As an initial matter, the Government expects that the evidence at trial will show that beginning in late July/early August 2016, the defendant, Tech Executive-1, and agents of the Clinton Campaign were “acting in concert toward a common goal,”, namely, the goal of assembling and disseminating the Russian Bank-1 allegations and other derogatory information about Trump and his associates to the media and the U.S. government.

In particular, the evidence will show that in late July and early August, Tech Executive-1 commenced a project in coordination with the defendant and Law Firm-1 to support an “inference” and “narrative” tying Trump to Russia. For example, calendar entries will show that on August 12, August 17, and August 19, 2016, Tech Executive-1 had meetings and/or conference calls with the defendant and the Clinton Campaign’s General Counsel (i.e., Campaign Lawyer-1).6 During or around that same time period, Tech Executive-1 began tasking his own employees and associates to mine and assemble internet data that would support an “inference” or “narrative” tying Trump to Russia. Tech Executive-1 expressly stated in emails that a purpose of this effort was to please these “VIPs,” apparently referring to the defendant, Campaign Lawyer-1, and the Clinton Campaign.

Memo to ABC 4 Corners.