had briefed him.

I don't

23

remember anything specific about the issue arising

24

again other than to say generally that as the

25

summer progressed the situation with the hacking of

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the Democrats and the efforts by the Russians to

2

influence the election and the possibility that the

3

Trump organization was, in fact, doing things to

4

curry favor with the Russians became more and more

5

serious as external developments occurred.

6

So, for instance, they changed the Republican

7

platform, which is addressed in here.

Carter Page

8

shows up in Moscow and gives a speech.

9

campaign advisor and he gives a speech about

He's a

10

dropping sanctions.

11

mysterious things about what a great guy Putin is.

12

So I vaguely recall that these external events

13

prompted us to say I wonder what the FBI did,

14

whoops, haven't heard from them.

15

basically the state of things through September

16

Trump continues to say

So that was

Q. So do you know whether or not Mr. Steele

17

did have any subsequent conversations with the FBI

18

after that initial conversation in the first week

19

of July 2016?

20

A. Yes, I do.

21

Q. So can you explain the next incident where

22
23

He did.

you know that Mr. Steele met with the FBI?
A. Yes.

I guess what I'd like to explain is

24

what I knew at the time and what I know now.

It

25

was September and obviously the controversy was

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really front and center now in the election.

2

can't remember whether the intelligence community

3

had come out with their statement, but, you know,

4

there was a lot of concern in Washington and in the

5

U.S. about whether there was a Kremlin operation to

6

interfere with our election and there was a lot of

7

debate throughout this period about whether they

8

were trying to help Trump or just trying to cause

9

trouble.

10

I

But there wasn't much debate that they

were up to something.

11

So, you know, I'm dealing with Chris on the

12

underlying reporting and by this time my concern,

13

you know, was -- I was very concerned because Chris

14

had delivered a lot of information and by this time

15

we had, you know, stood up a good bit of it.

16

Various things he had written about in his memos

17

corresponded quite closely with other events and I

18

began, you know, to view his reporting in this case

19

as, you know, really serious and really credible.

20

So anyway, we were working on all of that and

21

then he said, hey, I heard back from the FBI and

22

they want me to come talk to them and they said

23

they want everything I have, to which I said okay.

24

He said he had to go to Rome, I said okay.

25

to Rome.

He went

Then afterwards he came back and said,

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2

you know, I gave them a full briefing.
I'll add because I didn't consider this to

3

be -- you know, there was no objective here

4

politically because you can't -- in an ordinary

5

election I know from my decades of dealing with

6

U.S. elections that you can't expect the government

7

or the FBI to be of any use in a campaign because

8

the DOJ has rules against law enforcement getting

9

involved in investigations in the middle of a

10

campaign and this was obviously -- you know, this

11

obviously became a huge issue.

12

Anyway, because it wasn't really part of the

13

project in my mind I didn't really ask a lot of

14

questions about these meetings.

15

he met with, I didn't ask, you know, much of

16

anything, but he did tell me that he gave --

17
18

I didn't ask who

Q. Before we get to that, which I do want to
hear, I just want to get a sense of the chronology.

19

A. Sure.

20

Q. So when did that -- you had said the FBI

21

then came back and contacted Mr. Steele?

22

A. That's my understanding.

23

Q. When did that, to the best of your

24
25

knowledge, take place?
A. Mid to late September.

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Q. So in that intervening time period

2

Mr. Steele continues his research, he also

3

continues to provide you with memos?

4

A. Yes.

5

Q. And at no point in that time between

6

July -- the first week of July when he first met

7

with the FBI and then mid to late September did you

8

suggest to him that he should go back to the FBI?

9

A. Not that I recall.

What I would -- what I

10

believe I may have said was have you heard anything

11

from the FBI because by then it was obvious there

12

was a crime in progress.

13

whether he'd heard back.

14

So I just was curious

Q. And when you say it was obvious that there

15

was a crime in progress, what specifically are you

16

referencing?

17

A. Espionage.

They were hacking into the

18

computers of Democrats and think tanks.

19

computer crime.

20

That's a

Q. So the thing that was apparent was Russia

21

or somebody had engaged in cyber intrusion and

22

computer crimes?

23

A. Yes.

24

Q. So do you know whether or not Mr. Steele

25

was directed -- you said you did not direct him or

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ask him to go back to the FBI -- whether anyone

2

else either directly or indirectly asked him to go

3

to the FBI after his July 5th --

4

A. To my knowledge, no one else told him to

5

report this.

6

business associates, but I don't know.

7

He may have conferred with his

Q. And you said that meeting with the FBI,

8

you said Mr. Steele said he had to go to Rome for

9

this meeting.

10
11

Do you otherwise know who he met

with?
A. This gets into the chronology of what I

12

learned when.

13

meeting with the lead FBI guy from Rome.

14

remember when he told me that.

15
16

At some point I learned that he was
I don't

Q. And did you have a name associated with
who that was?

17

A. Not at that time.

18

Q. You said that he told you of the meeting

19

with the FBI in Rome in mid or late September, that

20

he "gave them a full briefing"?

21

A. A debrief I think is what he probably

22

said, they had debriefed him.

I don't remember him

23

articulating the specifics of that.

24

understanding was that they would have gotten into

25

who his sources were, how he knew certain things,

You know, my

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and, you know, other details based on their own

2

intelligence.

3

had other intelligence about this matter from an

4

internal Trump campaign source and that -- that

5

they -- my understanding was that they believed

6

Chris at this point -- that they believed Chris's

7

information might be credible because they had

8

other intelligence that indicated the same thing

9

and one of those pieces of intelligence was a human

10
11

Essentially what he told me was they

source from inside the Trump organization.
Q. And did you have any understanding then or

12

now as to who that human intelligence source from

13

inside the Trump campaign might have been?

14
15

MR. LEVY:

He's going to decline to answer

that question.

16

MS. SAWYER:

On what basis?

17

MR. SIMPSON:

18

MR. LEVY:

19

BY THE WITNESS:

Security.

Security.

20

A. We had been really careful -- I was really

21

careful throughout this process to not ask a lot of

22

specific sourcing questions.

23

I know that I just don't feel comfortable sharing

24

because obviously it's been in the news a lot

25

lately that people who get in the way of the

There are some things

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Russians tend to get hurt.

2

MR. LEVY:

And I would just add that there

3

are privileges and obligations that might be

4

implicated in the disclosure of any source related

5

to this matter.

6

BY MS. SAWYER:

7

Q. Was this individual also a person who had

8

been a source for Mr. Steele, without identifying

9

who that was?

10

A. No.

11

Q. So this was someone independent of

12

Mr. Steele's sources who potentially had

13

information also on the same topics?

14

A. Yes.

I mean, I don't think this

15

implicates any of the issues to say I think it was

16

a voluntary source, someone who was concerned about

17

the same concerns we had.

18

MR. DAVIS:

19

you.

20

BY THE WITNESS:

21
22
23
24
25

I'm having a hard time hearing

Please speak up.

A. It was someone like us who decided to pick
up the phone and report something.
Q. And your understanding of this, does that
come from Mr. Steele or from a different source?
A. That comes from Chris, yes.

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1
2

Q. And when did he share that information
with you?

3

A. I don't remember exactly.

4

Q. Do you think it was around the same time

5

that he had met with the FBI, so mid to late

6

September of 2016?

7

A. I think more likely early October.

8

Q. Do you know whether when Mr. Steele met

9

with the FBI he provided them with the memos that

10

he would have had at that point in time, which

11

would have been mid to late September of 2016?

12

A. I don't know that.

He didn't tell me

13

that.

14

to know everything he had, but whether that would

15

include getting paper I don't know.

16

He did say they asked him for -- they wanted

Q. And did he indicate that he had cooperated

17

fully and given them whatever information he had

18

available?

19

A. Yes.

In the course of these, you know,

20

discussions, you know, he indicated to me this was

21

someone he had worked with previously who knew him

22

and that they had a -- they worked together.

23

Q. By that person you're referring to

24
25

in Rome?
A. Yes.

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Q. Now, with regard to -- just to finish up

2

on the interactions with FBI, do you know were

3

there any additional interactions between

4

Mr. Steele and the FBI?

5

A. There was some sort of interaction, I

6

think it was probably telephonic that occurred

7

after Director Comey sent his letter to Congress

8

reopening the investigation into Hillary Clinton's

9

e-mails.

That episode, you know, obviously created

10

some concern that the FBI was intervening in a

11

political campaign in contravention of

12

long-standing Justice Department regulation.

13

So it made a lot of people, including us,

14

concerned about what the heck was going on at the

15

FBI.

16

the press about, you know, whether they were also

17

investigating Trump and, you know, we encouraged

18

them to ask the FBI that question.

19

think -- I'm not sure we've covered this fully,

20

but, you know, we just encouraged them to ask the

21

FBI that question.

So, you know, we began getting questions from

You know, I

22

On October 31st the New York Times posed a

23

story saying that the FBI is investigating Trump

24

and found no connections to Russia and, you know,

25

it was a real Halloween special.

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Sometime thereafter the FBI -- I understand

2

Chris severed his relationship with the FBI out of

3

concern that he didn't know what was happening

4

inside the FBI and there was a concern that the FBI

5

was being manipulated for political ends by the

6

Trump people and that we didn't really understand

7

what was going on.

8

them.

9

Q. Okay.

So he stopped dealing with

So I do want to get to the timing

10

on that.

I know that I'm getting close to the end

11

of my hour.

12

on the memos that we were talking about.

13

asked you specifically about the first one, if you

14

had in any way -- first of all, with regard to the

15

packet on whole, did you have any input or

16

involvement in the drafting of these or input for

17

the research?

Can I just ask you a general question
I had

18

A. No.

19

Q. And did you edit any of them in any way?

20

A. No.

21

Q. So these were documents that you were just

22
23

receiving from Mr. Steele?
A. Yes.

I mean, the only qualifier I'd add

24

is I'm sure I said things like Paul Manafort was

25

just named campaign manager, what do you know about

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2

him, that kind of thing.
Q. I do want to get into some more specifics

3

about kind of what steps and what items you may

4

also clarify, but I do want to make sure, if I

5

could have your indulgence, just that we -- well,

6

we can finish up the FBI part on our next hour

7

because it sounds like there's a little more to

8

finishing that.

9

give me a moment.

10
11

Okay.
record.

14

It is 2:58.
(A short break was had.)

MR. DAVIS:

17
18
19
20
21
22

We'll go back on the record.

It's now 3:09.

15
16

If you'll just

So we'll go ahead and go off the

12
13

So our hour is up.

EXAMINATION
BY MR. DAVIS:
Q. Mr. Simpson, do you know Emin Agalarov,
E-M-I-N, A-G-A-L-A-R-O-V?
MR. LEVY:

Personally or just does he know

about him?
MR. DAVIS:

Personally.

BY THE WITNESS:

23

A. No.

24

Q. Do you know Aras, A-R-A-S, Agalarov?

25

A. No.

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2

Q. Has Fusion ever worked with either of
them?

3

A. No.

4

Q. To the best of your knowledge,

5

have

either of them had any role in the Prevezon work?

6

A. Not to my knowledge.

7

Q. Do you know Rob Goldstone?

8

A. No.

9

Q. Has Fusion ever worked with him?

10

A. No.

11

Q. Paid him or been paid by him?

12

A. No.

13

Q. To the best of your knowledge, has

14

Mr. Goldstone had any work in the Prevezon or

15

Magnitsky work?

16

A. Not to my knowledge.

17

Q. When you had these dinners in June of 2006

18

with Ms. Veselnitskaya, who else attended those

19

dinners?

20

MR. FOSTER:

21

MR. DAVIS:

22
23
24
25

2016.
2016.

Excuse me.

BY THE WITNESS:
A. The Baker lawyers would have attended, did
attend.
Q. Was Rinat Akhmetshin there?

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A. I specifically remember he was at the

2

second dinner on I think it was the 10th.

3

specifically remember if he was at the other

4

dinner.

5

dinner.

6
7

I don't have many memory of the other

Q. Do you recall if he was at the court
hearing on the 9th?

8
9

I don't

A. I believe he was.

I'm not certain of it.

The other person would have been a translator at

10

some of these dinners.

11

ones.

I can't remember which

12

Q. Were there any other individuals there

13

involved with HRAGI or Prevezon work beyond the

14

people you've mentioned?

15
16
17
18
19
20

MR. LEVY:

When you say "there," you're

talking about now?
MR. DAVIS:

You're right.

At the hearing.

BY THE WITNESS:
A. The hearing.

Before you were asking about

the dinners, right?

21

Q. I was.

22

A. Now you're asking about the hearing.

23

just want to be clear.

24

hearing and there may have been other people

25

involved.

I

Well, it was a crowded

I mean, I remember specifically pretty

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much most of the Baker legal team was there,

2

Natalia was there, I believe she -- I believe

3

Anatoli was her translator for that.

4

some other people who I think were also from Baker

5

Hostetler who were there.

6

Mukasey was arguing for Prevezon.

7

remember that there were lawyers -- people who I

8

believed were lawyers who were there to watch the

9

argument and maybe had some connection to the case.

There was

Former Attorney General
So I just

10

There was another associate I think from New York

11

who was there, usually came to some of the Court

12

hearings.

13
14
15
16

That's all I remember.

Q. And the first dinner on the 8th were there
any other attendees?
A. I don't remember.

I think John Moscow

might have been there.

17

Q. And the second dinner on the 10th, were

18

there any other attendees beyond the ones you've

19

already described?

20

A. I don't recall.

My wife.

21

Q. You mentioned that information Fusion had

22

gathered may have been passed on to the HRAGI

23

people via Baker Hostetler or if they instructed

24

you to that you would have.

25

expectation that that would reasonably result in

Did you have any

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them influencing U.S. policy?

2

A. I can't say that I would have specifically

3

expected anything from that.

I was acting --

4

lawyers hire me to do research for them, the

5

research is their property or their client's

6

property, it's not mine.

7

provide it to somebody else, it's their

8

information.

9

ministerial thing.

So if they want me to

So I would -- it's a fairly
I'm not sure I would have an

10

expectation of any sort of specific result from

11

that.

12
13
14
15
16

Q. But you did understand HRAGI to be
lobbying on the Hill?
A. They were registered to lobby on the Hill.
So I believe that's what they were doing, yeah.
Q. And did you understand that your actions

17

on behalf of Prevezon or Baker Hostetler would

18

principally benefit the Russian government?

19

did you believe the principal beneficiary to be?

20

MR. LEVY:

I'd like to note for the record

21

that Patrick is smiling as he's asking the

22

question.

23

Who

You can answer.

MR. MUSE:

24

laughter.

25

BY THE WITNESS:

He's trying to contain his

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2
3

A. We did not believe that was being done on
behalf of the Russian government.
Q. What do you understand Prevezon's

4

relationship, if any, to be with the Russian

5

government?

6

A. Prevezon was introduced to me as the

7

client and Denis Katsyv was the owner of Prevezon.

8

Generally speaking, when we take on a new case, you

9

know, from a respected law firm part of the, you

10

know, discussion is who's the client, and, you

11

know, Mark Cymrot said they've checked out Denis

12

Katsyv and he has -- he's a legitimate businessman.

13

He's got a real estate company, it's a successful

14

company, and he has an explanation for how he makes

15

his money and appears to be legit.

16

whenever you enter a new case that's part of what

17

you're being hired to determine is whether that

18

initial due diligence stands up, but in any event,

19

he was presented to me as a successful real estate

20

investor.

21

To some extent

As I say, I worked with Baker Hostetler for a

22

number of years and it's a conservative midwestern

23

law firm with a lot of respected people in it, and

24

part of the obligations of lawyers in this country

25

and now in a lot of other countries is to determine

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where their money comes from and who their clients

2

are and whether their clients are involved in

3

criminal activity.

4

specifics of our discussions of these matters, but

5

one of the issues was whether he's a legitimate

6

businessman.

7

I don't remember the exact

Q. Did you ever receive a letter of inquiry

8

from the Department of Justice regarding the

9

applicability of the Foreign Agent Registration Act

10

to your work on the Prevezon case or Magnitsky

11

matter?

12

A. No, I have not.

13

Q. Did you charge any fees to any other

14

entities or people besides Baker Hostetler for work

15

on the Prevezon or Magnitsky matters?

16

A. I don't think so, no.

I specifically can

17

tell you I wasn't compensated by this foundation or

18

anybody else involved in any of the lobbying.

19

Q. At the time of this June -- early June

20

trip to New York had you already engaged Mr. Steele

21

to do work on Mr. Trump's involvement with Russia?

22

A. I don't specifically remember.

As I

23

mentioned, the actual agreements are handled by

24

other people on my staff.

25

Q. Which employees and associates of Fusion

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worked on the project investigating then candidate

2

Donald Trump?

3
4

MR. LEVY:

We can give you that information

at the end of the interview.

5

MR. DAVIS:

6

MR. LEVY:

Why at the end of the interview?
I just want to make sure that

7

employees involved in this matter are protected.

8

We've had death threats come to the company.

9

be happy to cooperate with the committee and give

We'll

10

the names of those people.

11

outside of this transcript, unless you're going to

12

assure me the transcript is going to be kept

13

confidential.

14
15
16
17
18
19

MR. FOSTER:
question.

Let's go back to the previous

What was the previous question?

MR. DAVIS:

Whether he'd already started

working with Mr. Steele during the time of the -MR. FOSTER:

During the time of the meetings

in early June, right?

20

MR. SIMPSON:

21

MR. FOSTER:

22

And your answer was?

I don't know.
Do you have -- you said you

don't handle those issues at the company.

23

MR. SIMPSON:

24

MR. FOSTER:

25

I just want to do it

That's right.
So your company does have

records that would establish that fact?

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2

MR. SIMPSON:

We

should have records of agreements and things, yeah.

3
4

We keep books and records.

MR. FOSTER:

So did you not review any of

those in preparation for today?

5

MR. LEVY:

6

MR. FOSTER:

What he reviewed is privileged.
Have you reviewed them -- I'm

7

not asking if you reviewed them with counsel.

8

you reviewed them recently?

9

MR. LEVY:

If he reviewed anything to prepare

10

for this interview it would have been at the

11

direction of counsel and attorney work product.

12

Have

MR. FOSTER:

So you do or don't know whether

13

you have such records that would identify the

14

date -- the precise dates of the engagements?

15

MR. LEVY:

We will --

16

MR. FOSTER:

17

MR. LEVY:

18

MR. SIMPSON:

I'm just asking what he knows.
I think he's told you.

Go ahead.

I'll just restate that we run

19

a -- it's a reasonably well-run company, we keep

20

books and records.

21

things are kept in our corporate files.

22

BY MR. DAVIS:

23

So, you know, those kinds of

Q. Did Baker Hostetler or Prevezon pay for

24

your travel to New York for the meetings in June of

25

2016?

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MR. LEVY:

2

MR. DAVIS:

3

The meetings?
The dinner after the hearing.

BY THE WITNESS:

4

A. The purpose of the trip was the hearing.

5

It was routine for me to attend hearings.

6

would bill them -- my office would bill them for my

7

train trips and hotels depending on whether there

8

was -- whether it was specifically for the Prevezon

9

case.

10
11
12

So I

I don't know if -- I don't know for a fact

that we billed them.
Q. Did you travel with any other members of
the Prevezon team either to or from New York?

13

A. I don't think so.

14

Q. So I think you've already stated that Ed

15

Baumgartner worked on both projects, on the

16

Prevezon project and another Trump investigation.

17

To the best of your knowledge, does Mr. Baumgartner

18

know Rinat Akhmetshin?

19

A. I don't know.

I'd just like to clarify,

20

you know, my recollection is that Ed worked -- the

21

Prevezon thing wound down and I don't think I

22

brought Ed on until it was either ending or had

23

already ended.

24
25

Q. Can you clarify the time frame for when it
was winding down?

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MR. LEVY:

2

you say "it."

3

BY THE WITNESS:

4

Talk about what the "it" was when

A. The hearing was on June 9th, I guess we

5

said, and that was the culmination of a long

6

controversy over whether Browder was going to have

7

to testify and whether, you know, we had to be

8

disqualified and, you know, there was a whole

9

series of media attacks on us during that period

10

from Browder.

11

that was, you know, sort of the peak of that.

12

was after that that a lot of the issues involving

13

Russia and the campaign started to heat up.

14

Then nothing happened after that and
It

Q. Was there any overlap between the

15

employees from Fusion who were working on the Trump

16

investigation and the Prevezon case?

17

A. I think the primary employees did not

18

overlap, but I can't tell you that there was a

19

Chinese wall of separation.

20

specialize in certain things and can contribute

21

ad hoc to something.

Various people

22

Q. And you worked on both, correct?

23

A. Yes, I did.

24

Q. You previously mentioned that Fusion had

25

hired subcontractors beyond Mr. Steele to work on

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the Trump project.

Was there any overlap of other

2

subcontractors between the Trump investigation and

3

the Prevezon work?

4

A. Not to my recollection.

5

Q. And had Fusion worked with Mr. Steele

6

prior to this project regarding Mr. Trump?

7

A. Yes.

8

Q. And had you previously paid him or Orbis?

9

A. I believe so, yeah.

10
11

Q. And had Fusion been paid by him or Orbis
as well?

12

A. Yes, I believe so.

13

Q. And are you aware of any interactions

14

Mr. Steele had with the FBI prior to his work on

15

the investigation of Mr. Trump and his associates?

16

MR. MUSE:

17

MR. DAVIS:

Could you repeat that?
Are you aware of any interactions

18

with Mr. Steele with the FBI prior to his work on

19

the investigation of Mr. Trump and his association?

20

BY THE WITNESS:

21

A. I was not at the time, but I am now.

22

Q. Did you have reason to believe that in his

23

prior position within British intelligence he would

24

have interacted with the FBI?

25

A. Yes, he's told me that.

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Q. Do you believe that the FBI generally

2

considers sources more credible if they have

3

previously provided reliable information?

4

A. That's my understanding.

5

Q. Was Mr. Steele's reportedly successful

6

history in working with the FBI a factor in

7

deciding to hire Orbis for the Trump project?

8

A. No.

9

Q. Do you know Christopher Burrows?

10

A. Yes.

11

Q. Do you know if he worked on the Trump-

12

Russia project with Orbis?

13

A. I do not.

14

Q. Do you know Sir Andrew Wood?

15

A. No.

16

Q. Are you aware he's an associate of Orbis

17
18

Business Intelligence?
A. I am aware of that as of now.

I didn't

19

know it -- I don't know when I learned of it, but I

20

didn't know it last year, much of last year.

21

Q. Did Fusion ask Orbis to undertake other

22

actions beyond preparing the memoranda containing

23

the allegations regarding Mr. Trump and his

24

associates?

25

A. Not that I specifically -- I'm sorry.

In

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connection with that engagement?

2

Q. In connection with that engagement.

3

A. Not that I specifically recall.

4

Q. Did you communicate with Mr. Steele other

5

than through these memos?

6

and e-mails with him?

Did you have phone calls

7

A. Mostly we spoke by phone.

8

MR. FOSTER:

You did also e-mail with him?

9

MR. SIMPSON:

Nothing -- I don't believe I

10

had anything substantive.

11

major problem.

12

try to communicate telephonically on an encrypted

13

line.

14
15

E-mail security is a

So, generally speaking, we would

MR. FOSTER:

Did you have another method of

communicating with him via text.

16

MR. SIMPSON:

17

methods of communicating.

18

concern we have involve there's been a lot of

19

attempts to break into our systems.

20

not to get into a lot of that, but suffice to say

21

we use secured encrypted systems.

22

MR. FOSTER:

I mean, we used encrypted
Part of the security

So I prefer

Regardless of the details of how

23

you did, do you retain copies of written

24

communications that you may have engaged with him

25

through some other secure method?

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MR. SIMPSON:

2

MR. FOSTER:

3

MR. SIMPSON:

4
5

You have not retained?

MR. FOSTER:

Disappearing messages, auto

deleting messages?

7

MR. SIMPSON:

9
10
11
12

Generally we use things that

can't be stolen because they no longer exist.

6

8

Generally not.

Is that correct?
That sort of thing, yes, that's

correct.
MR. FOSTER:

I just needed a verbal answer.

MR. SIMPSON:

Yeah.

Sorry.

BY MR. DAVIS:
Q. You previously mentioned the relationship

13

with Mr. Steele was more collaborative than a

14

manager-employee and I think you referenced

15

mentioning as an example Paul Manafort's been named

16

campaign chairman, what do you know about him.

17

you collaborate with Mr. Steele on the content of

18

the memos even if he did the drafting?

19

A. No, generally speaking.

Did

I was managing a

20

much bigger project and he's a reliable provider.

21

So I did very little tasking.

22

Q. You mentioned other subcontractors were

23

focusing on other regions in which the Trump

24

organization has business.

25

subcontractors retained until the election or how

Were those other

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2

long did their engagements last?
A. It was ad hoc.

So as things came we said

3

can we find someone in Latin America, give them an

4

assignment, they'd complete the assignment.

5

there's no more to do, stop.

6

generalize.

7

If

So it's hard to

Q. One point I'd like to clarify from

8

Ms. Sawyer's questioning.

I believe you said that

9

Mr. Steele had told you that the FBI had a source

10

from inside the Trump organization and I believe

11

she referred to a source from inside the Trump

12

campaign.

13

Do you know which is the accurate --

MR. LEVY:

He's not going to get into the

14

details of that source.

15

MR. DAVIS:

16

details.

17

and by counsel.

18

BY THE WITNESS:

I'm not asking for any particular

It was characterized differently by you
I just wanted to make sure.

19

A. I don't know.

20

MR. FOSTER:

21

So you don't know whether it was

the organization or the campaign, in other words?

22

MR. SIMPSON:

23

MR. FOSTER:

24

campaign.

25

BY MR. DAVIS:

That's correct.
Meaning the business versus the

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2

Q. And did Mr. Steele tell you that the FBI
had relayed this information to him?

3

A. He didn't specifically say that.

4

Q. I'm going to have you take a look at one

5

of the filings --

6

MR. FOSTER:

7
8
9

I thought you said earlier that

he did say the FBI told him.
MR. SIMPSON:

I think I was saying we did not

have the detailed conversations where he would

10

debrief me on his discussions with the FBI.

11

would say very generic things like I saw them, they

12

asked me a lot of questions, sounds like they have

13

another source or they have another source.

14

wouldn't put words in their mouth.

15

18

He

(Exhibit 4 was marked for

16
17

He

identification.)
BY MR. DAVIS:
Q. I'm going to have you take a look at one

19

of the filings by Mr. Steele's attorneys in the

20

lawsuit against him and Orbis in the United

21

Kingdom.

22

please turn to page 2 and read paragraph No. 8.

23

That paragraph states "At all material times Fusion

24

was subject to an obligation not to disclose to

25

third parties confidential intelligence material

This will be Exhibit 4.

If you could

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provided to it by the Defendants in the course of

2

that working relationship without the agreement of

3

the Defendants."

4

your understanding of how the material was to be

5

treated?

6
7
8
9

MR. MUSE:

Is that a correct description of

There's also a context to that who

the Defendants are in other such matters.
MR. DAVIS:

Sure.

The Defendants are Orbis

Business Intelligence Limited and Christopher

10

Steele.

11

BY THE WITNESS:

12

A. What's the question?

13

Q. Is that an accurate description of what

14

you understood the obligations to be with that

15

material?

16

A. I mean, that's hard for me to answer.

17

There's a mutual expectation of confidentiality,

18

and if that's what you read that as saying, then

19

yes, there's a mutual expectation of

20

confidentiality.

21
22
23

Q. Was that expectation established by
contract?
MR. LEVY:

We're not going to talk about

24

contracts with clients.

25

BY MR. DAVIS:

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Q. Was it established by practice?

2

A. I guess I'll just reiterate we do

3

confidential work together and we treat all matters

4

as confidential.

5

that and so am I.

6

He's pretty good at sticking to

Q. Was any of the information included in the

7

memoranda Orbis prepared during the Trump

8

investigation not considered "confidential

9

intelligence" under this understanding such that

10

Fusion was not required to obtain Orbis's

11

permission in order to disclose it?

12

A. I don't really understand the question.

13

Q. I'm saying if the understanding is that

14

you weren't to disclose confidential intelligence

15

material, were the memos confidential intelligence

16

material, the dossier memos?

17

A. They're confidential, yes.

18

MR. MUSE:

Hold on one second.

Here's the

19

mischief that's created by that.

Someone else is

20

sending this and you're asking what they mean.

21

There may be direct answers to those questions if

22

you ask direct questions, but to do it in the frame

23

of reference of someone else putting forth a piece

24

of evidence, which this is, it inevitably creates

25

confusion.

The reference to the document adds

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nothing to his knowledge.

2

of reference by you, but it doesn't add anything to

3

what he might be saying.

4

to get at it is simply to ask direct questions.

5

MR. DAVIS:

It's just simply a point

So I think the better way

There are two parties to this, at

6

least, and we've got one's description.

7

to know if he agrees with that description.

8
9

MR. MUSE:

But even within what do they mean

by this is the question.

10

by this sort of paragraph.

11

an interpretation.

12

the relationship.

13

MR. DAVIS:

I'd like

I mean, what do they mean
You're asking him for

He can answer questions about

I'm asking him to give an

14

interpretation of their agreement in terms of what

15

he did.

16

MR. MUSE:

17

MR. DAVIS:

And therein lies the problem.
But if it's an agreement to which

18

he's a party, there's a basis for that

19

understanding.

20
21
22

MR. MUSE:

I don't think that's the way the

rule works.
MR. FOSTER:

Well, I think the bigger

23

mischief from my point of view is the fact that

24

we're trying to get an understanding of what the

25

contractual relationship was.

You're telling us

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you're not going to provide us with details about

2

that contractual relationship, you're not going to

3

provide us with copies of any nondisclosure

4

agreements, contracts we've asked for and we don't

5

have.

6

what obligations he had.

So we're asking him for his understanding of

7

MR. LEVY:

8

this interview.

9

And that's outside the scope of
Go ahead.

MS. SAWYER:

Can I in general ask that you

10

guys all speak up a little bit because we're right

11

under the blower.

12

MR. LEVY:

13

MR. FOSTER:

14

not raising our voices.

15

Will do.
The record will reflect we are

To be clear, you're instructing him not to

16

answer that question because you think it's outside

17

the scope of what he agreed to come here to talk

18

about voluntarily?

19

MR. LEVY:

That's not what I said.

You had

20

made a comment about contracts, and I just wanted

21

to make sure that obviously the Chair and the

22

Ranking Member have agreed those questions are not

23

part of the scope of this interview.

24

I've now forgotten what the pending question was.

25

So if Patrick wants to restate it he can and we can

That said,

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2

evaluate it.
MR. DAVIS:

Sure.

In general we're asking

3

questions about distribution of the material within

4

the dossier which was the scope of the agreement.

5

If you look at page 4 of that same exhibit,

6

paragraph 30, Steele's attorneys state "The

7

Defendants" -- and again, that's Orbis Business

8

Intelligence and Christopher Steele -- "did not

9

however provide any of the pre-election memoranda

10

to any of the media or journalists, nor did they

11

authorize anyone to do so, nor did they provide the

12

confidential December memorandum to media

13

organizations or journalists, nor did they

14

authorize anyone to do so."

15

To the best of your knowledge, did Orbis ever

16

authorize Fusion to make any disclosures of the

17

memoranda to the media?

18

MR. LEVY:

Just before we get into this

19

question, this paragraph began with a sentence you

20

did not read and it says "In the first sentence of

21

subparagraph 8.2.5 as noted."

22

they're referring to.

23

us that?

24
25

MR. DAVIS:

I don't know what

Maybe you do.

Can you show

I don't have that with me at the

moment, but I'll see if we can find it. Regardless,

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did Orbis ever authorize you to share the memoranda

2

with the media?

3

BY THE WITNESS:

4
5

A. I'm not sure I can answer this in -- I'm
not sure I know the answer to this.

6

MR. LEVY:

7

MR. SIMPSON:

8

MR. FOSTER:

9

If you don't know, then...
It's a little confusing.
You don't know whether or not

Orbis or Mr. Steele authorized you to distribute

10

the memos to the media?

11

MR. SIMPSON:

I think what I would like to

12

say is that we had discussions about, you know,

13

information as opposed to memos and, you know, at

14

various times in talking to reporters about the

15

Trump-Russia connection, you know, things -- those

16

discussions would be informed by what's in the

17

memos.

18

MR. FOSTER:

So are you saying that you may

19

have provided information from the memos to the

20

media without discussing whether or not -- without

21

getting permission specifically From Mr. Steele or

22

Orbis?

23

MR. SIMPSON:
No.

What I'm saying is we discussed

24

that.

I'm saying we discussed generally the

25

wisdom of answering questions from reporters about

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different matters, what we could say and what we

2

couldn't say.

3

MR. FOSTER:

And in those discussions did he

4

ever authorize you to discuss the information

5

contained in the memoranda with the media?

6

MR. SIMPSON:

As I've stated before, this is

7

not a master-servant relationship.

8

together.

9

sometimes I'm working for his.

We worked

Sometimes he's working for my clients,
So we might jointly

10

make a decision, but it's not a sort of can I do

11

this, yes you can do that kind of relationship.

12

if they -- so I hope that's responsive.

13

MR. FOSTER:

So did you ever share either the

14

memos or the content of the memos with the media

15

independently of him without having discussed it

16

with him?

17

So

MR. SIMPSON:

I think what I said was I had

18

spoken with reporters over the course of the summer

19

and through the fall about the investigations by

20

the government and the controversy over connections

21

between -- alleged connections between the Trump

22

campaign and the Russians.

23

discussed was informed by Chris's reporting.

24

whether that was -- I don't think there's any sense

25

that that was an unauthorized thing to do.

Some of what we
So

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MR. DAVIS:

2

MR. FOSTER:

3
4
5

On page 5 -Is it something that you

discussed with him that you were doing?
MR. SIMPSON:

We would discuss inquiries that

we had received from reporters, yes.

6

MR. FOSTER:

And that you were answering?

7

MR. SIMPSON:

To the best of our ability.

8

mean, we obviously didn't tell people about the

9

existence of these things for a long time.

10
11

I

BY MR. DAVIS:
Q. On page 5 of that same exhibit, paragraph

12

32 there's a portion of the sentence -- and I'll

13

just read this for background before we move on to

14

another segment.

15

context.

16

attorneys state that he gave -- that the Defendants

17

gave "Off-the-record briefings to a small number of

18

journalists about the pre-election memoranda in

19

late summer/autumn 2016."

20

Exhibit 5 which is the second filing by

21

Mr. Steele's attorneys.

22

MS. SAWYER:

23
24
25

I think this is relevant for

There's a portion here in which Steele's

Patrick, you've represented this

one as the second filing.
MR. DAVIS:

I'd like to provide

Are we sure these are --

Second for the purpose of this

interview, second one we're referencing.

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MS. SAWYER:

Were these documents that were

2

requested or obtained from a third party in the

3

course of the investigation?

4

MR. DAVIS:

5

published in the media.

6

was published by McClatchy.

7

MS. SAWYER:

8

MR. DAVIS:

9

I believe the second one

And what about the first?
That was the one published by the

Washington Times.

10

(Exhibit 5 was marked for

11
12

These were documents that were

identification.)
BY MR. DAVIS:

13

Q. So with the second one on page 8 of

14

Exhibit 5, under the response to 18 Steele's

15

attorneys state "The journalists initially briefed

16

at the end of September 2016 by the second

17

Defendant and Fusion at Fusion's instruction were

18

from the New York Times, the Washington Post, Yahoo

19

News, the New Yorker, and CNN.

20

Defendant" -- that would be Mr. Steele --

21

"subsequently participated in further meetings at

22

Fusion's instruction with Fusion and the New York

23

Times, the Washington Post, and Yahoo News which

24

took place in mid-October 2016.

25

cases the briefing was conducted verbally in

The second

In each of those

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person.

In addition, and again at Fusion's

2

instruction, in late October 2016 the second

3

Defendant briefed the journalist from Mother Jones

4

by Skype.

5

were ever shown or provided to any journalist by or

6

with the authorization of the Defendants.

7

briefings involved the disclosure of limited

8

intelligence regarding indications of Russian

9

interference in the U.S. election process and the

No copies of the pre-election memoranda

The

10

possible coordination of members of Trump's

11

campaign team and Russian government officials."

12

To the best of your knowledge, is that a full

13

and accurate account of all the news organizations

14

with which Fusion and Mr. Steele shared information

15

from the memoranda.

16

A. I'd say it's largely right.

17

Q. Are there any that have been omitted?

18

A. Maybe, yeah.

19

MR. LEVY:

20

BY THE WITNESS:

Just say what you know or recall.

21

A. Yeah.

I think there's at least one thing

22

misidentified.

23

can't specifically think of it, but I think this is

24

incomplete, that maybe one of the broadcast

25

networks is misidentified.

There might have been another.

I

I just don't have a

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tally of this.

2
3

It's mostly right.

Q. By broadcast network I assume you mean CNN
is incorrect, it was a different network?

4

A. I think so.

5

Q. Do you recall which network it was?

6

A. I think it was ABC.

7

Q. Did you attend these meetings with

8

Mr. Steele?

9

A. Yeah.

Yes.

10

Q. Did any other Fusion associates attend?

11

A. Possibly, yes.

12

Q. Can you identify them?

13

MR. LEVY:

14

afterwards.

15

BY MR. DAVIS:

16
17

We can give that to you

Q. Do you recall the specific dates of these
meetings?

18

A. No.

19

Q. I believe the filing says end of September

20

2016.

Does that comport with your recollection?

21

A. Yes.

22

Q. Was this, as far as you know, before or

23

after Mr. Steele had had his second meeting with

24

the FBI?

25

A. I don't remember.

Sorry.

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Q. Did Mr. Steele ever indicate to you

2

whether the FBI had asked him not to speak with the

3

media?

4

A. I remember Chris saying at some point that

5

they were upset with media coverage of some of the

6

issues that he had discussed with him.

7

Q. Sorry.

8

A. He never said they told him he couldn't

9

I didn't hear.

talk to them.

10

Q. Do you recall which journalists you spoke

11

to at each of these organizations and what

12

information from the memoranda was revealed to

13

each?

14

A. I remember some of them and I remember

15

some of the names, yeah, some of the people I

16

talked to and some of these discussions.

17

Q. Can you tell us what those were?

18

MR. LEVY:

The answer to that question goes

19

to confidential conversations that's been declined

20

to answer.

21

MR. FOSTER:

22

MR. LEVY:

Sorry.

Confidential what?

The answer to that question might

23

implicate privilege and other obligations we've

24

already set forth and he's not going to answer the

25

question.

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MR. FOSTER:

2

MR. LEVY:

3

MR. FOSTER:

What's the privilege?
First amendment, confidentiality.
Confidentiality agreement,

4

contractual obligation, is that what you're talking

5

about?

6

MR. LEVY:

No.

Just talking to confidential

7

sources, First Amendment issue.

8

later after the interview.

9

BY MR. DAVIS:

10

We can discuss it

Q. Mr. Steele's filing indicates that these

11

meetings occurred at Fusion's instruction.

12

correct, did you initiate these meetings and

13

instruct Mr. Steele to participate in them?

14

Is that

A. I'd just reiterate the nature of our

15

relationship was that we would -- I might propose

16

something and he might agree to do it, but it was

17

not a -- it was not a military style relationship

18

where I gave the orders and he carried them out.

19

Q. Was part of the purpose of your

20

investigation to share information with

21

journalists?

22

A. I think that's a fair statement.

23

extent -- I mean, I'm sorry.

24

You mean the project overall?

25

To the

Could you be clear.

Q. Yes, investigating Mr. Trump and his

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associates.

2

A. As I said earlier, in any project, and

3

that would include this one, the objective is to

4

gather relevant information, and some of that

5

information was gathered for other purposes and

6

some of it was gathered for the possibility that it

7

might be useful to the press.

8
9

Q. Did your client instruct you to have these
meetings?

10

MR. LEVY:

The answer to that question might

11

implicate privilege or obligations that we've set

12

forth.

13

BY MR. DAVIS:

14

Q. Do you have any reason to believe that

15

Mr. Steele passed any information on to journalists

16

without Fusion?

17

A. Without me -- you mean without me

18

participating, without me authorizing it?

19

be more specific?

Can you

20

Q. Sure.

Let's start without you

21

participating.

22

both you and Fusion jointly had with journalists.

23

Do you believe he had any meetings with journalists

24

without you present?

25

MR. LEVY:

The filing references meetings that

Without Mr. Simpson physically

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present?

2

MR. DAVIS:

For physical meetings or via

3

Skype, without him aware of them contemporaneously.

4

BY THE WITNESS:

5

A. That's a difficult question to answer

6

because I don't know what I don't know, but I don't

7

have any reason to believe that he did anything

8

that I didn't authorize or approve.

9

Q. Jason may have already touched on this,

10

but did Fusion disclose hard copies of the

11

memoranda to any journalists?

12

MR. LEVY:

The answer to that question might

13

implicate privilege or obligations.

14

to decline to answer that question.

15
16

MR. FOSTER:

So he's going

Doesn't the filing say that they

did not?

17

MR. LEVY:

While our letter to the committee

18

has said that neither Mr. Simpson nor Fusion GPS

19

provided the dossier to BuzzFeed, Mr. Simpson's

20

going to decline to answer your question

21

respectfully.

22

today.

23

BY MR. DAVIS:

24
25

He's given you a lot of information

He's not going to answer that question.

Q. Still with Exhibit 5 on page 2, the
responses to 4 and 6.

Here the attorneys for Orbis

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2
3

and Mr. Steele -MR. LEVY:

Where are you again?

BY MR. DAVIS:

4

Q. Page 2, the response to 4 and to 6.

Here

5

the attorneys for Orbis and Mr. Steele state "The

6

duty not to disclose intelligence to third parties

7

without the prior agreement of the Defendants" --

8

again, that's Orbis and Mr. Steele -- "do not

9

extend to disclosure by Fusion to its clients,

10

although the Defendants understand that copies of

11

the memoranda were not disclosed by Fusion."

12
13

A. Where are you?

You're on page 2 -- okay.

I see it now.

14

Q. -- "do not extend to disclosure by Fusion

15

to its clients, although the Defendants understand

16

that copies of the memoranda were not disclosed by

17

Fusion to its clients."

18

Further down on that same page in response to

19

a question about whether Fusion's clients, insofar

20

as disclosure to them, was permitted, could

21

themselves disclose the intelligence from Orbis,

22

the filing responds "Defendants understood that the

23

arrangement between Fusion and its clients was that

24

intelligence would not be disclosed."

25

Is that a correct statement of the

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relationship between you and the client, did Fusion

2

not disclose the memoranda or information contained

3

there in to its clients?

4

MR. LEVY:

He's not going to get into

5

discussion with the client because of privileges

6

and obligations that might be implicated by the

7

answer to that question.

8

BY MR. DAVIS:

9
10
11

Q. Do you believe this filing is accurate in
those paragraphs?
MR. LEVY:

Again, to comment on that he would

12

have to talk about client communications that are

13

privileged and might implicate privilege or

14

obligation were he to answer your question.

15

BY MR. DAVIS:

16

Q. Mr. Simpson, do you believe that any

17

confidentiality obligations regarding the memos did

18

not extend to law enforcement and intelligence

19

services?

20

A. Yes.

I mean, I -- well, in general I

21

think that in the course of any sort of

22

confidential business lawyers or other

23

professionals engage in if they come across

24

information about a possible terrorist attack or a

25

mafia operation they should report it, yes, and

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that that is, in fact, not covered by ordinary

2

confidentiality.

3

Q. Was Fusion aware of the reports that the

4

FBI considered -- let me rephrase.

5

aware that the FBI considered paying Mr. Steele to

6

investigate Mr. Trump and his associates?

7

A. When?

8

Q. At any time.

9

MR. LEVY:

10

MR. DAVIS:

12

MR. LEVY:

13

reimbursements?
MR. DAVIS:

15

context.

16

BY THE WITNESS:

17

Providing money.
For a fee?

Are you talking about

Fees or reimbursements in this

A. We've learned that.

18

fact, it was --

19

MR. LEVY:

20

BY THE WITNESS:

21

When you say "paying," what do you

mean by that?

11

14

Was Fusion

We know that now.

Learned what?

A. Well, we learned -- sometime after the

22

election we learned that Chris had discussed

23

working for the FBI on these matters after the

24

election and that that didn't happen.

25

In

Q. Did Mr. Steele discuss that with you at

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the time?

2

A. He didn't discuss it -- I don't remember

3

exactly when he mentioned this to me, but he

4

mentioned to me at some point I think after the

5

election that he had discussed this with them.

6

MR. FOSTER:

So prior to news reports to that

7

effect?

8

not from the news; is that right?

9

In other words, you learned it from him

MR. LEVY:

Wait.

10

questions.

11

want him to answer.

I'm trying to figure out which one you

12

MR. FOSTER:

13

MR. LEVY:

14

MR. FOSTER:

15

not from him?

16

him?

The last one.
What was the last one?
You learned it from the news and

Are you saying you learned it from

17

MR. LEVY:

18

MR. FOSTER:

19

Learned what from him?
That he discussed with the FBI

having the FBI pay Mr. Steele.

20

MR. SIMPSON:

21

MR. LEVY:

22
23
24
25

You asked two different

I don't remember.

The witness is yawning.

Let's

take a break.
MR. MUSE:

We will attribute that to fatigue

as opposed to the questions.
MR. FOSTER:

Let's go off the record.

It is

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3:55.

2

(A short break was had.)

3

MR. DAVIS:

4

It's now 4:05.

5

BY MR. DAVIS:

We'll go back on the record.
We'll continue with the questions.

6

Q. Mr. Simpson, did anyone from Fusion ever

7

communicate with the FBI regarding information in

8

the memoranda or other allegations regarding

9

Mr. Trump and his associates?

10

A. From Fusion, did anyone from Fusion

11

communicate with the FBI?

12

ever spoke with the FBI, to the best of my

13

knowledge.

14
15
16
17
18
19

Q. Did you ever exchange any e-mails with
them?
A. We did not communicate with them by e-mail
either.
Q. Do you know any current or former FBI
personnel?

20

MR. LEVY:

21

MR. DAVIS:

22
23

No, no one from Fusion

As a general matter?
Yeah, as a general matter.

BY THE WITNESS:
A. As a general matter I'm sure I do.

24

current and former law enforcement officials.

25

to a lot of crime conferences and things like

I know
I go

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2
3

that.
Q. Were any of them consulted as part of this
investigation?

4

A. Not to my recollection.

5

Q. Was the amount of Fusion's compensation in

6

the Trump investigation dependent on the FBI

7

initiating an investigation of Mr. Trump or his

8

associates?

9
10

A. No.
Q. Was the amount of Orbis's compensation

11

dependent on the FBI initiating an investigation of

12

Mr. Trump and his associates?

13

A. No.

14

Q. Other than Senator McCain, who we'll

15

discuss later, did Fusion or Orbis disclose any of

16

the memoranda information contained therein or

17

related information from Mr. Steele with any

18

elected officials or staff in Congress?

19

A. I don't recall having done so, no.

20

Q. If we could turn briefly back to Exhibits

21
22

4 and 5.

I just want to reference two things.

MR. LEVY:

I also want to clarify in the

23

premise of that question there were factual

24

assertions made that may or may not be true to

25

which the witness did not respond.

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MR. DAVIS:

Sure.

Understood.

To be clear,

2

we obviously were not referencing any disclosures

3

to this committee as part of the committee's

4

inquiry.

5

BY MR. DAVIS:

6

Q. So on Exhibit 4, page 3, paragraph 21A,

7

Mr. Steele's attorneys state that the post-election

8

dossier memoranda was provided to a senior United

9

Kingdom government national security official

10

acting in his official capacity.

11

page 2 -- I'm sorry -- page 5, the response to 13

12

similarly references disclosing that memoranda to

13

the UK national security official.

14

In Exhibit 5 on

Mr. Simpson, to the best of your knowledge,

15

were the memoranda or information contained therein

16

disclosed to foreign governments?

17

A. I have no knowledge of this beyond what

18

you're showing me.

I can tell you about, you know,

19

what I know about Chris's encounter with David

20

Kramer and how all that came about.

21

specifically said something to me about showing

22

this to one of his government officials I don't

23

remember it.

If Chris

So...

24

MR. LEVY:

25

BY THE WITNESS:

Why don't you walk them through.

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2

A. If you want to know the rest of the story,
I'm happy to walk you through it.

3

Q. Sure, we can do that.

4

A. So after the election obviously we were as

5

surprised as everyone else and Chris and I were

6

mutually concerned about whether the United States

7

had just elected someone who was compromised by a

8

hostile foreign power, more in my case whether the

9

election had been tainted by an intervention by the

10

Russian intelligence services, and we were, you

11

know, unsure what to do.

12

anything other than to discuss our concerns, but we

13

were gravely concerned.

14

Initially we didn't do

At some point a few weeks after the election

15

Chris called me and said that he had received an

16

inquiry from David Kramer, who was a long-time

17

advisor to Senator McCain, and that according to --

18

Kramer told Chris that he had run into Sir Andrew

19

Wood at a security conference in Halifax,

20

Nova Scotia and that Kramer was accompanying

21

Senator McCain to this conference and that the

22

three of them had had an unscheduled or unplanned

23

encounter where the issue of this research was

24

discussed and the essence of it, I guess, was

25

conveyed to Senator McCain and to David Kramer from

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Andrew Wood.

2

Wood's name was specifically given to me by

3

Christopher Steele at that time.

4

given to me.

5

Chris had mentioned him to me.

6

probably mentioned it.

7

I don't remember whether Andrew

It was later

It later became an accepted fact that
I believe he

But anyway, he did say someone that he worked

8

with in the past who was a former UK government

9

official with experience in Russia had had this

10

conversation with David Kramer and John McCain and

11

that Senator McCain had followed up on it as to

12

what more there was to know about these

13

allegations, this information.

14

So Chris asked me do you know David Kramer,

15

and I said yes, I've known David Kramer for a long

16

time.

17

people that I'm sort of loosely affiliated with.

18

We've all worked on Russia and are very concerned

19

about kleptocracy and human rights and the police

20

state that Russia has become, in particular the

21

efforts of the Russians to corrupt and mess with

22

our political system.

23

going back to when I was at the Wall Street Journal

24

and that's how I met David.

25

State Department as assistant secretary for human

David Kramer is part of a small group of

So we shared this concern

He was working at the

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rights, and I was reporting on human rights and

2

corruption in Russia.

3

So I told Chris he's legit.

David is someone

4

I've known for a long time and he knows a lot about

5

these issues and he's very concerned about Putin

6

and the Kremlin and the rise of the new Russia and

7

criminality and kleptocracy.

8

we trust him?

9

him.

So he said, well, can

And I said yes, I think we can trust

He says he wants information to give to

10

Senator McCain so that Senator McCain can ask

11

questions about it at the FBI, with the leadership

12

of the FBI.

13

wanted was for the government to do its job and we

14

were concerned about whether the information that

15

we provided previously had ever, you know, risen to

16

the leadership level of the FBI.

17

didn't know.

18

if he was aware -- if he was made aware of this

19

information would treat it seriously.

That was essentially -- all we sort of

We simply just

It was our belief that Director Comey

20

Again, at this time, you know, while we

21

believed that we had very credible reporting here,

22

you know, what we really -- we just wanted people

23

in official positions to ascertain whether it was

24

accurate or not.

You know, we just felt that was

25

our obligation.

So I said to Chris I think we can

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trust him, and he said okay.

2

met with him, and I told him what happened.

3

he's back in Washington and, you know, I'm going to

4

hand him to you.

5

Well, he was here, I
Now

I don't remember whether I called David or

6

David called me, I just don't remember, but we got

7

in touch and he, you know, asked me -- we met.

8
9
10
11

Q. And after you met how did he -- did you
provide the memoranda to -MR. LEVY:

Sorry.

Finish your question.

BY MR. DAVIS:

12

Q. -- did you provide the memoranda to him?

13

MR. LEVY:

The answer to that question might

14

implicate privilege and other obligations.

15

going to decline to answer the question.

16

BY MR. DAVIS:

17

So he's

Q. Did Mr. Steele represent to you that Orbis

18

or Mr. Wood had initiated this contact with

19

Mr. Kramer and Mr. McCain to share the dossier

20

information?

21

A. Well, that has two parts on that question.

22

I think I can answer the first part which I think

23

answers the second.

24

this as having been initiated by Orbis.

25

described this as a chance encounter at a security

Anyway, he did not describe
He

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conference where, you know, someone who had some

2

knowledge of these matters shared it with Senator

3

McCain and David Kramer and that caused David

4

Kramer to follow up with Chris and that it was

5

passive.

6

Mr. Kramer.

7

In other words, it was initiated by

Q. Did Mr. Steele describe anyone else being

8

involved at the Halifax international security

9

conference in this discussion?

10

A. Not that I can recall.

11

Q. According to the official attendee list

12

for that conference, Mr. Akhmetshin was also there.

13

To the best of your knowledge, was he involved in

14

any capacity in the effort to discuss the dossier

15

information with Mr. Kramer and Mr. McCain?

16
17
18
19

A. That's the first time I've received that
information.

So I don't have any knowledge.

Q. And you haven't spoken with Mr. Akhmetshin
about that, I assume?

20

A. No.

21

Q. In addition to the disclosures we have

22

already discussed, to whom did Fusion GPS provide

23

the memoranda, information contained therein, or

24

related information from Orbis?

25

MR. LEVY:

Beyond what you've discussed?

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MR. DAVIS:

2

MR. LEVY:

Anyone we've left out.
The answer to that might implicate

3

privilege or other obligations.

4

decline to answer the question.

5

BY MR. DAVIS:

6

So he's going to

Q. To the extent there's any portion of the

7

answer to that question that would not implicate

8

those privileges, I would ask that you reveal

9

those.

10
11

A. I'm not sure I see how I could answer that
question without getting into privileged areas.

12

MR. FOSTER:

13

MR. LEVY:

Again, what privilege?
We can discuss it at the end.

14

It's a voluntary interview.

15

answer that.

16

BY MR. DAVIS:

17

He's declining to

Q. Did any Fusion employees communicate with

18

any foreign governments or foreign intelligence

19

agencies about the memoranda or the information

20

contained therein?

21
22
23

A. I don't believe so, certainly not
knowingly.
Q. Did you and Mr. Steele ever discuss any

24

communications he had with foreign government

25

officials about the information in the memoranda?

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A. It would be difficult -- nothing specific

2

that I recall.

3

talk about information that foreign government

4

officials provided in the course of their research,

5

but beyond what's in the memos I don't really have

6

any recollection.

7
8
9

There are parts of the memos that

Q. Do you know who paid for Mr. Steele's trip
to Rome to meet with the FBI?
A. I have read recently that -- I think in a

10

letter from Senator Grassley that the FBI

11

reimbursed the expense, but to be clear, I mean,

12

that's it.

13

compensated for that work or any other work during

14

this time.

15
16

He was, to my knowledge, not been

MR. FOSTER:

I'm sorry.

You're saying that

Fusion did not pay for the trip?

17

MR. LEVY:

Go ahead and answer the question.

18

MR. SIMPSON:

I don't think we did.

I have

19

no information that we paid for it.

Again, this

20

sort of emphasizes, you know, the point I was

21

making earlier which was this was something that I

22

considered to be something that Chris took on on

23

his own based on his professional obligations and

24

not something that was part of my project.

25

makes sense to me that he was reimbursed by them,

So it

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not us.

2

BY MR. DAVIS:

3

Q. To clarify, you were saying his

4

interactions with the FBI were not part of your

5

project?

6

A. They obviously grew out of the project,

7

but as he explained it to me, you know, when you

8

learn things in your daily life that raise national

9

security considerations you're obligated to report

10

them.

11

client's goals or project.

12

So that wouldn't have anything to do with my

Q. But in your briefings with journalists you

13

did reference his interactions -- Mr. Steele's

14

interactions with the FBI, correct?

15

A. At some point that occurred, but I don't

16

believe it occurred until very late in the

17

process.

18

Q. Can you estimate when in the process?

19

A. It was probably the last few days before

20

the election or immediately thereafter.

21

Q. So the meetings in September that you

22

referenced, you didn't reveal Mr. Steele passing on

23

information to the FBI?

24
25

MR. LEVY:

Can you repeat the question.

Sorry.

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MR. DAVIS:

So in your meetings with

2

journalists in September you didn't reference

3

Mr. Steele's interactions with the FBI or passing

4

on of information to them?

5

BY THE WITNESS:

6

A. I don't recall.

7

MR. DAVIS:

8

MR. FOSTER:

9
MS. SAWYER:

We'll go back on the record.

It's 4:30.

12
13

Off the record at 4:21.
(A short break was had.)

10
11

I think my hour is up.

EXAMINATION
BY MS. SAWYER:

14

Q. I wanted to return to our conversation

15

about interactions that Mr. Steele had with the

16

FBI.

17

met in Rome.

18

meeting in early July, are you aware of any other

19

meetings or conversations that Mr. Steele had with

20

the FBI?

21

We had been talking about a second time he
Besides that meeting and the first

A. I think I was just recounting that he

22

vaguely said that he had broken off with them over

23

this concern that we didn't really know what was

24

going on.

25

didn't understand what was going on and he said he

I'm sorry to be vague, but we just

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had broken off with them.

2
3

Q. When you say "we" did not understand what
was going on, who are you referring to as the "we"?

4

A. Chris and I, mostly just the two of us.

5

There was a lot of public controversy over the

6

conduct of the FBI.

7

many people, but this conversation was between the

8

two of us.

9
10

I remember discussing it with

Q. And what was the time frame of when Steele
said he had broken off with the FBI?

11

A. I can -- I don't know exactly, but it

12

would have been between October 31st and election

13

day.

14

MS. QUINT:

October 31st was when you said

15

there was an article --

16

MR. SIMPSON:

In the New York Times.

There

17

was an article in the New York Times on

18

October 31st that created concern about what was

19

going on at the FBI.

20
21
22
23
24
25

MS. QUINT:

Because it wasn't consistent with

your understanding of the investigation?
MR. SIMPSON:

Exactly.

BY MS. SAWYER:
Q. And I think, just to be clear, this was an
article you had talked about that both revealed

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that Director Comey had alerted Congress to

2

something about the Clinton e-mail investigation?

3

A. No.

That happened a few days previous.

4

don't know the exact date that he sent the letter

5

to Congress, but this was an article specifically

6

about -- it was disclosing the existence of an FBI

7

investigation of Trump's ties to Russia, which, to

8

my recollection, was the first time that anyone

9

reported that the FBI was looking at whether the

10

Trump campaign had ties to the Kremlin but at the

11

same time saying that they had investigated this

12

and not found anything, which threw cold water on

13

the whole question through the election.

14

Q. And was that -- just to tie it together

15

when you were talking previously, was that in

16

connection with your conversation with journalists

17

where you directed them to ask the FBI as to

18

whether there was an investigation going on?

19

A. I'm not going to get into specific news

20

organizations or reporters or stories, but I would

21

restate that this was during the period when we

22

were encouraging the media to ask questions about

23

whether the FBI was, in fact, investigating these

24

matters.

25

I

I'll add that, you know, a lot of what we

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were talking to the media about were things in the

2

public record, specifically Carter Page, Paul

3

Manafort had resigned over allegations of illicit

4

relationships with Russian oligarchs and Ukrainian

5

oligarchs.

6

source public information pointing towards the

7

possibility that the Russians had infiltrated the

8

Trump campaign.

9

and encouraged them to look into this.

10

So there was, you know, a lot of open

So we spoke broadly to reporters

Q. And did you ever come to find out who the

11

journalists had spoken with at the FBI about the

12

existence of an investigation into Russian

13

interference and possible ties to the Trump

14

campaign?

15

A. No.

16

Q. So you had indicated that Mr. Steele said

17

he had -- I think your phrase was "broken off" with

18

the FBI.

19

What did you understand that to mean?

A. That Chris was confused and somewhat

20

disturbed and didn't think he understood the

21

landscape and I think both of us felt like things

22

were happening that we didn't understand and that

23

we must not know everything about, and therefore,

24

you know, in a situation like that the smart thing

25

to do is stand down.

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Q. And had he been reaching out affirmatively

2

to the FBI and providing them with information or

3

were they reaching out to him and he was simply

4

responding to their requests?

5
6

A. The first contact was initiated by Chris
to someone that he said he knew.

7
8

Q. And now you're just going back to the July
contact?

9

A. Yes.

The September briefing or debriefing

10

in Rome I believe I understood -- to this day I

11

understand that to have been initiated by the FBI.

12

Subsequent contacts during this period I just don't

13

know.

14

Q. Do you know if there were any contacts

15

after that second meeting in Rome between then and

16

the point in time which occurred sometime between

17

October 31st and the election day when he stopped

18

communicating with the FBI, do you know if there

19

actually were any conversations or meetings between

20

Mr. Steele and the FBI?

21

A. He didn't literally tell me about specific

22

contacts.

I just recall that there was -- that he

23

broke off, which implies that he told him he didn't

24

want to have anything more to do with them.

25

believe he also mentioned that they didn't like

I

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media coverage, that there was media coverage of,

2

you know, FBI interest in Donald Trump.

3

know what it was that they didn't like.

4

I don't

Q. And I think you've already answered this

5

question, but to the best of your knowledge, did

6

Mr. Steele ever obtain payment from the FBI for

7

actual research that he was doing on Russian

8

interference or on possible ties between the Trump

9

campaign and Russia?

10

A. He told me he did not, and I have no

11

independent information other than what he told me.

12

I don't believe he ever received compensation for

13

working on anything related to Trump and Russia.

14

Q. I'm going to direct your attention back to

15

what we marked as Exhibit 3, which is the series of

16

memos that you had received from Mr. Steele in the

17

course of his work.

18

and we also talked about the second memo to some

19

degree.

20

the second memo, which starts at page 41394, came

21

about, why he had generated that report or done

22

that research, and you had indicated that there was

23

much more public reporting on the hacking.

24

you had mentioned -- that's when you mentioned

25

Debbie Wasserman Schultz.

We talked about the first memo

You were explaining to me why you believed

I think

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So with regard to that memo, were there any

2

particular things that you independently verified?

3

A. I just need to review it here for a

4
5

second.
Q. Sure.

6
7
8
9

(Reviewing document.)
BY THE WITNESS:
A. Most of this I did not seek to
independently verify and was relatively new

10

information.

11

connections between Russian intelligence and cyber

12

criminals, and I was aware at the time that the

13

Russian mafia and Russian cyber crime was a

14

subcontractor to the Russian intelligence services.

15

So this comported with my general knowledge of

16

these matters, but a lot of the specifics was new

17

information to me.

18

I was aware at the time of

The only things in here that I specifically

19

recognize from other work or from other research

20

was that the -- the allegation that the telegram

21

encrypted messaging system, which is an app, had

22

been compromised by Russian intelligence and that

23

someone else in the business of cyber security had

24

told me that too who was in a position to know.

25

don't remember who that was, but I was told that by

I

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an American.

2

operations with names like Booktrap and Maddel

3

(phonetic) rings a bell to me or did ring a bell to

4

me at the time.

5

had been a great deal at this time even of U.S. law

6

enforcement activity against organized Russian

7

cyber crime operations.

8
9

And issues of Russian criminal

There's been a great deal -- there

Q. And this memo which is dated 26 July -- it
actually bears the date 2015.

10

A. I noticed that.

11

Q. Is that just, as far as you understand it,

12

a typo or mistake?

Was it actually 2016?

13

A. Yes.

14

Q. Then similarly with what I have -- and I'm

15

just doing it in the order that it was Bates-

16

stamped and appeared on BuzzFeed -- there's a

17

two-page report and it bears the Bates Nos. 41397

18

and 41398 and it has a company report number

19

2016/095.

20

Presidential Election, Further Indications of

21

Extensive Conspiracy Between Trump's Campaign Team

22

and the Kremlin."

23
24
25

This one has the title "Russia/U.S.

Did you do any independent verification of
these facts?
A. I did some work on aspects of this.

We

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were separately -- you know, my team and myself

2

were separately investigating various things in

3

here.

4

verification, but I was analyzing this.

5
6
7
8
9

So I can't talk about this as a

MR. FOSTER:

Speak up, please.

BY THE WITNESS:
A. I analyzed this information in the same
manner I analyzed the other stuff.
Q. So based on the work that you were doing,

10

did any of that independent work that you did alter

11

the content of this?

12

A. No.

13

Q. So it was in addition to whatever was

14

provided in this memo, this two-page memo?

15

A. Yes, that's right.

16

Q. And to the best that you can recall, can

17

you tell us what you were learning at the same time

18

about the topics covered in this memo?

19

A. Yes.

Could I just clarify something?

I

20

assume this is exactly how it was published and

21

someone mixed up the sequence of the memos.

22

next memo's numbered 94 and is dated July 19th and

23

this one is 95 and is not dated, I don't believe.

24

Maybe that's why they got mixed up.

25

So the

But in any event, what I would loosely call

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the Carter Page memo came before this conspiracy

2

memo.

3

investigating just based on open sources and, you

4

know, other methods, more public information Carter

5

Page's trip to Russia.

6

did background work on Carter Page, I did research

7

on his business dealings, and in the course of

8

trying to analyze -- you know, this is some new

9

detail here about how the operation is working in

So with that caveat I can say we were

We watched tapes of it, we

10

the Kremlin and how they are trying to use

11

influence and it comports with my knowledge and

12

Chris's knowledge of how the Kremlin does this,

13

which is they offer people business deals as a way

14

to compromise them.

15

knowledge, this is a much bigger issue than

16

personal indiscretions when it comes to the way the

17

Kremlin operates and is something I know a fair bit

18

about.

19

And, in fact, you know, to my

So we looked into Carter Page and we also

20

looked into Igor Sechin and whether Sergei Ivanov

21

was in a position to be managing the election

22

operation, which is what 94 talks about, and we

23

determined that he was.

24

verified he does have a deputy who's very obscure

25

named Igor Divyekin.

I, you know, independently

It's spelled two different

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ways here.

2

D-I-V-Y-E-K-I-N.

3
4
5
6
7

I believe the correct spelling is

MR. MUSE:

Can you give the Bates number of

the document you're looking at.
MR. SIMPSON:

This one is 41399.

BY MS. SAWYER:
Q. And just for the record, it's a two-page

8

document, 41399 to 41400, and it has the date, I

9

think you indicated before, 19 July 2016.

Is this

10

the memo that you said you referred to as the

11

Carter Page memo?

12

A. Yes.

13

Q. And you were explaining that in the

14

sequencing this one came before the document that

15

actually in terms of Bates numbers --

16

A. Right.

17

Q. -- comes before it which we had talked

18

about which had the company report No. 095.

So 94

19

came to you before 095 -- report No. 095; is that

20

correct?

21

A. That's my recollection.

22

Q. So with regard to the research you were

23

also doing, is it also just true that whatever

24

independent research you were doing did not then

25

get incorporated into document company report

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2016/94, the Carter Page memo?

2

A. That's correct.

We essentially segregated

3

this reporting from other things we were doing for

4

reasons we discussed earlier.

5

human intelligence, it's not the kind of thing that

6

you would share with almost anyone basically.

7

lot of the work that we do is public record

8

research.

9

information is useful for making decisions and

10

trying to understand what's going on, but it's

11

not -- doesn't have much use beyond that unless you

12

can independently verify it.

13

full of footnotes and appendices and court records

14

and that sort of thing.

15

A lot of this is

A

Generally speaking, most of this

So our reports are

Q. So is it fair to characterize the research

16

that you were doing as kind of a separate track of

17

research on the same topic sometimes?

18

A. I think so.

I wouldn't say it was

19

completely separate because, for instance, on some

20

subjects I knew more than Chris.

21

to Paul Manafort, he's a long-time U.S. political

22

figure about whom I know a lot.

23

reporting -- you know, so there may have been some

24

bleed between things I told him about someone like

25

Manafort, but most of these characters neither of

So when it comes

But his

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us know much about and it's really just he's

2

faithfully reporting information to him that's

3

being reported to him by his network.

4

In British intelligence the methodology's a

5

little different from American intelligence.

6

There's a practice of being faithful to what people

7

are saying.

8

straightforward recitations of things that people

9

have said.

So these are relatively

Obviously as we talked about before,

10

you know, disinformation is an issue that Chris

11

wrestles with, has wrestled with his entire life.

12

So if he believed any of this was disinformation,

13

he would have told us.

14

Q. And did he ever tell you that information

15

in any of these memos, that he had concerns that

16

any of it was disinformation?

17

A. No.

What he said was disinformation is an

18

issue in my profession, that is a central concern

19

and that we are trained to spot disinformation, and

20

if I believed this was disinformation or I had

21

concerns about that I would tell you that and I'm

22

not telling you that.

23

believe this is disinformation.

24
25

I'm telling you that I don't

Q. And then on the memo, the Carter Page
memo, which is company report 2016/94, you said

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that you had done -- you, Fusion -- you, Glenn

2

Simpson had done some research into Carter Page,

3

including Mr. Page's business dealings?

4

A. Yes.

5

Q. Is that information that you still have?

6

A. I don't know.

7
8
9

Q. You also specifically mentioned Igor
Sechin and maybe work that you had done research
into Sechin.

11

still have?

Is that work that you would also

A. I don't know if I have anything specific

13

on Sechin.

14

collect, you know, research on various people who

15

are oligarchs or mafia figures.

16

have any specific reports on Sechin, but I know a

17

lot about him.

18

No. 1 compadre in the kleptocracy.

19

I

don't know.

10

12

I haven't looked for it.

Sechin is a well-known character.

I

I don't think I

He's, you know, sort of Putin's

Q. And with regard to Carter Page, did you

20

reach any findings, conclusions about his business

21

dealings, about him, about his connections in

22

particular to, you know, Russia?

23

A. Yes.

24

Q. And can you share what those were?

25

A. Carter Page seemed to us to be a typical

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person who the Russians would attempt to co-opt or

2

compromise or manipulate.

3

side, a little bit -- considered to be a striver

4

who was ambitious and not terribly savvy, and those

5

are the kind of people that the Russians tend to

6

compromise.

7

was also, you know, from early on described as

8

somewhat eccentric.

He was on the younger

That was the general sense we had.

He

9

There was a -- I remember quite clearly there

10

was a bit of a -- when we were talking to reporters

11

about him because he was all over the news for this

12

trip to Russia and we had done -- there was a fair

13

amount of open source on his consulting firm, his

14

complaint that he'd lost money on Russian

15

investments and he owned stock in Gazprom and he

16

was really mad about the sanctions and he went over

17

there in this hastily-arranged trip to speak to

18

this school and that was all pretty unusual, but

19

there's a lot of skepticism in the press about

20

whether he could be linked between the Kremlin and

21

the Trump campaign because he seemed like a zero, a

22

lightweight.

23

I remember sort of not being able to kind of

24

explain to people that's exactly why he would end

25

up as someone who they would try to co-opt.

Of

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course, you know, when we talk about things in the

2

dossier that are confirmed, this is one of the

3

things that I think really stands out as notable,

4

which is that Chris identified Carter Page as

5

someone who had -- seemed to be in the middle of

6

the campaign, between the Trump campaign and the

7

Kremlin, and he later turned out to be an espionage

8

suspect who was, in fact, someone that the FBI had

9

been investigating for years.

10

Q. So beyond what is in the dossier, did you

11

kind of find any evidence that he had actually been

12

compromised?

13

Now I'm speaking of Carter Page.

A. Well, the definition of compromised is

14

someone who has been influenced sometimes without

15

even their knowledge.

16

that he had, in fact, been offered business deals

17

that were -- that would tend to influence him,

18

business arrangements.

19
20
21

We had reason to believe

Q. And do you have the records of those
business deals that you had collected?
A. Yeah.

I don't think so.

Most of that

22

was, in fact, reporting that we did with other

23

people who knew him from the business world.

24
25

Q. And then just the next memo that we had
touched on, 2016/95, it has Bates numbers 41397 to

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398, it does not bear a date on it.

Do you recall

2

roughly when you received this particular report?

3

A. Sometime in midsummer.

4

Q. The next report, which is 2016/097 which

5

is two pages, has the date of 30 July 2016.

6

by the numbers it would appear to maybe have come

7

between those two.

8

came sometime between July 19th and July 30th?

9
10

Just

Does it seem logical that it

A. That seems logical.
Q. And then just in general, with regard to

11

this particular memo did you do any research to

12

verify this information that was in this memo?

13
14
15
16
17

MR. LEVY:

Beyond what he said as a general

matter?
MR. MUSE:
and forth.

I'm sorry.

You were going back

Which one in particular?

MS. SAWYER:

This is memo No. -- it has

18

Company Intelligence Report 2016/095, it's Bates

19

numbers 41397 and 41398.

20
21
22
23
24
25

MR. MUSE:

Thank you.

BY MS. SAWYER:
Q. Was there particular information in this
memo that you did verify?
A. One of the things I did, which is pretty
typical of how I would sort of analyze things, was

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I looked at the Russian pension system to determine

2

if, in fact, the Russian government was

3

distributing lots of pension payments to Russian

4

immigrants in the United States, and I found some

5

reports from the Social Security Administration and

6

other places describing this system.

7

Basically because everyone in Russia, you

8

know, more or less works for the government,

9

there's a lot of -- there's a large number of

10

Russian emigres in the United States who receive

11

pension payments that are paid through the

12

embassies and various people, Russian lawyers and

13

others who we became interested in in the course of

14

this investigation seem to be involved in that

15

process.

16

I'm just saying, you know, we looked at this

17

system, and as someone who does a lot of money

18

laundering work this was an interesting thing that

19

I hadn't heard about.

20

I'm not saying they did anything illegal.

There's all this money flowing in the United

21

States from Russia, it probably flows in under some

22

sort of diplomatic status.

23

on Russia and the Russians can't move money in the

24

United States for most things, this would, in fact,

25

be an ideal mechanism for moving money into the

So if there's sanctions

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United States for whatever purpose, for some kind

2

of illicit purpose.

3

example of the kind of general work I would do to

4

determine whether there's some base level of

5

credibility to the things we're getting.

6

I think that's a pretty good

Q. And in answering that you said that some

7

of the officials that you had identified as

8

involved in this effort seemed to come up with

9

regard to the pension disbursements.

10
11

Who

specifically are you referring to?
A. We identified a lawyer in Sunny Isles

12

Beach, Florida who said she previously worked for

13

Gazprom and just had on her professional Website or

14

someplace that she was -- she had some kind of

15

relationship with the Russian embassy in dealing

16

with these pension issues.

17

Q. And do you recall that lawyer's name?

18

A. I don't.

19

Q. Anyone else besides that individual?

20

A. If I could look at this for a second.

21

Q. Sure.

22
23
24
25

(Reviewing document.)
BY THE WITNESS:
A. I don't have a clear recollection of this.
I'm sorry.

I thought there was another name in

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here that we had looked at, but I don't see it in

2

this memo.

3

Q. To the extent you have records about this

4

and the individual in Sunny Isles, would you at

5

least look for them and let us know whether you

6

would be willing to provide them to the committee?

7
8

MR. LEVY:

Counsel has the request.

BY MS. SAWYER:

9

Q. Just moving on to the next memo, which is

10

Company Intelligence Report 2016/097, it bears the

11

Bates Nos. 401 and 41402, it's a two-page memo

12

dated 30 July 2016.

13

that, was there anything that you independently

14

verified that comes out of this memo?

15
16

Again, when you take a look at

(Reviewing document.)
BY THE WITNESS:

17

A. I don't think so.

18

Q. Okay.

Then Company Intelligence Report

19

2016/100, was there any information there that you

20

either independently verified or had independent

21

research on any of the individuals mentioned in

22

there?

23

It mentions Sergei Ivanov, Dmitry Peskov.
MR. MUSE:

If I may, some clarification.

24

When you say is there anything that you

25

independently verified that comes out of the memo,

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are you talking -- it's a little confusing because

2

the memo comes in, he already knows some

3

information, but I think he's generally said that

4

he's not doing a draft of the memo beforehand and

5

yet your question seems to permit that possibility.

6

MS. SAWYER:

7

clarification.

8

BY MS. SAWYER:

9

No.

I appreciate the

Q. Just to be clear, I'm not trying to --

10

what we're trying to determine is is there

11

information that either you had in your possession

12

that corroborated and verified this or even went

13

beyond what was in this and amplified information

14

on any of these individuals relevant to Russia's

15

interference or possible ties with the Trump

16

campaign?

17

A. Yes.

I'm trying to be as helpful as I

18

can.

The thing that we worked on with regard to

19

Sergei Ivanov, who was the head of what's called

20

the head of administration which we confirmed from

21

open sources is kind of an internal Kremlin

22

intelligence operation, and that Ivanov according

23

to experts on Russia, the Russian military, Russian

24

intelligence, does, in fact, run this internal

25

Kremlin intelligence operation that sort of sits

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atop the FSB and the SVR, the GRU, which are the

2

other agencies specifically tasked with areas of

3

intelligence, military for the GRU, foreign for the

4

SVR, domestic for the FSB.

5

Before I got this memo I didn't know about

6

this internal Kremlin structure.

It was either

7

this one or the previous one.

8

saying who is this Ivanov guy, you know, we looked

9

at Ivanov and found journal articles and other

So in the course of

10

public information about his long history of

11

intelligence.

12

history with Vladimir Putin, and his role atop this

13

internal operation.

He's a veteran of the FSB, his long

14

In particular I remember reading a paper by a

15

superb academic expert whose name is Mark Galeotti,

16

G-A-L-E-O-T-T-I, who's done a lot of work on the

17

Kremlin's black operations and written quite widely

18

on the subject and is very learned.

19

have given me comfort that whoever Chris is talking

20

to they know what they're talking about.

21

So that would

Q. With regard to that just in general, I did

22

want to ask you not to identify based on the

23

particular sources, but did Mr. Steele ever share

24

with you who his sources were?

25

MR. LEVY:

That conversation, if it occurred,

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would implicate obligations and he's going to

2

decline to answer that question.

3

MS. SAWYER:

And is that based just on the --

4

can you just articulate the obligations so we can

5

understand them.

6

MR. LEVY:

It's a very sensitive security

7

issue and I just don't -- in a transcript where

8

there's no assurance of confidentiality it's not a

9

discussion we want to have here.

10
11
12

BY MS. SAWYER:
Q. And do you know whether he shared his
sources with the FBI?

13

A. I don't.

I don't know.

14

MR. FOSTER:

What was the answer?

15

MR. SIMPSON:

16
17
18

I don't know whether he

shared his sourcing with the FBI.
MS. SAWYER:

Can we just take a minute.

We

can go off the record for a minute.

19
20

Sorry.

(A short break was had.)
MS. SAWYER:

Just with sensitivity toward the

21

lateness of the day and in the interest of time it

22

would just be helpful -- and I'll give you as much

23

time as you need to take a few minutes and, if you

24

could, look through the remaining memos and let us

25

know if anything kind of stood out to you, if there

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were things that either did not ring true at the

2

time and that you were concerned about or things in

3

particular that in addition to what's in here you

4

had independent research about that you could share

5

with the committee in the context of our

6

investigation.

Is that a clear request?

7

MR. MUSE:

8

MS. SAWYER:

9

MR. MUSE:

Heather, may I make a suggestion?
Sure.
Why don't we break for a few

10

minutes so he can look at it, but here's a bigger

11

problem and I don't mean this as criticism

12

particularly with regard to the sensitivity as to

13

time.

14

there's sometimes the problem that is created when

15

you try to sort of do a wholesale commentary,

16

particularly after it's been sort of more

17

focused --

18

The difficulty is in summary questions

MS. SAWYER:

19

So yeah.

20

where --

21
22
23
24
25

I understand where you're going.

I don't want to put us in a position

MR. LEVY:

Let's just take some time for the

witness to review the document.
MS. SAWYER:

Why don't you take a little bit

of time.
MR. MUSE:

In that spirit maybe you could

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look in case you have a more focused inquiry too.

2

MS. SAWYER:

We can certainly do that.

3

don't we take a five-minute break and I'll ask

4

whatever remaining questions we have on the

5

dossier.

6

MR. FOSTER:

7

10
11

We'll go off the record at 5:11.
(A short break was had.)

8
9

Why

MS. SAWYER:

We're back on the record at

5:20.
BY MS. SAWYER:
Q. We appreciate you are walking through some

12

of these and we understand your general practice

13

and I want to make sure I'm characterizing this

14

accurately.

15

would -- from Mr. Steele you would review them, you

16

would see if they resonated with information that

17

you already knew and other research you may already

18

have done.

19

don't recall at the time anything jumping out at

20

you as patently inaccurate; is that fair to say?

When you would get the memos you

I think you already told me that you

21

A. Yes, that's fair to say.

22

Q. And I had just asked you to review and I

23

appreciate you taking the time to review the

24

additional memos which would just run from Bates

25

No. 41405 to 41425 to just try to determine for the

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committee if research that you had been doing on

2

the separate track on some of these topics in

3

particular amplified the work in the dossier.

4
5

MR. LEVY:

When you say "amplified the work

in the dossier," what do you mean?

6

MS. SAWYER:

Both kind of verified and maybe

7

gave you some additional information and insights

8

on either the factual allegations in them or

9

whether or not the key players identified had also

10

engaged in either similar or related behavior on

11

Russian -- you know, related to Russian

12

interference.

13

BY THE WITNESS:

14

A. I'd say that's generally right.

I read a

15

lot of books and studies on Russia and organized

16

crime.

17

residual knowledge of some of the people and

18

subjects that are covered in the memos.

19
20

So over the years I just have a lot of

Q. Okay.

So nothing certainly jumped out at

you and then as --

21

A. Nothing jumped out at me --

22

Q. -- as inconsistent with information that

23

you had gained from other sources?

24

A. That's correct.

25

Q. And did you have any reason to believe

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either then or now that Mr. Steele would have kind

2

of fabricated any of the information that he

3

included in any of these memos?

4

A. No.

5

Q. I do want to return to a few of the topics

6

and a few of the specifics, but I think I'll hold

7

that until the next round because I have a few

8

other just follow-up questions for you.

9

It had come up in the last round that there

10

was a meeting and some information was provided to

11

Mr. Kramer.

12

occurred were you, Fusion GPS, still working on

13

behalf of a client who had engaged you to do

14

research as part of the presidential election

15

campaign or did that occur after that engagement

16

ended?

17
18

Were you still -- at the time that

A. It occurred after the engagement had
ended.

19

Q. And besides Mr. Steele, did you discuss

20

sharing information with Mr. Kramer with anyone

21

else?

22

A. Not that I recall.

23

Q. My colleagues had also asked you about

24

meetings and particularly that occurred between

25

June 8th and June 10th of 2016 and some of the

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individuals involved in those meetings.

2

general matter, did you discuss the work you were

3

doing related to the presidential election campaign

4

with -- did you ever discuss that with Natalia

5

Veselnitskaya?

6

A. I don't believe I ever discussed it with

7

her.

8

English.

9

didn't discuss it with her.

10

As a

I'd just add that she doesn't speak much
So the possibilities are almost none.

I

Q. Do you have any reason to believe that she

11

knew that you were doing work -- opposition

12

research work on then Candidate Trump?

13

A. No.

14

Q. Do you have any reason to believe that she

15

knew that Christopher Steele was doing work for you

16

as part of that project, the opposition research on

17

Candidate Trump?

18

A. No.

19

Q. What about Rinat Akhmetshin, did you ever

20

talk with Rinat Akhmetshin about the fact that you

21

were doing opposition research on Candidate Trump?

22

A. Not that I recall, no.

23

Q. Do you have any reason to believe that

24

Christopher Steele ever spoke with Rinat Akhmetshin

25

about the fact that Christopher Steele had been

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engaged by you to do work -- related to the

2

opposition work on then Candidate Trump?

3
4

A. Do I have any reason to believe that he
spoke?

No, I have no reason to believe he did.

5

Q. Do you know if he did or not?

6

A. It's never -- we've never discussed it,

7
8
9

but I have no reason to think he would have.
Q. And if he had discussed it, would that
have been consistent with the nondisclosure

10

agreement that you indicated you would have had

11

with Mr. Steele?

12

A. That would -- if he discussed it with

13

someone like that without my knowledge, it would

14

not have been consistent with our agreement.

15

Q. And then given that, would it surprise you

16

if Mr. Steele had talked with Rinat Akhmetshin

17

about the work he was doing related to then

18

Candidate Trump?

19

A. Yes, that would surprise me.

20

Q. Did you discuss the fact that you were

21

doing opposition research on Candidate Trump with

22

anyone at Prevezon Holdings?

23

A. Not that I recall, no.

24

Q. And if you had done so, would that have

25

been consistent with your confidentiality

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obligations to that client?

2

A. No, it wouldn't have been consistent.

3

Q. Did you speak with anyone at Baker

4

Hostetler about the work that you had been engaged

5

to do on then Candidate Trump?

6

A. Not that I recall.

7

Q. So the point in time at which you were in

8

meetings that included -- the meetings that you had

9

related to the Court hearing at Prevezon that

10

you've already discussed, the dinner, the Court

11

hearing, and then a subsequent dinner, they occur

12

right around the same time that Natalia

13

Veselnitskaya and Rinat Akhmetshin and the

14

individual you described as a translator, Anatoli

15

Samochornov, met -- or it has been reported met

16

with individuals in the Trump campaign.

17

topic just never come up during those three days?

18
19
20

A. It never came up.
to say.

Did that

I don't know what else

It never came up.

Q. So you at the time had no idea that they

21

were meeting with or met -- and actually, in fact,

22

met with members of the Trump campaign?

23
24
25

A. I didn't have any idea about that meeting
until quite recently.
Q. So in an August 1, 2017 news briefing

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White House Press Secretary Sarah Huckabee Sanders

2

said "The Democrat linked firm Fusion GPS actually

3

took money from the Russian government while it

4

created the phoney dossier that's been the basis

5

for all of the Russia scandal fake news."

6

your response to that statement?

What is

7

A. It's not true?

8

Q. And what in particular is not true about

9
10

it?
A. Well, it's a false allegation leveled by

11

William Browder before this committee and in other

12

places for the purpose of his advantage.

13

repeating an allegation that was aired before this

14

committee and in other places that we were working

15

for the Russian government and it's not true.

She's

16

Most importantly the allegation that we were

17

working for the Russian government then or ever is

18

simply not true.

19

political rhetoric to call the dossier phoney.

20

memos are field reports of real interviews that

21

Chris's network conducted and there's nothing

22

phoney about it.

23

and what's not, but it's not a fabrication.

24
25

I don't know what to say.

It's
The

We can argue about what's prudent

Q. And I think you've already answered you
contend that you were not taking money from the

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Russian government and that was in relation to the

2

litigation work you had done with Baker Hostetler,

3

correct?

4

A. Yes.

They are a well-regarded law firm

5

that has obligations to determine the sources of

6

funds when they take a client and, to my knowledge,

7

they did so and the money was not coming from the

8

Russian government.

9

Q. So that was for the Prevezon work for

10

Baker Hostetler.

Did you take money in any way,

11

shape, or form that could be attributed to the

12

Russian government for the work that you were

13

doing -- the opposition research work that you were

14

doing on then Candidate Trump?

15

A. No.

16

Q. Did, to the best of your knowledge,

17

Mr. Steele take money in any way, shape, or form

18

that could be attributed to the Russian government

19

for the work that he did on the memos as part of

20

the opposition research on Candidate Trump?

21

A. No.

22

I'll add one more thing to the response to

23

Sarah Huckabee Sanders, which is her assertion that

24

we are a Democrat linked opposition research firm.

25

I think I addressed this earlier, but to be clear,

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we don't have a business of -- we're not an

2

appendage to the Democratic party.

3

commercial business, we're all ex-journalists.

4

take clients from both sides of the aisle.

We have

5

a long history of that, I'm proud of that.

I'm

6

happy to say I have lots of Republican clients and

7

friends.

8
9

We run a
We

Q. To the extent there have been allegations
or indications that the work that Mr. Steele did,

10

his research into Russian interference in the 2016

11

election, or your work could have been influenced

12

by Rinat Akhmetshin, do you believe that is true

13

and if -- do you believe it's true?

14

A. No.

15

Q. Do you believe that the work that

16

Mr. Steele did on Russian interference and possible

17

ties to the Trump campaign or your work could have

18

been influenced by Natalia Veselnitskaya?

19

A. No.

20

MS. SAWYER:

21

round.

22

take a break.

23

So I appreciate your patience and we'll

MR. FOSTER:

24
25

I think my time is up for this

It's 5:34.
(A short break was had.)

MR. DAVIS:

We'll go back on the record.

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It's 5:43 p.m.

2
3

EXAMINATION
BY MR. DAVIS:

4

Q. Mr. Simpson, could you walk us through

5

your itinerary to the best you remember it from

6

June 8th through 10th of 2016, especially any

7

interactions you had with Prevezon team members

8

during those three days?

9

MR. LEVY:

10
11

MR. DAVIS:

Beyond what he's discussed today?
Yes.

BY THE WITNESS:

12

A. I took the train to New York.

I don't

13

recall, but I may have had other business.

14

remember.

15

to my hotel, went to bed.

16

I don't remember the sequence, but I remember

17

meeting with Weber Shandwick, the PR firm, about

18

preparations for -- I think we expected there was

19

going to be a trial.

20

about.

21

of the hearing.

22

the hearing and I think -- if I remember the

23

sequence correctly, I went to the hearing, then I

24

had the meeting with those guys, the Weber

25

Shandwick guys, and then I hightailed it home.

I think there was a dinner.

I don't

I went back

Got up the next morning.

I think that's what it was

It might have been about the press coverage
I just don't remember.

I went to

My

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son's junior prom was that night or senior prom and

2

I was under some pressure to go home and be a dad.

3

Q. And then on the 10th, that first day back

4
5
6

in D.C.?
A. I don't think that was my first day back.
I was back the evening of the 9th.

7

Q. Sorry.

8

A. I think it was a weekend.

9

The first full day.

what I was doing.

So I don't know

Probably just relaxing.

I went

10

to the dinner, it was at a restaurant called

11

Barcelona up on Wisconsin Avenue, it was a social

12

occasion.

13

their wives.

14

nongermane topics.

15

occasion.

I brought my wife, other people brought
We talked about books and other other

16

(Exhibit 6 was marked for

17
18
19

It was just a social

identification.)
BY MR. DAVIS:
Q. I'm going to show you an exhibit.

I think

20

we're on 6.

We understand these are meeting notes.

21

Do these phrases about -- including Mr. Browder

22

mean anything to you or relate to any of the

23

research that you conducted or otherwise aware of

24

regarding Mr. Browder?

25

MR. LEVY:

When say "meetings notes," meeting

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2

notes about what meeting?
MR. DAVIS:

These are the meeting notes from

3

the June 9th meeting at Trump Tower.

4

Mr. Manafort's notes or they're contemporaneous.

5

BY THE WITNESS:

6

These are

A. I could tell -- obviously you know who

7

Bill Browder is.

Cyprus Offshore, Bill Browder's

8

structure, you know, investment -- Hermitage

9

Capital, his hedge fund, set up numerous companies

10

in Cyprus to engage in inward investment into

11

Russia, which is a common structure, both partially

12

for tax reasons but also to have entities outside

13

of Russia, you know, managing specific investments.

14

I can only tell you I assume that's what that

15

references.

16
17

I don't know what the 133 million --

MR. FOSTER:

Can I interrupt?

that from research that you did and provided to --

18

MR. SIMPSON:

19

MR. LEVY:

20

MR. FOSTER:

21

And you know

Yes.

Let him finish.
-- research that you did and

provided to Baker Hostetler and their client?

22

MR. SIMPSON:

Yes.

There was a -- I can

23

elaborate a little bit.

24

into how Hermitage Capital worked we looked at

25

various things, their banking relationships, the

As part of the research

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way they structured their investments in Russia.

2

don't remember how many, but there was a large

3

number of shell companies in Cyprus that were used

4

to hold the investments of individual clients of

5

Hermitage.

6

that was the likely identities of some of

7

Hermitage's clients.

8

BY MR. DAVIS:

9

So one of the things we discovered from

Q. Do any of the other entries in here mean

10

anything to you in light of the research you've

11

conducted or what you otherwise know about

12

Mr. Browder?

13

I

A. I'm going to -- I can only speculate about

14

some of these things.

15

MR. LEVY:

16

BY THE WITNESS:

I mean, sometimes --

Don't speculate.

17

A. Just would be guesses.

18

Q. Okay.

19

A. I can skip down a couple.

So "Value in

20

Cyprus as inter," I don't know what that means.

21

"Illici," I don't know what that means.

22

sponsors of RNC," I don't know what that means.

23

"Browder hired Joanna Glover" is a mistaken

24

reference to Juliana Glover, who was Dick Cheney's

25

press secretary during the Iraq war and associated

"Active

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with another foreign policy controversy.

2

adoptions by American families" I assume is a

3

reference to the adoption issue.

4

"Russian

Q. And by "adoption issue" do you mean Russia

5

prohibiting U.S. families from adopting Russian

6

babies as a measure in response to the Magnitsky

7

act?

8

A. I assume so.

9

Q. The information here, is this generally

10

consistent with the type of information you or

11

Baker Hostetler were providing about Mr. Browder

12

and his activities?

13

MR. LEVY:

14

MR. DAVIS:

Can you repeat that question.
Is the information here, to the

15

best you can decipher it, consistent with the

16

information that you and Baker Hostetler and HRAGI

17

were relaying to other parties about Mr. Browder's

18

activities?

19

MR. LEVY:

He's just told you that a lot of

20

what's here he doesn't know what it means, he

21

doesn't have knowledge or recollection as to these

22

terms.

23
24
25

MR. DAVIS:

The parts you do recognize.

BY THE WITNESS:
A. Couple of the items touch on things that I

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worked on, Cyprus, Bill Browder.

2

Q. I'm going to jump back to the Russia

3

investigation.

You'd mentioned before you've had

4

some subcontractors that you've worked with long

5

enough that you call them super subs; is that

6

correct?

7

A. Yes.

8

Q. Orbis or Mr. Steele, is that one such

9

super sub in your opinion?

10
11

A. It's a loose term.

We don't have a list

of super subs.

12

MR. FOSTER:

Is he one of them?

13

MR. SIMPSON:

There is no list.

So I can't

14

tell you if he's one of them.

15

subcontractor who's worked with us in the past and

16

we've been very satisfied with the quality of his

17

work.

18

MR. LEVY:

He's a reliable

Just to reiterate, I think as you

19

described these super subs earlier loosely, even

20

with some of these super subs Mr. Simpson said that

21

he would talk about clients only on a need-to-know

22

basis even with the super subs, so-called.

23

BY MR. DAVIS:

24
25

Q. Beyond the memoranda prepared by
Mr. Steele, did Fusion create any other work

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product relating to this investigation?

2

MR. LEVY:

3

MR. DAVIS:

4

Which investigation?

and his associates.

5

MR. LEVY:

6

MR. DAVIS:

7
8
9
10

The investigation into Mr. Trump

In addition to what?
Sorry.

The investigation into

Mr. Trump and his associates.
MR. LEVY:

I'm sorry.

Just repeat the whole

question.
MR. DAVIS:

Sure.

In addition to the

11

memoranda compiled by Mr. Steele, did Fusion itself

12

create any other work product as part of this

13

investigation?

14

MR. LEVY:

15

no confusion.

16

memoranda.

17
18
19
20
21
22

I just want to make sure there's
It wasn't Fusion that created the

MR. DAVIS:

Right, but it was a subcontractor

giving it back to Fusion.
MR. LEVY:

That's correct.

BY MR. DAVIS:
Q. With that understanding, did Fusion create
any work product of its own?

23

A. Yes.

24

Q. And can you describe what type of work

25

product that was?

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A. I believe I described it before.

We do a

2

lot of public records research, things that are in

3

the news, things that are in court documents.

4

summarize those things and try to document, you

5

know, and attach them to the underlying source

6

material.

7
8

Q. So you create sort of summary memoranda of
those documents?

9

A. Yes.

10

Q. Okay.

11

MR. LEVY:

12

MR. DAVIS:

13

We

And to whom is that distributed?
As a general matter?
Well, within the course of this

investigation.

14

MR. LEVY:

Inasmuch as that answer calls for

15

client communications the answer might be

16

privileged, might touch on obligations Mr. Simpson

17

has.

18
19
20

So he's not going to answer that question.
MR. FOSTER:

Did you provide work product to

your client?
MR. LEVY:

Again, the answer to that question

21

might implicate privilege or his obligations.

22

BY MR. DAVIS:

23

Q. Is the version of the Steele memoranda

24

that was published by BuzzFeed identical to the

25

version that Orbis provided Fusion?

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A. To my knowledge, yes.

2

Q. The version published by BuzzFeed contains

3

several redactions, not merely the ones by

4

Mr. Gubarev, G-U-B-A-R-E-V, that were later added.

5

Were those redactions in the versions Mr. Steele

6

provided to you?

7

MR. LEVY:

8

version in Exhibit 3?

9

MR. DAVIS:

10

MR. LEVY:

So wait.

You're asking about the

Right.
And you're asking if the

11

redactions that appear here were delivered to

12

Fusion?

13
14

MR. DAVIS:

Right.

BY THE WITNESS:

15

A. No.

16

Q. Do you know who added those redactions?

17

A. No.

18

Q. Did any version of the memoranda list

19

source and subsource names rather than referring to

20

sources anonymously?

21

A. I'm not sure I understand the question.

22

Q. In the version that we have as an exhibit

23

obviously it doesn't give identifying information

24

for sources, it says source A, subsources, things

25

like that.

Was there ever a version that listed

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the actual source names rather than substituting

2

them?

3

A. These are the versions that we received.

4

Q. They're what?

5

A. These are the memos that we received.

6

Q. Those are the memos you received.

7

MR. FOSTER:

8
9

Okay.

But he's asking if you received

any other memos that listed the sources?
MR. LEVY:

He did not -- what I think he said

10

is that he did not receive any versions of these

11

memos that listed the sources.

12

MR. FOSTER:

Okay.

Did you receive any other

13

documentation from Mr. Steele that listed the

14

sources?

15

MR. SIMPSON:

16

information.

17

BY MR. DAVIS:

18

I don't want to get into source

Q. Again, I don't want to repeat questions

19

that have been asked, but I don't want to

20

unintentionally omit anything.

21

provided to the FBI include all source names?

22
23
24
25

Did the version

A. I don't know that there was a version
provided to the FBI.
Q. When Mr. Steele first met with the FBI in
the summer of 2016 do you know if he provided the

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2

first memoranda that he created?
MR. LEVY:

3

question.

4

BY THE WITNESS:

He's already answered that

5

A. No, I don't know.

6

Q. Do you know if he provided any other

7

memoranda to the FBI on a rolling basis at all at

8

any point?

9

MR. LEVY:

10

BY THE WITNESS:

He's answered that question too.

11

A. I don't know.

12

Q. So I'd like to go back to Exhibit 4, I

13

believe.

14

attorneys are describing the December memoranda and

15

they state "The Defendants" -- again, that's

16

Mr. Steele and Orbis -- "continued to receive

17

unsolicited intelligence on the matters covered by

18

the pre-election memoranda after the U.S.

19

presidential election and the conclusion of the

20

assignment for Fusion."

21

On page 3, paragraph 18 Mr. Steele's

They reiterate this point on Exhibit 5 on

22

page 4.

23

intelligence was actively sought by the

24

Defendant" --

25

Request 11 asks "Please state whether such

A. Where are you at?

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Q. Page 4, request 11.

It states "Please

2

state whether such intelligence was actively sought

3

by the second Defendant or merely received as

4

presently pleaded."

5

intelligence was not actively sought, it was merely

6

received."

7
8
9
10

The response they say is "Such

Did anyone -- are you aware of who sent this
unsolicited intelligence to Mr. Steele?
A. No.
Q. Could you describe his methods of

11

compiling the dossier a little more?

12

before you described field interviews.

13

be talking about unsolicited information coming to

14

him rather than information he sought out?

15

A. I can try.

I think
He seems to

When you're doing field

16

information gathering you have a network of people,

17

sources.

18

turn on and off, these are people you work with.

19

So they call you and tell you stuff.

20

don't close the window and stop answering phone

21

calls, you know, when the engagement ends.

22

assume this is stuff that came in straggle,

23

whatever you call it.

It's not like a light switch that you

You know, you

So I

24

Q. To the best of your knowledge, did

25

Mr. Steele pay any of his sources or subsources in

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2

the memoranda for information?
A. I don't know.

I think there's been a

3

little bit of confusion I would like to clear up.

4

Some people were saying that he was paying people

5

for information.

6

not, but that's not basically how I understand

7

field operations to work.

8

gather information for you rather than sort of

9

paying someone for a document or to sit for an

I don't know whether he does or

You commission people to

10

interview or something like that.

11

understand it works.

12

That's not how I

Q. To make sure I understand, are you saying

13

you don't pay for particular information, you would

14

have an established financial arrangement with

15

someone?

16

A. If he did at all, but I did not ask and he

17

did not share that information.

18

me for any such.

19
20
21

He did not invoice

Q. Did Mr. Steele ever discuss his opinion of
Mr. Trump with you?
A. We didn't discuss our political views of

22

Mr. Trump, I don't think, at least not that I

23

specifically remember, if that's what you mean.

24

Q. That is.

25

If I recall correctly, you said earlier that

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once Fusion had exhausted public documentary

2

sources you turned to Mr. Steele and some other

3

subcontractors for human intelligence; is that

4

correct?

5

A. Yeah, field intelligence.

6

Q. Would your engagement with your client

7

have ended had you not turned to human

8

intelligence?

9
10

A. I have no idea.

I mean, I can't

speculate.

11

Q. Well, to clarify, when say you had

12

exhausted the public documentation, are you saying

13

you reached the end of your work or was there still

14

more?

15

A. No.

It's a broad project, there's lots of

16

things going on.

17

bankruptcies and all sorts of other stuff on all

18

kinds of issues.

19

lines of inquiry.

20

We're pulling legal filings and

I was talking about specific

Q. To the best of your knowledge, do Rinat

21

Akhmetshin and Christopher Steele know each

22

other?

23

A. I don't know.

24

Q. To the best of your knowledge, has

25

Mr. Akhmetshin ever worked with Orbis?

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A. Not to my knowledge.

2

MR. FOSTER:

3

If Mr. Akhmetshin were one of

the sources in the dossier, would you know that?

4

MR. SIMPSON:

I believe he would have told me

5

that by now given the public controversy over this

6

matter, but he hasn't.

7

BY MR. DAVIS:

8

Q. I'm sorry.

9

A. Chris Steele.

10

Is the "he" --

Q. How often would you say you interacted

11

with Mr. Akhmetshin during the 2016 elections

12

season?

13

A. Infrequently, intermittently.

14

Q. When was the last time you spoke with him?

15

A. I don't remember, but I don't think it

16

was -- I just don't remember.

17

Q. To the best of your knowledge, was Ed

18

Lieberman aware of your Trump research project?

19

A. Not to the best of my knowledge.

20

MR. FOSTER:

Could you just tell us generally

21

who else other than your client was aware of the

22

Trump research project as it was going on.

23

excluding your client and excluding your

24

subcontractors, who else knew that you were doing

25

it?

So

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MR. SIMPSON:

2

MR. FOSTER:

3

MR. SIMPSON:

4

MR. FOSTER:

5
6

Journalists.
In the summer of 2016?
Yes.
And they knew that because you

were telling them about it?
MR. SIMPSON:

We get calls from journalists

7

who are working on stories about all kinds of

8

subjects and some things we can answer questions on

9

and others we don't.

I'm a former journalist, as I

10

think you know, and we do lots of different kinds

11

of research and people who are working on a story

12

will call us and say what do you know about, you

13

know, Carter Page and we'll say, well, here's the

14

things that we know.

15
16
17
18
19

MR. FOSTER:

And they're aware you're being

paid to do that research for a client?
MR. SIMPSON:

I don't know.

Generally that's

not an issue.
MR. FOSTER:

So my question was who knew that

20

you were doing the research, the Trump-Russia

21

research at the time?

22

MR. LEVY:

He answered the question.

He told

23

you he spoke with journalists and told them what he

24

had found.

25

MR. FOSTER:

Right.

I was trying to clarify.

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My question was whether or not they knew you were

2

being paid to do that research.

3
4

MR. LEVY:

He answered that question too and

he said he did not explain that to the journalists.

5

MR. SIMPSON:

It's hard to generalize.

I run

6

a business, it's a research business.

Reporters

7

know we have clients who pay us to do research.

8

So, you know, I don't remember any specific queries

9

about whether we were being paid or not, but I

10

think most journalists would assume that someone

11

had paid us to do research.

12

MR. FOSTER:

They knew you were doing a Trump

13

oppo research project as opposed to a Hillary

14

Clinton oppo research project?

15
16

MR. LEVY:
election?

17
18

From 2015 through the end of the

MR. FOSTER:

Can you let the witness answer,

please.

19

MR. SIMPSON:

The word "they" is extremely

20

broad.

Journalists would call and ask questions

21

about specific things and from that they might

22

conclude that we were doing a Trump oppo project.

23

It's just worth pointing out that in a

24

political season all kinds of people are doing

25

research on all kinds of things.

Some people are

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interested in trade, other people are interested in

2

guns.

3

what we were doing.

4

you know -- they're interested in the story they're

5

working on.

6

interested in whether Donald Trump gets his ties

7

from third-world countries and they wouldn't ask

8

about anything else.

9

BY MR. DAVIS:

10

So you wouldn't necessarily intuit exactly
Most people are interested in,

So some people will say, hey, I'm

Q. You mentioned before, if I recall

11

correctly, that Fusion was having issues with

12

persons attempting to hack it?

13

A. That's a current concern, yes.

14

Q. When did that concern -- when did you

15

first become aware of that concern?

16

A. Relatively recently.

17

Q. So after the election?

18

A. Yes.

19

MR. FOSTER:

20
21
22

Did you tell journalists that

you had engaged Mr. Steele in the summer of 2016?
MR. SIMPSON:

I don't specifically remember

doing that until the fall.

23

MR. FOSTER:

After the election or before?

24

MR. SIMPSON:

25

MR. FOSTER:

Before the election.
Can you remember the context in

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which you told them that?

2

MR. SIMPSON:

3

MR. FOSTER:

4

Yes.
Can you describe it for us,

please.

5

MR. SIMPSON:

Sure.

Essentially there was --

6

at some point the controversy over the Trump

7

campaign's possible relationship with the Kremlin

8

became, you know, one of the main -- major issues

9

in the campaign and there were things that Chris

10

knew and understood to be the case that only he

11

could really explain in a credible way, and I

12

thought that -- we thought that he should be the

13

one that explains them, you know.

14

with a small group of reporters who were involved

15

in investigative journalism of national security

16

issues and we thought were in a position to make

17

use of him as a resource.

18

MR. FOSTER:

So we sat down

Do you recall whether that was

19

before or after he ended his relationship with the

20

FBI?

21
22
23

MR. SIMPSON:

Before.

BY MR. DAVIS:
Q. Do you recall what the first published

24

article -- when the first published article came

25

out that referenced material from the memoranda?

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A. Not specifically.

2

MR. FOSTER:

Earlier you talked about

3

evaluating the credibility of the information in

4

the memoranda that you were being provided by

5

Mr. Steele and, by way of summary, you talked about

6

your belief that he was credible and that you had

7

worked with him before and the information he had

8

provided you had been reliable in the past.

9

you take any steps to try to assess the credibility

10

of his sources, his unnamed sources in the material

11

that he was providing to you?

12
13

MR. SIMPSON:

Did

Yes, but I'm not going to get

into sourcing information.

14

MR. FOSTER:

So without getting into naming

15

the sources or anything like that, what steps did

16

you take to try to verify their credibility?

17
18

MR. SIMPSON:

I'm going to decline to answer

that.

19

MR. FOSTER:

20

MR. LEVY:

Why?
It's a voluntary interview, and in

21

addition to that he wants to be very careful to

22

protect his sources.

23

killed as a result of the publication of this

24

dossier and no harm should come to anybody related

25

to this honest work.

Somebody's already been

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MR. FOSTER:

I'm not asking him to identify

2

the sources.

I'm just asking what steps he took to

3

try to verify or validate the information.

4

MR. LEVY:

5

MR. FOSTER:

He's given you -If he can answer generally

6

without identifying the sources, I'd ask him to

7

answer.

8
9
10

MR. LEVY:

information and he's going to decline to answer
this one question.

11

MR. FOSTER:

12

MR. LEVY:

13
14

He's given you over nine hours of

And several others.
Not many.

BY MR. DAVIS:
Q. I think you mentioned that you were in

15

London when you first heard that someone was

16

interested in hiring Fusion to work on the Trump

17

research; is that correct?

18

MR. LEVY:

19

MR. DAVIS:

Repeat the question.
If I recall correctly,

20

Mr. Simpson said that he was in London when he

21

first heard that somebody was interested in hiring

22

Fusion to do Trump research?

23

BY THE WITNESS:

24

A. That's my recollection.

25

Q. Were either of the clients on this project

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not American citizens?

2

A. Were either of the clients on this --

3

MR. LEVY:

4

BY MR. DAVIS:

5
6

Q. Were any clients on the Trump research not
American citizens?

7
8
9

Clients on which project?

A. I don't mind answering that if that's
okay.

They're domestic clients.
MR. FOSTER:

You said earlier that the

10

information that you gather in your work is owned

11

by the client, it's not owned by you, and so

12

therefore you also referenced your nondisclosure

13

agreements and that you felt like if you had

14

information that related to national security or

15

law enforcement that the nondisclosure agreement

16

did not prevent you from disclosing that

17

information to third parties.

18

summary?

19
20

MR. LEVY:

Wait.

Is that a fair

You said a lot there.

Which third parties are you talking about?

21

MR. FOSTER:

22

MR. LEVY:

Well, to law enforcement.
I think he's answered this

23

already.

You're asking him whether it was

24

permittable under his contractual obligations to

25

report a crime to the national security community,

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2

and he said yes, it's fine for him to do that.
MR. FOSTER:

Right.

I'm trying to summarize

3

the previous answer as a premise to my next

4

question.

5

said before?

6

Is that an accurate summary of what you

MR. LEVY:

Summarizing testimony is dangerous

7

after he's given nine hours of it.

8

ask him a question, ask him a question.

9

MR. FOSTER:

If you want to

Is there a specific provision in

10

your NDA that provides an exception for disclosure

11

to law enforcement or intelligence agencies?

12

MR. LEVY:

I think he earlier didn't talk

13

about the contract, but if you want to talk about

14

it as a matter of practice what your understanding

15

is, go ahead.

16

MR. SIMPSON:

17

MR. FOSTER:

I don't know.
My colleague Ms. Sawyer asked

18

you earlier about public reports that the initial

19

client on the Trump work was a Republican and that

20

it's also been publicly reported that later there

21

was another client who was a supporter of Hillary

22

Clinton.

23

public reports?

24

MR. LEVY:

25

Are you the source for any of those

A hundred percent of what you were

saying was referring to news articles, right.

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MR. SIMPSON:

I've been asked about this by

2

various journals as to what I've heard, whether

3

they can report things that they've heard

4

elsewhere, and I have not -- I don't know if you'd

5

classify that as being a source, but I've been

6

asked those questions and I've avoiding getting

7

into specifics.

8

accurate information of a general nature like that,

9

I generally would not -- I would confirm things.

10
11

But I have -- if people have

MR. FOSTER:

Sorry.

I didn't understand your

answer.

12

MR. MUSE:

It's quite clear.

13

MR. SIMPSON:

Depends on what you say a

14

source is.

15

client No. 1 was a Republican, then I'd say I don't

16

have any problem with you writing that.

17

quite the same thing.

18
19

If someone calls me and say I hear

MR. FOSTER:

That's not

So you confirm the accuracy of

information?

20

MR. LEVY:

He didn't say that.

21

MR. SIMPSON:

22

I've chosen not to deny.

23

speaking, I deal with a lot of journalists.

24

not going to mislead people.

25

BY MR. DAVIS:

There are certain things that
You know, generally
I'm

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Q. To the extent you can clarify, is it that

2

there were two sets of clients, one of whom was

3

Republican and one of which was a Clinton

4

supporter, or was it one person's whose views

5

changed?

6

MR. LEVY:

We're not going to get into the

7

identity of clients.

8

an interview about questions 5 through 13 of the

9

March 24 request.

As you know, we've agreed to

Questions 1 through 4 talk about

10

the identities of the clients.

11

Ranking Member agreed with counsel for Mr. Simpson

12

about the scope of this interview and that question

13

is outside of it.

14

question would implicate privilege and obligations.

15

He's talked to you for nine hours, he's given you a

16

lot of information, and he's not going to answer

17

questions about identities of clients.

18
19
20

MR. DAVIS:

The Chair and the

In addition, the answer to that

You've asserted attorney-client

work product privilege -MR. LEVY:

There is no such privilege.

I've

21

asserted the attorney work product privilege, we've

22

asserted privileges under the First Amendment,

23

we've asserted the attorney-client privilege, and

24

we've asserted privileges of confidentiality.

25

a voluntary interview and he's declining to answer

It's

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2
3

the question.
MR. DAVIS:

I understand that.

BY MR. DAVIS:

4

Q. So with the Prevezon matter, then, is it

5

correct the law firm involved was Baker Hostetler

6

and the ultimate client was Prevezon, is that

7

right, while you were working there?

8

A. Yes.

9

Q. So any attorney-client privileges within

10

the context of that information would be -- the

11

holder of that privilege is Prevezon; is that

12

correct?

13
14
15
16

MR. LEVY:

he's not qualified to draw.
MR. DAVIS:

You don't feel that you can speak

to it without their permission?

17

MR. LEVY:

18

MR. DAVIS:

19

That's a legal conclusion that

Speak to what?
To questions that would be

covered by attorney-client privilege.

20

MR. LEVY:

21

answer that question.

22

BY MR. DAVIS:

23
24
25

I'm not sure he's qualified to

Q. Did you work with any law firms in
relation to the Trump investigation?
MR. LEVY:

Again, we're not getting into the

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identity of any clients --

2

MR. DAVIS:

3

MR. LEVY:

4

MR. FOSTER:

I didn't say client.
I understand.

Or their lawyers.

I think the issue we're trying

5

to deal with is in order to assess your claims of

6

privilege the committee needs to understand at

7

least as much about the context of the dossier work

8

as it does about the Prevezon work in terms of who

9

was involved.

So if there's a law firm involved or

10

if he was reporting to a law firm or acting under

11

the direction of a law firm, then we need to be

12

able to assess whether or not that was in

13

anticipation of litigation, whether he was doing it

14

by the direction of a law firm in order to assess

15

your assertions of privilege.

16

MR. LEVY:

I understand.

We've identified

17

our position.

We've been talking -- Mr. Simpson

18

has been answering your questions since 9:30 this

19

morning, it's now 6:15.

20

cooperative and he's here because the Chair and the

21

Ranking Member agreed to a limited scope.

22

questions you're asking are outside of that scope

23

and this is part of why appearing at a hearing was

24

going to be impossible.

25

we're here.

He's been fully

The

Through this agreement

He's given you a ton of information.

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If you want to discuss the privilege with counsel

2

after the interview, you may do so.

3

a ton of questions today and he's going to decline

4

to answer this last one.

5

MR. FOSTER:

6

The last one was did you work

with a law firm on the Trump matter?

7

MR. LEVY:

8

MR. FOSTER:

9

He's answered

He's declining to answer.
There were several points in the

interview where you made a point of saying your

10

firm is not a Democratic linked firm in reference

11

to the Sarah Huckabee Sanders quote.

12

publicly reported that you did opposition research

13

for a client targeting Mr. Romney in the 2012

14

election.

15

Trump opposition research.

16

opposition research regarding Mr. Obama?

17

It's been

Obviously we've been talking about the

MR. LEVY:

Have you ever done

We're not going to get into

18

specific client matters that are outside the scope

19

of this interview.

20

clients on the right and left, but he's not going

21

to get into other matters beyond Prevezon and what

22

he did in the 2016 election.

23

MR. SIMPSON:

He's told you he's represented

I did investigate Senator

24

Obama's campaign in 2008 when I was working for the

25

Wall Street Journal and wrote an article that

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caused his campaign chair to resign.

2

replete -- or the public report of my work is

3

replete with examples of investigations I've done

4

of Democrats that resulted in them losing their

5

elections and being prosecuted.

6

MR. LEVY:

7

MR. SIMPSON:

8

At the Wall Street Journal?
Yes.

BY MR. DAVIS:

9
10

The record is

Q. Are you party to a joint defense agreement
related to your Prevezon work?

11

MR. LEVY:

He's not going to talk about

12

privileged discussions or agreements, and he's

13

probably not qualified to answer anyway.

14

BY MR. DAVIS:

15

Q. Is Fusion GPS paying Cunningham Levy for

16

the firm's representation of you or as a third

17

party?

18

MR. LEVY:

That's privileged also.

He's not

19

getting into payments to his lawyers and it's

20

beyond the scope of this interview which has now

21

gone on for almost nine hours.

22

BY MR. DAVIS:

23

Q. Has Fusion GPS ever offered directly or

24

indirectly to pay journalists to publish

25

information?

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A. No.

2

Q. Are you aware of any Fusion clients

3

offering directly or indirectly to pay journalists

4

to publish information from Fusion?

5
6

MR. LEVY:

Fusion matter or as a general matter?

7

MR. FOSTER:

8

MR. LEVY:

9

MR. FOSTER:

11

MR. LEVY:

13

Can you let the witness answer.
Well, if the question's clear he

can answer any question --

10

12

While working for Fusion on a

I think the question was clear.
-- within the scope of the

interview -MR. DAVIS:

Are there any of Fusion's

14

clients offering --

15

THE REPORTER:

16
17

Guys.

BY MR. DAVIS:
Q. I'll repeat the question.

Are you aware

18

of any of Fusion's clients offering directly or

19

indirectly to pay journalists to publish

20

information from Fusion?

21

A. Not to my knowledge or recollection, no.

22

MR. FOSTER:

23

Trump engagement?

24
25

MR. LEVY:

What was the end date of the

He told you he didn't recall

exactly.

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MR. SIMPSON:

That's not correct.

2

election was the end date.

3

about the general election?

4

would have been the end.

5

MR. FOSTER:

The

I assume you're asking
The election date

So you didn't do any work on the

6

Trump matter after the election date, that was the

7

end of your work?

8
9
10
11

MR. SIMPSON:
election.
MR. FOSTER:

14

17
18
19
20
21

Let's go off the

(A short break was had.)
MS. SAWYER:

We'll go back on the record.

It's 6:30.

15
16

It's 6:21.

record for a minute.

12
13

I had no client after the

EXAMINATION
BY MS. SAWYER:
Q. We appreciate your time today, your
patience in answering our questions.
You've been asked a number of questions just
about -- well, strike that.
Were any of the particular factual findings

22

or conclusions that you reached with regard to the

23

research that was being done related to Russian

24

interference in the 2016 election including

25

possible ties to the Trump campaign, were any of

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the factual findings or conclusions influenced in

2

any way by the identity of the client for whom you

3

were doing that work?

4

A. All the questions you've asked I guess

5

this one I've not given a lot of thought to.

6

Offhand, not that I can think of.

7

Q. So you weren't trying to reach a

8

particular conclusion based on the identity had

9

they asked you to find -- well, strike that.

10

I think what I'm trying to get some sense of

11

comfort around is to the extent there might be

12

concerns that the work being done was driven in a

13

direction designed to reach a particular conclusion

14

for a client or because of the client's identity

15

was that the case?

16

A. I think it's safe to say that, you know,

17

at some point probably early in 2016 I had reached

18

a conclusion about Donald Trump as a businessman

19

and his character and I was opposed to Donald

20

Trump.

21

have entered into my thinking.

You know, again, I

22

was a journalist my whole life.

So we were, you

23

know, trained not to take sides and practiced in

24

not taking sides.

25

I'm not going to pretend that that wouldn't

So most of what I do as a research person is

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we try to avoid getting into situations where one's

2

etiology or political views would cloud your work

3

because it's a known hazard, but, you know, I

4

reached an opinion about Donald Trump and his

5

suitability to be president of the United States

6

and I was concerned about whether he was the best

7

person for the job.

8
9

Q. And given that you had been trained not to
allow etiology to cloud your work, it sounds like

10

you reached a conclusion and had concerns about

11

Candidate Trump.

12

ensure that your conclusion didn't cloud the work

13

that was being done?

What steps did you take to then

14

A. Well, to be clear, my concerns were in the

15

category of character and competence rather than --

16

I didn't have any specific concerns for much of the

17

time about his views, which I don't share, but that

18

wasn't really the issue.

19

do with do people have integrity and whether

20

they've been involved in illicit activity.

21

those were the things I focused on.

22

Most of what we do has to

So

Q. So the conclusion that you reached, was it

23

informed by the research that you were -- your

24

personal conclusion, was it informed by the

25

research that you were conducting?

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A. Yes.

We deal in factual information and

2

over the course of this project we gathered lots of

3

facts about Donald Trump.

4

Q. You mentioned that earlier and I think you

5

made clear a number of times in the course of the

6

day that the specific work on Russian interference

7

and possible ties to the campaign that Mr. Steele

8

was doing was one part of that bigger picture, and

9

I did want to ask you about some of that bigger

10

picture of the work and get a sense from you, if I

11

could, you know, some of the background and

12

findings.

13

mentioned -- well, you just mentioned right now as

14

we were speaking the term "illicit activity."

15

What, if any, research did you conduct that gave

16

you any concerns about then Candidate Trump and

17

potential illicit activity?

18

In particular one of the things you had

A. I think the thing I cited to you was his

19

relationship with organized crime figures, and that

20

was a concern.

21
22
23

Q. And what can you share with us about the
findings, your findings?
A. Well, I've tried to share as much as I

24

could think of over the course of today.

As I say,

25

there were various allegations of fraudulent

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business practices or dishonest business practices

2

or connections with organized crime figures.

3

fact, you know, there was numerous others that I

4

can't remember the names of.

5

of associations with people accused of involvement

6

in criminal activity.

7

In

It was a long history

You know, just to reiterate, the facts of

8

these investigations are the facts and we don't try

9

to drive an investigation to any particular

10

conclusion, certainly not based on our political

11

views.

12

believable for me to tell you I didn't reach, you

13

know, views about Donald Trump's integrity, but,

14

you know, those were -- those didn't influence the

15

research in terms of the findings.

16

findings.

17

So I think it would be, you know, not

Those were the

Q. You mentioned specifically and I think

18

with regard to organized crime particularly ties to

19

Felix Sater is one.

20

Yudkovich Mogilebich, I think it is.

You indicated a connection to

21

A. Mogilebich.

22

Q. Mogilebich, which we can spell for you.

23

Tell me if I have this correct.

24

M-O-G-I-L-E-B-I-C-H.

25

A. Yes.

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THE REPORTER:

2

MR. SIMPSON:

3

What's the first name?
Semyon, S-E-M-Y-O-N.

BY MS. SAWYER:

4

Q. Yudkovich, did I get that --

5

A. I believe I was probably talking fast and

6

I think I might have made a reference to

7

Yanukovych, which is the former president of the

8

Ukraine.

9
10
11
12
13

Q. With regard to any of that work, did you
create work product based on that work?
A. I don't specifically recall what we would
have created.
Q. And with regard to that work, did you

14

share any of that information with law enforcement

15

agencies?

16

A. No.

I mean, just to reiterate, the only

17

contact that, you know, occurred during this

18

engagement was -- at least to my knowledge, was

19

Chris's dealing with the FBI.

20

don't remember having any dealings with the FBI.

21

Other than that, I

Q. You had also mentioned earlier in the day

22

work -- that there was an investigation about money

23

from Kazakhstan?

24

A. Yes.

25

Q. And could you tell me about that and what

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2

you investigated and what you learned.
A. There was some parallel litigation in

3

New York involving attempts by the government of

4

Kazakhstan to recover money that had been allegedly

5

stolen from Kazakhstan, billions of dollars in a

6

colossal bank failure.

7

BTA Bank.

8

courts that the government's allegations are

9

basically true, which is that large amounts of

The name of the bank was

It's been well established in various

10

money were illicitly removed from this bank,

11

laundered across Europe and into the United States

12

apparently.

13

Allegedly.

So there was a civil case, at least one civil

14

case in New York involving -- filed by the city of

15

Almaty, A-L-M-A-T-Y, against some alleged Kazakh

16

money launderers.

17

but we learned that -- it wasn't from Chris.

18

learned that Felix Sater had some connections with

19

these people, and it's been more recently in the

20

media that he's helping the government of

21

Kazakhstan to recover this money.

22

media reports that the money went into the Trump

23

Soho or it went into the company that built the

24

Trump Soho.

25

I don't remember exactly how,
We

There's been

I can't remember the name.

Q. So the connection in that instance was to

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Felix Sater and through Felix Sater to --

2

potentially to Donald Trump?

3
4
5

A. Yes.

It was a company that Felix Sater

and Donald Trump were involved in together.
Q. And the research you did on that project,

6

was that public source research?

7

other -- did you have human intelligence sources on

8

that project?

9
10
11
12
13

Did you have any

A. I think I probably did have some human
sources.

That's my answer.

Q. And did you use subcontractors at all on
that work?
A. I can't say specifically whether it was --

14

I remember commissioning some public record-type

15

research on Felix Sater and his history in

16

New York.

17

Q. Did you feel in the course of that that

18

you had uncovered evidence of any criminal activity

19

by Donald Trump?

20

A. In the course of that I don't think so.

21

think my concern was the associations with known

22

organized crime figures.

23

Q. And that included Felix Sater?

24

A. Yes.

25

Q. Anyone else in particular?

I

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A. There were others.

2

MR. LEVY:

3

MS. SAWYER:

4

discussed.

5

BY THE WITNESS:

6

Beyond what we've discussed today?
Yes, beyond what we've already

A. Another figure involved in the Trump Soho

7

project was a central Asian person named Arif,

8

A-R-I-F, is the last name.

9

generally spelled Tevfik, it's T-E-V-F-I-K.

The first name is
If you

10

search under a different transiteration of that

11

name you can find open source reporting alleging

12

that he's an organized crime figure from Central

13

Asia and he had an arrest for involvement in child

14

prostitution.

15

Q. You mentioned as well that you had

16

reviewed tax bills.

17

Trump's tax bills?

18

Were these specifically Donald

A. They were Trump properties and I believe

19

we may have reviewed some public information about

20

estate taxes and things like that.

21

access to his tax returns.

22

We didn't have

Q. Did you reach any conclusions based on

23

your review of his tax bills?

I think you

24

mentioned that in connection with trying to assess

25

either financial connections or his financial

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standing.

2

regard to either of those?

3

Did you reach any conclusions with

A. Yes.

I concluded -- we concluded that his

4

statements about what individual properties were

5

worth were greatly exaggerated and at odds with the

6

information that he'd supplied, you know, in legal

7

filings with tax authorities and other records,

8

corporate records.

9

Q. Did any of that indicate anything that

10

showed a connection to Russia or the Russian

11

government or Russian officials or Russian

12

oligarchs?

13

A. Not that I can recall.

14

Q. You mentioned as well, you brought up

15

Trump golf courses.

16

looking into with regard to Donald Trump's golf

17

courses?

18

What in particular were you

A. The original inquiry was into the value of

19

the courses, whether he had to borrow money to buy

20

them, whether they were encumbered with debt, how

21

much money they brought in, what valuations he put

22

on them, and property tax filings.

23
24
25

Q. And in general can you share what findings
and conclusions you reached?
MR. LEVY:

With regard to?

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MS. SAWYER:

2

properties.

3

BY THE WITNESS:

4

To the work on the golf

A. A number of them don't make any money.

5

His valuations of the properties are questionable.

6

I guess those would be the main findings.

7

Q. You just mentioned broadly but didn't

8

describe it, you mentioned research on Scotland.

9

don't know if it was particular properties or

10

something with regard to Scotland.

11

describe what that research was.

12

A. Sure.

Can you just

He has golf courses in Scotland and

13

Ireland and one of the facets of UK or anglo

14

company law is that private companies have to file

15

financial statements, public financial statements.

16

So when you're looking at a guy like Donald Trump

17

who doesn't like to share information about his

18

company, it's useful to find a jurisdiction where

19

he's required to share that information with the

20

local government.

21

I

So we went and ordered the records -- the

22

financial statements of the golf courses.

There's

23

also a long-running land use controversy -- I think

24

there's multiple long-running land use

25

controversies over those properties.

We haven't

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really touched on this at all, but there were also

2

environmental issues that were part of the

3

research.

4

Q. With regard to the public financial

5

statements, did you reach any conclusions based on

6

that?

7

A. That they were not profitable entities.

I

8

don't specifically recall.

I just remember that

9

these were not doing very well and that he'd sunk a

10

lot of money into them and he hadn't gotten a lot

11

of money back yet.

12

MS. QUINT:

You mentioned a couple of times,

13

Mr. Simpson, that you had particular familiarity

14

with Mr. Manafort and even that you were more

15

familiar with him in particular than Chris Steele

16

was.

17

general about it, but what was your focus when you

18

had looked into Manafort?

19

familiar with?

20

In general and it might not be easy to be

MR. SIMPSON:

What main areas were you

Over the years, originally at

21

the Wall Street Journal we learned of his

22

relationship with Ukrainian and Russian oligarchs.

23

So it was generally continued in that vein.

24

subject of some litigation over his business

25

dealings in New York.

He was

There was a lawsuit filed by

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the opposition politician from Ukraine accusing him

2

of involvement in corruption in Ukraine.

3

just a -- not for any particular client, but just

4

because these matters are something I follow I had

5

collected those documents.

6

probably some other litigation that I collected

7

that was in a similar vein.

8
9
10

MS. QUINT:

So as

I think there's

And it was all documentary or did

you have human sources for your Manafort research?
MR. SIMPSON:

I don't think -- for the most

11

part it was just what you call gathering string,

12

just accumulating files on people or subjects that

13

are of interest.

14

BY MS. SAWYER:

15

Q. The committee, certain members of the

16

committee, the Chairman and Ranking Member along

17

with Senators Graham and Whitehouse had sent a

18

request for documents and information on July 19.

19

I understand your efforts to identify that

20

information are ongoing and I know that in response

21

to one of my questions about Mr. Page your attorney

22

has already said that the request for information

23

is pending and being reviewed.

24

ask you a couple of questions about some of the

25

other individuals that we had identified in that

I just wanted to

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letter and in particular in request No. 6?

2

MR. LEVY:

3

just get my copy out?

4

Do you have an exhibit or should I

MS. SAWYER:

I'm happy to enter it as an

5

exhibit or I can just read the names.

6

think there's any reason we need to --

7
8

MR. LEVY:

I don't

Just read the names to move it

along, that's fine.

9

MS. SAWYER:

I don't think there's any

10

reason -- there's nothing in this letter to inform

11

your answer otherwise.

12

BY MS. SAWYER:

13

Q. So with regard to Alpha Group, sometimes

14

I've heard Alpha Group, sometimes I've heard Alpha

15

Bank.

16

entities.

17

Alpha Group with regard to Russian interference in

18

the 2016 election?

19

I don't know if they're two distinct
Do you know anything about Alpha Bank or

A. Alpha Group is not a corporate person,

20

it's not an entity.

21

Alpha Bank is a bank.

22

know, you know, journalists were working on some

23

issues related to this and they asked us about it,

24

but the information didn't come from us.

25

It's just a collective name.
I know a limited amount.

I

Q. So you were asked by journalists about it,

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but you're saying whatever information you had was

2

not generated by Fusion GPS?

3

A. That's right.

I know they're a big player

4

and they have long, deep ties to Vladimir Putin.

5

One of the founders, Pyotr Aven, P-Y-O-T-R, second

6

word Aven, A-V-E-N, was an associate of Vladimir

7

Putin when he was in the mayor's office in Saint

8

Petersburg around the time same that Bill Browder

9

was doing business with the mayor's office.

10

They're very powerful politically and economically

11

in Russia and they have -- in the tens of billions

12

are the assets of the founders and they have all

13

sorts of interests.

14

western corporations, including BP.

15

my business tend to just have a lot of

16

institutional knowledge about them and, you know, I

17

shared my institutional knowledge about them.

18

Q. You mentioned other founders.

19

They have epic disputes with
So people in

Are those

other founders Mikhail Fridman and German Khan?

20

A. Yes.

21

Q. Do you have any information there have

22

been reports about potential communications between

23

a server at Alpha Bank and potentially servers that

24

belong to the Trump organization or Trump -- some

25

entity associated with Donald Trump?

Do you have

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any information about those particular reports?

2

A. That's kind of an open-ended question.

I

3

think what I said is we were asked about that and

4

it wasn't -- that information wasn't generated by

5

us and I'm happy to say it's beyond our competence

6

to have generated, but in the course of being asked

7

about it, you know, people gave us information.

8

don't know what else to say.

9

Q. And what information were you given?

10

A. A bunch of data.

I mean, we were shown

11

like do you know what this would mean, does this

12

mean, and it's beyond -- it's really -- it's

13

certainly beyond my competence.

14
15

Q. So the data that you were shown, you could
not draw any conclusions from it?

16
17
18

A. I did not draw any conclusions from the
data.
Q. Another individual that there's been a lot

19

of press reporting on is Sergei Millian.

20

than what -- what, if anything, can you tell us

21

about did you conduct any research into

22

Mr. Millian?

23

reach with regard to Russian interference in the

24

2016 election?

25

I

Other

And, if so, what conclusions did you

A. We learned from sources that he had

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connections to the Trump organization and we did an

2

open source investigation of him.

3

picture of him with Donald Trump and another real

4

estate investor in Florida.

5

that's not his real name or at least not the name

6

he came to the United States with and that before

7

he became a real estate broker he was a linguist

8

and translator.

9

advanced training in linguistics are oftentimes

We found a

We've discovered

Speaking generally, people with

10

involved in intelligence matters, but I don't know

11

whether he is or isn't.

12

interested in him because he was boasting about his

13

connections to the Trump organization in the Trump

14

campaign.

15

was he, was he a spy, you know, that sort of thing.

16
17

Various reporters became

So we got lots of inquiries about who

Q. And did you make a determination whether
or not he had actual ties to the Trump campaign?

18

A. Well, some of the -- yes.

I mean, he

19

was -- I think he's Facebook friends with Michael

20

Cohen.

21

connection.

22

Facebook friends.

23

took it from that that they did know each other.

24

guess we gradually learned of Michael Cohen's role

25

in the Trump campaign as opposed to in the Trump

I'm sorry.

It was some social media

It was either Twitter friends or
It was public information.

We
I

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organization.

2
3

Q. And what did you learn about Mr. Cohen's
role in the Trump campaign?

4

A. We learned that his job included dealing

5

with inquiries about Russia and he seemed to get

6

all of the serious inquiries, investigative

7

inquiries about Russia.

8

about that.

9

intimidating person who had a history of

He seemed to know a lot

We learned that he was a very

10

threatening reporters with libel suits.

11

that he's married to -- his father-in-law is a

12

Ukrainian emigre, that he had some Ukrainian

13

clients and connections to the taxi industry in

14

New York which is heavily populated with Russian

15

emigres, and we learned that he was involved in

16

some of Trump's projects where there was a lot of

17

Russian buyers.

18

of is that he was also the person who dealt with

19

allegations against Mr. Trump from the tabloids.

20

We learned

The only other thing I can think

Q. And with regard to Trump projects with

21

Russian buyers, what specific projects had a number

22

of Russian buyers?

23
24
25

A. I don't specifically remember.
maybe.

I think it was Florida.
MS. SAWYER:

Florida

Sorry.

Just give us a minute.

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2
3
4
5

I think that's really all of our questions.
I don't know if there's follow-up that you all had.
MR. FOSTER:

Just very quickly.

I can do it

from right here.
So I asked you -- or you were asked earlier

6

about representations that you're not -- you don't

7

see your firm as being Democrat linked and in my

8

previous question I asserted that there had been

9

public reports that you had done work, opposition

10

research during the 2012 election aimed at

11

Mr. Romney, but I didn't ask you to confirm that.

12

Is that correct?

13

MR. LEVY:

Work for clients outside the scope

14

of the interview is not within the scope of the

15

interview.

16
17
18

MR. FOSTER:

It's relevant to his claim that

he's not a Democrat linked firm.
MR. LEVY:

He's answered that question.

He's

19

given you multiple answers to that question and

20

significant information in support of his answer to

21

that question, and that small fact which may or may

22

not be pertinent is that he's going to decline to

23

answer because it's outside the scope of this

24

interview.

25

MR. SIMPSON:

I decline to answer.

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MR. FOSTER:

In some of the questioning in

2

the last round there was some talk of your -- you

3

didn't have a particular aim in your research, you

4

were following the facts wherever they lead.

5

fair to say -- is it a fair description to say that

6

your job was opposition research aimed at

7

Mr. Trump?

8

characterized that way.

9

characterization of what your job was?

10

Is it

That's been widely reported and

MR. LEVY:

Do you think that's a fair

He's been talking for nine and a

11

half hours, a lot of which was describing his work.

12

To simplify it in any particular way at this point

13

I think is unfair to the witness.

14
15
16

MR. FOSTER:

You weren't hired to find

positive information about Mr. Trump, were you?
MR. SIMPSON:

To the contrary.

I think when

17

you're doing research on any subject you're trying

18

to figure out what the truth is.

19

Trump's got a good business record and he's really

20

worth billions of dollars, that's important

21

information.

22

reporters stories about how Donald Trump is not

23

worth billions of dollars if he's worth billions of

24

dollars.

25

negativity, I get, you know, where you're coming

So if Donald

In fact, you shouldn't be feeding

So, you know, I think the connotation of

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from, but, in fact, you're just trying to figure

2

out what's true.

3

It's like with the Prevezon case, we were

4

trying to figure out who's telling the truth, is it

5

our guys or is it Browder.

6

get rehired when I give them the right information,

7

when I give them accurate information.

8

Donald Trump turned out to be a great businessman,

9

that's what I would have to tell people.

10

MR. FOSTER:

11

MR. LEVY:

12
13

I do my job well and I

So if

Nothing further from me.
Before we go off the record, will

we be entitled to a copy of the transcript?
MR. FOSTER:

You'll be able to review the

14

transcript and request corrections, make an

15

errata.

16

MR. LEVY:

Will it be kept confidential?

17

We'd like to make a request that it be kept

18

confidential given the sensitivity of the matters

19

discussed today.

20

MR. FOSTER:

21

MR. LEVY:

22

MR. FOSTER:

23

MR. LEVY:

24
25

Your request is noted.
Noted, but no decision on it?
No decision.
And upon reviewing the transcript,

when will we have that opportunity?
MR. FOSTER:

We can arrange that off the

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record.

2

MR. LEVY:

When we do we just reserve the

3

right obviously to correct the record or supplement

4

it.

5
6

MR. FOSTER:
review it.

7

MR. LEVY:

8

MR. DAVIS:

9

That's why we'd allow you to

Thank you very much.
Nothing further.

We're going off

the record at 7:04.

10
11

(Whereupon the interview was
concluded at 7:04 p.m.)

12
13
14
15
16
17
18
19
20
21
22
23
24
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CERTIFICATE OF SHORTHAND REPORTER - NOTARY PUBLIC

2

I, TINA M. ALFARO, Certified Shorthand

3

Reporter No. 084-004220, Certified Realtime

4

Reporter, and Notary Public in and for the State of

5

Illinois, do hereby certify:

6

That GLENN SIMPSON, whose interview is

7

hereinbefore set forth, was duly sworn by me and

8

that said deposition is a true record of the

9

testimony given by such witness.

10

I further certify that I am not counsel

11

for nor in any way related to any of the parties to

12

this suit, nor am I in any way interested in the

13

outcome thereof.

14
15

In witness, whereof, I have hereunto set
my hand this ____ day of __________,2017.

16
17
18
19

_____________________________

20

Tina M. Alfaro, CSR, CRR

21
22
23
24
25

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