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SENATE JUDICIARY COMMITTEE
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U.S. SENATE
3
WASHINGTON, D.C.
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5
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INTERVIEW OF: GLENN SIMPSON
8
9
10
11
TUESDAY, AUGUST 22, 2017
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WASHINGTON, D.C.
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The interview in this matter was held at the
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Hart Senate Office Building, commencing at 9:34 a.m.
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APPEARANCES:
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SENATE JUDICIARY COMMITTEE:
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Patrick Davis, Deputy Chief Investigative Counsel,
4
Chairman Grassley
5
Jason Foster, Chief Investigative Counsel,
6
Chairman Grassley
7
Samantha Brennan, Investigative Counsel,
8
Chairman Grassley
9
Daniel Parker, Investigative Assistant,
10
Chairman Grassley
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Joshua Flynn-Brown, Investigative Counsel,
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Chairman Grassley
13
Scott Graber, Legislative Assistant/Counsel,
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Senator Graham
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Heather Sawyer, Chief Oversight Counsel,
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Senator Feinstein
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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,
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Senator Whitehouse
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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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I N D E X
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EXAMINATION
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PAGE
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By Mr. Davis 11
5
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
14
Exhibit 1 11
8/3/17 letter agreement
15
Exhibit 2 30
16
Privilege log
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Exhibit 3 138
BuzzFeed memos
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Exhibit 4 196
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Filing in UK litigation
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Exhibit 5 205
(Not described)
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Exhibit 6 261
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Meeting notes
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Glenn Simpson
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MR. DAVIS: Good morning. This is the
2
transcribed interview of Glenn Simpson. Chairman
3
Grassley and Ranking Member Feinstein requested
4
this interview as part of the Senate Judiciary
5
Committee's investigation of Fusion GPS's
6
activities related to the dossier compiled by
7
Christopher Steele, the Prevezon case, and the
8
Magnitsky Act.
9
Would the witness please state your name for
10
the record.
11
MR. SIMPSON: Glenn Simpson.
12
MR. DAVIS: On behalf of the Chairman I want
13
to thank Mr. Simpson for appearing here today. My
14
name is Patrick Davis. I'm the Deputy Chief
15
Investigative Counsel with the committee's majority
16
staff.
17
I'll ask everyone else from the committee who
18
is here to introduce themselves as well.
19
MR. FOSTER: Jason Foster, I'm the Chief
20
Investigative Counsel for Chairman Grassley.
21
MS. BRENNAN: Samantha Brennan, Investigative
22
Counsel, Chairman Grassley.
23
MR. GRABER: Scott Graber, Senator Graham.
24
MR. PARKER: Daniel Parker, Investigative
25
Assistant for Senator Grassley.
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MR. BROWN: Joshua Flynn-Brown, Investigative
2
Counsel for Senator Grassley.
3
MS. DUCK: Jennifer Duck, Staff Director for
4
Senator Feinstein.
5
MS. QUINT: Lara Quint, Chief Counsel,
6
Senator Whitehouse.
7
MS. SAWYER: Heather Sawyer, Chief Oversight
8
Counsel, Senator Feinstein.
9
MS. CLAFLIN: Molly Claflin, Counsel, Senator
10
Feinstein.
11
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. There are some guidelines we follow,
15
and I'll go over those now.
16
Our questioning will proceed in rounds. The
17
majority staff will ask questions first for one
18
hour, then the minority staff will have an
19
opportunity to ask questions for an equal amount of
20
time. We will go back and forth until there are no
21
more questions and the interview is over.
22
We typically take a short break at the end of
23
each hour, but should you need a break at any other
24
time, please just let us know. And we can discuss
25
taking a break for lunch whenever you're ready to
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do so.
2
We have an official reporter taking down
3
everything we say to make a written record. So we
4
ask that you give verbal responses to all
5
questions. Do you understand?
6
MR. SIMPSON: Yes.
7
MR. DAVIS: So that the court reporter can
8
take down a clear record, we'll do our best to
9
limit the number of people directing questions at
10
you during any given hour to those whose turn it
11
is. It's also important that we don't talk over
12
one another or interrupt each other to the extent
13
we can help it. That goes for everybody present at
14
today's interview.
15
We encourage witnesses who appear before the
16
committee to freely consult with counsel if they
17
should choose. You are appearing here today with
18
counsel. Counsel, could you please state your name
19
for the record.
20
MR. LEVY: Josh levy.
21
MR. MUSE: I'm Bob Muse and I represent Glenn
22
Simpson.
23
MS. CLATTENBURG: I'm Rachel Clattenburg.
24
MR. DAVIS: We want you to answer our
25
questions in the most complete and truthful manner
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possible. So we will take our time. If you have
2
any questions or if you don't understand any of our
3
questions, please let us know. If you honestly
4
don't know the answer to a question or don't
5
remember, it's best not to guess. Just give us
6
your best recollection.
7
It's okay to tell us if you learned
8
information from somewhere else if you indicate how
9
you came to know the information. If there are
10
things that you don't know or can't remember, we
11
ask that you inform us to the best of your
12
knowledge who might be able to provide a more
13
complete answer to the question.
14
This interview is unclassified. So if any
15
question calls for information that you know to be
16
classified, please state that for the record as
17
well as the reason for the classification. Then
18
once you've clarified that to the extent possible,
19
please respond with as much unclassified
20
information as you can. If we need to have a
21
classified session later, that can be arranged.
22
It is this committee's practice to honor
23
valid common law privilege claims as an
24
accommodation to a witness or party when those
25
claims are made in good faith and accompanied by
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sufficient explanation so that the committee can
2
evaluate the claim. When deciding whether to honor
3
a privilege the committee weighs its need for the
4
information against any legitimate basis for
5
withholding it. The committee typically does not
6
honor contractual confidentiality agreements.
7
The committee and Mr. Simpson have agreed
8
that this interview is occurring without prejudice
9
to any future discussions with the committee and we
10
reserve the right to request Mr. Simpson's
11
participation in future interviews or to compel his
12
testimony. The committee and Mr. Simpson have also
13
agreed that participation in this interview does
14
not constitute a waiver of his ability to assert
15
any privileges in response to future appearances
16
before this committee.
17
Mr. Simpson, you should understand that
18
although the interview is not under oath, by law
19
you are required to answer questions from Congress
20
truthfully. Do you understand that?
21
MR. SIMPSON: Yes.
22
MR. DAVIS: Specifically 18 U.S.C. Section
23
1001 makes it a crime to make any materially false,
24
fictitious, or fraudulent statement or
25
representation in the course of a congressional
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investigation. That statute applies to your
2
statements in this interview. Do you understand
3
that?
4
MR. SIMPSON: Yes, I do.
5
MR. DAVIS: Witnesses who knowingly provide
6
false statements could be subject to criminal
7
prosecution and imprisonment for up to five years.
8
Do you understand this?
9
MR. SIMPSON: Yes, I do.
10
MR. DAVIS: Is there any reason you're unable
11
to provide truthful answers to today's questions?
12
MR. SIMPSON: No.
13
MR. DAVIS: Finally, we ask that you not
14
speak about what we discuss in this interview with
15
anyone else outside of who's here in the room today
16
in order to preserve the integrity of our
17
investigation. We also ask that you not remove any
18
exhibits or other committee documents from the
19
interview.
20
Once again, the Chairman and Ranking Member
21
withdrew their subpoena of you due to your
22
willingness to provide information in this
23
voluntary interview and document production.
24
However, the extent to which the committee deems
25
further compulsory process necessary will likely
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depend on your level of cooperation and candor.
2
Is there anything else that my colleagues
3
from the minority would like to add?
4
MS. SAWYER: Thank you. We appreciate it.
5
And we appreciate you being here as part of the
6
investigation into the Russian interference into
7
the 2016 election.
8
I did want to, with agreement of my
9
colleagues, just enter into the record the letter
10
agreement regarding the interview that was sent to
11
your counsel on August 3, 2017. I think my
12
colleague has gone over a number of the parameters
13
that we agreed to, but I think it would be helpful
14
to have this in the record. So we'll go ahead and
15
mark it as Interview Exhibit No. 1 just for
16
identification purposes.
17
(Interview Exhibit 1 was
18
marked for identification.)
19
MS. SAWYER: With that, again, thank you for
20
being here.
21
MR. DAVIS: The time is now 9:40 and we will
22
get started with the first hour of questions.
23
EXAMINATION
24
BY MR. DAVIS:
25
Q. Mr. Simpson, what is your professional
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background?
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A. I have a degree in journalism from George
3
Washington University and I've spent most of my
4
working adult life as a journalist, much of it as
5
an investigative reporter for the Wall Street
6
Journal. Prior to that I worked as an
7
investigative reporter at Roll Call Newspaper
8
writing about political corruption, financial
9
crime, terrorism, tax evasion, stock fraud,
10
financial scandals, congressional investigations,
11
government prosecutions, money laundering,
12
organized crime.
13
Q. And when did you leave the Wall Street
14
Journal?
15
A. In 2009.
16
Q. And did you found SNS Global after leaving
17
the Wall Street Journal?
18
A. That's right.
19
Q. And how many employees and associates did
20
SNS Global have?
21
A. There were two partners and in the first
22
part of the time I think we had one employee. No,
23
I'm sorry. We had two employees.
24
Q. And who were they?
25
A. We had a research assistant named Margot
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Williams, M-A-R-G-O-T Williams, and another
2
administrative assistant whose name I don't recall
3
right now.
4
Q. And who was the other partner?
5
A. Susan Schmidt was my other partner, former
6
colleague from the Wall Street Journal, and prior
7
to that was an investigative reporter at the
8
Washington Post.
9
Q. And what was the nature of SNS Global's
10
business?
11
A. Research, business intelligence.
12
Q. And what types of clients did SNS Global
13
have?
14
A. It's a while ago, so it's not fresh in my
15
mind. Other consulting firms, lawyers. I don't
16
specifically remember a lot of them.
17
Q. And is SNS Global still in business?
18
A. No.
19
Q. When did it cease operations?
20
A. I believe at the end of 2010.
21
Q. And why did it -- why did SNS Global cease
22
operations?
23
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. Basically in modern research you need
4
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
7
wasn't able to do. I prefer to spend my time doing
8
the research. So I wanted to have more of an
9
infrastructure where I could focus on that.
10
Q. What is Bean, LLC?
11
A. That's the LLC that is my current
12
company.
13
Q. And what is your role in Bean, LLC?
14
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
Q. Bean, LLC registered Fusion GPS as a trade
18
name in the District of Columbia; is that correct?
19
A. Yes, it's a DBA.
20
Q. Why did you choose to use a trade name for
21
Bean, LLC rather than directly name the company
22
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. So I just picked a
2
name. You know, a bean is a seed, a new thing. So
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. We wanted to
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
Q. Is Bean, LLC currently registered in D.C.
11
to conduct business under the trade name Fusion
12
GPS?
13
A. To my knowledge it is. It should be.
14
Q. Have any other LLC's or business entities
15
conducted business as Fusion GPS?
16
A. I don't think so.
17
Q. Have any other LLC's or business entities
18
received payments for work conducted by Fusion GPS,
19
its employees, or its associates?
20
MR. LEVY: Are you asking to include
21
subcontractors or are you --
22
MR. DAVIS: Sure.
23
MR. LEVY: Does Fusion GPS have
24
subcontractors?
25
MR. DAVIS: 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. Then there's
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.
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
19
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
A. I own an LLC in Maryland that holds some
25
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. It was
4
registered fairly recently. Obviously we can get
5
that to you.
6
Q. So is it correct that Fusion has at times
7
worked with different LLC's based on by project?
8
A. For most of the history of the company
9
Bean, LLC was the primary entity through which we
10
did business. I'm not sure I totally understand
11
your question. There's this other LLC I mentioned
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
Q. Anything that your partners would have set
16
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
account at
?
25
A. Yes.
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MR. LEVY: I don't know that we need to get
2
into bank accounts.
3
MR. DAVIS: Are you offering a basis for that
4
objection?
5
MR. LEVY: It's outside the scope of the
6
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
MR. LEVY: Yeah, and he's answering those
13
questions.
14
MR. FOSTER: He answered yes to the question.
15
BY MR. DAVIS:
16
Q. Where is Fusion GPS's physical office, if
17
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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Q. In general, what is Fusion GPS's business?
2
A. We primarily are a research, strategy,
3
consulting firm.
4
Q. And what types of clients has Fusion GPS
5
had?
6
A. It runs the gamut from corporations to law
7
firms, various investment funds, people involved in
8
litigation.
9
Q. And roughly how many active clients --
10
MR. LEVY: Did you finish? I don't know if
11
he finished.
12
MR. DAVIS: I'm sorry.
13
BY THE WITNESS:
14
A. It's hard to categorize them all. Those
15
are some of the main types of clients we have.
16
Q. And roughly how many active clients did
17
Fusion GPS have in 2016?
18
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. Our specialty is public
15
record information. So if we get an inquiry about
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
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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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
A. No, I don't think so, not to my
5
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
MR. LEVY: Within the scope of this
20
interview?
21
MR. DAVIS: In general. I'm not asking about
22
any particular case.
23
MR. LEVY: Hold on. 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: Do you want to take a break?
5
MR. LEVY: Sure.
6
MR. FOSTER: Let's go off the record. It's
7
9:55.
8
(A short break was had.)
9
MR. DAVIS: We'll go back on the record.
10
It's 10:02.
11
BY MR. DAVIS:
12
Q. After conferring with your counsel, are
13
you able to answer the question?
14
A. Yes. Could you just state it one more
15
time.
16
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
how to use it.
11
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. Your clients are
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
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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. So that's
4
generally the way we do it.
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. In the course of,
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. There's any number of scenarios
17
there that might come under discussion, but, as I
18
say, that's generally not how we frame a project.
19
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. I want to sort of generally make it clear
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
10
subcontractors. If it's not clear to you who I'm
11
referring to in the question, please just ask and
12
I'll clarify.
13
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. So I'm
25
generally putting those under that umbrella. If
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you need me to clarify for any specific question,
2
just ask.
3
MR. LEVY: You obviously said a lot there.
4
MR. DAVIS: I did.
5
MR. LEVY: 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
MR. DAVIS: Right. That's what I would be
10
asking you to do.
11
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
MR. DAVIS: Feel free to raise questions
15
about any particular question we ask.
16
MR. LEVY: Okay.
17
BY MR. DAVIS:
18
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
Q. And to whom did Fusion GPS report in the
4
course of this work?
5
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
Q. Did Mr. Cymrot provide instructions to
10
Fusion GPS during the course of the work?
11
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
Q. And when did Fusion GPS cease working on
6
the Prevezon Holdings case?
7
A. I can't say exactly. It was mid to late
8
2016.
9
Q. Which of Fusion's associates and employees
10
have worked on the Prevezon or Magnitsky issues?
11
A. For the most part it was myself and one of
12
my analysts,
. There may have -- from
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: To follow up on the previous
18
answer, you said mid to late 2016 is when the
19
investigation ended, generally speaking. Do you
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. I am --
23
we have a division of labor and I don't do a lot of
24
things like invoicing. So this is not going to be
25
my strong suit.
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MR. FOSTER: But you could figure it out
2
later for us?
3
MR. SIMPSON: We maintain books and records.
4
MR. FOSTER: 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. I mean, generally speaking, you know, when
12
we stop billing the case is over.
13
(Exhibit 2 was marked for
14
identification.)
15
BY MR. DAVIS:
16
Q. I'd like to introduce an exhibit. It's
17
one of two privilege logs that your attorneys
18
provided us. This will be Exhibit 2.
19
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. To the best of your recollection,
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?
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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
BY MR. DAVIS:
11
Q. Did Fusion ever work with subcontractors
12
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
MR. LEVY: What do you mean by "Magnitsky
22
efforts"?
23
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
MR. LEVY: And you were also asking about
6
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. So I don't -- it's going to be difficult
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.
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. There may have
5
been others. I just don't recall.
6
Q. And what type of work did Mr. Baumgartner
7
undertake for Fusion?
8
A. Discovery mostly, helping locate
9
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. He may have dealt with the
14
press. I just don't remember.
15
MR. FOSTER: What is his professional
16
background?
17
MR. SIMPSON: He has a degree in Russian.
18
MR. FOSTER: So his primary role was as a
19
Russian speaker? Is he a private investigator?
20
What does he do?
21
MR. SIMPSON: He runs a consulting firm like
22
me and deals with issues more in Ukraine than
23
Russia, but in both. Yeah, he was doing Russian
24
language things. The case revolved around,
25
centered on events in Russia. 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. I
3
don't speak Russian, I've never been to Russia. So
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
Q. And how did you come to hire him for this
9
engagement?
10
A. I met him on a previous engagement and I
11
was impressed by his knowledge of the region and
12
his general abilities.
13
MR. FOSTER: What was the previous
14
engagement?
15
MR. LEVY: We're not going to get into prior
16
engagements. It's outside the scope.
17
MR. FOSTER: Generally speaking, what was it?
18
MR. SIMPSON: It was something involving
19
Russia.
20
MR. FOSTER: A little more specifically
21
speaking.
22
MR. SIMPSON: It's my understanding that I
23
was not required to talk about my other cases at
24
this interview.
25
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
MR. LEVY: He's been answering questions and
6
we're here all day for you.
7
MR. SIMPSON: I'm here to cooperate.
8
BY MR. DAVIS:
9
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. It's not
15
particularly noteworthy. I've worked with Baker
16
Hostetler since 2009 on a number of legal cases.
17
This is the only one that involved Russia. And in
18
the course of any legal case, you know, various
19
people are retained by a law firm to perform
20
various services. So you would meet other
21
subcontractors in the course of doing legal work.
22
That's common.
23
Q. What types of services would they tend to
24
be providing?
25
A. Translators would be common, in this case
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particularly. Forensic people, accountants, PR
2
people, all those services are facets of modern
3
litigation.
4
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. Could you repeat that?
8
Q. Sure. I asked if Fusion had hired any
9
subcontractors that you worked with on the Prevezon
10
matter, whether Baker hired anyone that you worked
11
with. Now I'm wondering did you work with anyone
12
hired directly through Prevezon on this as opposed
13
to Baker Hostetler?
14
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. Generally
24
if I'm introduced to somebody they'll explain, you
25
know, why there were other lawyers who worked for
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Prevezon who were part of the case. Other people
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
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. I basically -- you know, in all
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
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. If you're asking me if we
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
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. I think
3
Weber Shandwick was the one we ended up with.
4
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: Beyond what he's already told you?
9
MR. DAVIS: With a little more detail.
10
BY THE WITNESS:
11
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. So they claimed that the
9
allegations originated with a mobster named Demetri
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. As you know, Russia is rife with
16
corruption and there's a lot of anger over
17
corruption.
18
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. So as far as it
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
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law enforcement that western law enforcement did
2
consider Baranovsky to be a lieutenant in this
3
organized crime family. So we did that for a
4
while. Edward Baumgartner helped a lot with that
5
because of his Russian language skills and his
6
ability to interface with the court system in
7
Russia.
8
And, you know, around the -- similarly, there
9
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. Then the lawyers
22
wanted to know, you know, whether he could be
23
subpoenaed. So a lot of what I did in 2014 was
24
help them figure out whether he could be subpoenaed
25
in the United States to give a deposition, and the
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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. So
8
we subpoenaed his hedge fund. He then changed the
9
hedge fund registration, took his name off, said it
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. That was around the
15
time he started making all the money in Russia. So
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
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. So we found this to
25
be a frustrating and somewhat curious situation.
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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. We were able to ascertain that he does
14
use that property because he registered cars to
15
that property with the Colorado DMV in the name of
16
William Browder.
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. So we -- I served him a
22
subpoena in the parking lot of the Aspen Institute
23
in the summer of 2014 using two people -- two
24
subcontractors. Actually, those other
25
subcontractors were -- their names escape me, but I
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forgot about those. We can get you that. This is
2
all in the Pacer court record, the public court
3
record.
4
In any event, the three of us served -- there
5
was another subcontractor working for the law firm
6
whose name I also forget. I did not retain him,
7
but I was asked to work with him on this. He is a
8
private investigator and we can get you his name.
9
In any event, we served him the subpoena and he ran
10
away. He dropped it on the ground and he ran away.
11
He jumped in his car and went back to his mansion.
12
At that point he tried to suppress -- tried
13
to quash the subpoena on the grounds it hadn't been
14
properly served. We didn't get a video, but there
15
are sworn affidavits from my servers in the court
16
record about the service. But he objected to it on
17
a number of grounds. A, he continued to insist he
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. He also said
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. He also began to raise
24
questions about whether Baker Hostetler had a
25
conflict of interest because of some previous work
Glenn Simpson
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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. This was, you know, a lot of what I
7
did. This was -- the main focus was on trying to
8
get William Browder to testify under oath about his
9
role in this case and his activities in Russia.
10
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. I think the first time I met
25
him he lectured me about -- I was working on a
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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. There are numerous documents
5
that he published himself, interviews he gave
6
singing the praises of Vladimir Putin. At that
7
time I was already investigating corruption in
8
Putin's Russia.
9
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. So through this period while
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. We
21
were doing it all together. It was a -- you know,
22
there were a number of lawyers involved, other
23
people.
24
In the course of doing this research into
25
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. It's the only Buddhist republic in
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.
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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. Ultimately they were caught, some of these
6
companies were prosecuted, and he was forced to
7
make an enormous tax payment to the government of
8
Russia in 2006.
9
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. This
13
precedes all that.
14
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. At that point somewhere in there the Panama
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
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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. They
8
were servicing every bad guy around. And I'm
9
familiar with them from other money laundering and
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. This
16
is, again, a public fact that you can check
17
on-line.
18
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. I'll add also that I was
23
extremely sympathetic for what happened to Sergei
24
Magnitsky and I told him that myself and I tried to
25
help him. 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. Can you tell us who that was and who
12
conducted the interview?
13
MR. LEVY: Mr. Simpson should definitely
14
answer that question. I just want to make sure for
15
the record that he hadn't finished his answer. He
16
can talk more extensively about the litigation
17
support that he provided for Baker --
18
MR. FOSTER: We're happy to get into that if
19
he wants to do that. We're just coming up at the
20
end of our hour.
21
MR. LEVY: No problem.
22
MR. FOSTER: and I wanted to get that
23
follow-up in before --
24
MR. LEVY: No problem. No problem at all.
25
BY THE WITNESS:
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A. I'll just finish with one last thing and
2
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. So I read his book and I began doing
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. When I went
25
back into the history of Peter Star I realized that
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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. There's no mention of William
9
Browder's deal with Peter Star in Red Notice. 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. So I assume he might
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 your question about the ICE agent, he was
21
deposed by John Moscow of the New York office of
22
Baker Hostetler. John is an old associate of mine
23
from my days as a journalist. John's an expert on
24
tax evasion and money laundering. He was the head
25
of the rackets bureau for the district attorney's
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office in New York.
2
MR. FOSTER: You're talking about a formal
3
deposition in the litigation?
4
MR. SIMPSON: Yeah.
5
MR. FOSTER: I just wanted to clarify that.
6
MR. SIMPSON: 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. So you
11
won't see my name scattered through the court
12
record, but a lot of this is what I did.
13
MR. DAVIS: I think that's concludes our
14
first hour. Let's take a short break before we
15
begin a new one.
16
MR. FOSTER: Let's go off the record.
17
MR. DAVIS: We'll go off the record at
18
10:45.
19
(A short break was had.)
20
MS. SAWYER: It's about 10:55.
21
EXAMINATION
22
BY MS. SAWYER:
23
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. They may have some
2
follow-up.
3
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. Again,
6
we appreciate you being here today to answer our
7
questions.
8
You had talked with my colleagues a bit about
9
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. We
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. At least, you know, the kind
18
of journalism I practiced was based on documents.
19
I'm a document hound and so are my colleagues.
20
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. We do a lot of Freedom of
25
Information Act work. We work with court records
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a lot, corporate records a lot. Some of my
2
employees do a lot of financial crime and money
3
laundering and fraud investigations, tax evasion,
4
that sort of thing. Those are my specialties.
5
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. So we do things like policy disputes,
9
one industry versus another, one company versus
10
another. We don't do a lot of campaign consulting,
11
but every four years for the last couple of cycles
12
we've done some presidential work.
13
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. So we only
16
would do things where people have the resources to
17
pay for a serious piece of research. So we do
18
things like a California initiative or
19
presidential.
20
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. So I think that's what
3
I referred to earlier as the decision support part
4
of our work.
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. I
9
mean, that's a kind of typical thing. Also another
10
example would be I think I've been defrauded, but I
11
can't figure out how or why. Or I keep -- you
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
Q. So in some ways it's fact gathering and
18
due diligence for clients?
19
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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like a McDonald's cheeseburger.
2
Q. I think when you were speaking with my
3
colleagues you described your work as open ended
4
and not results directed. Can you explain a little
5
more what you mean by that?
6
A. Sure. Another thing we say about our work
7
is it's custom information, it's a customized
8
product. You tell us what your problem is and we
9
customize a research solution. 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. I like to call it a holistic
15
methodology.
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. So it's
21
better -- you know, it's pure versus applied
22
science, right? You're looking to understand how
23
things work before you understand what you might
24
need to address a particular problem.
25
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. So if you're not able
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.
8
Q. So the way it's structured you are
9
certainly free to follow the facts wherever they
10
may lead you in the course of research?
11
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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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. And most of our clients are
5
not trying to win an election. They're trying to
6
win a lawsuit or, you know, find out who ripped
7
them off.
8
Q. With regard to the political or campaign
9
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. In the
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. So, you know, that was a natural
21
subject for me. So we do, we investigate
22
multinational enterprises on a frequent basis.
23
Q. Just to be clear, when you say "in the
24
current example," what are you referring to?
25
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. How do you handle the fact that you
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?
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. You know, there's some
3
exceptions when things become public. If we're
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. But we have
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
As the business has grown, you know, we've
11
taken on more and more matters. So I don't -- you
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. So sometimes we work together, but
16
frequently each of them will be doing three, four,
17
five cases at a time.
18
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. Again, it would also be on a kind of
15
need-to-know basis. There's no need for a
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. Sometimes we identify clients
19
to prevent conflicts. So unless there's a reason
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
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? Can you just
4
describe it first generally and then I'll ask you
5
some follow-up.
6
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. You
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
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. So this was typical. We
19
ordered every Donald Trump book and, to my
20
surprise, that's a lot of books. I was never very
21
interested in Donald Trump. He was not a serious
22
political figure that I'd ever had any exposure to.
23
He's a New York figure really.
24
So anyway, we read everything we could read
25
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. I'm trying to
3
think what else. His taxes certainly have always
4
been a big issue. Again, it was sort of an
5
unlimited look at his -- you know, his business and
6
finances and that sort of thing.
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
Q. And what can you tell us about who engaged
13
you initially to do that work?
14
MR. LEVY: The answer to that question might
15
implicate privilege.
16
BY MS. SAWYER:
17
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. Can
20
you confirm whether that is accurate or not?
21
MR. LEVY: We're not going to talk about the
22
identity of clients.
23
BY MS. SAWYER:
24
Q. So with regard to this engagement in
25
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. I believe it was
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
request like most of the things that we get.
11
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: We're not going to get into client
17
communications. It's privileged.
18
BY MS. SAWYER:
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
A. Can I talk generally about my practices
23
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. So it's
4
really counterproductive for somebody to tell you
5
look here, don't look there, I'm interested in X
6
but not Y. So we generally sort of push back when
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 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. So it was regular
24
order.
25
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. Did you -- were
6
those the general options on the table with regard
7
to this engagement as well?
8
MR. LEVY: If you can discuss it without
9
talking about client communications. If you can't,
10
you can't.
11
BY THE WITNESS:
12
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. It was tell me what we need to know about
20
this guy. So later on, you know, we started
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
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. With regard to this initial
9
engagement that started in October, September, can
10
you just explain for us what your findings were.
11
A. I guess I'll just give you the caveat
12
that, you know, it's a group effort. So I can tell
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
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. It wasn't hard to find, it wasn't any
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
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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. I guess I should just repeat, you know,
7
this is a subject that I covered extensively at the
8
Wall Street Journal. I wrote a series of front-
9
page articles about various corrupt politicians
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. So, you
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
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. It's much
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. Stock fraud in
20
particular was the big thing in the U.S. In any
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
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. That was not true. He knew him well and,
9
in fact, continued to associate with him long after
10
he learned of Felix's organized crime ties. So,
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. I also, you know, began
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. We saw indications
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
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. You know, it wasn't really a Russia
24
focused investigation for the first half of it.
25
That was just one component of a broader look at
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his business career, his finances. We spent a lot
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
than that.
11
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. We looked at the
14
bankruptcies, how could somebody go through so many
15
bankruptcies, you know, and still have a billion
16
dollars in personal assets. So those are the kinds
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
23
know, when it comes to paying taxes, Donald Trump
24
claims to not have much stuff. At least the Trump
25
organization. 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: Yeah. Can you tell us when that
13
engagement ended?
14
MR. LEVY: Which question is pending? Can
15
you repeat the question?
16
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. I'm wondering the time frame to
20
make sure we're all on the same page.
21
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. So, you know, we collected lawsuits from
4
around the country and the world. And I do
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. There had been another one in Ireland. There
9
was a lot of Freedom of Information Act requests
10
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. So in the course of reading that
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
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. Can you tell us when that particular
24
engagement ended?
25
A. I can only estimate it.
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Q. And in general when do you think that
2
ended?
3
A. Spring of 2016.
4
MR. LEVY: Don't guess.
5
MR. SIMPSON: I'm sorry.
6
BY MS. SAWYER:
7
Q. Okay. 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: Not nothing as a factual matter,
22
but he's going to decline to answer that question.
23
MS. SAWYER: And the basis again for
24
declining that question?
25
MR. LEVY: Privilege.
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MS. SAWYER: Okay.
2
MR. LEVY: And other obligations of
3
confidentiality.
4
MS. SAWYER: Just to be clear for the record,
5
specifically what privilege?
6
MR. LEVY: The privileges that we previously
7
asserted with the committee. They're in our
8
April 7 and June 23 letters.
9
MS. SAWYER: Okay.
10
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
A. I think I'd like to confer with my lawyer
17
about this.
18
MR. LEVY: Sure.
19
(Whereupon a discussion was had
20
sotto voce.)
21
MR. SIMPSON: I'm going to decline to answer
22
that question.
23
MS. SAWYER: And, again, the grounds for
24
declining?
25
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
MS. SAWYER: Sure.
4
BY MS. SAWYER:
5
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. I've lived in this city for 30 years or
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. We
18
intentionally don't hire people who have strong
19
partisan affiliations. We prefer journalists who
20
don't see things through ideological prisms and
21
ideological prisms are not helpful for doing
22
research.
23
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? And when I say "you" here I
5
mean Fusion GPS.
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
Q. And why did you engage Mr. Steele in May
13
or June of 2016?
14
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. He was not the
18
only subcontractor that we engaged. Other parts of
19
the world required other people. For example, we
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. So we
24
needed someone else for that. So there were other
25
things. 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. He was
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. I would say that's
17
broadly why I asked him to see what he could find
18
out about Donald Trump's business activities in
19
Russia.
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. Did something in
24
particular trigger that assignment?
25
A. No, I don't think I could point to
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something in particular as a trigger. I mean, the
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
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. So in any kind of
12
investigation you would naturally want to know
13
whether there was some issue with improper business
14
relationships.
15
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
A. I don't specifically remember. What I
25
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. I don't think at the time at least that
6
we were particularly focused on -- well, I don't
7
specifically remember.
8
Q. So you hired Mr. Steele. Had you worked
9
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. And so, you know, the former Soviet
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. So
23
particularly in Europe there's a lot of disputes
24
over who really owns what.
25
And so we would collaborate on those kinds of
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investigations. Sometimes a controversy would
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. It's
7
interesting work, but it's kind of plain vanilla
8
business intelligence, litigation support stuff.
9
Q. And roughly how many years -- over how
10
many years, like when do you first recall working
11
with him?
12
A. I believe we met in 2009. We've worked
13
together since 2009.
14
Q. And how did you find the quality of his
15
work over that period of time?
16
A. Quality is a really important issue in the
17
business intelligence industry. There's a lot of
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. Chris was, you know, a person
23
who delivered quality work in very appropriate
24
ways.
25
So -- I mean, I hope you won't be insulted,
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but he's basically a Boy Scout. You know, he
2
worked for the government for a very long time. He
3
lives a very modest, quiet life, and, you know,
4
this is his specialty. We got along very well
5
because my speciality is public information. So he
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
When I was at the Journal I spent many years
11
investigating the financing of Al-Qaeda. So I did
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. So we had a lot of common
17
interests and background.
18
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. We didn't
25
know what he was doing there. 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. We
3
said see if you can find out what Donald Trump's
4
been doing on these trips to Russia. Since Chris
5
and I worked together over the years there's a lot
6
that didn't need to be said. That would include
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
10
you would look at. I don't think I gave him any
11
specific instructions beyond the general find out
12
what he was up to.
13
Q. And was anyone else -- did you engage
14
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. It just involves reading Russian newspaper
22
accounts and that sort of thing.
23
Q. So was Mr. Baumgartner also working on
24
opposition research for Candidate Trump?
25
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
Q. With regard to the presidential election
6
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. There wouldn't have been any
16
reason to -- he operates under the same rules that
17
I do.
18
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
with him?
5
A. Yes. I mean, do you mean as
6
subcontractors or within his company?
7
Q. First within his company.
8
MR. LEVY: If you know.
9
BY THE WITNESS:
10
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? I said Russia-related research with
19
regard to Candidate Trump. Would that be a fair
20
way to describe the assignment?
21
A. Yes.
22
Q. Did you have any input into the actual
23
work that he did? Did you give him directions as
24
to what to research specifically?
25
A. I don't recall giving him specific
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instructions. We spoke on the phone about various
2
areas of interest. For example, when Paul Manafort
3
was elevated to running the campaign, we talked
4
about Paul Manafort and his long history of
5
dealings with Russian oligarchs. So it's more of a
6
collaboration than, you know, sort of manager-
7
employee kind of relationship. You know, we would
8
talk about things that were interesting to us and
9
that seemed to be -- you know, needed to be
10
(indecipherable).
11
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. I mean, Chris's
2
role was specifically to do the thing that we
3
couldn't do, which was to arrange to talk to
4
people. Generally speaking, we don't do a lot of
5
interviewing. Our research is very document
6
focused.
7
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. I think speaking broadly, you know, there's
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. The thing that people
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
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. It was only, you
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. So these things
6
eventually converged into, you know, a major issue,
7
but at the time it wasn't one.
8
Q. I have five or so more minutes and I know
9
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. So the first sort of beginning
25
of that is he says, you know, I've worked on this
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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. It's
4
the number one issue.
5
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. So it's front
11
and center when you gather information in Russia.
12
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? Did they overlap, the two
16
clients?
17
A. I just don't know. I can just tell you
18
that it was -- I mean, things follow the political
19
cycle. So there was a point at which the
20
Republican primaries were fundamentally over and
21
the Democrats hadn't really begun yet. So there
22
was some transition period. That's all I can say.
23
I don't keep the books at my place. So I would
24
feel -- I'm afraid to give you a wrong answer that.
25
I just don't know.
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Q. Did either client know that you had hired
2
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: Do you want to take a break?
17
MR. SIMPSON: Sure.
18
MR. LEVY: Let's take a break and confer.
19
MR. SIMPSON: That's fine.
20
MS. SAWYER: Sure. We'll go off the record
21
for a few minutes.
22
MR. FOSTER: It's 11:51.
23
(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. I think at one
23
point you indicated that you and Mr. Baumgartner
24
had operated under the same rules?
25
A. Right. We're both professionals and we
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both deal with multiple clients. So we don't talk
2
about a case with one client with another client.
3
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
MR. FOSTER: Can you speak up a little bit.
8
BY THE WITNESS:
9
A. Mr. Baumgartner did not know about the
10
work that we were doing with Mr. Steele. One of
11
the ways that we avoid bleeding between one case
12
and another is compartmentalization. We don't tell
13
people -- we don't tell one subcontractor what
14
we're doing with another subcontractor. We don't
15
even tell them, you know, that they exist.
16
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. So he was operating under an NDA.
22
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. So they're not allowed to share
6
information with anyone outside the case.
7
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. So by its very nature the question of
20
whether something is accurate isn't really asked.
21
The question that is asked generally is whether
22
it's credible. Human intelligence isn't good for,
23
you know, filing lawsuits. It's good for making
24
decisions and trying to understand what's going on
25
and that's a really valuable thing, but it's not
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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. You don't really decide
7
who's telling the truth. You decide whether the
8
person is credible, right, whether they know what
9
they're talking about, whether there's other
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. So, you know, for example, he, you know,
17
wrote a memo about a Trump campaign advisor named
18
Carter Page and his mysterious trip to Moscow.
19
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. I was just trying to get
22
a sense of the specific ways in which you assessed
23
his performance in determining to hire him.
24
A. That's how we did it. We would assess it
25
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
MR. MUSE: His reference was to give you an
4
example. I think that's where he was going.
5
MR. SIMPSON: Yeah.
6
MS. SAWYER: 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: So we'll go off the record.
15
It's high noon, 12:00. So let's go off the record.
16
(A short break was had.)
17
MR. DAVIS: We're back on the record. It's
18
12:06 p.m.
19
EXAMINATION
20
BY MR. DAVIS:
21
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. I think you've described three main
25
areas so far. 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
MR. LEVY: I think he said a lot more than
8
that, but go ahead.
9
MR. DAVIS: I listed the main topics. That's
10
where we left off.
11
MR. LEVY: I don't think that's the main
12
topics either, but go ahead.
13
BY THE WITNESS:
14
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: Just make sure you answer his
15
question. Was it done?
16
BY THE WITNESS:
17
A. That's part of what the lawyers hire you
18
to do and that's what they instruct you to do. The
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
Q. So then was it typically done on a
25
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. So the reporter will
8
call and they'll want to know whatever, where the
9
house was in Colorado, and he'll say somewhere in
10
Aspen, ask Glenn. Then he'll send him to me or
11
he'll send me to them. Later on when you get where
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. They won't tell you on an individual
17
basis talk to so-and-so. It's a little of both.
18
Q. Was Fusion then paid for these
19
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. So in the fundamental sense
23
yes, we were. Specifically paid for individual
24
conversations, I don't think so.
25
MR. FOSTER: Do you bill hourly?
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MR. SIMPSON: It depends on the case.
2
MR. FOSTER: On this case?
3
MR. SIMPSON: I think we did on this case.
4
MR. FOSTER: So did you bill for
5
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. So I would go to a court hearing with
12
the lawyers and there would be reporters there. So
13
part of what I was billing for was answering their
14
questions.
15
BY MR. DAVIS:
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. It was the
20
major news organizations that were covering the
21
litigation. Usually it was their courthouse or
22
legal reporters. So it was Bloomberg, New York
23
Times, Wall Street Journal, probably Reuters, Legal
24
360. I'm sure there were a handful of others.
25
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. I don't think they covered the case prior to
13
that.
14
Q. What about NBC?
15
A. We would have -- I'm sorry. Yes.
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
21
generally speaking, the work -- we provided
22
information about the work that I had done about
23
William Browder's credibility. The whole case
24
ended up -- when I said when he declined to appear
25
voluntarily as I am here and explain things, you
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know, it ended up being an issue of why he didn't
2
want to talk. So a lot of it was about his
3
credibility, about his account of his activities in
4
Russia, about his history of tax avoidance, all
5
these things.
6
Q. Did Fusion provide the media information
7
alleging that Browder had illicitly engineered the
8
purchase of 133 million shares of Gazprom?
9
A. I don't know for sure, but we certainly
10
did research on that issue.
11
Q. And you described investigating these
12
series of issues. How did you acquire the
13
information in the course of this investigate?
14
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. So there was obviously a sharing of
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. In a lot of
6
these cases we were giving people court filings.
7
So the information was mixed together from various
8
sources.
9
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. So if they
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
Q. And did Prevezon or Baker Hostetler ever
25
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. So I think so, but I just don't have
11
an idea.
12
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
documents.
19
Q. Do any Fusion employees or associates
20
speak Russian?
21
A. No. I'll qualify that. Depends on how
22
you define associate. Edward isn't an employee of
23
the company, but he speaks Russian. He's a
24
subcontractor.
25
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. There was other Russian speakers I think
5
that were engaged by Baker Hostetler in various
6
situations, like translators, Russian bilingual
7
lawyers, that sort of thing.
8
Q. Do you remember the names of any of those
9
people?
10
A. Anatoli, whose last name I can't really
11
pronounce, was a New York-based English-Russian
12
court translator. He was mostly a courtroom
13
translator. So I don't know whether he -- I really
14
don't know the extent of their other involvement
15
with other people in these things.
16
MR. FOSTER: Can I just back up before we get
17
too far afield of this. I want to follow up on an
18
answer that you gave earlier. You described your
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. That's my
22
understanding of how you described it.
23
MR. LEVY: 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. My question is were there instances where
2
you were initiating contact with the press or
3
pitching stories to the press?
4
MR. SIMPSON: Sure. I mean, the range of
5
things that you would do, you know, again, it would
6
evolve. In the beginning you were going to a lot
7
of hearings and a lot of legal reporters are
8
showing up and you're mostly answering their
9
questions. 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. So there was definitely some
14
reach out like that. Then we would also talk to
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
MR. FOSTER: 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. So for much of this case it was reactive
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. So, you know, unhappily,
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
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. In fact, you know, the third one he ran
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.
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? Yeah, we wanted people to know that.
24
BY MR. DAVIS:
25
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
mentioned, you said Anatoli and that you didn't
10
know how to pronounce --
11
A. Samochornov I think is his --
12
Q. Okay.
13
A. I'm massacring it. Again, it's something
14
that's in the public record.
15
Q. Do you know Rinat Akhmetshin?
16
A. Yes, I do.
17
MR. MUSE: Spell it.
18
MR. DAVIS: Sure. R-I-N-A-T,
19
A-K-H-M-E-T-S-H-I-N.
20
BY MR. DAVIS:
21
Q. When did you first meet Mr. Akhmetshin?
22
A. When I was a reporter at the Wall Street
23
Journal.
24
Q. And as far as you know, what is his
25
business?
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A. Some kind of PR consulting lobbyist. I
2
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. I don't have any economic relations
9
with him. You know, I've bumped into him over the
10
years around town. So, you know, the only thing
11
that I specifically recall having done with him was
12
interacting for a brief period on the Prevezon
13
case.
14
Q. You don't recall working with him for any
15
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. I met him in connection with some stories I
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. He's told me various things and I
25
think I even met one of his clients at one point,
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but it wasn't a business thing. I don't think I
2
was doing any work. I was just networking.
3
Q. You said he told you various things. Do
4
you mean he would pass along information to you?
5
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. It was coffee or
11
something.
12
Q. You said he claimed credit for having
13
started the congressional investigation?
14
A. That's my recollection, but this was some
15
years ago.
16
Q. And you said you met one of his clients.
17
Do you remember which client?
18
A. A former Kazakh politician whose name
19
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. I would hesitate to say 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
Q. Has Mr. Akhmetshin ever paid Fusion GPS
10
for work?
11
A. Not to my knowledge.
12
Q. You mentioned interacting with him in the
13
Prevezon matter. What did you understand his role
14
to be in the Prevezon work?
15
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? I don't recall anyone ever
19
saying to me you're not doing X, Y, or Z. They may
20
have. I just don't recall. The lane that I was in
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. 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. Who else attended these
12
meetings?
13
A. I don't specifically remember. I mean, Ed
14
Lieberman I think was at a meeting. Again, I don't
15
think it was -- it wasn't a lot of meetings, just
16
one or two, but it was at Baker Hostetler.
17
MR. FOSTER: Can you explain briefly who Ed
18
Lieberman is.
19
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. And then subsequently
24
also he knows Rinat from I guess, I don't know,
25
college or something and subsequently the two of
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them were working on the -- I don't know what to
2
call it, the congressional stuff.
3
MR. FOSTER: Lobbying Congress?
4
MR. SIMPSON: I believe they registered to
5
lobby Congress.
6
BY MR. DAVIS:
7
Q. Did Fusion provide any of its research to
8
Mr. Akhmetshin whether directly or through an
9
intermediary such as Baker Hostetler?
10
A. Yes. We were directed to do so by Baker
11
Hostetler.
12
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. I don't remember. He may have
18
told me what he did. As I say, it was not the
19
focus of my work.
20
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. He may have -- I don't recall whether he
3
mentioned having worked with the Russian
4
government.
5
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. He certainly didn't
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
ties to the Russian government?
22
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. It just
2
didn't come up. Obviously with the news of this
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.
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
Ms. Veselnitskaya?
14
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. So when you say
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.
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. So if that's
24
what your question is, then the answer is yes, but
25
I mean, I don't think the money came from her. It
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came from Prevezon.
2
Q. Were there any direct payments that didn't
3
go through Baker Hostetler?
4
A. No.
5
Q. So what did you understand her role to be
6
in the litigation? You said she was the attorney
7
for Prevezon. Was she managing the case for
8
Prevezon?
9
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. It was represented to
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. So, you know, that's how I learned
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
information about that extortion case?
23
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. They would have materials
3
analyzed and translated and then they would -- I
4
don't read a word of Russian. So I would get the
5
certified translations of stuff from Baker.
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. Later on when
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. So I don't remember
17
specific conversations with her about that, but
18
that's what we would have discussed.
19
Q. Have you met in person with her on other
20
occasions besides court hearings?
21
A. I attended a couple client dinners and I
22
think that's about it.
23
Q. Do you recall when and where those would
24
have been?
25
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. I don't remember when
3
they started. I think probably 2015. And there
4
was some in 2016 in both cities.
5
Q. Were any in June 2016?
6
A. Yes. Two.
7
Q. Were those in New York or in D.C.?
8
A. I believe that one was in New York and one
9
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
Q. And what were the purposes of these
16
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. The one in D.C. was more of a social
21
thing. It wasn't -- she was at it, but it wasn't
22
really about the case. It was just a bunch of Mark
23
Cymrot's friends. You know, the editor of the
24
Washington Post book section was there and his wife
25
who's a well-known author were also there. I can't
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remember who else was there. But anyway, she sat
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. So not a lot of
5
chit-chat.
6
Q. Was it your understanding that the
7
research you provided to Baker Hostetler would then
8
be passed on to Ms. Veselnitskaya?
9
A. To the extent that it was useful and
10
interesting to her I'm sure they did, yes.
11
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. Of course given to wonder
5
given all the recent events and disclosures that I
6
was unaware of whether my assessment of her was
7
right or wrong. As we sit here today, the jury's
8
kind of out. I honestly can tell you all I knew is
9
she didn't seem to be a heavy hitter in the Kremlin
10
world.
11
Q. This might be a little repetitive, but
12
when did you first meet Ed Lieberman?
13
A. I don't remember specifically, but it was
14
years ago.
15
Q. I believe you described his business.
16
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
role to be in the Prevezon issue?
25
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. At that time we didn't know about
8
the offshore companies in BVI.
9
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. So
14
we talked about tax stuff. Later on, much later on
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.
19
Q. Did Fusion provide its research to
20
Mr. Lieberman either directly or through an
21
intermediary such as Baker Hostetler?
22
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
A-R-A-K-E-L-I-A-N?
5
A. There was a guy at a lunch or dinner or
6
something named Robert and he was introduced to me
7
as Robert. Again, when you're going to like these
8
client meals or things like that, you know, we
9
didn't get into a lot of details of who he was. I
10
just remember he was introduced as a friend Denis
11
Katsyv, K-A-T-S-Y-V. That's my recollection. It
12
may be that he's a friend of Rinat's. I don't
13
really know.
14
Q. As far as you know, what is Mr. -- what is
15
Robert's business?
16
A. I don't know.
17
Q. So presumably, then, has Fusion ever
18
worked with him?
19
A. Not to my knowledge.
20
Q. What did you understand Mr. Arakelian's
21
role to be in the Prevezon work?
22
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
directly or through an intermediary such as Baker
10
Hostetler?
11
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
Q. Do you have any reason to believe he has
15
ties to the Russian government?
16
A. No.
17
Q. But you said he is friends with the
18
Katsyvs?
19
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
Prevezon work?
5
A. I've read that his firm was involved in
6
the lobbying, but it's just something I read. I
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.
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
A. She was introduced to me as the lawyer for
19
Prevezon. I never --
20
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: Denis or Pyotr.
24
MR. SIMPSON: As I said, she was introduced
25
to me as the lawyer for Prevezon. So -- and I
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think the lawyer for Denis. So beyond that I
2
don't know.
3
BY MR. DAVIS:
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
Q. What did you understand his role to be in
3
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. William Browder likes to use the
8
press, but he doesn't like anyone talking freely
9
about him or raising questions about the story of
10
his activities in Russia. So when this movie came
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, 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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lawyers and people trying to suppress free speech
2
Q. And was the showing arranged for Prevezon,
3
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. They
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
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. I don't
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. So it was the central issue in the
24
Prevezon case.
25
Q. So you mentioned Mr. Cooper was involved
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in establishing this screening. Do you know how he
2
came to be hired by Prevezon or HRAGI or whoever?
3
A. I know a little. As I was saying earlier,
4
I've known Chris from Wall Street Journal days and
5
I refer business to him. I know this doesn't fit
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
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. So we were trying to find
14
PR people and he was one of the people that I
15
recommended as a trial PR guy. From there I don't
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
Q. Do you know who came up with the idea of
20
creating HRAGI?
21
A. I would be guessing. I just don't
22
remember. Someone may have told me. I don't
23
remember.
24
Q. What kind of interaction did Fusion have
25
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. We were
3
very peripheral to this stuff and I don't remember
4
if I had any specific interactions with it. I
5
don't know if they had an office, I don't know if
6
they had a bank account. I just don't know. I do
7
know they registered to lobby.
8
Q. Do you know Lanny Wiles, L-A-N-N-Y,
9
W-I-L-E-S?
10
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. He's
21
a lobbyist. He was involved in the lobbying.
22
Beyond that I really couldn't say.
23
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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Q. Do you have any reason to believe that
2
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
A. The meeting that I was aware of that I
9
remember hearing about was a meeting that actually
10
didn't happen which was some meeting that Mark
11
Cymrot was supposed to have. It's possible that he
12
was going to meet some Congressman. It's possible
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
Q. If I could refer back to Exhibit 2, the
19
partial privilege log. The first page of that
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." Do you
23
believe that to be a reference Congressman French
24
Hill?
25
A. I don't know. I believe it was a
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Congressman named Hill. I don't know if it was a
2
Congressman named French Hill.
3
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. It was either Rinat or
9
Mark Cymrot or maybe both about some of these
10
issues, but, again, I don't have a great
11
recollection for the specifics.
12
Q. Did Fusion have any role in these
13
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. It's their information.
18
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. This would have been a
4
recurring issue in the case. You know, our lawyers
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. I just remember that was an issue.
10
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
Q. And that hearing was on June 8th; is that
25
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. I
7
don't have a clear recollection of the dinner, but
8
I know -- I believe we had a dinner. The problem
9
is I had more than one. So I don't have a clear
10
recollection of it.
11
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. I think she was with Anatoli and she left
15
afterwards. I know she didn't tell me any other
16
plans she had.
17
Q. So you had dinner the 8th, saw her in
18
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. Were you aware of this
6
meeting beforehand?
7
A. No.
8
Q. It didn't come up at the dinner the night
9
before?
10
A. No.
11
Q. When did you first become aware of the
12
meeting?
13
A. Around the time it broke in the New York
14
Times. I was stunned.
15
Q. Is it correct that that means it wasn't
16
discussed at the dinner on the 10th?
17
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. So, you know,
22
fortunately I was not going to do a lot of
23
entertaining.
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
the meeting other than what you read in the media?
5
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
A. I think so. If it's, you know, stuff I
14
worked on I obviously will recognize it, yes.
15
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. You know, as a sort of
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
meeting at any time with Rinat Akhmetshin?
8
A. No. No.
9
Q. Have you had any communications about the
10
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. I think we all exchanged mutual
16
expressions of surprise. I think I talked to Paul
17
Levine, a lawyer at Baker Hostetler. I'm sure I
18
discussed it with Ed Baumgartner, Mark Cymrot. You
19
know, if anyone knew about it they certainly didn't
20
confess it to me.
21
Q. Do you know -- I'm going to butcher this
22
name -- Irakle Kaveladze?
23
A. I know who he is.
24
Q. I'll spell it. I-R-A-K-L-E, last name
25
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
any role in the Prevezon or Magnitsky work?
6
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. Beyond that I don't have any -- I
20
don't have any information.
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
Q. Has Fusion ever worked with him other than
7
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. He, to my knowledge, didn't have
16
a pre-existing relationship with Ms. Veselnitskaya
17
or Prevezon. That's my understanding to this day.
18
MR. DAVIS: I think that's the end of our
19
hour. 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
EXAMINATION
3
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. It has
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. Is that accurate?
11
A. To the best of my knowledge, that's
12
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. Is
17
that also accurate?
18
A. I think what he has said is that -- yeah,
19
that's basically accurate. What he said was that
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
identification.)
25
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. The first one is
9
CLMS-JC-00041391 and then the last one is number
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. I never actually numbered -- totaled
21
them up, but these are the ones I'm familiar
22
with.
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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A. To the best of the my knowledge as part of
2
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." I'm just looking at the
6
first page. That one says "Company Intelligence
7
Report 2016/080." What would that have signified?
8
A. Company Intelligence Report is just a way
9
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. That's my understanding.
15
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. So the interpretation is that it's
20
an internal numbering system for maybe Russia stuff
21
or maybe it's just -- I'm sorry. I don't know what
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
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. Were those other five reports
8
reports that were being generated for Fusion GPS
9
or --
10
A. No.
11
MR. LEVY: I don't think he said that. Go
12
ahead.
13
BY THE WITNESS:
14
A. I mean, there aren't five reports that he
15
did for us between these two. This is the first
16
and second.
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. Would you
21
have received it around that time that it's dated,
22
June 20, 2016?
23
A. Within a couple days, yeah. Yes.
24
Q. And not every single discrete memo has a
25
date, but a number of them do. To the extent they
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had dates, would you have been receiving them
2
around the time they were dated?
3
A. Yeah. I believe so, yes. There might be
4
some lag, transition lag.
5
Q. And what was -- what use did you make of
6
these memos?
7
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. He has
25
worked on projects all over the world, but in
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particular, you know, several in the former Soviet
2
Union, Georgia, Azerbaijan, both former Soviet
3
republics. So over the course of the spring I'd
4
say -- and Russia -- we gradually began to exhaust
5
the public record, the open source about these
6
topics in various places. As you, you know, sort
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
source.
11
So the purpose of this was to see if we could
12
learn more, generally speaking, about his business
13
dealings in Russia. What came back was something,
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. You know, initially we didn't know
19
what do with this.
20
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. So when this arrived
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
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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. So when this arrived, you know,
12
we made no immediate use of it at all in terms of,
13
you know, giving it to anybody. It was essentially
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 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. You know,
25
I did -- you know, in the initial round of this
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that was the big question, was this credible.
2
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. So I want to
6
clarify when you said "this," in the context of
7
answering that I assumed you were talking about the
8
first --
9
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
June 2016?
14
A. Correct. To be totally clear, you know,
15
what people call the dossier is not really a
16
dossier. It's a collection of field memoranda, of
17
field interviews, a collection that accumulates
18
over a period of months. You know, they came in
19
intermittently, there was no schedule. You know,
20
he'd reach a point in the reporting where he had
21
enough to send a new memo; so he'd send one. So
22
you won't find any real rhythm or chronological
23
sort of system to the way they came in.
24
MR. MUSE: Just for clarification of "this,"
25
there are bates numbers I think that could be
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identified here.
2
MS. SAWYER: Right. So that first document,
3
the one that we've just been talking about, has
4
Bates Nos. 49391 to 41393. Do we need to go off
5
the record for a moment? Let's go off the record
6
for a moment.
7
(A short break was had.)
8
BY MS. SAWYER:
9
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. So was Mr. Steele's kind of
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
A. Yes. I mean, in other cases we did other
18
things.
19
MR. LEVY: Don't get into other cases.
20
BY THE WITNESS:
21
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. So in an
2
ordinary case you would try to gather public
3
records and you would conduct yourself in a much
4
more open fashion.
5
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. You can pull records for companies and
10
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. Did you take steps to verify any of
20
the information?
21
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. There's other secondary
25
questions that would follow on from that, can it
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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. So the one thing
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. So
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. That would include people from the U.S.
22
government.
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. And in that episode it was eventually
23
dug out by congressional investigations that the
24
fundraisers, the Asian fundraisers were Chinese
25
intelligence assets. 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. So I
4
knew all of that while reading this and digesting
5
it for the first time.
6
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. So I knew all that when I read this.
24
Q. Okay. So if I can stop you there. It
25
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
A. I covered that. I also would add that the
9
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. So all of
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. Who specifically was
8
that?
9
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. He's extremely close to
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.
19
Q. And you had also mentioned your background
20
knowledge of Paul Manafort and his involvement with
21
Russian oligarchs. Can you identify who those
22
individuals were and the basis of that knowledge?
23
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
Q. Was that work you had done while still a
7
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
A. My articles about this are available on
17
the Internet.
18
MR. LEVY: Some of them we've produced to you
19
already because it was responsive to your request.
20
MS. SAWYER: Understood.
21
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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Q. Let's start with the Wall Street
2
Journal?
3
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. It does talk about
11
potential -- as it's called in here, a dossier of
12
compromising material on Hillary Clinton. Did you
13
take any steps to verify whether that dossier of
14
compromising material existed on Hillary Clinton?
15
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. I mean, you know, I
8
think that also -- of course, in retrospect we now
9
know this was pretty right on target in terms on
10
what it says. So anyway --
11
Q. In reference to you think that particular
12
sentence?
13
A. I mean, it clearly refers to, you know,
14
them being interested in and willing to -- it
15
depicts them as accepting information. What we
16
have seen to date with the disclosures this year is
17
they were at a minimum super interested in getting
18
information.
19
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
Tower meeting?
25
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. You were
11
actually clarifying a statement I made, which I
12
appreciate.
13
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. Had you -- were you involved in
18
editing this memo in any way?
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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to engage in an open-ended research project?
2
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. It was take a
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. So it was a short-term engagement in
9
the beginning.
10
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. It appears to
8
be -- it's three pages and it has a date of 26 July
9
2015 and it has "Company Intelligence Report
10
2016/086." To the best of your recollection, was
11
this the second memo you had received from
12
Mr. Steele?
13
A. To the best of my recollection, this is
14
the second memo.
15
Q. And how did you kind of use this
16
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. I think -- what is the date again? Yeah,
22
it's 26 July. So by this time Debbie Wasserman
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.
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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. You know, after the first memo, you know,
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. He thought from his
23
perspective there was an issue -- a security issue
24
about whether a presidential candidate was being
25
blackmailed. 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. Then he raised it
9
again with me. 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. In any event, he said don't worry about
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. I said okay. You know, I
19
agreed, it's potentially a crime in progress. So,
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
Q. Okay. So let me just stop you there and
23
let's just make sure we get the sequencing
24
accurate.
25
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. I mean, that's the
15
only ones I remember, the two of us. The only ones
16
I know of.
17
Q. You said you had asked for some time to
18
think it over. What in particular did he
19
articulate to you was of significant national
20
security concern to indicate that it should be
21
taken to the FBI?
22
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. And the whole problem of
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. So, you know, a trained intelligence
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
a significant national security issue.
11
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. It was that I didn't feel
14
qualified to be the arbitrar of whether this is a
15
national security expert. He's the pro and I'm the
16
ex-journalist.
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. I know a lot about politics, I know
22
a good bit about financial crime, but, you know, my
23
specialty was journalism and his was security.
24
Q. And with specific regard to the issue of
25
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. As I say, I don't have really
8
any additional information beyond this except
9
that -- I mean, it's probably in here somewhere
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. So the problem of kompromat and
15
kompromating is just endemic to east-west
16
intelligence work. So that's what I'm referring
17
to. That's what he's referring to.
18
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
of who or what FSB is?
24
A. It's a successor to the KGB. I mean,
25
nominally it's the domestic intelligence agency on
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the domestic side of what was the KGB. In practice
2
it's sort of the preeminent intelligence organ of
3
the Russian state, government.
4
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
A. I believe it was sometime around the turn
9
of the month. It would have been in late June or
10
at latest early July. That's my recollection.
11
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. This was -- to me this was
17
like, you know, you're driving to work and you see
18
something happen and you call 911, right. It
19
wasn't part of the -- it wasn't like we were trying
20
to figure out who should do it. He said he was
21
professionally obligated to do it. Like if you're
22
a lawyer and, you know, you find out about a crime,
23
in a lot of countries you must report that. So it
24
was like that. So I just said if that's your
25
obligation, then you should fulfill your
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obligation.
2
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
first conversation actually then took place?
8
A. Over the last several months that this has
9
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
Q. And that information about that time, that
14
first week of July, where does that come from?
15
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. So when an incorrect
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
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provide you.
2
Q. And do you know who it is that Mr. Steele
3
contacted and talked with at the FBI?
4
A. I did not know at the time. I believe I
5
know now, but I don't have authoritative
6
information on that. I didn't -- yeah. I didn't
7
know who it was in July.
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. It was after the
15
election.
16
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
the FBI.
22
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. You had indicated that it was
3
just the two of you having those conversations and
4
coming to that decision. Once the decision was
5
made, did you share that decision with anyone, that
6
he was going to go to the FBI with this
7
information?
8
A. I think we're not able to answer that.
9
MR. LEVY: He's going to decline to answer
10
that question.
11
BY MS. SAWYER:
12
Q. Did you seek anyone else's approval for
13
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: Beyond what he's said already?
7
MS. SAWYER: Yes.
8
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. I can talk generally about the FBI and what
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. There's no
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ask.
2
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. He's not
8
dealt with in this memo, but he's dealt with in the
9
later memos. I don't know there's any connection
10
between these events. I do know in Director
11
Comey's testimony he said -- I'm sorry. Maybe I'm
12
skipping ahead. As far as I know, they didn't -- I
13
don't know what they did.
14
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
when he would take information to the FBI?
21
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. He's a
9
campaign advisor and he gives a speech about
10
dropping sanctions. Trump continues to say
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. So that was
15
basically the state of things through September
16
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. He did.
21
Q. So can you explain the next incident where
22
you know that Mr. Steele met with the FBI?
23
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. I
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. But there wasn't much debate that they
10
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. He went
25
to Rome. Then afterwards he came back and said,
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you know, I gave them a full briefing.
2
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. I didn't ask who
15
he met with, I didn't ask, you know, much of
16
anything, but he did tell me that he gave --
17
Q. Before we get to that, which I do want to
18
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
knowledge, take place?
25
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. So I just was curious
13
whether he'd heard back.
14
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. That's a
19
computer crime.
20
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. He may have conferred with his
6
business associates, but I don't know.
7
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. Do you otherwise know who he met
10
with?
11
A. This gets into the chronology of what I
12
learned when. At some point I learned that he was
13
meeting with the lead FBI guy from Rome. I don't
14
remember when he told me that.
15
Q. And did you have a name associated with
16
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. You know, my
24
understanding was that they would have gotten into
25
who his sources were, how he knew certain things,
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and, you know, other details based on their own
2
intelligence. Essentially what he told me was they
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
source from inside the Trump organization.
11
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
MR. LEVY: He's going to decline to answer
15
that question.
16
MS. SAWYER: On what basis?
17
MR. SIMPSON: Security.
18
MR. LEVY: Security.
19
BY THE WITNESS:
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. There are some things
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
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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: I'm having a hard time hearing
19
you. Please speak up.
20
BY THE WITNESS:
21
A. It was someone like us who decided to pick
22
up the phone and report something.
23
Q. And your understanding of this, does that
24
come from Mr. Steele or from a different source?
25
A. That comes from Chris, yes.
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Q. And when did he share that information
2
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. He did say they asked him for -- they wanted
14
to know everything he had, but whether that would
15
include getting paper I don't know.
16
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
in Rome?
25
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. So, you know, we began getting questions from
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. You know, I
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.
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. So he stopped dealing with
8
them.
9
Q. Okay. 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. Can I just ask you a general question
12
on the memos that we were talking about. I had
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?
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
receiving from Mr. Steele?
23
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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him, that kind of thing.
2
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. So our hour is up. If you'll just
9
give me a moment.
10
Okay. So we'll go ahead and go off the
11
record. It is 2:58.
12
(A short break was had.)
13
MR. DAVIS: We'll go back on the record.
14
It's now 3:09.
15
EXAMINATION
16
BY MR. DAVIS:
17
Q. Mr. Simpson, do you know Emin Agalarov,
18
E-M-I-N, A-G-A-L-A-R-O-V?
19
MR. LEVY: Personally or just does he know
20
about him?
21
MR. DAVIS: Personally.
22
BY THE WITNESS:
23
A. No.
24
Q. Do you know Aras, A-R-A-S, Agalarov?
25
A. No.
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Q. Has Fusion ever worked with either of
2
them?
3
A. No.
4
Q. To the best of your knowledge, have
5
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: 2016.
21
MR. DAVIS: 2016. Excuse me.
22
BY THE WITNESS:
23
A. The Baker lawyers would have attended, did
24
attend.
25
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. I don't
3
specifically remember if he was at the other
4
dinner. I don't have many memory of the other
5
dinner.
6
Q. Do you recall if he was at the court
7
hearing on the 9th?
8
A. I believe he was. I'm not certain of it.
9
The other person would have been a translator at
10
some of these dinners. I can't remember which
11
ones.
12
Q. Were there any other individuals there
13
involved with HRAGI or Prevezon work beyond the
14
people you've mentioned?
15
MR. LEVY: When you say "there," you're
16
talking about now?
17
MR. DAVIS: You're right. At the hearing.
18
BY THE WITNESS:
19
A. The hearing. Before you were asking about
20
the dinners, right?
21
Q. I was.
22
A. Now you're asking about the hearing. I
23
just want to be clear. Well, it was a crowded
24
hearing and there may have been other people
25
involved. 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. There was
4
some other people who I think were also from Baker
5
Hostetler who were there. Former Attorney General
6
Mukasey was arguing for Prevezon. So I just
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.
10
There was another associate I think from New York
11
who was there, usually came to some of the Court
12
hearings. That's all I remember.
13
Q. And the first dinner on the 8th were there
14
any other attendees?
15
A. I don't remember. I think John Moscow
16
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. Did you have any
25
expectation that that would reasonably result in
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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. So if they want me to
7
provide it to somebody else, it's their
8
information. So I would -- it's a fairly
9
ministerial thing. I'm not sure I would have an
10
expectation of any sort of specific result from
11
that.
12
Q. But you did understand HRAGI to be
13
lobbying on the Hill?
14
A. They were registered to lobby on the Hill.
15
So I believe that's what they were doing, yeah.
16
Q. And did you understand that your actions
17
on behalf of Prevezon or Baker Hostetler would
18
principally benefit the Russian government? Who
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. You can answer.
23
MR. MUSE: He's trying to contain his
24
laughter.
25
BY THE WITNESS:
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A. We did not believe that was being done on
2
behalf of the Russian government.
3
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. To some extent
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
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. I don't remember the exact
4
specifics of our discussions of these matters, but
5
one of the issues was whether he's a legitimate
6
businessman.
7
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
MR. LEVY: We can give you that information
4
at the end of the interview.
5
MR. DAVIS: Why at the end of the interview?
6
MR. LEVY: 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. We'll
9
be happy to cooperate with the committee and give
10
the names of those people. I just want to do it
11
outside of this transcript, unless you're going to
12
assure me the transcript is going to be kept
13
confidential.
14
MR. FOSTER: Let's go back to the previous
15
question. What was the previous question?
16
MR. DAVIS: Whether he'd already started
17
working with Mr. Steele during the time of the --
18
MR. FOSTER: During the time of the meetings
19
in early June, right? And your answer was?
20
MR. SIMPSON: I don't know.
21
MR. FOSTER: Do you have -- you said you
22
don't handle those issues at the company.
23
MR. SIMPSON: That's right.
24
MR. FOSTER: So your company does have
25
records that would establish that fact?
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MR. SIMPSON: We keep books and records. We
2
should have records of agreements and things, yeah.
3
MR. FOSTER: So did you not review any of
4
those in preparation for today?
5
MR. LEVY: What he reviewed is privileged.
6
MR. FOSTER: Have you reviewed them -- I'm
7
not asking if you reviewed them with counsel. Have
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
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: I'm just asking what he knows.
17
MR. LEVY: I think he's told you. Go ahead.
18
MR. SIMPSON: I'll just restate that we run
19
a -- it's a reasonably well-run company, we keep
20
books and records. So, you know, those kinds of
21
things are kept in our corporate files.
22
BY MR. DAVIS:
23
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: The meetings?
2
MR. DAVIS: The dinner after the hearing.
3
BY THE WITNESS:
4
A. The purpose of the trip was the hearing.
5
It was routine for me to attend hearings. So I
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. I don't know if -- I don't know for a fact
10
that we billed them.
11
Q. Did you travel with any other members of
12
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
Q. Can you clarify the time frame for when it
25
was winding down?
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MR. LEVY: Talk about what the "it" was when
2
you say "it."
3
BY THE WITNESS:
4
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. Then nothing happened after that and
11
that was, you know, sort of the peak of that. It
12
was after that that a lot of the issues involving
13
Russia and the campaign started to heat up.
14
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. Various people
20
specialize in certain things and can contribute
21
ad hoc to something.
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
Q. And had Fusion been paid by him or Orbis
11
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: Could you repeat that?
17
MR. DAVIS: 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
Business Intelligence?
18
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? Did you have phone calls
6
and e-mails with him?
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. E-mail security is a
11
major problem. So, generally speaking, we would
12
try to communicate telephonically on an encrypted
13
line.
14
MR. FOSTER: Did you have another method of
15
communicating with him via text.
16
MR. SIMPSON: I mean, we used encrypted
17
methods of communicating. Part of the security
18
concern we have involve there's been a lot of
19
attempts to break into our systems. So I prefer
20
not to get into a lot of that, but suffice to say
21
we use secured encrypted systems.
22
MR. FOSTER: 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: Generally not.
2
MR. FOSTER: You have not retained?
3
MR. SIMPSON: Generally we use things that
4
can't be stolen because they no longer exist.
5
MR. FOSTER: Disappearing messages, auto
6
deleting messages? Is that correct?
7
MR. SIMPSON: That sort of thing, yes, that's
8
correct.
9
MR. FOSTER: I just needed a verbal answer.
10
MR. SIMPSON: Yeah. Sorry.
11
BY MR. DAVIS:
12
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. Did
17
you collaborate with Mr. Steele on the content of
18
the memos even if he did the drafting?
19
A. No, generally speaking. 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. Were those other
25
subcontractors retained until the election or how
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long did their engagements last?
2
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. If
5
there's no more to do, stop. So it's hard to
6
generalize.
7
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. Do you know which is the accurate --
13
MR. LEVY: He's not going to get into the
14
details of that source.
15
MR. DAVIS: I'm not asking for any particular
16
details. It was characterized differently by you
17
and by counsel. I just wanted to make sure.
18
BY THE WITNESS:
19
A. I don't know.
20
MR. FOSTER: So you don't know whether it was
21
the organization or the campaign, in other words?
22
MR. SIMPSON: That's correct.
23
MR. FOSTER: Meaning the business versus the
24
campaign.
25
BY MR. DAVIS:
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Q. And did Mr. Steele tell you that the FBI
2
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: I thought you said earlier that
7
he did say the FBI told him.
8
MR. SIMPSON: I think I was saying we did not
9
have the detailed conversations where he would
10
debrief me on his discussions with the FBI. He
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. He
14
wouldn't put words in their mouth.
15
(Exhibit 4 was marked for
16
identification.)
17
BY MR. DAVIS:
18
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. This will be Exhibit 4. If you could
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
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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." Is that a correct description of
4
your understanding of how the material was to be
5
treated?
6
MR. MUSE: There's also a context to that who
7
the Defendants are in other such matters.
8
MR. DAVIS: Sure. The Defendants are Orbis
9
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
Q. Was that expectation established by
22
contract?
23
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. He's pretty good at sticking to
5
that and so am I.
6
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. It's just simply a point
2
of reference by you, but it doesn't add anything to
3
what he might be saying. So I think the better way
4
to get at it is simply to ask direct questions.
5
MR. DAVIS: There are two parties to this, at
6
least, and we've got one's description. I'd like
7
to know if he agrees with that description.
8
MR. MUSE: But even within what do they mean
9
by this is the question. I mean, what do they mean
10
by this sort of paragraph. You're asking him for
11
an interpretation. He can answer questions about
12
the relationship.
13
MR. DAVIS: I'm asking him to give an
14
interpretation of their agreement in terms of what
15
he did.
16
MR. MUSE: And therein lies the problem.
17
MR. DAVIS: But if it's an agreement to which
18
he's a party, there's a basis for that
19
understanding.
20
MR. MUSE: I don't think that's the way the
21
rule works.
22
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. So we're asking him for his understanding of
6
what obligations he had.
7
MR. LEVY: And that's outside the scope of
8
this interview. Go ahead.
9
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: Will do.
13
MR. FOSTER: The record will reflect we are
14
not raising our voices.
15
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. That said,
24
I've now forgotten what the pending question was.
25
So if Patrick wants to restate it he can and we can
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evaluate it.
2
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." I don't know what
22
they're referring to. Maybe you do. Can you show
23
us that?
24
MR. DAVIS: I don't have that with me at the
25
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
A. I'm not sure I can answer this in -- I'm
5
not sure I know the answer to this.
6
MR. LEVY: If you don't know, then...
7
MR. SIMPSON: It's a little confusing.
8
MR. FOSTER: You don't know whether or not
9
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: What I'm saying is we discussed
24
that. No. 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. We worked
8
together. Sometimes he's working for my clients,
9
sometimes I'm working for his. 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. So
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
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. Some of what we
23
discussed was informed by Chris's reporting. So
24
whether that was -- I don't think there's any sense
25
that that was an unauthorized thing to do.
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MR. DAVIS: On page 5 --
2
MR. FOSTER: Is it something that you
3
discussed with him that you were doing?
4
MR. SIMPSON: We would discuss inquiries that
5
we had received from reporters, yes.
6
MR. FOSTER: And that you were answering?
7
MR. SIMPSON: To the best of our ability. I
8
mean, we obviously didn't tell people about the
9
existence of these things for a long time.
10
BY MR. DAVIS:
11
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. I think this is relevant for
15
context. There's a portion here in which Steele's
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." I'd like to provide
20
Exhibit 5 which is the second filing by
21
Mr. Steele's attorneys.
22
MS. SAWYER: Patrick, you've represented this
23
one as the second filing. Are we sure these are --
24
MR. DAVIS: Second for the purpose of this
25
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: These were documents that were
5
published in the media. I believe the second one
6
was published by McClatchy.
7
MS. SAWYER: And what about the first?
8
MR. DAVIS: That was the one published by the
9
Washington Times.
10
(Exhibit 5 was marked for
11
identification.)
12
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. The second
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. In each of those
25
cases the briefing was conducted verbally in
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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. No copies of the pre-election memoranda
5
were ever shown or provided to any journalist by or
6
with the authorization of the Defendants. The
7
briefings involved the disclosure of limited
8
intelligence regarding indications of Russian
9
interference in the U.S. election process and 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: Just say what you know or recall.
20
BY THE WITNESS:
21
A. Yeah. I think there's at least one thing
22
misidentified. There might have been another. I
23
can't specifically think of it, but I think this is
24
incomplete, that maybe one of the broadcast
25
networks is misidentified. I just don't have a
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tally of this. It's mostly right.
2
Q. By broadcast network I assume you mean CNN
3
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: We can give that to you
14
afterwards.
15
BY MR. DAVIS:
16
Q. Do you recall the specific dates of these
17
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. I didn't hear.
8
A. He never said they told him he couldn't
9
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: Sorry. Confidential what?
22
MR. LEVY: 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: What's the privilege?
2
MR. LEVY: First amendment, confidentiality.
3
MR. FOSTER: 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. We can discuss it
8
later after the interview.
9
BY MR. DAVIS:
10
Q. Mr. Steele's filing indicates that these
11
meetings occurred at Fusion's instruction. Is that
12
correct, did you initiate these meetings and
13
instruct Mr. Steele to participate in them?
14
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. To the
23
extent -- I mean, I'm sorry. Could you be clear.
24
You mean the project overall?
25
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
Q. Did your client instruct you to have these
9
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? Can you
19
be more specific?
20
Q. Sure. Let's start without you
21
participating. The filing references meetings that
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: 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. So he's going
14
to decline to answer that question.
15
MR. FOSTER: Doesn't the filing say that they
16
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. He's given you a lot of information
22
today. He's not going to answer that question.
23
BY MR. DAVIS:
24
Q. Still with Exhibit 5 on page 2, the
25
responses to 4 and 6. Here the attorneys for Orbis
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and Mr. Steele --
2
MR. LEVY: Where are you again?
3
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
A. Where are you? You're on page 2 -- okay.
13
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
Q. Do you believe this filing is accurate in
10
those paragraphs?
11
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. Was Fusion
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: When you say "paying," what do you
10
mean by that?
11
MR. DAVIS: Providing money.
12
MR. LEVY: For a fee? Are you talking about
13
reimbursements?
14
MR. DAVIS: Fees or reimbursements in this
15
context.
16
BY THE WITNESS:
17
A. We've learned that. We know that now. In
18
fact, it was --
19
MR. LEVY: Learned what?
20
BY THE WITNESS:
21
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
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? In other words, you learned it from him
8
not from the news; is that right?
9
MR. LEVY: Wait. You asked two different
10
questions. I'm trying to figure out which one you
11
want him to answer.
12
MR. FOSTER: The last one.
13
MR. LEVY: What was the last one?
14
MR. FOSTER: You learned it from the news and
15
not from him? Are you saying you learned it from
16
him?
17
MR. LEVY: Learned what from him?
18
MR. FOSTER: That he discussed with the FBI
19
having the FBI pay Mr. Steele.
20
MR. SIMPSON: I don't remember.
21
MR. LEVY: The witness is yawning. Let's
22
take a break.
23
MR. MUSE: We will attribute that to fatigue
24
as opposed to the questions.
25
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: We'll go back on the record.
4
It's now 4:05. We'll continue with the questions.
5
BY MR. DAVIS:
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? No, no one from Fusion
12
ever spoke with the FBI, to the best of my
13
knowledge.
14
Q. Did you ever exchange any e-mails with
15
them?
16
A. We did not communicate with them by e-mail
17
either.
18
Q. Do you know any current or former FBI
19
personnel?
20
MR. LEVY: As a general matter?
21
MR. DAVIS: Yeah, as a general matter.
22
BY THE WITNESS:
23
A. As a general matter I'm sure I do. I know
24
current and former law enforcement officials. I go
25
to a lot of crime conferences and things like
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that.
2
Q. Were any of them consulted as part of this
3
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
A. No.
10
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
4 and 5. I just want to reference two things.
22
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. In Exhibit 5 on
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
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. If Chris
21
specifically said something to me about showing
22
this to one of his government officials I don't
23
remember it. So...
24
MR. LEVY: Why don't you walk them through.
25
BY THE WITNESS:
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A. If you want to know the rest of the story,
2
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. Initially we didn't do
12
anything other than to discuss our concerns, but we
13
were gravely concerned.
14
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. I don't remember whether Andrew
2
Wood's name was specifically given to me by
3
Christopher Steele at that time. It was later
4
given to me. It later became an accepted fact that
5
Chris had mentioned him to me. I believe he
6
probably mentioned it.
7
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. David Kramer is part of a small group of
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. So we shared this concern
23
going back to when I was at the Wall Street Journal
24
and that's how I met David. He was working at the
25
State Department as assistant secretary for human
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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. So he said, well, can
8
we trust him? And I said yes, I think we can trust
9
him. 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. That was essentially -- all we sort of
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. We simply just
17
didn't know. It was our belief that Director Comey
18
if he was aware -- if he was made aware of this
19
information would treat it seriously.
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. Well, he was here, I
2
met with him, and I told him what happened. Now
3
he's back in Washington and, you know, I'm going to
4
hand him to you.
5
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
Q. And after you met how did he -- did you
9
provide the memoranda to --
10
MR. LEVY: Sorry. Finish your question.
11
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. So he's
15
going to decline to answer the question.
16
BY MR. DAVIS:
17
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. Anyway, he did not describe
24
this as having been initiated by Orbis. He
25
described this as a chance encounter at a security
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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. In other words, it was initiated by
6
Mr. Kramer.
7
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
A. That's the first time I've received that
17
information. So I don't have any knowledge.
18
Q. And you haven't spoken with Mr. Akhmetshin
19
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: Anyone we've left out.
2
MR. LEVY: The answer to that might implicate
3
privilege or other obligations. So he's going to
4
decline to answer the question.
5
BY MR. DAVIS:
6
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
A. I'm not sure I see how I could answer that
11
question without getting into privileged areas.
12
MR. FOSTER: Again, what privilege?
13
MR. LEVY: We can discuss it at the end.
14
It's a voluntary interview. He's declining to
15
answer that.
16
BY MR. DAVIS:
17
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
A. I don't believe so, certainly not
22
knowingly.
23
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. There are parts of the memos that
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
Q. Do you know who paid for Mr. Steele's trip
8
to Rome to meet with the FBI?
9
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. He was, to my knowledge, not been
13
compensated for that work or any other work during
14
this time.
15
MR. FOSTER: I'm sorry. You're saying that
16
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. So it
25
makes sense to me that he was reimbursed by them,
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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. So that wouldn't have anything to do with my
11
client's goals or project.
12
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
MR. LEVY: Can you repeat the question.
25
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: I think my hour is up.
8
MR. FOSTER: Off the record at 4:21.
9
(A short break was had.)
10
MS. SAWYER: We'll go back on the record.
11
It's 4:30.
12
EXAMINATION
13
BY MS. SAWYER:
14
Q. I wanted to return to our conversation
15
about interactions that Mr. Steele had with the
16
FBI. We had been talking about a second time he
17
met in Rome. Besides that meeting and the first
18
meeting in early July, are you aware of any other
19
meetings or conversations that Mr. Steele had with
20
the FBI?
21
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. I'm sorry to be vague, but we just
25
didn't understand what was going on and he said he
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had broken off with them.
2
Q. When you say "we" did not understand what
3
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. I remember discussing it with
7
many people, but this conversation was between the
8
two of us.
9
Q. And what was the time frame of when Steele
10
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
MS. QUINT: Because it wasn't consistent with
21
your understanding of the investigation?
22
MR. SIMPSON: Exactly.
23
BY MS. SAWYER:
24
Q. And I think, just to be clear, this was an
25
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. I
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'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. So there was, you know, a lot of open
6
source public information pointing towards the
7
possibility that the Russians had infiltrated the
8
Trump campaign. So we spoke broadly to reporters
9
and encouraged them to look into this.
10
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. What did you understand that to mean?
19
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
A. The first contact was initiated by Chris
6
to someone that he said he knew.
7
Q. And now you're just going back to the July
8
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. I
25
believe he also mentioned that they didn't like
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media coverage, that there was media coverage of,
2
you know, FBI interest in Donald Trump. I don't
3
know what it was that they didn't like.
4
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. We talked about the first memo
18
and we also talked about the second memo to some
19
degree. You were explaining to me why you believed
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. I think
24
you had mentioned -- that's when you mentioned
25
Debbie Wasserman Schultz.
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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
second.
5
Q. Sure.
6
(Reviewing document.)
7
BY THE WITNESS:
8
A. Most of this I did not seek to
9
independently verify and was relatively new
10
information. I was aware at the time of
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
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. I
25
don't remember who that was, but I was told that by
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an American. And issues of Russian criminal
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. There's been a great deal -- there
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
Q. And this memo which is dated 26 July -- it
9
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. This one has the title "Russia/U.S.
20
Presidential Election, Further Indications of
21
Extensive Conspiracy Between Trump's Campaign Team
22
and the Kremlin."
23
Did you do any independent verification of
24
these facts?
25
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. So I can't talk about this as a
4
verification, but I was analyzing this.
5
MR. FOSTER: Speak up, please.
6
BY THE WITNESS:
7
A. I analyzed this information in the same
8
manner I analyzed the other stuff.
9
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. So the
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
But in any event, what I would loosely call
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the Carter Page memo came before this conspiracy
2
memo. So with that caveat I can say we were
3
investigating just based on open sources and, you
4
know, other methods, more public information Carter
5
Page's trip to Russia. We watched tapes of it, we
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
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. And, in fact, you know, to my
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
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. I, you know, independently
24
verified he does have a deputy who's very obscure
25
named Igor Divyekin. It's spelled two different
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ways here. I believe the correct spelling is
2
D-I-V-Y-E-K-I-N.
3
MR. MUSE: Can you give the Bates number of
4
the document you're looking at.
5
MR. SIMPSON: This one is 41399.
6
BY MS. SAWYER:
7
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. A lot of this is
5
human intelligence, it's not the kind of thing that
6
you would share with almost anyone basically. A
7
lot of the work that we do is public record
8
research. Generally speaking, most of this
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. So our reports are
13
full of footnotes and appendices and court records
14
and that sort of thing.
15
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. So when it comes
21
to Paul Manafort, he's a long-time U.S. political
22
figure about whom I know a lot. But his
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
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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. So these are relatively
8
straightforward recitations of things that people
9
have said. 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. I'm telling you that I don't
23
believe this is disinformation.
24
Q. And then on the memo, the Carter Page
25
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. I haven't looked for it. I
7
don't know.
8
Q. You also specifically mentioned Igor
9
Sechin and maybe work that you had done research
10
into Sechin. Is that work that you would also
11
still have?
12
A. I don't know if I have anything specific
13
on Sechin. Sechin is a well-known character. I
14
collect, you know, research on various people who
15
are oligarchs or mafia figures. I don't think I
16
have any specific reports on Sechin, but I know a
17
lot about him. He's, you know, sort of Putin's
18
No. 1 compadre in the kleptocracy.
19
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. He was on the younger
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. That was the general sense we had. He
7
was also, you know, from early on described as
8
somewhat eccentric.
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? Now I'm speaking of Carter Page.
13
A. Well, the definition of compromised is
14
someone who has been influenced sometimes without
15
even their knowledge. We had reason to believe
16
that he had, in fact, been offered business deals
17
that were -- that would tend to influence him,
18
business arrangements.
19
Q. And do you have the records of those
20
business deals that you had collected?
21
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
Q. And then just the next memo that we had
25
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. Just
6
by the numbers it would appear to maybe have come
7
between those two. Does it seem logical that it
8
came sometime between July 19th and July 30th?
9
A. That seems logical.
10
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
MR. LEVY: Beyond what he said as a general
14
matter?
15
MR. MUSE: I'm sorry. You were going back
16
and forth. Which one in particular?
17
MS. SAWYER: This is memo No. -- it has
18
Company Intelligence Report 2016/095, it's Bates
19
numbers 41397 and 41398.
20
MR. MUSE: Thank you.
21
BY MS. SAWYER:
22
Q. Was there particular information in this
23
memo that you did verify?
24
A. One of the things I did, which is pretty
25
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. I'm not saying they did anything illegal.
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
There's all this money flowing in the United
21
States from Russia, it probably flows in under some
22
sort of diplomatic status. So if there's sanctions
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
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United States for whatever purpose, for some kind
2
of illicit purpose. I think that's a pretty good
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
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. Who
10
specifically are you referring to?
11
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
(Reviewing document.)
23
BY THE WITNESS:
24
A. I don't have a clear recollection of this.
25
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
MR. LEVY: Counsel has the request.
8
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. Again, when you take a look at
13
that, was there anything that you independently
14
verified that comes out of this memo?
15
(Reviewing document.)
16
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? It mentions Sergei Ivanov, Dmitry Peskov.
23
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: No. I appreciate the
7
clarification.
8
BY MS. SAWYER:
9
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. So in the course of
8
saying who is this Ivanov guy, you know, we looked
9
at Ivanov and found journal articles and other
10
public information about his long history of
11
intelligence. He's a veteran of the FSB, his long
12
history with Vladimir Putin, and his role atop this
13
internal operation.
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. So that would
19
have given me comfort that whoever Chris is talking
20
to they know what they're talking about.
21
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
BY MS. SAWYER:
11
Q. And do you know whether he shared his
12
sources with the FBI?
13
A. I don't. I don't know.
14
MR. FOSTER: What was the answer?
15
MR. SIMPSON: Sorry. I don't know whether he
16
shared his sourcing with the FBI.
17
MS. SAWYER: Can we just take a minute. We
18
can go off the record for a minute.
19
(A short break was had.)
20
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: Heather, may I make a suggestion?
8
MS. SAWYER: Sure.
9
MR. MUSE: 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. The difficulty is in summary questions
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
MS. SAWYER: I understand where you're going.
19
So yeah. I don't want to put us in a position
20
where --
21
MR. LEVY: Let's just take some time for the
22
witness to review the document.
23
MS. SAWYER: Why don't you take a little bit
24
of time.
25
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. Why
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: We'll go off the record at 5:11.
7
(A short break was had.)
8
MS. SAWYER: We're back on the record at
9
5:20.
10
BY MS. SAWYER:
11
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. When you would get the memos you
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. I think you already told me that you
19
don't recall at the time anything jumping out at
20
you as patently inaccurate; is that fair to say?
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
MR. LEVY: When you say "amplified the work
5
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. So over the years I just have a lot of
17
residual knowledge of some of the people and
18
subjects that are covered in the memos.
19
Q. Okay. So nothing certainly jumped out at
20
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. Were you still -- at the time that
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
A. It occurred after the engagement had
18
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. As a
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. I'd just add that she doesn't speak much
8
English. So the possibilities are almost none. I
9
didn't discuss it with her.
10
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
A. Do I have any reason to believe that he
4
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
but I have no reason to think he would have.
8
Q. And if he had discussed it, would that
9
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. Did that
17
topic just never come up during those three days?
18
A. It never came up. I don't know what else
19
to say. It never came up.
20
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
A. I didn't have any idea about that meeting
24
until quite recently.
25
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." What is
6
your response to that statement?
7
A. It's not true?
8
Q. And what in particular is not true about
9
it?
10
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. She's
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.
16
Most importantly the allegation that we were
17
working for the Russian government then or ever is
18
simply not true. I don't know what to say. It's
19
political rhetoric to call the dossier phoney. The
20
memos are field reports of real interviews that
21
Chris's network conducted and there's nothing
22
phoney about it. We can argue about what's prudent
23
and what's not, but it's not a fabrication.
24
Q. And I think you've already answered you
25
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. We run a
3
commercial business, we're all ex-journalists. We
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
Q. To the extent there have been allegations
9
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: I think my time is up for this
21
round. So I appreciate your patience and we'll
22
take a break.
23
MR. FOSTER: It's 5:34.
24
(A short break was had.)
25
MR. DAVIS: We'll go back on the record.
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It's 5:43 p.m.
2
EXAMINATION
3
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: Beyond what he's discussed today?
10
MR. DAVIS: Yes.
11
BY THE WITNESS:
12
A. I took the train to New York. I don't
13
recall, but I may have had other business. I don't
14
remember. I think there was a dinner. I went back
15
to my hotel, went to bed. Got up the next morning.
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. I think that's what it was
20
about. It might have been about the press coverage
21
of the hearing. I just don't remember. I went to
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. 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
in D.C.?
5
A. I don't think that was my first day back.
6
I was back the evening of the 9th.
7
Q. Sorry. The first full day.
8
A. I think it was a weekend. So I don't know
9
what I was doing. 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. I brought my wife, other people brought
13
their wives. We talked about books and other other
14
nongermane topics. It was just a social
15
occasion.
16
(Exhibit 6 was marked for
17
identification.)
18
BY MR. DAVIS:
19
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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notes about what meeting?
2
MR. DAVIS: These are the meeting notes from
3
the June 9th meeting at Trump Tower. These are
4
Mr. Manafort's notes or they're contemporaneous.
5
BY THE WITNESS:
6
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. I don't know what the 133 million --
16
MR. FOSTER: Can I interrupt? And you know
17
that from research that you did and provided to --
18
MR. SIMPSON: Yes.
19
MR. LEVY: Let him finish.
20
MR. FOSTER: -- research that you did and
21
provided to Baker Hostetler and their client?
22
MR. SIMPSON: Yes. There was a -- I can
23
elaborate a little bit. As part of the research
24
into how Hermitage Capital worked we looked at
25
various things, their banking relationships, the
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way they structured their investments in Russia. I
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. So one of the things we discovered from
6
that was the likely identities of some of
7
Hermitage's clients.
8
BY MR. DAVIS:
9
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
A. I'm going to -- I can only speculate about
14
some of these things. I mean, sometimes --
15
MR. LEVY: Don't speculate.
16
BY THE WITNESS:
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. "Active
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
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with another foreign policy controversy. "Russian
2
adoptions by American families" I assume is a
3
reference to the adoption issue.
4
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: Can you repeat that question.
14
MR. DAVIS: 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
MR. DAVIS: The parts you do recognize.
24
BY THE WITNESS:
25
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
A. It's a loose term. We don't have a list
11
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. He's a reliable
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: 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
Q. Beyond the memoranda prepared by
25
Mr. Steele, did Fusion create any other work
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product relating to this investigation?
2
MR. LEVY: Which investigation?
3
MR. DAVIS: The investigation into Mr. Trump
4
and his associates.
5
MR. LEVY: In addition to what?
6
MR. DAVIS: Sorry. The investigation into
7
Mr. Trump and his associates.
8
MR. LEVY: I'm sorry. Just repeat the whole
9
question.
10
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: I just want to make sure there's
15
no confusion. It wasn't Fusion that created the
16
memoranda.
17
MR. DAVIS: Right, but it was a subcontractor
18
giving it back to Fusion.
19
MR. LEVY: That's correct.
20
BY MR. DAVIS:
21
Q. With that understanding, did Fusion create
22
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. We
4
summarize those things and try to document, you
5
know, and attach them to the underlying source
6
material.
7
Q. So you create sort of summary memoranda of
8
those documents?
9
A. Yes.
10
Q. Okay. And to whom is that distributed?
11
MR. LEVY: As a general matter?
12
MR. DAVIS: Well, within the course of this
13
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. So he's not going to answer that question.
18
MR. FOSTER: Did you provide work product to
19
your client?
20
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: So wait. You're asking about the
8
version in Exhibit 3?
9
MR. DAVIS: Right.
10
MR. LEVY: And you're asking if the
11
redactions that appear here were delivered to
12
Fusion?
13
MR. DAVIS: Right.
14
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. Okay.
7
MR. FOSTER: But he's asking if you received
8
any other memos that listed the sources?
9
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: I don't want to get into source
16
information.
17
BY MR. DAVIS:
18
Q. Again, I don't want to repeat questions
19
that have been asked, but I don't want to
20
unintentionally omit anything. Did the version
21
provided to the FBI include all source names?
22
A. I don't know that there was a version
23
provided to the FBI.
24
Q. When Mr. Steele first met with the FBI in
25
the summer of 2016 do you know if he provided the
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first memoranda that he created?
2
MR. LEVY: He's already answered that
3
question.
4
BY THE WITNESS:
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: He's answered that question too.
10
BY THE WITNESS:
11
A. I don't know.
12
Q. So I'd like to go back to Exhibit 4, I
13
believe. On page 3, paragraph 18 Mr. Steele's
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
They reiterate this point on Exhibit 5 on
22
page 4. Request 11 asks "Please state whether such
23
intelligence was actively sought by the
24
Defendant" --
25
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." The response they say is "Such
5
intelligence was not actively sought, it was merely
6
received."
7
Did anyone -- are you aware of who sent this
8
unsolicited intelligence to Mr. Steele?
9
A. No.
10
Q. Could you describe his methods of
11
compiling the dossier a little more? I think
12
before you described field interviews. He seems to
13
be talking about unsolicited information coming to
14
him rather than information he sought out?
15
A. I can try. When you're doing field
16
information gathering you have a network of people,
17
sources. It's not like a light switch that you
18
turn on and off, these are people you work with.
19
So they call you and tell you stuff. You know, you
20
don't close the window and stop answering phone
21
calls, you know, when the engagement ends. So I
22
assume this is stuff that came in straggle,
23
whatever you call it.
24
Q. To the best of your knowledge, did
25
Mr. Steele pay any of his sources or subsources in
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the memoranda for information?
2
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. I don't know whether he does or
6
not, but that's not basically how I understand
7
field operations to work. You commission people to
8
gather information for you rather than sort of
9
paying someone for a document or to sit for an
10
interview or something like that. That's not how I
11
understand it works.
12
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. He did not invoice
18
me for any such.
19
Q. Did Mr. Steele ever discuss his opinion of
20
Mr. Trump with you?
21
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
A. I have no idea. I mean, I can't
10
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. We're pulling legal filings and
17
bankruptcies and all sorts of other stuff on all
18
kinds of issues. I was talking about specific
19
lines of inquiry.
20
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: If Mr. Akhmetshin were one of
3
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. Is the "he" --
9
A. Chris Steele.
10
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. So
23
excluding your client and excluding your
24
subcontractors, who else knew that you were doing
25
it?
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MR. SIMPSON: Journalists.
2
MR. FOSTER: In the summer of 2016?
3
MR. SIMPSON: Yes.
4
MR. FOSTER: And they knew that because you
5
were telling them about it?
6
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
MR. FOSTER: And they're aware you're being
16
paid to do that research for a client?
17
MR. SIMPSON: I don't know. Generally that's
18
not an issue.
19
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
MR. LEVY: He answered that question too and
4
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
MR. LEVY: From 2015 through the end of the
16
election?
17
MR. FOSTER: Can you let the witness answer,
18
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. So you wouldn't necessarily intuit exactly
3
what we were doing. Most people are interested in,
4
you know -- they're interested in the story they're
5
working on. So some people will say, hey, I'm
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
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: Did you tell journalists that
20
you had engaged Mr. Steele in the summer of 2016?
21
MR. SIMPSON: I don't specifically remember
22
doing that until the fall.
23
MR. FOSTER: After the election or before?
24
MR. SIMPSON: Before the election.
25
MR. FOSTER: Can you remember the context in
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which you told them that?
2
MR. SIMPSON: Yes.
3
MR. FOSTER: Can you describe it for us,
4
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. So we sat down
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: Do you recall whether that was
19
before or after he ended his relationship with the
20
FBI?
21
MR. SIMPSON: Before.
22
BY MR. DAVIS:
23
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. Did
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
MR. SIMPSON: Yes, but I'm not going to get
13
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
MR. SIMPSON: I'm going to decline to answer
18
that.
19
MR. FOSTER: Why?
20
MR. LEVY: It's a voluntary interview, and in
21
addition to that he wants to be very careful to
22
protect his sources. Somebody's already been
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.
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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: He's given you --
5
MR. FOSTER: If he can answer generally
6
without identifying the sources, I'd ask him to
7
answer.
8
MR. LEVY: He's given you over nine hours of
9
information and he's going to decline to answer
10
this one question.
11
MR. FOSTER: And several others.
12
MR. LEVY: Not many.
13
BY MR. DAVIS:
14
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: Repeat the question.
19
MR. DAVIS: 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: Clients on which project?
4
BY MR. DAVIS:
5
Q. Were any clients on the Trump research not
6
American citizens?
7
A. I don't mind answering that if that's
8
okay. They're domestic clients.
9
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. Is that a fair
18
summary?
19
MR. LEVY: Wait. You said a lot there.
20
Which third parties are you talking about?
21
MR. FOSTER: Well, to law enforcement.
22
MR. LEVY: 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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and he said yes, it's fine for him to do that.
2
MR. FOSTER: Right. I'm trying to summarize
3
the previous answer as a premise to my next
4
question. Is that an accurate summary of what you
5
said before?
6
MR. LEVY: Summarizing testimony is dangerous
7
after he's given nine hours of it. If you want to
8
ask him a question, ask him a question.
9
MR. FOSTER: 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: I don't know.
17
MR. FOSTER: 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. Are you the source for any of those
23
public reports?
24
MR. LEVY: A hundred percent of what you were
25
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. But I have -- if people have
8
accurate information of a general nature like that,
9
I generally would not -- I would confirm things.
10
MR. FOSTER: Sorry. I didn't understand your
11
answer.
12
MR. MUSE: It's quite clear.
13
MR. SIMPSON: Depends on what you say a
14
source is. If someone calls me and say I hear
15
client No. 1 was a Republican, then I'd say I don't
16
have any problem with you writing that. That's not
17
quite the same thing.
18
MR. FOSTER: So you confirm the accuracy of
19
information?
20
MR. LEVY: He didn't say that.
21
MR. SIMPSON: There are certain things that
22
I've chosen not to deny. You know, generally
23
speaking, I deal with a lot of journalists. I'm
24
not going to mislead people.
25
BY MR. DAVIS:
Glenn Simpson
August 22, 2017
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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. As you know, we've agreed to
8
an interview about questions 5 through 13 of the
9
March 24 request. Questions 1 through 4 talk about
10
the identities of the clients. The Chair and the
11
Ranking Member agreed with counsel for Mr. Simpson
12
about the scope of this interview and that question
13
is outside of it. In addition, the answer to that
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
MR. DAVIS: You've asserted attorney-client
19
work product privilege --
20
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. It's
25
a voluntary interview and he's declining to answer
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the question.
2
MR. DAVIS: I understand that.
3
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
MR. LEVY: That's a legal conclusion that
14
he's not qualified to draw.
15
MR. DAVIS: You don't feel that you can speak
16
to it without their permission?
17
MR. LEVY: Speak to what?
18
MR. DAVIS: To questions that would be
19
covered by attorney-client privilege.
20
MR. LEVY: I'm not sure he's qualified to
21
answer that question.
22
BY MR. DAVIS:
23
Q. Did you work with any law firms in
24
relation to the Trump investigation?
25
MR. LEVY: Again, we're not getting into the
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identity of any clients --
2
MR. DAVIS: I didn't say client.
3
MR. LEVY: I understand. Or their lawyers.
4
MR. FOSTER: 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. He's been fully
20
cooperative and he's here because the Chair and the
21
Ranking Member agreed to a limited scope. The
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. Through this agreement
25
we're here. 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. He's answered
3
a ton of questions today and he's going to decline
4
to answer this last one.
5
MR. FOSTER: The last one was did you work
6
with a law firm on the Trump matter?
7
MR. LEVY: He's declining to answer.
8
MR. FOSTER: There were several points in the
9
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. It's been
12
publicly reported that you did opposition research
13
for a client targeting Mr. Romney in the 2012
14
election. Obviously we've been talking about the
15
Trump opposition research. Have you ever done
16
opposition research regarding Mr. Obama?
17
MR. LEVY: We're not going to get into
18
specific client matters that are outside the scope
19
of this interview. He's told you he's represented
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: 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. The record is
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: At the Wall Street Journal?
7
MR. SIMPSON: Yes.
8
BY MR. DAVIS:
9
Q. Are you party to a joint defense agreement
10
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
MR. LEVY: While working for Fusion on a
6
Fusion matter or as a general matter?
7
MR. FOSTER: Can you let the witness answer.
8
MR. LEVY: Well, if the question's clear he
9
can answer any question --
10
MR. FOSTER: I think the question was clear.
11
MR. LEVY: -- within the scope of the
12
interview --
13
MR. DAVIS: Are there any of Fusion's
14
clients offering --
15
THE REPORTER: Guys.
16
BY MR. DAVIS:
17
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: What was the end date of the
23
Trump engagement?
24
MR. LEVY: He told you he didn't recall
25
exactly.
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MR. SIMPSON: That's not correct. The
2
election was the end date. I assume you're asking
3
about the general election? The election date
4
would have been the end.
5
MR. FOSTER: 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
MR. SIMPSON: I had no client after the
9
election.
10
MR. FOSTER: It's 6:21. Let's go off the
11
record for a minute.
12
(A short break was had.)
13
MS. SAWYER: We'll go back on the record.
14
It's 6:30.
15
EXAMINATION
16
BY MS. SAWYER:
17
Q. We appreciate your time today, your
18
patience in answering our questions.
19
You've been asked a number of questions just
20
about -- well, strike that.
21
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. I'm not going to pretend that that wouldn't
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
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
Q. And given that you had been trained not to
9
allow etiology to cloud your work, it sounds like
10
you reached a conclusion and had concerns about
11
Candidate Trump. What steps did you take to then
12
ensure that your conclusion didn't cloud the work
13
that was being done?
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. Most of what we do has to
19
do with do people have integrity and whether
20
they've been involved in illicit activity. So
21
those were the things I focused on.
22
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. In particular one of the things you had
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
A. I think the thing I cited to you was his
19
relationship with organized crime figures, and that
20
was a concern.
21
Q. And what can you share with us about the
22
findings, your findings?
23
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. In
3
fact, you know, there was numerous others that I
4
can't remember the names of. It was a long history
5
of associations with people accused of involvement
6
in criminal activity.
7
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. So I think it would be, you know, not
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. Those were the
16
findings.
17
Q. You mentioned specifically and I think
18
with regard to organized crime particularly ties to
19
Felix Sater is one. You indicated a connection to
20
Yudkovich Mogilebich, I think it is.
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: What's the first name?
2
MR. SIMPSON: Semyon, S-E-M-Y-O-N.
3
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
Q. With regard to any of that work, did you
10
create work product based on that work?
11
A. I don't specifically recall what we would
12
have created.
13
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. Other than that, I
20
don't remember having any dealings with the FBI.
21
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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you investigated and what you learned.
2
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. The name of the bank was
7
BTA Bank. It's been well established in various
8
courts that the government's allegations are
9
basically true, which is that large amounts of
10
money were illicitly removed from this bank,
11
laundered across Europe and into the United States
12
apparently. Allegedly.
13
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. I don't remember exactly how,
17
but we learned that -- it wasn't from Chris. We
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. There's been
22
media reports that the money went into the Trump
23
Soho or it went into the company that built the
24
Trump Soho. I can't remember the name.
25
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
A. Yes. It was a company that Felix Sater
4
and Donald Trump were involved in together.
5
Q. And the research you did on that project,
6
was that public source research? Did you have any
7
other -- did you have human intelligence sources on
8
that project?
9
A. I think I probably did have some human
10
sources. That's my answer.
11
Q. And did you use subcontractors at all on
12
that work?
13
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. I
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?
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A. There were others.
2
MR. LEVY: Beyond what we've discussed today?
3
MS. SAWYER: Yes, beyond what we've already
4
discussed.
5
BY THE WITNESS:
6
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. The first name is
9
generally spelled Tevfik, it's T-E-V-F-I-K. 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. Were these specifically Donald
17
Trump's tax bills?
18
A. They were Trump properties and I believe
19
we may have reviewed some public information about
20
estate taxes and things like that. We didn't have
21
access to his tax returns.
22
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. Did you reach any conclusions with
2
regard to either of those?
3
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. What in particular were you
16
looking into with regard to Donald Trump's golf
17
courses?
18
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
Q. And in general can you share what findings
24
and conclusions you reached?
25
MR. LEVY: With regard to?
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MS. SAWYER: To the work on the golf
2
properties.
3
BY THE WITNESS:
4
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. I
9
don't know if it was particular properties or
10
something with regard to Scotland. Can you just
11
describe what that research was.
12
A. Sure. 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
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. In general and it might not be easy to be
17
general about it, but what was your focus when you
18
had looked into Manafort? What main areas were you
19
familiar with?
20
MR. SIMPSON: 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. He was
24
subject of some litigation over his business
25
dealings in New York. There was a lawsuit filed by
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the opposition politician from Ukraine accusing him
2
of involvement in corruption in Ukraine. So as
3
just a -- not for any particular client, but just
4
because these matters are something I follow I had
5
collected those documents. I think there's
6
probably some other litigation that I collected
7
that was in a similar vein.
8
MS. QUINT: And it was all documentary or did
9
you have human sources for your Manafort research?
10
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. I just wanted to
24
ask you a couple of questions about some of the
25
other individuals that we had identified in that
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letter and in particular in request No. 6?
2
MR. LEVY: Do you have an exhibit or should I
3
just get my copy out?
4
MS. SAWYER: I'm happy to enter it as an
5
exhibit or I can just read the names. I don't
6
think there's any reason we need to --
7
MR. LEVY: Just read the names to move it
8
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. I don't know if they're two distinct
16
entities. Do you know anything about Alpha Bank or
17
Alpha Group with regard to Russian interference in
18
the 2016 election?
19
A. Alpha Group is not a corporate person,
20
it's not an entity. It's just a collective name.
21
Alpha Bank is a bank. I know a limited amount. I
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
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
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Petersburg around the time same that Bill Browder
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was doing business with the mayor's office.
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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. They have epic disputes with
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western corporations, including BP. So people in
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my business tend to just have a lot of
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institutional knowledge about them and, you know, I
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shared my institutional knowledge about them.
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Q. You mentioned other founders. Are those
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other founders Mikhail Fridman and German Khan?
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A. Yes.
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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
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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?
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A. That's kind of an open-ended question. I
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think what I said is we were asked about that and
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it wasn't -- that information wasn't generated by
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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. I
8
don't know what else to say.
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Q. And what information were you given?
10
A. A bunch of data. I mean, we were shown
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like do you know what this would mean, does this
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mean, and it's beyond -- it's really -- it's
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certainly beyond my competence.
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Q. So the data that you were shown, you could
15
not draw any conclusions from it?
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A. I did not draw any conclusions from the
17
data.
18
Q. Another individual that there's been a lot
19
of press reporting on is Sergei Millian. Other
20
than what -- what, if anything, can you tell us
21
about did you conduct any research into
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Mr. Millian? And, if so, what conclusions did you
23
reach with regard to Russian interference in the
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2016 election?
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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. We found a
3
picture of him with Donald Trump and another real
4
estate investor in Florida. We've discovered
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. Speaking generally, people with
9
advanced training in linguistics are oftentimes
10
involved in intelligence matters, but I don't know
11
whether he is or isn't. Various reporters became
12
interested in him because he was boasting about his
13
connections to the Trump organization in the Trump
14
campaign. So we got lots of inquiries about who
15
was he, was he a spy, you know, that sort of thing.
16
Q. And did you make a determination whether
17
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. I'm sorry. It was some social media
21
connection. It was either Twitter friends or
22
Facebook friends. It was public information. We
23
took it from that that they did know each other. I
24
guess we gradually learned of Michael Cohen's role
25
in the Trump campaign as opposed to in the Trump
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organization.
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Q. And what did you learn about Mr. Cohen's
3
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. He seemed to know a lot
8
about that. We learned that he was a very
9
intimidating person who had a history of
10
threatening reporters with libel suits. We learned
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. The only other thing I can think
18
of is that he was also the person who dealt with
19
allegations against Mr. Trump from the tabloids.
20
Q. And with regard to Trump projects with
21
Russian buyers, what specific projects had a number
22
of Russian buyers?
23
A. I don't specifically remember. Florida
24
maybe. I think it was Florida. Sorry.
25
MS. SAWYER: Just give us a minute.
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I think that's really all of our questions.
2
I don't know if there's follow-up that you all had.
3
MR. FOSTER: Just very quickly. I can do it
4
from right here.
5
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
MR. FOSTER: It's relevant to his claim that
17
he's not a Democrat linked firm.
18
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.
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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. Is it
5
fair to say -- is it a fair description to say that
6
your job was opposition research aimed at
7
Mr. Trump? That's been widely reported and
8
characterized that way. Do you think that's a fair
9
characterization of what your job was?
10
MR. LEVY: 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
MR. FOSTER: You weren't hired to find
15
positive information about Mr. Trump, were you?
16
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. So if Donald
19
Trump's got a good business record and he's really
20
worth billions of dollars, that's important
21
information. In fact, you shouldn't be feeding
22
reporters stories about how Donald Trump is not
23
worth billions of dollars if he's worth billions of
24
dollars. So, you know, I think the connotation of
25
negativity, I get, you know, where you're coming
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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. I do my job well and I
6
get rehired when I give them the right information,
7
when I give them accurate information. So if
8
Donald Trump turned out to be a great businessman,
9
that's what I would have to tell people.
10
MR. FOSTER: Nothing further from me.
11
MR. LEVY: Before we go off the record, will
12
we be entitled to a copy of the transcript?
13
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: Your request is noted.
21
MR. LEVY: Noted, but no decision on it?
22
MR. FOSTER: No decision.
23
MR. LEVY: And upon reviewing the transcript,
24
when will we have that opportunity?
25
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
MR. FOSTER: That's why we'd allow you to
6
review it.
7
MR. LEVY: Thank you very much.
8
MR. DAVIS: Nothing further. We're going off
9
the record at 7:04.
10
(Whereupon the interview was
11
concluded at 7:04 p.m.)
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CERTIFICATE OF SHORTHAND REPORTER - NOTARY PUBLIC
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I, TINA M. ALFARO, Certified Shorthand
3
Reporter No. 084-004220, Certified Realtime
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Reporter, and Notary Public in and for the State of
5
Illinois, do hereby certify:
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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.
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I further certify that I am not counsel
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for nor in any way related to any of the parties to
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this suit, nor am I in any way interested in the
13
outcome thereof.
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In witness, whereof, I have hereunto set
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my hand this ____ day of __________,2017.
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_____________________________
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Tina M. Alfaro, CSR, CRR
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