EFiled: Jul 27 2020 10:37AM EDT

Transaction ID 65799719
Case No. S20C-07-030 CAK
IN THE SUPERIOR COURT FOR THE STATE OF DELAWARE

CARTER PAGE, an individual,

Plaintiff,

v. C.A. No.

OATH INC., a corporation,

JURY TRIAL DEMANDED

Defendant.

COMPLAINT

Plaintiff Carter Page (Dr. Page), by and through the undersigned counsel,

brings this action against Oath Inc., for (i) false and defamatory statements published

by its media outlets Yahoo! and the Huffpost, as well as (ii) injuries suffered by Dr.

Page from the tortious interference with prospective business relationships created

by the publication of the false and defamatory statements, and to recover all

categories of damages as allowed by law upon a trial of this matter, and alleges as

follows:

I. INTRODUCTION

This action is brought against multi-billion-dollar media company

Oath, Inc., which negligently published false, and defamatory statements of and

concerning Dr. Page without privilege and published the statements with actual

knowledge of falsity or with a reckless disregard of truth or falsity. Dr. Page is an

1
innocent individual whose entire way of life was shattered as a direct result of being

defamed and falsely branded as a traitor to his country by the Defendant’s media

brands. He was allegedly secretly plotting with Russian leaders to sabotage the 2016

Presidential Election and give “aid and comfort” to Russian President Putin’s efforts

to “weaken” America. Such criminal acts of treason against the United States are

punishable by a death penalty. These false accusations against Dr. Page, a law-

abiding and patriotic former U.S. Navy officer, were devastating: overnight he was

defamed and thrown onto the world stage as a traitor.

Since the defamatory statements were published within weeks of the

2016 U.S. Presidential Election, and contained lurid and sensational alleged facts

describing international political intrigue involving the presidential candidates, the

Defendant’s economic expectation that the false and defamatory statements would

increase “clicks” and globally drive internet traffic to its various websites—and

thereby result in a financial benefit—is undeniable. While this is the business model

of digital journalism practiced on the internet, it does not excuse or justify the

publication of false and defamatory statements which catastrophically harmed an

innocent person.

Specifically, between approximately June 2016 through at least July

2017, Defendant’s prominent news subsidiaries and/or divisions Yahoo! News

(“Yahoo!”) and TheHuffingtonPost.com brand HuffPost (“HuffPost”) each

2
maliciously published highly damaging articles and statements about Dr. Page

which falsely portrayed him as a traitor to America who illegally conspired with

Russia in an intentional effort to subvert the 2016 U.S. Presidential Election.

Ironically, sabotaging the 2016 U.S. Presidential Election was the political

objective of the political actors whose resources were used to conceive, create

and strategically distribute to corrupt members of the media (and the United

States government). This sordid and salacious tale about a counterfeit political

scandal had no basis in fact and thus, did not exist in reality.

On September 23, 2016, in a historically reckless and irresponsible

display of tabloid “journalism,” Yahoo! chose to publish an article authored by

its Chief Investigative Correspondent Michael R. Isikoff (“Isikoff”). The article

was titled, “U.S. intel officials probe ties between Trump adviser and Kremlin”

(the “2016 Yahoo Article”), was replete with false and defamatory statements

about Dr. Page.1

The 2016 Yahoo Article included a wealth of categorically and

objectively false, misrepresentive, and unverified statements and information

compiled by Orbis Business Intelligence Ltd. (“Orbis”), a private company in

London, created on behalf of Fusion GPS, a mercenary investigative firm. Fusion

1
See Michael Isikoff, U.S. intel officials probe ties between Trump adviser and Kremlin,
YAHOO! NEWS (Sept. 23, 2016), https://www.yahoo.com/news/u-s-intel-officials-probe-ties-
between-trump-adviser-and-kremlin-175046002.html. A copy of the 2016 Yahoo Article is
attached hereto as Exhibit 1.

3
GPS, in turn, curated this information on behalf of, and with input from, its clients:

Perkins Coie LLP and the Democratic National Committee (“DNC”), who conspired

to use their resources and invent a fictitious claim about hypothetical “collusion”

between the Russian government and the campaign of then-candidate for President

Donald Trump.

It has now been exposed that the claim of such alleged “collusion” was

a complete fraud (see Section IV.B). This manufactured political “scandal” was

created out of thin air and funded by the DNC, working in collaboration with its law

firm Perkins Coie, for the obvious political advantage that would result if their lie

was believed by enough of the electorate. However, the DNC’s resources expended

to concoct the fairy tale of “collusion” between Russia and the Trump Campaign

were wasted unless the counterfeit “scandal” was widely published by the media.

This is where the Defendant’s illegal corporate conduct comes into play.

The 2016 Yahoo Article made various statements concerning, among

other things, meetings between Dr. Page and two sanctioned Russian officials:

Rosneft Oil Company (“Rosneft”) CEO Igor Sechin (“Sechin”) and Igor

Diveykin (“Diveykin”). It was further reported as fact that these

communications involved lifting of U.S. sanctions under a Trump presidency in

return for receiving compromising materials harmful to presidential candidate

Hillary Clinton. In fact, Dr. Page has never met with either Sechin or Diveykin

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at any time in his entire life. Furthermore, the reported conversations in which

Dr. Page allegedly participated with Sechin and Diveykin never happened

(directly or indirectly) with either of these people, or any other person.

The 2016 Yahoo Article was part of an extensive series of false and

defamatory articles targeting Dr. Page by another one of the Defendant’s media

outlets, the HuffPost. These defamatory articles were published beginning no later

than June 21, 2016, and continuing through at least July 30, 2017 (see Section

IV.B).

Despite Yahoo! and HuffPost having actual knowledge that the

portions of these articles defaming Dr. Page were false, they printed them anyway

(see Section V). These widely disseminated articles maliciously and falsely

described Dr. Page as a traitor to his country who was involved in a criminal

conspiracy to undermine American democracy and the 2016 U.S. Presidential

Election. Defendant, through its subsidiaries and/or divisions, disseminated

worldwide lies about Dr. Page’s connections to, and interactions with, identified

foreign agents of influence in order to create the false impression that Dr. Page—a

law-abiding American citizen who served his country honorably as a military officer

and otherwise—was acting in a treasonous manner to further the interests of Russia,

a hostile foreign power.

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 Not only was publishing the false and defamatory statements about

Dr. Page ‘good for business’ at Oath, it was in perfect alignment with the

political bias and aims of the senior management of the Defendant. Tim

Armstrong, prior to becoming the CEO of Oath in 2017, was CEO of Verizon’s

subsidiary AOL, Inc., when it purchased the HuffPost in 2011. He was the CEO

of AOL, Inc., when it produced a documentary honoring Hillary Clinton. He

has introduced Mrs. Clinton at a high-profile event in November 2015, at the

kick-off of her candidacy with the statement, “Leaders are not judged by their

number of followers, leaders are judged by the leaders they create.”2 Using the

media empire he ran as CEO to help elect Hillary Clinton and defeat then-

candidate Trump at all costs further explains this epic failure of journalistic

integrity at Defendant Oath resulting in the defamation of Dr.Page.

As a direct and proximate result of Defendant’s media outlets’ tortious

conduct, Dr. Page became a primary target of a vicious and sustained political witch

hunt of almost unparalleled proportion. During this saga and in significant part

stemming from the defamatory 2016 Yahoo Article by the Defendant, Dr. Page was

wrongfully surveilled for over a year by the United States government pursuant to

Foreign Intelligence Surveillance Act (“FISA”) warrants. He was subjected to

2
Jenna Belhumeur, On Closing Night, Hillary Clinton Reflects On A Rallying Cry, DOC NYC
(Nov. 11-19, 2020), https://www.docnyc.net/featured/on-closing-night-hillary-clinton-reflects-
on-a-rallying-cry/.

6
widespread public ridicule and shame and his life was threatened. Because his

personal safety was put at great risk by the Defendant’s defamatory statements,

Dr. Page was forced against his will to lead a life of seclusion and extreme

caution. His career and business prospects were effectively destroyed (see

Section VI).

This Complaint seeks to remedy one key aspect of the broad-based

wrongs perpetrated against Dr. Page—and against the United States Constitution—

occurring in the run-up to, and immediate aftermath of, the 2016 U.S. Presidential

Election: the publication of false and defamatory statements, and the resulting

tortious interference with business relationships of Dr. Page. These heinous

accusations were unleashed by outlets in the news media industry operated by Oath.

In the body of this Complaint, Dr. Page sets forth the circumstances of

how Defendant’s false and defamatory articles asserting he was secretly meeting

with the Kremlin on behalf of then-candidate Trump destroyed the exemplary life of

patriotism, high accomplishment and excellent character he had spent over four

decades building. This action seeks to redress the wrongs which inflicted great

damage upon Dr. Page and to serve as a deterrent to other members of the media to

minimize potential for a recurrence of this form of injustice which targets law-

abiding American citizens.

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 II. PARTIES

Plaintiff Dr. Carter Page is a natural person who is a citizen and

domiciliary of the State of Oklahoma. Dr. Page is a distinguished graduate of the

United States Naval Academy who served on active duty (including deployments at

sea and other assignments worldwide, many in Intelligence-related billets) from

1993 until 1998, reaching the rank of Lieutenant. After completing his active

military service, Dr. Page served as an International Affairs Fellow at the Council

on Foreign Relations and focused his research on energy-related developments in

the strategically important Caspian Sea region. Although Dr. Page earned a Master

of Arts degree in National Security from Georgetown University while on active

duty, he decided to pursue further education and completed NYU’s MBA program

in 2001. This educational qualification led to a position as an investment banker

with Merrill Lynch. After a series of promotions, Dr. Page became the Chief

Operating Officer of Merrill Lynch’s energy and power group in New York. In

2012, Dr. Page was awarded his Ph.D. degree from SOAS University of London

(School of Oriental and African Studies). He ran the international affairs program

at Bard College in New York, and subsequently returned to his alma mater NYU to

teach courses on energy and politics. During the 2016 U.S. Presidential Election,

Dr. Page was an informal member of a volunteer foreign policy advisory committee

to then-candidate Donald J. Trump’s election campaign. Dr. Page is, and has been

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at all recent relevant times, involved in the international energy business. He is the

sole-member of two LLCs: Global Energy Capital LLC (“GEC”), a limited liability

company organized under the laws of New York, and Global Natural Gas Ventures

LLC (“GNGV”), a limited liability company organized under the laws of Oklahoma

(collectively, the “Companies”).

Defendant Oath Inc. (“Oath”) is a corporation formed under the laws

of the State of Delaware. Oath’s registered agent in the State of Delaware is the

Corporation Trust Company, located at Corporation Trust Center, 1209 Orange

Street, Wilmington, County of New Castle, Delaware 19801. Service can be made

upon Oath’s registered agent pursuant to 10 Del. Code § 3103 and Del. R. Super. Ct.

R. Civ. P. Rule 4. Oath is a wholly-owned subsidiary of Verizon Communications

Inc. (“Verizon”), a public company listed on the New York Stock Exchange. In

2017, all of the assets and liabilities of Yahoo!, also a Delaware corporation, were

indirectly purchased by Verizon and merged into Oath.3

The Oath portfolio also includes HuffPost. Previously branded as the

Huffington Post, HuffPost was acquired in 2011 by AOL, a Delaware corporation.4

3
See Yahoo! April 24, 2017 Proxy Statement, SEC.gov (filed Apr. 27, 2017), Ex. B-1-1, B-1-2,
https://www.sec.gov/Archives/edgar/data/1011006/000119312517133449/d206374ddefm14a.ht
m (Verizon acquired from Yahoo! “all of [Yahoo!]’s right, title and interest in and to all of the
Assets of [Yahoo!]” other than Yahoo!’s equity in Aliababa Group, Aabaco Holdings, Yahoo!
Japan, and other, minor equity positions).
4
AOL Agrees To Acquire the Huffington Post, HUFFPOST.COM (last updated May 25, 2011),
https://www.huffpost.com/entry/aol-huffington-post_n_819375 (last visited July 20, 2020).

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In 2015, AOL was acquired by Verizon, a Delaware corporation.5

Oath is comprised of the assets and brands that Verizon acquired

through its purchases of AOL and Yahoo!, including HuffPost and Yahoo! News.6

In 2019, Oath was rebranded to the public as Verizon Media Group but

on information and belief remained the same legal entity.

Oath describes itself as “a digital media company of more than 50

media and technology brands, including HuffPost, Yahoo Sports, Tumblr, Engadget,

Autoblog, and AOL.com.” Indeed, archived versions of Oath’s website from as early

as August 3, 2017 reveal that Oath listed both Yahoo! News and HuffPost on its

“Our Brands” webpage.7

In public filings with the SEC, Verizon described Oath as “Verizon’s

Oath subsidiary, launched at the June 13 close of the company’s acquisition of

Yahoo’s operating business, houses AOL and Yahoo brands serving about 1 billion

5
Verizon to Acquire AOL, PRNEWSWIRE.COM (May 12, 2015),
https://www.prnewswire.com/news-releases/verizon-to-acquire-aol-300081541.html (last visited
July 20, 2020).
6
See Verizon Communications Inc., Form 8-K, SEC.GOV (filed Dec. 11, 2018),
https://www.sec.gov/Archives/edgar/data/0000732712/000073271218000060/a12-118xk.htm
(“Verizon’s Media business, branded Oath . . . has also achieved lower than expected benefits
from the integration of the Yahoo Inc. and AOL Inc. businesses”); see also Yahoo Provides
Notice to Additional Users Affected by Previously Disclosed 2013 Data Theft, SEC.GOV (Oct. 3,
2017),
https://www.sec.gov/Archives/edgar/data/732712/000073271217000003/a2017_10x3xoathxexhi
bitx991.htm (“Yahoo, now part of Oath . . . .”).
7
Our brands, OATH.COM (archived Aug. 3, 2017),
http://web.archive.org/web/20170803085315/https://www.oath.com/our-brands/ (last visited July
21, 2020).

10
unique monthly users globally and representing about $7 billion in annual

revenues.”8

In the alternative, as a result of the above-described acquisitions of all

of AOL’s and Yahoo!’s assets and liabilities by Verizon—and the merging of such

assets and liabilities, including Yahoo! News and HuffPost, into Oath—Yahoo!

News and HuffPost continue to be operated as Oath brands. In a 2017 filing in the

District Court for the Southern District of New York discussing the 2016 Yahoo

Article and the subsequently published defamatory HuffPost articles, Oath averred

that “as a news publisher, Oath obviously had a lawful interest in reporting to the

public news concerning suspected ties to a hostile foreign power of a high ranking

advisor to a Presidential candidate.” 9 Accordingly, Oath presents itself to the public

as the operator of its “brands” and may be held legally responsible for false and

defamatory statements published by the “brands” it operates and promotes,

irrespective of its corporate hierarchical ownership structure.

8
See Verizon Communications Inc., Form 8-K, SEC.GOV (filed July 27, 2017), Ex. 99,
https://www.sec.gov/Archives/edgar/data/0000732712/000119312517237279/d432411dex99.ht
m.
9
Memorandum of Law ISO Motion by Defendant Oath Inc. to Dismiss Complaint at 25, Page v.
Oath Inc., No. 17-CV-06690-LGS (S.D.N.Y. Nov. 6, 2017) (Dkt. No. 21).

11
 III. JURISDICTION AND VENUE

This Court has personal jurisdiction over Oath because it is

incorporated in the State of Delaware.10 Further, Oath utilized the laws of the State

of Delaware specifically to accomplish the business transaction described in this

Complaint whereby Oath became owner of all the assets and liabilities of Delaware

corporation, Yahoo!.

IV. FACTUAL ALLEGATIONS

To properly understand the reprehensible nature of the acts of

defamation and related harm targeting Plaintiff, and in order to award a proper

amount of all categories of recognized damages available to deter such conduct, the

following additional allegations are provided.

A. Dr. Carter Page — The Target of the Defendant’s Defamatory

Statements

As background, Dr. Page has sought to lead an exemplary life dedicated

to being a patriot. He is, and always has been, steadfastfully loyal to the ideals of

America. As a youth in the Fall of 1986, Dr. Page watched news accounts of

President Reagan and then-General Secretary Gorbachev negotiate a nuclear-arms

10
Delaware courts are empowered to exercise personal jurisdiction over defendants to the
maximum extent possible under the Due Process Clause. E.I. du Pont De Nemours & Co. v.
Agfa-Gavaert NV, 335 F. Supp. 3d 657, 666 (D. Del. 2018); the Due Process Clause permits a
state’s courts to exercise general personal jurisdiction over any corporation incorporated in that
state. Daimer AG v. Bauman, 571 U.S. 117, 137 (2014).

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control agreement. This event kindled Dr. Page’s desire to choose a path for his life

in which he could use his abilities to serve his country, particularly in the

sophisticated arena of promoting United States interests on matters of crucial foreign

policy and national security.

After earning the award of Eagle Scout and graduating high school, Dr.

Page accepted appointment to the United States Naval Academy. He graduated with

distinction in the top 5% of his class. Due to his exceptional achievement, he was

selected for the Navy’s distinguished Trident Scholar program. These details, and

the overall unblemished record of high achievement in the fields of military service,

educational accolades, business success, and academic instruction set out in

paragraph 13 above, are important to establish the type of respected citizen Dr. Page

spent his life becoming, and the successful reputation for devotion to this country he

had spent his life earning. It is this very reputation that the Defendant’s media outlets

unlawfully stole from him defiled for their financial gain.

Having spent most of his life as a largely unknown private figure, Dr.

Page did not have a Wikipedia entry until September 24, 2016—one day after

Defendant published the false and defamatory 2016 Yahoo Article accusing him of

colluding with several notorious, sanctioned Russians in pursuit of actions seeking

to compromise the 2016 U.S. Presidential Election. Prior to this date, Dr. Page had

never received death threats from his fellow countrymen nor had he been accused of

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being a traitor to the United States.

B. The False and Defamatory Statements Targeting Dr. Page

Among the defined sets of people Dr. Page knew and with whom he

interacted in the discrete academic and business communities he inhabited, Dr. Page

had earned a stellar reputation and established himself as a patriotic citizen of high

character and significant achievement. However, his admirable personal profile was

viciously attacked by the extensive collection of defamatory materials catalogued

below. The Defendant’s articles thrust the previously unknown Dr. Page onto the

public stage and defamed him before a national and worldwide audience. The overall

gist of the campaign of defamation that the Defendant waged against Dr. Page was

that Dr. Page was a traitor to his country – a crime punishable by death – and was

actively conspiring with a potentially hostile foreign power to the detriment of the

United States. The actionable defamatory materials for which Defendant Oath is

responsible are as follows:

False and Defamatory Statements by Oath Brand “Yahoo!”

The catalyst for the ensuing media tsunami damaging Dr. Page was the

2016 Yahoo Article as described below.

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 Exhibit 1 – False and Defamatory Statements by Oath Brand Yahoo! in the
2016 Yahoo Article (September 23, 2016)

The article is false and defamatory. The gist of the 2016 Yahoo Article

conveyed that Dr. Page was a traitor to his country – a crime punishable by death –

and was conspiring with a potentially hostile foreign power to the detriment of the

United States. It falsely stated that Dr. Page met with the Kremlin (specifically with

Sechin and Diveykin). In particular, it stated:

But U.S. officials have since received intelligence reports

that during that same three-day trip, Page met with Igor
Sechin, a longtime Putin associate and former Russian
deputy prime minister who is now the executive chairman
of Rosneft, Russia’s leading oil company, a well-placed
Western intelligence source tells Yahoo News. . . . At their
alleged meeting, Sechin raised the issue of the lifting of
sanctions with Page, the Western intelligence source said.
....
U.S. intelligence agencies have also received reports that
Page met with another top Putin aide while in Moscow —
Igor Diveykin. A former Russian security official,
Diveykin now serves as deputy chief for internal policy
and is believed by U.S. officials to have responsibility for
intelligence collected by Russian agencies about the U.S.
election, the Western intelligence source said.

The basis for this allegation was not a “well-placed Western

intelligence source.” This statement was a lie.

In fact, it was Steele, 11 Fusion GPS and their associates, who had

11
OFFICE OF THE INSPECTOR GENERAL, U.S. DEP’T OF JUSTICE, REVIEW OF FOUR FISA
APPLICATIONS AND OTHER ASPECTS OF THE FBI’S CROSSFIRE HURRICANE INVESTIGATION 106,
114, 364 (rev. Dec. 20, 2019), https://www.justice.gov/storage/120919-examination.pdf
[hereinafter IG REPORT].

15
compiled blatantly false statements involving Dr. Page.

Immediately beneath the article’s title, the Defendant placed a photo

altered to impose a Russian flag behind Dr. Page12:

The 2016 Yahoo Article also falsely claimed:

The source added that U.S. officials in the briefings

indicated that intelligence reports about the adviser’s talks
with senior Russian officials close to President Vladimir
Putin were being “actively monitored and investigated.”

These and other false statements throughout the 2016 Yahoo Article

claimed to rely upon “intelligence reports” from U.S. government agencies. This

description provided a cloak of authenticity and thereby concealed reality.

Instead, they were fabricated and unfinished reports submitted by Christopher

Steele in exchange for compensation paid to him by the DNC and their

12
The Code of Ethics published by the Society of Professional Journalists admonishes journalists
to “Never deliberately distort facts or context, including visual information.” SOC’Y OF PROF’L
JOURNALISTS, CODE OF ETHICS (rev. Sept. 6, 2014), https://www.spj.org/pdf/spj-code-of-
ethics.pdf [hereinafter CODE OF ETHICS] (emphasis added).

16
sponsored presidential campaign. This funding and disinformation was funneled

through the DNC’s law firm, and their subcontractor Fusion GPS – an entity

operated by Chief Investigative Reporter Michael Isikoff’s long-time friend:

Glenn Simpson.

The 2016 Yahoo Article falsely connected Dr. Page to involvement

in, and attributed primary blame for, the fake political scandal communicating the

now-debunked story that President Trump’s campaign colluded with Russia to

undermines the 2016 U.S. Presidential Election in return for subverting

America’s geopolitical interests:

The questions about Page come amid mounting

concerns within the U.S. intelligence community about
Russian cyberattacks on the Democratic National
Committee and state election databases in Arizona and
Illinois. In a rare public talk this week, former
undersecretary of defense for intelligence Mike Vickers
said that the Russian cyberattacks constituted meddling
in the U.S. election and were “beyond the pale.” Also,
this week, two senior Democrats – Sen. Dianne
Feinstein, ranking minority member on the Senate
Intelligence Committee, and Rep. Adam Schiff, ranking
minority member on the House Intelligence Committee
– released a joint statement that went further than what
U.S. officials had publicly said about the matter.

These false and defamatory statements suggested one of the worst

possible things about Dr. Page: that he was responsible, at least in part, for the

“mounting concerns within the U.S. Intelligence community” relating to “Russian

17
cyberattacks on the Democratic National Committee and state election databases in

Arizona and Illinois.” In no uncertain terms, this article falsely and defamatorily cast

Dr. Page as a traitor to the United States, the very nation he loved and honorably

served with dedication throughout his life. This article initiated a maelstrom of

events that would severely damage his reputation and career prospects, while

subjecting him to death threats and the contempt of his fellow Americans as well as

people worldwide.

Isikoff further attacked Dr. Page by advancing the false and defamatory

misinformation campaign initiated by Yahoo! when he retweeted an article by ABC

News on September 24, 2016. In the article, ABC News repeated the misinformation

first published by Yahoo! News in the 2016 Yahoo Article by stating, “Yahoo News

reported Friday that during the same trip, Page may have also held private meetings

with senior Russian officials.” Thus, one day after its initial publication, the

defamatory statements in the 2016 Yahoo Article were already being widely

republished and disseminated through the internet to a global audience creating

devastating damage to Dr. Page.

The degree to which the content of the 2016 Yahoo Article was rapidly

disseminated to millions upon millions of readers is impossible to overstate. On or

about 9:37 p.m. on October 19, 2016, during the third and final 2016 U.S.

Presidential Debate at the University of Nevada, Las Vegas, the Hillary for

18
America press office distributed to an extensive list of media contacts an email

with the subject line: “15 Facts About Donald Trump’s Deeply Unsettling Russia

Problem And WikiLeaks.” A total of nine supporters of the Trump campaign

were mentioned in alleged “Fact” number 11: “The Trump campaign’s ties to

Russia are deeply disturbing.” The first name listed (of the nine individuals

mentioned) in the Hillary for America statement was Dr. Page. The primary

foundation for making him the lead target? The 2016 Yahoo Article. In fact, the

distributed email included a web link to the defamatory article which

significantly increased internet traffic to the Defendant’s media outlet Yahoo!.

According to the American advertising trade publication Ad Week: the

“third and final debate between Hillary Clinton and Donald Trump brought in 71.6

million viewers, making it the third-most-watched debate ever.” With the Clinton

Campaign prominently emphasizing the false and defamatory 2016 Yahoo Article

as a highlighted web link in its press statement sent to a huge swath of the media, it

was ensured that internet traffic directed to the Yahoo! website containing the 2016

Yahoo Article was exponentially increased.

The highly misleading assertions included throughout the 2016 Yahoo

Article directly led to the U.S. Government’s false evaluations and resultant abuse

of process pleadings in the U.S. Foreign Intelligence Surveillance court surrounding:

“the FBI’s assessment that Steele was not the direct source of the disclosure to

19
Yahoo News in September 2016 about the FBI's investigation of Carter Page and

Page's alleged meetings with Igor Sechin and Igor Divyekin.”13

Later and despite the Defendants’ having made Dr. Page a primary

target of the U.S. Government’s and the U.S. Congress’s investigations, the Mueller

report subsequently concluded that there was no collusion between Dr. Page or any

other supporter of the Trump campaign with Russia.14

Indeed, the FBI has concluded that this allegation against Dr. Page

was a complete fabrication, with no basis in fact.15

These alleged associations and activities involving Dr. Page (or anyone

other campaign personnel) were comprehensively debunked and determined to be

false. The assessment by the Deputy Assistant Director of the FBI’s

Counterintelligence Division Peter Strzok also establishes this: “We have not seen

evidence of any individuals affiliated with the Trump team in contact with

[intelligence officers].”16

13
IG REPORT at 238.
14
Mueller finds no collusion with Russia, leaves obstruction question open, AM. BAR ASSOC.
(Mar. 2019), https://www.americanbar.org/news/abanews/aba-news-archives/2019/03/mueller-
concludes-investigation/.
15
IG REPORT at 187.
16
Judiciary Committee Releases Declassified Documents that Substantially Undercut Steele
Dossier, Page FISA Warrants, U.S. SENATE JUDICIARY COMM. (July 17, 2020),
https://www.judiciary.senate.gov/press/rep/releases/judiciary-committee-releases-declassified-
documents-that-substantially-undercut-steele-dossier-page-fisa-warrants.

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 False and Defamatory Statements by Oath Brand, HuffPost

While the false and defamatory statements published in the 2016 Yahoo

Article was the most provocative, it was maliciously published in a series of other

defamatory articles by the other Defendant Oath brand at issue in this case: the

Huffington Post (subsequently rebranded by the Defendant as “HuffPost” amidst the

course of their media campaign against the Plaintiff 17 ) deployed a barrage of

defamatory articles against Dr. Page. Listed below is a brief summary of false and

defamatory statements about Dr. Page published by Oath’s subsidiary and/or

division, HuffPost. In sum, these articles evince Oath’s malicious abuse of its media

position to spread the accusatory statements to as many readers as possible.

Exhibit 2 – HuffPost Republishes False and Defamatory Statements From the

2016 Yahoo Article (September 25, 2016)

On or about 12:01 p.m. on September 25, 2016, Oath brand HuffPost

republished many of the false and defamatory statements of the 2016 Yahoo Article

in an article titled “Trump Campaign: That Adviser Reportedly Talking With

Russian Officials Isn’t An Adviser Anymore.” 18 (Attached as Exhibit 2.) This

article, written by Matt Fuller, included a web link to the full 2016 Yahoo Article.

17
Mike Shields, Huffington Post Shrinks Its Name to HuffPost, in a Step Back From Founder,
WALL ST. J. (Apr. 25, 2017), https://www.wsj.com/articles/the-huffington-post-shrinks-its-name-
to-huffpost-1493110800.
18
See Matt Fuller, Trump Campaign: That Adviser Reportedly Talking With Russian Officials
Isn’t An Adviser Anymore, HUFFPOST (Sept. 25, 2016), https://www.huffpost.com/entry/trump-
campaign-russia-carter-page_n_57e7eb59e4b0e80b1ba299b9.

21
Further, this article featured the video of an appearance by Isikoff on MSNBC’s

“AM Joy” program on Saturday, September 24, 2016.19

In Mr. Isikoff’s interview with MSNBC host Joy Reid, he stated:

“Now I should say, there are a lot of… there’s a lot of murkiness to this. Precisely

what Page’s role in the Trump campaign, we don’t know…”20

Rather than raising the far darker “murkiness” of Mr. Isikoff’s own

highly unreliable sources whose allegations represented the cornerstone of Yahoo’s

libelous reporting which had risen towards the forefront of world news that weekend,

his statement on MSNBC instead referred to this Oath reporter’s own questions

about the self-evident nature of Dr. Page’s support to the Trump campaign. These

comments on MSNBC provide further evidence of both Mr. Isikoff’s actual

knowledge of the falsity of the 2016 Yahoo Article and his reckless disregard for the

truth about what actually happened during Dr. Page’s July 2016 trip to Moscow. In

fact, to avoid even the appearance of impropriety, Dr. Page opened his speech at

New Economic School with the following disclaimer: “I am speaking with you today

as a private citizen and business executive, so this lecture only reflects my own

ideas which I have developed over years past. Therefore, the ideas discussed do

19
At the end of this article, an Editor’s note was included: “Donald Trump regularly incites
political violence and is a serial liar, rampant xenophobe, racist, misogynist and birther who has
repeatedly pledged to ban all Muslims — 1.6 billion members of an entire religion — from
entering the U.S.” Id.
20
Id.

22
not necessarily reflect other people or organizations that I may be working with

at the present time.” In an abundance of caution, Dr. Page repeated this disclaimer

during his New Economic School academic lecture. Accordingly, everyone

attending the lecture unequivocally understood that Dr. Page was not representing

the Trump campaign in any way during his visit to Moscow.

With respect to what role Dr. Page did play in supporting the Trump

campaign, he was unable to contribute any material assistance due to the malevolent

personal attacks by Oath assets including HuffPost and Yahoo, as well as to a far

lesser extent other media outlets. This stands in stark contrast to the close, material

support that Oath brands, employees, and contractors – including Mr. Isikoff –

provided to the DNC.

Exhibit 3 – HuffPost Publishes False and Defamatory Statements in “Douglas

Valentine’s CIA vs Trump’s CIA” (February 16, 2017)

On February 16, 2017, HuffPost published an article written by Brad

Schreiber entitled “Douglas Valentine’s CIA vs. Donald Trump’s CIA.”21 (Attached

as Exhibit 3.)

The article is false and defamatory. The article falsely stated and

implied that Dr. Page was working with Russian intelligence against United States

interests. In particular, the article falsely states that “Carter Page [had] been caught

21
See Brad Schreiber, Douglas Valentine’s CIA vs. Donald Trump’s CIA, HUFFPOST (Feb. 16,
2017), https://www.huffpost.com/entry/douglas-valentines-cia-vs-donald-trumps-
cia_b_58a615cae4b0b0e1e0e20877.

23
by the CIA and NSA for collusion with Russian intelligence officers.” This

accusation is false.22 With such similar misrepresentations now the subject of alleged

criminal investigations 23 which have continued this summer 24 , these conspiracy

theories published by the Defendant have now been throroughly debunked by the

U.S. Department of Justice Office of Inspector the General.25

Exhibit 4 – HuffPost Publishes False and Defamatory Statements in “Was

Trump Putin’s Fool or His Partner in Crime” (March 23, 2017)

On March 23, 2017, HuffPost published an article by Richard North

Patterson entitled “Was Trump Putin’s Fool or His Partner in Crime?”26 (Attached

as Exhibit 4)

The article is also false and defamatory. The article falsely conveys

that Dr. Page helped President Trump collude with Russia. In particular, the article

falsely states that there are “[a]s yet unexplained numerous contacts between Trump

22
The most relevant contact by Dr. Page with Russian intelligence officers would have occurred
several years earlier but while working voluntarily on behalf of U.S. intelligence services during
periods of foreign travel. See Jonathan Turley, An apology to Carter Page, THE HILL, (Dec. 14,
2019), https://thehill.com/opinion/judiciary/474570-an-apology-to-carter-page (emphasis added).
23
Jerry Dunleavy, FBI lawyer under criminal investigation altered document to say Carter Page
'was not a source' for another agency, WASH. EXAMINER, (Dec. 9, 2019),
https://www.washingtonexaminer.com/news/fbi-lawyer-under-criminal-investigation-altered-
document-to-say-carter-page-was-not-a-source-for-another-agency.
24
Gregg Re, Barr says familiar names among those DOJ is investigating in Durham probe, calls
findings 'very troubling', FOX NEWS, (June 9, 2020), https://www.foxnews.com/politics/barr-
says-familiar-names-among-those-doj-is-investigating-in-durham-probe.
25
IG REPORT at 248-51, 254.
26
See Richard Patterson, Was Trump Putin’s Fool Or His Partner In Crime?, HUFFPOST (Mar.
23, 2017), https://www.huffpost.com/entry/was-trump-putins-fool-his-partner-in-
crime_b_58d406fce4b099c777b9dfdc.

24
officials and Russian intelligence” including at the 2016 Republican National

Convention where “Trump foreign policy adviser Carter Page met with the

omnipresent envoy [Russian Ambassador Sergey Kislyak], just before Trump

operatives stripped the party platform of a pledge to aid Ukraine against Russian

aggression.” According to the FBI, there is no factual basis for this allegation.27 To

the contrary, the evidence showed that “Page was not involved in the [platform

change].”28

Exhibit 5 – HuffPost Publishes False and Defamatory Statements in “Michael

Flynn Pleads Fifth and Refuses to . . . .” (May 22, 2017)

Oath compounded its lies in an article posted on May 22, 2017 by

Amanda Terkel entitled “Michael Flynn Pleads the Fifth and Refuses to Cooperate

with Senate Russia Probe.”29 (Attached as Exhibit 5)

This article is false and defamatory. The gist of this article falsely

conveys that Dr. Page was obstructing a congressional investigation. In particular,

the article falsely states that “The Senate intelligence committee has also requested

documents from former Trump adviser Carter Page, who is so far refusing to

cooperate.” Dr. Page never failed to cooperate with any investigation, and indeed

went above and beyond to cooperate in every conceivable way. He offered

27
IG REPORT at 242, 263-65.
28
Id. at 266.
29
See Amanda Terkel, Michael Flynn Pleads The Fifth And Refuses To Cooperate With Senate
Russia Probe, HUFFPOST (May 22, 2017), https://www.huffpost.com/entry/michael-flynn-senate-
intelligence_n_5922ea65e4b03b485cb33b4a.

25
significant cooperation and a substantial quantity of documents to the U.S.

Senate Select Committee on Intelligence (“SSCI”) via their Chairman Senator

Richard Burr their Vice Chairman, Senator Mark Warner, and senior members

of the SSCI staff.

Numerous other HuffPost articles were published that contain false and

defamatory statements about Dr. Page.

Exhibit 6 – HuffPost Publishes False and Defamatory Statements in “Trump’s

Russian Connections Explain . . . .” (September 29, 2016)

This article by Amica Graber, titled “Trump’s Russian Connections

Explain His Climate Change Denial,” was published on September 29, 2016. 30

(Attached as Exhibit 6). This article is false and defamatory. In particular, the

gist of the article conveys that U.S. law enforcement was invesigating Dr. Page

for conspiring with a hostile foreign power to the detriment of the United States.

The article states that “Putin personally owns 4.5 per cent of Gazprom, while the

Russian government he helms owns 50 per cent of it. Carter Page has his own wealth

invested in Gazprom and attends the annual investor meetings. Before Page's

resignation on Monday, Yahoo reported that U.S. intelligence officers were ‘looking

into’ Page’s connections in Moscow after he flew there shortly before the RNC

convention in Cleveland.” At the time of publication, Dr. Page held no Gazprom

30
See Amica Graber, Trump’s Russian Connections Explain His Climate Change Denial,
HUFFPOST (Sept. 29, 2016), https://www.huffingtonpost.ca/amyrose-lane/trump-russian-
connection_b_12223494.html.

26
shares. Further, U.S. intelligence agencies were only “looking into” Dr. Page

because they were supplied with the same false information that informed the

2016 Yahoo Article, and then wrongfully obtained warrants to spy on Dr. Page

by committing fraud on the FISA court.

Exhibit 7 – HuffPost Publishes False and Defamatory Statements in “All The

President’s Traitors” (March 23, 2017)

This article by Jennifer Sabin, titled “All The President's Traitors,”

was published March 23, 2017.31 (Attached as Exhibit 7). This article referred

to “. . . lying Carter Page . . . .” This article is false and defamatory. In particular,

the gist of this article explicitly conveys that Dr. Page is a traitor to the United

States – a crime which is punishable by death; further, this article conveys that

Dr. Page was lying when he denied being a traitor. Dr. Page is not a traitor, nor

has he lied in connection with any of the relevant events. This article presents

no evidence that Dr. Page has ever lied to any investigator or other source. To

the contrary, the U.S. Department of Justice Office of the Inspector General has

confirmed that at least one unnamed CIA “employee had given a positive

assessment of Page's candor.”32 More recently, the Special Counsel for the U.S.

Department of Justice, Robert Mueller, subpoenaed Dr. Page to assess such false

allegations. Contrary to these false media reports from the Defendant, he has

31
See Jennifer Sabin, All The President’s Traitors, HUFFPOST (Mar. 23, 2017),
https://www.huffpost.com/entry/all-the-presidents-traitors_b_58d4266de4b002482d6e6fa2.
32
IG REPORT at 366.

27
never been charged with any crime under 18 U.S.C. § 1001 or any such related

statutory authority.

Exhibit 8 – HuffPost Publishes False and Defamatory Statements in “Trump’s

‘High Crimes’ – Not Treason” (May 16, 2017)

This article by Warren Goldstein, titled “Trump's ‘High Crimes' – Not

Treason,” was published May 16, 2017. 33 (Attached as Exhibit 8). This article is

false and defamatory. In particular, the gist of this article conveys that Dr. Page

was a traitor to the United States – a crime punishable by death. The article

falsely states the following about Dr Page: “Trump and his sleazy minions (Paul

Manafort, Carter Page, Michael Flynn, and Roger Stone what a bunch!) really

did give ‘aid and comfort’ to Vladimir Putin's efforts to weaken the United

States.” Dr. Page never gave “aid and comfort” to Vladimir Putin or Russia.34

Exhibit 9 – HuffPost Publishes False and Defamatory Statements in “Friday's

Morning Email: The Latest In . . . .” (May 19, 2017)

This article by Lauren Weber, titled “Friday's Morning Email: The

Latest In The Trump-Comey Saga,” was published May 19, 2017.35 (Attached as

33
See Warren Goldstein, Trump’s ‘High Crimes’ – Not Treason, HUFFPOST (May 16, 2017),
https://www.huffpost.com/entry/trumps-high-crimes-not-
treason_b_591b6e2de4b0a8551f3f83c5.
34
Not only is Goldstein’s allegation false, it is a total inversion of the truth: in reality, Dr. Page
provided information to U.S. intelligence agencies about Russia and Russian intelligence. IG
REPORT at 248-51, 254. Accordingly, Dr. Page gave aid and comfort to the United States, to the
detriment of Vladimir Putin.
35
See Lauren Weber, Friday’s Morning Email: The Latest In The Trump-Comey Saga,
HUFFPOST (May 19, 2017), https://www.huffpost.com/entry/fridays-morning-email-the-latest-in-
the-trump-comey-saga_n_591ecefae4b034684b0b8b18.

28
Exhibit 9). This article is false and defamatory. In particular, the gist of this

article conveys that Dr. Page was denounced by the President of the United

States. The article falsely claims that “. . . many wonder why Trump continues

to stand by the man despite denouncing his ties to Paul Manafort and Carter

Page.” President Trump never “denounced” Dr. Page.

Exhibit 10 – HuffPost Publishes False and Defamatory Statements in “All The

President's Miscreants, Lowlifes . . . .” (June 2, 2017)

This article by Jon Hotchkiss, titled “All The President's Miscreants,

Lowlifes and Villains,” was published June 2, 2017.36 (Attached as Exhibit 10).

This article is false and defamatory. In particular, the gist of this article conveys

that Dr. Page was of exceptionally low intelligence and that he was being

investigated by law enforcement. The article falsely states that Dr. Page's,

“secret service code name is: ‘Gomer Pyle, But Dumber’.” Dr. Page never had

Secret Service protection or any “code name” and this false and defamatory

statement was written to hold Dr. Page up to public ridicule and scorn and

reveals a mean-spirited personal ad hominem attack. Again, this article further

states that Dr. Page was “under investigation by the FBI.” This statement fails

to provide the crucial context that the investigation was commenced based on

unverified allegations obtained for political purposes, and was enabled throught

36
See Jon Hotchkiss, All The President’s Miscreants, Lowlifes and Villains, HUFFPOST (June 2,
2017), https://www.huffpost.com/entry/all-the-presidents-miscreants-lowlifes-and-
villains_b_5931ae68e4b00573ab57a30f.

29
fraud on the FISA court.

Although Dr. Page has never received U.S. Secret Service protection,

the only reason why he might have necessitated security support from the federal

government initially originated as a result of terror threats directly stemming from

the 2016 Yahoo Article and other malicious false stories that stemmed from

publication by the Defendants since at least September 2016.

Exhibit 11 – HuffPost Publishes False and Defamatory Statements in “Exxon-

Treasury Fight And The Roots Of Russiagate” (July 30, 2017)

This article by David Halperin, titled “Exxon-Treasury Fight And The

Roots Of Russiagate,” was published on July 30, 2017.37 (Attached as Exhibit 11).

This article is false and defamatory. In particular, the gist of this article conveys

that Dr. Page was not only a traitor to the United States – a crime punishable by

death – but that Dr. Page was selling out his own country in exchange for bribes

from Russian officials. The article falsely states “that Trump campaign adviser

Carter Page met last summer with Rosneft's president Sechin and a senior

Russian government official and that ‘Sechin’s associate said that the Rosneft

president was so keen to lift personal and corporate western sanctions imposed

on the company, that he offered Page and his associates the brokerage of up to a

19 percent (privatized) stake in Rosneft. In return, Page had expressed interest

37
See David Halperin, The Exxon-Treasury Fight And The Roots of Russiagate, HUFFPOST (July
30, 2017), https://www.huffpost.com/entry/the-exxon-treasury-fight-and-the-roots-of-
russiagate_b_597de928e4b0c69ef70528ff.

30
and confirmed that were Trump elected U.S president then sanctions on Russia

would be lifted.’”

Dr. Page never met with Sechin, received no such offer from Sechin

and made no such statements to Sechin. Once again, this is another HuffPost

article asserting defamatory statements of objective facts about Dr. Page which

are wholly false. Like countless other defamatory articles by the Defendant and

based on an extensive investigation by the U.S. Department of Justice

encompassing “over one million records and… over 100 interviews,” 38 such

false statements have been entirely disproven by DOJ Inspector General Michael

Horowitz and his large team of investigators.

V. DEFENDANT ACTED WITH MALICE DEFAMING DR.

PAGE

As correctly noted in recent proceedings before the High Court of

Justice in London on July 21, 2020:

“…We do not believe that this serious allegation about these specific
alleged meetings had been published anywhere previously. Certainly,
neither side has disclosed any article to this effect. Self-evidently Mr
Isikoff had not verified them, but he published. That is not a criticism
of him, it’s a fact. There is not a whiff of evidence that Mr Steele was
uncomfortable with this article. Indeed, he briefed Mr Isikoff in person
again in October 2016.”39

38
IG Horowitz letter to Congress, (Sept. 13, 2019),
https://www.scribd.com/document/425739490/IG-Horowitz-letter-to-Congress.
39
Claimant’s Opening Speech at ¶ 42, Gubarev v. Orbis Business Intelligence Ltd, QB-2017-
002808 (EWHC (QB) argued July 20, 2020) (emphasis added).

31
 A. Falsity, Defamation Per Se, Actual Malice, and Common Law
Malice

In April 2016, the law firm Perkins Coie LLP (acting on behalf of its

clients the DNC and Hillary Clinton’s presidential campaign) retained Fusion GPS

to develop negative information that could be used to allege then-candidate Trump

and his campaign had ties to Russia.

Fusion GPS is and was a private investigation firm specializing in

politics. It was founded in 2010 by former Wall Street Journal investigative reporter

Glenn Simpson. Simpson was employed at the Wall Street Journal from 1995

through 2009. Simpson utilized aggressive tactics, but had a particular—and well-

deserved reputation for the use of ad hominem attacks in lieu of legitimate

investigative journalism. Simpson has conducted his business in Washington, DC.

Fusion GPS had long been known as a hired gun.40 Fusion GPS and

Simpson’s performance of their investigations was unsavory. Their credibility was

questionable, and they were known for their willingness to launch professional

smear campaigns for hire.

B. Fusion GPS’s Smear Campaign and the 2016 U.S. Presidential

Election

Fusion GPS then did what they were compensated for and expected to

do: wage a smear campaign of false accusations. Fusion GPS and its associates were

40
Kimberley A. Strassel, Trolling for Dirt on the President's List, WALL ST. J. (May 10, 2012),
https://www.wsj.com/articles/SB10001424052702304070304577396412560038208.

32
involved in creating reports connecting presidential candidate Trump and Russia.

These reports were expressly based on unverified—and unverifiable—hearsay from

anonymous sources. Often the reports’ conclusions were founded on multiple levels

of anonymous hearsay.

Fusion GPS acquired much of the fodder for its smear campaign from

foreign consulting firm Orbis and Orbis’ founder and owner, Christopher Steele

(collectively, “Steele”). 41 In June 2016, just weeks after the DNC determined to

funnel money through its law firm Perkins Coie to begin constructing the counterfeit

political scandal that did not exist in reality, Fusion GPS hired Steele for the purpose

of creating materials that could be used to allege a connection between the Trump

campaign and Russian and subverting the 2016 U.S. Presidential Election.42

Steele was described by his professional colleagues as “keen to help,”

but “underpinned by poor judgment”43; that it was “not clear what [Steele] would

have done to validate” his reports44; and that Steele “demonstrates [a] lack of self-

awareness, [and] poor judgment.” 45 Further, Steele was “desperate that Donald

Trump not get elected and was passionate about [Trump] not being the U.S.

President.”46

41
IG REPORT at 93.
42
Id. at 94.
43
Id. at 182.
44
Id.
45
Id.
46
Id. at 234.

33
 Steele was not the originating source of most of the information he

reported. Steele received all of his information from a single primary sub-source. In

turn, the primary sub-source received all of his/her47 information from a network of

secondary sub-sources. Even worse, none of the secondary sub-sources had access

to the information they reported – rather, all of the secondary sub-sources received

their information from “someone else who may have had access.”48

This means there were at least four degrees of separation between the

2016 Yahoo Article and the sources of the information on which the Steele reports

were based, if any even existed. But as the DOJ IG’s report determined, the contents

of the “unfinished” Steele Dossier, as it is popularly known, this information likely

passed through an unknown – and unknowable – number of additional sub-sources.49

The information was almost certainly inaccurate50 if not deliberately fabricated.51

Notwithstanding these fatal flaws preventing publishing information from the Steele

Dossier, the 2016 Yahoo Article deceptively packaged its most outlandish claims as

the product of as legitimate investigative journalism so that the story would be

47
The IG REPORT refers to the primary sub-source as “him/her” throughout.
48
Id. at 186, 188.
49
It was unknown “how many degrees of separation existed” between the sub-sources and the
originators of the information that the sub-sources were reporting. Id. at 188.
50
Steele’s primary sub-source believed that the secondary sub-sources “exaggerated their access
to information.” Id. The primary sub-source took what the secondary sub-sources reported “with
a grain of salt.” Id.
51
Id. at 189 (“the ability to blackmail Trump was [the [secondary] sub-source’s] ‘logical
conclusion’ rather than reporting”).

34
believed and the Yahoo! News website would benefit from the increased “clicks” of

internet traffic.

Steele was compensated in return for assembling at least 10 reports used

to advance the fiction that there was a political scandal involving ties between the

Trump presidential campaign and Russia. However, even Steele, with whom Isikoff

had direct access, described these reports as “uncorroborated,” not designed to be

finished products, and not to be consumed as “written product[s].”52

The reports were not just unverified; on their face the various reports

included clear errors and internal inconsistencies.53 They had obvious misspellings.

They also included many factual errors on matters of objective fact which could

easily be exposed as false if fact-checked by a quick Google search. The information

in the reports was inherently improbable.

The reports amounted to no more than internet rumor, and many had

dismissed them as such, including Steele’s primary sub-source.54 At most, the Steele

Dossier contained some potential leads to pursue. But under no circumstance were

they verified and objective facts. They were not ready for publication, under any

journalistic standard.

52
Id. at 94.
53
See, e.g., id. at 187, n.338.
54
Steele’s primary sub-source explained that his/her information came from “word of mouth and
hearsay,” including from “conversation[s] that [he/she] had with friends over beers.” Id. at 188.
The primary sub-source never expected that Steele would put his/her statements in reports or
present them as facts. Id.

35
 Beginning in September 2016 and onward, Fusion GPS (and Steele,

acting at Fusion GPS’s behest)55 took these reports and their accusations to the

press. They met with and briefed Yahoo!.56 Fusion GPS and Steele briefed other

members of the press on the reports and their contents.

One suspicious aspect of the Steele Dossier was the involvement of

law firm Perkins Coie, the party who actually compensated Fusion GPS and Steele

using DNC and Hillary Clinton Campaign funds. Amongst the meetings that Steele

and Fusion GPS held with representatives of media outlets, Perkins Coie hosted at

least one of them.

What journalists did with that information is telling. On the one hand,

Dr. Page was contacted by correspondents from the New York Times and

Washington Post. These professional news organizations asked Dr. Page directly for

his side of the story. The correspondents clearly explained the accusations that they

had heard from Steele and Fusion GPS. Dr. Page explained that these accusations

were categorically false. Consequently, both the New York Times and the

Washington Post (hardly media outlets sympathetic to then-candidate Trump)

understood publishing Steele’s and Fusion GPS’s outlandish information was not

legally permissible.

55
Id. at 94, 234, 239.
56
Id. at 104-05 (Steele also briefed The New York Times, The Washington Post, The New
Yorker, and CNN).

36
 Months later, BuzzFeed spent weeks attempting to verify Fusion GPS’s

claims but could not do so. Similar to the New York Times and Washington Post

decisions, BuzzFeed recognized that it could not publish Fusion GPS’s reports as-

is.

Instead, BuzzFeed chose to published the Steele Dossier with a warning

which explained that Fusion GPS’s reports contained “specific, unverified, and

potentially unverifiable allegations” which BuzzFeed had investigated. BuzzFeed

noted that the reports did not come from an unbiased source or a governmental

intelligence agency; they were “prepared for political opponents of Trump . . . .”

And BuzzFeed explained that Fusion GPS’s reports were “not just unconfirmed:

[They] include[] some clear errors.”

On the other hand, Yahoo! and Isikoff handled the publication of the

information they received from Fusion GPS in stark contrast to the handling given

it by the correspondents for the New York Times or the Washington Post, including

Isikoff’s utter failure to verify the incredible accusations asserted by Steele and

Fusion GPS.

Another difference is Yahoo! Chief Investigative Journalist Isikoff’s

failure to interview Dr. Page before publishing the accusatory accusations which

were potentially devastating to the reputation of Dr. Page. On September 15, 2016,

Isikoff left the following voicemail for Dr. Page: “Uh, Carter Page, hey, it’s Mike

37
Isikoff with uh Yahoo News. If you could please give me a call at (202) [number

preceded by Washington, D.C. area code]. Thanks.” Isikoff gave no explanation as

to why he wanted to speak with Dr. Page.

The evening before the 2016 Yahoo Article was published, Isikoff left

Dr. Page a second, equally cryptic voicemail on September 22, 2016. Again, Isikoff

failed to give any explanation as to the purpose of the call, or why he wanted to

speak with Dr. Page.

No other person from Yahoo! contacted, or attempted to contact, Dr.

Page about the 2016 Yahoo Article.57 There were no email contacts with Dr. Page.

Furthermore, unlike Buzzfeed, Isikoff and Yahoo! failed to perform

any form of investigation into the veracity of the article they were about to publish

and deploy against Dr. Page. Even the most cursory investigation would have

revealed the overwhelming defects with the 2016 Yahoo Article. For example,

Fusion GPS had discovered that one of Steele’s most important secondary sub-

sources was an officer in the Russian Intelligence Services.58 This information

was recklessly disregarded and ignored by Yahoo! and no such background

57
Cf. CODE OF ETHICS (“Diligently seek subjects of news coverage to allow them to respond to
criticism or allegations of wrongdoing”) (emphasis added).
58
See Apr. 15, 2020 letter from Richard Grenell to Senators Charles Grassley and Ron Johnson
at 5, n.302 (Apr. 15, 2020), https://www.grassley.senate.gov/sites/default/files/2020-04-
15%20ODNI%20to%20CEG%20RHJ%20%28FISA%20Footnote%20Declassification%29.pdf
[hereinafter APRIL 15 GRASSLEY LETTER] (“[Glenn] Simpson had assessed that [Steele’s
secondary sub-source] was a [Russian Intelligence Services] officer who was central in
connecting Trump to Russia”).

38
questions on bias or the potential for political disinformation were developed.

If Fusion GPS was capable of making this discovery, it was reckless for

Yahoo!, a multibillion-dollar corporation that employed many investigative

journalists, to fail to make this discovery. This knowing, intentional, and blatant

violation of basic values and standards of journalistic integrity and ethics59 itself

strongly evidences actual malice.

Yahoo! and Isikoff published the information almost in its entirety in

the 2016 Yahoo Article. Additionally, there were no disclaimers within the article

such as with BuzzFeed. To the contrary, they cited the source as “a well-placed

Western intelligence source”—implying a high-level government employee in a

three-letter agency – the exact preconceived and false narrative Defendant intended

to convey to the average reader. There was nothing in the 2016 Yahoo Article from

which the average reader could ascertain the truth about the Article’s accusations

which were based solely on facially defective and politically biased information

supplied by Fusion GPS and Steele who were compensated to produce the false and

defamatory materials. The express purpose of these private actors in compiling such

information was to falsely smear Trump, his presidential campaign, and anyone

59
The very first rule of the Code of Ethics specifically admonishes journalists to “Take
responsibility for the accuracy of their work. Verify information before releasing it.” CODE OF
ETHICS (emphasis added).

39
associated with his campaign, including Dr. Page.60

Through Yahoo! and various republications that followed, the false

accusations that portrayed Dr. Page as a traitor to his country effectively reached a

nation-wide and worldwide audience.

Yahoo!’s economic motivations for publishing the universe of

unverified allegations appearing in the 2016 Yahoo Article, and the many other

defamatory articles that followed, were without legal privilege or excuse but to the

contrary were negligently published and published with actual malice.

First, Defendant Oath’s “brands” Yahoo! News and HuffPost actions

publishing the defamatory materials identified above were incentivized and intended

to unlawfully increase corporate revenue and economic benefits. Online news

outlets, such as Yahoo!, earn revenue through advertisements appearing in their

news stories. Advertising revenue is determined, to a large extent, by the number of

persons who view each news story. Yahoo! was aware of the excited state of the

political climate in the run-up to the 2016 U.S. Presidential Elections. Further, as

with any media report, Yahoo! understood that the more sensational and salacious,

the greater the potential to exploit the heated political climate to increase viewer and

readers by millions of people throughout the world, thereby creating enormous

60
Steele’s primary sub-source believed that Steele’s reports were “far more ‘conclusive’ than
justified.” IG REPORT at 188. The primary sub-source “made it clear to Steele that he/she had no
proof to support the statements” from the secondary sub-sources, and also clearly communicated
to Steele that information reported by the secondary sub-sources “was just talk.” Id.

40
advertising revenue for the publisher.

But Yahoo! also knew that publishing the 2016 Yahoo Article and

branding Dr. Page a traitor to his country would inflict immense and permanent

damage to Dr. Page’s reputation, standing in the community, and business prospects.

Yahoo! further knew that worldwide publication of thise false and defamatory

accusation would cause Dr. Page to suffer tremendous personal humiliation and

mental anguish. In the pursuit of revenue and profit, Yahoo! consciously,

deliberately, and callously disregarded Dr. Page’s legally protected interest in his

person and his reputation to such an extent that the publication of the 2016 Yahoo

Article amounts to willful, wanton, and intentional misconduct. All of the foregoing

is equally true for the many defamatory articles published by HuffPost subsequent

to the 2016 Yahoo Article.

Second, Yahoo! was motivated by an intent to harm Dr. Page because

it possessed actual knowledge of Dr. Page’s association with the Trump election

campaign and knew its lies about Dr. Page serving Russia’s interests would create

sensationalism and garner massive attention. As stated above, Yahoo! knew that

publishing the 2016 Yahoo Article and branding Dr. Page a traitor to his country

would do immense and permanent damage to Dr. Page’s reputation, standing in the

community, and business prospects. Yahoo! further knew that having these false

allegations published worldwide would inflict tremendous personal humiliation and

41
mental anguish upon Dr. Page. In order to effectuate its ill will towards Dr. Page,

Yahoo! consciously, deliberately, and callously disregarded Dr. Page’s legally

protected interest in his person and reputation to such an extent that the publication

of the 2016 Yahoo Article was nothing less than willful, wanton, and intentional

misconduct and intentional character assasination.

The articles are false and defamatory per se. And Defendant acted

negligently and with actual malice in publishing these statements; Defendant knew

the statements were false and/or acted with reckless disregard of whether they were

true or false.

Defendant published the false and defamatory accusations with

common law malice: Defendant was motivated by an expectation of financial gain

and profit notwithstanding the personal harm to Dr. Page that was reasonably

forseeable. Defendant knew that publishing these statements would generate

immense advertising revenue. Defendant knew that publishing the statements would

cause enormous and permanent damage to every facet of Dr. Page’s life. That

Defendant repeatedly published these false statements despite this knowledge

evidences a conscious and deliberate disregard of Dr. Page’s legally protected

interest in his person and reputation that Defendant’s conduct rises to the level of

being willful or wanton.

42
 Dr. Page never met with Sechin. He never met Diveykin. And there was

no “well-placed Western intelligence source” saying otherwise. To the contrary and

as subsequent investigations have now confirmed, Western intelligence reports

strongly suggest that these misrepresented allegations about Dr. Page were part of a

disinformation campaign by Russian intelligence.61

Nor did Dr. Page ever work for or “collude with” Russian intelligence

officers. As was widely pointed out, the most minimal investigation into Dr. Page

would have established that Dr. Page had been wrongly accused and was, in fact,

supporting the CIA rather than any foreign power. Indeed, in stark contrast to

“refusing to cooperate” with congressional investigations, Dr. Page offered

significant cooperation and provided extensive documents to the U.S. Senate Select

Committee on Intelligence and other Congressional committees via their respective

members and staff. The Defendant nonetheless negligently and intentionally

published articles accusing Dr. Page of, not only meeting with these Russian

individuals, but also colluding with them against the United States’ interests.

Defendant knowingly branded Dr. Page as a Benedict Arnold.

The average person who read the articles understood them to convey

statements of fact that Dr. Page had met with Sechin and Diveykin, and worked on

61
According to the FBI, “[Steele’s] subsource who provided the information about the Carter
Page-Sechin meeting had connections to Russian Intelligence Services.” APRIL 15 GRASSLEY
LETTER at 5, n.339.

43
behalf of Russian intelligence. These were not opinions; they were statements of fact

that could be objectively characterized as true or false. And these statements were

objectively and demonstrably false. Dr. Page’s life and business were permanently

ruined by the false accusations that he was secretly meeting with these Russian

officials. Tragically, Dr. Page’s personal safety and life were put at great risk due to

the wide-spread dissemination of the false and defamatory accusations by the

Defendant.

The Defendant intended the statements to be interpreted by the average

reader as truthful statements of fact. That is why it referenced a “well-placed

Western intelligence source.” 62 The Defendant tried to create credibility for the

article’s source with reckless – possibly intentional – disregard for the truth or falsity

of the statements. And that is how the average reader could reasonably construe the

statements.

This statement too—“a well-placed Western intelligence source”—was

false. Isikoff did not get the information from a government intelligence agency. He

got it from Fusion GPS, a private investigation firm hired and compensated by the

political opponend of candidate Trump and a firm with a known reputation as a

professional smear artist and liar for hire, and from Steele, a foreign national whose

62
Cf. CODE OF ETHICS (“Identify sources clearly. The public is entitled to as much information as
possible to judge the reliability and motivations of sources”).

44
professional judgment was questioned by his colleagues, despite their known dislike,

if not hatred, for the idea of a Trump presidency.

Ironically, the 2016 Yahoo Article was itself a delivery device for

Russian propaganda. U.S. Department of Justice and American intelligence agencies

have concluded that many of Steele’s most consequential 2016 election reports

which were initially misrepresented by the Defendant were in turn similarly

fabricated by Russian intelligence.63 Moreover, numerous U.S. intelligence reports

show that Steele’s network of sub-sources was also thoroughly infiltrated by Russian

intelligence. For example, a report found that in early July 2016, “two persons

affiliated with [Russian intelligence] were aware of Steele’s election investigation,”

and that “[Russian intelligence] may have targeted Orbis.”64 FBI reports indicate that

one of Steele’s secondary sub-sources (who had “voic[ed] strong support for

candidate Clinton in the 2016 U.S. elections”) was in contact with the Russian

Presidential Administration in June and July 2016.65

Indeed, there are indications that Steele was a willing purveyor of

Russian disinformation. Steele had a substantial and ongoing relationship with a

63
APRIL 15 GRASSLEY LETTER at 6, n.350 (describing Steele’s reporting on Michael Cohen as
“part of a Russian disinformation campaign to denigrate U.S. foreign relations,” and Steele’s
reporting on President Trump’s sexual activities as “false . . . the product of [Russian
intelligence] ‘infiltrate[ing] a source into [Steele’s] network’”).
64
Id. at 5, n.342.
65
Id. at 5, n.347.

45
Russian oligarch.66 Steele assisted this oligarch with personal litigation matters,67

used his FBI contacts to advocate on the oligarch’s behalf regarding U.S. sanctions,68

and brokered meetings between this oligarch and FBI officials.69 This relationship

antedated the publication of the 2016 Yahoo Article by at least several years. 70

According to one FBI agent, this relationship raised the possibility that “Steele was

being used in a Russian ‘controlled operation’ to influence perceptions (i.e., a

disinformation campaign).” 71 Indeed, Steele’s “frequent contacts with Russian

oligarchs” had “raised concerns in the FBI Transnational Organized Crime

Intelligence Unit.”72

Fusion GPS’s unsavory reputation was not lost on Isikoff. He had actual

knowledge of its reputation.73 Isikoff and Simpson (Fusion GPS’s founder) were

longtime friends and colleagues. Their relationship had developed over the course

66
U.S. sanctions were imposed on this oligarch and on his business interests because of “his
links to Senior Russian government officials, suspected criminal activities, and ties to Russian
organized crime.” IG REPORT at 270, n.409.
67
Id. at 109.
68
Id. at 194.
69
Id. at 270.
70
Id.
71
Id. at 109; see also APRIL 15 GRASSLEY LETTER at 4, n.211 (“sensitive source reporting”
indicated that a person affiliated with Steele’s oligarch may have been aware of Steele’s election
investigation as early as July 2016).
72
IG REPORT at 194-95, n.349; see also APRIL 15 GRASSLEY LETTER at 3-4, n.208 (“A 2015
report concerning oligarchs written by the FBI’s Transnational Organized Crime Intelligence
Unit (TOCIU) noted that from January through May 2015, 10 Eurasian oligarchs sought
meetings with the FBI, and 5 of these had their intermediaries contact Steele. The report noted
that Steele’s contact with 5 Russian oligarchs in a short period of time was unusual and
recommended that a validation review be completed on Steele because of this activity”).
73
Cf. CODE OF ETHICS (“Consider sources’ motives before promising anonymity . . . Explain
why anonymity was granted”).

46
of many years while they worked as prominent investigative journalists at national

outlets. Isikoff joined Newsweek in 1994 as an investigative journalist, and Simpson

joined the Wall Street Journal as an investigative journalist in 1995. Both had written

and published significant stories on politics. And both had worked in the

“journalistic” world of Washington, DC. The circle of DC-based investigative

“journalists” on the national political beat is small, and Isikoff and Simpon ran in it

together.

The average person who read the statements would reasonably construe

them to be serious criminal charges of the highest order against Dr. Page—that he

was conspiring with United States’ geopolitical rival Russia on matters against

United States’ interests. Indeed, persons who read the statements contacted Dr. Page,

threatened his life and cursed at him for “trad[ing] out your fucking country for some

fucking Russian dollars” and for being “in cahoots with fucking Rosneft and every

fucking Russian oligarch . . . .” Furthermore, the Defendant knew that the publication

of the statements would reach a national and worldwide audience.

These statements are materially false because they would have a

different effect on the average reader or listener from that which the truth would

have produced. Dr. Page’s life and business were ruined by the false accusations that

he was secretly meeting with the Kremlin and false statements that he was conspiring

with Russian intelligence. Whereas if the truth were reported—that he met with

47
nobody of that kind—his life and business would have almost unquestionably

prospered based on his life’s accomplishments before being branded a traitor to his

country.

The same goes for the “well-placed Western intelligence source” lie. If

the average reader knew the truth—that the source was functioning as a hired gun PI

firm for a political opponent, they would not have given the statements anywhere

near the same weight as a leak from the CIA, FBI, or any other legitimate intelligence

agency. In fact, they likely would have given the statements no weight at all.74

Defendant harbored serious doubts about both the truth or falsity of the

statements and Fusion GPS’s reliability, lack of bias and political agenda. Defendant

knew Fusion GPS’s reputation: Fusion GPS was a liar for hire, a professional smear

artist, and an active, biased participant in the political arena.

Defendant also knew that it had not seen any evidence supporting the

allegations, and that the allegations rested upon anonymous hearsay from unverified,

unreliable, and anonymous sources—and often anonymous were hearsay statements

on top of anonymous hearsay statements. Isikoff himself actually knew that some of

Fusion GPS’s allegations were likely false. Isikoff also knew that, in the political

battlefield, disinformation campaigns and spin doctors wage war through private

74
Cf. Id. (“Identify sources clearly. The public is entitled to as much information as possible to
judge the reliability and motivations of sources”).

48
investigators to destroy their political enemies. Given the nature of Fusion GPS’s

accusations, Defendant knew, understood or intentionally ignored the fact that

Fusion GPS was funded by individuals or entities with an anti-Trump agenda and

bias. Indeed, the explanation of why Steele possessed the information used to create

the Fusion GPS reports made clear that it was politically motivated.

The defamatory statements were patently absurd and inherently

improbable. Anybody with a remote understanding of Sechin would know the

difficulty of meeting with him. And even the barest investigation—asking Western

businesspersons active in Russia—would have shown the article’s allegations to be

meritless. However, the Defendant chose to prioritize the profitability of publishing

these statements over the truth and in conscious disregard for the damage to Dr.

Page. Defendant intentionally avoided the truth in publishing the false and

accusatory publications.

Defendant acted with reckless disregard of whether these statements

were true or false. BuzzFeed received these statements, spent weeks attempting to

verify, and ultimately concluded that all it could report was that Fusion GPS’s

allegations:

were “specific, unverified, and potentially unverifiable

allegations”;
they could not be “verified or falsified”;
were “prepared for political opponents of Trump”; and
“not just unconfirmed,” but also “include[d] some clear errors” and
obvious misspellings.

49
 Defendant also demonstrated actual malice because it never gave Dr.

Page notice of the 2016 Yahoo Article that was about to upend his life, nor any

opportunity to review the false statements in the article in order to reasonably

respond and correct the record prior to publication.

As a private person at the time who was trying to avoid publicity, Dr.

Page never responded to Isikoff’s voicemail requests. These short communications

offered no advance warning whatsoever of the horrendously destructive and

malevolent content that Yahoo! had planned for the following week and day,

respectively, when the 2016 Yahoo Article was published on the morning of

September 23, 2016. The messages were intentionally benign to avoid alerting Dr.

Page to the seriousness of the reporting and conveying to him a sense of urgency and

importance to his need to respond to the messages.

Upon publication of the 2016 Yahoo Article, Yahoo! immediately set

about triggering its widespread republication. At 11:12 a.m. the day of publication,

Isikoff distributed it from his Twitter social media account.

Despite the (i) uniform recognition that the claims and conclusions of

Fusion GPS were unreliable and in many critical instances wrong and unverified;

(ii) the fact that the information upon which the Steele Dossier has been thoroughly

discredited after one of this country’s most comprehensive internal reviews since

50
Watergate;75 and (iii) that Isikoff himself has publicly admitted this status quo of the

Dossier’s falsity to a significant extent, Defendant has utterly failed to correct or

retract its false and defamatory accusations of and concerning Dr. Page.

As for Fusion GPS, it has directly or indirectly acknowledged that its

conduct and course of dealings with the DNC and its law firm raise implications of

criminal misconduct. When the United States House of Representatives subpoenaed

Simpson to testify on Fusion GPS’s reports, instead of testifying which he was

authorized by the DNC to do, Simpson invoked his Fifth Amendment right against

self-incrimination. Meaning: Simpson recognized that his testimony may implicate

him in criminal misconduct. Simpson was represented by counsel and necessarily

understood he must have a good faith basis to invoke his Fifth Amendment rights to

refuse to testify, as he surely does.

Fusion GPS has also admitted that its reports were factually flawed and

not meant for public consumption or publication. Yet, the Defendant’s “brands”

published the statements that were as false as they were malicious and defamatory

to Dr. Page.

Yet still, after all this and to this day, Defendant has failed to correct

and retract its statements. 76 But this corporate hostility to reality, and to the

75
See IG REPORT.
76
Cf. CODE OF ETHICS (“Acknowledge mistakes and correct them promptly and prominently”).

51
innocence of Dr. Page whose life Defendant destroyed, accurately reveals the culture

and bias against anyone associated with either candidate or President Trump, starting

with the former CEO of Defendant Oath, Tim Armstrong. He has professionally

supported Hillary Clinton’s candidacy for president. But on his watch, HuffPost

posted a statement on its website that said, “Trump is a serial liar who incites

violence ….”

Before the 2016 Yahoo Article was published, Dr. Page did not seek

media attention. He did not make appearances on television, radio, or other news

programs, or have significant contact with the media. Indeed, Dr. Page hoped to live

his entire life without being thrust in the limelight. After the 2016 Yahoo Article was

published, and particularly once the HuffPost articles further escalated the nature

and extent of the defamatory campaign being waged against him, Dr. Page realized

that his only chance of combatting Oath’s lies and mitigating the immense

reputational damage they caused was to bring the truth directly to the American

people. To this end, Dr. Page expended enormous effort on mitigating these false

attacks through countless television and radio appearances.

VI. INJURIES AND DAMAGES TO PLAINTIFF

Defendant’s defamatory statements injured Dr. Page’s reputation.

The defamatory statements had an increasingly harmful effect when

other news outlets began to republish the Defendant’s defamatory statements about

52
Dr. Page which remained continuously published on the Yahoo! and HuffPost

websites. Of course the increased internet traffic visiting the Yahoo! and HuffPost

websites accomplished the Defendant’s objective for originally publishing the false

sensational information about a phony scandal political. Defendant and its

subsidiaries and/or divisions and/or agents knew this would be the result and in fact

encouraged the republication.

A. Special Damages

Dr. Page is the sole member of GEC and GNGV (collectively, the

“Companies”).

As such, Dr. Page’s reputation is inextricably connected to the

reputations of the Companies, Defendant’s defamatory statements caused Dr. Page

and the Companies to lose many business opportunities. For example, before

Defendant’s defamatory statements, Dr. Page and the Companies were pursuing a

lucrative business relationship with several international partners. By all accounts,

the pursuit was going exceedingly well and the final negotiations were near

completion.

Then, Defendant published the defamatory statements. When Dr. Page

was falsely accused of being a traitor to his country and an agent of Russia, such

reputational harm was equally imputed to the Companies’ reputation.

53
 A primary prospective international business partner ceased

negotiations and declined to contract with Dr. Page. The prospective partner told Dr.

Page it would not move forward with him in a business relationship because of the

widespread and pervasive reporting on Dr. Page and his supposed meetings with

Sechin and Diveykin. The prospective partner told Dr. Page that it could not do

business with someone who was the subject of such significant negative press, or

with companies closely associated with someone who was the subject of such

significant negative press.

Dr. Page is, and at all times was, the only principal and representative

of the Companies. Prior to the Defendant publishing life-threatening defamatory

allegations and related misinformation, Dr. Page’s professional reputation was

flawless. Because the Companies’ business involves advising and partnering with

corporations and financial institutions, Dr. Page’s impeccable reputation was key to

his ability to complete the building of the Companies into successful going concerns

with international financial institutions.

As a direct result of the harm to Dr. Page’s reputation caused by the

2016 Yahoo Article and the other false and defamatory articles published by

Defendant and/or its subsidiaries and/or divisions, the Companies suffered, and will

continue to suffer, actual injury. At least three banks and diversified financial

services companies have declined to do business with Dr. Page and the Companies

54
because of the defamatory statements published by the Defendant. The defamatory

statements have also cost Plaintiff numerous other clients and business

opportunities. These economic and pecuniary losses of value flowed directly from

the wrongful injury to Dr. Page’s reputation proximately caused by the Defendant’s

defamatory publications.

B. General Damages

Dr. Page also began receiving countless death threats after Defendant

published the defamatory statements. For example, this is one threat (among many)

that was left on Dr. Page’s voicemail:

Yo, what’s up man? Sounds like things are going pretty

fucking good for you. Go to trade out your fucking country
for some fucking Russian dollars. We know what the fuck
you’ve been doing, you piece of shit mother fucker. You
think you’re not, you know you’re not in fucking in
cahoots with fucking Rosneft and every fucking Russian
oligarch over there? You fucking half-wit, fucking piece
of shit. You deserve everything you fucking get. Every
fucking thing you get. If it was up to me, after we fucking
tried you for treason, we’d take you out in the street and
beat the fucking piss out of you with baseball bats, you
cock sucking mother fucker. Next time you turn your back
on your fucking country, you’ll fucking regret it.
(emphasis added).

Dr. Page did not receive death threats before the defamatory statements

were published. Since Oath thrusted Dr. Page into the public light on a global basis

with its defamatory publications targeting him, he suffered public humiliation and

threats of the same scale.

55
 Because of these death threats, Dr. Page could no longer walk public

streets without reasonably and legitimately fearing for his safety. Thus, Dr. Page

has been required to avoid being in public or in crowds as much as physically

possible.

It is no understatement to say the 2016 Yahoo Article and other articles

containing false and defamatory statements about Dr. Page published by Defendant

and/or its subsidiaries have completely devastated the life Dr Page had built for

himself over four decades. Dr. Page has never been, or aspired to become, a

politician or otherwise be a public figure. Beyond certain discrete academic foreign

policy circles and energy finance circles, he was not known at all.

C. Defendant Was Unjustly Enriched By Its Destruction of Dr. Page’s

Life, Reputation, Privacy, and Business Prospects

With the 2016 Yahoo Article, the other defamatory articles, and the

large-scale online promotion techniques that Verizon, Oath, Yahoo! and HuffPost

utilized to spread the stories in the days and months following their publication,

Defendant and its subsidiaries and/or divisions put its revenue and profit above

telling the truth and basic principles of journalistic integrity, as well as the right not

to be defamed which is owned by all individuals such as the Plaintiff.

The Defendant reaped ill-gotten gains from internet advertising

associated with the articles, which under the unique and special circumstances of

this case should be disgorged to Dr. Page. Many of the false and defamatory articles

56
display advertising from well-known companies. The companies that advertised in

the false and defamatory articles include: Oscar Mayer, BMW AG's subsidiary

MINI, Zillow Group, Popular Community Bank, Liberty Interactive Corporation’s

e-commerce company Zulily, Affinia Hotel Collection property Shelburne NYC,

Williams-Sonoma Inc.’s subsidiary home furnishing store chain Pottery Barn, Audi

AG, Georgia-Pacific LLC’s Brawny brand, Berkshire Hathaway Inc.’s battery

manufacturing company Duracell Inc., Nissan’s Infiniti luxury vehicle division,

private equity firm Sycamore Partners’ portfolio company Talbots Inc., Graham

Holdings Company’s for-profit education subsidiary Kaplan Inc., Choice Hotels

International Inc., The American Express Company, Lending Tree LLC, Dentsply

Sirona Inc., MeCommerce Inc.’s bra shopping website ThirdLove, and Liberty

Mutual Insurance.

Defendant should not be permitted to profit from the identified false

and defamatory articles its “brands” published about Dr. Page with actual malice,

and with the expectation that the falsehoods originating from the 2016 Yahoo

Article would increase its online viewership, its website “clicks”, and ultimately

enhance Defendant’s financial results.

D. Defendant Caused Dr. Page Humiliation and Mental and

Emotional Anguish

Prior to the Defendant’s defamatory publication, Dr. Page had earned

the trust, respect, and friendship of his colleagues in the academic and business

57
communities in which he circulated.

Prior to the Defendant’s defamatory publication, Dr. Page regularly

enjoyed the company of friends, colleagues, and acquaintances. Dr. Page could

appear in public and walk among a crowd without having a second thought as to his

personal safety.

Before September 23, 2016, Dr. Page never once avoided going out in

public or walking in a crowd for fear of being targeted for bodily harm or death by

a stranger.

This profile and aspect of his private life all changed because of the

2016 Yahoo Article and the Defendant’s many subsequent defamatory publications.

As set forth above, Dr. Page began receiving frequent anonymous death threats (by

phone and voicemails, as well as via the internet) for the first time in his life. Because

of the frequency and anonymous nature of these threats, Dr. Page feared, and

continues to fear, to go out in public for any reason. Thus, Dr. Page can no longer

enjoy the freedom of movement that the great majority of American’s take for

granted as a fundamental right.

Dr. Page has always been a patriot. Therefore, he finds the lie that he

would betray his country to engage engage in acts of treason to be particularly

humiliating. This is especially true in light of the fact that the Defendant’s reach as

a media outlet caused this lie to be published globally, and the unfortunate situation

58
that many Americans continue to harbor questions whether Dr. Page is a traitor even

after every single accusation that the Defendant leveled against him has been

conclusively demonstrated to be false by multiple sources.

Further, as a result of Defendant’s defamatory publications, Dr. Page’s

relationships with many of his professional and academic colleagues have been

permanently harmed. In many cases, such relationships have been completely

destroyed by the defamatory publications. The same is true of Dr. Page’s personal

relationships.

VII. THIS ACTION IS TIMELY FILED IN DELAWARE

This action against Oath was originally filed in the United States

District Court for the Southern District of New York, Case No. 1:17-cv-06990, on

September 14, 2017. [Dr. Page filed this action pro se.]

On March 20, 2018, the Southern District of New York dismissed Dr.

Page’s federal claims under a Rule 12(b)(6) motion. The court then declined to

exercise supplemental jurisdiction over Dr. Page’s state law claims for defamation

and tortious interference with business relations since the federal claims had been

dismissed.77 Therefore, the Southern District of New York did not reach a decision

77
See Page v. Oath Inc., No. 17-CV-06690-LGS, 2018 WL 1474620, at *6-7 (S.D.N.Y. Mar. 20,
2018) (finding that it was “appropriate to decline to exercise supplemental jurisdiction” over Dr.
Page’s state-law claims because “[judicial] economy, convenience, fairness, and comity . . . will
usually lead to the dismissal of the non-federal claims when the federal claims have been
dimissed at a relatively early stage”).

59
on the merits of Dr. Page’s state law claims; they were dismissed without prejudice

to a future filing due to a jurisdictional defect.

Dr. Page timely appealed the District Court’s ruling. On December 2,

2019, the Court of Appeals for the Second Circuit affirmed the lower court’s

judgment and held there was no diversity of citizenship conferring subject matter

jurisdiction on the Southern District of New York.78 Mandate was issued by the

District Court on January 27, 2020. However, there is no claim preclusion

doctrine that bars either state law claim from being refiled based on the

Southern District of New York’s dismissal of Case No. 1:17-cv-06990.

Pursuant to 10 Del. Code § 8118(a) and N.Y. CPLR § 205, if the

original federal action in the Southern District of New York was timely filed as to

the state law claims, because these claims were dismissed without prejudice, there is

no legally operative judgment on the merits or other bar to bringing this action

within six months of the dismissal of the federal action on January 27, 2020. 79

Accordingly, this action is timely pursuant to 10 Del. Code § 8118(a) and N.Y.

CPLR § 205. 80

78
Page v. U.S. Agency for Glob. Media, 797 F. App’x. 550, 555-56 (2nd Cir. 2019) (district
court properly dismissed Dr. Page’s defamation claim because “the fact that Oath and Page were
both New York citizens is enough to defeat diversity jurisdiction in this case”).
79
See Howmet Corp. v. City of Wilmington, 285 A.2d 423, 427 (Del. Super. Ct. 1971) (holding
that Delaware saving statute applies where claim is dismissed from a U.S. District Court due to
lack of jurisdiction over claim).
80
When a trial court decision is appealed, Delaware’s saving statutory period does not begin
running until mandate issues. See Gosnell v. Whetsel, 198 A.2d 924, 927 (Del. 1964).

60
 VIII. RELATED LITIGATION

Now pending in the Northern District of Illinois is Page v. Democratic

Nat’l Comm., No. 1:20-cv-00671 (N.D. Ill.) (the “Illinois Litigation”). The

Defendants in the Illinois Litigation are two entity Defendants: DNC and Perkins

Coie LLP, as well as, two Perkins Coie partners, Marc Elias and Michael Sussmann.

The Illinois Litigation is against the political actors responsible for conspiring

against Dr. Page to cause the creation and compiling of the contents of the Steele

Dossier, and for providing false accusations against Dr. Page to the media and the

FBI. The Illinois Litigation Defendants pursued political objectives and committed

their tortious acts to obtain political advantages. Plaintiff is aware that, should the

Illinois Litigation be adjudicated first, there is a potential for overlapping recovery

with certain components of a damages award that could be included as part of

judgment to be entered in this case. Nonetheless, Defendant Oath engaged in the

complained of tortious behavior for financial gain rather than political advantage and

is liable for certain categories of damages separate and distinguishable from

damages sought in the Illinois Litigation.

Oath abused its position as a media concern, published lies that globally

and immeasurably defamed Dr. Page, and economically benefitted from such

reprehensible actions. Unlike the claims at issue in the Illinois Litigation, this action

against Oath seeks disgorgement of economic benefits enjoyed by Oath’s media

61
outlet based on its financial motive for wrongfully publishing the defamatory

articles. This specific disgorgement component of Plaintiff’s requested damages

against Defendant Oath is not available as a remdy available for recovery from the

Illinois Litigation Defendants.

Furthermore, this action seeks punitive damages against Oath, a multi-

billion-dollar media company which exploited its commercial position as a giant in

the media industry, violated the tenets of ethical journalism, and remained

unapologetic for the the revenues it generated in connection with damaging an

innocent person’s reputation without cause. Dr. Page seeks punitive damages from

the Defendant to send a deterrence message to companies like Oath in the media and

journalism industry signaling that no innocent American citizen —regardless of

political affiliation— may have their life destroyed as was done to Dr. Page. Similar

to the disgorgement remedy, Plaintiff may not seek a recovery for punitive damages

against Defendant Oath from the Illinois Litigation Defendants.

In order to pursue a damages award which includes recovery for

disgorgement and punitive damages from Defendant Oath, Dr. Page has brought his

claims against Oath in Delaware, the state of Oath’s incorporation and the

jurisdiction that Oath availed themselves to by choice. There will not be joint and

several liability with the Illinois Litigation Defendants, or a right of contribution for

the award of damages for either the disgorgement remedy or punitive damages

62
sought from Oath. The action brought in this court is not identical to the Illinois

Litigation but is a separate action against an unrelated corporate Defendant,

supporting several distinct and/or unique remedies, including a recovery based on

disgorgement as well as punitive damages for this media Defendant’s specific

malicious conduct, both such remedies are unavailable in the Illinois Litigation.

IX. CAUSES OF ACTION

COUNT NO. 1:

By Dr. Page against Oath for Defamation

Dr. Page realleges and incorporates by reference each of the preceding

paragraphs as if fully set forth herein.

Defendant made numerous false statements including without

limitation the following: Dr. Page met with Sechin; Dr. Page met with Diveykin; Dr.

Page met with the Kremlin; and a well-placed Western intelligence source confirmed

that Dr. Page met with Sechin and Diveykin.

These statements were defamatory per se and the damages from such

defamatory statements are presumed.81 The statements accused Dr. Page of criminal

conduct – meeting and colluding with Russia – which led to him being falsely

suspected as an agent of foreign power by both the public and the United States

government. Consequently, each statement is on its face malicious and injurious to

81
N.Y. Pattern Jury Instruction – Civil 3:29 (Dec. 2019 Updated).

63
Dr. Page’s reputation, business trade, and profession.

The defamatory statements concerned Dr. Page, as they referenced him

by name. The average reader understood the statements to be about Dr. Page and

reasonably read them to be statements of fact. These statements clearly implied that

Dr. Page was working in the interest of a foreign power and was disloyal to the

United States.

Defendant published the defamatory statements. Defendant

communicated the defamatory statements to someone other than Dr. Page, and

Defendant intended that the defamatory statements be distributed widely—both

nationally and internationally.

The defamatory statements were false, substantially untrue, and

materially false. None of the alleged meetings nor alleged collusion between Dr.

Page and the Russian individuals ever occurred. Rather, they were sensational lies

published for economic gain and with the intention to benefit the Defendant’s media

business.

When Defendant made the defamatory statements, it knew that they

were false or acted in reckless disregard of the truth or falsity of the statements.

Defendant failed to conduct any reasonable investigation. Further, Defendant knew

or should have known the falsity of the statements, and with such knowledge, should

not have publicly disseminated the defamatory statements. Therefore, Defendant

64
made the statements with actual malice.

Defendant acted with common law malice in making the defamatory

statements: Defendant was motivated by its pursuit of financial benefit and a desire

to harm Dr. Page. Defendant knew that publishing these defamatory statements in

connection with the 2016 U.S. Presidentiual Election would generate immense

interest and heavy additional internet visits to its websites. However, Defendant

knew that publishing the statements would cause enormous damage to every facet

of Dr. Page’s life. That Defendant repeatedly published these false statements

despite this knowledge evinces such a conscious and deliberate disregard of Dr.

Page’s legally protected interest in his personality that Defendant’s conduct was

willful or wanton.

Defendant had no applicable privilege or legal authorization to publish

the defamatory statements. The statements were malicious lies published without

any knowledge, or notice to Dr. Page, let alone an authorization.

Defendant’s defamatory statements severely and permanently injured

Dr. Page’s professional, academic, and personal reputations. These reputational

injuries have severely impaired ––and continue to severely impair–– Dr. Page’s

ability to operate his businesses, maintain existing business relationships, enter into

new business relationships, and earn a living. Dr. Page expects that Defendant’s

defamatory statements will continue to impair his ability to operate his businesses,

65
maintain existing business relationships, enter into new business relationships, and

earn a living well into the foreseeable future.

Defendant’s defamatory statements, and the near-universal obloquy

and derision that Dr. Page has been subjected to ever since, continue to cause Dr.

Page humiliation and mental and emotional suffering. Dr. Page expects that this

harm caused by the Defendant will continue into the foreseeable future.

Defendant’s defamatory statements have caused Dr. Page to receive

countless anonymous threats against his life. As a result, Dr. Page continues to fear

for his life. Dr. Page cannot go out in public or walk among a crowd without fearing

an attack from someone who read and believed the Defendant’ defamatory

statements. Living in constant fear continues to cause Dr. Page mental and emotional

suffering. Dr. Page expects that this harm caused by the Defendant will continue into

the foreseeable future.

Defendant’s defamatory statements have permanently harmed or

destroyed Dr. Page’s relationships with his professional and academic colleagues

and his friends and acquaintances, which continues to cause Dr. Page mental and

emotional suffering. Dr. Page expects that this harm caused by the Defendant will

continue into the foreseeable future.

Dr. Page expects that all of the harms that Defendant’s defamatory

statements have caused to him will continue into the foreseeable future.

66
 The defamatory statements were a substantial factor in causing Dr. Page

to suffer economic and non-economic loss, in an amount to be proven at trial.

COUNT NO. 2:

By Dr. Page against Oath for Tortious Interference

Dr. Page realleges and incorporates by reference each of the preceding

paragraphs as if fully set forth herein.

Dr. Page was well-established in the field of energy and energy finance.

His business relationships with energy companies included Chesapeake Energy,

KazMunayGas, Tatneft, and Gazprom. Dr. Page’s business relationships with

financial institutions included Deutsche Bank, Goldman Sachs, Citi, Mubadala

Development Company, China Investment Corporation, Canaccord Genuity, HSBC,

Piper Jaffray Companies, Ladenburg Thalman, and Morgan Stanley. Because of his

credentials and experience, Dr. Page had the opportunity to enter into business

relationships with blue chip companies and firms such the aforementioned ones—

and a reasonable expectancy of entering those relationships. These prospective

relationships contemplated the successful completion of future energy financing

transactions.

Defendant knew of these relationships. Dr. Page’s extensive business

relationships with international energy companies and financial institutions was a

fact of his businesses and his profile. In fact, Defendant’s false and defamatory

67
statements expressly recognize that Dr. Page “specialize[s] in oil and gas deals in

Russia and other Central Asian countries.”

Defendant reasonably knew and expected that publishing the

defamatory statements would interfere with Dr. Page’s businesses and Defendant

intentionally interfered with these prospective relationships by deciding to publish

the defamatory statements at issue.

But for Defendant’s interference, Dr. Page would have entered into the

prospective business relationships in this area of commerce for which he was

recognized.

Defendant’s interference with the prospective relationships used

wrongful means, and was accomplished by making defamatory statements defaming
Dr. Page.
X. PRAYER FOR RELIEF

Dr. Page demands judgment against Defendant as follows:

i. An award of compensatory, special, presumed and punitive

damages in appropriate amounts to be established at trial;
ii. An award requiring Defendant to disgorge any benefits obtained
from publishing the defamatory statements;
iii. An award of attorneys’ fees and costs associated with this action;
iv. An award of prejudgment and post-judgment interest at the legal
rate to the maximum extent permitted by law; and
v. Such other and further relief as the Court may deem just and
proper.

68
 JURY DEMAND

Dr. Page demands a trial by jury on all issues so triable.

Date: July 27, 2020 BELLEW LLC

/s/ Sean J. Bellew

2961 Centerville Rd., Suite 302
Wilmington, DE 19808
Telephone: (302) 353-4951
sjbellew@bellewllc.com

PIERCE BAINBRIDGE P.C.

John M. Pierce (pro hac vice to be
sought)
355 S. Grand Ave., 44th Floor
Los Angeles, CA 90071
Telephone: (213) 262-9333
jpierce@piercebainbridge.com

L. LIN WOOD, P.C.

L. Lin Wood (pro hac vice to be
sought)
663 Greenview Avenue
Atlanta, GA 30305
Telephone: (404) 891-1402
lwood@linwoodlaw.com

MILLER KEFFER & PEDIGO PLLC

K. Lawson Pedigo (pro hac vice to be
sought)
3400 Carlisle Street, Suite 550
Dallas, Texas 75204
Telehone: (214) 696-2050
klpedigo@mkp-law.net

Counsel for Plaintiff Carter Page

69
 EFiled: Jul 27 2020 10:37AM EDT
Transaction ID 65799719
Case No. S20C-07-030 CAK

EXHIBIT 1
U.S. intel officials probe ties between Trump adviser and Kremlin, YAHOO! NEWS (Sept. 23,
2016)
Home Mail News Finance Sports Entertainment Search Mobile More

Search Search News Search web Sign in Mail

U.S. intel officials probe ties between Trump

adviser and Kremlin
Follow Michael Isikoff Chief Investigative Correspondent • September 23, 2016

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What to Read Next

Carter Page speaks at the graduation ceremony for the New Economic
School in Moscow in July. (Photo illustration: Yahoo News, photos: Pavel
Golovkin/AP, AP)

U.S. intelligence officials are seeking to determine

whether an American businessman identified by Donald
Trump as one of his foreign policy advisers has opened DHS team deployed to Seattle; unit on standby
in case of new unrest in city
up private communications with senior Russian officials
USA TODAY
— including talks about the possible lifting of economic
sanctions if the Republican nominee becomes president,
according to multiple sources who have been briefed on
the issue.

The activities of Trump adviser Carter Page, who has

extensive business interests in Russia, have been
discussed with senior members of Congress during 20% Off Vitamin Sale!
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recent briefings about suspected efforts by Moscow to
influence the presidential election, the sources said.
After one of those briefings, Senate minority leader
Harry Reid wrote FBI Director James Comey, citing
reports of meetings between a Trump adviser (a
reference to Page) and “high ranking sanctioned
individuals” in Moscow over the summer as evidence of
White House, GOP at odds over jobless aid in
“significant and disturbing ties” between the Trump virus bill
campaign and the Kremlin that needed to be Associated Press

investigated by the bureau.

Some of those briefed were “taken aback” when they

learned about Page’s contacts in Moscow, viewing them
as a possible back channel to the Russians that could
undercut U.S. foreign policy, said a congressional source
familiar with the briefings but who asked for anonymity
Confederate names will stay on military bases,
due to the sensitivity of the subject. The source added Trump insists, citing talk with Inhofe talk
that U.S. officials in the briefings indicated that MarketWatch

intelligence reports about the adviser’s talks with senior

Russian officials close to President Vladimir Putin were
being “actively monitored and investigated.”

A senior U.S. law enforcement official did not dispute

that characterization when asked for comment by Yahoo
News. “It’s on our radar screen,” said the official
As Trump trails in national polls, his new
about Page’s contacts with Russian officials. “It’s being campaign manager says the surveys ‘keep
looked at.” getting it wrong’
MarketWatch

Page is a former Merrill Lynch investment banker in

Moscow who now runs a New York consulting firm,
Global Energy Capital, located around the corner from
Trump Tower, that specializes in oil and gas deals in
Russia and other Central Asian countries. He declined
repeated requests to comment for this story.
Stream CBS Hits
Trump first mentioned Page’s name when asked to CBS All Access Ad ...
identify his “foreign policy team” during an interview
with the Washington Post editorial team last March.
Describing him then only as a “PhD,” Trump named
Page as among five advisers “that we are dealing with.”
But his precise role in the campaign remains
unclear; Trump spokeswoman Hope Hicks last month
called him an “informal foreign adviser” who “does not
NOT REAL NEWS: A look at what didn't happen
speak for Mr. Trump or the campaign.” Asked this week this week
by Yahoo News, Trump campaign spokesman Jason Associated Press

Miller said Page “has no role” and added: “We are not
aware of any of his activities, past or present.” Miller did
not respond when asked why Trump had previously
described Page as one of his advisers.

Giants' Sam Coonrod says faith kept him from

 Giants' Sam Coonrod says faith kept him from
kneeling during racial justice demonstration
Yahoo Sports

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The questions about Page come amid mounting
concerns within the U.S. intelligence community about
Russian cyberattacks on the Democratic National
Committee and state election databases in Arizona and
Illinois. In a rare public talk this week, former
undersecretary of defense for intelligence Mike Vickers
said that the Russian cyberattacks constituted meddling
in the U.S. election and were “beyond the pale.” Also, 2.5% FIXED California Mortgage, No Hidden
Fees/Points
this week, two senior Democrats — Sen. Dianne LendGo Ad ...
Feinstein, ranking minority member on the Senate
Intelligence Committee, and Rep. Adam Schiff, ranking
minority member on the House Intelligence Committee
— released a joint statement that went further then what
U.S. officials had publicly said about the matter.

“Based on briefings we have received, we

No masks, just questions, in Kansas counties
have concluded that the Russian with no cases
Associated Press
intelligence agencies are making a
serious and concerted effort to influence
the U.S. election,” they said. “At the
least, this effort is intended to sow doubt
about the security of our election and
may well be intended to influence the
outcomes of the election.” They added
that “orders for the Russian intelligence Doctors are posting bikini selfies in protest of a
study that said it is 'unprofessional' for female
agencies to conduct such actions could medics to share bikini photos online
come only from very senior levels of the INSIDER

Russian government.”

Page came to the attention of officials at the U.S.

Embassy in Moscow several years ago when he showed
up in the Russian capital during several business trips
and made provocative public comments critical of U.S.
policy and sympathetic to Putin. “He was pretty much a
brazen apologist for anything Moscow did,” said one
U.S. official who served in Russia at the time.

He hasn’t been shy about expressing those views in the

U.S. as well. Last March, shorty after he was named by
Trump as one of his advisers, Page told Bloomberg News
he had been an adviser to, and investor in, Gazprom, the
Russian state-owned gas company. He then blamed
Obama administration sanctions — imposed as a
response to the Russian annexation of Crimea — for
driving down the company’s stock. “So many people who
I know and have worked with have been so adversely
affected by the sanctions policy,” Page said in the
interview. “There’s a lot of excitement in terms of the
possibilities for creating a better situation.”

Page showed up again in Moscow in early July, just two

weeks before the Republican National Convention Those face masks with breathing valves? They
aren't effective, doctors say
formally nominated Trump for president, and once
USA TODAY
again criticized U.S. policy. Speaking at a
commencement address for the New Economic School,
an institution funded in part by major Russian oligarchs
close to Putin, Page asserted that “Washington and
other West capitals” had impeded progress in Russia
“through their often hypocritical focus on ideas such as
democratization, inequality, corruption and regime
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change.” Investing.com Ad ...
At the time, Page declined to say whether he was
meeting with Russian officials during his trip, according
to a Reuters report.

Musician dad gives free trumpets to kids who

give up their guns, 'no questions asked'
Yahoo Life

Rosneft CEO Igor Sechin with Vladimir Putin at a signing ceremony at the St. Trump urges Americans to wear masks then
Petersburg International Economic Forum 2014. (Photo: Sergei appears without one to meet Little Leaguers
Karpukhin/Reuters) Yahoo News Video

But U.S. officials have since received intelligence reports

that during that same three-day trip, Page met with Igor
Sechin, a longtime Putin associate and former Russian
deputy prime minister who is now the executive
chairman of Rosneft, Russian’s leading oil company, a
well-placed Western intelligence source tells Yahoo Iraqi forces free German woman kidnapped in
Baghdad
News. That meeting, if confirmed, is viewed as especially AFP

problematic by U.S. officials because the Treasury

Department in August 2014 named Sechin to a list of
Russian officials and businessmen sanctioned over
Russia’s “illegitimate and unlawful actions in the
Ukraine.” (The Treasury announcement described
Sechin as “utterly loyal to Vladimir Putin — a key
component to his current standing.” At their alleged
Lindsey Graham Approval Poll
meeting, Sechin raised the issue of the lifting of Jaime Harrison For U.S. Senate Ad ...
sanctions with Page, the Western intelligence source
said.

U.S. intelligence agencies have also received reports that

Page met with another top Putin aide while in Moscow
— Igor Diveykin. A former Russian security official,
Diveykin now serves as deputy chief for internal policy
and is believed by U.S. officials to have responsibility for PHOTOS: John Lewis – congressman and civil
rights activist – a life of extraordinary service
intelligence collected by Russian agencies about the U.S. Yahoo News Photo Staff

election, the Western intelligence source said.

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 EXHIBIT 2
Trump Campaign: That Adviser Reportedly Talking With Russian Officials Isn’t An Adviser
Anymore, HUFFPOST (Sept. 25, 2016)
 ' Log In Join HuffPost Plus

NEWS CORONAVIRUS POLITICS 2020 ELECTIONS ENTERTAINMENT LIFE PERSONAL VIDEO U.S. Edition
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POLITICS 09/25/2016 12:01 pm ET | Updated Dec 19, 2016

Trump Campaign: That Adviser !

"
Reportedly Talking With Russian#

Officials Isn’t An Adviser Anymore

$
Note to Russia.
%
By Matt Fuller
&
Ad : (0:29)

WASHINGTON ― Carter Page, who reportedly has had

discussions with senior Russian officials about lifting economic
sanctions, is no longer an adviser to Republican presidential
nominee Donald Trump, campaign manager Kellyanne Conway
said Sunday.

Members of Congress have been briefed on Page discussing

sanctions relief with Russia, Yahoo News reported Friday. But
Conway said she has not spoken to Page about these talks
because he’s not part of the campaign anymore.
“Meaning he’s not part of our national security or foreign policy TRENDING
briefings that we do now at all, certainly not since I have become
Anthony Fauci Reveals
campaign manager,” Conway said.
‘Serious Threats’ To Himself,
His Family
It’s unclear when Page stopped advising the Trump campaign,
but Trump called him an adviser during a March interview with
Ivanka Trump Visits National
The Washington Post. Hope Hicks, a spokeswoman for the GOP Park In The Middle Of
nominee, said last month that Page was an “informal foreign Pandemic, And People Are
Ticked
adviser” who “does not speak for Mr. Trump or the
campaign,” Yahoo noted in its report.
Explosive UFO Report In NYT
Mentions ‘Off-World Vehicles
If Page is in talks with Russian officials, “he’s certainly not doing
Not Made On This Earth’
it with the permission or knowledge of the campaign,” Conway
said Sunday. She clarified that he is “certainly not authorized” to
Ex-GOP House Member:
be talking to Russia on behalf of the Trump campaign. Donald Trump’s ‘Cake Has
Been Baked’ On Coronavirus
Editor’s note: Donald Trump regularly incites political violence
and is a serial liar, rampant xenophobe, racist, misogynist and
Sean Hayes Plays Doctor,
birther who has repeatedly pledged to ban all Muslims — 1.6 Prescribes Cure For Anti-
billion members of an entire religion — from entering the U.S. Maskers On ‘Jimmy Kimmel’

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 EXHIBIT 3
Douglas Valentine’s CIA vs. Donald Trump’s CIA, HUFFPOST (Feb. 16, 2017)
 ' Log In Join HuffPost Plus

NEWS CORONAVIRUS POLITICS 2020 ELECTIONS ENTERTAINMENT LIFE PERSONAL VIDEO U.S. Edition
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Brad Schreiber, Contributor

Author-journalist-screenwriter

Douglas Valentine’s CIA vs. Donald

!

"
Trump’s CIA #
02/16/2017 04:18 pm ET

$
The firing of General Michael Flynn, Donald Trump’s former
%
national security adviser, for ties to Russian intelligence has
precipitated a certain chaos in the White House and Washington
&
that could determine whether there will be more revelations that
result in firings or whether we will see unparalleled control of
intelligence agencies by the so-called President of the United
States.

In an effort to battle the fallout from campaign advisors Paul

Manafort, Roger Stone and Carter Page having been caught by
the CIA and NSA for collusion with Russian intelligence officers,
This post was published on the now-
Trump has announced his intention to have billionaire Stephen closed HuffPost Contributor platform.
Feinberg, co-founder of Cerberus Capital Management, oversee Contributors control their own work and
posted freely to our site. If you need to
a broad review of this nation’s intelligence agencies. (Cerberus, flag this entry as abusive, send us an
appropriately, was in Greek mythology the multi-headed dog that email.

guarded the gates of the Underworld to prevent the dead from

leaving.)

Trump hopes to avoid further scrutiny regarding both his

business dealings with Russia and connections to Vladimir
Putin’s intelligence agents, using Feinberg, who has no national
security background. He is a crony of chief strategist Steve
Bannon, formerly of Breitbart News and Jared Kushner, whose
expertise is being the son-in-law of Trump. This is a crucial
moment in US history, as Trump attempts to stop leaks from the TRENDING
intel gatherers he has frequently criticized.
Anthony Fauci Reveals
‘Serious Threats’ To Himself,
One irony in the midst of what is clearly looming as a
His Family
constitutional crisis is the public perception of the role of the
Central Intelligence Agency. Steeped in a history of
Ivanka Trump Visits National
assassination, destabilization and infiltration of other Park In The Middle Of
governments, including working democracies, the Agency is Pandemic, And People Are
Ticked
now being counted upon by opponents of Trump’s intel
totalitariansism to be some kind of whistleblowing knight in
Explosive UFO Report In NYT
shining armor.
Mentions ‘Off-World Vehicles
Not Made On This Earth’
To understand how unexpected the above scenario is, one
needs to consider author Douglas Valentine’s recent book The
Ex-GOP House Member:
CIA As Organized Crime: How Illegal Operations Corrupt Donald Trump’s ‘Cake Has
America and the World. In it, he has laid out not only some of the Been Baked’ On Coronavirus
most egregious acts of the Agency but also how it now
dominates branches like the Drug Enforcement Agency and Sean Hayes Plays Doctor,
State Department. Prescribes Cure For Anti-
Maskers On ‘Jimmy Kimmel’
Valentine’s expansive, penetrating knowledge of the Central
Intelligence Agency began with his book The Phoenix Program,
the definitive work on the CIA-directed murder of between 25-
40,000 civilians during the Vietnam War, suspected of affiliation
with the Viet Cong, but without any kind of legal redress. These
Wake up to the day's
suspects, referred to as VCI or Viet Cong infrastructure, often most important
accused via hearsay, could only be released by bribing local news.
Vietnamese officials. As Valentine reports, CIA officer Lucien Subscribe to The Morning Email.
Conein called the Phoenix Program “the greatest blackmail
scheme ever invented. If you don’t do what I want, you’re a VC.” address@email.com

In addition to summarizing the Phoenix Program in his book,

Valentine takes us through a horrifying history of Agency abuses SUBSCRIBE
in the name of democracy. From Southeast Asia, where the CIA
funneled money to Laotian Hmong leader Vang Pao to fight
North Vietnam, with opium as a financial benefit to the Agency,
Valentine moves on to the CIA in the 80s. Here, he illuminates
how the Agency “coerced law enforcement agencies into
‘looking away’ in regard to both cocaine smuggling by the
Nicaraguan Contra terrorists and heroin trafficking by the
Northern Alliance warlords fighting the Soviets in Afghanistan.”
Valentine contemporizes the moral relativity of CIA operations,
the lesser-of-two-evils paradigm that historically morphs into the
creation of newer and more potent enemies of the US. After the
CIA used an early al-Qaeda to fight in Chechnya, Bosnia, Kosovo
and other locations, our support of Hamid Karzai and his
trafficking in opium led to an al-Qaeda committed to American
destruction. “This same scenario,” Valentine writes, “has been
playing out in Afghanistan for the last 15 years, largely through
the DEA’s Special Operations Division (SOD), whose sole
purpose is to provide cover for CIA operations worldwide.”
Our Community
And connecting the CIA’s geopolitical relativism to even more
current affairs, Valentine explores the recent failed support of
the rebels in Bashar al-Assad’s Syria. Valentine emphasizes that
“Iran publicly backs Assad, as does Russia, and that Iran seeks
to help Assad defeat the rebels, many of whom are foreign
mercenaries trained and financed by the CIA, Israel, Jordan,
1,146
Comments posted on HuffPost
Turkey and Saudi Arabia.” Never have CIA loyalties been more
today
confused and counterintuitive, Valentine asserts, than in a world
where factions of our sworn enemies al-Qaeda and ISIS aid us in
Comment
our failed attempt to depose Assad.

Now, FBI and Congressional investigations probe Trump’s

connections to Russia, which must include the previous oil and
gas business dealings of Secretary of State Rex Tillerson. Yet
there is serious doubt about how deeply they will dig. The FBI’s
James Comey was willing to sit on evidence about Michael Flynn
presented by then acting Attorney General Sally Yates. The
Republican controlled Congress and current Attorney General
Jeff Sessions, who worked on the Trump campaign, have no
commitment to actual revelations that would embarrass their
own party, even if those facts revealed treasonous actions.
AdChoices Sponsored
Thus, the CIA of old, who Douglas Valentine rightfully excoriates
for its illegalities in the name of American national interests, has
an unexpected and rare opportunity to remake its own image at
this point in history. Whether it is done in the name of preserving
CIA independence from Trump and people like Stephen
Feinberg or in the name of preserving democracy, it seems the
CIA, NSA and our intelligence partners around the world are now
the only source of enlightenment about Trump’s true relationship
to Putin’s Russia.

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 EXHIBIT 4
Was Trump Putin’s Fool Or His Partner In Crime?, HUFFPOST (Mar. 23, 2017)
 ' Log In Join HuffPost Plus

NEWS CORONAVIRUS POLITICS 2020 ELECTIONS ENTERTAINMENT LIFE PERSONAL VIDEO U.S. Edition
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Richard North Patterson, Contributor

Columnist
Columnist

Was Trump Putin’s Fool Or His Partner

!

"
In Crime? #
03/23/2017 01:39 pm ET | Updated Mar 24, 2017

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The FBI is investigating whether an American president colluded

with Russia to win the 2016 election.

Seventeen American intelligence agencies confirm that Russia

hacked the Democratic National Committee and Hillary Clinton’s
campaign chair to accomplish that. The remaining — and
historically remarkable — question is whether the web of
contacts between Donald Trump’s operatives and Russian
officials means that they criminally conspired to attack American
democracy.

As yet unexplained are numerous contacts between Trump

officials and Russian intelligence, some taking place in Europe TRENDING
and detected by the British and Dutch. Those we know about
Anthony Fauci Reveals
are disturbing.
‘Serious Threats’ To Himself,
His Family
Trump’s former national security adviser, Michael Flynn, took
money from entities affiliated with the Kremlin. He spoke with
Ivanka Trump Visits National
Russian Ambassador Sergey Kislyak numerous times during the Park In The Middle Of
campaign. After the election, they had several conversations Pandemic, And People Are
Ticked
concerning sanctions, about which Flynn lied, both in public and,
privately, to Mike Pence. Trump knew about these lies for weeks
Explosive UFO Report In NYT
before media reports compelled him to sever ties with Flynn.
Mentions ‘Off-World Vehicles
Not Made On This Earth’
Jeff Sessions met twice with Kislyak, then denied such meetings
during his confirmation hearing, a lapse requiring the attorney
Ex-GOP House Member:
general’s recusal from the current investigation. Trump foreign Donald Trump’s ‘Cake Has
policy adviser Carter Page met with the omnipresent envoy at Been Baked’ On Coronavirus
the GOP convention, just before Trump operatives stripped the
party platform of a pledge to aid Ukraine against Russian Sean Hayes Plays Doctor,
aggression. Prescribes Cure For Anti-
Maskers On ‘Jimmy Kimmel’
Then there’s Roger Stone, a longtime Trump adviser of dubious
reputation. Stone acknowledges contacts with Julian Assange,
Russia’s intermediary in leaking e-mails, and with the online
persona Guccifer 2.0, likely a front for Russian intelligence. More
curious yet, after the Russians leaked DNC e-mails through
From Washington to
WikiLeaks, Stone tweeted that “it will soon be [Clinton campaign the campaign trail, get
chair John] Podesta’s time in the barrel.” Shortly thereafter, the latest politics
WikiLeaks released Podesta’s e-mails. news.
Subscribe to the Politics email.
Paul Manafort, for five months Trump’s campaign chair, stands
address@email.com
accused of laundering millions of dollars received from the pro-
Russian former president of Ukraine. Recent reporting reveals
that, as early as 2006, Manafort was engaged by a Russian SUBSCRIBE
billionaire to advance Vladimir Putin’s political strategy in
Eastern Europe and, potentially, across Europe and the United
States.

Clearly, Trump’s real estate enterprise depends on Russian

money — a fact acknowledged in 2008 by Donald Trump Jr. —
though the extent of this reliance is unclear. There are
unexplained communications between a Trump computer server
and a bank connected to Putin. And Trump still withholds tax
returns, which could illuminate his financial connections to
Russia.

All this demands a serious investigation by the FBI — and

Congress — and there is likely more to discover. Already, these
threads mirror Russian efforts to undermine European
governments. Perhaps Trump and his campaign knew nothing
about Russia’s plans to help elect him. But his frenzied efforts to
squelch inquiry make Richard Nixon look like a model of
transparency — and sanity.

Trump’s lies grow more grotesque. His claim that Barack Obama Our Community
wiretapped him also slanders the FBI. But long before that, he
claimed that no one in his campaign had spoken to the Russians;
more recently, he lied contemporaneously about testimony by
James Comey.
1,146
In his hysteria, Trump makes liars of his lackeys, who torture
Comments posted on HuffPost
truth to excuse his falsehoods. Sean Spicer rationalized Trump’s today
slur about Obama until words lost all meaning. He falsely
claimed that British intelligence helped Obama wiretap Trump.
Comment
He said former campaign director Manafort “played a very
limited role.” He called Flynn – a principal adviser who traveled
with Trump throughout the campaign, who spoke at the GOP
convention, and who became Trump’s national security adviser –
“a volunteer.” For Spicer, all that remains is ritual harikari.

Trump reinforces mendacity with threats and distractions. He

threatens to hunt down the “lowlife leakers” who revealed the
New Era Of Internet Is Days Away
FBI investigation — “fake news” that Comey revealed to be true.
He threatened to deputize a friend to review US intelligence
Watch The Video
agencies. He tried to compel those agencies to support his lie Promoted Content

about Obama.
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Which raises a logical question: If you try to concoct evidence of
a lie, have you destroyed evidence of the truth? And another: Do
congressional Republicans want to know the truth?

With the exception of Senators John McCain and Lindsey

Graham, it seems not. Take Devin Nunes, chairman of the House
Intelligence Committee. He minimizes contacts between Russia
and Trump’s campaign, claiming there is no evidence of
collusion and, therefore, no need for the investigation that could
uncover it. Instead, he focuses on punishing those who revealed
the contacts.

On Wednesday Nunes visited the White House, without

informing his committee, to defend Trump by saying that legal
surveillance of Russians captured conversations with Trump’s
campaign. His purpose? To justify Trump’s lies about Obama. In
the process he confirmed the contacts, and provoked Adam
Schiff, the committee’s ranking Democratic member, to counter
that the evidence of collusion was now “more than
circumstantial.”

Americans must know whether Trump is merely Putin’s useful

fool or his partner in betraying our democracy. To avoid the truth
would be a betrayal all its own.

Richard North Patterson’s column appears regularly in the

Boston Globe. His latest book is “Fever Swamp.” Follow him on
Twitter @RicPatterson.

Do you have information you want to share with HuffPost?

Here’s how.

BEFORE YOU GO

01:57

Pelosi Calls Intel Chairman A

'Stooge' For Trump

MORE:

01:57
 EXHIBIT 5
Michael Flynn Pleads The Fifth And Refuses To Cooperate With Senate Russia Probe,
HUFFPOST (May 22, 2017)
 ' Log In Join HuffPost Plus

POLITICS 05/22/2017 10:25 am ET | Updated May 22, 2017

Michael Flynn Pleads The Fifth And Refuses

To Cooperate With Senate Russia Probe
The Senate intelligence committee subpoenaed documents from President
Donald Trump’s former national security adviser.

By Amanda Terkel

' Michael Flynn Pleads The Fifth And Refuses To Cooperate With Senate Russia
! " Probe
# % &

"

Former national security&

adviser Michael Flynn will not cooperate with a
Senate intelligence committee investigation, invoking his Fifth Amendment
right against self-incrimination Monday to avoid turning over documents
lawmakers have subpoenaed related to his interactions with Russian officials.

Flynn resigned in February, after it was revealed that he

/www.nytimes.com/2017/02/13/us/politics/donald-trump-national-security-
adviser-michael-flynn.html”}}” data-beacon-parsed=”true”>lied about whether
he had substantive contacts with the Russian ambassador before President
/www.huffingtonpost.com/topic/donald-trump”}}” data-beacon-
parsed=”true”>Donald Trump took office.

In a letter to the leaders of the Senate intelligence committee posted by the

Associated Press, Flynn’s lawyer said that without “assurances against unfair
prosecution,” he would “respectfully decline your request for an interview and TRENDING
for the production of documents.”
Anthony Fauci Reveals
‘Serious Threats’ To Himself,
“The context in which the Committee has called for General Flynn’s testimonial
His Family
production of documents makes clear that he has more than a reasonable
apprehension that any testimony he provides could be used against him,”
Ivanka Trump Visits National
Flynn attorney Robert Kelner wrote. “Multiple Members of Congress have Park In The Middle Of
demanded that he be investigated and even prosecuted. He is the target on Pandemic, And People Are
Ticked
nearly a daily basis of outrageous allegations... [that] feed the escalating public
frenzy against him.”
Explosive UFO Report In NYT
Mentions ‘Off-World Vehicles
“While we recognize General Flynn’s constitutional right to invoke the Fifth
Not Made On This Earth’
Amendment, we are disappointed he has chosen to disregard the Committee’s
subpoena request for documents relevant and necessary to our investigation,”
Ex-GOP House Member:
responded Sens. Richard Burr (R-N.C.) and Mark Warner (D-Va.), the chair and Donald Trump’s ‘Cake Has
ranking member, respectively, of the committee. “We will vigorously pursue Been Baked’ On Coronavirus
General Flynn’s testimony and his production of any and all pertinent materials
pursuant to the Committee’s authorities.” Sean Hayes Plays Doctor,
Prescribes Cure For Anti-
Trump kept Flynn in the administration long after the White House had been Maskers On ‘Jimmy Kimmel’
alerted to his ethics issues. Before Trump’s inauguration, Flynn had told the
transition team that he was under federal investigation for secretly lobbying for
the Turkish government during the campaign, according to The New York
Times. Even with this information, Trump named him national security adviser.
From Washington to
During the campaign, Flynn criticized the technology specialist who set up the campaign trail, get
Hillary Clinton’s private email server for invoking his Fifth Amendment rights the latest politics
during a court case. news.
Subscribe to the Politics email.
address@email.com
General Flynn
@GenFlynn

@HillaryClinton IT specialist takes 5th over 100 times. SUBSCRIBE

#Trump2016 #fieldoffight #AmericaFirst
twitter.com/mgf_83/status/…
4:40 AM · Jun 23, 2016

236 689 people are Tweeting about this

Trump has also blasted Clinton associates for pleading the Fifth, arguing, “If
you’re innocent, why are you taking the Fifth Amendment?”

The Senate intelligence committee has also requested documents from former
Trump adviser Carter Page, who is so far refusing to cooperate. He told
Business Insider Monday that he has no plans to plead the Fifth because he’s
“never done anything wrong.”
Trump continued to keep Flynn on the job after Sally Yates, the acting attorney Our Community
general, warned the White House that he could be subject to blackmail by the
Russians for hiding his contacts with the ambassador.

The president is now under fire for reports that he urged FBI Director James
Comey to drop his investigation into Flynn during an Oval Office meeting in
1,146
February. Trump fired Comey last week and admitted that the bureau’s Russia
Comments posted on HuffPost
probe was on his mind when he did so. today

The House intelligence committee also announced Thursday that it has

requested documents from the Justice Department and the FBI related to Comment

Comey’s dismissal and any conversations between Trump and the former FBI
director.

Subscribe to the Politics email.

From Washington to the campaign trail, get the latest politics
news.

address@email.com SUBSCRIBE

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Last week, Deputy Attorney General Rod Rosenstein named former FBI
Director Robert Mueller as the special counsel in charge of investigating
Russia’s role in the 2016 election.

According to a Congressional Research Service report, Congress has three

methods by which it can deal with Flynn’s non-compliance: It can detain and
imprison him until he complies, refer him to the executive branch (in this case,
the Department of Justice) for criminal prosecution, or seek a civil judgment
from a federal court that would compel Flynn to comply.

“Congress has to enforce the subpoena,” Sen. Marco Rubio (R-Fla.), a member
of the intelligence committee, said Monday. “We don’t have a police force
here, so it would require the Justice Department and the courts to do it.”

Burr declined to say last week whether he would recommend a contempt of

Congress vote regarding Flynn, stating, “I’m not going to go into what we
might or might not do. We’ve got a full basket of things we might want to test.”
 Sen. James Lankford
@SenatorLankford

It is Mike Flynn's right to plead the 5th. We will get to the

truth one way or another. We need facts, not speculation &
anonymous sources.
9:58 AM · May 22, 2017

137 114 people are Tweeting about this

NBC News reported Monday afternoon that two former Trump associates, Paul
Manafort and Roger Stone, turned over documents to the Senate intelligence
committee.

Laura Barron-Lopez contributed reporting.

This story has been updated to include official response from Flynn and the
Senate intelligence committee, along with responses from other Trump
associates.

Want more updates from Amanda Terkel? Sign up for her newsletter, Piping
Hot Truth, here.

Do you have information you want to share with HuffPost? Here’s how.

BEFORE YOU GO

PHOTO GALLERY

Donald Trump Meets With Russian Officials

( See Gallery

Amanda Terkel # Suggest a correction

Washington Bureau Chief, HuffPost

MORE:
 EXHIBIT 6
Trump’s Russian Connections Explain His Climate Change Denial, HUFFPOST (Sept. 29, 2016)
 ! "
NEWS CORONAVIRUS POLITICS BUSINESS LIFE PARENTS Ecpcfc"Gfkvkqp
PERSPECTIVES VIDEO

Catherine Bell At 51 Is Leaving Nothing To

Imagination READ MORE
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Kooc"ngv"{qw"fipkuj"dwv"—

Donald J. Trump
@realDonaldTrump

The concept of global warming was created by and for the

Chinese in order to make U.S. manufacturing non-
competitive.
11:15 AM · Nov 6, 2012

67.6K 107.8K people are Tweeting about this

Donald J. Trump
@realDonaldTrump

This very expensive GLOBAL WARMING bullshit has got to

stop. Our planet is freezing, record low temps,and our GW
scientists are stuck in ice
4:39 PM · Jan 1, 2014

5.5K 9.7K people are Tweeting about this

 Donald J. Trump
@realDonaldTrump

Any and all weather events are used by the GLOBAL

WARMING HOAXSTERS to justify higher taxes to save our
planet! They don't believe it $$$$!
1:40 PM · Jan 26, 2014

855 1.1K people are Tweeting about this

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05:12

Why Trump’s Russian Connection is a Big Problem

05:12
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 EXHIBIT 7
All The President’s Traitors, HUFFPOST (Mar. 23, 2017)
 ' Log In Join HuffPost Plus

NEWS CORONAVIRUS POLITICS 2020 ELECTIONS ENTERTAINMENT LIFE PERSONAL VIDEO U.S. Edition
SHOPPING

Jennifer Sabin, Contributor

Writer, political pundit, and former ABC News journalist

All The President’s Traitors

!

"
03/23/2017 04:16 pm ET | Updated Mar 24, 2017

#summer of 1974, when President

I was nine years old in the
Richard Nixon resigned. My 24-year-old sister made me watch,
$
recognizing the historic nature of that extraordinary moment. I
don’t remember much, except
% the multi-colored shag carpeting
and the small TV on a metal stand in the corner of our family
room, projecting Nixon’s&
defeated face to an exhausted country.
But I had a flashback to that moment Monday, watching O"cial Media Bias Poll
President Trump Wants to Hear
Congressman Adam Schiff’s eloquent, measured and damning
From You. Take the O8cial
recitation of the events as we know them thus far, connecting Mainstream Media Survey.

the Trump campaign to the Russians during the House

Intelligence Committee hearings. I was glued to the television, a
much bigger version than the one of my childhood.

08:20
Rep. Adam Schiff Lays Out
Evidence For Russian Involvement
In Presidential Election

08:20
The comparisons to Watergate are inevitable, but this is much TRENDING
bigger too. It’s almost impossible to stay abreast of the scandals
Anthony Fauci Reveals
swirling around President Trump and his campaign minions, to
‘Serious Threats’ To Himself,
keep track of the Russian contacts, Russian money and Russian His Family
secrets because they are coming at us with the unrelenting and
unnerving speed of semi-automatic rifle fire. Ivanka Trump Visits National
Park In The Middle Of
And just when you think you’ve got a handle on it all, out pops Pandemic, And People Are
Ticked
another villain, House Intel Chairman, Devin Nunes, proving that
Americans cannot trust the Republicans to run an investigation.
Explosive UFO Report In NYT
In an obvious attempt to come to the president’s aid like some
Mentions ‘Off-World Vehicles
knight in shining armor, Nunes inappropriately, maybe illegally, Not Made On This Earth’
revealed that Trump communications may have been
inadvertently picked up by surveillance of foreign agents. He not Ex-GOP House Member:
only offered that up to the media ― he also ran to President Donald Trump’s ‘Cake Has
Been Baked’ On Coronavirus
Trump to deliver the news, sidestepping Schiff and the
committee they both oversee. Thursday’s apology to that
committee was too little too late. Sean Hayes Plays Doctor,
Prescribes Cure For Anti-
Maskers On ‘Jimmy Kimmel’
Nunes should be removed from his position on the committee,
and the investigation must be conducted by an independent
commission, as Senator John McCain called for Wednesday. He
told MSNBC’s Greta Van Susteren, “no longer does the
Congress have credibility to handle this alone.” That’s one
From Washington to
Republican willing to put country, and truth, above party and lies.
But there aren’t many others.
the campaign trail, get
the latest politics
I don’t trust the Republicans to thoroughly investigate Trump’s news.
questionable financial dealings with Russian oligarchs, or the Subscribe to the Politics email.
lying Carter Page’s trips to Russia, or slimy Paul Manafort’s ten- address@email.com
million-dollar contract to promote Putin, or Mike Flynn’s sordid
foreign agent past, or the countless phone calls, and secret
meetings, or Rudy Giuliani. Remember during the campaign SUBSCRIBE
when the former NYC mayor hinted to Fox with glee that an
October surprise was in the works? And then there’s Roger
Stone, who tweeted on August 21st, “Trust me, It will be the (sic)
Podesta’s time in the barrel. #CrookedHillary.” Roger Stone is
one of the last guys in any room that Americans should trust.

We can’t trust the Republicans to do the right thing or reveal the

truth, and of course we can’t trust the President of the United
States – about anything. He has given us no reason to believe
him, and every reason to question his statements and tweets. I
don’t trust his spokespeople, Sean Spicer, Kellyanne Conway
and Sarah Huckabee Sanders, all of whom have knowingly lied
on the job. I don’t trust Stephen Miller or Steve Bannon, or even
Reince Priebus, who quietly aid and abet the liar-in-chief.

I don’t know whether to trust the FBI either. After what Director
Comey did to Hillary Clinton during the campaign, even as it
turns out the FBI was investigating the Trump campaign as early
as July, how can we be sure about his motives, his
thoroughness, his honesty? Will he reveal all? Will the Our Community
investigations dig as deeply as they must? Will a 2017 Deep
Throat emerge from the bureau? Will someone interview the
former British spy, Christopher Steele, who prepared that
infamous dossier?

I was feeling doubtful about the Democrats too, but along came
1,146
Comments posted on HuffPost
Rep Schiff. In the California congressman, we have a former
today
prosecutor, a man who appears to be intelligent, diligent,
determined, fair and so far, honest. He even told Rachel Maddow
Comment
that he would be willing to go to England to meet with Steele.
The man refrains from hyperbole ― he is thorough and credible.
And that’s just what this country needs right now. I am confident
that Schiff plus the many incredible reporters on this story, and
hopefully the intelligence community, will eventually uncover the
whole truth.
Sponsored
The Russia connections run wide and deep, and I do not believe
it possible that there are any coincidences at play here. Even
Rep. Schiff said in Monday’s hearing it was difficult to believe
that all of these contacts and relationships are just coincidences.
This administration is and has been in bed with Vladimir Putin,
and it may be a slow trickle that takes months to unravel, but it AdChoices Sponsored
will unravel.

Clearly, there are traitors in our midst. But they have all made
mistakes, and one by one, they are going to get tripped up by
them, and fall like a real-life house of cards.

Eventually the only question will be, just what are our elected
officials going to do about it all? Will they follow the lead of
Senator McCain and put country above party? An independent
commission would be an excellent start. And when all is said and
done, a TV resignation could be the inevitable conclusion.

Do you have information you want to share with HuffPost?

Here’s how.

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01:32
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01:32 News Republican Party

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 EXHIBIT 8
Trump’s ‘High Crimes’ – Not Treason, HUFFPOST (May 16, 2017)
 ' Log In Join HuffPost Plus

' Trump's 'High Crimes' -- Not Treason ! " # % &

Warren Goldstein, Contributor
Chair of the History Department, University of Hartford

Trump’s ‘High Crimes’ — Not Treason

!
05/16/2017 05:38 pm ET | Updated May 17, 2017

"

Yes or No? Is the Media Fair?

& Record Your Response to the
O0cial President Donald Trump
Media Poll. Start Now!

Monday morning as I sat down to write this piece I asked a law

professor friend for his “lawyerly” view of my using the word
“treason” to describe recent actions of the president of the
United States. He of course immediately referred me to the
Constitution itself, Article 3, Section 3 to be exact, where treason
gets its own section.

Treason against the United States shall consist only in

levying war against them, or in adhering to their enemies,
giving them aid and comfort. No person shall be convicted
of treason unless on the testimony of two witnesses to the
same overt act, or on confession in open court.
Pretty high bar, right? That was no accident, as James Madison TRENDING
explained in Federalist 43.
Anthony Fauci Reveals
‘Serious Threats’ To Himself,
But as new-fangled and artificial treasons have been the His Family
great engines by which violent factions, the natural
offspring of free government, have usually wreaked their Ivanka Trump Visits National
alternate malignity on each other, the [Constitutional] Park In The Middle Of
Pandemic, And People Are
convention have, with great judgment, opposed a barrier Ticked
to this peculiar danger, by inserting a constitutional
definition of the crime, fixing the proof necessary for Explosive UFO Report In NYT
conviction of it, and restraining the Congress, even in Mentions ‘Off-World Vehicles
Not Made On This Earth’
punishing it, from extending the consequences of guilt
beyond the person of its author.
Ex-GOP House Member:
Donald Trump’s ‘Cake Has
In other words, because accusations of treason were part of the Been Baked’ On Coronavirus

rough and tumble of politics even then, the framers defined it

precisely in the Constitution itself and made it hard to prove. In a Sean Hayes Plays Doctor,
Prescribes Cure For Anti-
persuasive piece for the Washington Post back in February, Maskers On ‘Jimmy Kimmel’
“Five Myths about Treason,” Prof. Carlton Larson of UC Davis
lays out just how restrictive treason law is. The fact that we’re
not formally at war with Russia means that even if Trump and his
sleazy minions (Paul Manafort, Carter Page, Michael Flynn, and
Roger Stone—what a bunch!) really did give “aid and comfort” to From Washington to
Vladimir Putin’s efforts to weaken the United States, they haven’t the campaign trail, get
committed treason.
the latest politics
That’s as far as I’d gotten when the Washington Post bombshell news.
exploded all over the Internet yesterday. Did anything change? Subscribe to the Politics email.
address@email.com
The New Yorker’s Andy Borowitz thought so: “Three Russian
Spies Meet in Oval Office,” he posted. “After approximately an
hour, the meeting broke up, with two of the spies leaving the SUBSCRIBE
Oval Office and the third remaining behind.” But being a spy isn’t
automatically treasonous. It might be criminal (The Espionage
Act), or impeachable (a high crime and misdemeanor) — but it’s
not treason. And despite, or perhaps because of Trump’s bluster
about his brain, I just don’t think he’s smart enough to be a spy
— or a mole, working craftily in the dark for years on behalf of his
secret masters. He needs affirmation, which the Sergeys, Lavrov
and Kislyak, by the looks of it, were all too happy to provide.
Can’t you just hear them? “Oh, that’s a good one, Mr. President!
Tell us another!”

Now that he’s connecting all of the dots for us, in plain sight, I
think it’s time to call him a Russian asset ― who can be played
by genuinely smart Russians just as easily as he is by his staff.

Consider his value as a Russian asset, one who has already 1)

derided and impeded his own government’s investigation into
his campaign’s ties to Russian intelligence; 2) changed his
party’s position on Russia’s annexation of Crimea; 3) defended
Our Community
and kept the national security advisor in office for 18 days after
learning that he was deeply compromised by Russian
intelligence; 4) retained an Attorney General who lied to
Congress about his contacts with the Russian Ambassador; 5)
disclosed top-secret intelligence to the Russian Ambassador and
Foreign Minister that they can almost certainly use to discover
1,146
Comments posted on HuffPost
the source of the intelligence, thus putting the source at grave
today
personal risk; and 6) likened his own intelligence community to
Nazi Germany. From Putin’s perspective, Trump’s only mistake so
Comment
far is that he’s generating too much pushback. But Putin wins
either way: by getting compliant policies or by turning American
politics into a nonstop circus.

In his oath of office, the president promised to “faithfully execute

the Office of President,” and, “to the best of my ability, preserve,
protect and defend the Constitution of the United States.”

Instead, Trump’s making a mockery of the office. Instead of Legend Who Bought Apple at $1.42 Says
Buy TaaS Now
defending the Constitution, he’s acting on behalf of a foreign
adversary, and making us less safe every day. Heads Putin wins, Watch The Video
Promoted Content
tails we lose. It may not be treason, but it sure looks like a “high
crime” to me. AdChoices Sponsored

NOTE: Just as I published this, news broke about Trump

asking Comey to drop his investigation of Michael Flynn. I
don’t think it changes any of the above, but I have newfound
sympathy for the reporters covering the White House. As soon
as they publish, they run the risk of being yesterday’s news.
Do you have information you want to share with HuffPost?
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 EXHIBIT 9
Friday’s Morning Email: The Latest In The Trump-Comey Saga, HUFFPOST (May 19, 2017)
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News After 27 Years READ MORE
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Friday’s Morning Email: The Latest In

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And Michael Flynn has yet to cooperate with the Senate Intelligence Committee.

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THE TRUMP-COMEY SAGA CONTINUES President Donald TRENDING
Trump lashed out against the idea of a “special counsel
Anthony Fauci Reveals
appointment” Thursday, saying it was harmful for the country.
‘Serious Threats’ To Himself,
More stories about former FBI Director James Comey’s thoughts His Family
on the president broke, including reports that Trump asked
Comey when the Feds would say he wasn’t under investigation, Ivanka Trump Visits National
as well as a detail about Comey attempting to blend into the Park In The Middle Of
Pandemic, And People Are
curtains at the White House to avoid interactions with Trump.
Ticked
Comey is 6’8”. Deputy Attorney General Rod Rosenstein told
senators Thursday that he knew Trump would fire Comey before
Explosive UFO Report In NYT
writing the infamous memo. All the while, Michael Flynn has yet Mentions ‘Off-World Vehicles
to cooperate with the Senate Intelligence Committee. And many Not Made On This Earth’
wonder why Trump continues to stand by the man despite
denouncing his ties to Paul Manafort and Carter Page. [HuffPost] Ex-GOP House Member:
Donald Trump’s ‘Cake Has
Been Baked’ On Coronavirus
TRUMP: FORMER SEN. JOE LIEBERMAN TOP PICK FOR FBI
DIRECTOR The other three candidates include “current acting
FBI Director Andrew McCabe; Frank Keating, the former Sean Hayes Plays Doctor,
Prescribes Cure For Anti-
governor of Oklahoma who previously served as an FBI agent Maskers On ‘Jimmy Kimmel’
and in high-level positions in the Justice Department; and
Richard McFeely, who served in the FBI for 24 years before
retiring as executive assistant director in 2014.” [HuffPost]

SWEDEN DROPS SEXUAL ASSAULT CHARGES AGAINST

From Washington to
JULIAN ASSANGE However, British police say the Wikileaks
founder would still be arrested if he left the Ecuadorian embassy
the campaign trail, get
in London. [Reuters]
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THIS VISUAL REPRESENTATION OF THE FLOOD THREAT
FROM A MELTING ANTARCTICA Doesn’t bode well for the
world. [NYT]

THE 2016 LITIGATION WILL NEVER END Former Vice President

Joe Biden said, “I never thought [Clinton] was the correct
candidate. I thought I was the correct candidate.” [HuffPost]
JASON CHAFFETZ RESIGNING FROM CONGRESS
SHORTLY The chairman of the House Committee on Oversight
and Government Reform announced he would step down by
June 30, leaving before his term concluded in 2019. He is
expected to head to Fox News. [HuffPost]

TIME IS RUNNING OUT TO COMBAT THE RISK OF FAMINE IN

SOMALIA “As their farms dry up and their cattle die, it’s
impossible for people, many of whom are herders who rely on
water, to escape the harsh environmental reality each day. They
leave their homes, walking miles on the parched dirt in search of
help.” [HuffPost] Our Community
WHAT’S BREWING
TRUMP’S DISASTER RELIEF POLICY RAISING CONCERNS AS
HURRICANE AND WILDFIRE SEASON NEARS The Trump
administration denied 99 percent of the aid North Carolina 1,146
Gov. Roy Cooper asked for following Hurricane Comments posted on HuffPost
today
Matthew. [HuffPost]

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THERE Could this be signaling for Prince Harry and Meghan
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is getting married tomorrow. Prepare yourself for the AdChoices Sponsored

onslaught. [Vanity Fair]

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BEFORE YOU GO
Roger Ailes is dead at 77.

Chelsea Manning shared the first photo of herself since

leaving prison.

Chris Cornell’s cause of death has been ruled a suicide.

It’s incredibly disturbing that this man broke into Amber

Rose’s house while she slept and just sat there for hours
before leaving.

You’ll soon be able to binge (and then be terrified

by) another Margaret Atwood creation.

We wish our parents had sent us to the kindergarten where

you get to play in the forest all day long.

Of course you’re going to love Harry Styles’ latest “Carpool

Karaoke.”

Don’t worry “This Is Us” fans ― William will be back for

Season 2.

We are all this dog attempting to do human exercises.

 T-Pain and Lil Wayne have collaborated for “T-Wayne.” How
did we not think of this earlier?

Trump and Toby Keith are holding a men-only concert in

Saudi Arabia.

The tweets that sum up married life in a nutshell.

Meet the workers who “sandblast Chernobyl’s radioactive

metal.”

Could you eat the “world’s hottest pepper?”

And have you paid attention to the news this past week?
Test your knowledge with this week’s HuffPost Headline
Quiz.

This article has been updated with new information about the
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 EXHIBIT 10
All The President’s Miscreants, Lowlifes and Villains, HUFFPOST (June 2, 2017)
 ! Log In Join HuffPost Plus

12 Insanely Cool Gadgets That Are Going to Sell

out This July

Jon Hotchkiss, Contributor

A 14 time Emmy nominee and host of Be Less Stupid

All The President’s Miscreants, Lowlifes

and Villains
06/02/2017 02:44 pm ET | Updated Jun 02, 2017

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closed HuffPost Contributor platform.
Contributors control their own work and
posted freely to our site. If you need to
See every episode of Be Less Stupid FREE @ factbox.tv flag this entry as abusive, send us an
email.

Did President Trump ALSO secretly meet with the Russians in

the spring of 2016?

NBC News reports the FBI has focused its attention on an

alleged meeting Donald Trump secretly held at the Mayflower
Hotel with the Russian Ambassador to the US in the spring of
2016. And so, the noose is getting tighter around his Presidency.
And when Attorney General Jeff Sessions got word of a
tightening noose, just out of habit, he jumped up and yelled,
“OK. You get the gasoline and cross. I’ll get the hoods.” TRENDING

As of today, nearly more members of Trump’s inner circle are Anthony Fauci Reveals
All by
The ‘Serious
" Threats’
# $To Himself,
! investigation
under thePresident's Miscreants,
FBI than there are who ain’t.Lowlifes
And it’s and Villains & '
His Family
getting harder and harder to remember who’s an alleged traitor
working for the commies… who’s just an ordinary Trump
Ivanka Trump Visits National
supporting dolt and who secretly thinks Kathy Griffin’s picture Park In The Middle Of
with Trump’s bloody head"was actually kinda cool. Pandemic, And People Are
Ticked
So, as the number of officials
# under investigation by the FBI,
Congress and federal courts gets higher than Woody Harrelson Explosive UFO Report In NYT
$ Mentions ‘Off-World Vehicles
on Ben And jerry’s Free Ice Cream day, here’s a comprehensive
Not Made On This Earth’
list so you can keep track.
%

#1. In addition to a new spotlight

& on President Trump, his Ex-GOP House Member:
Donald Trump’s ‘Cake Has
personal lawyer, Michael Cohen, was sent a subpoena to turn Been Baked’ On Coronavirus
' testimony to the investigators in
over documents and provide
the House and Senate.
Sean Hayes Plays Doctor,
Prescribes Cure For Anti-
If he refuses, Cohen could be jailed. Or, face an even worse Maskers On ‘Jimmy Kimmel’
punishment: remain working for Donald Trump.

#2. We learned last week that Jared Kushner is now ALSO the
subject of an FBI investigation… he too, is alleged to have held
secret meetings with the Russian ambassador last spring. Wake up to the day's
Kushner may have also committed treason if allegations are true
most important
that he attempted to set up a secret back channel to directly
communicate with Vladimir Putin.
news.
Subscribe to The Morning Email.
Reactions to this news have been mixed. The President
dismissed the charges against Kushner as quote “Locker room address@email.com
diplomacy.” Meanwhile, NBC fired Billy Bush again. Which is
kinda cruel right? because Billy Bush doesn’t work for NBC
anymore. SUBSCRIBE

#3. The FBI is also investigating former Trump Campaign boss,

Paul Manafort, for shady financial dealings and lobbying for the
Pro-Putin regime in the Ukraine. Manafort is accused of
accepting 12.7 million dollars in consulting fees – an amount
President Trump referred to as quote “Bronzer money.”

The FBI also alleges Manafort did not register as a foreign agent.
Plus, the FBI is looking into a 3.5 million dollar loan Manafort got
from a former Trump business partner the day after he left the
Trump campaign. A 3.5 million dollar loan every living creature
on earth… except Paul Manafort… has described as quote “really
fucking suspicious.”

#4. Former national security advisor, Mike Flynn is under

multiple investigations. The Pentagon inspector general wants to
know if Flynn violated military rules by accepting foreign
payments from Russia and Turkey – without registering as a
Foreign Agent.

Plus, the FBI has two other questions for Flynn. 1. Did he tell Our Community
Russia Trump’s administration would lift Obama’s sanctions in
return for help winning the election? And 2. Would he like soup
OR salad with his last meal before he faces the electric chair?

#5. President Trump’s former campaign aid, Roger Stone is also

1,146
being investigated by the FBI. He is accused of interfering in the
Comments posted on HuffPost
US election by communicating over the internet with a Russian today
hacker. And with releasing those stolen naked pictures of
Scarlett Johansen.
Comment

Subscribe to The Morning Email.

Wake up to the day's most important news.

address@email.com SUBSCRIBE

#6. Carter Page, whose secret service code name is: “Gomer
Pyle. But Dumber,” is another of Trump’s former advisors, now AdChoices Sponsored
under investigation by the FBI. In the summer of 2016, a US court
OK’d wiretapping his communications when allegations surfaced
he was being cultivated as a source for a Russian spy.

#7. Congressman Devin Nunes is the former leader of the

House’s investigation of Trump. HOWEVER — he is now being
investigated by the House Ethics Committee for revealing to
Trump team members that they themselves were picked up on
legal wire taps of foreign nationals.

When Mike Flynn faces the electric chair, Devin Nunes is his plus
one.

#8. NBC News has ALSO revealed that former Trump associate
and press aide Boris Epshteyn has been contacted by the
House Intelligence committee. They are determined to find out
Epshteyn’s grandmother’s Passover kugle recipe.

I’m kidding. It’s about colluding with Russia.

Investigative committees are also interested in…

#9. US attorney general, Jeff Sessions, who was forced to

recuse himself from the Trump Russia investigation after getting
caught failing to report at least one meeting – and perhaps now
as many as three — with the Russian ambassador to the US.

Think we’re done? Nope. There’s MORE!

#10. THE federal election commission has been alerted to

alleged illegal monies paid to White House advisor Steve
Bannon – of almost 1 million dollars. Bannon has been accused
of illegally coordinating activities between Trump’s campaign
and a Super Pac. AND with being a sick, dangerous fuck. And
yes, those are legal terms.

OK. So, there you have it. A murderer’s row of miscreants,

lowlifes and villains.

Be Less Stupid: Episode #51 - Miscreants, Liars and …

Jon Hotchkiss is a 14 time Emmy nominated comedy writer and
host of Be Less Stupid, which has been called “The Daily Show
meets Popular Science.”

Popular in the Community

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 EXHIBIT 11
The Exxon-Treasury Fight And The Roots of Russiagate, HUFFPOST (July 30, 2017)
 ' Log In Join HuffPost Plus

Learn To Coach Your Teams

OPEN
Experts in advanced systems and team coach training for leaders, professionals
& coaches. CRR Global U.S.

David Halperin, Contributor

Attorney, advocate, writer at RepublicReport.org

The Exxon-Treasury Fight And The Roots

Of Russiagate
Putin and Exxon have aimed relentlessly at ending U.S. sanctions, but scandal and
Congress have now tied Trump’s hands.
07/30/2017 10:14 am ET | Updated Jul 30, 2017

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This article was co-written with Kert Davies.
%
When the Treasury Department announced on July 20 that it
had fined ExxonMobil $2&
million for violations of U.S. sanctions
against Russia, there were multiple ways to view the dispute.
Was it best understood as an awkward battle pitting Treasury
Secretary Steven Mnuchin against Secretary of State Rex
Tillerson, who was ExxonMobil’s CEO at the time of the alleged
misconduct? Was the decision a case of principled career
Treasury staff standing up to Exxon and Russian bad behavior in TRENDING
defiance of pro-fossil fuel, pro-Putin President Trump? Was
Anthony Fauci Reveals
Tillerson, given Exxon’s alleged defiance of U.S. law on his
‘Serious Threats’ To Himself,
watch, morally qualified to be our nation’s chief diplomat? Was His Family
the Treasury action the final insult for Tillerson, who seems to
have been frustrated at every turn by Trump and his own lack of Ivanka Trump Visits National
effectiveness, triggering a resignation? Park In The Middle Of
Pandemic, And People Are
Ticked
But the most relevant context for the Treasury fine on Exxon is,
in fact, the thing we’re all talking about anyway: Russiagate.
Explosive UFO Report In NYT
Mentions ‘Off-World Vehicles
As we wrote back in February, if there was, in fact, a corrupt
Not Made On This Earth’
bargain between the Trump campaign and the Russian
government, or a tacit understanding, the outlines of the deal
Ex-GOP House Member:
seem straightforward. Trump wanted help to win the most Donald Trump’s ‘Cake Has
prestigious and potentially lucrative prize available in America: Been Baked’ On Coronavirus
the Oval Office. What Vladimir Putin wanted most, what he has
wanted desperately for several years, is also crystal clear: for the Sean Hayes Plays Doctor,
next U.S. president to lift the major sanctions that have been Prescribes Cure For Anti-
Maskers On ‘Jimmy Kimmel’
strangling the Russian economy. And Trump repeatedly signaled
as a candidate that he might do just that.

To be sure, there were reasons besides the sanctions that Putin

might have wanted to help Trump win: Trump lacked Hillary
Clinton’s national security and government experience and thus
From Washington to
was potentially a weaker adversary; Trump was calling into the campaign trail, get
question U.S. alliances and commitments overseas, including the latest politics
NATO; and Trump repeatedly expressed personal admiration for news.
Putin. As president, Donald Trump seems, disgracefully, to have Subscribe to the Politics email.
exceeded all possible expectations as to these factors. address@email.com

Putin also could have believed that even if Russian interference

did not manage to swing the election to Trump, the email hacks SUBSCRIBE
and other measures could embarrass Clinton, weaken her
presidency, create a sense of chaos, and give Russia new
advantages.

But the chance to rescue the flagging Russian economy by

electing Trump and eliminating the sanctions certainly would
have loomed large for the Kremlin leader.
And in this regard, at this point, it seems that the whole scheme
may have backfired. Trump was elected, but his presidency is in
total disarray, in part under the weight of the mounting
investigation of the campaign’s Russia ties. Tillerson became
Secretary of State, which must have thrilled Putin, and the
Russian state oil company that had signed extensive
agreements with Exxon, but his influence seems to be minimal. Are You a Trump Supporter?
And political pressure on Trump from Russiagate has greatly Yes or No
reduced the likelihood that the U.S. will relax its Russia sanctions
any time soon; indeed, Congress has just forced Trump to agree
to tighten them.

Putin’s Relentless Effort to End U.S. Sanctions Our Community

The concept of an election help/ sanctions relief deal is reflected

in the story of the crowded June 2016 Trump Tower meeting:
Donald Trump Jr. jumped at the emailed offer of dirt on Hillary
Clinton from the Russian government, and pulled in Trump son- 1,146
in-law Jared Kushner and campaign chairman Paul Manafort. But Comments posted on HuffPost
when the Russians showed up, Trump Jr. and Kushner have each today
claimed, they mostly wanted to talk about “adoption.” President
Trump told the New York Times that in their extra discussion at Comment
the G20, Putin also wanted to talk about adoptions, “which is
interesting because it was a part of the conversation that Don
had in that meeting.” Interesting, sure, because “adoptions”
really meant sanctions.

The Russians weren’t raising Putin’s ban on U.S. adoptions of

Russian children because they care about orphans; Putin
imposed the adoption ban in response to the 2012 U.S.
Magnitsky Act sanctions against a group of powerful Russians
who are suspected of playing a role in the death of a
whistleblowing Russian lawyer. These are penalties that Putin
wants lifted.
AdChoices Sponsored

But the 2012 Magnitsky sanctions were not nearly as critical for
Russia’s economy, and thus for Putin, as the sanctions imposed
by President Obama from March to July 2014 in response to
Russia’s annexation of the Ukrainian territory of Crimea. Those
Crimea sanctions, as implemented by Treasury, prohibit U.S.
companies from doing business with a group of even more
powerful Russians, including Igor Sechin, a close associate of
Putin and the head of Rosneft, the Russian state-owned oil
company. When it issued the sanctions, Treasury said that
Sechin “has shown utter loyalty to Vladimir Putin - a key
component to his current standing.” The sanctions also bar U.S.
deals with Rosneft itself and with other Russian businesses,
including Vnesheconombank, whose Putin-connected CEO met
with Kushner last December at the insistence, according to
Kushner, of ubiquitous Russian ambassador Sergey Kislyak.

Putin’s drive to overturn the U.S. sanctions also led to the

sudden departure of national security advisor Michael Flynn, less
than a month after Trump’s inauguration, supposedly for
misleading the White House about his multiple phone calls with
Kislyak. The apparent hook for those calls was President
Obama’s Dec. 29 imposition of new sanctions against Russia ―
expelling 35 suspected Russian spies from the United States,
penalizing Russia’s two major intelligence services, and kicking
the Russians out of waterfront mansions in New York and
Maryland believed to be used for intelligence operations.
Obama imposed this last round of penalties in the wake of U.S.
intelligence findings that Russia had aimed to tilt the election to
Trump by hacking emails and spreading disinformation.

Although transcripts of the calls from intelligence community

intercepts have not been publicly released, the Washington Post
reported that some senior U.S. officials interpreted Flynn’s words
as signaling that Moscow could expect a lessening of the
sanctions. On Dec. 30, Putin announced that Russia would not
impose retaliatory sanctions, and instead would wait and see
what President Trump did after he was sworn in, a decision that
Trump promptly praised on Twitter (“Great move on delay (by V.
Putin) ― I always knew he was very smart!”)

At his only solo press conference as president, back in February,

Trump said, as to whether Flynn discussed the sanctions with
Kislyak in December, “It would have been okay with me … I
would have directed him if I thought he wasn’t doing it.”

Also in February, the New York Times reported that Michael

Cohen, Trump’s long-time lawyer, hand-delivered to Flynn, the
week before he resigned, a proposal for a Russia-Ukraine peace
deal that included lifting the U.S. sanctions. The plan was
endorsed by Cohen, Felix Sater, a Russian-American
businessman with longstanding connections to Trump, and a
Ukrainian opposition politician.

(In addition, the unconfirmed intelligence dossier created by ex-

MI6 agent Christopher Steele includes the allegation that Trump
campaign adviser Carter Page met last summer with Rosneft’s
president Sechin and a senior Russian government official and
that “Sechin’s associate said that the Rosneft president was so
keen to lift personal and corporate western sanctions imposed
on the company, that he offered Page and his associates the
brokerage of up to a 19 percent (privatized) stake in Rosneft. In
return, Page had expressed interest and confirmed that were
Trump elected U.S. president, then sanctions on Russia would
be lifted.”)

It’s clear from all these episodes that the Russians have been
focused like a laser on getting Donald Trump to lift or relax the
U.S. sanctions.

Exxon’s Sanctions Violation

Other than the relentless Kremlin, the entity that most wants to
be free of these restrictions, it seems, is ExxonMobil.

In April of this year, ExxonMobil asked Treasury for a waiver of

the Russia sanctions so it could proceed efforts with Rosneft to
drill in the Black Sea. Treasury denied the request.

On July 20, Treasury’s Office of Foreign Assets Control (OFAC)

concluded that Exxon violated U.S. sanctions in May 2014 when
its officials signed a series of agreements with Sechin on behalf
of Rosneft.

Even though the $2 million fine is a drop in the Arctic Ocean

compared with Exxon’s annual revenue of some $225 billion,
Exxon promptly sued Treasury, claiming that it had received
guidance from Obama Administration that indicated it was legal
to make a deal with Sechin acting in his official capacity for
Rosneft, as opposed to acting personally. At the time of the
contract signings, U.S. sanctions announced in April 2014 were
already in effect against Sechin, but the broader prohibition
against Rosneft wasn’t imposed until July 2014.

But Treasury says the April sanctions offered no such loophole

and that Exxon, in signing the deals with Sechin, “demonstrated
reckless disregard” for the law.

The Russia-Exxon Deal

While the new $2 million penalty focuses on the 2014 contracts,

the biggest deal that the U.S. sanctions shut down was the
remarkable 2011 agreement that Putin, Sechin, and Rosneft
brokered with Exxon and Tillerson. The plum in this deal,
potentially worth hundreds of billions of dollars, was new
exploration for offshore oil and gas in the Russian Arctic. (The
drilling deal was facilitated by global warming that has melted
Arctic ice; some have asked whether Exxon was sharing with
Rosneft its knowledge and modeling of accelerating climate
change, even as it continued to fund efforts to conceal the risks
of climate change from the American people.)

A 1988 CIA secret report, since declassified, underscores the

value of the Arctic deal. According to the report, the Kara Sea,
the place where Exxon and Rosneft later targeted their major
offshore operations, “could become one of the major petroleum
regions in the USSR early in the next century.” But the agency
judged that development was unlikely without joint ventures
with Western oil companies. Twenty-three years later, Exxon
stepped into the very role the CIA predicted.

Oil and gas revenue has accounted for upwards of 70 percent of

Russia’s export income and 40 to 50 percent of the Russian
budget over the past decade.
 Subscribe to the Politics email.
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The Russian Arctic alone is said to hold upwards of 90 billion

barrels of oil. And Rosneft has exclusive access, granted by
Putin. The Rosneft deal was also crucial for Exxon’s future,
allowing it to book massive reserves unavailable elsewhere on
earth, before the sanctions shut it down.

A glut of oil on the global market has crashed oil prices and
tanked the Russian economy in the last few years. Nonetheless,
Russia is now second to the United States in oil and gas
production, and only the U.S. fracking boom of the past five
years puts the U.S. in the lead. And in brokering the Russian
deal, Exxon promised to teach Rosneft to frack, with made-in-
America technology and equipment. This step would inevitably
lead to a Russian glut of oil and gas production, just as the U.S.
is now experiencing. That would further depress global energy
prices, and make U.S. oil and gas less competitive and less
profitable on the global market. The dubious “American Energy
Dominance” goal set by Trump would surely be undermined.

One might ask how allowing this deal to proceed would help the
United States anywhere except at Exxon headquarters. But the
deal has the potential to make Russia great again.

Trump and Tillerson on the Sanctions

While Trump and Tillerson have appeared to be at odds on a

range of policy and personnel decisions since January, the one
thing they have seemed to agree upon is opposition to Russia
sanctions.

Trump as a candidate promised that he “would be looking into”

recognizing Crimea as part of Russia and lifting the Obama
sanctions. A few days later Trump told an interviewer that “the
people of Crimea, from what I’ve heard, would rather be with
Russia.”

On Jan. 16, president-elect Trump returned to the subject, saying

he might propose a deal under which the U.S. would end its
Crimea sanctions if Russia agreed to a nuclear arms agreement.
“Russia’s hurting very badly right now because of sanctions,”
Trump said, “but I think something can happen that a lot of
people are gonna benefit.”

(Although Trump reportedly told Ukrainian opposition leader

Yulia Tymoshenko in February that he would not lift the
sanctions until Russia withdrew from Ukraine, that could have
been a case of the low-knowledge Trump listening to the last
interesting person he talked with, or else wishful thinking by
Tymoshenko.)

Buttressing the idea that Trump was preparing to lift the Russia
sanctions was his choice for secretary of state. Rex Tillerson had
no diplomatic or government experience. Instead, he had spent
41 years at Exxon.

As an Exxon executive, Tillerson got to know Putin and

developed strong personal ties to Rosneft head Sechin, an ex-
KGB agent; the two men enjoyed riding motorcycles together.
Tillerson’s advancement to be ExxonMobil CEO was preceded
by his appointment in 1998 to run Exxon Neftegas Limited, the
division in charge of an Exxon-Rosneft project drilling for oil near
Sakhalin Island off the Siberian coast. The project has produced
hundreds of millions of barrels of oil in the last 12 years. Because
it doesn’t involve new technology transfer, it has been able to
proceed despite the U.S. sanctions.

In 2012, Russia awarded Tillerson one of its highest honors, the

Order of Friendship decoration.

Despite Tillerson’s denials at his confirmation hearing, Exxon

lobbied against Obama’s 2014 sanctions on Russia and Sechin.
At Exxon’s annual meeting in May 2014, after the U.S. imposed
sanctions on Sechin but before imposing them on Rosneft,
Tillerson told reporters, “There has been no impact on any of our
business activities in Russia to this point, nor has there been any
discernible impact on the relationship” with Rosneft. “The
organizations continue to work business as usual.” He added,
according to the Associated Press, that “he generally opposes
sanctions as imprecise and ineffective. He said he has discussed
his view with U.S. officials. He declined to identify them but said,
‘Our views are being heard at the highest levels.’”

Tillerson did not know Trump prior to election day. He was,

reportedly, recommended to Trump by former Secretary of State
Condoleeza Rice and former Secretary of Defense Robert Gates.
But those two were not merely national security heavyweights
from prior administrations; they now work in the same consulting
firm, whose clients include ExxonMobil. So the push to make
Tillerson Secretary of State could be seen, in part, as consistent
with Exxon’s own efforts to influence the Trump administration,
including on the issue of the sanctions blocking the Exxon-
Russia deal.

Although Tillerson has been notably missing from key Trump

meetings and his views often overruled, he was the only other
U.S. official in the room when Trump met with Putin at the G20
meeting in Hamburg earlier this month.

As president, Trump has continued to push back on pressure

from all sides, including Republicans in Congress, to accept the
overwhelming evidence that Russia sought to hack the U.S.
election, which was the basis for the last round of Obama
sanctions on Russia. Some days Trump grudgingly admits it, sort
of. And other days he rebels. Last Sunday on CNN’s “State of the
Union,” energetic new White House communications director
Anthony Scaramucci cited the argument of an unnamed expert
that if it had been the Russians who hacked the U.S. election, we
never would have found out, because the Russians are so
smooth at hacking. Pressed by host Jake Tapper as to the
identity of the expert, Scaramucci said: It was Trump. It turned
out that Trump got that talking point from Vladimir Putin.
It seems clear that Trump’s resistance to blaming Russia for the
hack arises in part from his obsession with proving that he won
the election overwhelmingly and in legitimate fashion. But
there’s also that powerful hold that Putin seems to have over
him.

The New Sanctions Legislation and Putin Response

As evidence has mounted that Russiagate is real ― that Putin

sought to influence the election, that Trump campaign officials
had a web of ties and meetings with Russian government
officials and other powerful Russians, that Trump officials have
repeatedly failed to disclose such interactions, and that Trump
pressured FBI director James Comey to drop the Flynn
investigation and then fired Comey when he didn’t ― Congress
has been moved to commit the U.S. to the opposite course on
sanctions from what Putin has sought.

On Tuesday, the House of Representatives, by a vote of 419 to 3,

passed legislation to tighten U.S. sanctions on Russia, as well as
Iran and North Korea, and to constrain the ability of the president
to soften or waive them.

The Senate passed similar sanctions legislation in June, by a

vote of 98 to 2, and Senate Foreign Relations Committee
chairman this month backed off some previous objections to the
House version.

The Trump White House lobbied aggressively against the

sanctions bills, in particular a provision that would require
Congress to approve any steps to loosen the sanctions on
Russia.

Tillerson, although he committed to Senators during his

confirmation process to recuse from matters relating to Exxon,
had publicly argued against sanctions legislation, saying it would
undercut the administration’s flexibility in making deals with
Russia.

The legislation was weakened in recent days, as the Washington

Post explained, “to address some administration concerns,
including its potential effect on overseas oil and gas projects
that include Russian partners.”

ExxonMobil, as well as other energy companies, also had

lobbied against these provisions, on the same grounds.

According to a Wall Street Journal report: “Lobbyists for Exxon

and other oil industry players have expressed dismay to
lawmakers about several provisions in the legislation, including
measures to prohibit partnerships with Russian individuals or
companies under sanctions around the world, and to add
congressional review of certain sanctions exemptions ... Exxon
spokesman Alan Jeffers said the company doesn’t have a
position on sanctions but has provided legislators with
information about how the bill could ‘disadvantage U.S.
companies compared to our non-U.S. counterparts.’” Exxon was
reportedly concerned, among other things, about the fact of its
joint projects with Rosneft in New Mexico and Canada.

But the bill, even as modified, remains a barrier to the easing of

Russia sanctions that Putin has sought, and thus, in particular, a
barrier to the lucrative Exxon-Rosneft Arctic deal.

The White House hedged for week as to whether Trump would

sign or veto the legislation. Press Secretary Sarah Huckabee
Sanders said last week that Trump “has been very vocal about
his support for continuing sanctions on those three countries.”
But she added that Trump “wants to make sure we get the best
deal for the American people possible ... Congress does not
have the best record on that. . . . He’s going to study that
legislation and see what the final product looks like.”

Vladimir Putin, unlike Trump, could count votes, and knew that
even a Trump veto would likely be overridden by Congress. So
Friday morning, Putin tried a new take, implementing the
retaliation he put on hold in December. Russia seized two U.S.
diplomatic properties in the Moscow area ― a warehouse a
collection of rustic cottages ― and ordered the U.S. to cut its
staff in Russia down to 455, matching the number of Russian
diplomats in the U.S. “It’s impossible to endlessly tolerate this
kind of insolence toward our country,” Putin said Friday.
Friday afternoon the White House announced that Trump would
sign the bill, tightening the grip of the Russia sanctions ― the
opposite of what candidate Trump had proposed.

Still, Putin and Trump seem unlikely to stop pursuing their

bromance, seemingly driven by a mutual love of autocratic
government, of pressuring the media and judiciary to do their
bidding, of their white nationalist fans, and of mingling their
financial interests with their government power, as well as their
agreed-upon liquids of choice, oil and gas.

Whatever the fate of its former CEO Tillerson in the Trump

government, and despite its current tiff with Treasury,
ExxonMobil, along with Sechin and Rosneft, will be waiting in the
wings, hoping that a new era of detente will unleash boundless
new fossil fuel production and profits.

Kert Davies directs the Climate Investigations Center. David

Halperin, a lawyer, formerly worked at the National Security
Council and the Senate Intelligence Committee. This article also
appears on Republic Report.

Do you have information you want to share with HuffPost?

Here’s how.

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01:19

Exxon Sues Treasury Department

Over Russia Sanction Fines

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01:19
 IN THE SUPERIOR COURT FOR THE STATE OF DELAWARE

CARTER PAGE, an individual,

Plaintiff,

v. C.A. No.

OATH INC., a corporation,

Defendant.

PRAECIPE
TO: The Prothonotary
Superior Court of the State of Delaware
Sussex County Court House
1 The Circle, Suite 2
Georgetown, DE 19947

PLEASE ISSUE A SUMMONS to the Sheriff of New Castle County,

commanding him to summon and direct the below-listed Defendant, to appear and

answer the Complaint in this case, by delivering copies of the aforesaid Summons

and Complaint to the Defendants listed below in accordance with the Rules of Civil

Procedure.

OATH INC.
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
Dated: July 27, 2020
Sean J. Bellew, Esq. (#4072)
BELLEW LLC
2961 Centerville Road, Suite 302
Wilmington, DE 19808
Telephone: (302) 353-4951
Email: sjbellew@bellewllc.com

Counsel for Plaintiff Carter Page

 EFiled: Jul 27 2020 10:37AM EDT
Transaction ID 65799719
Case No. S20C-07-030 CAK
IN THE SUPERIOR COURT FOR THE STATE OF DELAWARE

CARTER PAGE, an individual,

Plaintiff,

v. C.A. No.

OATH INC., a corporation,

Defendant.

SUMMONS

THE STATE OF DELAWARE,

TO THE SHERIFF OF NEW CASTLE COUNTY:
YOU ARE COMMANDED:

To summon the above named Defendant, OATH INC., c/o its Registered
Agent, The Corporation Trust Company, Corporation Trust Center 1209 Orange
Street, Wilmington, DE 19801, so that, within 20 days after service hereof upon
Defendant, exclusive of the day of service, Defendant shall serve upon Sean J.
Bellew, Plaintiffs’ counsel, whose address is Bellew LLC, 2961 Centerville Road,
Suite 302, Wilmington, DE 19808, an Answer to the Complaint (and, if an Affidavit
of Demand has been filed, an Affidavit of Defense).

To serve upon Defendant a copy here to of the Complaint (and if an Affidavit

of Demand if any has been filed by Plaintiff).

Date: , 2020 Myrtle A. Thomas

Prothonotary

Per Deputy
TO THE ABOVE NAMED DEFENDANT:

In case of your failure, within twenty (20) days after service hereof upon you,
exclusive of the day of service, to serve on Plaintiff’s attorney named above an
Answer to the Complaint (and, if an Affidavit of Demand has been filed, an Affidavit
of Defense), judgment by default will be rendered against you for the relief
demanded in the Complaint (or in the Affidavit of Demand, if any).

Myrtle A. Thomas
Prothonotary

Per Deputy
 SUPERIOR COURT
CIVIL CASE INFORMATION STATEMENT (CIS)
EFiled: Jul 27 2020 10:37AM EDT
Transaction ID 65799719
Case No. S20C-07-030 CAK
COUNTY: N K S CIVIL ACTION NUMBER:__________________________

Caption:
CDEF
Civil Case Code: ___________
CARTER PAGE, an individual,
_______________________________________ Defamation
Civil Case Type: ________________________________
(SEE REVERSE SIDE FOR CODE AND TYPE)
Plaintiff,
_______________________________________
MANDATORY NON-BINDING ARBITRATION (MNA) ______
v.
_______________________________________ Name and Status of Party filing document:

OATH INC., a corporation,

_______________________________________ Carter Page, Plaintiff
_________________________________________
Defendant.
_______________________________________ Document Type:(E.G.; COMPLAINT; ANSWER WITH COUNTERCLAIM)

_______________________________________ Complaint
_________________________________________

X
JURY DEMAND: YES ____ NO ____

ATTORNEY NAME(S): IDENTIFY ANY RELATED CASES NOW PENDING IN THE SUPERIOR COURT OR ANY
RELATED CASES THAT HAVE BEEN CLOSED IN THIS COURT WITHIN THE LAST
Sean J. Bellew
_______________________________________ TWO YEARS BY CAPTION AND CIVIL ACTION NUMBER INCLUDING JUDGE’S
INITIALS:
ATTORNEY ID(S):
N/A
________________________________________________
#4072
_______________________________________
FIRM NAME:
________________________________________________
Bellew LLC EXPLAIN THE RELATIONSHIP(S):
_______________________________________
ADDRESS:
_______________________________________
2961 Centerville Road, Suite 302
_______________________________________
_______________________________________
Wilmington, DE 19808
_______________________________________
TELEPHONE NUMBER: _______________________________________

(302) 353-4951
_______________________________________ _______________________________________
FAX NUMBER: OTHER UNUSUAL ISSUES THAT AFFECT CASE MANAGEMENT:

_______________________________________ N/A
_______________________________________
E-MAIL ADDRESS:
_______________________________________
sjbellew@bellewllc.com
_______________________________________
_______________________________________
(IF ADDITIONAL SPACE IS NEEDED, PLEASE ATTACH PAGE)

THE PROTHONOTARY WILL NOT PROCESS THE COMPLAINT, ANSWER, OR FIRST RESPONSIVE PLEADING IN THIS MATTER FOR SERVICE UNTIL
THE CASE INFORMATION STATEMENT (CIS) IS FILED. THE FAILURE TO FILE THE CIS AND HAVE THE PLEADING PROCESSED FOR SERVICE MAY
RESULT IN THE DISMISSAL OF THE COMPLAINT OR MAY RESULT IN THE ANSWER OR FIRST RESPONSIVE PLEADING BEING STRICKEN.

Revised 01/2019
 SUPERIOR COURT CIVIL CASE INFORMATION STATEMENT (CIS)
INSTRUCTIONS
CIVIL CASE TYPE
Please select the appropriate civil case code and case type (e.g., CODE - AADM and TYPE - Administrative Agency) from
the list below. Enter this information in the designated spaces on the Case Information Statement.

APPEALS MISCELLANEOUS
AADM - Administrative Agency MAGM - AG Motion - Civil/Criminal Investigations *
ACER - Certiorari MADB - Appeal from Disability Board *
ACCP - Court of Common Pleas MAFF - Application for Forfeiture
AIAB - Industrial Accident Board MAAT - Appointment of Attorney
APSC - Public Service Commission MGAR - Appointment of Guardianship
AUIB - Unemployment Insurance Appeal Board MCED - Cease and Desist Order
MCON - Civil Contempt/Capias
COMPLAINTS MCVP - Civil Penalty
CABT – Abatement MSOJ - Compel Satisfaction of Judgment
CASB – Asbestos MSAM - Compel Satisfaction of Mortgage
CAAA - Auto Arb Appeal MCTO - Consent Order
CMIS - Civil Miscellaneous MIND - Destruction of Indicia of Arrest *
CACT - Class Action MESP - Excess Sheriff Proceeds
CCON – Condemnation MHAC - Habeas Corpus
CCLD – Complex Commercial Litigation Division (NCC ONLY) MTOX - Hazardous Substance Cleanup
CDBT - Debt/Breach of Contract MFOR - Intercept of Forfeited Money
CDEJ - Declaratory Judgment MISS - Issuance of Subpoena
CDEF - Defamation MLEX - Lien Extension
CEJM - Ejectment MMAN - Mandamus
CATT - Foreign & Domestic Attachment MWIT - Material Witness *
CFJG - Foreign Judgment MWOT - Material Witness - Out of State
CFRD - Fraud Enforcement MRAT - Motion for Risk Assessment
CINT - Interpleader MROP - Petition for Return of Property
CLEM - Lemon Law MCRO - Petition Requesting Order
CLIB - Libel MROD - Road Resolution
CMAL - Malpractice MSEL - Sell Real Estate for Property Tax
CMED - Medical Malpractice MSEM - Set Aside Satisfaction of Mortgage
CPIN - Personal Injury MSSS - Set Aside Sheriff's Sale
CPIA - Personal Injury Auto MSET - Structured Settlement
CPRL - Products Liability MTAX - Tax Ditches
CPRD - Property Damage MREF - Tax Intercept
CRPV - Replevin MLAG - Tax Lagoons
CSPD - Summary Proceedings Dispute MVAC - Vacate Public Road
CCCP - Transfer from CCP MPOS - Writ of Possession
CCHA - Transfer from Chancery MPRO - Writ of Prohibition

MASS TORT MORTGAGES

CABI - Abilify Cases MCOM - Mortgage Commercial
CBEN - Benzene Cases MMED - Mortgage Mediation
CFAR - Farxiga Cases MORT - Mortgage Non-Mediation (Res.)
CHON - Honeywell Cases
CMON - Monsanto Cases
CPEL - Pelvic Mesh Cases MECHANICS LIENS
CPLX - Plavix Cases LIEN - Mechanics Lien
CPPI - PPI Cases
CTAL - Talc Cases
CTAX - Taxotere Cases
CXAR - Xarelto Cases

INVOLUNTARY COMMITMENTS
INVC- Involuntary Commitment

* Not eFiled
DUTY OF THE PLAINTIFF
Each plaintiff/counsel shall complete the attached Civil Case Information Statement (CIS) and file with the complaint.

DUTY OF THE DEFENDANT

Each defendant/counsel shall complete the attached Civil Case Information Statement (CIS) and file with the answer
and/or first responsive pleading.
Revised 10/2019