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Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 1 of 21

AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched )
or identify the person by name and address) ) Case No. 17-MJ-567
INFORMATION ASSOCIATED WITH THE TWITTER )
ACCOUNTS )
)

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before August 21, 2017 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to 10:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued:

City and state: Washington, D.C. Hon. Beryl A. HoweJL,,-Chief U.S. District Judge
· Printed name and title
Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 2 of 21

ATTACHMENT A

Property to Be Searched

This warrant applies to information associated with the Twitter profile with usemarnes:

that is stored at premises owned, maintained, controlled, or operated by Twitter, a company

headquartered in San Francisco, California.


Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 3 of 21

ATTACHMENT B

Particular Things to be Seized

I. Information to be disclosed by Twitter

To the extent that the information described in Attachment A is within the possession,

custody, or control of Twitter, including any messages, records, files, logs, or information that

have been deleted but are still available to Twitter, or have been preserved pursuant to a request

made under 18 U.S.C. § 2703(f), Twitter is required to disclose the following information to the

government for each account listed in Attachment A:

a. All identity and contact information, including full name, e-mail address, physical

address (including city, state, and zip code), date of birth, gender, hometown,

occupation, and other personal identifiers;

b. All past and current usernames, account passwords, and names associated with

the account;

c. The dates and times at which the account and profile were created, and the

Internet Protocol ("IP") address at the time of sign-up;

d. All IP logs and other documents showing the IP address, date, and time of each

login to the account;

e. All data and information associated with the profile page, including photographs,

"bios," and profile backgrounds and themes;

f. All "Tweets" and Direct Messages sent, received, "favorited," or retweeted by the

account, and all photographs or images included in those Tweets and Direct

Messages;
Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 4 of 21

g. All information from the "Connect" tab for the account, including all lists of

Twitter users who have favorited or retweeted Tweets posted by the account, as

well as a list of all Tweets that include the usemame associated with the account

(i.e., "mentions" or "replies");

h. All photographs and images in the user gallery for the account;

1. All location data associated with the account, including all information collected

by the "Tweet With Location" service;

J. All information about the account's use of Twitter's link service, including all

longer website links that were shortened by the service, all resulting shortened

links, and all information about the number of times that a link posted by the

account was clicked;

k. All data and information that has been deleted by the user;

I. A list of all of the people that the user follows on Twitter and all people who are

following the user (i.e., the user's "following" list and "followers" list);

m. A list of all users that the account has "unfollowed" or blocked;

n. All "lists" created by the account;

o. All information on the "Who to Follow" list for the account;

p. All privacy and account settings;

q. All records of Twitter searches performed by the account, including all past

searches saved by the account;

r. All information about connections between the account and third-party websites

and applications;

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Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 5 of 21

s. All records pertaining to communications between Twitter and any person

regarding the user or the user's Twitter account, including contacts with support

services, and all records of actions taken, including suspensions of the account.

3
Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 6 of 21

II. Information to be seized by the government

All information described above in Section I that constitutes fruits, evidence, and

instrumentalities of violations of 18 U.S.C. § 1030 (fraud and related activities in connection

with computers) involving since March 1, 2016 including, for each user ID identified on

Attachment A, information pertaining to the following matters:

a. Any correspondence regarding hacked emails or other data from the

Democratic National Committee (DNC) and the email belonging to John

Podesta ("the email hack");

b. Any communications between the Target Accounts and individuals

associated with the email hack;

c. Any communications indicating any advance knowledge or direction,

planning, or control of the email hack;

d. Evidence indicating how and when the Twitter account was accessed or used,

to determine the chronological and geographic context of account access, use,

and events relating to the crime under investigation and to the Twitter account

owner;

e. Evidence indicating the Twitt~r account owner's state of mind as it relates to

the crime under investigation;

f. The identity of the person(s) who created or used the user ID, including

records that help reveal the whereabouts of such person(s).

g. The identity of the person(s) who communicated with the accounts about

matters related to 18 U.S.C. § 1030, including records that help reveal their

whereabouts.

4
Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 7 of 21
AO 106 (Rev. 04/10) Application fora Search Warrant

UNITED STATES DISTRICT COURT


for the FILED
District of Columbia
AUG -7 2017
In the Matter of the Search of ) Clerk, U.S. District and
(Briefly describe the property to be searched ) Bankruptcy Courts
or identify the person by name and address) Case No. 17-MJ-567
)
INFORMATION ASSOCIATED WITH THE TWIITER )
ACCOUNTS )
)

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A.
located in the - - -
Northern
- - - - - District of - - - - -
California
- - - - - - - , there is now concealed (identify the
person or describe the property to be seized):
See Attachment B.
This warrant is sought pursuant to 18 U.S.C. §§ 2703(a), 2703(b)(1)(A), and 2703(c)(1)(A).

The basis for the search under Fed. R. Crim. P. 41 (c) is (check one or more):
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
(y{ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section Offense Description
18 U.S.C. § 1030 Fraud and Related Activities in Connection with Computers

The application is based on these facts:

See attached Affidavit.

'J Continued on the attached sheet.


0 Delayed notice of_.__ days (give exact ending date if more than 30 days: _ _ _ _ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA: ~ p p U r o n t ' , ,ignatu,e

IAaron Zelinsky (ASC) ] Mickey Robinson, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date: 08/07/2017
Judge's signature

City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 8 of 21

IN THE UNITED STATES DISTRICT COURT


FILED
FOR THE DISTRICT OF COLUMBIA AUG -7 2017
IN THE MATTER OF THE SEARCH OF Clerk, U.S. District and
B8nkruptcy Courts
INFORMATION ASSOCIATED WITH THE Case No. 17-MJ-569

Filed Under Seal

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Mickey Robinson, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the Twitter Accounts (hereafter "Target Account

1") and (hereafter "Target Account 2") and that is stored at premises owned,

maintained, controlled, or operated by Twitter, a social-networking company headquartered in

San Francisco, CA. The information to be disclosed by Twitter and searched by the Government

is described in the following paragraphs and in Attachments A and B. This affidavit is made in

support of an application for a search warrant under 18 U.S.C. §§ 2703(a), 2703(b)(l)(A), and

2703(c)(1 )(A).

2. I am a Special Agent with Federal Bureau oflnvestigation ("FBI") assigned to

FBI Headquarters working directly with the Special Counsel's Office. I have been a Special

Agent with the FBI since 2012. Since then, I have conducted national security investigations of

foreign intelligence services, espionage, and counter proliferation matters. I have training and

experience related to foreign intelligence services national security investigations, as well as

federal financial crimes. I have conducted and participated in various investigations involving

multiple threat countries as well as national security threats and applicable criminal violations.
Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 9 of 21

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that certain individuals with whom Target Account 1 was in

communication have committed violations of 18 U.S.C.§ 1030 (fraud and related activities in

connection with computers), and that communications related to these violations will be found

on the Target Accounts. There is therefore probable cause to search the information described

in Attachment A for evidence of these crimes and contraband or fruits of these crimes, as

described in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), & (c)(l)(A).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below

in paragraphs 6, 20, and 28.

PROBABLE CAUSE

A. The 2016 Email Hack and Russia's Use of "Guccifer 2.0" and Wikileaks to
Disseminate Hacked Information.

6. According to the public and unclassified intelligence report conducted by the

United States Intelligence Community, the Russian military intelligence (General Staff Main

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Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 10 of 21

Intelligence Directorate or "GRU") probably began cyber operations aimed at the U.S. election

by March 2016. The GRU operations resulted in the compromise of the personal e-mail

accounts of Democratic National Committee (DNC) and other Democratic Party officials and

political figures. By May 2016, the GRU had exfiltrated large volumes of data from the DNC.

The DNC headquarters is located at 430 South Capitol Street SE, Washington, D.C. 20003.

7. The public and unclassified intelligence report assessed that the GRU used a

Twitter account, "Guccifer 2.0," as well as the websitesDCLeaks.com, and WikiLeaks to release

U.S. victim data obtained in the cyber operations publicly and in exclusives to media outlets.

Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple contradictory

statements and false claims about his likely Russian identity throughout the election. Press

reporting suggests more than one person claiming to be Guccifer 2.0 interacted with journalists.

B. Roger Stone's Interactions with Guccifer 2.0 and Wikileaks.

8. Roger Stone is a self-employed political strategist/consultant and has been

actively involved in U.S. politics since 1975. Stone worked on the presidential campaign of

Donald J. Trump (the "Campaign") until he was fired in August 2015. Although Stone had no

official relationship with the Campaign thereafter, Stone maintained his support for Trump and

continued to make media appearances in support of Trump's presidential campaign.

9. As discussed further below, Stone made a number of public references to

Wikileaks and its release of DNC-related emails. Stone has also stated that he was in contact via

Twitter with Guccifer 2.0.

10. On June 14, 2016, news reports indicated that the computer systems of the DNC

had been hacked. On June 15, 2016, Guccifer 2.0 publicly claimed responsibility for the DNC

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Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 11 of 21

hack. Shortly thereafter, Guccifer 2.0 began releasing the hacked documents, including a June,

21, 2016 release of hacked documents.

11. On July 22, 2016, Wikileaks published approximately 20,000 emails stolen from

the DNC.

12. On August 5, 2016, Roger Stone published an article on Breitbart.com entitled,

"Dear Hillary: DNC Hack Solved, So Now Stop Blaming Russia." Stone wrote: "It doesn't

seem to be the Russians that hacked the DNC, but instead a hacker who goes by the name of

Guccifer 2.0." Stone embedded publicly available Tweets from Guccifer 2.0 in the article and

wrote: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and why

he did the hack of the DNC." Stone also stated: "Guccifer 2.0 made a fateful and wise decision.

He went to Wikileaks with the DNC files and the rest is history. Now the world would see for

themselves how the Democrats had rigged the game."

13. On August 8, 2016, Stone addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by Wikileaks founder Julian

Assange to Russia Today (RT) several days earlier about an upcoming "October Surprise" aimed

at the Hillary Clinton presidential campaign. Specifically, Stone was asked: "With regard to the

October surprise, what would be your forecast on that given what Julian Assange has intimated

he's going to do?" Stone responded: "Well, it could be a number of things. I actually have

communicated with Assange. I believe the next tranche of his documents pertain to the Clinton

Foundation but there's no telling what the October surprise may be." A few days later, Stone

clarified that while he was not personally in touch with Assange, he had a close friend who

served as an intermediary.

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Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 12 of 21

14. On August 12, 2016, Guccifer 2.0 publicly tweeted: [Target

Account 1] thanks that u believe in the real #Guccifer2." That same day, Guccifer 2.0 released

the personal cellphone numbers and email addresses from the files of the Democratic

Congressional Campaign Committee (DCCC).

15. On August 13, 2016, Stone posted a tweet using Target Account 1 calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

16. On August 14, 2016, Stone sent a private message on Twitter using Target

Account 1 to Guccifer 2.0, stating he was "delighted" to see the user's Twitter handle reinstated

after having been suspended. 1

17. On August 15, 2016, Guccifer 2.0 replied to Stone on Target Account 1, stating:

"wow. thank u for writing back, and thank u for an article about me!!! did you find anything

interesting in the docs I posted."

18. On August 16, 2016, Stone sent a private message using Target Account 1

asking Guccifer to retweet an article he had written regarding the 'rigg[ing]' of the 2016

presidential elections.

19. On August 17, 2016, Guccifer 2.0 publicly tweeted, [Target

Account 1] paying you back." Guccifer also sent a private message to Target Account 1 stating

"i 'm pleased to say u r great man. please tell me if I can help u anyhow. it would be a great

pleasure to me."

1
These messages were release by Stone on March I 0, 2017, as described further below in paragraph 28.

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20. On August 18, 2016, Paul Manafort, Stone's longtime friend and associate,

resigned as Chairman of the Campaign. Contemporary press reports at the time indicated that

Manafort had been involved in using Washington D.C.-based lobbying firms to influence U.S.

policy toward the Ukraine, including the lobbing group of Anthony Podesta (the brother of John

Podesta), the Podesta Group. At the same time, press reports indicated that investigators were

examining Manafort for potential violations of the Foreign Agent Registration Act (FARA), and

that investigators were also examining the Podesta Group.

21. On August 21, 2016, using Target Account 1, Stone directed a tweet at John

Podesta, Hillary Clinton's presidential campaign manager, stating: "Trust me, it will soon the

[sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same day,

Stone reiterated that because of the work of a "'mutual acquaintance' of both his and [Assange],

the public [could] expect to see much more from the exiled whistleblower in the form of

strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

22. On September 16, 2016 Stone said in a radio interview with Boston Herald Radio

that he expected Wikileaks to "drop a payload of new documents on a weekly basis fairly soon.

And that of course will answer the question of exactly what was erased on that email server."

23. On Saturday, October 1, 2016, using Target Account 1, Stone Tweeted,

"Wednesday@HillaryClinton is done. #Wikileaks."

24. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement Julian Assange had scheduled for the next day from the

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Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 14 of 21

balcony of the Ecuadoran Embassy in London. On the day of the Assange announcement -

which was part of Wikileaks' 1O,..year anniversary celebration - Stone told Infowars that his

intermediary described this release as the "mother load." On Tuesday, October 4, 2016, Stone

· used Target Account 1 to tweet: "Payload coming. #Lockthemup."

25. On Friday, October 7, 2016, at approximately 4:03 P.M., the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series oflewd remarks.

26. Approximately a half hour later, at 4:32 P.M., Wikileaks send a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

27. Wikileaks continued to release John Podesta's hacked emails throughout October

10-14, 2016. On October 12, 2016, John Podesta- referring back to Stone's August 21, 2016 C-

SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to - or at

least a reasonable conclusion - that [Stone] had advanced warning [of the release of his emails]

and the Trump campaign had advanced warning about what Assange was going to do. I think

there's at least a reasonable belief that [Assange] may have passed this information on to

[Stone]." Commenting to the Miami Herald, Stone responded: "I have never met or spoken with

Assange, we have a mutual friend who's traveled to London several times, and everything I

know is through that channel of communications. I'm not implying I have any influence with

him or that I have advanced knowledge of the specifics of what he is going to do. I do believe he

has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides, thought were

deleted. I hear that through my emissary."

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Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 15 of 21

28. On March 10, 2017, Stone spoke with The Washington Times and acknowledged

he had been in contact with Guccifer 2.0 using Target Account 1. Stone publicly stated that he

had been in contact with Guccifer 2.0 regarding the DNC hack, and that he had used Twitter's

private message system to do so. Stone provided a copy of the private messages to The

Washington Times.

29. On or about May 12, 2017, United States Magistrate Judge Michael S.

Nachmanoff of the Eastern District of Virginia issued an Order pursuant to 18 U.S.C. § 2705(b)

requiring Twitter to disclose certain records, including subscriber and user activity information,

associated with the Target Accounts described above (Case number 17-GJ-0835). On or about

May 23, 2017, Twitter provided the FBI with records that confirmed that the Target Accounts

are registered to Stone.

30. As described above, it appears that Stone has used the private messaging function

of Target Account 1 to communicate with Guccifer 2.0. I know in my training and experience

that individuals with multiple accounts on the same service, such as Stone has on Twitter, often

use both accounts for their communications. A review of Target Account 2's publicly available

information indicates that it has been in use since November 2015. Stone also appears to

comment using Target Account 2 frequently. Stone also often publicly "Retweets" messages

using Target Account 2 which originated from Target Account 1. Therefore there is probable

cause to believe that messages pertaining to the investigation, including messages to individuals

regarding the hack, as well as communications with Guccifer 2.0, will be found on Target

Account 1 and Target Account 2.

INFORMATION CONCERNING TWITTER

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Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 16 of 21

31. Twitter owns and operates a free-access social-networking website of the same

name that can be accessed at http://www.twitter.com. Twitter allows its users to create their own

profile pages, which can include a short biography, a photo of themselves, and location

information. Twitter also permits users to create and read 140-character messages called

"Tweets," and to restrict their "Tweets" to individuals whom they approve. These features are

described in more detail below.

32. Upon creating a Twitter account, a Twitter user must create a unique Twitter

username and an account password, and the user may also select a different name of 20

characters or fewer to identify his or her Twitter account. The Twitter user may also change this

username, password, and name without having to open a new Twitter account.

33. Twitter asks users to provide basic identity and contact information, either during

the registration process or thereafter. This information may include the user's full name, e-mail

addresses, physical address (including city, state, and zip code), date of birth, gender, hometown,

occupation, and other personal identifiers. For each user, Twitter may retain information about

the date and time at which the user's profile was created, the date and time at which the account

was created, and the Internet Protocol ("IP") address at the time of sign-up. Because every

device that connects to the Internet must use an IP address, IP address information can help to

identify which computers or other devices were used to access a given Twitter account.

34. A Twitter user can post a personal photograph or image (also known as an

"avatar") to his or her profile, and can also change the profile background or theme for his or her

account page. In addition, Twitter users can post "bios" of 160 characters or fewer to their profile

pages.

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35. Twitter also keeps IP logs for each user. These logs contain information about the

· user's logins to Twitter including, for each access, the IP address assigned to the user and the

date stamp at the time the user accessed his or her profile.

36. As discussed above, Twitter users can use their Twitter accounts to post "Tweets"

of 140 characters or fewer. Each Tweet includes a timestamp that displays when the Tweet was

posted to Twitter. TwiUer users can also "favorite," "retweet," or reply to the Tweets of other

users. In addition, when a Tweet includes a Twitter username, often preceded by the @ sign,

Twitter designates that Tweet a "mention" of the identified user. In the "Connect" tab for each

account, Twitter provides the user with a list of other users who have "favorited" or "retweeted"

the user's own Tweets, as well as a list of all Tweets that include the user's username (i.e., a list

of all "mentions" and "replies" for that username ).

37. Twitter users can include photographs or images in their Tweets. Each Twitter

account also is provided a user gallery that includes images that the user has shared on Twitter,

including images uploaded by other services.

38. Twitter users can also opt to include location data in their Tweets, which will

reveal the users' locations at the time they post each Tweet. This "Tweet With Location"

function is off by default, so Twitter users must opt in to the service. In addition, Twitter users

may delete their past location data.

39. When Twitter users want to post a Tweet that includes a link to a website, they

can use Twitter's link service, which converts the longer website link into a shortened link that

begins with http://t.co. This link service measures how many times a link has been clicked.

40. A Twitter user can "follow" other Twitter users, which means subscribing to

those users' Tweets and site updates. Each user profile page includes a list of the people who are

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following that user (i.e., the user's "followers" list) and a list of people whom that user follows

(i.e., the user's "following" list). Twitters users can "unfollow" users whom they previously

followed, and they can also adjust the privacy settings for their profile so that their Tweets are

visible only to the people whom they approve, rather than to the public (which is the default

setting). A Twitter user can also group other Twitter users into "lists" that display on the right

side of the user's home page on Twitter. Twitter also provides users with a list of "Who to

Follow," which includes a few recommendations of Twitter accounts that the user may find

interesting, based on the types of accounts that the user is already following and who those

people follow.

41. In addition to posting Tweets, a Twitter user can also send DMs to one of his or

her followers. These messages are typically visible only to the sender and the recipient, and both

the sender and the recipient have the power to delete the message from the inboxes of both users.

As of January 2012, Twitter displayed only the last 100 DMs for a particular user, but older DMs

are stored on Twitter' s database.

42. Twitter users can configure the settings for their Twitter accounts in numerous

ways. For example, a Twitter user can configure his or her Twitter account to send updates to the

user's mobile phone, and the user can also set up a "sleep time" during which Twitter updates

will not be sent to the user's phone.

43. Twitter includes a search function that enables its users to search all public

Tweets for keywords, usernames, or subject, among other things. A Twitter user may save up to

25 past searches.

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44. Twitter users can connect their Twitter accounts to third-party websites and

applications, which may grant these websites and applications access to the users' public Twitter

profiles.

45. If a Twitter user does not want to interact with another user on Twitter, the first

user can "block" the second user from following his or her account.

46. In some cases, Twitter users may communicate directly with Twitter about issues

relating to their account, such as technical problems or complaints. Social-networking providers

like Twitter typically retain records about such communications, including records of contacts

between the user and the provider's support services, a:s well as records of any actions taken by

the provider or user as a result of the communications. Twitter may also suspend a particular user

for breaching Twitter' s terms of service, during which time the Twitter user will be prevented

from using Twitter' s services.

47. As explained herein, information stored in connection with a Twitter account may

provide crucial evidence of the "who, what, why, when; where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, a

Twitter user's account information, IP log, stored electronic communications, and other data

retained by Twitter, can indicate who has used or controlled the Twitter account. This "user

attribution" evidence is analogous to the search for "indicia of occupancy" while executing a

search warrant at a residence. For example, profile contact information, communications,

"tweets" (status updates) and "tweeted"photos (and the data associated with the foregoing, such

as date and time) may be evidence of who used or controlled the Twitter account at a relevant

time. Further, Twitter account activity can show how and when the account was accessed or

12
Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 20 of 21

used. For example, as described herein, Twitter logs the Internet Protocol (IP) addresses from

which users access their accounts along with the time and date. By determining the physical

location associated with the logged IP addresses, investigators can understand the chronological

and geographic context of the account access and use relating to the crime under investigation.

Such information allows investigators to understand the geographic and chronological context of

Twitter access, use, and events relating to the crime under investigation. Additionally, Twitter

builds geo-location into some of its services. If enabled by the user, physical location is

automatically added to "tweeted" communications. This geographic and timeline information

may tend to either inculpate or exculpate the Twitter account owner. Last, Twitter account

activity may provide relevant insight into the Twitter account owner's state of mind as it relates

to the offense under investigation. For example, information on the Twitter account may

indicate the owner's motive and intent to commit a crime (e.g., information indicating a criminal

plan) or consciousness of guilt (e.g., deleting account information in an effort to conceal

evidence from law enforcement).

48. Therefore, the computers of Twitter are likely to contain all the material described

above, including stored electronic communications and information concerning subscribers and

their use of Twitter, such as account access information, transaction information, and other

account information.

INFORMATION TO BE SEARCHED AND THINGS TO BE SEIZED

49. I anticipate executing this warrant under the Electronic Communications Privacy

Act, in particular 18 U.S.C. §§ 2703(a), 2703(b)(l)(A) and 2703(c)(l)(A), by using the warrant

to require Twitter to disclose to the government copies of the records and other information

(including the content of communications) associated with the accounts in Attachment A and

13
Case 1:19-mc-00029-CRC Document 29-1 Filed 04/28/20 Page 21 of 21

particularly described in Section I of Attachment B. Upon receipt of the information described in

Section I of Attachment B, government-authorized persons will review that information to locate

the items described in Section II of Attachment B.

CONCLUSION

50. Based on the forgoing, I request that the Court issue the proposed search warrant.

51. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

52. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

Special Agent
Federal Bureau of Investigation

-z-~
Subscribed and sworn to before me on this _1_ day of August, 2017.

Th~i11:t~
Chief United States District Judge

14
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 1 of 23

AO 93 (Rev. 11/ 13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District ofC'" 111 mhi"

In the Matter of the Search of ) Case: 1: 17-mj-00661


(Briefly describe the property to be searched ) Assigned To : Howell, Beryl A
or identify the person by name and address) ) Assian. Date : 9/11 /201 7
INFORMATION ASSOCIATED WITH THE EMAIL )
Description: Search & Seizure Warrant
ACCOUNT )
)

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location) :

See Attachment A.

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B.

YOU ARE COMMANDED to execute this warrant on or before September 25, 2017 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to 10:00 p.m.
0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued: ~~ /~ 4?/ l@//:~;f-lJ


....1--_--c-P--
~_,'--'-- -'~d
~ '--=---
~/uc1ge,; signature
~'---
~- - - -- -

City and state: Washington, DC Hon . Beryl A. Howell , Chief U.S. District Judge
- -- -- - -- -- -- - -
Printed name and title
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 2 of 23
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 3 of 23
AO 106 (Rev. 04/ 10) Application for a Search Warrant

UNITED STATES DISTRICT COURT SEP ~ 1 2017


for the
District of Columbia Cterk. U.S. Dis,,:;·! & 1]ank1•Jlltc,
. Courts for t~e o:r.t•i,;t of Go!u.1i1;1la

In the Matter of the Search of ) Case: 1: 17-mj-00661


(Briefly describe the property to be searched )
or identify the person by name and address) ) Assigned To : Howell. Beryl A.
INFORMATION ASSOCIATED WITH THE EMAIL ) Assian . Date . 9/1 11201 7
ACCOUNT ) Description: Search & Seizure Warrant
)

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A
District of
located in the
- - -Northern
-----
person or describe the property to be seized):
- - - - -California
- - - - - - - , there is now concealed (identify the
See Attachment B
This warrant is sought pursuant to 18 U.S .C. §§ 2703(a) , 2703(b)(1)(A), and 2703(c)(1)(A).

The basis for the search under Fed. R. Crim. P. 4 l (c) is (check one or more):
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
~ property designed fo r use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
18 U.S .C. § 1030; Fraud and related activities in connection with computers

18 U.S.C. § 371 Conspiracy to commit an offense against the United States


The application is based on these facts:

See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of _ _ days (give exact ending date if more than 30 days: _ _ __ _ ) is requested
under 18U.S.C.§3 103a, the basis of which is set fo on the attached sheet.

Reviewed by AUSA/SAUSA:
IAaron Zelinsky {AS9 Amy Anderson , Special Agent. FBI
Printed name and title

Sworn to before me and signed in my presence.

Date: 09/11/2017 (il11,' J,o,11>1


Judge's signature

City and state: Washington, D.C. Hon . Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 4 of 23

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA
SEP 11 2017
C!er~·. 'v.,
I: "\ r s" ;n,
1.-l ,r,.,, & ..,ankru;:itny
:-"I

"' r 1·1" ' n·


Ct ur··- 'o ~ "
• ,nt,-', ·1 or· Co 1u ' Imo a
IN THE MATTER OF THE SEARCH OF . v - " ', '

Case No.
INFORMATION AS SOCIATED WITH THE
EMAIL ACCOUNT
Filed Under Seal

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Amy Anderson, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the Email Account (hereafter the "Target

Account"), that is stored at premises owned, maintained, controlled, or operated by Microsoft

Corp. , d/b/a Hotmail, an email provider headquartered at One Microsoft Way, Redmond, WA

98052 (hereinafter "Microsoft"). The information to be disclosed by Microsoft and searched by

the Government is described in the following paragraphs and in Attachments A and B. This

affidavit is made in support of an application for a search warrant under 18 U.S.C. §§ 2703(a),

2703(b)( l)(A), and 2703(c)(l)(A).

2. I am a Special Agent with Federal Bureau of Investigation ("FBI") assigned to

FBI Headquarters working directly with the Special Counsel's Office. I have been a Special

Agent with the FBI since 2010. Since then, I have conducted national security investigations of

foreign intelligence services, espionage, and counter proliferation matters. I have training and

experience related to espionage and foreign intelligence services national security investigations.

I have conducted and participated in various investigations involving multiple threat countries as

well as national security threats and applicable criminal violations.


Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 5 of 23

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Account contains communications relevant to

violations of 18 U.S.C.§ 1030 (fraud and related activities in connection with computers) and 18

U.S.C. § 371 (conspiracy to commit an offense against the United States). As set forth below,

Roger Stone used Twitter' s private direct messaging function to message Wikileaks, Julian

Assange, and Guccifer 2.0, a Twitter account used by Russian intelligence to disseminate hacked

information. Stone also repeatedly used Twitter' s private direct messaging function to instruct

individuals to email him on the Target Account to continue conversations begun on Twitter' s

private direct messaging system. These conversations included discussion of information related

to the Campaign and potential derogatory information concerning a presidential candidate in the

Republican primary. There is therefore probable cause to search the information described in

Attachment A for evidence of these crimes and contraband or fruits of these crimes, as described

in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), & (c)(l)(A).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

2
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 6 of 23

§ 27 11(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below

in paragraphs 6, 20, and 28.

PROBABLE CAUSE

A. The 2016 Email Hack and Russia's Use of "Guccifer 2.0" and Wikileaks to
Disseminate Hacked Information.

6. According to the public and unclassified intelligence report conducted by the

United States Intelligence Community, the Russian military intelligence (General Staff Main

Intelligence Directorate or "GRU") probably began cyber operations aimed at the U.S. election

by March 2016. The GRU operations resulted in the compromise of the personal e-mail

accounts of Democratic National Committee (DNC) and other Democratic Party officials and

political figures. By May 2016, the GRU had exfiltrated large volumes of data from the DNC.

The DNC headquarters is located at 430 South Capitol Street SE, Washington, D.C. 20003.

7. The public and unclassified intelligence report assessed that the GRU used a

Twitter account, "Guccifer 2.0," as well as the websitesDCLeaks.com, and WikiLe~ to release

U.S. victim data obtained in the cyber operations publicly and in exclusives to media outlets.

Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple contradictory

statements and false claims about his likely Russian identity throughout the election. Press

reporting suggests more than one person claiming to be Guccifer 2.0 interacted with journalists.

B. Roger Stone's Publicly Disclosed Interactions with Guccifer 2.0 and Wikileaks.

8. Roger Stone is a self-employed political strategist/consultant and has been

actively involved in U.S. politics since 1975. Stone worked on the presidential campaign of

Donald J. Trump (the "Campaign") until he was fired in August 20 15. Although Stone had no

3
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 7 of 23

official relationship with the Campaign thereafter, Stone maintained his suppo1i for Trump and

continued to make media appearances in support of Trump's presidential campaign.

9. As discussed further below, Stone made a number of public references to

Wikileaks and its release of DNC-related emails. Stone has also stated that he was in contact via

Twitter with Guccifer 2.0.

10. On June 14, 2016, news reports indicated that the computer systems of the DNC

had been hacked. On June 15, 2016, Guccifer 2.0 publicly claimed responsibility for the DNC

hack. Shortly thereafter, Guccifer 2.0 began releasing the hacked documents, including a June,

21, 2016 release of hacked documents.

11. On July 22, 2016, Wikileaks published approximately 20,000 emails stolen from

theDNC.

12. On August 5, 2016, Roger Stone published an article on Breitbart.com entitled,

"Dear Hillary: DNC Hack Solved, So Now Stop Blaming Russia." Stone wrote: " It doesn't

seem to be the Russians that hacked the DNC, but instead a hacker who goes by the name of

Guccifer 2.0." Stone embedded publicly available Tweets from Guccifer 2.0 in the article and

wrote: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and why

he did the hack of the DNC." Stone also stated: "Guccifer 2.0 made a fateful and wise decision.

He went to Wikileaks with the DNC files and the rest is history. Now the world would see for

themselves how the Democrats had rigged the game."

13. On August 8, 2016, Stone addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by Wikileaks founder Julian

Assange to Russia Today (RT) several days earlier about an upcoming "October Surprise" aimed

at the Hillary Clinton presidential campaign. Specifically, Stone was asked: "With regard to the

4
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 8 of 23

October surprise, what would be your forecast on that given what Julian Assange has intimated

he ' s going to do?" Stone responded: "Well, it could be a number of things. I actually have

communicated with Assange. I believe the next tranche of his documents pertain to the Clinton

Foundation but there's no telling what the October surprise may be." A few days later, Stone

clarified that while he was not personally in touch with Assange, he had a close friend who

served as an intermediary.

14. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the Democratic Congressional Campaign

Committee (DCCC).

15. On August 13, 2016, Stone posted a tweet using @RogerJStoneJr calling Guccifer

2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day, Guccifer 2.0' s

Twitter account was reinstated.

16. On August 14, 2016, Stone sent a private message on Twitter using

@RogerJStoneJr to Guccifer 2.0, stating he was "delighted" to see the user's Twitter handle

reinstated after having been suspended. 1

17. On August 15, 20 16, Guccifer 2.0 replied to Stone on Target Account 1, stating:

"wow. thank u for writing back, and thank u for an article about me! !! did you find anything

interesting in the docs I posted."

1 These messages were released by Stone on March 10, 2017, as described further below in paragraph 28.

5
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 9 of 23

18. On August 16, 2016, Stone sent a private message using @RogerJStoneJr asking

Guccifer to retweet an article he had written regarding the 'rigg[ing]' of the 2016 presidential

elections.

19. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i' m pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

20. On August 18, 2016, Paul Manafort, Stone's longtime friend and associate,

resigned as Chairman of the Campaign. Contemporary press reports at the time indicated that

Manafort had been involved in using Washington D.C.-based lobbying firms to influence U.S.

policy toward the Ukraine, including the lobbing group of Anthony Podesta (the brother of John

Podesta), the Podesta Group. At the same time, press reports indicated that investigators were

examining Manafort for potential violations of the Foreign Agent Registration Act (FARA), and

that investigators were also examining the Podesta Group.

21. On August 21, 2016, using @RogerJStoneJR, Stone directed a tweet at John

Podesta, Hillary Clinton's presidential campaign manager, stating: "Trust me, it will soon the

[sic] Podesta' s time in the barrel. #CrookedHillary." In a C-SPAN interview that same day,

Stone reiterated that because of the work of a "'mutual acquaintance' of both his and [Assange] ,

the public [could] expect to see much more from the exiled whistleblower in the form of

strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

6
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 10 of 23

22. On September 16, 2016 Stone said in a radio interview with Boston Herald Radio

that he expected Wikileaks to "drop a payload of new documents on a weekly basis fairly soon.

And that of course will answer the question of exactly what was erased on that email server."

23. On Saturday, October 1, 20 16, using @RogerJStoneJr, Stone Tweeted,

"Wednesday @ HillaryClinton is done. #Wikileaks."

24. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement Julian Assange had scheduled for the next day from the

balcony of the Ecuadoran Embassy in London. On the day of the Assange announcement -

which was part of Wikileaks' 10-year anniversary celebration - Stone told lnfowars that his

intermediary described this release as the "mother load." On Tuesday, October 4, 2016, Stone

used @RogerJStoneJr to tweet: "Payload coming. #Lockthemup."

25. On Friday, October 7, 2016, at approximately 4:03 P.M., the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

26. Approximately a half hour later, at 4:32 P.M., Wikileaks send a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

27. Wikileaks continued to release John Podesta's hacked emails throughout October

10-21, 2016. On October 12, 20 16, John Podesta-referring back to Stone's August 21 , 2016 C-

SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to - or at

least a reasonable conclusion - that [Stone] had advanced warning [of the release of his emails]

and the Trump campaign had advanced warning about what Assange was going to do. I think

there' s at least a reasonable belief that [Assange] may have passed this information on to

7
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 11 of 23

[Stone]." Commenting to the Miami Herald, Stone responded: "I have never met or spoken with

Assange, we have a mutual friend who' s traveled to London several times, and everything I

know is through that channel of communications. I'm not implying I have any influence with

him or that I have advanced knowledge of the specifics of what he is going to do. I do believe he

has all of the e-mails that Hurna ALeJiu auJ Cheryl Mill:s, the Clinton ai<le:s, thought wtm::

deleted. I hear that through my emissary."

28. On March 10, 2017, Stone spoke with The Washington Times and acknowledged

he had been in contact with Guccifer 2.0 using @RogerJStoneJr. Stone publicly stated that he

had been in contact with Guccifer 2.0 regarding the DNC hack, and that he had used Twitter's

private message system to do so. Stone provided a copy of the private messages to The

Washington Times.

29. , On March 27, 2017, CNN reported that a representative of Wikileaks, writing

from an email address associated with Wikileaks, denied that there was any backchannel

communication during the Campaign between Stone and Wikileaks. The same article quoted

Stone as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

C. Roger Stone's Private Twitter Direct Messages with Wikileaks and Julian Assange.

30. On August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the

Twitter account @RogerJStoneJr. While the full review of that returned information is ongoing,

the initial review indicates that, contrary to Stone' s representation to CNN that he "never

communicated with WikiLeaks," Stone in fact communicated via private direct messaging with

8
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 12 of 23

Wikileaks during the Campaign. Stone also used the @RogerJStoneJr Twitter account's private

direct messaging system to communicate directly with Julian Assange since at least June 2017.

31. For example, on October 13, 2016, while Wikileaks was in the midst of releasing

the hacked Podesta emails, @RogerJStoneJr sent a private direct message to the Twitter account

@Wikileaks. This account is the official Twitter account of Wikileaks and has been described as

such by numerous news reports. The message read: "Since I was all over national TV, cable and

print defending wikileaks and assange against the claim that you are Russian agents and

debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

32. Less than an hour later, @Wikileaks responded by direct message: "We

appreciate that. However, the false claims of association are being used by the democrats to

undermine the impact of our publications. Don't go there if you don't want us to correct you."

33. On October 16, 2016, @RogerJStoneJr sent a direct message to @Wikileaks:

"Ha! The more you \"correct\" me the more people think you're lying. Your operation leaks like

a sieve. You n,eed to figure out who your friends are."

34. On November 9, 2016, one day after the presidential election, @Wikileaks sent a

direct message to @RogerJStoneJr containing a single word: "Happy?" @Wikileaks

immediately followed up with another message less than a minute later: "We are now more free

to communicate."

35. In addition, @RogerJStoneJr has also recently exchanged direct messages with

Julian Assange, the founder of Wikileaks. For example, on June 4, 2017, @RogerJStoneJr

directly messaged @JulianAssange, an address associated with Julian Assange in numerous

public reports, stating: "Still nonsense. As a journalist it doesn't matter where you get

9
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 13 of 23

information only that it is accurate and authentic. The New York Times printed the Pentagon

Papers which were indisputably stolen from the government and the courts ruled it was legal to

do so and refused to issue an order restraining the paper from publishing additional articles. If

the US government moves on you I will bring down the entire house of cards. With the trumped-

up sexual assault charges dropped I don't know of any crimt:: you nt::t::c.l lo be pardoned for - best

regards. R." That same day, @J ulianAssange responded: "Between CIA and DoJ they're doing

quite a lot. On the DoJ side that's coming most strongly from those obsessed with taking down

Trump trying to squeeze us into a deal."

36. On Saturday, June 10, 20 17, @RogerJStoneJr sent a direct message to

@Wikileaks, reading: "I am doing everything possible to address the-issues at the highest level

of Government. Fed treatment of you and Wikileaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

D. Roger Stone's Use of the Target Account to Continue Conversations Begun on


Twitter Direct Message.

37. Using the direct messaging function associated with the account @RogerJStoneJr,

Stone sent direct messages to individuals instructing them to email the Target Account to

continue conversations began via Twitter direct message. For example, on August 8, 2015, an

individual sent @RogerJStoneJr a direct message asking ifhe had "a few minutes this afternoon

to talk about all of today' s drama with Trump." Stone responded the next day: "Sorry I missed

this - my email [Target Account]."

38. On August 8, 2015, an individual sent a direct message to @RogerJStoneJr

reading: "Just got some stuff from the campaign you may want to respond to." That same day,

@RogerJStoneJr responded: "Such as-? My email is [Target Account] ."

10
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 14 of 23

39. On August 9, 20 15, an individual sent @RogerJStoneJr a direct message asking to

arrange an interview. @RogerJStoneJr replied, "Okay - what do you need from me." The

individual replied, " Your email address. Twitter too public." Stone replied with the Target

Account.

40. On September 7, 20 15, an individual sent a private direct message to

@RogerJStoneJr containing a " White Paper," regarding the "Most likely questions to be asked of

Mr. Trump on Foreign Policy." @RogerJStoneJr replied: "Send to me at [Target Account]."

41 . On February 17, 2016, an individual sent a direct message to Stone reading: "Mr.

Stone I have a delightful story about one foul tempered governor currently pretending to be Ned

Flanders up on the stage. Interested?" @RogerJStoneJr responded on Friday, February 19, 2016:

"Sure---tell me what u know-[Target Account]."

42. On March 21, 2016, an individual sent a private direct message to

@RogerJStoneJr reading: " Im trying to get a list of upcoming Trump events so I can Fly out and .

Film these Anti-Trump protesters. To show the American people that these are the people that

are actually creating the Chaos. No one is showing whats really going on outside at these events

honestly and quite frankly its pissing me off." The next day, @RogerJStoneJr responded: "Email

me at [Target Account]."

43. On April 30, 2016, an individual sent a private direct message to @RogerJStoneJr

stating: "Give me a shout if you need a story moved. My followers are RTing fiends! lol."

@RogerJStoneJr responded: "Great- please e-mail me again at [Target Account]."

44. On September 13, 2016, an individual send a private direct message to

@RogerJStoneJr asking for a "contact info so I can stay in touch in a more appropriate way than

Twitter DM." @RogerJStoneJr replied, "email me at [Target Account]."

11
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 15 of 23

BACKGROUND CONCERNING HOTMAIL

45. In my training and experience, I have learned that Microsoft provides a variety of

on-line services, including electronic mail ("email") access, to the public. Microsoft allows

subscribers to obtain email accounts at the domain name Hotmail.com, like the email account

listed in Attachment A. Subscribers obtain an account by registering with Hotmail. During the

registration process, Hotmail asks subscribers to provide basic personal information. Therefore,

the computers of Microsoft are likely to contain stored electronic communications (including

retrieved and unretrieved email for Hotmail subscribers and information concerning subscribers

and their use of Hotmail services, such as account access information, email transaction

information, and account application information. In my training and experience, such

information may constitute evidence of the crimes under investigation because the information

can be used to identify the account's user or users.

46. In my training and experience, email providers generally ask their subscribers to

provide certain personal identifying information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and

other identifiers, alternative email addresses, and, for paying subscribers, means and source of

payment (including any credit or bank account number). In my- training and experience, such

information may constitute evidence of the crimes under investigation because the information

can be used to identify the account' s user or users. Based on my training and my experience, I

know that, even if subscribers insert false information to conceal their identity, this information

often provides clues to their identity, location, or illicit activities.

47. In my training and experience, email providers typically retain certain

transactional information about the creation and use of each account on their systems. This

12
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 16 of 23

information can include the date on which the account was created, the length of service, records

of log-in (i.e., session) times and durations, the types of service utilized, the status of the account

· (including whether the account is inactive or closed), the methods used to connect to the account

(such as logging into the account via the provider's website), and other log files that reflect usage

of the account. In addition, email providers often have records of the Internet Protocol address

(" IP address") used to register the account and the IP addresses associated with particular logins

to the account. Because every device that connects to the Internet must use an IP address, IP

address information can help to identify which computers or other devices were used to access

the email account.

48. In my training and experience, in some cases, email account users will

communicate directly with an email service provider about issues relating to the account, such as

technical problems, billing inquiries, or complaints from other users. Email providers typically

retain records about such communications, including records of contacts between the user and

the provider's support services, as well as records of any actions taken by the provider or user as

a result of the communications. In my training and experience, such information may constitute

evidence of the crimes under investigation because the information can be used to identify the

account's user or users.

49. This application seeks a warrant to search all responsive records and information

under the control of Microsoft, a provider subject to the jurisdiction of this court, regardless of

where Microsoft has chosen to store such information. The government intends to require the

disclosure pursuant to the requested warrant of the contents of wire or electronic

communications and any records or other information pertaining to the customers or subscribers

if such communication, record, or other information is within Microsoft's possession, custody, or

13
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 17 of 23

control, regardless of whether such communication, record, or other information is stored, held,

or maintained outside the United States.

50. As explained herein, information stored in connection with an email account

may provide crucial evidence of the "who, what, why, when, where, and how" of the criminal

conduct under investigation, thus enabling the United States to establish and prove each element

or alternatively, to exclude the innocent from further suspicion. In my training and experience,

the information stored in connection with an email account can indicate who has used or

controlled the account. This "user attribution" evidence is analogous to the search for "indicia of

occupancy" while executing a search warrant at a residence. For example, email

communications, contacts lists, and images sent (and the data associated with the foregoing, such

as date and time) may indicate who used or controlled the account at a relevant time. Further,

information maintained by the email provider can show how and when the account was accessed

or used. For example, as described below, email providers typically log the Internet Protocol

(IP) addresses from which users access the email account, along with the time and date of that

access. By determining the physical location associated with the logged IP addresses,

investigators can understand the chronological and geographic context of the email account

access and use relating to the crime under investigation. This geographic and timeline

information may tend to either inculpate or exculpate the account owner. Additionally,

information stored at the user's account may further indicate the geographic location of the
'
account user at a particular time (e.g., location information integrated into an image or video sent

via email). Last, stored electronic data may provide relevant insight into the email account

owner's state of mind as it relates to the offense under investigation. For example, information in

the email account may indicate the owner's motive and intent to commit a crime (e.g.,

14
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 18 of 23

communications relating to the crime), or consciousness of guilt (e.g. , deleting communications

in an effort to conceal them from law enforcement).

INFORMATION TO BE SEARCHED AND THINGS TO BE SEIZED

51 . I anticipate executing this warrant under the Electronic Communications Privacy

Act, in particular 18 U.S.C. §§ 2703(a), 2703(b)(l)(A) and 2703(c)(l)(A), by using the warrant

to require Hotmail to disclose to the government copies of the records and other information

(including the content of communications) associated with the account in Attachment A and

particularly described in Section I of Attachment B. Upon receipt of the information described in

Section I of Attachment B, government-authorized persons will review that information to locate

the items described in Section II of Attachment B. The items identified in Attachments A and B

will also be screened by reviewers not on the prosecution team to identify andilter out privileged

material.

CONCLUSION

52. Roger Stone used the @ RogerJStoneJr to communicate directly with Wikileaks

during the campaign, even though he publicly claimed to have "never" communicated with

Wikileaks. He also sent private messages to Julian Assange and Guccifer 2.0, the entity which

claimed responsibility for the DNC hack. Using @RogerJStoneJr, Stone has repeatedly

instructed individuals to continue conversations, including particularly sensitive issues related to

the Campaign, on the Target Account. There is therefore probable cause to believe that

evidence of the DNC hack and the hacking of other emails associated with the 2016 election will

be found on the Target Account.

53. Based on the forgoing, I request that the Court issue the proposed search warrant.

15
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 19 of 23

54. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

55. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

~f~e
~so~
Special Agent
Federal Bureau of Investigation

Subscribed and sworn to before me on this / / ~y of September, 2017.

~d!f/k-d/
The Honorable Beryl A. Howell
Chief United States District Judge

16
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 20 of 23

ATTACHMENT A

Property to Be Searched

This warrant applies to information associated with the Account

(the "Target Account") that is stored at premises owned, maintained,

controlled, or operated by Microsoft Corp., d/b/a Hotmail, a company headquartered at One

Microsoft Way, Redmond, WA 98052.

17
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 21 of 23

ATTACHMENT B

I. Information to be disclosed by Microsoft, Corp.


To the extent that the information described in Attachment A is within the possession,
custody, or control of the Microsoft, Corp. (hereinafter "the Provider"), regardless of whether
such information is stored, held or maintained inside or outside of the United States, and
including any emails, records, files, logs, ur iufunualiun lhal has been deleted but is still
available to the Provider, the Provider is required to disclose the following information to the
government for each account or identifier listed in Attachment A2:
a. The contents of all emails associated with the account, including stored or
preserved copies of emails sent to and from the account, draft emails, the source
and destination addresses associated with each email, the date and time at which
each email was sent, and the size and length of each email;
b. All records or other information regarding the identification of the account, to
include full name, physical address, telephone numbers and other identifiers,
records of session times and durations, the date on which the account was created,
the length of service, the IP address used to register the account, log-in IP
addresses associated with session times and dates, account status, alternative
email addresses provided during registration, methods of connecting, log files,
and means and source of payment (including any credit or bank account number);
c. The types of service utilized;
d. All records or other information stored at any time by an individual using the
account, including address books, contact and buddy lists, calendar data, pictures,
and files;
e. All records pertaining to communications between the Provider and any person
regarding the account, including contacts with support services and records of
actions taken; and other identifiers, records of session times and durations, the
date on which the account was created, the length of service, the types of service
utilized, the IP address used to register the account, log-in IP addresses associated
with session times and dates, account status, alternative e-mail addresses provided
during registration, all other user names associated with the account, all account
names associated with the ~ubscriber, methods of connecting;
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 22 of 23

f. All search history or web history;


g. All records indicating the services available to subscribers of the account;
h. All usernames associated with or sharing a login IP address or browser cookie
with the account;
1. All cookies, including third-party cookies, associated with the user;
J. All records that are associated with the machine cookies associated with the user;
and
k. All telephone or instrument numbers associated with the Account (including
MAC addresses, Electronic Serial Numbers ("ESN"), Mobile Electronic Identity
Numbers ("MEIN"), Mobile Equipment Identifier ("MEID"), Mobile
Identification Numbers ("MIN"), Subscriber Identity Modules ("SIM"), Mobile
Subscriber Integrated Services Digital Network Number ("MSISDN"),
International Mobile Subscriber Identifiers ("IMSI"), or International Mobile
Equipment Identities ("IMEi").

II. Information to be Seized by the Government


All information described above in Section I that constitutes evidence, contraband, fruits,
and/or instrumentalities of violations of 18 U.S.C. § 1030 (fraud and related activities in
connection with computers) and 18 U.S.C. §371 (conspiracy to commit and offense against the
United States) involving Roger Stone or others associated with him and occurring after January
1, 2015, including, for each account or identifier listed on Attachment A, information pertaining
to the following matters:
(a) Communications, records, documents and other files that reveal efforts by Roger
Stone to communicate with any individuals associated with carrying out the hacks
of the DNC or individual email addresses associated with the Clinton Campaign.
(b) Records of any funds or benefits received by or offered to Roger Stone or an
individuals or entities associated with him by, or on behalf of, any individuals
associated with the hacks of the DNC or individual email addresses associated
with the Clinton Campaign.

2
Case 1:19-mc-00029-CRC Document 29-2 Filed 04/28/20 Page 23 of 23

(c) Evidence indicating how and when the account was accessed or used, to
determine the geographic and chronological context of account access, use, and
events relating to the crimes under investigation and. to the account owner;
(d) Evidence indicating the account owner' s state of mind as it relates to the crimes
under investigation;
(e) The identity of the person(s) who created or used the account, including records
that help reveal the whereabouts of such person(s).
(f) The identity of any person(s)- including records that help reveal the person(s)'
whereabouts-who communicated with the account about any matters relating to
activities conducted by Roger Stone on behalf of, for the benefit of, any
individual associated with hacks of the DNC or individual email addresses
associated with the Clinton Campaign.

3
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 1 of 25
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 2 of 25

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Google account:

that is stored at premises owned, maintained, controlled, or operated by Google, Inc., a business

with offices located at 1600 Amphitheatre Parkway, Mountain View, CA 94043.

17
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 3 of 25

ATTACHMENT B

Particular Things to be Seized

I. Files and Accounts to be produced by Google, Inc. between January 1, 2015 and
the Present.

To the extent that the information described in Attachment A is within the possession,
custody, or control of Google, Inc. including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to Google or have been preserved
pursuant to a preservation request under 18 U.S.C. § 2703(f), Google is required to disclose the
following information to the government for each account or identifier listed in Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the
account, including copies of e-mails sent to and from the account, draft e-mails, the
source and destination e-mails sent addresses associated with each e-mail, the date and
time at which each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail
described above in Section LA. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above


in Section LA, including log files, dates, times, methods of connecting, ports, dial ups,
and/or locations;

e. All records or other information stored by an individual using the account,


including address books, contact and buddy lists, calendar data, pictures, and files;

f. All records or other information regarding the identification of the account


described above in Section LA, to include application, full name, physical address,
telephone numbers and other identifiers, records of session times and durations, the date
on which the account was created, the length of service, the types of service utilized, the
IP address used to register the account, log-in IP addresses associated with session times
and dates, account status, alternative e-mail addresses provided during registration, all
screen names associated with subscribers and/or accounts, all account names associated
with the subscriber, methods of connecting, log files, means and source of payment
(including any credit or bank account number), and detailed billing records;

g. All records indicating the services available to subscribers of the


electronic mail address described above in Section LA.;

h. Google+ subscriber information, circle information, including name of


circle and members, contents of posts, comments, and photos, to include date and
timestamp;
18
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 4 of 25

i. Google Drive files created, accessed or owned by the account;

j. YouTube subscriber information, private videos and files, private


messages, and comments;

k. Google+ Photos contents to include all images, videos and other files, and
associated upload/download date and timestamp;

l. Google Talk and Google Hangouts conversation logs associated with the
account.

19
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 5 of 25
06 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT OCT 1 7 2017


for the
Clerk, U.S. District & Bankruptcy
District of Columbia Courts for the District of Columbia

In the Matter of the Search of ) Case: 1:17-mj-00760


(Briefly describe the property to be searched
or identify the p erson by name and address) ~ Assigned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH ) Assign . Date : 10/17/2017
) Description: Search and Seizure Warrant
)

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location): ·

See Attachment A.
located in the - - -Northern
- ---- District of California
------=-='-=--'=- - - - , there is now concealed (identify the
person or describe the property to be seized):
See Attachment B.
This warrant is sought pursuant to 18 U.S .C. §§ 2703(a), 2703(b)(1)(A), and 2703(c)(1 )(A).

The basis for the search under Fed. R. Crim. P. 4 l(c) is (check one or more):
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
~ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
18 U.S. C. § 1030 Fraud and Related Activities in Connection with Computers Agents
18 U.S.C. § 2 Aiding and Abetting
22 U.S.C. § 371 Conspiracy to Commit an Offense Against the United States
The appl ication is based on these facts:

See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of _ _ days (give exact ending date if more than 30 days: _ _ __ _ ) is requested
under I 8 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

Rev;ewed by AUSA/SAUSk ~ ~ f!;;;;:;.=


Amy Anderson, Special Agent, FBI
IAaron Zelinsky (ASC)
Printed name and title

Sworn to before me and signed in my presence.

Date: 10/17/2017
Judge's s ignature

City and state: Washington , D.C. Hon . Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 6 of 25
FILED
OCT 17 2017
IN THE UNITED STATES DISTRICT COURT Clerk, U.S. District & Bankruptcy
Courts for the District of Columbia
FOR THE DISTRICT OF rnr f Th1fRT /:;.

Case: 1:17-mj-00760
IN THE MATIER OF THE SEARCH OF
Assigned To : Howell, Beryl A
INFORMATION ASSOCIATED WITH
Assign. Date : 10/1 7/2017
Description: Search and Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Amy Anderson, being first duly sworn, hereby depose and state as follows :

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the email account (hereafter the "Target

Account"), that is stored at premises owned, maintained, controlled, or operated by Google,

Inc., a business with offices located at 1600 Amphitheatre Parkway, Mountain View, CA 94043 .

The information to be disclosed by Google and searched by the government is described in the

following paragraphs and in Attachments A and B. This affidavit is made in support of an

application for a search warrant under 18 U.S.C. §§ 2703(a), 2703(b)(l)(A), and 2703(c)(l)(A).

2. I am a Special Agent with Federal Bureau of Investigation ("FBI") assigned to

FBI Headquarters working directly with the Special Counsel's Office. I have been a Special

Agent with the FBI since 2010. Since then, I have conducted national security investigations of

foreign intelligence services, espionage, and counter proliferation matters. I have training and

experience related to espionage and foreign intelligence services national security investigations.

I have conducted and participated in various investigations involving multiple threat countries as

well as national security threats and applicable criminal violations.

3. The facts in this affidavit come from ~y personal observations; my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 7 of 25

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there.is probable cause to believe that the Target Account contains communications relevant to

violations of 18 U.S.C. § 1030 (fraud and related activities in connection with co.mputers), 18

U.S.C. § 2 (aiding and abetting), and 18 U.S.C. § 371 (conspiracy to commit an offense against

the United States).

5. As set forth below, Roger STONE communicated directly via Twitter with

WikiLeaks, Julian Assange, and Guccifer 2.0, a Twitter account used _by Russian intelligence to

disseminate hacked information. STONE, using his Account, also emailed instructions

to Jerome CORSI to " Get to Assange" in person at the Ecuadorian Embassy and "get pending

WikiLeaks emails[.]" CORSI emailed STONE back on his Account that it was "Time

to let more than Podesta to be exposed" (before any of Podesta' s were leaked). After Podesta's

emails were leaked, CORSI emailed STONE "talking points" about Podesta to the Target

Account. CORSI also emailed the Target Account to convey information "from a very trusted

source" regarding Julian ASSANGE, WikiLeaks, and potential future disclosures. In addition,

STONE used the Target Account to continue conversations via email that he began on Twitter

and forwarded emails, including at least one related to WikiLeaks, from his account to

the Target Account.

JURISDICTION

6. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), & (c)(l)(A).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

2
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 8 of 25

such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below,

including in paragraph 7.

PROBABLE CAUSE

A. The 2016 Email Hack and Russia's Use of "Guccifer 2.0" and WikiLeaks to
Disseminate Hacked Information.

7. According to the public and unclassified intelligence report conducted by the

United States Intelligence Community, the Russian military intelligence (General Staff Main

Intelligence Directorate or "GRU") probably began cyber operations aimed at the U.S. election

by March 2016. The GRU operations resulted in the compromise of the personal e-mail

accounts of Democratic National Committee (DNC) and other Democratic Party officials and

political figures. By May 2016, the GRU had exfiltrated large volumes of data from the DNC.

The DNC headquarters is located at 430 South Capitol Street SE, Washington, D.C. 20003 .

8. The public and unclassified intelligence report assessed that the GRU used a

Twitter account, "Guccifer 2.0," as well as the websitesDCLeaks.com, and WikiLeaks to release

U.S. victim data obtained in the cyber operations publicly and in exclusives to media outlets.

Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple contradictory

statements and false claims about his likely Russian identity throughout the election. Press

reporting suggests more than one person claiming to be Guccifer 2.0 interacted with journalists.

B. Roger Stone's Publicly Disclosed Interactions with Guccifer 2.0 and WikiLeaks.

9. Roger Stone is a self-employed political strategist/consultant and has been

actively involved in U.S. politics since 1975. Stone worked on the presidential campaign of

Donald J. Trump (the "Campaign") until he was fired in August 2015. Although Stone had no

3
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 9 of 25

official relationship with the Campaign thereafter, Stone maintained his support for Trump and

continued to make media appearances in support of Trump's presidential campaign.

10. As discussed further below, Stone made a number of public references to

WikiLeaks and its release of DNC-related emails. Stone has also stated that he was in contact via

Twitter with Guccifer 2.0.

11. On June 14, 2016, news reports indicated that the computer systems of the DNC

had been hacked. On June 15, 2016, Guccifer 2.0 publicly claimed responsibility for the DNC

hack. Shortly thereafter, Guccifer 2.0 began releasing the hacked documents, including a June,

21, 2016 release of hacked documents.

12. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

13. On August 5, 2016, Roger Stone published an article on Breitbart.com entitled,

"Dear Hillary: DNC Hack Solved, So Now Stop Blaming Russia." Stone wrote_: "It doesn't

seem to be the Russians that hacked the DNC, but instead a hacker who goes by the name of

Guccifer 2.0." Stone embedded publicly available Tweets froni Guccifer 2.0 in the article and

wrote: "Here' s Guccifer 2.0's website. Have a look and you'll see he explains who he is and why

he did the hack of the DNC." Stone also stated: "Guccifer 2.0 made a fateful and wise decision.

He went to WikiLeaks with the DNC files and the rest is history. Now the world would see for

themselves how the Democrats had rigged the game."

14. On August 8, 2016, Stone addressed the Southwest Broward Republican

Organizat_ion. During his speech, he was asked about a statement by WikiLeaks founder Julian

Assange to Russia Today (RT) several days earlier about an upcoming "October Surprise" aimed

at the Hillary Clinton presidential campaign. Specifically, Stone was asked: "With regard to the

4
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 10 of 25

October surprise, what would be your forecast on that given what Julian Assange has intimated

he' s going to do?" Stone responded: "Well, it could be a number of things. I actually have

communicated with Assange. I believe the next tranche of his documents pertain to the Clinton

Foundation but there's no telling wha~ the October surprise may be." A few days later, Stone

clarified that while he was not personally in touch with Assange, he had a close friend who

served as an intermediary.

15. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the Democratic Congressional Campaign

Committee (DCCC).

16. On August 13, 2016, Stone posted a tweet using @RogerJStoneJr calling Guccifer

2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day, Guccifer 2.0's

Twitter account was reinstated.

17. On August 14, 2016, Stone sent a private message on Twitter using

@RogerJStoneJr to Guccifer 2.0, stating he was "delighted" to see the user' s Twitter handle

reinstated after having been suspended. 1

18. On August 15, 2016, Guccifer 2.0 replied to Stone at@RogerJStoneJr, stating:

"wow. thank u for writing back, and thank u for an article about me!!! did you find anything

interesting in the docs I posted."

1 · ~~MA
These messages were released by Stone on March I 0, 2017, as described further below in paragraph 28-:

5
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 11 of 25

19. On August 16, 2016, Stone sent a private message using @RogerJStoneJr asking

Guccifer to retweet an article he had written regarding the ' rigg[ing]' of the 2016 presidential

elections.

20. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i' m pleased to say u r

great man. please tell me ifl can help u anyhow. it would be a great pleasure to me."

21. On August 18, 2016, Paul Manafort, Stone' s longtime friend and associate,

resigned as Chairman of the Campaign. Contemporary press reports at the time indicated that

Manafort had working with a Washington D.C.-based lobbying firms to influence U.S. policy

toward Ukraine.

22. On August 21, 2016, using @RogerJStoneJR, Stone directed a tweet at John

Podesta, Hillary Clinton' s presidential campaign manager, stating: "Trust me, it will soon the

[sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same day,

Stone reiterated that because of the work of a " ' mutual acquaintance' of both his and [Assange],

the public [could] expect to see much more from the exiled whistleblower in the form of

strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

23. On September 16, 2016 Stone said in a radio interview with Boston Herald Radio

that he expected WikiLeaks to "drop a payload of new documents on a weekly basis fairly soon.

And that of course will answer the question of exactly what was erased on that email server."

6
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 12 of 25

24. On Saturday, October 1, 2016, using@RogerJStoneJr, Stone Tweeted,

"Wednesday @HillaryClinton is done. #WikiLeaks."

25. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement Julian Assange had scheduled for the next day from the

balcony of the Ecuadoran Embassy in London. On the day of the Assange announcement -

which was part of WikiLeaks' 10-year anniversary celebration - Stone told lnfowars that his

intermediary described this release as the "mother load." On Tuesday, October 4, 2016, Stone

used @RogerJStoneJr to tweet: "Payload coming. #Lockthemup."

26. On Friday, October 7, 2016, at approximately 4:03 P.M., the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

27. Approximately a half hour later, at 4:32 P.M., WikiLeaks send a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta' s personal email account.

28. WikiLeaks continued to release John Podesta's hacked emails throughout October

10-21, 2016. On October 12, 2016, John Podesta - referring back to Stone' s August 21 , 2016 C-

SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to - or at

least a reasonable conclusion - that [Stone] had advanced warning [of the release of his emails]

and the Trump campaign had advanced warning about what Assange was going to do. I think

there' s at least a reasonable belief that [Assange] may have passed this information on to

[Stone]." Commenting to the Miami Herald, Stone responded: " I have never met or spoken with

Assange, we have a mutual friend who's traveled to London several times, and everything I

know is through that channel of communications. I'm not implying I have any influence with

7
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 13 of 25

him or that I have advanced knowledge of the specifics of what he is going to do. I do believe he

has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides, thought were

deleted. I hear that through my emissary."

29. On March 10, 2017, Stone spoke with The Washington Times and acknowledged

he had been in contact with Guccifer 2.0 using @RogerJStoneJr. Stone publicly stated that he

had been in contact with Guccifer 2.0 regarding the DNC hack, and that he had used Twitter's

private message system to do so. Stone provided a copy of the private messages to The

Washington Times.

30. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between Stone and WikiLeaks. The same article quoted

Stone as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

C. Roger Stone's Private Twitter Direct Messages with WikiLeaks and Julian Assange.

31. On August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the

Twitter account@RogerJStoneJr. Contrary to Stone's representation to CNN that he "never

communicated with WikiLeaks," Stone in fact communicated via private direct messaging with

WikiLeaks during the Campaign. Stone also used the @RogerJStoneJr Twitter account's private

direct messaging system to communicate directly with Julian Assange since at least June 2017.

32. For example, on October 13, 2016, while WikiLeaks was in the midst ofreleasing

the hacked Podesta emails, @RogerJStoneJr sent a private direct message to the Twitter account

8
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 14 of 25

@wikileaks. This account is the official Twitter account of WikiLeaks and has been described as

such by numerous news reports. The message read: "Since I was all over national TV, cable and

print defending WikiLeaks and assange against the claim that you are Russian agents and

debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

33. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

34. On October 16, 2016, @RogerJStoneJr sent a direct message to @wikileaks: "Ha!

The more you \"correct\" me the more people think you're lying. Your operation leaks like a

sieve. You need to figure out who your friends are."

35. On November 9, 2016, one day after the presidential election, @wikileaks sent a

direct message to @RogerJStoneJr containing a single word: "Happy?" @wikileaks immediately

followed up with another message less than a minute later: "We are now more free to

communicate."

36. In addition, @RogerJStoneJr has also recently exchanged direct messages with

Julian Assange, the founder of WikiLeaks. For example, on June 4, 20 17, @RogerJStoneJr

directly messaged @JulianAssange, an address associated with Julian Assange in numerous

public reports, stating: "Still nonsense. As a journalist it doesn't matter where you get

information only that it is accurate and authentic. The New York Times printed the Pentagon

Papers which were indisputably stolen from the government and the courts ruled it was legal to

do so and refused to issue an order restraining the paper from publishing additional articles. If

the US government moves on you I will bring down the entire house of cards. With the trumped-

9
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 15 of 25

up sexual assault charges dropped I don't know of any crime you need to be pardoned for - best

regards. R." That same day, @JulianAssange responded: "Between CIA and DoJ they're doing

quite a lot. On the DoJ side that's coming most strongly from those obsessed with taking down

Trump trying to squeeze us into a deal."

37. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@wikileaks, reading: " I am doing everything possible to address the issues at the highest level of

Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

D. Roger Stone's Emails Regarding WikiLeaks, Julian Assange, Russia, and John
Podesta

38. On September 11 , 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, (the "

Account"). Emails recovered pursuant to that search warrant indicated the following:

39. On July 25, 20 16, STONE sent an email from his Account to JEROME

CORSI, an author and political commentator, with the subject line, "Get to Assange." The body

of the message read: "Get to Assange [a]t Ecuadorian Embassy in London and get pending

WikiLeaks emails .. . they deal with Foundation, allegedly."

40. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed the Account, " Word is

friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct. Impact planned to

be very damaging ... Time to let more than Podesta to be exposed as in bed w enemy if they are

not ready to drop HRC. That appears to be the game hackers are now about. Would not hurt to

start suggesting HRC old, memory bad, has stroke -- neither he nor she well. I expect that much

10
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 16 of 25

of next dump focus, setting stage for Foundation debacle." Based on my training, experience,

and review of materials in this case, it appears that CORSI's reference to a "friend in embassy

[who] plans 2 more dumps" refers to Julian ASSANGE, the founder ofWikiLeaks, who resided

in Ecuador's London Embassy in 2016.

41. On or about August 16, 2016, CORSI emailed the Target Account link to a piece

CORSI had written about STONE titled, "Trump Adviser: WikiLeaks Plotting Email Dump to

Derail Hillary."

42. On or about August 31 , 2016, CORSI emailed the Account: "Did you get

the Podesta writeup." STONE replied "yes."

43 . On or about September 6, 2016, CORSI emailed the Account: "Roger[,]

Is NY Post going to use the Pedesta [sic] stuff?"

44. On or about October 4, 2016 STONE forwarded an email from his

Account to the Target Account with the subject line "Comment on WikiLeaks?" The email,

from a reporter, asked STONE for any comment on the "lack of an 'October surprise' release

from WikiLeaks today?"

45. On or about October 7, 2016, WikiLeaks began releasing the Podesta emails.

46. On or about October 12, 2016, the same day on which Podesta accused STONE of

having advance knowledge of the publication of his emails, CORSI emailed STONE on both the

Target Account and the Account, with a subject line "Podesta talking points." Attached

to the email was a file labeled, "ROGER STONE podesta talking points Oct 12 2016.docx." The

"talking points" included the statement that, "Podesta is at the heart of a Russian-government

money laundering operation that benefits financially Podesta personally and the Clintons through

the Clinton Foundation." CORSI followed up several minutes later with another email to the

11
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 17 of 25

Target Account and the Account titled, "Podesta talking points," with the text "sent a

second time just to be sure you go it." STONE emailed CORSI back via the Account,

"Got them and used them."

47. On or about October 17, 2016, CORSI emailed the Target Account and the

Account with the subject, "Fwd: AS SAN GE . .. URGENT ... " CORSI wrote, "From a

very trusted source," and forwarded an email with the header information stripped out, showing

only the body text. The email read, "Yes[.] I figured this. Assange is threatening Kerry, Ecuador

and U .K. He will drop the goods on them if they move to extradite him. My guess is that he has a

set of dead man files that include Hillary. It's what they used to call a ' Mexican stand off[.]'

Only hope is that if Trump speaks out to save him[.] Otherwise he'd dead anyway, once he's

dropped what he has. If HRC wins, Assange can kiss his life away. Interesting gambit Assange

has to play out. He's called Podesta's bluff and raised him the election."

48. On or about January 7, 2017, emailed the Target Account,

the Account, CORSI, and with the subject line, "in case you need

his mail ... ...... " Attached to the message was a scan of a business card for John Podesta.

Several hours later, replied to all recipients, including the Target Account, "Ha ...

maybe he wants to go phishing with us?"

49. I know from my training and experience that the term "phishing" is used to refer

to the practice of sending emails purporting to be from a reputable party in order to induce

individuals to reveal personal information, including passwords. Public reports indicate that

Podesta's emails were obtaining through a "phishing" scheme.

E. Roger Stone's Use of the Target Account to Continue Conversations Begun on


Twitter Direct Message.

12
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 18 of 25

50. STONE has also used Target Account to continue conversations began via

Twitter direct message. For example, on August 18, 2016, an individual sent @RogerJStoneJr a

direct message asking "know where to send information to" regarding "Presidential polls and

why cycle favors Trump." Stone responded: "[Target Account] ."

51. On August 19, 2017, an individual sent a direct message to @RogerJStoneJr

concerning an offer for "$500 for a 30 minute phone call," stating that "My audience would be

fascinated by discussion." The individual then direct messages Stone, "Hi Roger! I'm striking

out with your rep. Hoping we can swing something this week. My offer still stands."

@RogerJStoneJr wrote back: "Email me direct (Target Account]."

BACKGROUND CONCERNING GOOGLE

52. Google provides numerous free services to the users with a Google profile. Some

of services include, Gmail, Google Talk, Google Wallet, Google+, Google Drive, Google+

Photos, and YouTube. Gmail is a web based email service. Google Talk is an instant messaging

service that provides both text and voice communication. Google Talk conversation logs are

saved to a "Chats" area in the user' s Gmail account. Google+ is a social networking service.

Google Drive is a file storage and synchronization service which provides users with cloud

storage, file sharing, and collaborative editing. Google+ Photos (formerly knowns as Picasa Web

Albums) is an image hosting and sharing web service that allows users with a Google account to

store and share images for free. YouTube is a free video sharing website that allows users

upload, view, and share videos. Google also retains a record of searches conducted by the user,

as well as location data for the use of some of the services described above. All of these services

may record information uploaded, inputted, or gathered from the user.

13
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 19 of 25

53. In my training and experience, in addition to information such as search history

can help to show the state of mind of an individual at the time the search was made, as well as

the individuals potential advance knowledge of events, as they search to see if the anticipated

event has occurred. Individuals who communicate via Gmail also often use other Google

products, including Google Talk, to communicate, and Google Drive to store or transfer, open, or

edit files.

INFORMATION TO BE SEARCHED AND THINGS TO BE SEIZED

54. I anticipate executing this warrant under the Electronic Communications Privacy

Act, in particular 18 U.S.C. §§ 2703(a), 2703(b)(l)(A) and 2703(c)(l)(A), by using the warrant

to require Google to disclose to the government copies of the records and other information

(including the content of communications) associated with the account in Attachment A and

particularly described in Section I of Attachment B. Upon receipt of the information described

in Section I of Attachments B, government-authorized persons will review that information to

locate the items described in Section II of Attachments B. The items identified in Attachments A

and B will also be screened by reviewers not on the prosecution team to identify and filter out

privileged material.

CONCLUSION

55. STONE instructed CORSI via the Account to "Get to Assange" at the

Ecuadorian Embassy regarding upcoming leaks, and CORSI emailed Stone on the

Account that it was "Time to let more than Podesta to be exposed as in bed w enemy if they are

not ready to drop HRC." CORSI later emailed STONE "talking points" about Podesta to the

Target Account, and also emailed the Target Account to convey information "from a very

trusted source" regarding ASSANGE, WikiLeaks, and potential disclosure. STONE also used

14
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 20 of 25

the Target Account to continue conversations via email that he began on Twitter and forwarded

emails related to WikiLeaks from the Account to the Target Account. There is

therefore probable cause to believe that evidence of the DNC hack and the hacking of other

emails associated with the 2016 election will be found in the information associated with the

Target Account.

56. Based on the forgoing, I request that the Court issue the proposed search warrant.

57. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

15
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 21 of 25

REQUEST FOR SEALING

58. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

Special Agent
Federal Bureau of lnvestigati_o n

Subscribed and sworn to before me on this I J ~ of October, 2017.

~le~
The Honorable Beryl A. Howell
Chief United States District Judge

16
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 22 of 25

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Google account:

that is stored at premises owned, maintained, controlled, or operated by Google, Inc., a business

with offices located at 1600 Amphitheatre Parkway, Mountain View, CA 94043.

17
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 23 of 25

ATTACHMENT B

Particular Things to be Seized

I. Files and Accounts to be produced by Google, Inc. between January 1, 2015 and
the Present.

To the extent that the information described in Attachment A is within the possession,
custody, or control of Google, Inc. including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to Google or have been preserved
pursuant to a preservation request under 18 U.S.C. § 2703(±), Google is required to disclose the
following information to the government for each account or identifier listed in Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the
account, including copies of e-mails sent to and from the account, draft e-mails, the
source and destination e-mails sent addresses associated with each e-mail, the date and
time at which each e-mail was sent, and-the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail
described above in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above


in Section I.A, including log files, dates, times, methods of connecting, ports, dial ups,
and/or locations;

e. All records or other information stored by an individual using the account,


including address books, contact and buddy lists, calendar data, pictures, and files;

f. All records or other information regarding the identification of the account


described above in Section I.A, to include application, full name, physical address,
telephone numbers and other identifiers, records of session times and durations, the date
on which the account was created, the length of service, the types of service utilized, the
IP address used to register the account, log-in IP addresses associated with session times
and dates, account status, alternative e-mail addresses provided during registration, all
screen names associated with subscribers and/or accounts, all account names associated
with the subscriber, methods of connecting, log files, means and source of payment
(including any credit or bank account number), and detailed billing records;

g. All records indicating the services available to subscribers of the


electronic mail address described above in Section I.A.;

h. Google+ subscriber information, circle information, including name of


circle and members, contents of posts, comments, and photos, to include date and
timestamp;
18
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 24 of 25

1. Google Drive files created, accessed or owned by the account;

J. YouTube subscriber information, private videos and files, private


messages, and comments;

k. Google+ Photos contents to include all images, videos and other files, and
associated upload/download date and timestamp;

1. Google Talk and Google Hangouts conversation logs associated with the
account.

19
Case 1:19-mc-00029-CRC Document 29-3 Filed 04/28/20 Page 25 of 25

II. Information to be Seized by Law Enforcement Personnel

a. Any and all records that relate in any way to the accounts described in Attachment A which
consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C.§ 1030 (fraud and
related activities in connection with computers), 18 U.S.C. § 2 (aiding and abetting), and 18
U.S.C. § 371 (conspiracy to commit an offense against the United States), for the period January
2015 to the present, including:

All records, information, documents or tangible materials that relate 'in any way to
communications regarding hacking, release of hacked material, communications
with persons or entities associated with WikiLeaks, including but not limited to
Julian Assange;

b. All images, messages, communications, calendar entries, search terms,


and contacts, including any and all preparatory steps taken in furtherance of the above-
listed offenses;

c. Communication, information, documentation and records relating to who


created, used, or communicated with the account or identifier, including records about
their identities and whereabouts;

d. Evidence of the times the account was used;

e. All images, messages and communications regarding wipmg software,


encryption or other methods to avoid detection by law enforcement;

f. Passwords and encryption keys, and other access information that may be
necessary to access the account and other associated accounts;

g. Credit card and other financial information, including but not limited to,
bills and payment records evidencing ownership of the subject account;

h. All existing printouts from original storage which concern the categories
identified in subsection II.A; and

1. All "address books" or other lists of contacts.

20
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 1 of 31
AO 106 (Rev. 04/ 10) Application for a Search Warrant
FILED
UNITED STATES DISTRICT COURT NOV -s 2017
for the
Clerk, U.S. District & Bankruptcy
District of Columbia Courts for the District of Columbia

In the Matter of the Search of Case: 1: 17-mj-00a21


)
(Briefly describe the prop erty to be searched )
or identi.fj, the p erson by name and address) Ass!gned To : Howell, Beryl A
)
INFORMATION ASSOCIATED WITH THE TWITTER
)
Assign. Date : 11/6/2017 .
ACCOUNTS
) Description: Search and Seizure Warrant
)

APPLICATION FOR A SEARCH WARRANT


I , a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A.
located in the Northern
- - - ' - - - - - -- District of _ _ __ California
__.:....c.;c.:,c.;:_;_:--=-- --- , there is now concealed (identi.fj, the
p erson or describe the property to be seized) :
See Attachment 8.
This warrant is sought pursuant to 18 U.S.C. §§ 2703(a), 2703(b)(1)(A), and 2703(c)(1)(A).

The basis for the search under Fed. R. Crim. P. 41 (c) is (check one or more) :
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
~ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section Offense Description
18 U.S.C. § 1030 Fraud and Related Activities in Connection with Computers
18 U.S.C. § 371, § 2 Conspiracy Against the United States, Aiding and Abetting
50 U.S.C. § 30121 Foreign Contribution Ban
The application is based on these facts:

See attached Affidavit.

~ Continued on the attached sheet.

Rev:.::~~::::/::::::fue b~is ofwhich isset a;-~!:;


0 Delayed notice of _ _ days (give exact ending date if more than 30 days: _ __ _ _ ) is requested

IAaron Zelinsky (ASC) Amy Anderson, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date: 11/6/2017

City and state: Washington , D.C. Hon . Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 2 of 31

FILED
IN THE UNITED STATES DISTRICT COURT
NOV -s 2017
FOR THE DISTRICT OF COLUMBIA Clerk us 0 . .
Courts fo.r the ';~ntc~ & Bankruptcy
is net ot Columbia
IN THE MATTER OF THE SEARCH OF Case: 1: 17-mj-00821
INFORMATION AS SOCIA TED WITH THE Ass!gned To : Howell, Beryl A
TWITTER ACCOUNT AND Assign. Date : 11/6/2017
Description: Search and Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Amy Anderson, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

I. I make this affidavit in support of an application for a search warrant for

information associated with the Twitter Accounts (hereafter "Target Account 1")

and (hereafter "Target Account 2"), that is stored at premises owned,

maintained, controlled, or operated by Twitter, a social-networkin? company headquartered in

San Francisco, CA. The information to be disclosed by Twitter and searched by the Government

is described in the following paragraphs and in Attachments A and B. This affidavit is made in

support of an application for a search warrant under 18 U.S.C. §§ 2703(a), 2703(b)(l)(A), and

2703(c)(I )(A).

2. I am a Special Agent with Federal Bureau oflnvestigation ("FBI") working

directly with the Special Counsel's Office. I have been a Special Agent with the FBI since 2010.

Since then, l have conducted national security investigations of foreign intelligence services,

espionage, and counter proliferation matters. I have training and experience related to espionage,

foreign intelligence services, and national security investigations. I have conducted and

participated in various investigations involving multiple threat countries as well as national

security threats and applicable criminal violations.


Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 3 of 31

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that certain individuals with whom the Target Accounts were

in communication have committed violations of 18 U..S.C. § I 030 (fraud and related activities in

connection with computers), 50 U.S.C. § 30121 (foreign contribution ban), 18 U.S .C. § 2 (aiding

and abetting), 18 U.S.C. § 371 (conspiracy to commit an offense against the United States), and

that communications related to these violations will be found on the Target Accounts. There is

therefore probable cause to search the information described in Attachment A for evidence of

these crimes and contraband or fruits of these crimes, as described in Attachment B.

5. As detailed further below, from on or about June 22, 20 I 6, through at least on or

about July 17, 2016, Target Account 1, belonging to WikiLeaks, exchanged numerous direct

messages concerning hacked information with Guccifer 2.0, which was a Twitter account used

by the Russian Government to release data obtained through hacking accounts of U.S. users.

Target Account 1 also sent direct messages via Twitter concerning a "guessed" password for the

website " " to Target Account 2 belongs to Julian Assange,

the founder of WikiLeaks. Beginning no later than on or about July 2016, former Campaign

adviser Roger Stone was in contact with Assange via an intermediary regarding upcoming leaks

of hacked information obtained by WikiLeaks. In addition, Assange, using Target Account 2,

communicated directly with Stone beginning no later than on or about April 7, 2017. Stone

stated to Target Account 2 that he was "doing everything possible to address the issues [related

2
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 4 of 31

to WikiLeaks] at the highest level of Government," and that he and Target Account 2 "must be

circumspect in this forum as experience demonstrates it is monitored."

JURISDICTION

6. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), & (c)(l)(A).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below

in paragraph 9.

PROBABLE CAUSE

A. Background on the Target Accounts, Julian Assange, and Roger Stone.

7. Target Account 1 is the public account of WikiLeaks. As detailed further below,

it frequently has been used to release hacked information, including during the 2016 election.

Target Account 2 is the public account of Julian Assange. Target Account 2 has over 500,000

followers, but only follows one account, Target Account 1. Target Account 2 frequently

tweets information related to WikiLeaks and tags Target Account 1.

8. Julian Assange is the founder of WikiLeaks. According to the publicly-accessible

profile of Target Account 2, Assange currently is the "Publisher @WikiLeaks [Target Account

1]." Target Account 2's profile contains a link to the website " IamWikiLeaks.org\donate."

According to publicly-available press reporting, Assange began hacking secure computer

systems when he sixteen years old, in 1987. On or about December 1996, Assange pied guilty in

Australia to twenty-five charges related to hacking secure computer systems. In 2006, Assange

and others established WikiLeaks, and he previously described himself as WikiLeaks's Editor-

3
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 5 of 31

in-Chief. Assange has stated in public interviews that he is deeply involved in running

WikiLeaks. Referring to the DNC emails, Assange stated in an August, 2017 interview that, "We

had quite some difficulties to overcome, in terms of the technical aspects, and making sure we

were comfortable with the forensics," and that "You have to get close and interact with it, then

you start to get a feel." Assange indicated that only a small number of people, including himself,

worked on the release of the DNC emails. Assange stated in August 20 16 to a news organization

that, "We are working around the clock. We have received quite ·a lot of material."

9. Roger Stone is a self-employed political strategist/consultant and has been

actively involved in U.S. politics sine~ 1975. Stone officially worked on the presidential

campaign of Donald J. Trump (the "Campaign") until August 2015. Although Stone had no

official relationship with the Campaign thereafter, Stone maintained his support for Trump and

continued to make media appearances in support of Trump' s presidential campaign. After

Stone's public departure from the Campaign, Stone continued to correspond with individuals

related to the Campaign, including Paul Manafort (who worked for a time as Campaign

manager), Rick Gates (a campaign adviser), and Jason Miller (Campaign spokesman). As

discussed further below, Stone made a number of public references to WikiLeaks, Julian

Assimge, and the release of DNC-related emails.

B. The DNC Email Hack and Russia's Use of "Guccifer 2.0" and WikiLeaks to
Disseminate Hacked Information.

10. According to the public and unclassified intelligence report prepared by the

United States Intelligence Community, Russian intelligence gained access to the Democratic

National Committee (DNC) networks in July 2015 and maintained that access until at least June

2016. By March 2016, the Russian military intelligence (General Staff Main Intelligence

4
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 6 of 31

Directorate or "GRU") probably began cyber operations aimed at the U.S. election. The GRU

operations resulted in the compromise of personal e-mail accounts within the DNC and other

Democratic Party officials and political figures. By in or about May 2016, the GRU had

exfi ltrated large volumes of data from the DNC. The DNC headquarters is located at 43 0 South

Capitol Street SE, Washington, D.C. 20003.

11 . The public and unclassified intelligence report assessed that:

a. The GRU used a Twitter account, "Guccifer 2.0" and the website

DCLeaks.com to release the U.S. victim data obtained in cyber operations publicly and in

exclusives to media outlets and relayed material to WikiLeaks.

b. Guccifer 2.0, who claimed to be an independent Romanian hacker, made

multiple contradictory statements and false claims about hi s likely Russian identity

throughout the election.

c. Content that was taken from e-mail accounts targeted by the GRU in

March 2016 appeared on DCLeaks.com starting in June 20 16.

d. The GRU relayed material it acquired from the DNC and senior

Democratic officials to WikiLeaks. WikiLeaks was mostly likely chosen because of its

self-proclaimed reputation for authenticity. Disclosures through WikiLeaks did not

contain any evident forgeries.

e. The Kremlin 's principal international propaganda outlet RT (formerly

Russia Today) has actively collaborated with WikiLeaks. RT's editor-in-chief visited

WikiLeaks founder Julian Assange at the Ecuadorian Embassy in London in August

2013, where they discussed renewing his broadcast contract with RT, according to

Russian and Western media. Russian media has subsequently announced that RT had

5
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 7 of 31

become "the only Russian media company" to partner with WikiLeaks and had received

access to "new leaks of secret information."

f. On or about August 6, 2016, RT published an English-language video

called "Julian Assange Special: Do WikiLeaks Have the E-Mail That'll Put Clinton in

Prison?" and an exclusive interview with Assange entitled "Clinton and ISIS Funded by

the Same Money."

12. On or about June 14, 2016, the Washington Post reported that "Russian

government hackers" had penetrated the DNC computer network and stole opposition research

on Donald J. Trump. The Kremlin's spokesman denied any Russian involvement in the hack.

13. On or about June 15, 2016, Guccifer 2.0 claimed responsibility for the DNC hack

and began posting hacked documents.

14. As detailed further below, on or about June 22, 2016, Guccifer 2.0 and Target

Account 1 initiated communication via Twitter private messaging regarding the transfer and

release of hacked information, including the hacked email accounts related to the DNC.

15. On or about July 22, 2016, WikiLeaks published about 20,000 emails stolen from

the DNC. Using Target Account 1, WikiLeaks publicly tweeted: "WikiLeaks releases thousands

of documents about Clinton and internal deliberations" and linked to a Washington Post article

and www.wiki leaks .org/dnc-emails/.

I 6. On or about August 12, 2016, Guccifer 2.0 released personal cellphone numbers

and email addresses from the files of the Democratic Congressional Campaign Committee

(DCCC).

17. On or about August 21, 20 16, Roger Stone directed a publicly-available tweet at

John Podesta, Hillary Clinton's presidential campaign manager, stating: "Trust me, it will soon

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the [sic] Podesta's time in the barrel. #CrookedHi llary." In a C-SPAN interview that same day,

Stone reiterated that because of the work of a '" mutual acquaintance' of both his and [Assange],

the public [could] expect to see much more from the exiled whistleblower in the form of

strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

18. On or about September 13, 2016, Target Account 1 tweeted a public message

stating, "678.4 MB of new ' DNC documents' from @Guccifer_2," with a link to a publicly

available file.

19. On Friday, October 7, 2016, at approximately 4:03 P.M., the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

20. Approximately a half hour later, at 4:32 P.M., Target Account 1 sent out a Tweet

reading "RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing

a link to approximately 2,050 emai ls that had been hacked from John Podesta's personal emai l

account. WikiLeaks, via Target Account 1, continued to release John Podesta's hacked emails

throughout October 10-14, 2016.

C. Communications Between the Target Account 1 and Guccifer 2.0

21 . On July 7, 2017 Magistrate Judge Maria-Elena James of the Northern District of

California issued a search warrant for the Twitter Account associated with Guccifer 2.0. The

communications obtained from the account are detailed further below.

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22. On or about June 22, 2016, WikiLeaks sent Guccifer 2.0 sent a direct message

(OM) stating "Do you have secure communications?" Target Account 1 stated, "Send any new

material here for us to review and it will have a much higher impact than what you are doing. No

other media will release the full material." Guccifer 2.0 replied, "what can u suggest for a secure

connection? Soft, keys, etc? I'm ready to cooperate with you, but I need to know what's in your

archive 80gb? Are there only HRC emails? Or some other docs? Are there any DNC docs? If it's

not secret when you are going to release it?" Target Account 1 wrote back, "You can send us a

message in a .txt file here," and attached a web link. Guccifer 2.0 responded, "do you have

GPG?" I know from my training and experience that "GPG" refers to a program for exchanged

encrypted information.

23. On or about June 24, 2016, Guccifer 2.0 wrote to Target Account 1, "How can

we chat? Do u have jabber or something like that?" I know from my training and experience that

"Jabber" is an instant messaging service. Target Account 1 wrote back, "Yes, we have

everything. We' ve been busy celebrating Brexit. You can also email an encrypted message to

[email protected]. They key is here." 1 A web link was attached to the message. I know from

my training and experience that an encryption "key" is a string of information created for

scrambling and unscrambling data.

24. On or about June 27, 2016, Guccifer 2.0 wrote to Target Account 1, "Hi, [I]'ve

just sent you an email with a text message encrypted and an open key." Target Account 1 wrote

back, "Thanks." Guccifer 2.0 replied, "waiting for ur response. I send u some interesting piece."

1
Target Account I sent each sentence as a separate message, though close in time. These messages have been
consolidated into a single quote for ease of reading. The same is done below with other close in time messages.

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25. On or about July 4, 2016, Guccifer 2.0 wrote to Target Account 1, "hi there,

check up r email, waiting for [r]eply."

26. On or about July 6, 2016, Guccifer 2.0 wrote to Target Account 1, "have u

received my parcel?" Target Account 1 responded, "Not unless it was very recent. [we haven't

checked in 24h]." 2 Guccifer 2.0 replied, "I sent it yesterday, an archive of about 1 gb. via

[website link]. [A]nd check your email." Target Account 1 wrote back, "Wil[l] check, thanks."

Guccifer 2.0 responded, " let me know the results." Target Account 1 wrote back, "Please don't

make anything you send to us public. It' s a lot of work to go through it and the impact is severely

reduced if we are not the first to publish." Guccifer 2.0 replied, "agreed. How much time will it

take?" Target Account 1 responded, " likely sometime today." Guccifer 2.0 wrote back, "will u

announce a publication? and what about 3 docs [I] sent u earlier?" Target Account 1 responded,

" I don' t believe we received them. Nothing on 'Brexit' for example." Guccifer 2.0 wrote back,

"wow. have you checked ur mail?" Target Account 1 replied, "At least not as of 4 days ago . . . .

For security reasons mail cannot be checked for some hours." Guccifer 2.0 wrote back, "fuck, [I]

sent 4 docs on brexit on jun 29, an archive in gpg[.] ur submission form is too fucking slow, [I]

spent the whole day uploading 1 gb." I know from my training and experience that the term "gb"

is an abbreviation for "gigabyte," a unit of measurement of information stored on a computer.

27. Target Account 1 wrote back, "We can arrange servers l00x as fast. The speed

restrictions are to anonymise the path. Just ask for custom fast upload point in an email."

Guccifer 2.0 wrote, "will u be able to check ur email?" Target Account 1 responded, "We're

best with very large data sets. e.g. 200gb. these prove themselves since they're too big to fake. "

2
The brackets appear in the original message.

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Guccifer 2.0 responded, "or shall I send brexit docs via submission once again?" Target

Account 1 responded, "to be safe, send via [web link]."

28. On or about that same day, Guccifer 2.0 wrote, "can u confirm u received dnc

emails?" Target Account 1 wrote back several messages later, "for security reasons we can 't

confirm what we' ve received here. e.g., in case your account has been taken over by us

intelligence and is probing to see what we have." Guccifer 2.0 responded, "then send me an

encrypted email." Target Account 1 wrote back, "we can do that. but the security people are in

another time zone so it will need to wait some hours." Target Account 1 wrote, "what do you

think about the FBl ' s failure to charge? To our mind the clinton foundation investigation has

always been the more serious. we would be very interested in all the emails/docs from there. She

set up quite a lot of front companies. e.g in sweden." Guccifer 2.0 responded, "ok, [l]'ll be

waiting for confirmation. [A]s for investigation, they have everything settled, or else I don' t

know how to explain that they found a hundred classified docs but fail to charge her. " Target

Account 1 responded, "She' s too powerful to charge at least without something stronger. [A]s

far as we know, the investigation into the clinton foundation remains open[.] [W]e hear the FBI

are 4nhappy with Loretta Lynch over meeting Bill, because he' s a target in that investigation."

29. On or about that same day, Guccifer 2.0 wrote to Target Account 1, "[D]o you

have any info about marcel lazar? There've been a lot of rumors of late." "Marcel Lazar" is the

name of a Romanian Hacker who used the pseudonym "Guccifer," and who pied guilty on May

25, 2016 in the Eastern District of Virginia to hacking the personal accounts of a variety of

victims, including a former U.S. president. According to publicly available reporting, in May

20 16, Lazar also claimed to have hacked the email served belonging to then-candidate Clinton.

Lazar stated, " For me, it was easy ... easy for me, for everybody." Lazar's claims have not been

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substantiated, and the undersigned is not aware of evidence indicating Lazar accomplished the

hack.

30. Target Account 1 wrote back, "the death? [A] fake story." Target Account 1

messaged: "His 2013 screen shots of Max Blumenthal's inbox prove that Hillary secretly deleted

at least one email about Libya that was meant to be handed over to Congress. So we were very

interested in his co-operation with the FBI." Guccifer 2.0 wrote back, "some dirty games behind

the scenes [I] believe[.] Can you send me an email now?" Target Account 1 wrote back, "No;

we have not been able to activate the people who handle it. Still trying." Guccifer 2.0 replied,

"what about tor submission? [W]ill u receive a doc now?" Target Account 1 replied, "We will

get everything sent on [weblink]." [A]s long as you see \"upload succseful\" at the end. [I]fyou

have anything hillary related we want it in the next tweo [sic] days prefable [sic] because the

DNC is approaching and she will solidify bernie supporters behind her after." Guccifer 2.0

responded, "ok. I see."

31. Target Account 1 wrote, " [W]e think the public interest is greatest now and in

early october." Guccifer 2.0 responded, "do u think a lot of people will attend bernie fans rally in

philly? Will it affect the dnc anyhow?" Target Account 1 wrote, "bernie is trying to make his

own faction leading up to the DNC. [S]o he can push for concessions (positions/policies) or, at

the outside, if hillary has a stroke, is arrested etc, he can take over the nomination. [T]he question

is this: can bemies supporters+staff keep their coherency until then (and after). [O]r will they

dis[s]olve into hillary's camp? [P]resently many of them are looking to damage hilary [sic]

inorder [sic] to increase their unity and bargaining power at the DNC. Doubt one rally is going to

be that significant in the bigger scheme. [I]t seems many of them will vote for hillary just to

prevent trump from winning."

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32. On or about that same day, Guccifer 2.0 sent Target Account 1 a message

reading, "sent brexit docs successfully." Target Account 1 responded, ":)))." Target Account 1

wrote back, "we think trump has only about a 25% chance of winning against hillary so conflict

between bernie and hillary is interesting." Guccifer 2.0 responded, "so it is." Target Account 1

wrote, "also, it' s important to consider what type of president hillary might be. If bernie and

trump retain their groups past 2016 in significant number, then they are a restraining force on

hillary."

33. On or about July 7, 2016, Target Account 1 wrote, "All good?" Guccifer 2.0

responded, "yeah, what about u? is smth wrong?" I know from my training and experience that

"smth" is used as an abbreviation for "something." Target Account 1 wrote back, "No. All

good." Guccifer 2.0 wrote back, "are working with the emails [I] sent u? [C]heck ur email. [I]

sent u a check archive from another email box. fuck, mail undelivered. [D]o you have another

way to receive large volumes of data? [B]esides for tor submission form?"

34. On or about July 11, 2016, Guccifer 2.0 wrote to Target Account 1, "sent it via

ur submission. check it."

35. On or about July 13, 2016, Guccifer 2.0 wrote, "r u there?" On or about July 14,

2016, Guccifer 2.0 wrote, "ping. Check ur email. sent u a link to a big archive and a pass."

Target Account 1 replied, "great, thanks; can' t check until tomorrow though ."

36. On or about July 17, 2016, Guccifer 2.0 wrote, "what bout now?" On or about

July 18, 2016, Target Account 1 responded, "have the 1Gb or so archive." Guccifer 2.0

responded, "have u managed to extract the files?" Target Account 1 responded, "yes. turkey

coup has delayed us a couple of days. [O]therwise all ready[.]" Guccifer 2.0 responded, "so

when r u about to make a release?" Target Account 1 wrote back, "this week. [D]o you have

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any bigger datasets? [D]id you get our fast transfer details?" Guccifer 2.0 wrote back, "i'll check

it. did u send it via email? Target Account 1 responded , "yes." Guccifer 2.0 replied, "to [web

link]. [I] got nothing." Target Account 1 wrote, "check your other mail? this was over a week

ago." Guccifer 2.0 wrote back, "oh, that one, yeah, [I] got it."

37. On or about July 18, 20 16, Target Account 1 wrote, "great. [D]id it work?"

Guccifer 2.0 wrote back, " [I] haven't tried yet." Target Account 1 responded, "Oh. We arranged

that server just for that purpose. Nothing bigger?" Guccifer 2.0 wrote back, "let's move step by

step, u have released nothing of what [I] sent u yet." Target Account 1 replied, "How about you

transfer it all to us encrypted. [T]hen when you are happy, you give us the decrypt key. [T]his

way we can move much faster. (A]lso it is protective for you if we already have everything

because then there is no point in trying to shut you up." Guccifer 2.0 wrote back, "ok, i' ll ponder

it."

D. Contacts Involving the Julian Assange, Roger Stone, and the Target Accounts

38. Approximately eight days after the last communication between Guccifer 2.0 and

WikiLeaks described above, on or about July 25, 2016, Stone sent an email to Jerome Corsi, an

author and political commentator, with the subject line, "Get to Assange." 3 The body of the

message read: "Get to Assange [a]t Ecuadorian Embassy in London and get the pendin~

wiki leaks emails ... they deal with Foundation, allegedly."

39. On or about A:ugust 2, 2016, Corsi emailed Stone, " Word is friend in embassy

plans 2 more dumps. One shortly after I'm back. 2nd in Oct. Impact planned to be very damaging

3
1. On August 7, 20 17, Chief Judge Beryl A. Howell of the District of Columbia issued a search warrant for
Roger Stone's Twitter account, @RogerJStoneJr. On September 11, 2017, Chief Judge Beryl A. Howell of the
District of Columbia issued a search warrant for Stone's Hotmail address, The relvant
results of those search warrants are summarized in the paragraphs which fo llow.

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... Time to let more than Podesta to be exposed as in bed w enemy if they are not ready to drop

HRC. That appears to be the game hackers are now about. Would not hurt to start suggesting

HRC old, memory bad, has stroke -- neither he nor she well. I expect that much of next dump

focus, setting stage for Foundation debacle." Based on my training, experience, and review of

materials in this case, it appears that Corsi's reference to a "friend in embassy [who] plans 2

more dumps" refers to Julian Assange (the user of Target Account 2), the founder of

WikiLeaks, who resided in Ecuador's London Embassy in 2016.

40. On or about August 16, 2016, Corsi emailed Stone a link to a piece Corsi had

written about Stone titled, "Trump Adviser: Wikileaks Plotting Email Dump to Derail Hillary."

41. As discussed above, on or about August 21, 2016, Roger Stone directed a

publicly-available tweet at John Podesta, Hillary Clinton' s presidential campaign manager,

stating: "Trust me, it will soon the [sic] Podesta's time in the barrel. #CrookedHillary."

42. On or about August 31, 2016, Corsi emailed Stone: "Did you get the PODESTA

write-up." STONE replied "Yes."

43. On or about September 6, 2016, Corsi emailed: "Roger[,] Is NY Post going to use

the Pedesta [sic] stuff?"

44. On or about October 7, 2016, WikiLeaks began releasing emails hacked from

John Podesta' s account.

45. WikiLeaks continued to release John Podesta' s hacked emails throughout October

I 0-21, 2016. On October 12, 2016, John Podesta argued publicly that " [it is] a reasonable

assumption to - or at least a reasonable conclusion - that [Stone] had advanced warning [of the

release of his emails] and the Trump campaign had advanced warning about what Assange was

going to do. I think there' s at least a reasonable belief that [Assange] may have passed this

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Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 16 of 31

information on to [Stone]." Commenting to the Miami Herald on or about that same date, Stone

responded: "I have never met or spoken with Assange, we have a mutual friend who ' s traveled to

London several times, and everything I know is through that channel of communications. I'm not

implying I have any influence with him or that I .have advanced knowledge of the specifics of

what he is going to do. I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills,

the Clinton aides, thought were deleted. I hear that through my emissary."

46. On or about that same day, October 12, 2016, Corsi emailed Stone on both the

with a subject line "Podesta talking points." Attached to the email was a file labeled, "ROGER

STONE podesta talking points Oct 12 2016.docx." The "talking points" included the statement

that, "Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation." Corsi followed

up several minutes later with another email titled, "Podesta talking points," with the text "sent a

second time just to be sure you go it." Stone emailed Corsi back, "Got them and used them."

47. On or about the next day, October 13, 20 I 6, Stone sent a private direct message to

Target Account 1 stating, "Since I was all over national TV, cable and print defending

wikileaks and assange against the claim that you are Russian agents and debunking the false

charges of sexual assault as trumped up bs you may want to rexamine the strategy of attacking

me- cordially R." Target Account 1 responded, "We appreciate that. However, the false claims

of association are being used by the democrats to undermine the impact of our publications.

Don't go there if you don't want us to correct you."

48. On or about October 16, 2016, Roger Stone wrote to Target Account 1, "Ha! The

more you \"con-ect\" me the more people think you're lying. Your operation leaks like a sieve.

You need to figure out who your friends are."

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49. On or about October 17, 2016, Corsi emailed Stone with the subject, "Fwd:

ASSANGE ... URGENT . .. " Corsi wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is he has a set of dead man files that include Hillary. It's

what they used to call a ' Mexican stand offt.]' Only hope is if Trump speaks out to save him[ .)

Otherwise he's dead anyway, once he' s dropped what he has. If HRC wins, Assange can kiss his

life away. Interesting gambit Assange has to play out. He' s called Podesta's bluff and raised him

the election."

50. The presidential election was held on November 8, 2016.

51. On or about November 9, 2016, Target Account 1 messaged Roger Stone,

" Happy?" and then wrote, "We are now more free to communicate."

52. On or about March 27, 2017, Target Account 1 wrote to Roger Stone, "FYI,

while we continue to be unhappy about false \"back channel\" claims, today CNN deliberately

broke our off the record comments."

53. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between Stone and WikiLeaks. The same article quoted

Stone as stating: " Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true. "

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54. On or about April 7, 2017, Roger Stone wrote to Target Account 1, " I am JA's

only hope for a pardon the chances of which are actually (weirdly) enhanced by the bombing in

Syria (which I opposed) . You have no idea how much your operation leaks. Discrediting me

only hurts you. Why not consider saying nothing? PS- Why would anyone listen to that asshole

Daniel Ellsberg." Based on my training, experience, and review of materials in this case, I

believe that "JA" refers to Julian Assange, the user of Target Account 2.

55. On or about April 19, 2017, Assange, using Target Account 2, wrote to Stone,

"Ace article in infowars. Appreciated. But note that U.S. intel is engages in slight of hand

maoevers [sic]. Listen closely and you see they only claim that we received U.S. election leaks

\"not directly\" or via a \"third party\" and do not know \"when\" etc. This line is Pompeo appears

to be getting at with his \"abbeted\". This correspnds to the same as all media and they do not

make any allegation that WL or I am a Russia asset."

56. On or about June 4, 2017, Roger Stone wrote back to Target Account 2, "Still

nonsense. As a journalist it doesn't matter where you get information only that it is accurate and

authentic. The New York Times printed the Pentagon Papers which were indisputably stolen

from the government and the courts ruled it was legal to do so and refused to issue an order

restraining the paper from publishing additional articles. If the US government moves on you I

will bring down the entire house of cards. With the trumped-up sexual assault charges dropped I

don't know of any crime you need to be pardoned for - best regards. R." Target Account 2

responded, "Between CIA and DoJ they're doing quite a lot. On the DoJ side that's coming most

strongly from those obsessed with taking down Trump trying to squeeze us into a deal."

57. On or about June 10, 2017, Roger Stone wrote to Target Account 2, "I am doing

everything possible to address the issues at the highest level of Government. Fed treatment of

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you and Wikileaks is an outrage. Must be circumspect in this forum as experience demonstrates

it is monitored. Best regards R ." Target Account 2 wrote back, "Appreciated. Of course it is!"

E. Target Account 1 Sends the "Guessed" Password to " " to

58. During the events described above, Target Account 1 also engaged in a separate

proviate conversation regarding a "guessed" password to the non-public website

"PutinTrump.org." On or about September 20, 2016, at approximately 9:07PM, Target Account

1 publicly tweeted, " ' Let's bomb Iraq' Progress for America PAC to launch 'PutinTrump.org' at

9:30.a m . Oops pw is putintrump.org."

59. On or about September 20, 2016, at approximately 11 :59PM, Target Account 1

sent a private message to a high level individual associated with the Campaign (the "high-level ·

Campaign individual"). 4 The message stated: "A PAC run anti-Trump site ' ' is

about to launch. The PAC is a recycled pro-Iraq war·PAC. We have guessed the password. It is

'. See 'About ' for who is behind it. Any comments?"

60. According to publicly available reporting, at approximately 9:31AM on or about

September 21 , 2016, the website " " was launched. The website was run by

individuals who stated they wanted to focus attention to what they described as the "dangerous

and unprecedented ties" between Vladimir Putin and Donald J. Trump.

61. On or about September 21, 2016, at approximately I I :50AM (approximately two

hours after PutinTrump.org went " live" according to publicly available press accounts), the high-

4
These records were obtained via a search warrant signed by Chief Judge Beryl A. Howell of the District of
Columbia on October 12, 2017.

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level Campaign individual sent Target Account 1 a private message: "Off the record I don't

know who that is but I' ll ask around. Thanks."

INFORMATION CONCERNING TWITTER

62. Twitter owns and operates a free-access social-networking website of the same

name that can be accessed at http://www.twitter.com. Twitter allows its users to create their own

profile pages, which can include a short biography, a photo of themselves, and location

information. Twitter also permits users to create and read 140-character messages called

"Tweets," and to restrict their "Tweets" to individuals whom they approve. These features are

described in more detail below.

63. Upon creating a Twitter account, a Twitter user must create a unique Twitter

usemame and an account password, and the user may also select a different name of 20

characters or fewer to identify his or her Twitter account. The Twitter user may also change this

usemame, password, and name without having to open a new Twitter account.

64. Twitter asks users to provide basic identity and contact information, either during

the registration process or thereafter. This information may include the user's full name, e-mail

addresses, physical address (including city, state, and zip code), date of birth, gender, hometown,

occupation, and other personal identifiers. For each user, Twitter may retain information about

the date and time at which the user's profile was created, the date and time at which the account

was created, and the Internet Protocol ("IP") address at the time of sign-up. Because every

device that connects to the Internet must use an IP address, IP address information can help to

identify which computers or other devices were used to access a given Twitter account.

65. A Twitter user can post a personal photograph or image (also known as an

"avatar") to his or her profile, and can also change the profile background or theme for his or her

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account page. In addition, Twitter users can post "bios" of 160 characters or fewer to their profile

pages.

66. Twitter also keeps IP logs for each user. These logs contain information about the

user's logins to Twitter including, for each access, the IP address assigned to the user and the

date stamp at the time the user accessed hi s or her profile.

67. As discussed above, Twitter users can use their Twitter accounts to post "Tweets"

of 140 characters or fewer. Each Tweet includes a timestamp that displays when the Tweet was

posted to Twitter. Twitter users can also "favorite," "retweet," or reply to the Tweets of other

users. In addition, when a Tweet includes a Twitter username, often preceded by the @ sign,

Twitter designates that Tweet a "mention" of the identified user. In the "Connect" tab for each

account, Twitter provides the user with a list of other users who have "favorited" or "retweeted"

the user's own Tweets, as well as a list of all Tweets that include the user' s username (i.e., a list

of all "mentions" and "replies" for that username).

68. Twitter users can include photographs or images in their Tweets. Each Twitter

account also is provided a user gallery that includes images that the user has shared on Twitter,

including images uploaded by other services.

69. Twitter users can also opt to include location data in their Tweets, which will

reveal the users' locations at the time they post each Tweet. Thi s "Tweet With Location"

function is off by default, so Twitter users must opt in to the service. In addition, Twitter users

may delete their past location data.

70. When Twitter users want to post a Tweet that includes a link to a website, they

can use Twitter's link service, which converts the longer website link into a shortened link that

begins with http://t.co. This link service measures how many times a link has been clicked.

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71 . A Twitter user can "follow" other Twitter users, which means ~ubscribing to

those users' Tweets and site updates. Each user profile page includes a list of the people who are

following that _user (i.e., the user' s "followers" list) and a list of people whom that user follows

(i.e., the user's "following" list). Twitters users can "unfollow" users whom they previously

followed, and they can also adjust the privacy settings for their profile so that their Tweets are

visible only to the people whom they approve, rather than to the public (which is the default

setting). A Twitter user can also group other Twitter users into " lists" that display on the right

side of the user' s home page on Twitter. Twitter ilso provides users with a list of "Who to

Follow," which includes a few recommendations of Twitter accounts that the user may find

interesting, based on the types of accounts that the user is already following and who those

people follow.

72. In addition to posting Tweets, a Twitter user can also send DMs to one of his or

her followers. These messages are typically visible only to the sender and the recipient, and both

the sender and the recipient have the power to delete the message from the in boxes of both users.

As of January 2012, Twitter displayed only the last 100 DMs for a particular user, but older DMs

are stored on Twitter's database.

73. Twitter users can configure the settings for their Twitter accounts in numerous

ways. For example, a Twitter user can configure his or her Twitter account to send updates to the

user's mobile phone, and the user can also set up a "sleep time" during which Twitter updates

will not be sent to the user's phone.

74. Twitter includes a search function that enables its users to search all public

Tweets for keywords, usemames, or subject, among other things. A Twitter user may save up to

25 past searches.

21
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 23 of 31

75. Twitter users can connect their Twitter accounts to third-party websites and

applications, which may grant these websites and applications access to the users' public Twitter

profiles.

76. If a Twitter user does not want to interact with another user on Twitter, the first

user can "block" the second user from following his or her account.

77. In some cases, Twitter users may communicate directly with Twitter about issues

relating to their account, such as technical problems or complaints. Social-networking providers

like Twitter typically retain records about such communications, including records of contacts

between the user and the provider's support services, as well as records of any actions taken by

the provider or user as a result of the communications. Twitter may also suspend a particular user

for breaching Twitter' s terms of service, during which time the Twitter user will be prevented

from using Twitter' s services.

78. As explained herein, information stored in connection with a Twitter account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, a

Twitter user' s account information, IP log, stored electronic communications, and other data

retained by Twitter, can indicate who has used or controlled the Twitter account. This " user

attribution" evidence is analogous to the search for "indicia of occupancy" while executing a

search warrant at a residence. For example, profile contact information, communications,

"tweets" (status updates) and "tweeted" photos (and the data associated with the foregoing, such

as date and time) may be evidence of who used or controlled the Twitter account at a relevant

time. Further, Twitter account activity can show how and when the account was accessed or

22
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 24 of 31

used. For example, as described herein, Twitter logs the Internet Protocol (IP) addresses from

which users access their accounts along with the time and date. By determining the physical

location associated with the logged IP addresses, investigators can understand the chronological

and geographic context of the account access and use relating to the crime under investigation.

Such information allows investigators to understand the geographic and chronological context of

Twitter access, use, and events relating to the crime under investigation. Additionally, Twitter

builds geo-location into some of its services. If enabled by the user, physical location is

automatically added to "tweeted" communications. This geographic and timeline information

may tend to either inculpate or exculpate the Twitter account owner. Last, Twitter account

activity may provide relevant insight into the Twitter account owner's state of mind as it relates

to the offense under investigation. For example, information on the Twitter account may

indicate the owner' s motive and intent to commit a crime (e.g., information indicating a criminal

plan) or consciousness of guilt (e.g., deleting account information in an effort to conceal

evidence from law enforcement).

79. Therefore, the computers of Twitter are likely to contain all the material described

above, including stored electronic communications and information concerning subscribers and

their use of Twitter, such as account access information, transaction information, and other

account information.

INFORMATION TO BE SEARCHED AND THINGS TO BE SEIZED

80. I anticipate executing this warrant under the Electronic Communications Privacy

Act, in particular 18 U.S.C. §§ 2703(a), 2703(b)(l)(A) and 2703(c)(l)(A), by using the warrant

to require Twitter to disclose to the government copies of the records and other information

(including the content of communications) associated with the accounts in Attachment A and

23
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 25 of 31

particularly described in Section I of Attachment B. Upon receipt of the information described in

Section I of Attachment B, government-authorized persons will review that information to locate

the items described in Section II of Attachment B.

CONCLUSION

81. Based on the forgoing, I request that the Court issue the proposed search warrant.

82. Pursuant to 18 U.S .C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

83. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

~AmyArson~
Special Agent
Federal Bureau of Investigation

Subscribed and sworn to before me on this(; ~ay of November, 2017.

&~~
The Honorable Beryl A. Howell
Chief United States District Judge

24
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 26 of 31

ATTACHMENT A

Property to Be Searched

All information that is associated with the Twitter profile with usernames from the period

from July 1, 2015 to the present:

@Wikileaks (twitter.com/wikileaks) (Target Account 1)

@JulianAssange(twitter.com/JulianAssange) (Target Account 2)

that is stored at premises owned, maintained, controlled, or operated by Twitter, a company

headquartered in San Francisco, California.


Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 27 of 31

ATTACHMENT B

Particular Things to be Seized

I. Information to be disclosed by Twitter

To the extent that the information described in Attachment A is within the possession,

custody, or control of Twitter, including any messages, records, files, logs, or information that

have been deleted but are still available to Twitter, or have been preserved pursuant to a request

made under 18 U .S.C. § 2703(f), Twitter is required to disclose the following information to the

government for each account listed in Attachment A:

a. All identity and contact information, including full name, e-mail address, physical

address (including city, state, and zip code), date of birth, gender, hometown,

occupation, and other personal identifiers;

b. All past and current usernames, account passwords, and names associated with

the account;

c. The dates and times at which the account and profile were created, and the

Internet Protocol ("IP") address at the time of sign-up;

d. All IP logs and other documents showing the IP address, date, and time of each

login to the account;

e. All data and information associated with the profile page, including photographs,

"bios," and 'profile backgrounds and themes;

f. All "Tweets" and Direct Messages sent, received, "favorited," or retweeted by the

account, and all photographs or images included in those Tweets and Direct

Messages;
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 28 of 31

g. All information from the "Connect" tab for the account, including all lists of

Twitter users who have favorited or retweeted Tweets posted by the account, as

well as a list of all Tweets that include the usemame associated with the account

(i.e., "mentions" or "replies");

h. All photographs and images in the user gallery for the account;

1. All location data associated with the account, including all information collected

by the "Tweet With Location" service;

J. All information about the account' s use ofTwitter's link service, including all

longer website links that were shortened by the service, ·all resulting shortened

links, and all information about the number of times that a link posted by the

account was clicked;

k. All data and information that has been deleted by the user;

I. A list of all of the people that the user follows on Twitter and all people who are

following the user (i.e., the user' s "following" list and "followers" list);

m. A list of all users that the account has "unfollowed" or blocked;

n. All "lists" created by the account;

o. All information on the " Who to Follow" list for the account;

p. All privacy and account settings;

q. All records of Twitter searches performed by the account, including all past

searches saved by the account;

r. All information about connections between the account and third-party websites

and applications;

2
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 29 of 31

s. All records pertaining to communications between Twitter and any person

regarding the user or the user' s Twitter account, including contacts with support

services, and all records of actions taken, including suspensions of the account.

3
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 30 of 31

II. Information to be seized by the government

All information described above in Section I that constitutes fruits, evidence, and

instrumentalities of violations of 18 U .S.C. § 1030 (fraud and related activities in connection

with computers), 50 U.S.C. § 30121 (foreign contribution ban), 18 U.S.C. § 371 (conspiracy to

commit an offense against the United States), and 18 U.S.C. § 2 (aiding and abetting) since

March 1, 2016 including, for each user ID identified on Attachment A, information pertaining to

the following matters:

a. Any correspondence regarding hacked emails or other data from:

1. the Democratic National Committee (DNC)

11. the email belonging to John Podesta ("the email hack")

111. any other individual related to the 2016 United States election.

b. Any communications between the Target Accounts and individuals

associated with the DNC email hack;

c. Any communications indicating any advance knowledge or direction,

planning, or control of the email hack;

d. Any communications related to the website PutinTrump.Org.

e. Evidence indicating how and when the Twitter account was accessed or used,

to determine the chronological and geographic context of account access, use,

and events relating to the crime under investigation and to the Twitter account

owner;

f. Evidence indicating the Twitter account owner's state of mind as it relates to

the crime under investigation;

4
Case 1:19-mc-00029-CRC Document 29-4 Filed 04/28/20 Page 31 of 31

g. The identity of the person(s) who created or used the user ID, including

records that help reveal the whereabouts of such person(s).

h. The identity of the person(s) who communicated with the accounts about

matters related to 18 U.S.C. § 1030, including records that help reveal their

whereabouts.

5
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 1 of 35

AO 93 (Rev. I l/13) Search and Seizure Warrant

UmrBI STATBS DTSTruCT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched
Case: 1'.17-mj-00982
)
or identify the person by name and address) )
Assigned To . Howell, BerylA.
) Assign. Date : 1211912017
INFORMATION ASSOCIATED WITH
) Description: Search and Seizure Warrant
)

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or propefty located in the Northern District of California
(identify the person or describe the property to be searched and give its location)',

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal Qdentifu the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before January 2, 2018 fuot to exceed t 4 days)
ilf in the daytime 6:00 a.m. to 10:00 p.m. ü at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the propefty was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. BervlA. Howell
(United States Magisffate Judge)

üPursuant to 18 U.S.C. $ 3103a(b), I find that immediate notification may have an adverse result listed in l8 U.S'C'
$ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized þheck the appropriate box)
fl for_days (nottoexceed30) il until,thefactsjustifying,thelaterspecificdateof

Date and time issued: 2ù/ ¿//h //ntu


Judge's signature

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 2 of 35

AO 93 (Rev. I l/13) Search and Seizure Wanant (Page 2)

Return

Case No.: Date and time warrant executed Copy of warrant and inventory left with

Inventory made in the presence of

Inventory ofthe properfy taken and name ofany person(s) seized:

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing ffi cer's s ignature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 3 of 35
AO l0ó (Rev. 04/10) Application t-or a Search Warrant

UmreD STATES DrsrRrcr Counr


0Ec Í e 20P
for the
Disfrict of Columbia ûlerk,
üourts å:-å5iifiåjÍ#,ffiffi*
In the Matter of the Search of Case: 1'.17-mi-O0982
(Briefly describe the property to be searched
or identify the person by name and address) Assigned To : Howell, BerYlA.
INFORMATION ASSOCIATED WTH
Assign. Date : 1211912017
Description: Search and Seizure Warrant

APPLICATION FOR A SEARCH WARRANT


, l, à federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the followiñg person or prdperty (identifu the person or describe the
property to be searched and give its location):

See Attachment A.
located in the Northern District of California , there is now concealed (dentifu the
person or describe Íhe property to be seized)i
See Attachment B.
This warrant is sought pursuant to l8 U.S.C. $$ 2703(a), 2703(bX1XA), and 2703(cXlXA).

The basis for the search under Fed. R. Crirn. P. a I (c) is (check one or more):

devidence of a crime;
dcontraband, fruits of crime, or other items illegally possessed;
dproperry designed for use, intended for use, or used in committing a crime;
ü a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section
18 U.S.C. S 1030 F ra ud a nd re ated activiti es h !#{:&3:iííK33i 0r,"'.,
I

18 U.S.C. S 371; 2 Conspiracy against the United States; Aídíng and abetting
52 U.S.C. S 30121 Foreign contribution ban
The application is based on these facts:

See attached Affidavit.

f, Continued on the attached sheet.


f, Delayed notice of _...._ days (give exact ending date if more than 30 days ) is requested
under l8 U.S.C. $ 3 I 03 a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA Applicant's signature

Aaron Zelinsky (ASC) Amy Anderson, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date: 12t19t2017 %2",æ


's signature

City and s1¿1s; Washington, D'C Hon. BerylA. Howell, Chief U.S. District J udge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 4 of 35

FTI.EÞ
IN THE UNITED STATES DISTRICT COURT DEC Ig 20t7
FOR THE DISTzuCT oF'r-oT IT]\IRIÁ

case: 1 :1 7-mj lfå?åTifrå:fffi#mil:' -


IN THE MATTER OF THE SEARCH OF 'onrpffi*
BerYlA.
Assigned To : Howell,
INFORMATION ASSOCIATED WITH :
Assign. Date 1211912017
Description: Search and Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Amy A. Anderson, being first duiy sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT B ACKGROIINT)

1. I make this affidavit in support of an application for a search warrant for

information associated with the following email account (hereafter the Target Account),

described in more detail in Attachments A and B:

o (the "Target Account") an email address associated

with , described further in Attachment A, maintained by

Google;

The information to be disclosed by Google (hereafter "the Provider") and searched by the

government is described in the following paragraphs and in Attachments A and B. This affidavit

is made in support of an application for a search warrant under 18 U.S.C. $$ 2703(a),

27 03 (b)(I)(A), and 2703 (cX 1 XA).

2. I am a Special Agent with Federal Bureau of Investigation ("FBI") assigned to

FBI Headquarters working directly with the Special Counsel's Office. I have been a Special

Agent with the FBI since 2010. Since then, I have conducted national security investigations of

foreign intelligence services, espionage, and counter proliferation matters. I have training and

experience related to espionage and foreign intelligence services national security investigations.
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 5 of 35

I have conducted and participated in various investigations involving multiple threat countries as

well as national security.threats and appiicable criminal violations

3. The facts in this affidavit come fi'om my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause ftrr the requested warrant and does not set

forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Account contáins communications relevant to

violations of 18 U.S.C. $ 1030 (fraud and related activities in connection with computers), 52

U.S.C. $ 30121 (foreign contribution ban), 18 U.S.C. $ 371 (conspiracy to commit an offense

against the United States), and 18 U.S.C. $ 2 (aiding and abetting).

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as deftned by 18 U.S.C. ç2711. /d. $$ 2703(a), (bX1XA), & (cX1XA).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a courl) . . . that has jurisdiction over the offense being investigated." 18 U.S.C.

$ 2711(3XAXi). The offense conduct included activities in Washington, D.C., as detailed below,

including in paragraph 1 1.

SUMMARY

6. On or about July 25,2016, Roger STONE emailed Jerome CORSI to "Get to

Assange" in person at the Ecuadorian Embassy and "get pending Wikileaks emails[.]" On or

about August I,2016, STONE also instructed CORSI to have (the user of

tlre Target Account) contact Julian ASSANGE. On or about August 2,2016, CORSI responded

2
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 6 of 35

to STONE that the "word is fi'iend in embassy IASSANGE] plans 2 more dumps. One shortly

after I'm b ack. 2nd in October. Impact planned 1o be. very .damaging. .. . Time to let Podesta to be

exposed as in bed w enemy if they are not ready to drop I{RC." Information disclosures

subsequently occurred on or about the times CORSI predicted: On or about August 12,2016, the

day CORSI was scheduled to return to the United States ("shortly after I'm back"), Guccifer 2.0

released hacked information related to the Democratic Congressional Campaign Committee

(DCCC). On October 7 ,2016 ("in October"), Wikileaks began releasing emails hacked from

John Podesta's email account.

7. On or about November 13,2016, , using the Target Account,

emailed Stone to congratulate him on "tak[ing] the country back," and stating, "You deserve a

lot of credit and working with you and Jeri Corsi, who is with me now in London has been a

great joy." On or about January 7,2017, using the Target Account emailed

recipients about John Podesta going "phishing."

PROBABLE CAUSE.

A. Background on Relevant Individuals

i. Roger STONE

8. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of Trump's presidential campaign. As

described further below, STONE also maintained contact with individuals employed by the

J
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 7 of 35

Campaign, including then-campaign chairman Paul MANAFORT and deputy chairman Rick

.GATES

ii. Jerome CORSI

g. Jerome CORSI is a political commentator who, according to publicly available

information, serves as the "'Washington Bureau Chief for Inforwars.com." According to

publicly-available sources, from2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a"/k/a "WND.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described fuither below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by Wikileaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

iii.
10.

4
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 8 of 35

B. Disclosure of Hacked Information by Wikileaks During the 2016 Presidential


Campaign

1 1. According to the public and unclassified intelligenòe report prepared by the

United States Intelligence Community, Russian intelligence gained access to the Democratic

National Committee (DNC) networks in July 2015 and maintained that access until at least June

2016. By March 20I6,the Russian military intelligence (General Staff Main Intelligence

Directorate or "GRU") probably began cyber operations aimed atthe U.S. election. The GRU

operations resulted in the compromise of personal e-mail accounts within the DNC and other

Democratic Party officials and political figures. By in or about }/ray 20ï6, the GRU had

exfiltrated large volumes of data from the DNC. The DNC headquarters is located at 430 South

Capitol Street SE, Washington, D.C. 20003.

12. The public and unclassified intelligence report assessed that:

a. The GRU used a Twitter account, "Guccifer 2.0" andthe website

DCleaks.com to release the U.S. victim data obtained in cyber operations publicly and in

exclusives to media outlets and relayed material to Wikileaks.

b. Guccifer 2.0, who claimed to be an independent Romanian hacker, made

multiple contradictory statements and false claims about his likely Russian identity

throughout the election.

c. Content that was taken from e-mail accounts targeted by the GRU in

March 2016 appeared on DCleaks.com starting in June 2016.

5
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 9 of 35

d. The GRU relayed material it acquired from the DNC and senior

Democratic officials to Wikileaks. Wikileaks .was mostly likely, chosen.because of its

self-proclaimed reputation for authenticity. Disclosures through Wikileaks did not

contain any evident forgeries.

e. The Kremlin's principal international propaganda outlet RT (formerly

Russia Today) has actively collaborated with Wikileaks. RT's editor-in-chief visited

Wikileaks founder Julian ASSANGE at the Ecuadorian Embassy in London in August

z}I3,where they discussed renewing his broadcast contract with RT, according to

Russian and Vy'estern media. Russian media has subsequently announced that RT had

become "the only Russian media company" to partner with V/ikileaks and had received

access to "new leaks of secret information."

13. On or about June 14, 2016, the Washington Post reported that "Russian

government hackers" had penetrated the DNC computer network and stole opposition research

on Donald J. Trump. The Kremlin's spokesman denied any Russian involvement in the hack.

14. On or about June 15, 2016, Guccifer 2.0 claimed responsibility for the DNC hack

and began posting hacked documents.

15. On or about JuIy 22,20ì6,V/ikileaks published about 20,000 emails stolen from

the DNC.

16. On or about August 12,2016, Guccifer 2.0 released personal cellphone numbers

and email addresses from the files of the Democratic Congressional Campaign Committee

(DCCC).

17. On or about August 2I,2016, Roger STONE sent a publicly-available tweet

referring to John Podesta, Hillary Clinton's presidential campaign manager, stating: "Trust me, it

6
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 10 of 35

will soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that

,same day, Stone reiterated that because of the work of a "imutual acquaintancel.of both his and

[Assange], the public fcould] expect to see much more from the exiled
whistleblower in the form

of strategically-dun'rped Clinton email batches." He added: "'Well, first of all, I think Julian

Assange is a hero... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

18. On Friday, October 7,2016,at approximately 4:03 P.M., the V/ashington Post

published an article containing a recorded conversation from a2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

lg. Approximately a half hour later, at 4:32 P.M., Wikileaks sent out a public Tweet

reading "RELEASE: The Podesta Emails #HillaryClinton #Podesta #imWithHer" and containing

a link to approxim ately 2,050 emails that had been hacked from John Podesta's personal email

account. V/ikileaks continued to release John Podesta's hacked emails throughout October 10-

14,2016.

C. Roger STONE's Private Twitter Messagbs with Guccifer 2.0, Wikileaks, and Julian
ASSANGE.

20. As discussed above, on or about July 22,2016, Wikileaks published

approximately 20,000 emails stolen from the DNC.

21. On August 5,2076,Roger Stone published an article on Breitbart.com entitled,

ooDear
Hillary: DNC Hack Solved, So Now Stop Blaming Russia." Stone wrote: "It doesn't

seem to be the Russians that hacked the DNC, but instead a hacker who goes by the name of

Guccifer 2.0."

7
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 11 of 35

22. On August 12,2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the,leal #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the Democratic Congressional Campaign

Committee (DCCC).

'¿3. On August l3,2olti, Stone posted a tweet using @RogerJStoneJr calling Guccifer

2.0 a "HERO" after Guccifer 2.0 hadbeen banned from Twitter. The next day, Guccifer 2.0's

Twitter account was reinstated.

24. On August 14,20l6,Stone sent a private message on Twitter using

@RogerJStoneJr to Guccifer 2.0, stating he was "delighted" to see the user's Twitter
handle

reinstated after having been suspended.l

25. On August 15,2016, Guccifer 2.0 replied to Stone at @RogerJStoneJr, stating:

"wow. thank u for writing back, and thank u for an article about me!!! did you find an¡hing

interesting in the docs I posted."

26. On August 16,2016, Stone sent a private message using @RogerJStoneJr asking

Guccifer to retweet an article he had written regarding the 'rigg[ing]' of the 2016 presidential

elections.

27. On August 17,2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a greatpleasure to me."

28. On August 18,2016, Paul Manafoft, Stone's longtime friend and associate,

resigned as Chairman of the Campaign. Contemporary press reports at the time indicated that

I On or about August7,2017, Chief Judge Beryl A. Howell issued a search warant for the Twitter account

@RogerJStoneJr.

8
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 12 of 35

Manafort had working with a Washington D.C.-based lobbying firms to influence U.S. policy

toward Ukrairre.

29. On August 2L,2016, using @RogerJStoneJR, Stone directed a tweet at John

Podesta, Hillary Clinton's presidential campaign manager, stating: "Trust me, it will soon the

lsicl Podesta's time in the barrel. #CrookedHillary."

30. On September 16, 2016 Stone said in a radio interview with Boston Herald Radio

that he expected Wikileaks to "drop a payload of new documents on a weekly basis fairly soon.

And that of course will answer the question of exactly what was erased on that email server."

3 1 . On Saturday, October 1,2016, using @RogerJStoneJr, Stone Tweeted,

"Wednesday @ Hillary Clinton i s done. #Wiki Leaks. "

32. On Sunday, October 2,20\6,MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement Julian Assange had scheduled for the next day from the :

balcony of the Ecuadoran Embassy in London. On the day of the Assange announcement -
which was part of V/ikileaks' 1O-year anniversary celebration - Stone told Infowars that his
intermediary described this release as the "mother load."

33. On Tuesday, October 4,2016, Stone used @RogerJStoneJr to tweet: "Payload

coming. #Lockthemup."

34. As discussed above, on Friday, October 7,2016, Wikileaks began to release

emails that had been hacked from John Podesta's personal email account.

35. On or about October 12,2016, John Podesta - referring back to Stone's August

2I,2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption

to - or at least a reasonable conclusion - that fStone] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

9
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 13 of 35

think there's at least a reasonable belief that fAssange] may have passed this information on to

[Stone]." Commenting to the Miami Herald, Stone responded: "I have never met or spoken with

Assange, we have a mutual friend who's traveled to London several times, and everything I

know is through that channel of communications. I'm not implying I have any influence with

him or that I have aclvanced knowledge of the specifics of what he is going to do. I do believe he

has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides, thought were

deleted. I hear that through my emissary."

36. On or about the next day, Octòber 13, 2016, @RogerJStoneJr sent a private direct

message to the Twitter account @Wikileaks. The message read: "Since I was all over national

TV, cable and pri.nt defending Wikileaks and assange against the claim that you are Russian

agents and debunking the false charges of sexual assault as trumped up bs you may want to

rexamine the strategy of attacking me- cordially R." Less than an hour later, @wikileaks

responded by direct message: "We appreciate that. However, the false claims of association are

being used by the democrats to undermine the impact of our publications. Don't go there if you

don't want us to correct you."

37. On October 16,2016, @RogerJStoneJr sent a direct message to @wikileaks: "Ha!

The more you \"correct\" me the more people think you're lying. Your operation leaks like a

sieve. You need to figure out who your friends are."

38. On November 9,2016, one day after the presidential election, @wikileaks sent a

direct message to @RogerJStoneJr containing a single word: "Happy?" @wikileaks immediately


ooWe
followed up with another message less than a minute later: are now more free to

communicate."

10
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 14 of 35

39 . On March 70, 2Al7 , Stone spoke with The Washington Times and acknowledged

he had been in contact with Guccifer 2.0 using @RogerJStoneJr. Stone publicly stated that he

had been in contact with Guccifer 2.0 regarding the DNC hack, and that he had used Twitter's

private message system to do so. Stone provided a copy of the private messages to The

Washington Times.

40. On or about March 27 ,2017 ,CNN reported that a representative of Wikileaks,

writing from an email address associated with'Wikileaks, denied that there was any backchannel

communication during the Campaign between Stone and Wikileaks. The same article quoted

Stone as stating: "Since I never communicated with Wikileaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope oftheir subsequent disclosures. So I am clairvoyant orjust a good guesser because the

limited things I did predict (Oct disclosures) all came true."

4I. On or about June 4, 2017,@RogerJStoneJr directly messaged @JulianAssange,

an address associated with Julian Assange in numerous public reports, stating: "Still nonsense.

As a journalist it doesn't matter where you get information only that it is accurate and authentic.

The New York Times printed the Pentagon Papers which were indisputably stolen from the

government and the courts ruled it was legal to do so and refused to issue an order restraining the

paper from publishing additional articles. If the US government moves on you I will bring down

the entire house of cards. V/ith the trumped-up sexual assault charges dropped I don't know of

any crime you need to be pardoned for - best regards. R." That Same day, @JulianAssange

responded: "Between CIA and DoJ they're doing quite a lot. On the DoJ side that's coming most

strongly from those obsessed with taking down Trump trying to squeeze us into a deal."

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Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 15 of 35

42. On or about June i0, 2017, @RogerJStoneJr sent a direct message to @wikileaks,

reading: "l am doing everything possible to address the issues at the highest level of

Government. Fed treatment of you and Wikileaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

D. Roger S'l'ONl-'s !-maits with Jerome CORSI and


43. On September 11, 2017 " Chief Judge Beryl A. Howell of the District of Columbia

issued a search warant for STONE's l address, Emails

recovered pursuant to that search warrant indicated the following:

44. On or about June 20, 20|6, , using the Target Account, emailed

STONE and Paul MANAFORT, the Campaign Chairman, asking to "know imrnediately how I

can help" the Campaign. also wrote that his "research on Rhodes House" was

nearing completion. The "Rhodes House" research appears to be a reference to STONE's

previous tweet on or about October T3,2015 that, "In 1969, Bill Clinton was expelled from

Oxford for raping nineteen-year-old ." Rhodes House is the headquarters of the

Rhodes Trust, and STONE mentioned again to a month later, as

discussed below.

45. On or about luly 7,2016, , using the Target Account, emailed Stone

that he had "my tickets to Cleveland[.] [D]o you have my credential pack?" appears

to be referencing the Republican National Convention held in Cleveland.

46. On or about July 25,20ì6, , using the Target Account, forwarded

an email to STONE and CORSI with the subject line: "Fwd: The Bill Gates of Turkey wants to

createa campaign for Donald J Trump in Turkey." wrote: "Do you want to have a

talk about this? Turkey is for Trump!" Below was a forwarded message sent to the Target

12
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 16 of 35

Account from an individuat who stated that he had been contacted by the "Bill Gates of Turkey,

in regards to creating a robust campaign for Mr Donald J Trump'"

47. On or about that same day, .Tuly 25,2016, (approximately three days after

Wikileaks began releasing emaiis hacked from the DNC), emailed Roger

STONE with the subject line, "You need to get to Assange." The body of the message read: "At

Ecuadorian Embassy in London and get the pending wikileaks emails...they deal with

Foundation, allegedly."

48. According to records , approximately ninety

minutes later STONE called CORSI and they spoke for 26 minutes.

49. Less than two hours after the phone call to CORSI, STONE emailed CORSI at

with the subject line, "Get to Assange." The body of the message read: "Get to Assange [a]t

Ecuadorian Embassy in London and get pending Wikileaks emails...they deal with Foundation,

allegedly." It appears that STONE cut and pasted the email from to CORSI.

50. On or about July 27,2016, then-candidate Donald Trump stated in a press

conference, "Russia, if you are listening, I hope you're able to find the 30,000 [Hillary Clinton]

emails that are missing. I think you will probably be rewarded mightily by our press. Let's see if
that happens. That will be next."

51. On or about July 28, 2016, Roger STONE called Richard GATES (then the

deputy-chair of the Campaign). The two spoke for approximately twelve minutes.

52. On or about July 30, 2016, Paul MANAFORT (then the Chairman of the

Campaign) called STONE. The two spoke for approximately one hour and seven minutes. The

Government has analyzedtoll records from January 1,2016 to November 9,2016. Sixty-seven

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Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 17 of 35

minutes is the longest call (by almost a halÊhour) that took place between STONE and

MANAFORT in this time period.

53. On or about July 31,2016, STONE called GATES and the two spoke for

approximately 5 minutes. Approximately ninety minutes later, STONE emailed CORSI at with

the subject [ine, "Call me MON."'l'he tsody read: should see Assange[.]

should find Bemie sanders brother who called Bill a Rapist - turn him for Trump[.]

should find or more proof of Bill getting kicked out."

54. On or about August 2,2016(approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE: "V,/ith family, 25th

wedding anniversary Aug 9. Return Home Aug12. Word is friend in embassy plans 2 more

dumps. One shortly after I'm back. 2ndinOct. Impact planned to be very damaging . . .Time to

let more than Podesta to be exposed as in bed w enemy if they are not ready to drop HRC. That

appears to be the game hackers are now about. Would not hurt to start suggesting HRC old,

memory bad, has stroke -- neither he nor she well. I expect that much of next dump focus, setting

stage for Foundation debacle." Based on my training, experience, and review of materials in this

o'friend in embassy
case, it appears that CORSI's reference to a [who] plans 2 more dumps"

refers to Julian ASSANGE; the founder of Wikileaks, who resided in Ecuador's London

Embassy in2016. As discussed above, Guccifer released information hacked from the DCCC on

August 12,2016 (the date CORSI identified as when he would "return home.").

55. On or about August 16,2016, CORSI, emailed STONE a link to a piece CORSI

had written about STONE titled, "Trump Adviser: Wikileaks Plotting Email Dump to Derail

Hillary."

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Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 18 of 35

56. On or about August 3I,2016, CORSI, using emailed STONE: "Did you get the

. Podesta writeup." STONE replied "yes."

57. On or about September 6,2016, CORSI, emailed STONE: "Roger[,] Is NY Post

going to use the Pedesta [sic] stuff?"

58. On or about October 7,2016, Wikileaks began releasing the Podesta emails.

59. On or about October 12,2016,the same day on which Podesta accused STONE of

having advance knowledge of the publication of his emails, CORSI emailed STONE with the

subject line "Podesta talking points." Attached to the email was a file labeled, "ROGER STONE

podesta talking points Oct 12 2016.docx." The "talking points" included the statement that,

"Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation." CORSI

followed up several minutes later with another email to STONE titled, "Podesta talking points,"

with the text "sent a second time just to be sure you go it." STONE emailed CORSI, "Got them

and used them."

60. On or about October 17,2016, CORSI emailed STONE with the subject, "Fwd:

ASSANGE...URGENT..." CORSI wrote, 'oFrom a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if
they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand off[.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he'd dead anyway, once he's dropped what he has. If HRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election."

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Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 19 of 35

6I. On or about November 1,2016, , using the Target Account, emailed

CORSI and STONE with the subject: "Turkey is a'GO'- FULL GREEN LIGHT."
wrote: "My good friend Husyein will be caking [sic] you he is in the Presidents office. The call

is a go. He has all the information you and DJT need for an article and another October surprise."

CORSI emailed back to the'l'arget Account and S'I'ON.tr: "And I have everything in progress

for a phone call tomorrow with DJT. I'm working with Roger Stone to accomplish this Roger
-
is copied above so he is up to date on status."

62. On or about November 2,20\6, using the Target Account, wrote to

STONE and CORSI: "The message from President Erdogan has been sent to you for DJT has

just been sent wrapped in an article about baseball as header. If there is a response please let me

know."

63. On or about November 13,2016, , using the Target Account,

emailed Stone. wrote, o'Well, we did it and now have an opportunity of a lifetime to

take the country back. God is good and we are well placed to steer things well. You deserve a lot

of credit and working with you and Jeri Corsi, who is with me now in London has been a great

joy."

64. On or about January 7,2017 , emailed STONE, and

(using the Target Account) with the subject line, "in case you need his

mail. . ......." Attached to the message was a scan of a business card for John Podesta. Several

hours later, , using the Target Account, replied to all recipients, "Ha... maybe he

wants to go phishing with us?"

65. I know from my training and experience that the term'ophishing" is used to refer

to the practice of sending emails purporting to be from a reputable party in order to induce

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Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 20 of 35

individuals to reveal personal information, including passwords. Public reports indicate that

Podesta's emails were obtaining through a "phishing" scheme.

E. Use of the Target Account to Communicate with Other Campaign


Officials

66. According to documents produced by the Campaign (both voluntarily

) has used the Target Account to correspond with

individuals throughout the Campaign. For example, on or about October 23,2015, ,

using the Target Account, emailed

stated that "[it] was so good talking to you earlier in the week it has sustained me all week.
-
Thank you for your contribution to this campaign and to our great country. I look forward to

working with you on a host of things."

67. On or about February 28,2016, , using the Target Account, emailed

, with the subject line "Trump on Putin." The text of the

message read: "Pass this to Donald," and contained an article by CORSI about how Putin

"fear[ed] impact on his plans if Trump takes victory."

68. On or about April4, 20ì6,

to introduce an individual who was interested in working with the Trump Campaign.

69. On or about }r/ray 25,2016, emailed the Target Account about a book

he was "toying with the idea of writing." wrote back noting that, "Roger Stone is

getting me on the list to go to Cleveland [the site of the Republican National Convention]."

70. On or about August 30, 106 , using the Target Account, emailed

Steve BANNON to report that he had been writing ¿'op-eds" and strategy pieces, "laboring non

stop for the Trump campaign even though I am all the way over here in Oxford."

T7
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 21 of 35

wïote that he had been "in constant touch with the campaign, Roger Stone, and Jeri Corsi."

suggested a "clever idea for . . . the first debate." In his idea, then-candidate Trump

would present then-candidate Clinton with a "Writ of Indictment," for "undeniable crimes

against America, destruction of evidence in the form of mails, and theft of funds to your own

personal benefit and enrichment."

71. On or about October 25,2016, , using the Target Account, emailed

regarding a piece had written about how

BACKGROUND CONCERNING EMAIL

72. In my training and experience, I have learned that the Providers provide avatiety

of on-line services, including electronic mail ("email") and search engines (in the case of Google

and Yahoo), to the public. The Providers allow subscribers to obtain email accounts at the

domain names identified in the email addresses contained in Attachment A. Subscribers obtain

an account by registering with the Providers. During the registration process, the Providers ask

subscribers to provide basic personal information. Therefore, the computers of the Providers are

likely to contain stored electronic communications (including retrieved and unretrieved email)

for their subscribers and information concerning subscribers and their use of services, such as

account access information, email transaction information, and account application information.

In my training and experience, such information may constitute evidence of the crimes under

investigation because the information can be used to identify the account's user or users.

73. In my training and experience, email providers generally ask their subscribers to

provide certain personal identif ing information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and

18
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 22 of 35

other identifiers, alternative email addresses, and, for paying subscribers, means and source of

payment (including any credit or bank account number). In my training and experience, such

informatio \ may constitute evidence of the crimes under investigation because the information

can be used to identify the account's user or users. Based on my training and my experience, I

know that, even if subscribers insert false information to conceal their identity, this information

often provides clues to their identit¡', location' or illicit activities'

74. tn my training and experience, email providers typically retain certain

transactional information about the creation and use of each account on their systems. This

information can include the date on which the account was created, the length of service, records

of log-in (l.e., session) times and durations, the types of service utilized, the status of the account

(including whether the account is inactive or closed), the methods used to connect to the account

(such as logging into the account via the provider's website), and other log files that reflect usage

of the account. In addition, email providers often have records of the Internet Protocol address

("IP address") used to register the account and the IP addresses associated with particular logins

to the account. Because every device that connects to the Internet must use an IP address, IP

address information can help to identify which computers or other devices were used to access

the email account.

75. In my training and experience, in some cases, email account users will

communÍcate directly with an email service provider about issues relating to the account, such as

technical problems, billing inquiries, or complaints from other users. Email providers typically

retain records about such communications, including records of contacts between the user and

the provider's support services, as well as records of any actions taken by the provider or user as

a result of the communications. In my training and experience, such information may constitute

I9
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 23 of 35

evidence of the crimes under investigation because the information can be used to identify the

account's user or users.

76. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, wh¡t, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

infiormation stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of

occupancy" while executing a search warrant at a residence. For example, email

communications, contacts lists, and images sent (and the data associated with the foregoing, such

as date and time) may indicate who used or controlled the account at a relevant time. Further,

information maintained by the email provider can show how and when the account was accessed

or used. For example, as described below, email providers typically log the Internet Protocol

(IP) addresses from which users access the email account, along with the time and date of that

access. By determining the physical location associated with the logged IP addresses,

investigators can understand the chronological and geographic context of the email account

access and use relating to the crime under investigation. This geographic and timeline

information may tend to either inculpate or exculpate the account owner. Additionally,

information stored at the user's account may fuither indicate the geographic location of the

account user at a particular time (e.g.,location information integrated into an image or video sent

via email). Last, stored electronic datamay provide relevant insight into the email account

owner's state of mind as it relates to the offense under investigation. For example, information in

the email account may indicate the owner's motive and intent to commit acúme (e.g.,

20
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 24 of 35

communications relating to the crime), or consciousness of guilt (e.g., deleting communications

in an effort to conceal them fiom law enforcement).

77. In my training and experience, information such as search history can help to

show the state of mind of an individual atthe time the search was made, as well as the

individuals potential advance knowledge of events, as they search to see if the anticipated event

has occurred.

INFORMATION TO BE SEARCHED AND THING TO BE SEIZED

78. I anticipate executing this warrant under the Electronic Communications Privacy
.
Act, in particular 18 U.S.C. $$ 2703(a),2703(b)(l)(A) and 2703(c)(I)(A), by using the warrant

to require Google to disclose to the government copies of the records and other information

(including the content of communications) associated with the account in Attachment A and

particularly described in Section I of Attachment B. Upon receipt of the information described

in Section I of Attachments B, government-authorized persons will review that information to

locate the items described in Section II of Attachment B. The items identified in Attachments A

will also be screened by reviewers not on the prosecution team to identify and filter out

privileged material.

CONCLUSION

79. STONE instructed CORSI to "Get to Assange" at the Ecuadorian Embassy

regarding upcoming leaks. STONE then instructed CORSI to have (the user of the

Target Account) talk to ASSANGE. CORSI subsequently emailed STONE that'oword is friend

in embassy IASSANGE] plans 2 morc dumps. One shortly after I'm back. 2nd in October.

Impact planned to be very damaging.... Time to let more than Podesta to be exposed as in bed w

enemy if they are not ready to drop HRC." Two releases, one from Guccifer and the other from

2T
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 25 of 35

Wikileaks, occuned at the times predicted by CORSI. CORSI later emailed STONE "talking

points" about Podesta. In January, (using the Target Account), STONE, and

CORSI received an email from an individual regarding Podesta, and wrote back,

using the Target Account, "Ha... maybe he wants to go phishing with us?"

80. Based on the forgoing, I request that the Court issue the proposed search warant.

81. Pursuant to 18 U.S.C. $ 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

nnQunsr ron snÀuNi


82. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously je opardízethat investigation.

Respectfully submitted,

E.
Special Agent
Federal Bureau of Investigation

Subscribed and sworn to before me on tn¡, Íl1of Decemb er,2017

The Honorable Beryl A. Howell


Chief United States District Judge

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Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 26 of 35

ATTACHMENT A

This warrant applies to information associated with the following Google account:

1.
that is stored at premises owned, maintained, controlled, or operated by Google, Inc., a business

with offices located at 1600 Amphitheatre Parkway, Mountain View, CA 94043'

23
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 27 of 35

ATTACHMENT B
Particular Things to be Seized
I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to the Provider or have been
preserved pursuant to a preservation request under 18 U.S.C. $ 2703(Ð, the Provider is required
to disclose the following information to the government for each account or identifier listed in
Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the
account, including copies of e-mails sent to and from the account, draft e-mails, the
source and destination e-mails sent addresses associated with each e-mail, the date and
time at which each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail
described above in Section I.A. above;

c All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above


in Section I.A, including log files, dates, times, methods of connecting, ports, dial ups,
andlor locations;

e. All records or other information stored by an individual using the account,


including address books, contact and buddy lists, calendar data, pictures, and files;

f. All records or other information regarding the identification of the account


described above in Section I.A, to include application, full name, physical address,
telephone numbers and other identifiers, records of session times and durations, the date
on which the account was created, the length of service, the types of service utilized, the
IP address used to register the account, log-in IP addresses associated with session times
and dates, account status, alternative e-mail addresses provided during registration, all
screen names associated with subscribers and/or accounts, all account names associated
with the subscriber, methods of connecting, log files, means and source of payment
(including any credit or bank account number), and detailed billing records;

g. All records indicating the services available to subscribers of the


electroniç mail address described above in Section I.A.;

24
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 28 of 35

il. Information to be Seized by Law Enforcement Personnel

a. Any and all records that relate in any way to the account described in Attachment A
which consists of evidence, fruits, or instrumentalities of violations of l8 U.S.C. $ 1030
(fraud and related activities in connection with computers), 52 U.S.C. $ 30121 (foreign
contribution ban), 18 U.S.C. $ 371 (conspiracy to commit an offense against the United
States), and 18 U.S.C. g 2 (aiding and abetting) for the period from January 1,2015 to the
present, including:

a. All records, information, documents or tangible materials that reiate in any


way to communications regarding hacking, release of hacked material, communications
with persons or entities associated with Wikileaks, including but not limited to Julian
Assange;

b. All records, information, documents or tangible materials that relate in any


way to communications or meetings between , Jerome Corsi, Roger
Stone, and individuals associate with Wikileaks or Turkey;

b. All images, messages? communications, calendar entries, search terms,


and contacts, includingaîy and all preparatory steps taken in fuitherance of the above-
listed offenses;

c. Communication, information, documentation and records relating to who


created, used, or communicated with the account or identifier, including records about
their identities and whereabouts;

d. Evidence of the times the account was used;

e. All images, messages and communications regarding wiping software,


encryption or other methods to avoid detection by law enforcement;

f. Passwords and encryption keys, and other access information that may be
necessary to access the account and other associated accounts;

g. Credit card and other financial information, including but not limited to,
bills and payment records evidencing ownership of the subject account;

h. All existing printouts from original storage which concern the categories
identified in subsection II.A; and

All "address books" or other lists of contacts.

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Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 29 of 35

IN THE LINITED STATES DISTRICT COURT


FOR THE DISTRICT OF' COI,I IMRIA

Case: 1.17-mj-0o982
IN THE MATTER OF THE SEARCH OF
Assigned To : Howell, BerylA.
TNFORMATION ASSOCI-ATED WITH
Assign. Date : 1211912017
Description: Search and Seizure Warrant

MOTION TO SEAL W ARRANT AND REI,ATEI) IMtr,NTS AND


2705

The United States of America, moving by and through its undersigned counsel, respectfully

moves the Court for an Order placing the above-captioned warrant and the application and affidavit

in support thereof (collectively herein the "Warrant") under seal, and precluding the provider from

notiffing any person of the Warrant pursuant to 18 U.S.C. $ 2705(b). In regard to the non-

disclosure, the proposed Order would direct Google, an electronic communication and/or remote

computing services provider headquartered in Mountain View, California not to notify any other

person (except attorneys for Google for the purpose of receiving legal advice) of the existence or

content of the Warrant for a period of one year or until further ãrder of the Court.

JURISDICTION AND LEGAL BACKGROUND

l. The Court has the inherent power to seal court fìlings when appropriate,
including the Warrant. lJnited States v. Hubbard,650 F.2d 293, 31 5- l6 (D.C. Cir. 1980) (citing

Nixonv. llarner Communications, 1nc.,435 U.S. 589, 598 (1978)). The Court may also seal the

Warrant to prevent serious jeopardy to an ongoing criminal investigation when, as in the present

case, such jeopardy creates a compelling governmental interest in preserving the confidentiality of

the Warranf . See lI/ashington Post v. Robinson, 935 F .2d 282,287 -89 (D.C. Cir. 1991).

2. In addition, this Court has jurisdiction to issue the requested order because it is'oa

court of competent jurisdiction" as defined by 18 U.S.C. ç 2711. Specifically, the Court is a

"district court of the United States . . . that - has jurisdiction over the offense being investigated."
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 30 of 35

l8'U.S.C. ç2711(3XAXi). As discussed fully below, acts or omissions in furtherance of the

offense under investigation occurred within Washington, D.C. See 18 U.S.C. ç 3237.

3. Further, the Court has authority to require non-disclosure of the Warrant under l8

U.S.C. $ 2705(b). Google provides an "electronic communications service," as defined in l8

U.S.C. $ 2510(15), and/or "remote computing service," as defined in 18 U.S.C.ç 271l(2). The

Stored Communications Act ("SCA"), 18 U.S.C. çç2701-2712, governs how Google may be

compelled to supply communications and other records using a subpoena, court order, or search

warrant. Specifically, Section 2703(c)(2) authorizes the Government to obtain certain basic

"subscriber information" using a subpoena, Section 2703(d) allows the Government to obtain other

"non-content" information using a court order, and Section 2703(a)-(bXlXA) allows the

Government to obtain contents of communications using a search warrant. See 18 U.S.C. 5 2703.

4. The SCA does not set forth any obligation for providers to notify subscribers about

subpoenas, court orders, or search warrants under Section 2703. However, many have voluntarily

adopted policies of notifying subscribers about such legal requests. Accordingly, when necessary,

Section 2705(b) of the SCA enables the Government to obtain a court order to preclude such

notification. In relevant part, Section 2705(b) provides as follows:l

(b) Preclusion of notice to subject of governmental access. A governmental


entity acting under section 2703 .. . may apply to a court for -
an order commanding
a provider of electronic communications service or remote computing service to
whom a warrant, subpoena, or court order is directed, for such period as the court
deems appropriate, not to noti$ any other person of the existence of the warrant,
subpoena, or couft order. The court shall enter such an order if it determines that
there is reason to believe that notification of the existence of the warrant, subpoena,
or court order will resultin-
(1) endangering the life or physical safety of an individual;
(2) flight from prosecution;

I Section 2705(b) contains additional requirements for legal process obtained pursuant to 18 U.S.C.

$ 2703(bX I )(B), but the Government does not seek to use the proposed Order for any legal
process
under that provision.

2
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 31 of 35

(3) destruction of or tampering with evidence;


(4) intimidation of potential witnesses; or
(5) otherwise seriously jeopardizing an investigation or unduly delaying atrial

18 U.S.C. $ 2705(b). The United States District Court for the District of Columbia has made clear

that a nondisclosure order under Section 2705(b) must be issued once the Government makes the

requisite showing about potential consequences of notification:

The explicit terms of section 2705(b) make clear that if a courts [slc] fìnds that there
is reason to believe that notifying the customer or subscriber of the court order or
subpoena may lead to one of the deleterious outcomes listed under $ 2705(b), the
court must enter an order commanding a service provider to delay notice to a
customer for a period of time that the court determines is appropriate. Once the
government makes the required showing under $ 2705(b), the court is required to
issue the non-disclosure order.

In re Applicationfor Order of Nondisclosure Pursuant to I8 U.S.C. S 2705(b) for Grand Jury

Subpoena #GJ2014031422765,41 F. Supp. 3d l, 5 (D.D.C. 2014).

5. Accordingly, this motion to seal sets forth facts showing reasonable grounds to

command Google not to notify any other person (except attorneys for Google for the purpose of

receiving legal advice) of the existence of the Subpoena for a period of one year or until further

order of the Couft.

FACTS SUPPORTING SEALING AND NON-DISCLOSURE

6. At the present time, law enforcement officers of the FBI are conducting an

investigation into violations related to 1S U.S.C. $ 1030 (fraud and related activities in connection

with computers), 52 U.S.C. $ 30121 (foreign contribution ban), l8 U.S.C. $ 371 (conspiracy to

commit an offense against the United States), and 18 U.S.C. $ 2 (aiding and abetting), arising out

of the conduct of Roger Stone, , and others. The investigation in ongoing, and

individuals associated with these offenses are not aware of the investigation. If they are made

awaro of the existence and contents of this search warrant, they may seek to delete additional

information contained in online platforms or otherwise destroy records related to the investigation.

3
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 32 of 35

REOUEST FOR SEALING AND NON-DISCLOSURE

7 . In this matter, the government requests that the Warrant be sealed until further order

of the Court and that Google and its employees be directed not to notify any other person of the

existence or content of the Warrant (except attorneys for Google for the purpose of receiving legal

advice) for a period of one year or until further order of the Court. Such an order is appropriate

because the Warrant relates to an ongoing criminal investigation, the full scope of which is neither

public nor known to the targets of the investigation, and its disclosure may aleft these targets to

the ongoing investigation and its scope. Once alerted to this investigation, potentialtargets would

be immediately prompted to destroy or conceal incriminating evidence, alter their operational

tactics to avoid future detection, and otherwise take steps to undermine the investigation and avoid

future prosecution. In particular, given that they are known to use electronic communication and

remote computing services, the potentia I targetcould quickly and easily destroy or encrypt digital

evidence relating to their criminal activity.

8. Given the complex and sensitive nature of the criminal activity under investigation,

and also given that the criminal scheme may be ongoing, the Government anticipates that this

confidential investigation will continue for the next year or longer. However, should

circumstances change such that court-ordered nondisclosure under Section 2705(b) becomes no

longer needed, the Government will notif, the Court and seek appropriate relief.

9. There is, therefore, reason to believe that notification of the existence of the

Warrant will seriously jeopardize the investigation, including by giving the targets an opportunity

to flee from prosecution, destroy or tamper with evidence, and intimidate witnesses. ,See l8 U.S.C.

$ 2705(bX2)-(5). Because of such potential jeopardy to the investigation, there also exists a

4
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 33 of 35

compelling governmental interest in confidentiality to justify the government's sealing request.

See Robinson, 935 F.2d at 287 -8g.

10. Based on prior dealings with Google the United States is aware that, absent a court

order under Section 2705(b) commanding Google not to notify anyone about a legal request, it is

Google's policy and practice, upon receipt of a warrant seeking the contents of electronically

stored wire or electronic communications for a certain account, to notify the subscriber or customer

of the existence of the warrant prior to producing the material sought.

WHEREFORE, for all the foregoing reasons, the government respectfully requests that the

above-captioned warrant, the application and affidavit in support thereof, and all attachments

thereto and other related materials be placed under seal, and fufthermore, that the Court command

Google not to notify any other person of the existence or contents of the above-captioned warrant

(except attorneys for Google for the purpose of receiving legal advice) for a period of one year or

until further order of the Court.

Respectfully subm itted,

ROBERT S. MUELLER, III


Special Counsel

Dated: lzlltt¿r,l? By:


Aaron S.J.
The Spec 's Office
(202)-s 37

5
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 34 of 35

FTI.EÞ
DEC I g 20r
IN THE trNtrED STATES DISTRICT COURT ctsrk, u,s. Disrricr & Bankrunrcv
FOR THE DISTRICT oF COt.I IMRTA {;ourté for ttreÐistrietof Cotirünlia:

Case: 1 .17 -mj-A0982


IN THE MATTER OF THE SEARCH OF
Assigned To : Howell, BerylA.
INFORMATION ASSOCIATED WITH
Assign. Date : 1211912017
Description: Search and Seizure Warrani
ORDER

The United States has filed a motion to seal the above-captioned warrant and related

documents, including the application arrd affidavit in support thereof (collectively the "Warrant"),

and to require Google, an electronic communication and/or remote computing service s

headquartered at 1600 Amphitheatre Parkway, Mountain View, California not to disclose the

existence or contents of the Warrant pursuant to l8 U.S.C. $ 2705(b)'

The Court finds that the United States has established that a compelling governmental

interest exists tojustiS the requested sealing, and that there is reason to believe that notification

of the existence of the Warrant will seriously jeopardize the investigation, including by giving the

targets an opportunity to flee from prosecution, destroy or tamper with evidence, and intimidate

witnesses. See t8 U.S.C..$ 2705(bX2)-(5).

IT IS TIIEREFORE ORDERED that the motion is hereby GRANTED, and that the

warrant, the application and affidavit in support thereof, all attachments thereto and other related

materials, the instant motion to seal, and this Order be SEALED until further order of the Court;

and
Case 1:19-mc-00029-CRC Document 29-5 Filed 04/28/20 Page 35 of 35

IT IS FURTHER ORDERED that, pursuant to l8 U.S.C. $ 2705(b), Google and its

or the Warrant to any ôtliei' þilrion' (eiðêþt

attorneys for Google for the purpose of receiving legal advice) for a period of one year or until

further order of the Court.

THE HON LE BERYL A. HOWELL


CHIEF UNITED STATES DISTRICT JUDGE

J /f talf

2
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 1 of 38

AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1:18-sc-00662
or identify the person by name and address) )
Assigned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH VARIOUS APPLE ) Assign. Date : 3/14/2018
ACCOUNTS ) Description: Search & Seizure Warrant
)

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A.

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search wi 11 reveal (identify the person or describe the property to be seized):

See Attachment B.

YOU ARE COMMANDED to execute this warrant on or before March 28, 2018 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to 10:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Be I A. Howell
(United States Magistrate Judge)

0 Pursuant to 18 U .S.C. § 3103a(b), I find that immediate notification may have an adverse result Iisted in 18 U .S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) •
until, the facts justifying, the later specific date of

Date and time issued: ;:;/J f/ Z£J ;g a,;f ~ 'f_zf;n_ __~-----~t'/_•~-¼


-~---- - Judge 's signature

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
- -- - - - - - -- - - - Printed name and title
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 2 of 38

AO 93 (Rev. l J/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 3 of 38

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Apple Accounts:

that is stored at premises owned, maintained, controlled, or operated by Apple, Inc., a business

with offices located at 1 Infinite Loop, Cupertino, California 95014.

26
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 4 of 38

ATTACHMENT B

Particular Things to be Seized

I. Information to be disclosed by Apple

To the extent that the information described in Attachment A is within the possession,

custody, or control of Apple, including any messages, records, files, logs, or information that

have been deleted but are still available to Apple, or have been preserved pursuant to a request

made under 18 U.S.C. § 2703(f), Apple is required to disclose the following infonnation to the

government, in unencrypted form whenever available, for each account or identifier listed in

Attachment A:

a. All records or other information regarding the identification of the account, to

include full name, physical address, telephone numbers, email addresses (including primary,

alternate, rescue, and notification email addresses, and verification information for each email

address), the date on which the account was created, the length of service, the IP address used to

register the account, account status, methods of connecting, and means and source of payment

(including any credit or bank account numbers);

b. All records or other information regarding the devices associated with, or used in

connection with, the account (including all current and past trusted or authorized iOS devices

and computers, and any devices used to access Apple services), including serial numbers, Unique

Device Identifiers ("UDID"), Advertising Identifiers ("IDF A"), Global Unique Identifiers

("GUID"), Media Access Control ("MAC") addresses, Integrated Circuit Card ID numbers

("ICCID"), Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),

27
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 5 of 38

Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber

Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Numbers

("MSISDN"), International Mobile Subscriber Identities ("IMSI"), and International Mobile

Station Equipment Identities ("IMEI");

c. The contents of all emails associated with the account, including stored or

preserved copies of emails sent to and from the account (including all draft emails and deleted

emails), the source and destination addresses associated with each email, the date and time at

which each email was sent, the size and length of each email, and the true and accurate header

information including the actual IP addresses of the sender and the recipient of the emails, and

all attachments;

d. The contents of all instant messages associated with the account, including stored

or preserved copies of instant messages (including iMessages, SMS messages, and MMS

messages) sent to and from the account (including all draft and deleted messages), the source and

destination account or phone number associated with each instant message, the date and time at

which each instant message was sent, the size and length of each instant message, the actual IP

addresses of the sender and the recipient of each instant message, and the media, if any, attached

to each instant message;

,.
e. The contents of all files and other records stored on iCloud, including all iOS

device backups, all Apple and third-party app data, all files and other records related to iCloud

Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWorks

(including Pages, Numbers, and Keynote), iCloud Tabs, and iCloud Keychain, and all address

28
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 6 of 38

books, contact and buddy lists, notes, reminders, calendar entries, images, videos, voicemails,

device settings, and bookmarks;

f. All activity, connection, and transactional logs for the account (with associated IP

addresses including source port numbers), including FaceTime call invitation logs, mail logs,

iCloud logs, iTunes Store and App Store logs (including purchases, downloads, and updates of

Apple and third-party apps), messaging and query logs (including iMessage, SMS, and MMS

messages), My Apple ID and iForgot logs, sign-on logs for all Apple services, Game Center

logs, Find my iPhone logs, logs associated with iOS device activation and upgrades, and logs

associated with web-based access of Apple services (including all associated identifiers);

g. All records and information regarding locations where the account was accessed,

including all data stored in connection with Location Services;

h. All records pertaining to the types of service used;

1. All records pertaining to communications between Apple and any person

regarding the account, including contacts with support services and records of actions taken; and

J. All files, keys, or other information necessary to decrypt any data produced in an

encrypted form, when available to Apple (including, but not limited to, the keybag.txt and

fileinfolist.txt files).

29
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 7 of 38

II. Information to be Seized by Law Enforcement Personnel

a. Any and all records that relate in any way to the accounts described in Attachment A which
consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C.§ 1030 (fraud and
related activities in connection with computers), 18 U.S.C. § 2 (aiding and abetting), and 18
U.S.C. § 371 (conspiracy to commit an offense against the United States), for the period January
2015 to the present, including:

All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications
with persons or entities associated with WikiLeaks, including but not limited to
Julian Assange;

b. All images, messages, communications, calendar entries, search terms,


and contacts, including any and all preparatory steps taken in furtherance of the above-
listed offenses;

c. Communication, information, documentation and records relating to who


created, used, or communicated with the account or identifier, including records about
their identities and whereabouts;

d. Evidence of the times the account was used;

e. All images, messages and communications regarding w1pmg software,


encryption or other methods to avoid detection by law enforcement;

f. Passwords and encryption keys, and other access information that may be
necessary to access the account and other associated accounts;

g. Credit card and other financial information, including but not limited to,
bills and payment records evidencing ownership of the subject account;

h. All existing printouts from original storage which concern the categories
identified in subsection II.A; and

1. All "address books" or other lists of contacts.

30
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 8 of 38
AO I 06 (Rev 04/10) App lication for a Search Warran t

UNITED STATES DISTRICT COURT MAR f 4 2018


for the
_Glerk, U.S. District & Bankruptcy
District of Columbia Courts for the District of Columbia

In the Matter of the Search of ) Case: 1: 18-sc-00662


(Briefly de.rcrih the proper/JI rob.~ .1·eardred )
or idem ify 1h person by na111e ar,d address)
)
Assigned To : Howell, Beryl A
INFORMATION ASSOCIATED WITH VARIOUS APPLE ) Assign. Date : 3/14/2018
ACCOUNTS ) Description: Search & Seizure Warrant
)

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A.
located in the District of
Northern
- -- - - -- -
person or describe the property to be seized):
- - ----- , there is now concealed (identify the
-- - --California
See Attachment B.
This warrant is sought pursuant to 18 U.S.C. §§ 2703(a), 2703(b)(1 )(A), and 2703(c)(1 )(A).

The basis for the search under Fed. R. Crim. P. 4 l(c) is (check one or more):
ref evidence of a crime;
ref contraband, fruits of crime, or other items illegally possessed;
rJ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


ode Section Offense Description
18 U.S.C. §§ 2, 3, 4, 371, 1343 Aiding & Abetting (§2); Accessory after the Fact (§3); Misprison of a Felony (§4);
and 1349; and Conspiracy (§371 ); Computer Fraud (§1030); Wire Fraud (§1343); Attempt and
52 U.S.C. § 30121(a)(1)(C) Conspiracy to Commit Wire Fraud (§1349); and Foreign Expenditure Ban (§30121)
The application is based on these facts:

See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of days (give exact ending date if more than 30 days: ) is requested
under 18U.S.C.§3103a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA:
&-4 /44~
!Aaron Zelinsky (ASC)

Sworn to before me and signed in my presence.


= Curtis Heide, Special Agent, FBI
Printed name and title

Date: 3/14/2018
Judge 's signature

City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 9 of 38

IN THE UNITED STATES DISTRICT COURT MAR 14 2018


FOR THE DISTRICT OF COLUMBIA
Clerk , -·-· 1~+•/~• • a .
,, c: ..,,oo v, a anM. t
Court11 tor th ·District at·Col~~ik-----
IN THE MATTER OF THE SEARCH OF Case: 1: 18-sc-00662
INFORMATION AS SOCIA TED WITH Assigned To : Howell, Beryl A,
VARIO US APPLE ACCOUNTS Assign . Date : 3/14/2018
Description: Search & Seizure Warrant
AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Curtis Heide, being first duly sworn, hereby depose and state as follows:

INTRODU TION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the following Apple Accounts:

that is stored at premises owned, maintained, controlled, or operated by Apple, Inc., a business

with offices located at llnfinite Loop, Cupertino, California 95014. The information to be

disclosed by Apple and searched by the government is described in the following paragraphs and

in Attachments A and B. This affidavit is made in support of an application for a search warrant.

2. I, Curtis A. Heide, have been a Special Agent with the Federal Bureau of

investigation for 11 years. In the course of my duties, I have been responsible for investigating

federal crimes and national security matters involving both counterintelligence and issues related

to cybersecurity.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my knowledge about this matter.


Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 10 of 38

4. Based on my training and experience and the facts as set forth in this affidavit,

---- - - - -----there is-probable-Gause-t0-believe-that-the-T'-arget--Accounts--00ntain--eommunications relevant-to -- - --- - ---- -

violations of 18 U.S.C. § 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the fact), 18

U.S.C. § 4 (misprision of a felony), 18 U.S.C. § 371 (conspiracy),, 18 U.S.C. § 1030

(unauthorized access of a protected computer); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349

(attempt and conspiracy to commit wire fraud),, and 52 U.S.C. § 30121 (foreign contribution

ban) (the "Subject Offenses"). 1

5. As set forth below, Roger STONE communicated directly via Twitter with

WikiLeaks, Julian Assange, and Guccifer 2.0, a Twitter account used to disseminate hacked

information. STONE, using his Account, also emailed instructions to Jerome CORSI to

"Get to Assange" in person at the Ecuadorian Embassy and "get pending WikiLeaks emails[.]"

CORSI emailed STONE back that it was "Time to let more than Podesta to be exposed" (before

any of Podesta's emails were leaked). After Podesta's emails were leaked, CORSI emailed

STONE "talking points" about Podesta. CORSI also emailed Stone to convey information "from

a very trusted source" regarding Julian ASSANGE, WikiLeaks, and potential future disclosures.

BANNON also sent text messages to STONE discussing potential upcoming leaks by

ASSANGE. The Target Accounts are STONE's iCloud accounts, which are registered to the

email accounts STONE used to communicate with CORSI.

JURISDICTION

1
Federal law prohibits a foreign national from making, directly or indirectly, an expenditure or independent
expenditure in connection with federal elections. 52 U.S.C. § 3012l(a)(l)(C); see also id. § 30101(9) & (17)
(defining the terms "expenditure" and "independent expenditure").

2
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 11 of 38

6. This Court has jurisdiction to issue the requested warrant because it is "a court of

------- ----c-0mpetent-jur-isdieti0n?2-as-de-fined--by-l--8--{:1.,.S"G,--§--2'.7-l--l--,-/da-§~-2-70J(aj,fbj(--1-)E-A0,&-(-G-)E-I-)(Aj.

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 271 l(J)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below,

including in paragraph 7.

PROBABLE CAUSE

A. U.S. Intelligence Community (USIC) Assessment of Russian Government-Backed

Hacking Activity during the 2016 Presidential Election

7. On October 7, 2016, the U.S. Department of Homeland Security and Office of the

Director of National Intelligence released a joint statement of an intelligence assessment of

Russian activities and intentions during the 2016 presidential election. 2 In the report, the USIC

assessed the following:

8. The U.S. Intelligence Community (USIC) is confident that the Russian

Government directed the recent compromises of e-mails from US persons and institutions,

including from US political organizations. The recent disclosures of alleged hacked e-mails on

sites like DCLeaks.com and WikiLeaks and by the Guccifer 2.0 online persona are consistent

with the methods and motivations of Russian-directed efforts. These thefts and disclosures are

intended to interfere with the US election process. Such activity is not new to Moscow-the

Russians have used similar tactics and techniques across Europe and Eurasia, for example, to

2
"Joint Statement from the Department Of Homeland Security and Office of the Director of National Intelligence on
Election Security," Oct. 7, 20 I 6, available at ttps://www.dhs.gov/news/2016/10/07 /joint-statement-department-
homeland-security-and-office-director-national.

3
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 12 of 38

influence public opinion there. We believe, based on the scope and sensitivity of these efforts,

- -that-only Russia's senior-most officials could have authorized these activities

9. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." 3 In the report, the USIC

assessed the following:

10. [] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed

at the US presidential election. Russia's goals were to undermine public faith in the US

democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her

electability and potential presidency. We further assess Putin and the Russian Government

developed a clear preference for President-elect Trump."

11. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

12. With respect to hacking activity, the USIC assessed: "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." In addition, "In July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC further assessed that cyber

3 "Assessing Russian Activities and Intentions in Recent US Elections," Jan. 6, 2017, available at
https://www.dni.gov/files/documents/ICA_2017 _ 0 l .pdf.

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operations by Russian military intelligence (General Staff Main Intelligence Directorate or GRU)

"resulted in the compromise of the personal e-mail accounts of Democratic Paiiy officials and

political figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

13. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

1. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his likely Russian identity throughout the

election. Press reporting suggests more than one person claiming to be Guccifer 2.0 interacted

with j oumalists.

A. Roger Stone's Disclosed Interactions with Guccifer 2.0 and WikiLeaks.

2. Roger Stone is a self-employed political strategist/consultant and has been

actively involved in U.S. politics since 1975. Stone worked on the presidential campaign of

Donald J. Trump (the "Campaign") until he was fired in August 2015. Although Stone had no

official relationship with the Campaign thereafter, Stone maintained his support for Trump and

continued to make media appearances in support of Trump's presidential campaign.

3. As discussed further below, Stone made a number of public references to

WikiLeaks and its release of DNC-related emails. Stone has also stated that he was in contact via

Twitter with Guccifer 2.0.

4. On June 14, 2016, news reports indicated that the computer systems of the DNC

had been hacked. On June 15, 2016, Guccifer 2.0 publicly claimed responsibility for the DNC

· hack. Shortly thereafter, Guccifer 2.0 began releasing the hacked documents, including a June,

21, 2016 release of hacked documents.

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5. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

6. On August 5, 2016, Roger Stone published an article on Breitbart.com entitled,

"Dear Hillary: DNC Hack Solved, So Now Stop Blaming Russia." Stone wrote: "It doesn't

seem to be the Russians that hacked the DNC, but instead a hacker who goes by the name of

Guccifer 2.0." Stone embedded publicly available Tweets from Guccifer 2.0 in the article and

wrote: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and why

he did the hack of the DNC." Stone also stated: "Guccifer 2.0 made a fateful and wise decision.

He went to WikiLeaks with the DNC files and the rest is history. Now the world would see for

themselves how the Democrats had rigged the game."

7. On August 8, 2016, Stone addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

Assange to Russia Today (RT) several days earlier about an upcoming "October Surprise" aimed

at the Hillary Clinton presidential campaign. Specifically, Stone was asked: "With regard to the

October surprise, what would be your forecast on that given what Julian Assange has intimated

he's going to do?" Stone responded: "Well, it could be a number of things. I actually have

communicated with Assange. I believe the next tranche of his documents pertain to the Clinton

Foundation but there's no telling what the October surprise may be." A few days later, Stone

clarified that while he was not personally in touch with Assange, he had a close friend who

served as an intermediary.

8. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

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numbers and email addresses from the files of the Democratic Congressional Campaign

Committee (DCCC).

9. On August 13, 2016, Stone posted a tweet using @RogerJStoneJr calling Guccifer

2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day, Guccifer 2.0's

Twitter account was reinstated.

10. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me ifl can help u anyhow. it would be a great pleasure to me."

11. On August 18, 2016, Paul Manafort, Stone's longtime friend and associate,

resigned as Chairman of the Campaign. Contemporary press reports at the time indicated that

Manafort had working with a Washington D.C.-based lobbying firms to influence U.S. policy

toward Ukraine.

12. On August 21, 2016, using @RogerJStoneJR, Stone directed a tweet at John

Podesta, Hillary Clinton's presidential campaign manager, stating: "Trust me, it will soon the

[sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same day,

Stone reiterated that because of the work of a "'mutual acquaintance' of both his and [Assange],

the public [could] expect to see much more from the exiled whistleblower in the form of

strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

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13. On September 16, 2016 Stone said in a radio interview with Boston Herald Radio

that he expected WikiLeaks to "drop a payload of new documents on a weekly basis fairly soon.

And that of course will answer the question of exactly what was erased on that email server."

14. On Saturday, October 1, 2016, using@RogerJStoneJr, Stone Tweeted,

"Wednesday@ HillaryClinton is done. #WikiLeaks."

15. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement Julian Assange had scheduled for the next day from the

balcony of the Ecuadoran Embassy in London. On the day of the Assange announcement -

which was part of WikiLeaks' 10-year anniversary celebration - Stone told Info wars that his

inten,nediary described this release as the "mother load." On Tuesday, October 4, 2016, Stone

used @RogerJStoneJr to tweet: "Payload coming. #Lockthemup."

16. On Friday, October 7, 2016, at approximately 4:03 P.M., the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

17. Approximately a half hour later, at 4:32 P.M., WikiLeaks send a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #imWithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

18. WikiLeaks continued to release John Podesta's hacked emails throughout October

10-21, 2016. On October 12, 2016, John Podesta- referring back to Stone's August 21, 2016 C-

SP AN and Twitter references - argued publicly that "[it is] a reasonable assumption to - or at

least a reasonable conclusion - that [Stone] had advanced warning [of the release of his emails]

and the Trump campaign had advanced warning about what Assange was going to do. I think

there's at least a reasonable belief that [Assange] may have passed this information on to

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Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 17 of 38

[Stone]." Commenting to the Miami Herald, Stone responded: "I have never met or spoken with

Assange, we have a mutual friend who ' s traveled to London several times, and everything I

know is through that channel of communications. I'm not implying I have any influence with

him or that I have advanced knowledge of the specifics of what he is going to do. I do believe he

has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides, thought were

deleted. I hear that through my emissary."

19. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between Stone and WikiLeaks. The same article quoted

Stone as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser·because the

limited things I did predict (Oct disclosures) all came true."

B. Roger Stone's Private Twitter Direct Messages with WikiLeaks and Julian Assange.

20. On August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the

Twitter account @RogerJStoneJr.

21. On October 13, 2016, while WikiLeaks was in the midst ofreleasing the hacked

Podesta emails, @RogerJStoneJr sent a private direct message to the Twitter account

@wikileaks. This account is the official Twitter account of WikiLeaks and has been described as

such by numerous news reports. The message read: "Since I was all over national TV, cable and

print defending WikiLeaks and assange against the claim that you are Russian agents and

debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

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22. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

23. On October 16, 2016, @RogerJStoneJr sent a direct message to @wikileaks: "Ha!

The more you \"correct\" me the more people think you're lying. Your operation leaks like a

sieve. You need to figure out who your friends are."

24. On November 9, 2016, one day after the presidential election, @wikileaks sent a

direct message to @RogerJStoneJr containing a single word: "Happy?" @wikileaks immediately

followed up with another message less than a minute later: "We are now more free to

communicate."

25. In addition, @RogerJStoneJr also exchanged direct messages with Julian

Assange, the founder of WikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly

messaged @JulianAssange, an address associated with Julian Assange in numerous public

reports, stating: "Still nonsense. As a journalist it doesn't matter where you get information only

that it is accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issu~ an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

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26. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@wikileaks, reading: "I am doing everything possible to address the issues at the highest level of

Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

C. Roger Stone's Private Email and Text Messages Regarding WikiLeaks, Julian
Assange, Russia, and John Podesta

27. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, . On October

17, 2017, Chief Judge Beryl A. Howell issued a search warrant for STONE's address,

. Information recovered pursuant to those search warrant indicated the

following:

28. On July 25, 2016, STONE sent an email from his Account to Jerome

CORSI, an author and political commentator, with the subject line, "Get to Assange." The body

of the message read: "Get to Assange [a]t Ecuadorian Embassy in London and get pending

WikiLeaks emails ... they deal with Foundation, allegedly."

29. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed the Account, "Word is

friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct. Impact planned to

be very damaging ... Time to let more than Podesta to be exposed as in bed w enemy if they are

not ready to drop HRC. That appears to be the game hackers are now about. Would not hurt to

start suggesting HRC old, memory bad, has stroke -- neither he nor she well. I expect that much

of next dump focus, setting stage for Foundation debacle." Based on my training, experience,

and review of materials in this case, it appears that CORSI's reference to a "friend in embassy

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[who] plans 2 more dumps" refers to Julian AS SAN GE, the founder of WikiLeaks, who resided

in Ecuador's London Embassy in 2016.

30. On or about August 5, 2016, , an associate of STONE's emailed

him a link to a poll indicated that Clinton lea Trump by 15 points. STONE responded "enjoy it

while u can[.] I dined with my new pal Julian Assange last night." subsequently

stated to investigators that, around the same time, STONE told him he had gone to London to

meet ASSANGE. also stated that in 2018, told STONE he would be

interviewed by the FBI and would have to divulge the conversation about meeting AS SAN GE.

STONE told he was joking and had not actually met Assange.

31. On or about August 16, 2016, CORSI emailed STONE a link to a piece CORSI

had written about STONE titled, "Trump Adviser: WikiLeaks Plotting Email Dump to Derail

Hillary."

32. On August 19, 2016, Bannon sent Stone a text message asking ifhe could talk

that morning. On August 20, 2016, Stone replied, "when can u talk???"

33. On or about August 31, 2016, CORSI emailed STONE: "Did you get the Podesta

writeup." STONE replied "yes."

34. On September 4, 2016, Stone texted Bannon that he was in New York City for a

few more days, and asked if Bannon was able to talk.

35. On or about September 6, 2016, CORSI emailed STONE: "Roger[,] Is NY Post

going to use the Pedesta [sic] stuff?"

36. On September 7, 2016, Stone and Bannon texted to arrange a meeting on

September 8, 2016 at the Warner Center in New York.

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37. On September 7, 2016, Bannon texted Stone asking him ifhe could "come by

trump tower now???"

38. On September 8, 2016, Stone and Bannon texted about arranging a me~ting in

New York.

39. On October 3, 2016, an associate of Stone emailed Stone and asked: "Assange -

what's he got? Hope it's good." Stone wrote back, "It is. I'd tell Bannon but he doesn't call me

back. My book on the TRUMP campaign will be out in Jan. Many scores will be settled." The

associate forwarded the email to Bannon and wrote: "You should call Roger. See below. You

didn't get from me." Bannon wrote back, "I've got important stuff to worry about." The

associate responded, "Well clearly he knows what Assange has. I'd say that's important."

40. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

ASSANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the lJ.S. election process." AS SAN GE also stated that

WikiLeaks would publish documents on various subjects every week for the next 10 weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

41. Later that day, BANNON emailed STONE, "What was that this morning???"

STONE replied, "Fear. Serious security concern. He thinks they are going to kill him and the

London police are standing done [sic]." BANNON wrote back, "He didn't cut deal w/

clintons???" Stone replied, "Don't think so BUT his lawyer is a big democrat."

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42. When BANNON spoke with investigators during a voluntary proffer on February

14, 2018, he initially denied knowing whether the October 4, 2017 email to STONE was about

WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking STONE

about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

43. On or about October 7, 2016, WikiLeaks began releasing the Podesta emails.

44. On or about October 12, 2016, the same day on which Podesta accused STONE of

having advance knowledge of the publication of his emails, CORSI emailed STONE on both the

email accounts, with a subject line "Podesta talking points." Attached to the email was a file

labeled, "ROGER STONE podesta talking points Oct 12 2016.docx." The "talking points"

included the statement that "Podesta is at the heart of a Russian-government money laundering

operation that benefits financially Podesta personally and the Clintons through the Clinton

Foundation." CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you go it." STONE emailed

CORSI back via the Account, "Got them and used them."

45. On or about October 17, 2016, CORSI emailed the STONE with the subject,

"Fwd: AS SANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded

an email with the header information stripped out, showing only the body text. The email read,

"Yes[.] I figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on

them if they move to extradite him. My guess is that he has a set of dead man files that include

Hillary. It's what they used to call a 'Mexican stand off[.]' Only hope is that if Trump speaks out

to save him[.] Otherwise he's dead anyway, once he's dropped what he has. If HRC wins,

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Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 23 of 38

Assange can kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's

bluff and raised him the election."

46. On or about January 7, 2017, emailed STONE, CORSI, and

with the subject line, "in case you need his mail. ........ " Attached to the

message was a scan of a business card for John Podesta. Several hours later, replied

to all recipients: "Ha ... maybe he wants to go phishing with us?"

47. I know from my training and experience that the term "phishing" is used to refer

to the practice of sending emails purporting to be from a reputable party in order to induce

individuals to reveal personal information, including passwords. Public reports indicate that

Podesta's emails were obtaining through a "phishing" scheme.

D. STONE's Recent Public Statements Regarding Contact with Assange

48. As described above, STONE stated that on October 12, 2016 that he was in

contact with ASSANGE via a "a mutual friend who's traveled to London several times," and that

"everything I know is through that channel of communications."

49. On March 13, 2018, the Washington Post published an article about STONE's

previous claims of contact with Assange. 4 The cited an anonymous source who claimed to have a

conversation with STONE in the "spring of 2016" where STONE indicated that he had learned

from "Julian Assange that his organization had obtained emails that would torment senior

Democrats such as John Podesta," and that the conversation occurred before it became publicly

known that hackers had obtained the "emails of Podesta and of the Democratic National

4
https://www.washingtonpost.com/politics/roger-stone-claimed-contact-with-wikileaks-founder-julian-assange-in-
20 l 6-according-to-two-associates/20 l 8/03/l 3/a263 f842-2604- l l e8-b79d-t3d93 I db7f68_ story.html?hpid=hp_rhp-
top-table-main_ stone-656am%3Ahomepage%2Fstory

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Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 24 of 38

Committee." The article also cited statements that STONE stated he had spoken to

ASSANGE. The article cited STONE denying any advance notice about the hacked emails or

any "contact with Assange." The Article stated that STONE "said he only recalled having one

conversation with anyone in which he alluded to meeting the WikiLeaks founder - a comment he

said he made as a joke to Nunberg." STONE was quoted as stating, "The allegation I met with

Assange, or asked for a meeting or communicated with Assange, is provably false."

50. The article also stated that STONE told the House Intelligence Committee in

September 2017 that his August 21 tweet was meant as a prediction that Podesta's business

opportunities would come under scrutiny after Paul MANAFORT was forced to resign amid

allegations about his work for a pro-Russian party in Ukraine. MANAFORT resigned from the

Campaign on or about August 19, 2016. CORSI's email to STONE about WikiLeaks and "Time

to let more than Podesta to be exposed as in bed w_enemy if they are not ready to drop HRC,"

occurred on August 2, 2016, over two weeks before MANAFORT's resignation.

E. STONE's use of the Target Accounts

51. On November 21, 2017, Chief Judge Beryl A. Howell signed an order pursuant to

18 U.S.C. §2703(d) for header information related to the Target Accounts. Pursuant to that

order, Apple prov_ided the following information:

52. Target Account 1 has the Apple ID , an email address

associated with STONE discussed above. The associated email address is

. The company registered as the account user is Citroen Associates, a

company linked to STONE by investigators. Additionally, the "rescue email" is

, which is STONE's account. IP login information shows that the

account was in use as of the time of the service of the Order According to Apple, the system has

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been set to a "Full iCloud" backup. I know from my training and experience that a full iCloud

backup can include other databases and messaging features, including third party messaging

programs. Often individuals are unaware that the information is being stored in their iCloud, and

therefore the iCloud may contain additional communications not contained in the standard mail

accounts. STONE's email account ( ) also contains messages regarding

his iCloud account, including an indication that iCloud storage was "full." STONE also used

Target Account 1's associated iCloud email account, , to send an email

in March, 201 7.

53. Target Account 2 has the Apple ID , an email address

associated with STONE. Target Account 2 is registered to "Roger Stone," and according to

information provided by Apple pursuant to the§ 2703(d) order, contains a full iCloud backup as

well. The account is currently locked.

INFORMATION REGARDING APPLE ID AND iCLOUD 5

54. Apple is a United States company that produces the iPhone, iPad, and iPod

Touch, all of which use the iOS operating system, and desktop and laptop computers based on

the Mac OS operating system.

The information in this section is based on information published by Apple on its website, including, but
not limited to, the following document and webpages: "U.S. Law Enforcement Legal Process Guidelines," available
at htlp://images.applc.com/ privacy/docs/legal-process-guidelines-us.pdf; "Create and start using an Apple ID,"
available at https://suppo11.apple.co111/en-us/HT203993; "iCloud," available at http://www.apple.com/icloud/;
"iCloud: iCloud storage and backup overview," available at https://suppo1i.apple.com/kb/PT-l l 25 L9; and "iOS
Security," available at lmp://images.app le.com/privacy/docs/iO, Security Guide.pdf.

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55. Apple provides a variety of services that can be accessed from Apple devices or,

in some cases, other devices via web browsers or mobile and desktop applications ("apps"). As

described in further detail below, the serv,ices include email, instant messaging, and file storage:

a. Apple provides email service to its users through email addresses at the

domain names mac.com, me.com, and icloud.com.

b. iMessage and FaceTime allow users of Apple devices to communicate in

real-time. iMessage enables users of Apple devices to exchange instant messages ("iMessages")

containing text, photos, videos, locations, and contacts, while FaceTime enables those users to

conduct video calls.

c. iCloud is a file hosting, storage, and sharing service provided by Apple.

iCloud can be utilized through numerous iCloud-connected services, and can also be used to

store iOS device backups and data associated with third-party apps.

d. iCloud-connected services allow users to create, store, access, share, and

synchronize data on Apple devices or via icloud.com on any Internet-connected device. For

example, iCloud Mail enables a user to access Apple-provided email accounts on multiple Apple

devices and on icloud.com. iCloud Photo Library and My Photo Stream can be used to store and

manage images and videos taken from Apple devices, and iCloud Photo Sharing allows the user

to share those images and videos with other Apple subscribers. iCloud Drive can be used to

store presentations, spreadsheets, and other documents. iCloud Tabs enables iCloud to be used

to synchronize webpages opened in the Safari web browsers on all of the user's Apple devices.

iWorks Apps, a suite of productivity apps (Pages, Numbers, and Keynote), enables iCloud to be

used to create, store, and share documents, spreadsheets, and presentations. iCloud Keychain

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enables a user to keep website usemame and passwords, credit card information, and Wi-Fi

network information synchronized across multiple Apple devices.

e. Game Center, Apple's social gaming network, allows users of Apple

devices to play and share games with each other.

f. Find My iPhone allows owners of Apple devices to remotely identify and

track the location of, display a message on, and wipe the contents of those devices.

g. Location Services allows apps and websites to use information from

cellular, Wi-Fi, Global Positioning System ("GPS") networks, and Bluetooth, to determine a

user's approximate location.

h. App Store and iTunes Store are used to purchase and download digital

content. iOS apps can be purchased and dow11loaded through App Store on iOS devices, or

through iTunes Store on desktop and laptop computers running either Microsoft Windows or

Mac OS. Additional digital content, including music, movies, and television shows, can be

purchased .through iTunes Store on iOS devices and on desktop and laptop computers running

either Microsoft Windows or Mac OS.

56. Apple services are accessed through the use of an "Apple ID," an account created

during the setup of an Apple device or through the iTunes or iCloud services. A single Apple ID

can be linked to multiple Apple services and devices, serving as a central authentication and

syncing mechanism.

57. An Apple ID takes the form of the full email address submitted by the user to

create the account; it can later be changed. Users can submit an Apple-provided email address

(often ending in @icloud.com, @me.com, or @mac.com) or an email address associated with a

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third-party email provider (such as Gmail, Yahoo, or Hotmail). The Apple ID can be used to

access most Apple services (including iCloud, iMessage, and FaceTime) only after the user

accesses and responds to a "verification email" sent by Apple to that "primary" email address.

Additional email addresses ("alternate," "rescue," and "notification" email addresses) can also be

associated with an Apple ID by the user.

58. Apple captures information associated with the creation and use of an Apple ID.

During the creation of an Apple ID, the user must provide basic personal information including

the user's full name, physical address, and telephone numbers. The user may also provide means

of payment for products offered by Apple. The subscriber information and password associated

with an Apple ID can be changed by the user through the "My Apple ID" and "iForgot" pages on

Apple's website. In addition, Apple captures the date on which the account was created, the

length of service, records of log-in times and durations, the types of service utilized, the status of

the account (including whether the account is inactive or closed), the methods used to connect to

and utilize the account, the Internet Protocol address ("IP address") used to register and access

the account, and other log files that reflect usage of the account.

59. Additional information is captured by Apple in connection with the use of an

Apple ID to access certain services. For example, Apple maintains connection logs with IP

addresses that reflect a user's sign-on activity for Apple services such as iTunes Store and App

Store, iCloud, Game Center, and the My Apple ID and iForgot pages on Apple's website. Apple

also maintains records reflecting a user's app purchases from App Store and iTunes Store, "call

invitation logs" for FaceTime calls, and "mail logs" for activity over an Apple-provided email

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account. Records relating to the use of the Find My iPhone service, including connection logs

and requests to remotely lock or erase a device, are also maintained by Apple.

60. Apple also maintains information about the devices associated with an Apple ID.

When a user activates or upgrades an iOS device, Apple captures and retains the user's IP

address and identifiers such as the Integrated Circuit Card ID number ("ICCID"), which is the

serial number of the device's SIM card. Similarly, the telephone number of a user's iPhone is

linked to an Apple ID when the user signs in to FaceTime or iMessage. Apple also may

maintain records of other device identifiers, including the Media Access Control address ("MAC

address"), the unique device identifier ("UDID"), and the serial number. In addition,

information about a user's computer is captured when iTunes is used on that computer to play

content associated with an Apple ID, arid information about a user's web browser may be

captured when used to access services through icloud.com and apple.com. Apple also retains

records related to communications between users and Apple customer service, including

communications regarding a particular Apple device or service, and the repair history for a

device.

61. Apple provides users with five gigabytes of free electronic space on iCloud, and

users can purchase additional storage space. That storage space, located on servers controlled by

Apple, may contain data associated with the use of iCloud-connected services, including: email

(iCloud Mail); images and videos (iCloud Photo Library, My Photo Stream, and iCloud Photo

Sharing); documents, spreadsheets, presentations, and other files (iWorks and iCloud Drive); and

web browser settings and Wi-Fi network information (iCloud Tabs and iCloud Keychain).

iCloud can also be used to store iOS device backups, which can contain a user's photos and

21
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 30 of 38

videos, iMessages, Short Message Service ("SMS") and Multimedia Messaging Service

("MMS") messages, voicemail messages, call history, contacts, calendar events, reminders,

notes, app data and settings, and other data. Records and data associated with third-party apps

may also be stored on iCioud; for example, the iOS app for WhatsApp, an instant messaging

service, can be configured to regularly back up a user' s instant messages on iCloud. Some of

this data is stored on Apple's servers in an encrypted form but can nonetheless be decrypted by

Apple.

62. In my training and experience, evidence of who was using an Apple ID and from

where, and evidence related to criminal activity of the kind described above, may be found in the

files and records described above. This evidence may establish the "who, what, why, when,

where, and how" of the criminal conduct under investigation, thus enabling the United States to

establish and prove each element or, alternatively, to exclude the innocent from further

suspicion.

63. The stored communications and files connected to an Apple ID may provide

direct evidence of the offenses under investigation. For example, stored iMessage

communications, voicemails, and emails may contain conversations with foreign government

officials similar to those described above in PAPADOPOULOS 's Linkedin and Gmail accounts.

Based on my training and experience, instant messages, emails, voicemails, photos, videos, and

documents are often created and used in furtherance of criminal activity, including to

communicate and facilitate the offenses under investigation.

64. In addition, the user's account activity, logs, stored electronic communications,

and other data retained by Apple can indicate who has used or controlled the account. This "user
22
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 31 of 38

attribution" evidence is analogous to the search for "indicia of occupancy" while executing a

search warrant at a residence. For example, subscriber information, email and messaging logs,

documents, and photos and videos (and the data associated with the foregoing, such as geo-

location, date and time) may be evidence of who used or controlled the account at a relevant

time. As an example, because every device has unique hardware and software identifiers, and

because every device that connects to the Internet must use an IP address, IP address and device

identifier information can help to identify which computers or other devices were used to access

the account. Such information also allows investigators to understand the geographic and

chronological context of access, use, and events relating to the crime under investigation.

65. Account activity may also provide relevant insight into the account owner's state

of mind as it relates to the offenses under investigation. For example, information on the account

may indicate the owner's motive and intent to commit a crime (e.g., information indicating a

plan to commit a crime), or consciousness of guilt (e.g., deleting account information in an effort

to conceal evidence from law enforcement).

66. Other information connected to an Apple ID may lead to the discovery of

additional evidence. For example, the identification of apps downloaded from App Store and

iTunes Store may reveal services used in furtherance of the crimes under investigation or

services used to communicate with co-conspirators. For instance, ifthere are secured and

encrypted communication applications downloaded from the App Store, that can show an

attempt to hide information from investigators. In addition, emails, instant messages, Internet

activity, documents, and contact and calendar information can lead to the identification of co-

conspirators and instrumentalities of the crimes under investigation.

23
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 32 of 38

67. Therefore, Apple's servers are likely to contain stored electronic communications

and information concerning subscribers and their use of Apple's services. In my training and

experience, such information may constitute evidence of the crimes under investigation including

information that can be used to identify the account's user or users.

CONCLUSION

68. STONE instructed CORSI to "Get to Assange" at the Ecuadorian Embassy

regarding upcoming leaks, and CORSI emailed Stone on the Account that it was "Time

to let more than Podesta to be exposed as in bed w enemy if they are not ready to drop HRC."

STONE also texted and emailed BANNON about potential forthcoming leaks from ASSANGE

and WikiLeaks. There is therefore probable cause to believe that evidence of the DNC hack and

the hacking of other emails associated with the 2016 election will be found in the information

associated with the Target Accounts.

69. Based on the forgoing, I request that the Court issue the proposed search warrant.

70. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

24
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 33 of 38

REQUEST FOR SEALING

71. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

, ·t. 4 - d/{,,. . .
• ----

li-s-Heide
Special Agent
Federal Bureau oflnvestigation

Subscribed and sworn to before me on this d .faf of March, 2018.

~;/~
The Honorabl Beryl A. Howell
Chief United States District Judge

25
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 34 of 38

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Apple Accounts:

that is stored at premises owned, maintained, controlled, or operated by Apple, Inc., a business

with offices located at 1 Infinite Loop, Cupertino, California 95014.

26
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 35 of 38

ATTACHMENT B

Particular Things to be Seized

I. Information to be disclosed by Apple

To the extent that the information described in Attachment A is within the possession,

custody, or control of Apple, including any messages, records, files, logs, or information that

have been deleted but are still available to Apple, or have been preserved pursuant to a request

made under 18 U.S.C. § 2703(f), Apple is required to disclose the following infonnation to the

government, in unencrypted form whenever available, for each account or identifier listed in

Attachment A:

a. All records or other information regarding the identification of the account, to

include full name, physical address, telephone numbers, email addresses (including primary,

alternate, rescue, and notification email addresses, and verification information for each email

address), the date on which the account was created, the length of service, the IP address used to

register the account, account status, methods of connecting, and means and source of payment

(including any credit or bank account numbers);

b. All records or other information regarding the devices associated with, or used in

connection with, the account (including all current and past trusted or authorized iOS devices

and computers, and any devices used to access Apple services), including serial numbers, Unique

Device Identifiers ("UDID"), Advertising Identifiers ("IDF A"), Global Unique Identifiers

("GUID"), Media Access Control ("MAC") addresses, Integrated Circuit Card ID numbers

("ICCID"), Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),

27
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 36 of 38

Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber

Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Numbers

("MSISDN"), International Mobile Subscriber Identities ("IMSI"), and International Mobile

Station Equipment Identities ("IMEI");

c. The contents of all emails associated with the account, including stored or

preserved copies of emails sent to and from the account (including all draft emails and deleted

emails), the source and destination addresses associated with each email, the date and time at

which each email was sent, the size and length of each email, and the true and accurate header

information including the actual IP addresses of the sender and the recipient of the emails, and

all attachments;

d. The contents of all instant messages associated with the account, including stored

or preserved copies of instant messages (including iMessages, SMS messages, and MMS

messages) sent to and from the account (including all draft and deleted messages), the source and

destination account or phone number associated with each instant message, the date and time at

which each instant message was sent, the size and length of each instant message, the actual IP

addresses of the sender and the recipient of each instant message, and the media, if any, attached

to each instant message;

,.
e. The contents of all files and other records stored on iCloud, including all iOS

device backups, all Apple and third-party app data, all files and other records related to iCloud

Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWorks

(including Pages, Numbers, and Keynote), iCloud Tabs, and iCloud Keychain, and all address

28
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 37 of 38

books, contact and buddy lists, notes, reminders, calendar entries, images, videos, voicemails,

device settings, and bookmarks;

f. All activity, connection, and transactional logs for the account (with associated IP

addresses including source port numbers), including FaceTime call invitation logs, mail logs,

iCloud logs, iTunes Store and App Store logs (including purchases, downloads, and updates of

Apple and third-party apps), messaging and query logs (including iMessage, SMS, and MMS

messages), My Apple ID and iForgot logs, sign-on logs for all Apple services, Game Center

logs, Find my iPhone logs, logs associated with iOS device activation and upgrades, and logs

associated with web-based access of Apple services (including all associated identifiers);

g. All records and information regarding locations where the account was accessed,

including all data stored in connection with Location Services;

h. All records pertaining to the types of service used;

1. All records pertaining to communications between Apple and any person

regarding the account, including contacts with support services and records of actions taken; and

J. All files, keys, or other information necessary to decrypt any data produced in an

encrypted form, when available to Apple (including, but not limited to, the keybag.txt and

fileinfolist.txt files).

29
Case 1:19-mc-00029-CRC Document 29-6 Filed 04/28/20 Page 38 of 38

II. Information to be Seized by Law Enforcement Personnel

a. Any and all records that relate in any way to the accounts described in Attachment A which
consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C.§ 1030 (fraud and
related activities in connection with computers), 18 U.S.C. § 2 (aiding and abetting), and 18
U.S.C. § 371 (conspiracy to commit an offense against the United States), for the period January
2015 to the present, including:

All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications
with persons or entities associated with WikiLeaks, including but not limited to
Julian Assange;

b. All images, messages, communications, calendar entries, search terms,


and contacts, including any and all preparatory steps taken in furtherance of the above-
listed offenses;

c. Communication, information, documentation and records relating to who


created, used, or communicated with the account or identifier, including records about
their identities and whereabouts;

d. Evidence of the times the account was used;

e. All images, messages and communications regarding w1pmg software,


encryption or other methods to avoid detection by law enforcement;

f. Passwords and encryption keys, and other access information that may be
necessary to access the account and other associated accounts;

g. Credit card and other financial information, including but not limited to,
bills and payment records evidencing ownership of the subject account;

h. All existing printouts from original storage which concern the categories
identified in subsection II.A; and

1. All "address books" or other lists of contacts.

30
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 1 of 35

AO 93 (Rev. l l/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of Case: 1:18-sc-01518


(Briefly describe the property to be searched Assigned To : Howell, Beryl A.
or identify the person by name and address)
Assign. Date: 5/4/2018
INFORMATION ASSOCIATED WITH THE GOOGLE Description: Search & Seizure Warrant
ACCOUNT ,
)

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A.

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B.

YOU ARE COMMANDED to execute this warrant on or before May 18, 2018 (not to exceed 14 days)
';$ in the daytime 6:00 a.m. to 10:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the awropriate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued:


Judge 's signature

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 2 of 35

AO 93 (Rev 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of :

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of pe1jury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 3 of 35

UNITED STATES DISTRICT COURT


Cferk, U.S. District & Bankrupicy
FOR THE DISTRICT OF COLUMBIA Gourts for tirn District of Columbl&

IN THE MATTER OF THE SEARCH OF Case: 1: 18-sc-01518


INFORMATION ASSOCIATED WITH
Assigned To : Howell, Beryl A.
THE GOOGLE ACCOUNT
Assign. Date: 5/4/2018
Description: Search & Seizure Warrant

ORDER

The United States has filed a motion to seal the above-captioned warrant and related

documents, including the application and affidavit in support thereof (collectively the "Warrant"),

and to require Google LLC, an electronic communication and/or remote computing services with

headquarters in Mountain View, California, not to disclose the existence or contents of the Warrant

pursuant to !8 U.S.C. § 2705(b).

The Court finds that the United States has established that a compelling governmental

interest exists to justify the requested sealing, and that there is reason to believe that notification

of the existence of the Warrant will seriously jeopardize the investigation, including by giving the

targets an opportunity to flee from prosecution, destroy or tamper with evidence, and intimidate

witnesses. See 18 U.S.C. § 2705(b)(2)-(5).

IT IS THEREFORE ORDERED that the motion is hereby GRANTED, and that the

warrant, the application and affidavit in support thereof, all attachments thereto and other related

materials, the instant motion to seal, and this Order be SEALED until further order of the Court;

and

Page 1 of2
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 4 of 35

IT IS FURTHER ORDERED that, pursuant to 18 U.S.C. § 2705(b), Google and its

employees shall not disclose the existence or content of the Warrant to any other person (except

attorneys for Google for the purpose of receiving legal advice) for a period of one year unless

otherwise ordered by the Court.

THE HONORABLE BERYL A. HOWELL


CHIEF UNITED STATES DISTRICT JUDGE

Date
41/Y>lf

Page 2 of2
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 5 of 35
AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT


for the MA\t !,
District of Columbia
•'II·\! • ·r 2018
,,t,c,rk, U.S. District & Bankruptcy
In the Matter of the Search of . ,,gurt~ lar 1hli-•D1strlctof Gollf/nh]•
) C ase.1:18-sc-01518 ·'
(Briefly describe the property to be searched )
or identify the person by name and address)
) Ass!gned To: Howell, Beryl A
) Assign. Date: 5;412018 ·
INFORMATION ASSOCIATED WITH THE GOOGLE )
ACCOUNT Description: Search & Seizure Warrant
)

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give ifs location):

See Attachment A.
located in the Northern District of _____C,-_a-,.l"'if.=o,..rn~ia..__ _ _ , there is now concealed (identijj, the
person or describe the property to be seized):
See Attachment B.

The basis for the search under Fed. R. Crim. P. 4 l(c) is (check one or more):
~ evidence of a crime;
ief contraband, fruits of crime, or other items illegally possessed;
r'lf property designed for use, intended for use, or used in committing a crime;
D a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section Offense Description
18 U.S.C. § 2 aiding and abetting
· et al. see attached affidavit

The application is based on these facts:

See attached Affidavit.

r;/ Continued on the attached sheet.


D Delayed notice of _ _ days (give exact ending date if more than 30 days: ______ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA:
~44 Appbcant's signature

•Aaron Zelinsky (Special Counsel's Office) Andrew Mitchell, Supervisory Special Agent, FBI
Printed name and title

Sworn to before me and signed in my presence.

Date:

City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 6 of 35

UNITED STATES DISTRICT COURT MAY · · ti 1018


FOR THE DISTRICT OF COLUMBIA Clerk, LLS. District & Bar1i<ruptcy
Gourts !or tirn District of Co\urntHfl
IN THE MATTER OF THE SEARCH OF
Case: 1:18-sc-01518
INFORMATION ASSOCIATED WITH
THE GOOGLE ACCOUNT Assigned To : Howell, Beryl A
Assign. Date: 5/4/20 18
Description: Search & Seizure Warrant

AFFIDAVIT IN SUPPORT OF AN
APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, having been first duly sworn, hereby depose and state as follows:

1. I make this affidavit in support of an application for a search warrant for

information associated with the following Google Account: (hereafter

the "Target Account 1"), that is stored at premises owned, maintained, controlled or operated by

Google, Inc., a social networking company headquartered in Mountain View, California

("Google"). The information to be searched is described in the following paragraphs and in

Attachments A and B. This affidavit is made in support of an application for a search warrant

under 18 U.S.C. §§ 2703(a), 2703(b)(l)(A) and 2703(c)(l)(A)to require Google to disclose to

the government copies of the information (including the content of communications) further

described in Attachment A. Upon receipt of the information described. in Attachment A,

government-authorized persons will review that information to locate the items described in

Attachment B.

2. I am a Special Agent with the Federal Bureau of Investigation (FBI), and have

been since 2011. As a Special Agent of the FBI, I have received training and experience in

investigating criminal and national security matters.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 7 of 35

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Accounts contain communications relevant to

violations of 18 U.S.C. § 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the fact), 18

U.S.C. § 4 (misprision ofa felony), 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (making a

false statement); 18 U.S.C. §1651 (perjury); 18 U.S.C. § 1030 (unauthorized access ofa

protected computer); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to

commit wire fraud),, and 52 U.S.C. § 30121 (foreign contribution ban) (the "Subject

Offenses"). 1

5. As set forth below, in May 2016, Jerome CORSI provided contact information for

to Roger STONE. In July 2016, also told STONE that he

needed to meet with then-candidate Trump "alone." In August 2016, told STONE

that there was an "OCTOBER SURPRISE COMING" and that Trump, "[i]s going to be defeated

unless we intervene. We have critical intel." In that same time period, STONE communicated

directly via Twitter with WikiLeaks, Julian AS SANGE, and Guccifer 2.0. On July 25, 2016,

STONE emailed instructions to Jerome CORSI to "Get to Assange" in person at the Ecuadorian

Embassy and "get pending WikiLeaks emails[.]" On August 2, 2016, CORSI emailed STONE

back that,"Word is friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in

Oct. Impact planned to be very damaging." On August 20, 2016, CORSI told STONE that they

needed to meet with. to determine "what if anything Israel plans to do in Oct."

1
Federal law prohibits a foreign national from making, directly or indirectly, an expenditure or independent
expenditure in connection with federal elections. 52 U.S.C. § 3012l(a)(l)(C); see also id § 30101(9) & (17)
(defining the terms "expenditure" and "independent expenditure").

2
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 8 of 35

(the Target Account) is Google Account, which

used to communicate with STONE and CORSI.

JURISDICTION

6. This Court has jurisdiction to issue the requested warrant because it is "a comt of

competent jurisdiction" as defined by l8 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), & (c)(l)(A).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisc\iction over the offense being investigated." 18 U.S.C.

§ 271 l(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below,

including in paragraph 8.

PROBABLE CAUSE

A. U.S. Intelligence Community (USIC) Assessment of Russian Government-


Backed Hacking Activity during the 2016 Presidential Election

7. On October 7, 2016, the U.S. Department of Homeland Security and the Office of

the Director of National Intelligence released a joint statement of an intelligence assessment of

Russian activities and intentions during the 20 l 6 presidential election. In the report, the USIC

assessed the following, with emphasis added:

8. The U.S. Intelligence Community (USIC) is confident that the Russian

Government directed the recent compromises of e mails from US persons and institutions,

including from US poiitical organizations. The recent disclosures of alleged hacked e mails on

sites like DC Leaks.com and WikiLeaks and by the Guccifer 2.0 online persona are consistent

with the methods and motivations of Russian-directed efforts. These thefts and disclosures are

intended to interfere with the US election process. Such activity is not new to Moscow-the

Russians have used similar tactics and techniques across Europe and Eurasia, for example, to

3
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 9 of 35

influence public opinion there. We believe, based on the scope and sensitivity of these efforts,

that only Russia's senior-most officials could have authorized these activities.

9. On January 6, 2017, the US[C released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the repoti, the USIC

assessed the following:

10. [] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed

at the US presidential election. Russia's goals were to undermine public faith in the US

democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her

electability and potential presidency. We further assess Putin and the Russian Government

developed a clear preference for President-elect Trump."

11. The USIC also described, at a high level, some of the techniques that the Russian

government employed during its interference. The USIC summarized the efforts as a "Russian

messaging strategy that blends coveti intelligence operations-such as cyber activity-with

overt efforts by Russian Government agencies, state-funded media, third-party intermediaries,

and paid social media users or 'trolls.'"

12. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities to

the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted in

the compromise of the personal e-mail accounts of Democratic Party officials and political

4
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 10 of 35

figures. By May, the GRU had exfiltrated large volumes of data from the DNC." The GRU is the

foreign military intelligence agency of the Russian Ministry of Defense, and is Russia's largest

foreign intelligence agency.

13. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Gucci fer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

14. Gucci fer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

B. · Roger Stone's Public Interactions with Guccifer 2.0 and WikiLeaks.

15. Roger Stone is a self-employed political strategist/consultant and has been

actively involved in U.S. politics since 1975. Stone worked on the presidential campaign of

Donald J. Trump (the "Campaign") until he was fired in August 2015. Although Stone had no

official relationship with the Campaign thereafter, Stone maintained his support for Trump and

continued to make media appearances in support of Trump's presidential campaign. On August

7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the Twitter account

@RogerJStoneJr.

16. On June 14, 2016, news reports indicated that the computer systems of the DNC

had been hacked. On June 15, 2016, Guccifer 2.0 publicly claimed responsibility for the DNC

hack. Shortly thereafter, Guccifer 2.0 began releasing the hacked documents, including a June,

21, 2016 release of hacked documents.

17. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

5
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 11 of 35

18. On August 5, 2016, Roger Stone published an article on Breitbart.com entitled,

"Dear Hillary: DNC Hack Solved, So Now Stop Blaming Russia." Stone wrote: "It doesn't

seem to be the Russians that hacked the DNC, but instead a hacker who goes by the name of

Guccifer 2.0." Stone embedded publicly available Tweets from Guccifer 2.0 in the article and

wrote: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and why

he did the hack of the DNC." Stone also stated: "Guccifer 2.0 made a fateful and wise decision.

He went to WikiLeaks with the DNC files and the rest is history. Now the world would see for

themselves how the Democrats had rigged the game."

19. On August 8, 2016, Stone addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

Assange to Russia Today (RT) several days earlier about an upcoming "October Surprise" aimed

at the Hillary Clinton presidential campaign. Specifically, Stone was asked: "With regard to the

.· October surprise, what would be your forecast on that given what Julian Assange has intimated

he's going to do?" Stone responded: "Well, it could be a number of things. I actually have

communicated with Assange. I believe the next tranche of his documents pertain to the Clinton

Foundation but there's no telling what the October surprise may be." A few days later, Stone

clarified that while he was not personally in touch with Assange, he had a close friend who

served as an intermediary.

20. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the Democratic Congressional Campaign

Committee (DCCC).

6
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 12 of 35

21. On August 13, 2016, Stone posted a tweet using @RogerJStoneJr calling Guccifer

2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day, Guccifer 2.0's

Twitter account was reinstated.

22. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

23. On August 18, 2016, Paul Manafort, Stone's longtime friend and associate,

resigned as Chairman of the Campaign. Contemporary press reports at the time indicated that

Manafort had worked with a Washington D.C.-based lobbying firms to influence U.S. policy

toward Ukraine.

24. On August 21, 2016, using @RogerJStoneJR, Stone directed a tweet at John

Podesta, Hillary Clinton's presidential campaign manager, stating: "Trust me, it will soon the

[sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same day,

Stone reiterated that because of the work ofa '"mutual acquaintance' of both his and [Assange],

the public [could] expect to see much more from the exiled whistleblower in the form of

strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat.

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

25. On September 16, 2016 Stone said in a radio interview with Boston Herald Radio

that he expected WikiLeaks to "drop a payload of new documents on a weekly basis fairly soon.

And that of course will answer the question of exactly what was erased on that email server."

7
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 13 of 35

26. On Saturday, October 1, 2016, using @RogerJStoneJr, Stone Tweeted,

"Wednesday@ HillaryC!inton is done. #WikiLeaks."

27. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement Julian Assange had scheduled for the next day from the

balcony of the Ecuadoran Embassy in London. On the day of the Assange announcement -

which was part of WikiLeaks' 10-year anniversary celebration - Stone told lnfowars that his

intermediary described this release as the "mother load." On Tuesday, October 4, 2016, Stone

used @RogerJStoneJr to tweet: "Payload coming. #Lockthemup."

28. On Friday, October 7, 2016, at approximately 4:03 P.M., the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

29. Approximately a half hour later, at 4:32 P.M., WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

30. WikiLeaks continued to release John Podesta's hacked emails throughout October

10-21, 2016. On October 12, 2016, John Podesta- referring back to Stone'~ August 21, 2016 C-

SP AN and Twitter references - argued publicly that "[it is J a reasonable assumption to - or at

least a reasonable conclusion - that [Stone] had advanced warning [of the release of his emails]

and the Trump campaign had advanced warning about what Assange was going to do. I think

there's at least a reasonable belief that [Assange] may have passed this information on to

[Stone]." Commenting to the Miami Herald, Stone responded: "I have never met or spoken with

Assange, we have a mutual friend who's traveled to London several times, and everything I

know is through that channel of communications. I'm not implying I have any influence with

8
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 14 of 35

him or that I have advanced knowledge of the specifics of what he is going to do. I do believe he

has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides, thought were

deleted. I hear that through my emissary."

31. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between Stone and WikiLeaks. The same article quoted

Stone as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email·(speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

C. · Roger Stone's Private Twitter Direct Messages with WikiLeaks and Jnlian
Assange.

32. On October 13, 2016, while WikiLeaks was in the midst of releasing the hacked

Podesta emails, @RogerJStoneJr sent a private direct message to the Twitter account

@wikileaks. This account is the official Twitter account of WikiLeaks and has been described as

such by numerous news reports. The message read: "Since I was all over national TV, cable and

print defending WikiLeaks and assange against the claim that you are Russian agents and

debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

33. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

9
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 15 of 35

34. On October 16, 2016, @RogerJStoneJr sent a direct message to@wikileaks: "Ha!

The more you \"correct\" me the more people think you're lying. Your operation leaks like a

sieve. You need to figure out who your friends are."

35. On November 9, 2016, one day after the presidential election, @wikileaks sent a

direct message to @RogerJStoneJr containing a single word: "Happy?" @wikileaks immediately

followed up with another message less than a minute later: "We are now more free to

communicate."

36. In addition, @RogerJStoneJr also exchanged direct messages with Julian

Assange, the founder of WikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly

messaged @JulianAssange, an address associated with Julian Assange in.numerous public

reports, stating: "Still nonsense. As a journalist it doesn't matter where you get information only

that it is accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

37. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@wikileaks, reading: "I am doing everything possible to address the issues at the highest level of

Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

JO
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 16 of 35

D. Emails with Stone and Corsi

39. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, On October

17, 2017, Chief Judge Beryl A. Howell issued a search warrant for STONE's address,

On March 14, 2018, Chief Judge Beryl A. Howell issued a search

warrant for STONE's iCloud account. On April 23, 2018, Chief Judge Beryl A. Howell signed

an order pursuant to 18 U.S.C. §2703(d) for the Target Accounts. Information recovered

pursuant to those search warrants and orders indicated the following:

40. On or about February 2 and February 3, 2016, using Target

Account 1, sent two emails to , an email address associated with

II
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 17 of 35

41. On or about February 5, 2016, received two emails on Target

Account l from an account associated with

42. On or about April 6, 2016, CORSI and (on Target Account 1)

exchanged seven emails. On or about April 7, CORSI email on Target Account

1. On or about April 8, 2016, mailed CORSI. On or about April 10,

and CORSI exchanged two emails. On or about April 18, 2016, CORSI sent

an email.

43. On or about May 1, 2016, CORSI emailed (on Target Account 1)

three times and sent him two responses. On or about May 2, 2017,

(on Target Account 1) emailed CORSI.

44. On or about May 17, 2016, STONE emailed Jerome CORSI, "send me e-

mail address." CORSI wrote back, "Roger[,] (Target

Account 1) also seems to work as "4

45. That same day, STONE emailed at Target Account 1. STONE

wrote that he would have to move "our meeting to Wednesday. I am uncomfortable meeting

without Jerry." As described further below, it appears that "Jerry" is Jerome CORSI. STONE

and exchanged additional emails about setting up dinner, and

emailed back, "RS[,] Confirming dinner Wednesday at 7PM at Club 21, JC included."

46. On or about that same day, May 17, 2016, n Target Account 1,

emailed CORSI.

47. On or about June 3, 2016, CORSI emailed on Target Account 1.

E. Stone, and Corsi's Text Messages about "October Surprise" and


"Critical Intel."

4
The period in a email account is not read as a character. Therefore, and
are the same account.

12
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 18 of 35

48. On or about May 17, 2016, messaged STONE, "Hi Roger, I hope

all is well. Our dinner tonight for 7PM is confirmed. I arrive at 4PM. Please suggest a good

restaurant that has privacy. Thank you. See you soon, " STONE responded,

'See e-mail."

49. On or about May 19, 2016, messaged STONE, "Hi Roger, It Was

Great Seeing You Again Last Night At Dinner. Did You Talk To Trump This Morning? Any

News? Thank You. Best, ." STONE responded, "Contact made - interrupted

- mood good." nd STONE continued to text about arranging a meeting with

then-candidate Trump.

50. On or about.June 21, 2016, messaged STONE, "RS: Secret I

CabinetMinister in NYC Sat. June 25. Available for DJT meeting. " According

to publicly-availabe information, during this time was a Minister without

portfolio in the cabinet dealing with issues concerning defense and foreign affairs.

51. On or about June 25, 2016, messaged Stone, "Roger, Minister left.

Sends greetings from PM. 5 When am I meeting DJT? Should I stay or leave Sunday as planned?

Hope you are well. "

52. On or about June 26, 2016, STONE messaged I am better but

turn out to have been poisoned. Completely out of action for 3 days-apologize to Minister for

me. I would not leave as we hope to schedule the meeting mon or tues."

53. On or about June 28, 2016, messaged STONE, "RETURNING TO

DC AFTER URGENT CONSULTATIONS WITH PM IN ROME.MUST MEET WITH YOU

WED. EVE AND WITH DJ TRUMP THURSDAY IN NYC.

5 Based on statements here and below, I belie-Ve "PM" refers to the" Prime Minister.

13
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 19 of 35

54. On or about Jun 29, 2016, STONE responded, "Monday meeting collapsed after

DJT cleared his schedule to deal with the money crisis. lam waiting the new schedule. Will try

for Thursday."

55. On or about June 30, 2016, STONE messaged "Revised - meeting

now I pm July 6."

56. On or about July l, 2016, wrote back, "Thank you my friend. I

will plan to be back in NYC on July 5th for the meeting with DJT on the 6'h at l pm.THAY YOU

ROGER." STONE responded, "Sorry this took so long. R."



57. On July 5, 2016, messaged STONE, "Roger, I am here, ready for

the meeting with DJ Trump at 1PM tomorrow. Let's you and I meet at 10.30AM at the St. Regis

Lobby. Thank you. "

58. On July 6, 2016, messaged STONE, "At St Regis With Lt General.

Waiting For You Thank You. " STONE wrote back, " - I am down

with a nasty cold. and too ill to travel- I have a1rnnged for Jerri to take u in at I rather than lose

the appointment- please connect with Jerri - Let me know how the meeting goes .DJT

expecting u. R" Based on STONE's contacts and emails described above, investigators believe

that the "Jerri" referenced in the message refers to Jerome CORSI.

59. wrote back, "Thank U Very Much[.] I Have To Meet Trump Alone

After A Brief Introduction by Jerry Thanks Roger." STONE wrote back, "As long as u get the

meeting-lam very sorry I cannot !jtlend- have a high fever and no voice."
lt<:1
60. On July 8, 2oy
-z.o.1~
essaged STONE, "Hi Roger. Have you

rescheduled the meeting with DJT? The PM is putting pressure for a quick decision. Thank you

for all your help!

14
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 20 of 35

61. On or about July 8, 2016, STONE wrote back, "T not in NYC again before the

convention. I have pneumonia and may be hospitalized later today. I can get this back on track

post convention when I can attend. Sorry about the fiasco last week, however you can't just bring

the General without tell me - R."

62. On or about July 25, 2016, STONE sent an email from his Account to

Jerome CORSI with the subject line, "Get to Assange." The body of the message read: "Get to

Assange [a]t Ecuadorian Embassy in London and get pending WikiLeaks emails ... they deal with

Foundation, allegedly."

63. On or about July 29, 2016, sent a messaged to STONE, "HI

ROGER, I HOPE YOU ARE WELL. HAVE YOU SET UP A NEW MEETING WITH

TRUMP? 1 PLAN TO BE BACK IN THE US NEXT WEEK. PLEASE ADVISE. THANK

YOU.

64. On or about July 31, 2016, STONE emailed CORSI with the subject line, "Call

me MON." The body of the email read: " .should see Assange[.] should find

Bernie [S]anders brother who called Bill a Rapist- turn him for Trump[.] should find

or more proof of Bill getting kicked out."

65. On or about August 2, 2016 (approximatelyl9 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed the STONE, "Word is friend in

embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct. Impact planned to be very

damaging ... Time to let more than Podesta to be exposed as in bed w enemy if they are not

ready to drop HRC. That appears to be the game hackers are now about. Would not hurt to start

suggesting HRC old, memory bad, has stroke -- neither he nor she well. I expect that much of

next dump focus, setting stage for Foundation debacle." Investigators believe that CORSI's

15
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 21 of 35

reference to a "friend in embassy [who] plans 2 more dumps" refers to Julian ASSANGE, the

founder of WikiLeaks, who resided in Ecuador's London Embassy in 2016.

'66. On or about August 9, 2016, messaged STONE, "Roger-As per PM

we have one last shot before moving on. Can you deliver? History will not forgive us. TRUMP

IN FREE FALL. OCTOBER SURPRISE COMrNG !

67. On or about August 12, 2016, messaged STONE, "Roger, hello

from Jerusalem. Any progress? He is going to be defoated unless we intervene. We have critical

intell. The key is in your hands! Back in the US next week. How is your Pneumonia? Thank you.

STONE replied, "I am well. Matters complicated. Pondering. R." wrote

back, "Thank You." No additional messages appear in STONE's iCloud between STONE and

until October 30, 2016.

68. As described above, on October 7, 2016, WikiLeaks began releasing the emails

hacked from John Podesta's account.

69. On October 26, 2016, emailed on the Target

Account. On or about October 27, 2016, emailed three

times on the Target Account.

70. On October 30, 2016, messaged S~ONE: "Roger, you are doing a

great job !!! I am in NY-met with DJT and helping. Victory is in sight. HK says hello. Thanks,

71. On Thursday, November 3,'2016, messaged STONE: "Roger,

European country ready to release secret tapes to DESTROY objective. Can we meet ASAP? 4

star General will join. " STONE responded, "Yes let's talk

thurs." wrote back, "Must meet in NYC Thursday AM."

16
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 22 of 35

72. On or about November 7, 2016 messaged STONE,

"ROGER,JERRY- SORRY, BUT DUE TO AN UNEXPECTED EMERGENCY I HAVE TO

CANCEL TODAY'S MEETING AT 9. THANKS .. HAVING a TIA. Early Stroke."

STONE responded, "Take care of yourself." wrote back, "Tnaks Xou RGer. Blury

Virson." STONE replied, "You can't die until after we elect Donald."

F. Stone's HPSCI Testimony and Subsequent Conversations

73. According to publicly-available reporting, Stone testified before the House

Permanent Select Intelligence Committee (HPSCI) on September 26, 2017. STONE released his

prepared remarks to the media. In his remarks, Stone stated that he had learned Assange was in

possession of the DNC emails via Twitter, and that he asked a "journalist" to "independently

confirm this report." Stone stated his "intermediary" had "assured me that WikiLeaks would

release this information in October and continued to assure me of this throughout the balance of

August and all of September." Stone denied knowledge in advance of Podesta's emails being

hacked. Accordingly to publicly-available news reports, Stone subsequently informed HPSCI

that his .intermediary was Randy Credico, an American radio host.

74. On or about November 24, 2017, Credico .texted Stone, "I told you to watch his

Tweets in October not before that I knew nothing about the DNC stuff. I just followed his

Tweets." Stone responded, "U never said anything about the DNC but it was August." Credico

replied, "It was not August because I didn't interview him or meet him until August 261h."

75. Credico and Stone continued to exchange messages, and on December 1, 2017,

Credico wrote: "I don't know why you had to lie and say you had a back Channel now I had to

give all ofmy forensic evidence to the FBI today what a headache. You could have just told him

the truth that you didn't have a back channel they now know that I was not in London until

17
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 23 of 35

September of this year. You had no back-channel and you could have just told the truth. You

want me to cover you for perjury now." 6 Stone responded, "What the fuck is your problem?

Neither ofus has done anything wrong or illegal. You got the best press of your life and you can

get away with asserting for 5th amendment rights ifu don't want talk about[.] And if you turned

over anything to the FBI you're a fool." Credico replied, "You open yourself up to six counts of

perjury. But I'm sure that wasn't sworn testimony so you're probably clear ... You should go

back in a minute your testimony and tell them the truth ... You need to amend your testimony

before I testify on the 15 1h." Stone wrote, "If you testify you're a fool. Because of tromp [sic] I

could never get away with a certain [sic] my Fifth Amendment rights but you can. I guarantee

you you are the one who gets·indicted for perjury if you're stupid enough to testify." Stone and

Credico continued to correspond, and according to publicly available news reports, on December

13, 2017, Credi co asse1ted his Fifth Amendment right not to testify before the HPSCI.

76. On January 25, 2018, Credico texted Stone, "You lied to the house Intel

committee. But you'll get off because you're friends with Trump so don't worry. I have. all the

forensic evidence. I was not a ba[ck] Channel and I have all those emails from September of

2016 to prove it."

INFORMATION REGARDING GOOGLE

77. Google provides numerous free services to the users with a Google profile. Some

of services include, Gmail, Google Talk, Google Wallet, Google+, Google Drive, Google+

Photos, and YouTube. Gmail is a web based email service. Google Talk is an instant messaging

service that provides both text and voice communication. Google Talk conversation logs are

saved to a "Chats" area in the user's Gmail account. Google+ is a social networking service.

Google Drive is a file storage and synchronization service which provides users with cloud

6 Contrary to his statement, Credico had not provided any information tot.he FBI.

18
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 24 of 35

storage, file sharing, and collaborative editing. Google+ Photos (fo1merly knowns as Picasa Web

Albums) is an image hosting and sharing web service that allows users with a Google account to

store and share images for free. YouTube is a free video sharing website that allows users

upload, view and share videos. Google also retains a record of searches conducted by the user, as

well as location data for the use of some of the services described above. All of these services

may record information uploaded, inputted, or gathered from the user.

CONCLUSION

78. Based on the forgoing, I request that the Court issue the proposed search warrant.

19
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 25 of 35

REQUEST FOR SEALING

79. I further request that the Court order that all papers in support of this application,

including the application, affidavit and search warrant, be sealed until further order of the Court.

These documents discuss an ongoing criminal investigation that is neither public nor known to

all of the targets of the investigation. Accordingly, there is good cause to seal these documents

because their premature disclosure may give targets an opportunity to flee/continue flight from

prosecution, destroy or tamper with evidence, change patterns of behavior, notify confederates,

or otherwise seriously jeopardize the investigation.

ft!. rew T. Mitchell


Special Agent
. Federal Bureau of Investigation

Subscribed and sworn to before me on this ~ y of May, 2018.

~i~
The Honorak~~l A. Howell
Chief United States District Judge

20
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 26 of 35

ATTACHMENT A

Property to Be Searched

This warrant applies to information associated with the Google account

hat is stored at premises owned, maintained, controlled, or operated

by Google, Inc., a business with offices located at 1600 Amphitheatre Parkway, Mountain View,

CA 94043.
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 27 of 35

ATTACHMENT B

ATTACHMENT B
Particular Things to be Seized

I. Files and Accounts to be produced by Google, Inc. betwceu January 1, 2016 and
the Present.

To the extent that the information described in Attachment A is within the possession,
custody, or control of Google, Inc. including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to Google or have been preserved
pursuant to a preservation request under 18 U.S.C. § 2703(f), Google is required to disclose the
following information to the government for each account or identifier listed in Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and destination
e-mails sent addresses associated with each e-mail, the date and time at which each e-mail was
sent, and the size and length of each e-mail; 1

b. All existing printouts from original storage of all of the electronic mail described
above in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above in


Section I.A, .including log files, dates, times, methods of connecting, ports, dial ups, and/or
locations;

e. All records or other information stored by an individual using the account,


including address books, contact and buddy lists, calendar data, pictures, and files;

f. All records or other information regarding the identification of the account


described above in Section I.A, to include application, full name, physical address, telephone
numbers and other identifiers, records of session times and durations, the date on which the
account was created, the length of service, the types of service utilized, the IP address used to
register the account, log-in IP addresses associated with session times and dates, account status,
alternative e-mail addresses provided during registration, all screen names associated with
subscribers and/or accounts, all account names associated with the subscriber, methods of
connecting, log files, means and source of payment (including any credit or bank account
number), and detailed billing records;

g. All records indicating the services available to subscribers of the electronic mail
address described above in Section I.A.;

h. Google+ subscriber information, circle information, including name of circle and

I This Search warrant applies on to email sent, received, or drafted on or after May 26, 20 I 7.

2
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 28 of 35

members, contents of posts, comments, and photos, to include date and timestamp;

i. Google Drive files created, accessed or owned by the account;

J. YouTube subscriber information, private videos and files, private messages, and
comments;

le Google+ Photos contents to include all images, videos and other files, and
associated upload/download date and timestamp;

l. Google Talk and Google Hangouts conversation logs associated with the account.

3
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 29 of 35

II. Information to be Seized by Law Enforcement Personnel

a. Any and all records that relate in any way to the account described in Attachment
A which is evidence, fruits, and instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision ofa felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (making a false statement); 18 U.S.C. §1651
(pe1jury); 18 U.S.C. § 1030 (unauthorized access ofa protected computer); 18 U.S.C. § 1343
(wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud),, and 52 U.S.C.
§ 30121 (foreign contribution ban) from Jan l, 2015 to the present, including:

All records, information, documents or tangible materials that relate in any way to
communications with foreign government officials or agents of a foreign power,
or discussions with others regarding those actions, or plans or attempts at
undertaking such actions:

b. All images, messages, communications, calendar entries, search terms, and


contacts, including any and all preparatory steps taken in furtherance of these crimes;

c. Communication, information, documentation and records relating to who created,


used, or communicated with the account or identifier, including records about their identities and
whereabouts;

d. Evidence of the times the account was used;

e. All images, messages and comm_unications regarding wiping software, encryption


or other methods to avoid detection by law enforcement;

f. Passwords and encryption keys, and other access information that may be
necessary to access the account and other associated accounts;

g. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

h. All existing printouts from original storage which concern the categories
identified in subsection II.A; and

1. All "address books" or other lists of contacts.

4
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 30 of 35

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF


INFORMATION ASSOCIATED WITH Case: 1:18-sc-01518
THE GOOGLE ACCOUNT Assigned To : Howell, Beryl A.
Assign. Date: 5/4/2018
Description: Search & Seizure Warrant

MOTION TO SEAL WARRANT AND RELATED DOCUMENTS


AND TO REQUIRE NON-DISCLOSURE UNDER 18 U.S.C. § 270S(B)

The United States ofAmerica, moving by and through its undersigned counsel, respectfully

moves the Court for an Order placing the above-captioned warrant and the application and affidavit

in support thereof (collectively herein the "Warrant") under seal, and precluding the provider from

notifying any person of the Warrant pursuant to 18 U.S.C. § 2705(b). In regard to non-disclosure,

the proposed Order would direct Google LLC, an electronic communication and/or remote

computing services provider with headquarters in Mountain View, California, not to notify any

other person (except attorneys for Google for the purpose of receiving legal advice) of the

existence or content of the Warrant for a period of one year unless otherwise ordered of the Court.

JURISDICTION AND LEGAL BACKGROUND

I. The Court has the inherent power to seal court filings when appropriate,

including the Warrant. United States v. Hubbard, 650 F.2d 293, 315-16 (D.C. Cir. 1980) (citing

Nixon v. Warner Communications, Inc., 435 U.S. 589, 598 (1978)). The Court may also seal the

Wanant to prevent serious jeopardy to an ongoing criminal investigation when, as in the present

case, such jeopardy creates a compelling governmental interest in preserving the confidentiality of

the Warrant. See Washington Post v. Robinson, 935 F.2d 282, 287-89 (D.C. Cir. 1991 ).

2. In addition, this Court has jurisdiction to issue the requested order because it is "a

court of competent jurisdiction" as defined by 18 U.S.C. § 2711. Specifically, the Court is a

Page 1 of6
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 31 of 35

"district court of the United States ... that- has jurisdiction over the offense being investigated."

18 U.S.C. § 2711(3)(A)(i). As discussed fully below, acts or omissions in fmtherance of the offense

under investigation occmTed within Washington, D.C. See 18 U.S.C. § 3237.

3. Further, the Court has authority to require non-disclosure of the Warrant under 18

U.S.C. § 2705(b). Google provides an "electronic communications service," as defined in 18

U.S.C. § 2510(15), and/or "remote computing service," as defined in 18 U.S.C. § 2711(2). The

Stored Communications Act ("SCA"), 18 U.S.C. §§ 2701-2712, governs how Google may be

compelled to supply communications and other records using a subpoena, court order, or search

warrant. Specifically, Section 2703(c)(2) authorizes the Government to obtain certain basic

"subscriber information" using a subpoena, Section 2703(d) allows the Government to obtain other

"non-content" information using a court order, and Section 2703(a)-(b)(l)(A) allows the

Government to obtain contents of communications using a search warrant. See 18 U.S.C. § 2703.

4. The SCA does not set forth any obligation for providers to notify subscribers about

subpoenas, court orders, or search warrants under Section 2703. However, many have voluntarily

adopted policies of notifying subscribers about such legal requests. Accordingly, when necessary,

Section 2705(b) of the SCA enables the Government to obtain a court order to preclude such

notification. In relevant part, Section 2705(b) provides as follows:. 1

(b) Preclusion of notice to subject of governmental access. - A governmental


entity acting under section 2703 ... may apply to a court for an order commanding
a provider of electronic communications service or remote computing service to
whom a warrant, subpoena, or court order is directed, for such period as the court

1
Section 2705(b) contains additional requirements for legal process obtained pursuant to
18 U.S.C. § 2703(b)(l)(B), but the Government does not seek to use the proposed Order for any
legal process under that provision.

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Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 32 of 35

deems appropriate, not to notify any other person of the existence of the warrant,
subpoena, or court order. The court shall enter such an ~rder if it determines that
there is reason to believe that notification of the existence of the warrant, subpoena,
or court order will result in -

(1) endangering the life or physical safety of an individual;

(2) flight from prosecution:

(3) destruction of or tampering with evidence;

(4) intimidation of potential witnesses; or

(5) otherwise seriously jeopardizing an investigation or unduly delaying


a trial.

18 U.S.C. § 2705(b). The United States District Court for the District of Columbia has made clear

that a nondisclosure order under Section 2705(b) must be issued once the Government makes the

requisite showing about potential consequences of notification:

The explicit terms of section 2705(b) make clear that if a courts [sicJfinds that there
is reason to believe that notifying the customer or subscriber of the court order or
subpoena may lead to one of the deleterious outcomes listed under § 2705(b), the
court must enter an order commanding a service provider to delay notice to a
customer for a period of time that the court determines is appropriate. Once the
government makes the required showing under § 2705(b), the court is required to
issue the non-disclosure order.

In re Application for Order of Nondisclosure Pursuant to 18 U.S.C. § 2705(b) for Grand Jury

Subpoena #GJ2014031422765, 41 F. Supp. 3d 1, 5 (D.D.C. 2014).

5. Accordingly, this motion to seal sets forth facts showing reasonable grounds to

command Google not to notify any other person (except attorneys for Google for the purpose of

receiving legal advice) of the existence of the Warrant for a period of one year unless othe1wise

ordered by the Court.

FACTS SUPPORTING SEALING AND NON-DISCLOSURE

6. At the present time, law enforcement officers of the FBI are conducting an

investigation into violations related to 18 U.S.C. § 2 (aiding and abetting), 18 U.S.C. § 3 (accessory

Page 3 of6
Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 33 of 35

after the fact), 18 U.S.C. § 4 (misprision of a felony), 18 U.S.C. § 371 (conspiracy), 18 U.S.C.

§ 1030 (unauthorized access of a protected computer); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C.

§ 1349 (attempt and conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign

contribution ban) arising out of the conduct of various unknown persons that operated and

controlled the subject accounts. It does not appear that these individuals are currently aware of the

nature and scope of the ongoing FBI investigation.

REQUEST FOR SEALING AND NON-DISCLOSURE

7. In this matter, the government requests that the Warrant be sealed until further order

of the Court and that Google and its employees be directed not to notify any other person of the

existence or content of the Warrant (except attorneys for Google for the purpose of receiving legal

advice) for a period of one year unless otherwise ordered by the Court. Such an order is appropriate

because the Warrant relates to an ongoing criminal investigation, the full scope of which is neither

public nor known to the targets of the investigation, ap.d its disclosure may alert these targets to

the ongoing investigation and its scope. Once alerted to this investigation, potential targets would

be immediately prompted to destroy or conceal incriminating evidence, alter their operational

tactics to avoid future detection, and otherwise take steps to undermine the investigation and avoid

future prosecution. In particular, given that they are known to use electronic communication and

remote computing services, the potential target could quickly and easily destroy or encrypt digital

evidence relating to their criminal activity.

8. Given the complex and sensitive nature of the criminal activity under investigation,

and also given that _the criminal scheme may be ongoing, the Government anticipates that this

confidential investigation will continue for the next year or longer. However, should circumstances

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Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 34 of 35

change such that court-ordered nondisclosure under Section 2705(b) becomes no longer needed,

the Government will notify the Comt and seek appropriate relief.

9. There is, therefore, reason to believe that notification of the existence of the Warrant

will seriously jeopardize the investigation, including by giving the targets an opportunity to flee

from prosecution, destroy or tamper with evidence, and intimidate witnesses. See 18 U.S.C.

§ 2705(b)(2}-(5). Because of such potential jeopardy to the investigation, there also exists a

compelling governmental interest in confidentiality to justify the government's sealing request.

See Robinson, 935 F.2d at 287-89.

10. Based on prior dealings with Google, the United States is aware that, absent a court

order under Section 2705(b) commanding Google not to notify anyone about a legal request, it is

Google's policy and practice, upon receipt of a warrant seeking the contents of electronically

stored wire or electronic communications for a certain account, to notify the subscriber or customer

of the existence of the warrant prior to producing the material sought.

WHEREFORE, for all the foregoing reasons, the government respectfully requests that the

above-captioned warrant, the application and affidavit in support thereof, and all attachments

thereto and other related materials be placed under seal, and furthermore, that the Court command

Google not to notify any other person of the existence or contents of the above-captioned warrant

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Case 1:19-mc-00029-CRC Document 29-7 Filed 04/28/20 Page 35 of 35

(except attorneys for Google for the purpose of receiving legal advice) for a period of one year

unless otherwise ordered by the Court.

Respectfully submitted,

ROBERTS. MUELLEf, III


Special Co)lnsel /

By:-~~~""'\,:.-_-t_-~~-···-·~/-_-_···--~-----
. Ktle Freeny ··
Specia:l Counsel's G
Office (202) 616-0800

Page 6 of6
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 1 of 23
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 2 of 23
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 3 of 23

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF MASSACHUSETTS

IN THE MATTER OF THE SEARCH OF Case No. J 'if-/V()-ol l'1c). -A-t_B~


THE PERSON OF
Filed Under Seal

IN THE MATTER OF THE SEARCH OF Case No. I 1J - fVl:S"" _ ~ 11 '!> _ Mt3B,


THE BAGGAGE OF
Filed Under Seal

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR SEARCH WARRANTS

I, Curtis Heide, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for search and seizure warrants

under Rule 41 of the Federal Rules of Criminal Procedure authorizing the search of the person of

(the Target Person) (described further in that warrant's

Attachment A), and any baggage associated with him (described further in that warrant's

Attachment A), and the seizure of the electronic devices and media described in Attachment B

(the Target Devices). I anticipate this search will be executed after lands at Logan

International Airport at approximately This warrant is for the

seizure of the devices only; the Government will seek a warrant to search any seized devices at a

later point in time.

2. I, Curtis A. Heide, have been a Special Agent with the Federal Bureau of

investigation for 11 years. In the course of my duties, I have been responsible for investigating

federal crimes and national security matters involving both counterintelligence and issues related

to cybersecurity.
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 4 of 23

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my lrnowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that ROGER STONE, JEROME CORSI and others have

committed violations of 18 U.S.C. § 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the

fact), 18 U.S.C. § 4 (misprision of a felony), 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 1030

(unauthorized access of a protected computer); 18 U.S.C. § 1343 (wire fraud), and 18 U.S.C.

§ 1349 (attempt and conspiracy to commit wire fraud) (the "Subject Offenses").

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because, as described

further below, it is anticipated that and his baggage will be located in the District of

Massachusetts on

SUMMARY

6. As set forth below, (the Target Person) was in contact with Roger

STONE and Jerome CORSI during the summer and fall of 2016, when STONE appears to have

obtained advance lrnowledge of the release by WikiLeaks of illegally hacked emails for the

benefit of the presidential campaign of Donald J. Trump (the "Campaign"). In July 2016,

STONE instructed CORSI to have talk with Julian AS SANGE, the founder of

WikiLeaks, and served as CORSI's conduit to ASSANGE to discuss hacked

information.

2
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 5 of 23

7. More specifically, on or about July 25, 2016, STONE emailed CORSI to "Get to

Assange" in person at the Ecuadorian Embassy and "get pending WikiLeaks emails[.]" On or

about July 31, 2016, STONE instructed CORSI to have "see ASSANGE." At the

time, lived in London, where Assange was located at the Ecuadorian Embassy. On

or about August 2, 2016, CORSI told STONE that the "word is friend in embassy [ASSANGE]

plans 2 more dumps. One shortly after I'm back. 2nd in October. Impact planned to be very

damaging .... Time to let Podesta to be exposed as in bed w enemy if they are not ready to drop

HRC." Information disclosures subsequently occurred on or about the times CORSI predicted.

8. On or about August 10, 2016, began emailing CORSI multiple news

articles regarding AS SANGE and alleged Russian involvement in the election. On or about

November 13, 2016, emailed STONE to congratulate him on "tak[ing] the country

back," and stating, "You deserve a lot of credit and working with you and Jeri Corsi, who is with

me now in London has been a great joy." On or about January 7, 2017, emailed

STONE and CORSI to joke about John Podesta going "phishing." As stated below, I know from

my training and experience that the term "phishing" is used to refer to the practice of sending

emails purporting to be from a reputable party in order to trick individuals to reveal to the sender

personal information, including passwords.

PROBABLE CAUSE TO BELIEVE THAT A FEDERAL CRIME WAS COMMITTED

A. Background on Relevant Individuals

i. Roger STONE

9. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the Campaign until August

2015. Although STONE had no official relationship with the Campaign thereafter, STONE

3
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 6 of 23

maintained his support for Trump and continued to make media appearances in support of the

Campaign. As described further below, STONE also maintained contact with individuals

employed by the Campaign, including then-campaign chairman Paul MANAFORT and deputy

chairman Rick GATES.

ii. Jerome CORSI

10. Jerome CORSI is a political commentator who, according to publicly-available

information, serves as the "Washington Bureau Chief for Infowars.com." According to publicly-

available sources, from 2014 until January 2017, CORSI was a "senior staff reporter" for the

website "World Net Daily" a/k/a "WND.com." CORSI has also written a number of books

regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

4
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 7 of 23

B. U.S. Intelligence Community (USIC) Assessment of Russian Government-Backed


Hacking Activity during the 2016 Presidential Election

12. On October 7, 2016, the U.S. Department of Homeland Security and Office of the

Director of National Intelligence released a joint statement of an intelligence assessment of

Russian activities and intentions during the 2016 presidential election. 1 In the report, the USIC

assessed the following:

13. "The U.S. Intelligence Community (USIC) is confident that the Russian

Government directed the recent compromises of e-mails from US persons and institutions,

including from US political organizations. The recent disclosures of alleged hacked e-mails on

sites like DCLeaks.com and WikiLeaks and by the Guccifer 2.0 online persona are consistent

with the methods and motivations of Russian-directed efforts. These thefts and disclosures are

intended to interfere with the US election process. Such activity is not new to Moscow-the

Russians have used similar tactics and techniques across Europe and Eurasia, for example, to

influence public opinion there. We believe, based on the scope and sensitivity of these efforts,

that only Russia's senior-most officials could have authorized these activities."

14. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

1
"Joint Statement from the Department Of Homeland Security and Office of the Director of National Intelligence on
Election Security," Oct. 7, 2016, available at ttps://www.dhs.gov/news/2016/10/07/joint-statement-department-
homeland-security-and-office-director-national.

5
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 8 of 23

"Assessing Russian Activities and Intentions in Recent US Elections."2 In the report, the USIC

assessed the following:

15. "[] Russian President Vladimir Putin ordered an influence campaign in 2016

aimed at the US presidential election. Russia's goals were to undermine public faith in the US

democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her

electability and potential presidency. We further assess Putin and the Russian Government

developed a clear preference for President-elect Trump."

16. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

17. With respect to hacking activity, the USIC assessed: "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." In addition, "In July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC further assessed that cyber

operations by Russian military intelligence (General Staff Main Intelligence Directorate or GRU)

"resulted in the compromise of the personal e-mail accounts of Democratic Party officials and

political figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

2
"Assessing Russian Activities and Intentions in Recent US Elections," Jan. 6, 2017, available at
https://www.dni.gov/files/documents/ICA_ 2017_ 0 l .pdf.

6
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 9 of 23

18. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

19. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his likely Russian identity throughout the

election. Press reporting suggests more than one person claiming to be Guccifer 2.0 interacted

with journalists.

C. Roger STONE's Disclosed Interactions with Guccifer 2.0 and WikiLeaks.

20. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics since 1975. STONE worked on the Campaign until he was

fired in August 2015. Although STONE had no official relationship with the Campaign

thereafter, STONE maintained his support for Trump and continued to make media appearances

in support of Trump's presidential campaign.

21. As discussed further below, STONE made a number of public references to

WikiLeaks and its release ofDNC-related emails. STONE has also stated that he was in contact

via Twitter with Guccifer 2.0.

22. On June 14, 2016, news reports indicated that the computer systems of the DNC

had been hacked. On June 15, 2016, Guccifer 2.0 publicly claimed responsibility for the DNC

hack. Shortly thereafter, Guccifer 2.0 began releasing the hacked documents, including a June

21, 2016 release of hacked documents.

23. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

7
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 10 of 23

24. On August 5, 2016, Roger STONE published an article on Breitbart.com entitled,

"Dear Hillary: DNC Hack Solved, So Now Stop Blaming Russia." STONE wrote: "It doesn't

seem to be the Russians that hacked the DNC, but instead a hacker who goes by the name of

Guccifer 2.0." STONE embedded publicly available Tweets from Guccifer 2.0 in the article and

wrote: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and why

he did the hack of the DNC." STONE also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

25. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

Assange to Russia Today (RT) several days earlier about an upcoming "October Surprise" aimed

at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With regard to

the October surprise, what would be your forecast on that given what Julian Assange has

intimated he's going to do?" STONE responded: "Well, it could be a number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain

to the Clinton Foundation but there's no telling what the October surprise may be." A few days

later, STONE clarified that while he was not personally in touch with Assange, he had a close

friend who served as an intermediary.

26. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJSTONEJr thanks

that u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal

cellphone numbers and email addresses from the files of the Democratic Congressional

Campaign Committee (DCCC).

8
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 11 of 23

27. On August 13, 2016, STONE posted a tweet using@RogerJSTONEJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

28. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJSTONEJr paying

you back." Guccifer also sent a private message to @RogerJSTONEJr stating "i'm pleased to say

u r great man. please tell me ifl can help u anyhow. it would be a great pleasure to me."

29. On August 18, 2016, Paul Manafort, STONE's longtime friend and associate,

resigned as Chairman of the Campaign. Contemporary press reports at the time indicated that

Manafort had been working with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

30. On August 21, 2016, using @RogerJSTONEJR, STONE directed a tweet at John

Podesta, Hillary Clinton's presidential campaign manager, stating: "Trust me, it will soon the

[sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same day,

STONE reiterated that because of the work of a "'mutual acquaintance' of both his and

[Assange], the public [could] expect to see much more from the exiled whistleblower in the form

of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Ruma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

31. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on a weekly basis fairly

soon. And that of course will answer the question of exactly what was erased on that email

server."

9
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 12 of 23

32. On Saturday, October 1, 2016, using@RogerJSTONEJr, STONE Tweeted,

"Wednesday@HillaryClinton is done. #WikiLeaks."

33. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement Julian Assange had scheduled for the next day from the

balcony of the Ecuadoran Embassy in London. On the day of the Assange announcement -

which was part ofWikiLeaks' 10-year anniversary celebration- STONE told Infowars that his

intermediary described this release as the "mother load." On Tuesday, October 4, 2016, STONE

used @RogerJSTONEJr to tweet: "Payload coming. #Lockthemup."

34. On Friday, October 7, 2016, at approximately 4:03 P.M., the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series oflewd remarks.

35. Approximately a half hour later, at 4:32 P.M., WikiLeaks send a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #imWithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

36. WikiLeaks continued to release John Podesta's hacked emails throughout October

10-21, 2016. On October 12, 2016, John Podesta-referring back to STONE's August 21, 2016

C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to - or at

least a reasonable conclusion - that [STONE] had advanced warning [of the release of his emails]

and the Trump campaign had advanced warning about what Assange was going to do. I think

there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the Miami Herald, STONE responded: "I have never met or spoken

with Assange, we have a mutual friend who's traveled to London several times, and everything I

know is through that channel of communications. I'm not implying I have any influence with

10
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 13 of 23

him or that I have advanced knowledge of the specifics of what he is going to do. I do believe he

has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides, thought were

deleted. I hear that through my emissary."

37. On March 27, 2017, CNN reported that a representative ofWikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

D. Roger STONE's Private Twitter Direct Messages with WikiLeaks and Julian
Assange.

38. On August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the

Twitter account @RogerJSTONEJr.

39. On October 13, 2016, while WikiLeaks was in the midst ofreleasing the hacked

Podesta emails, @RogerJSTONEJr sent a private direct message to the Twitter account

@wikileaks. This account is the official Twitter account ofWikiLeaks and has been described as

such by numerous news reports. The message read: "Since I was all over national TV, cable and

print defending WikiLeaks and assange against the claim that you are Russian agents and

debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

11
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40. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you/'

41. On October 16, 2016, @RogerJSTONEJr sent a direct message to @wikileaks:

"Ha! The more you \"correct\" me the more people think you're lying. Your operation leaks like

a sieve. You need to figure out who your friends are."

42. On November 9, 2016, one day after the presidential election, @wikileaks sent a

direct message to @RogerJSTONEJr containing a single word: "Happy?" @wikileaks

immediately followed up with another message less than a minute later: "We are now more free

to communicate."

43. In addition, @RogerJSTONEJr also exchanged direct messages with Julian

Assange, the founder ofWikiLeaks. For example, on June 4, 2017, @RogerJSTONEJr directly

messaged @JulianAssange, an address associated with Julian Assange in numerous public

reports, stating: "Still nonsense. As a journalist it doesn't matter where you get information only

that it is accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

12
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44. On Saturday, June 10, 2017, @RogerJSTONEJr sent a direct message to

@wikileaks, reading: "I am doing everything possible to address the issues at the highest level of

Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

E. Roger STONE's Emails with Jerome CORSI and about Assange


and WikiLeaks

45. On or about September 11, 2017, Chief Judge Beryl A. Howell of the District of

Columbia issued a search warrant for STONE's address On

or about October 17, 2017 Chief Judge Howell issued a warrant for STONE's address,

On or about December 12, 2017, Chief Judge Howell issued a warrant

for Gmail address, Emails recovered pursuant to that

search warrant indicated the following:

46. On or about May 23, 2016, emailed STONE with the subject,

"Trump Campaign," to offer his assistance to the Campaign. wrote that he was "on

to the notorious Oxford case already!" He also stated that he was "available, literally, as needed,

to contribute in ways the campaign sees fit. I'd like to go to Cleveland and pitch in, raise money

and work for you. Can you use me?" Cleveland, Ohio was the location of the 2016 Republican

National Convention, held July 18-21, 2016.

47. On or about June 4, 2016, STONE emailed telling him to "Plan on

going to Cleveland. Will need your help. Can handle credentials."

48. On or about June 20, 2016, emailed STONE and MANFORT, asking

to "know immediately how I can help" the Campaign. also wrote that his "research

on Rhodes House" was nearing completion. Rhodes House is the headquarters of the Rhodes

13
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 16 of 23

Trust, which provides scholarships to Oxford University, and the "Rhodes House" research

appears to be a reference to STONE' s previous tweet on or about October 13, 2015 that, "In

1969, Bill Clinton was expelled from Oxford for raping nineteen-year-old ."

STONE mentioned Wellstone again to a month later, as discussed below. The

"Rhodes House" research seems to be the same as the "notorious Oxford case" referenced by

above.

49. On or about July 7, 2016, emailed STONE that he had "my tickets to

Cleveland[.] [D]o you have my credential pack?"

50. On or about July 25, 2016, (approximately three days after WikiLeaks began

releasing emails hacked from the DNC), , a commentator who had publicly accused

the Clinton Foundation of fraud, emailed STONE with the subject line, "You need to get to

Assange." The body of the message read: "At Ecuadorian Embassy in London and get the

pending wikileaks emails ... they deal with Foundation, allegedly."

51. According to approximately ninety

minutes later STONE called CORSI and they spoke for 26 minutes.

52. Less than two hours after the phone call to CORSI, STONE emailed CORSI with

the subject line, "Get to Assange." The body of the message read: "Get to Assange [a]t

Ecuadorian Embassy in London and get pending WikiLeaks emails ... they deal with Foundation,

allegedly." It appears that STONE cut and pasted the email from Ortel to CORSI.

53. On or abou~ July 27, 2016, then-candidate Donald Trump stated in a press

conference, "Russia, if you are listening, I hope you're able to find the 30,000 [Hillary Clinton]

emails that are missing. I think you will probably be rewarded mightily by our press. Let's see if

that happens. That will be next."

14
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 17 of 23

54. On or about July 28, 2016, Roger STONE called Richard GATES (then the

deputy-chair of the Campaign). They spoke for approximately twelve minutes.

55. On or about July 30, 2016, Paul MANAFORT (then the Chairman of the

Campaign) called STONE. They spoke for approximately one hour and seven minutes. The

Government has analyzed toll records from January 1, 2016 to November 9, 2016. Sixty-seven

minutes is the longest call (by almost a half-hour) that took place between STONE and

MANAFORT in this time period.

56. On or about July 31, 2016, STONE emailed CORSI with the subject line, "Call

me MON." The body of the email read: " should see Assange[.] should find

Bernie sanders brother who called Bill a Rapist- turn him for Trump[.] should find

or more proof of Bill getting kicked out."

57. On or about August 2, 2016, CORSI emailed STONE: "With family, 25th

wedding anniversary Aug 9. Return Home Aug 12. Word is friend in embassy plans 2 more

dumps. One shortly after I'm back. 2nd in Oct. Impact planned to be very damaging ... Time to

let more than Podesta to be exposed as in bed w enemy if they are not ready to drop HRC. That

appears to be the game hackers are now about. Would not hurt to start suggesting HRC old,

memory bad, has stroke -- neither he nor she well. I expect that much of next dump focus, setting

stage for Foundation debacle." Based on my training, experience, and review of materials in this

case, it appears that CORSI's reference to a "friend in embassy [who] plans 2 more dumps"

refers to AS SANGE, the founder of WikiLeaks, who resided in Ecuador's London Embassy in

2016. On or about August 12, 2016, Guccifer publicly released information hacked from the

DCCC (the date CORSI identified as when he would "return home.").

15
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 18 of 23

58. On or about August 10, 2016, emailed CORSI an article titled,

"Assange Warns of 'Triangle of Terror'- Clinton, Pentagon & Google."

59. On or about August 13, 2016, emailed CORSI a news article titled,

"Assange Implies Murdered DNC Staffer Was WikiLeaks' Source."

60. On or about August 16, 2016, emailed CORSI an email with the

subject line, "Vladimir Putin Has Already Won Our Election." The body of email

contained two words: the word "VENONA" and the word "Observer." According to publicly

available information, the "Venona Project" was a top-secret U.S. intelligence effort to gather

and decrypt messages sent in the 1940s by Soviet military intelligence. On or about August 13,

2016, the Observer had published an article titled, "Vladimir Putin Has Already Won Our

Election" (the subject of the email). The subtitle of the article stated: "It's time to face facts:

Kremlin spies and hackers are undermining American politics." The article further discussed

how, "WikiLeaks, nowadays a transparent Kremlin front, disseminated some 20,000 purloined

DNC emails that were stolen by Russian intelligence." The article also stated that the "Kremlin is

weaponizing stolen information for political effect."

61. On or about August 30, 2016, emailed Steve Bannon, who had

become chief executive of the Campaign when MANAFORT left the Campaign on or about

August 19, 2016, with STONE and CORSI cc'd. wrote offering his assistance and

stating he had been "labouring non stop for the Trump campaign- even tho[u]gh I am all the

way over here in Oxford.... I have been in constant touch with the campaign, Roger Stone and

Jeri Corsi."

62. On or about October 7, 2016, WikiLeaks began releasing the Podesta emails.

16
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 19 of 23

63. On or about November 13, 2016, emailed STONE.

wrote, "Well, we did it and now have an opportunity of a lifetime to take the country back. God

is good and we are well placed to steer things well. You deserve a lot of credit and working with

you and Jeri Corsi, who is with me now in London has been a great joy."

64. On or about January 7, 2017, an individual named emailed

STONE, CORSI, and with the subject line, "in case you need his mail. ........ "

Attached to the message was a scan of a business card for John Podesta. Several hours later,

replied: "Ha ... maybe he wants to go phishing with us?"

65. I know from my training and experience that the term "phishing" is used to refer

to the practice of sending emails purporting to be from a reputable party in order to trick

individuals to reveal to the sender personal information, including passwords. Public reports

indicate that Podesta's emails were obtaining through a "phishing" scheme.

F. U.K.-Based Email Account

66. In addition to his Gmail account, also uses a U.K.-based email

address, Investigators found emails with this address in

Gmail account. The U.K. email address was also listed in messages sent as a means

of reaching him. A publicly-available database lists the U.K. email address as belonging to

The U.K. email address is housed outside the United States, and investigators

anticipate it may take substantial time to retrieve the messages on the account via a potential

treaty request. In addition, it is possible that emails may have been deleted or no longer

maintained. I know from my training and experienced that users often download and store emails

on their phones, tablets, and laptops, such as the Target Devices. Even if information has been

deleted by the user, the Government may be able to employ forensic tools to recover information

17
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 20 of 23

from his devices. In addition, as described further below, the Target Devices may include a

variety of other stored communications, including voicemail, text message, and other third party

messaging systems which may have used to communicate with CORSI, STONE,

and others regarding WikiLeaks.

THE PERSON AND BAGGAGE TO BE SEARCHED CONTAIN EVIDENCE, FRUITS,


AND INSTRUMENTALITIES

67. I also have probable cause to believe that the person and baggage to be searched

contains fruits, evidence, and instrumentalities of violations of the federal statutes listed above,

as described in the warrants' respective Attachments A and B.

68. Records indicate that has purchased a ticket on

I know from my training and experience that individuals often carry electronic devices and

storage media of the type described in Attachment B with them when they travel both on their

persons and in their baggage. These devices and media include but are not limited to cellular

phones, tablets, laptops, thumb drives, CDs, DVDs, and external hard drives.

69. From my training and experience, I am also aware that personal computer systems

are generally capable of creating, receiving, and otherwise processing computer files such as e-

mail, word-processing documents, photographs, and spreadsheets. As evidenced by the emails

above, uses computer systems to communicate with CORSI and STONE regarding

WikiLeaks.

70. Based on my training, experience, and information provided by other law

enforcement officers, I know that many smartphones (which are included in Attachment B) can

now function essentially as small computers. Smartphones have capabilities that include serving

18
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 21 of 23

as a wireless telephone, digital camera, portable media player, GPS navigation device, sending

and receiving text messages and e-mails, and storing a vast range and amount of electronic data.

Examining data stored on devices of this type can uncover, among other things, evidence that

reveals or suggests who possessed or used the device.

71. Based on my knowledge, training, experience, and information provided to me by

other agents, I know that computer files or remnants of such files can be recovered months or

years after they have been written, downloaded, saved, deleted, or viewed locally or over the

Internet. This is true because:

• Electronic files that have been downloaded to a storage medium can be stored for

years at little or no cost. Furthermore, when users replace their computers, they

can easily transfer the data from their old computer to their new computer.

• Even after files have been deleted, they can be recovered months or years later

using forensic tools. This is so because when a person "deletes" a file on a

computer, the data contained in the file does not actually disappear; rather, that

data remains on the storage medium until it is overwritten by new data, which

might not occur for long periods of time. In addition, a computer's operating

system may also keep a record of deleted data in a "swap" or "recovery" file.

• Wholly apart from user-generated files, computer storage media, in particular,

computers' internal hard drives, contain electronic evidence of how the computer

has been used, what it has been used for, and who has used it. This evidence can

take the form of operating system configurations, artifacts from operating system

or application operation, file system data structures, and virtual memory "swap"
19
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 22 of 23

or paging files. It is technically possible to delete this information, but computer

users typically do not erase or delete this evidence because special software is

typically required for that task.

• Similarly, files that have been viewed over the Internet are sometimes

automatically downloaded into a temporary Internet directory or "cache." The

browser often maintains a fixed amount of hard drive space devoted to these files,

and the files are overwritten only as they are replaced with more recently viewed

Internet pages or if a user takes steps to delete them.

CONCLUSION

72. Based on the forgoing, there is probable cause to believe that one or more people

have violated the statutes specified above and that electronic devices and media containing

evidence, fruits, and instrumentalities of those crimes, are contained on the person of

(described further in that warrant's Attachment A) and his baggage (described

further in that warrant's Attachment A), and for the seizure of the electronic devices and media

described in further in Attachment B.

REQUEST FOR AUTHORIZATION TO EXECUTE THEWARRANTS BEFORE


6 AM OR AFTER 10 PM

73. In addition, I request that the search warrants authorize searches and seizures

before 6 AM and after 10 PM. Although flight is scheduled to land at

I am aware that flight departure and arrival times can vary widely from those announced

because of adverse weather or other delays throughout the airline transportation system. If

because of a flight delay flight landed at 10:01 PM, a warrant without the

20
Case 1:19-mc-00029-CRC Document 29-8 Filed 04/28/20 Page 23 of 23

requested authorization could not be executed for another 8 hours, requiring me to either obtain a

new warrant or to detain and his baggage until 6 AM the next morning. The

requested authorization will allow the searches and seizures to progress as efficiently as possible,

with minimal delay to and any other person with whom he is travelling.

REQUEST FOR SEALING

74. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Sworn to under the pains and penalties of perjury,

Curtis Heide
Special Agent
Federal Bureau of Investigation

21
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 1 of 58

AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of


(Briefly describe the property lo be searched
Case: 1 :18-sc-02401
or identij)' the person by name and address) Assigned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH Assign. Date: 7/12/2018
Description: Search & Seizure Warrant

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or prope1iy located in the Northern District of ·- California
--------~
(identify the person or describe the property to be searched and give its location):

See Attachment C.

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identijj1 the person or describe the property to be seized):

See Attachment D.

YOU ARE COMMANDED to execute this warrant on or before July 26, 2018 ___ (,10110 exceed 14 days)
oif in the daytime 6:00 a.m. to I 0:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
propeiiy was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to ..... Hon. Beryl A. Howell
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 ( except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriale box)
0 for days (,101 to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued: 1j'l 2;/A?/i'ef f':{J-//J ~-~ 'Judge's signature

City and state: _W_a_sh_i_n~g_to_n_,_D_C_ _ _ _ _ _ __ Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title

/
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 2 of 58

AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
E.x:ecuting officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 3 of 58

ATTACHMENT C

Property to be Searched

This warrant applies to infonnation associated with the following Apple account:

1.

that is stored at premises owned, maintained, controlled, or operated by Apple, Inc., located at

One Apple Park Way, Cupertino, California 95014.

37
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 4 of 58

ATACHMENTD

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of Apple, regardless of whether such infmmation is located within or outside
of the United States, including any messages, records, files, logs, or information that have been
deleted but are still available to Apple, or have been preserved pursuant to a request made under
18 U.S.C. § 2703(f), Apple is required to disclose the following information to the government,
in unencrypted form whenever available, for each account or identifier listed in Attachment A:

a. All records or other information regarding the identification of the account, to


include full name, physical address, telephone numbers, email addresses (including primary,
alternate, rescue, and notification email addresses, and verification info1mation for each email
address), the date on which the account was created, the length of service, the IP address used to
register the account, account status, associated devices, methods of connecting, and means and
source of payment (including any credit or bank account numbers);

b. All records or other information regarding the devices associated with, or used in
connection with, the account (including all current and past trusted or authorized iOS devices
and computers, and any devices used to access Apple services), including serial numbers, Unique
Device Identifiers ("UDID"), Advertising Identifiers ("IDFA"), Global Unique Identifiers
("GUID"), Media Access Control ("MAC") addresses, Integrated Circuit Card ID numbers
("ICCID"), Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),
Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber
Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Numbers
("MSISDN"), International Mobile Subscriber Identities ("IMSI"), and International Mobile
Station Equipment Identities ("IMEI");

c. The contents of all emails associated with the account, including stored or
preserved copies of emails sent to and from the account (including all draft emails and deleted
emails), the source and destination addresses associated with each email, the date and time at
which each email was sent, the size and length of each email, and the true and accurate header
information including the actual IP addresses of the sender and the recipient of the emails, and
all attachments;

d. The contents of all instant messages associated with the account, including stored
or preserved copies of instant messages (including iMessages, SMS messages, and MMS
messages) sent to and from the account (including all draft and deleted messages), the source and
destination account or phone number associated with each instant message, the date and time at
which each instant message was sent, the size and length of each instant message, the actual IP
addresses of the sender and the recipient of each instant message, and the media, if any, attached
to each instant message;

38
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 5 of 58

e. The contents of all files and other records stored on iCloud, including all iOS
device backups, all Apple and third-party app data, all files and other records related to iCloud
Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWork
(including Pages, Numbers, Keynote, and Notes), iCloud Tabs and bookmarks, and iCloud
Keychain, and all address books, contact and buddy lists, notes, reminders, calendar entries,
images, videos, voicemails, device settings, and bookmarks;

f. All activity, connection, and transactional logs for the account (with associated IP
addresses including source port numbers), including FaceTime call invitation logs, messaging
and query logs (including iMessage, SMS, and MMS messages), mail logs, iCloud logs, iTunes
Store and App Store logs (including purchases, downloads, and updates of Apple and third-party
apps), My Apple ID and iForgot logs, sign-on logs for all Apple services, Game Center logs,
Find My iPhone and Find My Friends logs, logs associated with web-based access of Apple
services (including all associated identifiers), and logs associated with iOS device purchase,
activation, and upgrades;

g. All records and information regarding locations where the account or devices
associated with the account were accessed, including all data stored in connection with Location
Services, Find My iPhone, Find My Friends, and Apple Maps;

h. All records pertaining to the types of service used;

i. All records pertaining to communications between Apple and any person


regarding the account, including contacts with support services and records of actions taken; and

j. All files, keys, or other information necessary to decrypt any data produced in an
encrypted form, when available to Apple (including, but not limited to, the keybag.txt and
fileinfolist.txt files).

39
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 6 of 58

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A
which consists of evidence, fiuits, or instrumentalities of violations of 18 U.S.C. § 1030 (fraud
and related activities in connection with computers and 18 U.S.C. § 371 (conspiracy to commit
an offense against the United States) for the period from June 15, 2016 to November 10, 2016.
including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications
with persons or entities associated with WikiLeaks, including but not limited to
Julian Assange, or communications regarding disinformation, denial, dissembling
or other obfuscation about knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone, Julian
Assange, or any individual associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, and


contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created,


used, or communicated with the account or identifier, including records about
their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption


or other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be
necessary to access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

1. All existing printouts from original storage which concern the categories
identified in subsection II.A; and

J. All "address books" or other lists of contacts.

40
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 7 of 58
FILED
JUL 12 2018
IN THE UNITED STATES DISTRICT COURT Clerk, us Dis .
Courts ta'r ihe 0\~ct t & Bankruptcy
FOR THE DISTRICT OF COLUMBIA net ot Columbia

IN THE MATTER OF THE SEARCH OF Case: 1:18-sc-02401


INFORMATION ASSOCIATED WITH Assigned To : Howell, Beryl A.
Assign. Date: 7/12/2018
Description: Search & Seizure Warrant

ORDER

The United States has filed a motion to seal the above-captioned warrant and related

documents, including the application and affidavit in support thereof (collectively the "Warrant"),

and to require Apple, Inc. ("Apple") an electronic communication and/or remote computing

service headquartered at a company headquartered at I Infinite Loop, Cupertino, CA not to

disclose the existence or contents of the Warrant pursuant to 18 U.S.C. § 2705(b).

The Court finds that the United States has established that a compelling governmental

interest exists to justify the requested sealing, and that there is reason to believe that notification

of the existence of the Warrant will seriously jeopardize the investigation, including by giving the

targets an opp01tunity to flee from prosecution, destroy or tamper with evidence, and intimidate

witnesses. See 18 U.S.C. § 2705(b)(2)-(5).

IT IS THEREFORE ORDERED that the motion is hereby GRANTED, and that the

warrant, the application and affidavit in support thereof, all attachments thereto and other related

materials, the instant motion to seal, and this Order be SEALED until further order of the Court;

and
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 8 of 58

IT IS FURTHER ORDERED that, pursuant to 18 U.S.C. § 2705(b), Apple and its

employees shall not disclose the existence or content of the Warrant to any other person (except

attorneys for Apple for the purpose of receiving legal advice) for a period of one year or until

further order of the Comi.

THE HONORABLE BERYL A. HOWELL


CHIEF UNITED STATES DISTRICT JUDGE

2
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 9 of 58
AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT


FltED
JUL f 2 2018
for the
Clerk, U.S. District & Barikruptc
District of Columbia Courts for the District of Columbia

In the Matter of the Search of Case: 1:18-sc-02401


(Briefly describe the property to be searched
or identijj, the person by name and address)
l
)
Assigned To : Howell, Beryl A
Assign. Date: 7/12/2018
INFORMATION ASSOCIATED WITH )
Description: Search & Seizure Warrant
l
APPLICATION FOR A SEARCH WARRANT
I, a federal Jaw enforcement officer or an attorney for the government, request a search wan-ant and state under
penalty of perjury that I have reason. to believe that on the following person or properly (identify the person or describe the
property to be searched and give its location):

See Attachment C.
Northern , there is now concealed (identify the
located in the ===--- District of ---------'===~--
California
person or describe the property Lo be seized):
See Attachment D.
This warrant is sought pursuant to 18 U.S.C. §§ 2703(a), 2703(b)(1){A), and 2703(c)(1)(A).

The basis for the search under Fed. R. Crim. P. 41 (c) is (check one or more):
ref evidence of a crime;
ref contraband, fruits of crime, or other items illegally possessed;
ref property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
18 U.S.C. § 371 Conspiracy
18 U.S.C. § 1030 Unauthorized Access of a Protected Computer

The application is based on these facts:

See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of days (give exact ending date if more than 30 days: ___ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth o n ~

Reviewed by AUSA/SAUSA: Applicant's signature

haron Zelinsky(ASC) Andrew Mitchell, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date: 7/12/2018 ~/~~ Judge's signature

City and state: Washingto'n, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 10 of 58

FILED
IN THE UNITED STATES DISTRICT COURT JUL 12 2018
FOR THE DISTRICT OF COLUMBIA Clerk, U.S. District & Bankruptcy
Courts tor the District of Columbia
IN THE MATTER OF THE SEARCH OF
INFORMATION ASSOCIATED WITH Case No. J 'i- SC - c.. '-Id(

Filed Under Seal

AMENDED AFFIDAVIT IN SUPPORT OF


AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the following:

a. The email account maintained by CSC Holdings ("Target

Account 1 "), described further in Attachment A.

b. The Apple Account (including email) associated with , maintained

by Apple, Inc. (Target Account 2), described further in Attachment C.

c. The email accoun maintained by Windstream Communications

('Target Account 3"), described further in Attachment E.

The information to be disclosed by CSC Holdings, Apple, Inc., and Windstream

Communications ("the Providers") and searched by the government is described in the following

paragraphs and in Attachments A-F. This affidavit is made in support of an application for a

search warrant under 18 U.S.C. §§ 2703(a), 2703(b)(l)(A), and 2703(c)(l)(A).

2. I, Andrew Mitchell, am a Special Agent with the Federal Bureau oflnvestigation

(FBI), and have been since 2011. As a Special Agent of the FBI, I have received training and

experience in investigating criminal and national security matters.


Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 11 of 58

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my knowledge about this matter.

4. .Before the submission of this warrant application, the Special Counsel's Office

complied with all relevant Department of Justice policies, including the requirement for

Departmental approval under the Department's policy regarding obtaining information from

members of the news media, 28 C.F.R. 50.10.

5. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Accounts contain communications relevant to

violations of 18 U.S.C. § 371 (conspiracy) and 18 U.S.C. § 1030 (unauthorized access of a

protected computer).

JURISDICTION

6. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), & (c)(l)(A).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below,

including in paragraph 19.

SUMMARY

7. On or about July 25, 2016, Roger STONE emailed Jerome CORSI to "Get to

Assange" at the Ecuadorian Embassy and "get pending WikiLeaks emails[.]" On or about July

31, 2016, STONE.also instructed CORSI to have contact Julian

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ASSANGE. On or about August2, 2016, CORSI responded to STONE that the "word is friend !

in embassy [ASSANGE] plans 2 more dumps. One shortly after I'm back. 2nd in October.

Impact planned to be very damaging .... Time to let more than Podesta to be exposed as in bed w

enemy if they are not ready to drop HRC." After receipt of that message, on or about August 21,

2016, using @RogerJStoneJR, Stone tweeted: "Trust me, it will soon the [sic] Podesta's time in

the barrel. #CrookedHillary."

8. Information disclosures subsequently occurred on or about the times CORSI

predicted: On or about August 12, 2016, the day CORSI was scheduled to return to the United

States ("shortly after I'm back"), Guccifer 2.0 released hacked information related to the

Democratic Congressional Campaign Committee (DCCC). On or about October 7, 2016, the day

the Washington Post published a breaking story about an Access Hollywood videotape ofthen-

candidate Trump making disparaging remarks about women, WikiLeaks released emails hacked

from the account of John Podesta.

9. Furthermore, on the day of the Access Hollywood video disclosure, there were

phone calls between STONE and CORSI after the Washington Post contacted STONE prior to

publication. At approximately 11 :OOAM, the Washington Post received a tip regarding the

Access Hollywood video. Approximately one hour later, shortly before noon, STONE received

a call from the Washington Post. Approximately ninety minutes later, before 2:00 PM, STONE

called CORSI and they spoke. Approximately forty minutes later, CORSI called STONE and the

two spoke again at length. At approximately 4:00PM, the Washington Post published its story

regarding the Access Hollywood tape. By approximately 4:30PM, WikiLeaks tweeted out its

first release of emails hacked from John Podesta.

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PROBABLE CAUSE.

A. Background on Relevant Individuals

i. Roger STONE

11. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of Trump's presidential campaign. As

described further below, STONE also maintained contact with individuals employed by the

Campaign, including then-campaign chairman Paul MANAFORT and deputy chairman Rick

GATES.

ii. Jerome CORSI

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12. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staffreporter"

for the website "World Net Daily" a/k/a "WND.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of20I6 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

B. U.S. Intelligence Community (USIC) Assessment of Russian Government-Backed


Hacking Activity during the 2016 Presidential Election

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14. On October 7, 2016, the U.S. Department of Homeland Security and the Office of

the Director of National Intelligence released a joint statement of an intelligence assessment of

Russian activities and intentions during the 2016 presidential election. In the report, the USIC

assessed the following, with emphasis added:

15. The U.S. Intelligence Community (USIC) is confident that the Russian

Government directed the recent compromises of emails from US persons and institutions,

including from US political organizations. The recent disclosures of alleged hacked emails on

sites like DCLeaks.com and WikiLeaks and by the Guccifer 2.0 online persona are consistent

with the methods and motivations of Russian-directed efforts. These thefts and disclosures are

intended to interfere with the US election process. Such activity is not new to Moscow-the

Russians have used similar tactics and techniques across Europe and Eurasia, for example, to

influence public opinion there. We believe, based on the scope and sensitivity of these efforts,

that only Russia's senior-most officials could have authorized these activities.

16. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

17. "Russian President Vladimir Putin ordered an influence campaign in 2016 aimed

at the US presidential election. Russia's goals were to undermine public faith in the US

democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her

electability and potential presidency. We further assess Putin and the Russian Government

developed a clear preference for President-elect Trump."

18. The USIC also described, at a high level, some of the techniques that the Russian

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government employed during its interference. The USIC summarized the efforts as a "Russian

messaging strategy that blends covert intelligence operations-such as cyber activity-with

overt efforts by Russian Government agencies, state-funded media, third-party intermediaries,

and paid social media users or 'trolls.'"

19. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities to

the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted in

the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC." The GRU is the

foreign military intelligence agency of the Russian Ministry of Defense, and is Russia's largest

foreign intelligence agency.

20. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US .victim data obtained in cyber operations publicly and in exclusives to media outlets."

21. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

C. Additional Hacking Activity by Individuals Associated with the GRU

22. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 campaign through at least

November 1, 2016.

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23. For example, in or around September 2016, these individuals successfully gained ·

. access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

24. On or about September 4, 2016, individuals associated with the GRU stole the

· emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

25. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

D. Roger Stone's Public Interactions with Guccifer 2.0 and WikiLeaks

26. On June 14, 2016, Crowdstrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

27. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.

28. On August 5, 2016, Roger Stone published an article on Breitbart.com entitled,

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"Dear Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't

seem to be the Russians that hacked the DNC, but instead a hacker who goes by the name of

Guccifer 2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in

the article and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains

who he is and why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a

fateful and wise decision. He went to WikiLeaks with the DNC files and the rest is history. Now

the world would see for themselves how the Democrats had rigged the game."

29. On August 8, 2016, Stone addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

Assange to Russia Today (RT) several days earlier about an upcoming "October Surprise" aimed

at the Hillary Clinton presidential campaign. Specifically, Stone was asked: "With regard to the

October surprise, what would be your forecast on that given what Julian Assange has intimated

he's going to do?" Stone responded: "Well, it could be any number of things. I actually have

communicated with Assange. I believe the next tranche of his documents pertain to the Clinton

Foundation but there's no telling what the October surprise may be." A few days later, Stone

clarified that while he was not personally in touch with Assange, he had a close friend who

served as an intermediary.

30. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the Democratic Congressional Campaign

Committee (DCCC).

31. On August 13, 2016, Stone posted a tweet using@RogerJStoneJr calling Guccifer

2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day, Guccifer 2.0's

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Twitter account was reinstated.

32. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me ifl can help u anyhow. it would be a great pleasure to me."

33. On August 18, 2016, Paul Manafort, Stone's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that Manafort had worked with a Washington D.C.-based lobbying firms to influence U.S. policy

toward Ukraine.

34. On August 21, 2016, using @RogerJStoneJR, Stone tweeted stating: "Trust me, it

will soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that

same day, Stone reiterated that because of the work of a '"mutual acquaintance' of both his and

[Assange], the public [could] expect to see much more from the exiled whistleblower in the form

of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Ruma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

35. On September 16, 2016 Stone said in a radio interview with Boston Herald Radio

that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly basis

fair!y soon. And that of course will answer the question as to what exactly what was erased on

that email server."

36. On Saturday, October 1, 2016, using@RogerJStoneJr, Stone Tweeted,

"Wednesday @ HillaryClinton is done. #WikiLeaks."

37. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

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tweeted regarding an announcement Julian Assange had scheduled for the next day from the

balcony of the Ecuadoran Embassy in London. On the day of the Assange announcement -

which was part of WikiLeaks' I 0-year anniversary celebration - Stone told Infowars that his

intermediary described this release as the "mother load." On October 5, 2016, Stone used

@RogerJStoneJr to tweet: "Payload coming. #Lockthemup."

38. On Friday, October 7, 2016, at approximately 4:03 P.M., the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series oflewd remarks.

39. Approximately a half hour later, at 4:32 P.M., WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryC!inton #Podesta #imWithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

40. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, John Podesta- referring back to Stone's August

21, 2016 C-SPAN and Twitter references-argued publicly that "[it is] a reasonable assumption

to - or at least a reasonable conclusion - that [StoneJ had advanced warning [of the release of his

emailsJ and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [AssangeJ may have passed this information on to

[Stone]." Connnenting to the NBC News, Stone responded: "I have never met or spoken with

Assange, we have a mutual friend who's traveled to London several times, and everything I

know is through that channel of communications. I'm not implying I have any influence with

him or that I have advanced knowledge of the specifics of what he is going to do. I do believe he

has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides, thought were

deleted. I hear that through my emissary."

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41. On March 27, 2017; CNN reported that a representative ofWikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between Stone and WikiLeaks. The same article quoted

Stone as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

E. Roger Stone's Private Twitter Direct Messages with WikiLeaks and Julian Assange.

42. On August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the

Twitter account@RogerJStoneJr.

43. On October 13, 2016, while WikiLeaks was in the midst of releasing the hacked

Podesta emails, @RogerJStoneJr sent a private direct message to the Twitter account

@wikileaks. This account is the official Twitter account of WikiLeaks and has been described as

such by numerous news reports. The message read: "Since I was all over national TV, cable and

print defending WikiLeaks and assange against the claim that you are Russian agents and

debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

44. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

45. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

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46. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

47. In addition, @RogerJStoneJr also exchanged direct messages with Julian

Assange, the founder ofWikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly

messaged @JulianAssange, an address associated with Julian Assange in numerous public

reports, stating: "Still nonsense. As a journalist it doesn't matter where you get information only

that it is accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

48. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@wikileaks, reading: "I am doing everything possible to address the issues at the highest level of

Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

F. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks.

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49. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia
I
issued a search warrant for STONE's address, On October
II
17, 2017, Chief Judge Beryl A. Howell issued a search warrant for STONE's address,

On or about December 19, 2017 Chief Judge Beryl A. Howell issued a

search warrant for mail account. On or about March 14, 2018, Chief Judge Beryl

A. Howell issued a search warrant for STONE's iCloud account. Information recovered pursuant

to those search warrants indicated the following:

50. On or about May 15, 2016, emailed CORSI at Target Account 3:

"Here is my flight schedule. Need to get something confirmed now .... " CORSI responded, "I

copied Roger Stone so he knows your availability to meet Manafort and DT this coming week."

CORSI appears to have forwarded the message to STONE, who replied to CORSI that, "May

meet Manafort -guarantee nothing."

51. On or about May 16, 2016, emailed CORSI on Target Account 3:

"Outside of Wednesday 2-4 ... I am open. Do you have times for meeting on other things?

Flexible re DJT. How about the head of finance for them?" CORSI responded, "I will work on

other meetings today." replied, "Do you [want] me to bring you anything from the

Old Country? I have a meeting now from 2-6 on Wednesday. Open all other times!!!"

52. On or about May 18, 2016, CORSI, using Target Account 3, emailed STONE

with the Title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

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53. On July 25, 2016, STONE sent an erriail to CORSI at Target Account 1 with the

subject line, "Get to Assange." The body of the message read: "Get to Assange [a]t Ecuadorian

Embassy in London and get the pending WikiLeaks emails ... they deal with Foundation,

allegedly."

54. On or about July 31, 2016, STONE emailed CORSI at Target Account 1 with the

subject line, "Call me MON." The body of the email read: " should see Assange[.]

should find Bernie [S]anders brother who called Bill a Rapist - turn him for Trump[.]

should find or more proof of Bill getting kicked out."

55. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE using Target Account 1,

"Word is friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct. Impact

planned to be very damaging. Signs are Fox will have me on mid-Aug. more post Ailes shakeup

underway. Expect Shine to surface victor, for now. Post-DNC bump for HRC an artifact of

rigged polling. Won't last. I expect presidential campaign to get serious starting Sept. Still in pre-

season games. Time to let more than Podesta to be exposed as in bed w enemy if they are not

ready to drop HRC. That appears to be the game hackers are now about. Would not hurt to start

suggesting HRC old, memory bad, has stroke -- neither he nor she well. I expect that much of

next dump focus, setting stage for Foundation debacle." Investigators believe that CORSI's

reference to a "friend in embassy [who] plans 2 more dumps" refers to Julian AS SANGE, the

founder of WikiLeaks, who resided in Ecuador's London Embassy in 2016.

56. On or about August 5, 2016, an associate ofSTONE's, emailed

him a link to a poll indicating that Clinton led Trump by 15 points. STONE responded "enjoy it

while u can[.] I dined with my new pal Julian Assange last night." subsequently

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stated to investigators that, around the same time; STONE told him he had gone to London to

meet ASSANGE. also stated that in 2018, told STONE.he would be

interviewed by the FBI and would have to divulge the conversation about meeting ASSANGE.

STONE told he was joking and had not actually met Assange.

57. On or about August 15, 2016, CORSI messaged STONE using Target Account

3: "Give me a call today if you can. Despite MSM drumroll that HRC is already elected, it's not

over yet. More to come than anyone realizes. Won't really get started until after Labor Day. I'm

in NYC this week. Jerry."

58. On or about August 31, 2016, CORSI using Target Account 1 emailed STONE:

"Did you get the PODESTA writeup." STONE replied "yes."

59. On or about August 31, 2016, CORSI, using Target Account 2, messaged

STONE, "Podesta paid $180k to invest in Uranium One - was hired by Rosatom in Giustra

scandal. Podesta now under FBI investigation - tied to Ukraine Yanukovych - Panama papers

reveals Podesta hired by S[b]erbauk, Russia's largest financial institution-Podesta$$$ ties to

Russia undermine Clinton false narrative attempting to tie Trump to Putin."

60. On or about September 6, 2016, CORSI emailed STONE using Target Account

3: "Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

61. On or about September 24, 2016, emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded using Target

Account 3, "We have secure back channel through Roger. I saw him again in NYC last Friday

and spoke to him about it again today." wrote back, "Awaiting secret file.

Explosive ... Hope you are well. Can't wait for the debate. Channeling Reagan, I hope!" CORSI

responded, "Keep me posted about file[.]" In a subsequent meeting with investigators,

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indicated this conversation concerned possible derogatory information he was trying ·

to obtain from Turkey.

62. On or about October 3, 2016, an associate of STONE emailed STONE and asked:

"Assange-what's he got? Hope it's good." Stone wrote back, "It is. I'd tell Bannon but he

doesn't call me back. My book on the TRUMP campaign will be out in Jan. Many scores will be

settled." The associate forwarded the email to Steve BANNON and wrote: "You should call

Roger. See below. You didn't get from me." BANNON wrote back, "I've got important stuff to

worry about." The associate responded, "Well clearly he knows what Assange has. I'd say that's

important."

63. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

AS SANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, AS SANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

64. On or about October 4, 2016, CORSI messaged STONE using Target Account 2,

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

65. That same day, BANNON emailed STONE, "What was that this morning???"

STONE replied, "Fear. Serious security concern. He thinks they are going to kill him and the

London police are standing done [sic]." BANNON wrote back, "He didn't cut deal w/

clintons???" Stone replied, "Don't think so BUT his lawyer is a big democrat."

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66. When BANNON spoke with investigators during a voluntary proffer on February

14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE was about

WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking STONE

about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

G. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails·
Are Released.

67. According to a publicly available news article, 1 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same article,

"Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage from a

2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone, calling

Trump's campaign, 'Access Hollywood' and NBC for reaction."

68. According to phone records , at approximately

11 :27 AM, CORSI placed a call to STONE which STONE did not answer.

69. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

70. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

71. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

1 https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-then-the-race-was-

on/2016/10/07/3 ld74714-8ce5-l le6-875e-2c 1bfe943b66_story.html


Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 28 of 58

72. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

73. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, when CORSI emailed STONE on Target Account 1, he wrote "I

expect that much of next dump focus, setting stage for Foundation debacle."

74. At approximately 6:27PM, sent STONE an email titled,

"WikiLeaks - The Podesta Emails" with a link to the newly-released Podesta emails.

Approximately ten minutes later, STONE forwarded message to CORSI at Target

Account 1 without comment. STONE does not appear to have forwarded the email to any other

individual.

H. STONE Requests to CORSI for "SOMETHING" to Post About Podesta After


STONE Is Accused of Advance Knowledge of the Leak

75. On or about October 8, 2016, STONE messaged CORSI at Target Account 2,

"Lunch postponed- have to go see T." CORSI responded to STONE, "Ok. I understand."

Approximately twenty minutes later, CORSI texted, "Clintons know they will lose a week of

Paula Jones media with T attacking Foundation, using Wikileaks Goldman Sachs speech

comments, attacking bad job numbers."

76. On or about Wednesday, October 12, 2016, at approximately 8:17 EDT, STONE

emailed CORSI at Target Account 1, asking him to "send me your best podesta links." STONE

emailed CORSI at approximately 8:$$ EDT, "need your BEST podesta pieces." CORSI wrote

back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on Podesta is

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complicated. Two articles in length. I can give you in raw form ihe stuff I got in Russiau

trauslated but to write it up so it's easy to understand will take weekend. Your choice?"

77. On or about that same day October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI,

using Target Account 1, emailed STONE with a subject line "Podesta talking points." Attached

to the email was a file labeled, "ROGER STONE podesta talking points Oct 12 2016.docx." The

"talking points" included the statement that "Podesta is at the heart of a Russian-govermnent

money laundering operation that benefits financially Podesta personally aud the Clintons through

the Clinton Foundation."

78. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Hotmail Account, "Got them aud used them."

79. On or about Thursday, October 13, 2016, CORSI, using Target Account 3,

emailed STONE: "PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI wrote

back to STONE, "I'll give you one more -NOBODY YET HAS THIS[:] It looks to me like

skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russiaus launched a criminal investigation[.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

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Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

80. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email with the Subject, "ROGER STONE article RUSSIAN MAFIA STYLE

MONEY-LAUNDERING, the CLINTON FOUNDATION, and JOHN PODESTA." The text

stated: "Roger[,] You are free to publish this under your own name." That same day, STONE

posted a blog post with the title, "Russian Mafia money laundering, the Clinton Foundation and

John Podesta." In that post, STONE wrote, "although I have had some back-channel

communications with Wikileaks I had no advance notice about the hacking of Mr. Podesta nor I

have I ever received documents or data from Wikileaks." The post then asked, "Just how much

money did , a controversial Russian billionaire investor with ties to the

Vladimir Putin and the Russian government, launder through Metcombank, a Russian regional

bank owned 99 .978 percent by with the money transferred via Deutsche Bank and

Trust Company Americas in New York City, with the money ending up in a private bank

account in the Bank of America that is operated by the Clinton Foundation?"

81. On or about October 14, 2016, CORSI sent a message using Target Account 2 to

STONE, "i'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

82. On or about October 17, 2016, CORSI messaged STONE using Target Account

2, "On Assange, can you call me now - before 2pm[.]" STONE responded, "Missed u - just

landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

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I
I
I
83. On or about October 17, 2016, CORSI, using Target Account 1, emailed STONE I
with the subject, "Fwd: ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted source,"
!
and forwarded an email with the header information stripped out, showing only the body text.

The email read, "Yes[.] I figured this. Assange is threatening Kerry, Ecuador and U.K. He will

drop the goods on them if they move to extradite him. My guess is that he has a set of dead man

files that include Hillary. It's what they used to call a 'Mexican stand off[.]' Only hope is that if

Trump speaks out to save him[.] Otherwise he's dead anyway, once he's dropped what he has. If

HRC wins, Assange can kiss his life away. Interesting gambit Assange has to play out. He's

called Podesta' s bluff and raised him the election."

84. On or about October 18, 2016, CORSI messaged STONE using Target Account

2, "Pis call. Important."

85. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice ofWikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta' s business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

86. On or about November 8, 2016, the United States presidential election took place.

87. On or about November 9, 2016, CORSI, using Target Account 2, messaged

STONE, "Congratulations, Roger. He could not have done it without you."

88. On or about November 10, 2016, CORSI messaged STONE using Target

Account 2, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm

in London. Have some interesting news for you."

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· BACKGROUND CONCERNING EMAIL

96. In my training and experience, I have learned the Providers provide a variety of

on-line services, including electronic mail ("email") to the public. The Providers allow

subscribers to obtain email accounts at the domain names identified in the email address

contained in Attachment A and C. Subscribers obtain an account by registering with the

Providers. During the registration process, the Providers ask subscribers to provide basic

personal information. Therefore, the computers of the Providers are likely to contain stored

electronic communications (including retrieved and unretrieved email) for their subscribers and

information concerning subscribers and their use of services, such as account access information,

email transaction information, and account application information. In my training and

experience, such information may constitute evidence of the crimes under investigation because

the information can be used to identify the account's user or users.

97. Inmy training and experience, email Providers generally ask their subscribers to

provide certain personal identifying information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and

other identifiers, alternative email addresses, and, for paying subscribers, means and source of

payment (including any credit or bank account number). In my training and experience, such

information may constitute evidence of the crimes under investigation because the information

can be used to identify the account's user or users. Based on my training and my experience, I

know that, even if subscribers insert false information to conceal their identity, this information

often provides clues to their identity, location, or illicit activities.

98. In my training and experience, email Providers typically retain certain

transactional information about the creation and use of each account on their systems. This

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information can include the date on which the account was created, the length of service, records

oflog-in (i.e., session) times and durations, the types of service utilized, the status of the account

(including whether the account is inactive or closed), the methods used to connect to the account

(such as logging into the account via the Providers' website), and other log files that reflect

usage of the account. In addition, email Providers often have records of the Internet Protocol

address ("IP address") used to register the account and the IP addresses associated with particular

logins to the account. Because every device that connects to the Internet must use an IP address,

IP address information can help to identify which computers or other devices were used to access

the email account.

99. In my training and experience, in some cases, email account users will

communicate directly with an email service Providers about issues relating to the account, such

as technical problems, billing inquiries, or complaints from other users. Email Providers

typically retain records about such communications, including records of contacts between the

user and the Providers' support services, as well as records of any actions taken by the Providers

or user as a result. of the communications. In my training and experience, such information may

constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users.

100. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of

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occupancy" while executing a search warrant at a residence. For example, email

communications, contacts lists, and images sent ( and the data associated with the foregoing, such

as date and time) may indicate who used or controlled the account at a relevant time. Further,

information maintained by the email Providers can show how and when the account was

accessed or used. For example, as described below, email Providers typically log the Internet

Protocol (IP) addresses from which users access the email account, along with the time and date

of that access. By determining the physical location associated with the logged IP addresses,

investigators can understand the chronological and geographic context of the email account

access and use relating to the crime under investigation. This geographic and timeline

information may tend to either inculpate or exculpate the account owner. Additionally,

information stored at the user's account may further indicate the geographic location of the

account user at a particular time (e.g., location information integrated into an image or video sent

via email). Last, stored electronic data may provide relevant insight into the email account

owner's state of mind as it relates to the offense under investigation. For example, information in

the email account may indicate the owner's motive and intent to commit a crime (e.g.,

communications relating to the crime), or consciousness of guilt (e.g., deleting communications

in an effort to conceal them from law enforcement).

101. In my training and experience, information such as search history can help to

show the state of mind of an individual at the time the search was made, as well as the

individuals potential advance knowledge of events, as they search to see if the anticipated event

has occurred.

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INFORMATION REGARDING APPLE ID AND iCLOUD2

102. Apple is a United States company that produces the iPhone, iPad, and iPod

Touch, all of which use the iOS operating system, and desktop and laptop computers based on

the Mac OS operating system.

103. Apple provides a variety of services that can be accessed from Apple devices or,

in some cases, other devices via web browsers or mobile and desktop applications ("apps"). As

described in further detail below, the services include email, instant messaging, and file storage:

• Apple provides email service to its users through email addresses at the

domain names mac.com, me.com, and icloud.com.

• iMessage and FaceTime allow users of Apple devices to communicate in

real-time. iMessage enables users of Apple devices to exchange instant messages ("iMessages")

containing text, photos, videos, locations, and contacts, while FaceTime enables those users to

conduct video calls.

• iCloud is a file hosting, storage, and sharing service provided by Apple.

iCloud can be utilized through numerous iCloud-connected services, and can also be used to

store iOS device backups and data associated with third-party apps.

2 The information in this section is based on information published by Apple on its website, including, but
not limited to, the following document and webpages: "U.S. Law Enforcement Legal Process Guidelines," available
at http://images.apple.com/privacy/docs/legal-process-guidelines-us.pdf; "Create and start using an Apple ID,"
available at https://support.apple.com/en-us/HT203993; "iCloud," available at http://www.apple.com/icloud/; "What
does iCloud back up?," available at https://support.apple.com/kb/PH12519; "iOS Security," available at
https://www.apple.com/business/docs/i0S Security Guide.pd[, and "iCloud: How Can I Use iCloud?," available at
https://support.apple.com/kb/PH26502.

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·• iCloud-connected services allow users to create, store, access, share, and

synchronize data on Apple devices or via icloud.com on any Internet-connected device. For

example, iCloud Mail enables a user to access Apple-provided email accounts on multiple Apple

devices and on icloud.com. iCloud Photo Library and My Photo Stream can be used to store and

manage images and videos taken from Apple devices, and iCloud Photo Sharing allows the user

to share those images and videos with other Apple subscribers. iCloud Drive can be used to

store presentations, spreadsheets, and other documents. iCloud Tabs and bookmarks enable

iCloud to be used to synchronize bookmarks and webpages opened in the Safari web browsers

on all of the user's Apple devices. iWork Apps, a suite of productivity apps (Pages, Numbers,

Keynote, and Notes), enables iCloud to be used to create, store, and share documents,

spreadsheets, and presentations. iCloud Keychain enables a user to keep website usemame and

passwords, credit card information, and Wi-Fi network information synchronized across multiple

Apple devices.

• Game Center, Apple's social gaming network, allows users of Apple

devices to play and share games with each other.

• Find My iPhone allows owners of Apple devices to remotely identify and

track the location of, display a message on, and wipe the contents of those devices. Find My

Friends allows owners of Apple devices to share locations.

• Location Services allows apps and websites to use information from

cellular, Wi-Fi, Global Positioning System ("OPS") networks, and Bluetooth, to determine a

user's approximate location.

• App Store and iTunes Store are used to purchase and download digital

content. iOS apps can be purchased and downloaded through App Store on iOS devices, or
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through iTunes Store on desktop and laptop computers running either Microsoft Windows or

Mac OS. Additional digital content, including music, movies, and television shows, can be

purchased through iTunes Store on iOS devices and on desktop and laptop computers running

either Microsoft Windows or Mac OS.

104. Apple services are accessed through the use of an "Apple ID," an account created

during the setup of an Apple device or through the iTunes or iCloud services. A single Apple ID

can be linked to multiple Apple services and devices, serving as a central authentication and

syncing mechanism.

105. An Apple ID takes the form of the full email address submitted by the user to

create the account; it can later be changed. Users can submit an Applesprovided email address

(often ending [email protected], @me.com,or @mac.com)or an email address associated with a

third-party email provider (such as Gmail, Yahoo, or Hotmail). The Apple ID can be used to

access most Apple services (including iC!oud, iMessage, and FaceTime) only after the user

accesses and responds to a "verification email" sent by Apple to that "primary" email address.

Additional email addresses ("alternate," "rescue," and "notification" email addresses) can also be

associated with an Apple ID by the user.

106. Apple captures information associated with the creation and use of an Apple ID.

During the creation of an Apple ID, the user must provide basic personal information including

the user's full name, physical address, and telephone numbers. The user may also provide means

of payment for products offered by Apple. The subscriber information and password associated

with an Apple ID can be changed by the user through the "My Apple ID" and "iForgot" pages on

Apple's website. In addition, Apple captures the date on which the account was created, the

length of service, records oflog-in times and durations, the types of service utilized, the status of

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the account (including whether the account is inactive or closed), the methods used to· connect to
lI
and utilize the account, the Internet Protocol address ("IP address") used to register and access
1
the account, and other log files that reflect usage of the account.

107. Additional information is captured by Apple in connection with the use of an

Apple ID to access certain services. For example, Apple maintains connection logs with IP

addresses that reflect a user's sign-on activity for Apple services such as iTunes Store and App

Store, iCloud, Game Center, and the My Apple ID and iForgot pages on Apple's website. Apple

also maintains records reflecting a user's app purchases from App Store and iTunes Store, "call

invitation logs" for FaceTime calls, "query logs" for iMessage, and "mail logs" for activity over

an Apple-provided email account. Records relating to the use of the Find My iPhone service,

including connection logs and requests to remotely lock or erase a device, are also maintained by

Apple.·

108. Apple also maintains information about the devices associated with an Apple ID.

When a user activates or upgrades an iOS device, Apple captures and retains the user's IP

address and identifiers such as the Integrated Circuit Card ID number ("ICCID"), which is the

serial number of the device's SIM card. Similarly, the telephone number of a user's iPhone is

linked to an Apple ID when the user signs in to FaceTime or iMessage. Apple also may

maintain records of other device identifiers, including the Media Access Control address ("MAC

address"), the unique device identifier ("UDID"), and the serial number. In addition,

information about a user's computer is captured when iTunes is used on that computer to play

content associated with an Apple ID, and information about a user's web browser may be

captured when used to access services through icloud.com and apple.com. Apple also retains

records related to communications between users and Apple customer service, including

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communications regarding a particular Apple device or service, and the repair history for a

device.

I 09. Apple provides users with five gigabytes of free electronic space on iC!oud, and

users can purchase additional storage space. That storage space, located on servers controlled by

Apple, may contain data associated with the use of iCloud-connected services, including: email

(iCloud Mail); images and videos (iCloud Photo Library, My Photo Stream, and iCloud Photo

Sharing); documents, spreadsheets, presentations, and other files (iWork and iCloud Drive); and

web browser settings and Wi-Fi network information (iCloud Tabs and iCloud Keychain).

iCloud can also be used to store iOS device backups, which can contain a user's photos and

videos, iMessages, Short Message Service ("SMS") and Multimedia Messaging Service

("MMS") messages, voicemail messages, call history, contacts, calendar events, reminders,

notes, app data and settings, Apple Watch backups, and other data. Records and data associated

with third-party apps may also be stored on iCloud; for example, the iOS app for WhatsApp, an

instant messaging service, can be configured to regularly back up a user's instant messages on

iC!oud Drive. Some of this data is stored on Apple's servers in an encrypted form but can

nonetheless be decrypted by Apple.

110. In my training and experience, evidence of who was using an Apple ID and from

where, and evidence related to criminal activity of the kind described above, may be found in the

files and records described above. This evidence may establish the "who, what, why, when,

where, and how" of the criminal conduct under investigation, thus enabling the United States to

establish and prove each element or, alternatively, to exclude the innocent from further

susp1c10n.

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INFORMATION TO BE SEARCHED AND THINGS TO BE SEIZED

111. I anticipate executing this warrant under the Electronic Communications Privacy

Act, in particular 18 U.S.C. §§ 2703(a), 2703(b)(1 )(A) and 2703(c)(I )(A), by using the warrant

to require Google to disclose to the government copies of the records and other information

(including the content of communications) associated with the accounts in Attachment A, C, and

E and particularly described in Section I of Attachment B, D, and E. Upon receipt of the

information described in Section I of Attachments B, D, and F, government-authorized persons

will review that information to locate the items described in Section II of Attachment B, D, and

F. The items identified in Attachments A-F will also be screened by reviewers not on the

prosecution team to identify and filter out privileged material.

CONCLUSION

112. Based on the forgoing, I request that the Court issue the proposed search warrant.

113. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officeris not

required for the service or execution of this warrant.

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REQUEST FOR SEALING

114. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Andrew Mitchell
Special Agent
Federal Bureau oflnvestigation

Subscribed and sworn to before me on this/)/;}ay of July, 2018.

~~~
The Honorable Beryl A. Howell
Chief United States District Judge

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I
ATTACHMENT A
I
I
I
Property to be Searched

This warrant applies to information associated with the following email account:
I
1.

that is stored at premises owned, maintained, controlled, or operated by CSC Holdings, LLC,

1111 Stewart Avenue, Bethpage, NY 11714.

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ATTACHMENT B

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to the Provider or have been
preserved pursuant to a preservation request under 18 U.S.C. § 2703(:f), the Provider is required
to disclose the following information to the government for each account or identifier listed in
Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail described above
in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above in Section I.A,
including log files, dates, times, methods of connecting, ports, dial ups, and/or locations;

e. All records or other information stored by an individual using the account, including
address books, contact and buddy lists, calendar data, pictures, and files;

f. Records or other information regarding the identification of the account described above
in Section I.A, to include application, full name, physical address, telephone numbers and
other identifiers, records of session times and durations, log-in IP addresses associated
with session times and dates, account status, alternative e-mail addresses provided during
registration, all screen names associated with subscribers and/or accounts, all account
names associated with the subscriber,

g. All records indicating the services available to subscribers of the electronic mail address
described above in Section I.A.;

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Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 46 of 58
II
I
l
i
II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attaclnnent A
which consists of evidence, fruits, ~r instrumentalities of violations of 18 U.S.C. § 1030 (fraud
and related activities in connection with computers and 18 U.S.C. § 371 (conspiracy to commit
an offense against the United States) for the period from June 15, 2016 to November 10, 2016.
including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone, Julian Assange, or
any individual associated with the Trump Campaign;

All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

c. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
·including records about their identities and whereabouts;

d. Evidence of the times the account was used;

e. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

f. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

g. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

h. All existing printouts from original storage which concern the categories identified in
subsection II.A;

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'
I
,,I
ATTACHMENT C

Property to be Searched
I
This warrant applies to information associated with the following Apple account:

1.

1hat is stored at premises owned, maintained, controlled, or operated by Apple, Inc., located at

One Apple Park Way, Cupertino, California 95014.

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ATACHMENTD

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of Apple, regardless of whether such information is located within or outside
of the United States, including any messages, records, files, logs, o~ information that have been
deleted but are still available to Apple, or have been preserved pursuant to a request made under
18 U.S.C. § 2703(1), Apple is required to disclose the following information to the govermnent,
in unencrypted form whenever available, for each account or identifier listed in Attachment A:

a. All records or other information regarding the identification of the account, to


include full name, physical address, telephone numbers, email addresses (including primary,
alternate, rescue, and notification email addresses, and verification information for each email
address), the date on which the account was created, the length of service, the IP address used to
register the account, account status, associated devices, methods of connecting, and means and
source of payment (including any credit or bank account numbers);

b. All records or other information regarding the devices associated with, or used in
connection with, the account (including all current and past trusted or authorized iOS devices
and computers, and any devices used to access Apple services), including serial numbers, Unique
Device Identifiers ("UDID"), Advertising Identifiers ("IDFA"), Global Unique Identifiers
("GUID"), Media Access Control ("MAC") addresses, Integrated Circuit Card ID numbers
("ICCID"), Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),
Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber
Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Numbers
("MSISDN"), International Mobile Subscriber Identities ("IMSI"), and International Mobile
Station Equipment Identities ("IMEI"); .

c. The contents of all emails associated with the account, including stored or
preserved copies of emails sent to and from the account (including all draft emails and deleted
emails), the source and destination addresses associated with each email, the date and time at
which each email was sent, the size and length of each email, and the true and accurate header
information including the actual IP addresses of the sender and the recipient of the emails, and
all attachments;

d. The contents of all instant messages associated with the account, including stored
or preserved copies of instant messages (including iMessages, SMS messages, and MMS
messages) sent to and from the account (including all draft and deleted messages), the source and
destination account or phone number associated with each instant message, the date and time at
which each instant message was sent, the size and length of each instant message, the actual IP
addresses of the sender and the recipient of each instant message, and the media, if any, attached
to each instant message;

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e. The contents of all files and other records stored on iCloud, including ail iOS
device backups, all Apple and third-party app data, all files and other records related to iCloud
Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWork
(including Pages, Numbers, Keynote, and Notes), iCloud Tabs and bookmarks, and iCloud
Keychain, and all address books, contact and buddy lists, notes, reminders, calendar entries,
images, videos, voicemails, device settings, and bookmarks;

f. All activity, connection, and transactional logs for the account (with associated IP
addresses including source port numbers), including FaceTime call invitation logs, messaging
and query logs (including iMessage, SMS, and MMS messages), mail logs, iCloud logs, iTunes
Store and App Store logs (including purchases, downloads, and updates of Apple and third-party
apps), My Apple ID and iForgot logs, sign-on logs for all Apple services, Game Center logs,
Find My iPhone and Find My Friends logs, logs associated with web-based access of Apple
services (including all associated identifiers), and logs associated with iOS device purchase,
activation, and upgrades;

g. All records and information regarding locations where the account or devices
associated with the account were accessed, including all data stored in connection with Location
Services, Find My iPhone, Find My Friends, and Apple Maps;

h. All records pertaining to the types of service used;

i. All records pertaining to communications between Apple and any person


regarding the account, including contacts with support services and records of actions taken; and

j. All files, keys, or other information necessary to decrypt any data produced in an
encrypted form, when available to Apple (including, but not limited to, the keybag.txt and
fileinfolist. txt files).

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II. · Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 1030 (fraud
and related activities in connection with computers and 18 U.S.C. § 371 (conspiracy to commit
an offense against the United States) for the period from June 15, 2016 to November 10, 2016.
including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications
with persons or entities associated with WikiLeaks, including but not limited to
Julian Assange, or communications regarding disinformation, denial, dissembling
or other obfuscation about knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone, , Julian
Assange, or any individual associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, and


contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created,


used, or communicated with the account or identifier, including records about
their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption


or other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be
necessary to access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

i. All existing printouts from original storage which concern the categories
identified in subsection II.A; and

j. All "address books" or other lists of contacts.

41
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 51 of 58

ATTACHMENTE

Property to be Searched

This warrant applies to information associated with the following email account:

that is stored at premises owned, maintained, controlled, or operated by Windstream

Communications, Inc, with offices located at 11001 Executive Center Drive, Little Rock,

Arkansas, 72211.

42
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 52 of 58

ATTACHMENT F

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to the Provider or have been
preserved pursuant to a preservation request under 18 U.S.C. § 2703(±), the Provider is required
to disclose the following information to the government for each account or identifier listed in
Attachment E:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail described above
in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above in Section I.A,
including log files, dates, times, methods of connecting, ports, dial ups, and/or locations;

e. All records or other information stored by an individual using the account, including
address books, contact and buddy lists, calendar data, pictures, and files;

f. Records or other information regarding the identification of the account described above
in Section I.A, to include application, full name, physical address, telephone numbers and
other identifiers, records of session times and durations, log-in IP addresses associated
with session times and dates, account status, alternative e-mail addresses provided during
registration, all screen names associated with subscribers and/or accounts, all account
names associated with the subscriber,

g. All records indicating the services available to subscribers of the electronic mail address
described above in Attachment E;

43
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 53 of 58

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 1030 (fraud
and related activities in connection with computers and 18 U.S.C. § 371 (conspiracy to commit
an offense against the United States) for the period from June 15, 2016 to November 10, 2016.
including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone, Julian Assange, or
any individual associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating


.
to who created, used, or.
communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

1. All existing printouts from original storage which concern the categories identified
above;

44
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 54 of 58

IN THE UNITED STATES DISTRICT COURT.


FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF Case: 1:18-sc-02401


INFORMATION ASSOCIATED WITH Assigned To : Howell, Beryl A.
Assign. Date: 7/12/2018
Description: Search & Seizure Warrant

MOTION TO SEAL WARRANT AND RELATED DOCUMENTS AND


TO REQUIRE NON-DISCLOSURE UNDER 18 U.S.C. § 2705(b)

The United States of America, moving by and through its undersigned counsel, respectfully

moves the Court for an Order placing the above-captioned waITant and the application and affidavit

in support thereof (collectively herein the "Warrant") under seal, and precluding the provider from

notifying any person of the WmTant pursuant to 18 U.S.C. § 2705(b). In regard to the non-

disclosure, the proposed Order would direct Apple Inc. ("Apple") an electronic communication

and/or remote computing services provider headquartered in Cupertino, California not to notify

m1y other person (except attorneys for Apple for the purpose of receiving legal advice) of the

existence or content of the W aITant for a period of one year or until further order of the Court.

JURISDICTION AND LEGAL BACKGROUND

1. The Court has the inherent power to seal court filings when appropriate,

including the Wm-rant. United States v. Hubbard, 650 F.2d 293, 315-16 (D.C. Cir. 1980) (citing

Nixon v. Warner Communications, Inc., 435 U.S. 589,598 (1978)). The Court may also seal the

WaITant to prevent serious jeopm·dy to an ongoing criminal investigation when, as in the present

case, such jeopardy creates a compelling governmental interest in preserving the confidentiality of

the Warrant. See Washington Post v. Robinson, 935 F.2d 282, 287-89 (D.C. Cir. 1991).

2. In addition, this Court has jurisdiction to issue the requested order because it is "a

court of competent jurisdiction" as defined by 18 U.S.C. § 2711. Specifically, the Court is a

"district court of the United States ... that - has jurisdiction over the offense being investigated."
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 55 of 58

18 U.S.C. § 2711(3)(A)(i). As discussed fully below, acts or omissions in furtherance of the

offense under investigation occurred within Washington, D.C. See 18 U.S.C. § 3237.

3. Further, the Corui has authority to require non-disclosure of the Warrant under 18

U.S.C. § 2705(b). Apple provides an "electronic communications service," as defined in 18

U.S.C. § 2510(15), and/or "remote computing service," as defined in 18 U.S.C. § 2711(2). The

Stored Communications Act ("SCA"), 18 U.S.C. §§ 2701-2712, governs how Apple may be

compelled to supply communications and other records using a subpoena, court order, or search

warrant. Specifically, Section 2703(c)(2) authorizes the Government to obtain cetiain basic

"subscriber information" using a subpoena, Section 2703(d) allows the Government to obtain other

"non-content" information using a court order, and Section 2703(a)-(b)(l)(A) allows the

Government to obtain contents of conmmnications using a search warrant. See 18 U.S.C. § 2703.

4. The SCA does not set forth any obligation for providers to notify subscribers about

subpoenas, court orders, or search warrants under Section 2703. However, many have voluntarily

adopted policies of notifying subscribers about such legal requests. Accordingly, when necessary,

Section 2705(b) of the SCA enables the Government to obtain a court order to preclude such

notification. In relevant part, Section 2705(b) provides as follows: 1

(b) Preclusion of notice to subject of governmental access. - A governmental


entity acting under section 2703 ... may apply to a court for an order commanding
a provider of electronic communications service or remote computing service to
whom a warrant, subpoena, or court order is directed, for such period as the court
deems appropriate, not to notify any other person of the existence of the warrant,
subpoena, or corui order. The court shall enter such an order if it determines that
there is reason to believe that notification of the existence of the warrant, subpoena,
or court order will result .in-
(!) endangering the life or physical safety of an individual;
(2) flight from prosecution;

1 Section 2705(b) contains additional requirements for legal process obtained pursuant to 18 U.S.C.
§ 2703(b )(1 )(B), but the Government does not seek to use the proposed Order for any legal process
under that provision.

2
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 56 of 58

(3) destruction of or tampering with evidence;


(4) intimidation of potential witnesses; or
(5) otherwise seriously jeopardizing an investigation or unduly delaying a trial.

18 U.S.C. § 2705(b). The United States District Court for the District of Columbia has made clear

that a nondisclosure order under Section 2705(b) must be issued once the Government makes the

requisite showing about potential consequences of notification:

The explicit terms of section 2705(b) make clear that if a courts [sic] finds that there
is reason to believe that notifying the customer or subscriber of the court order or
subpoena may lead to one of the deleterious outcomes listed under § 2705(b), the
court must enter an order commanding a service provider to delay notice to a
customer for a period of time that the court determines is appropriate. Once .the
government makes the required showing under § 2705(b), the court is required to
issue the non-disclosure order.

In re Application for Order of Nondisclosure Pursuant to 18 US.C. § 2705{b) for Grand Jury

Subpoena #GJ2014031422765, 41 F. Supp. 3d 1, 5 (D.D.C. 2014).

5. Accordingly, this motion to seal sets forth facts showing reasonable grounds to

command Apple not to notify any other person (except attorneys for Apple for the purpose of

receiving legal advice) of the existence of the Subpoena for a period of one year or until further

order of the Court.

FACTS SUPPORTING SEALING AND NON-DISCLOSURE

6. At the present time, law enforcement officers of the FBI are conducting an

investigation into violations related to 18 U.S.C. § 1030 (unauthorized access of a protected

computer) and 18 U.S.C. § 371 (conspiracy) arising out of the conduct of Roger Stone, Jerome

Corsi, and others. It does not appear that Stone and Corsi are currently aware of the full nature and

scope of the ongoing FBI investigation. Disclosure of this waITant to Corsi could lead him to

destroy evidence or notify others who may delete information relevant to the investigation.

3
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 57 of 58

REQUEST FOR SEALING AND NON-DISCLOSURE

7. In this matter, the government requests that the Warrant be sealed until further order

of the Court and that Apple and its employees be directed not to notify any other person of the

existence or content of the Warrant (except attorneys for Apple for the purpose of receiving legal

advice) for a period of one year or until further order of the Court. Such an order is appropriate

because the Wanant relates to an ongoing criminal investigation, the full scope of which is neither

public nor known to the targets of the investigation, and its disclosure may alert these targets to

the ongoing investigation and its scope. Once ale1ied to this investigation, potential targets would

be immediately prompted to destroy or conceal incriminating evidence, alter their operational

tactics to avoid future detection, and otherwise take steps to undermine the investigation and avoid

future prosecution. In particular, given that they are known to use electronic communication and

remote computing services, the potential target could quickly and easily destroy or encrypt digital

evidence relating to their criminal activity.

8. Given the complex and sensitive nature of the criminal activity under investigation,

and also given that the criminal scheme may be ongoing, the Government anticipates that this

confidential investigation will continue for the next year or longer. However, should

circumstances change such that court-ordered nondisclosure under Section 2705(b) becomes no

longer needed, the Government will notify the Comi and seek appropriate relief;

9. There is, therefore, reason to believe that notification of the existence of the

Warrant will seriously jeopardize the investigation, including by giving the targets an opportunity

to flee from prosecution, destroy or tamper with evidence, and intimidate witnesses. See 18 U.S.C.

§ 2705(b)(2)-(5). Because of such potential jeopardy to the investigation, there also exists a

4
Case 1:19-mc-00029-CRC Document 29-9 Filed 04/28/20 Page 58 of 58

compelling· governmental interest in· confidentiality to justify the government's sealini request.

See Robinson, 935 F.2d at 287-89.

10. Based on prior dealings with Apple the United States is aware that, absent a court

order under Section 2705(b) commanding Apple not to notify anyone about a legal request, it is

Apple's policy and practice, upon receipt of a wanant seeking the contents of electronically stored

wire or electronic communications for a certain account, to notify the subscriber or customer of

the existence of the warrant prior to producing the material sought.

WHEREFORE, for all the foregoing reasons, the government respectfully requests that the

above-captioned wanant, the application and affidavit in suppmi thereof, and all attachments

thereto and other related materials be placed under seal, and furthe1more, that the Court command

Apple not to notify any other person of the existence or contents of the above-captioned wanant

(except attorneys for Apple for the purpose of receiving legal advice) for a period of one year or

until further order of the Court.

Respectfully submitted,

ROBERTS. MUELLER, III


Special Counsel

Dated: J/tl/2,D/'3 By: ~-~-~


kamnS.f Zeliy
The Special Counsel's Office
(202)-514-0637

5
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 1 of 57

AO 93 (Rev. ! l/l3) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of ) Case: 1: 18-sc-02403


(Briefly describe the property to be searched )
or identijj1 the person by name and address) )
Assigned To : Howell, Beryl A.
) Assign. Date: 7/12/2018
INFORMATION ASSOCIATED WITH
) Description: Search & Seizure Warrant
)

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or prope1ty located in the Eastern District of New York
(identijj1 the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the properly to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before July 26, 2018 (not to exceed 14 days)
<;;fin the daytime 6:00 a.m. to 10:00 p.m.
0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
prope1ty was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. _B_e_iyl A. H~o~w~e~l~I_ _ __
(UniJed States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 ( except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate bmj
0 for __ days (,101 to exceed 30) 0 until, the facts justifying, the later specific date of .. · - - -

Date and time issued: ~~A d-'.,,y0


Judge's signature

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
----
Printed name and title
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 2 of 57

AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of pe1jury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date: ..
Executing officer's signature

-
Printed name and title
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 3 of 57

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following email account:

1.

that is stored at premises owned, maintained, controlled, or operated by CSC Holdings, LLC,

1111 Stewart Avenue, Bethpage, NY 11714.

34
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 4 of 57

ATTACHMENT B

Particular Thiugs to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to the Provider or have been
preserved pursuant to a preservation request under 18 U.S.C. § 2703(f), the Provider is required
to disclose the following information to the government for each account or identifier listed in
Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail described above
in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above in Section I.A,
including log files, dates, times, methods of connecting, ports, dial ups, and/or locations;

e. All records or other information stored by an individual using the account, including
address books, contact and buddy lists, calendar data, pictures, and files;

f. Records or other information regarding the identification of the account described above
in Section I.A, to include application, full name, physical address, telephone numbers and
other identifiers, records of session times and durations, log-in IP addresses associated
with session times and dates, account status, alternative e-mail addresses provided during
registration, aU screen names associated with subscribers and/or accounts, all account
names associated with the subscriber,

g. All records indicating the services available to subscribers of the electronic mail address
described above in Section I.A.;

35
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 5 of 57

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 1030 (fraud
and related activities in connection with computers and 18 U.S.C. § 371 (conspiracy to commit
an offense against the United States) for the period from June 15, 2016 to November 10, 2016.
including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinfo1mation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone, Julian Assange, or
any individual associated with the Trump Campaign;

All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

c. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

d. Evidence of the times the account was used;

e. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

f. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

g. Credit card and other financial info1mation, including but not limited to, bills and
payment records evidencing ownership of the subject account;

h. All existing printouts from original storage which concern the categories identified in
subsection II.A;

36
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 6 of 57

FILED
IN THE UNITED STATES DISTRICT COURT JUL 1 2 2018
FOR THE DISTRICT OF COLUMBIA Clerk, U.S. District & Bankruptcy
Courts for the District of Columbia
IN THE MATTER OF THE SEARCH OF Case: 1:18-sc-02403
INFORMATION ASSOCIATED WITH Assigned To : Howell, Beryl A.
Assign. Date: 7/12/2018
Description: Search & Seizure Warrant

ORDER

The United States has filed a motion to seal the above-captioned warrant and related

documents, including the application and affidavit in support thereof (collectively the "Warrant"),

and to require CSC Holdings, an electronic communication and/or remote computing service s

headquartered at 1111 Stewart Avenue, Bethpage, NY 11714, not to disclose the existence or

contents of the Warrant pursuant to 18 U.S.C. § 2705(b).

The Court finds that the United States has established that a compelling governmental

interest exists to justify the requested sealing, and that there is reason to believe that notification

of the existence of the Wmrnnt will seriously jeopardize the investigation, including by giving the

targets an oppo1tunity to flee from prosecution, destroy or tamper with evidence, and intimidate

witnesses. See 18 U.S.C. § 2705(b)(2)-(5).

IT IS THEREFORE ORDERED that the motion is hereby GRANTED, and that the

warrant, the application and affidavit in support thereof, all attachments thereto and other related

materials, the instant motion to seal, and this Order be SEALED until further order of the Comi;

and
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 7 of 57

IT IS FURTHER ORDERED that, pursuant to 18 U.S.C. § 2705(b), CSC Holdings and

its employees shall not disclose the existence or content of the Warrant to any other person ( except

attorneys for CSC Holdings for the purpose of receiving legal advice) for a period of one year

unless otherwise ordered by the Comi.

THE HONORABLEERYL A.HOWELL


CHIEF UNITED STATES DISTRICT JUDGE

~/</
Date

2
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 8 of 57
AO I06 (Rev. 04/10) Application for a Search Warrant

fit!D
UNITED STATES DISTRICT COURT JUL 1 2 2018
for the Clerk, U.S. District & Bankruptcy
District of Columbia Courts for the District of Columbia

In the Matter of the Search of Case: 1 :18-sc-02403


(Briefly describe the property to be searched
or identify the person by name and address)
l Assigned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH
l
)
Assign. Date : 7/12/2018
Description: Search & Seizure Warrant

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the govermnent, request a search warrant and state under
penalty of pe1jury that I have reason to believe that on the following person or property (identify the person or describe the
properly to be searched and give its location):

See Attachment A.
New York , there is now concealed (identify the
located in the Eastern
--~=~~~--
person or describe the property to be seized):
District of
--~="-'=~--~
See Attachment B.
This warrant is sought pursuant to 18 U.S.C. §§ 2703(a), 2703(b)(1)(A), and 2703(c)(1)(A).

The basis for the search under Fed. R. Crim. P. 4 l(c) is (check one or more):
,!I evidence of a crime;
,!I contraband, fruits of crime, or other items illegally possessed;
r,/ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
18 U.S.C. § 371 Conspiracy
18 u.s.c. § 1030 Unauthorized Access of a Protected Computer

The application is based on these facts:

See attached Affidavit.

',;/ Continued on the attached sheet.


O Delayed notice of days (give exact ending date if more than 30 days: __ ___ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached eet.

Reviewed by AUSA/SAUSA:
IAaron Zelinsky (ASC) Andrew Mitchell, Special Agent, FBI
Printed name and title

Sworn to before me and signed in my presence.

Date: 7/12/2018
,. Judge's signature

City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 9 of 57

FILED
IN THE UNITED STATES DISTRICT COURT
JUL 12 2018
FOR THE DISTRICT OF COLUMBIA Clerk, U.S. District &Bankruptcy
Courts for tile District of Columbia

IN THE MATTER OF THE SEARCH OF


INFORMATION ASSOCIATED WITH Case No. (1,- 5C - c. Yo3
Filed Under Seal

AMENDED AFFIDAVIT IN SUPPORT OF


AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the following:

a. The email account maintained by CSC Holdings ("Target

Account 1"), described further in Attachment A.

b. The Apple Account (including email) associated with maintained

by Apple, Inc. (Target Account 2), described further in Attachment C.

c. The email accoun maintained by Windstream Communications

("Target Account 3"), described further in Attachment E.

The information to be disclosed by CSC Holdings, Apple, Inc., and Windstream

Communications ("the Providers") and searched by the government is described in the following

paragraphs and in Attachments A-F. This affidavit is made in support of an application for a

search warrant under 18 U.S.C. §§ 2703(a), 2703(b)(l)(A), and 2703(c)(l)(A).

2. I, Andrew Mitchell, am a Special Agent with the Federal Bureau of Investigation

(FBI), and have been since 2011. As a Special Agent of the FBI, I have received training and

experience in investigating criminal and national security matters.


Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 10 of 57

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for tbe requested warrant and does not set

forth all of my knowledge about this matter.

4. Before the submission of this warrant application, the Special Counsel's Office

complied with all relevant Department of Justice policies, including the requirement for

Departmental approval under the Department's policy regarding obtaining information from

members of the news media, 28 C.F.R. 50.10.

5. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Accounts contain communications relevant to

violations of 18 U.S.C. § 371 (conspiracy) and 18 U.S.C. § 1030 (unauthorized access of a

protected computer).

JURISDICTION

6. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &(c)(l)(A).

Specifically, tbe Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisdiction over tbe offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below,

including in paragraph 19.

SUMMARY

7. On or about July 25, 2016, Roger STONE emailed Jerome CORSI to "Get to

Assange" at the Ecuadorian Embassy and "get pending WikiLeaks emails[.]" On or about July

31, 2016, STONE also instructed CORSI to have contact Julian

2
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 11 of 57

ASSANGE. · On or about August 2, 2016, CORSI responded to STONE that the "word is friend

in embassy [ASSANGE] plans 2 more dumps. One shortly after I'm back. 2nd in October.

Impact planned to be very damaging .... Time to let more than Podesta to be exposed as in bed w

enemy if they are not ready to drop HRC." After receipt of that message, on or about August 21,

2016, using @RogerJStoneJR, Stone tweeted: "Trust me, it will soon the [sic] Podesta' s time in

the barrel. #CrookedHillary."

8. Information disclosures subsequently occurred on or about the times CORSI

predicted: On or aboutAugust 12, 2016, the day CORSI was scheduled to return to the United

States ("shortly after I'm back"), Guccifer 2.0 released hacked information related to the

Democratic Congressional Campaign Committee (DCCC). On or about October 7, 2016, the day

the Washington Post published a breaking story about an Access Hollywood videotape ofthen-

candidate Trump making disparaging remarks about women, WikiLeaks released emails hacked

from the account of John Podesta.

9. Furthermore, on the day of the Access Hollywood video disclosure, there were

phone calls between STONE and CORSI after the Washington Post contacted STONE prior to

publication. At approximately 11 :OOAM, the Washington Post received a tip regarding the

Access Hollywood video. Approximately one hour later, shortly before noon, STONE received

a call from the Washington Post. Approximately ninety minutes later, before 2:00 PM, STONE

called CORSI and they spoke. Approximately forty minutes later, CORSI called STONE and the

two spoke again at length. At approximately 4:00PM, the Washington Post published its story

regarding the Access Hollywood tape. By approximately 4:30PM, WikiLeaks tweeted out its

first release of emails hacked from John Podesta.

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PROBABLE CAUSE.

A. Background on Relevant Individuals

i. Roger STONE

11. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of Trump's presidential campaign. As

described further below, STONE also maintained contact with individuals employed by the

Campaign, including then-campaign chairman Paul MANAFORT and deputy chairman Rick

GATES.

ii. Jerome CORSI

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12. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WND.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

B. U.S. Intelligence Community (USIC) Assessment of Russian Government-Backed


Hacking Activity during the 2016 Presidential Election

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14. On October 7, 2016, the U.S. Department of Homeland Security an:d the Office of

the Director of National Intelligence released a joint statement of an intelligence assessment of

Russian activities and intentions during the 2016 presidential election. In the report, the USIC

assessed the following, with emphasis added:

15. The U.S. Intelligence Community (USIC) is confident that the Russian

Government directed the recent compromises of emails from US persons and institutions,

including from US political organizations. The recent disclosures of alleged hacked emails on

sites like DCLeaks.com and WikiLeaks and by the Guccifer 2.0 online persona are consistent

with the methods and motivations of Russian-directed efforts. These thefts and disclosures are

intended to interfere with the US election process. Such activity is not new to Moscow-the

Russians have used similar tactics and techniques across Europe and Eurasia, for example, to

influence public opinion there. We believe, based on the scope and sensitivity of these efforts,

that only Russia's senior~most officials could have authorized these activities.

16. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities a:nd intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US ·Elections." In the report, the USIC

assessed the following:

17. "Russian President Vladimir Putin ordered an influence campaign in 2016 aimed

at the US presidential election. Russia's goals were to undermine public faith in the US

democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her

electability and potential presidency. We further assess Putin and the Russian Government

developed a clear preference for President-elect Trump."

18. The USIC also described, at a high level, some of the techniques that the Russian

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government employed during its interference. The USIC summarized the efforts as a "Russian

messaging strategy that blends covert intelligence operations-such as cyber activity-with

overt efforts by Russian Government agencies, state-funded media, third-party intermediaries,

and paid social media users or 'trolls."'

19. With respect to "cyber activity," the USIC-assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities to

the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted in

the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC." The GRU is the

foreign military intelligence agency of the Russian Ministry of Defense, and is Russia's largest

foreign intelligence agency.

20. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

21. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

C. Additional Hacking Activity by Individuals Associated with the GRU

22. TheSpecial Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 campaign through at least

November 1, 2016.

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23. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

24. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

25. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

D. Roger Stone's Public Interactions with Guccifer 2.0 and WikiLeaks

26. On June 14, 2016, Crowdstrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

27. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.

28. On August 5, 2016, Roger Stone published an article on Breitbart.com entitled,

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"Dear Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't

seem to be the Russians that hacked the DNC, but instead a hacker who goes by the name of

Guccifer 2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in

the article and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains

who he is and why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a

fateful and wise decision. He went to WikiLeaks with the DNC files and the rest is history. Now

the world would see for themselves how the Democrats had rigged the game."

29. On August 8, 2016, Stone addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

Assange to Russia Today (RT) several days earlier about an upcoming "October Surprise" aimed

at the Hillary Clinton presidential campaign. Specifically, Stone was asked: "With regard to the

October surprise, what would be your forecast on that given what Julian Assange has intimated

he's going to do?" Stone responded: "Well, it could be any number of things. I actually have

communicated with Assange. I believe the next tranche of his documents pertain to the Clinton

Foundation but there's no telling what the October surprise may be." A few days later, Stone

clarified that while he was not personally in touch with Assange, he had a close friend who

served as an intermediary.

30. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the Democratic Congressional Campaign

Committee (DCCC).

31. On August 13, 2016, Stone posted a tweet using@RogerJStoneJr calling Guccifer

2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day, Guccifer 2.0's

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Twitter account was reinstated.

32. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i 'm pleased to say u r

great man. please tell me ifl can help u anyhow. it would be a great pleasure to me."

33. On August 18, 2016, Paul Manafort, Stone's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that Manafort had worked with a Washington D.C.-based lobbying firms to influence U.S. policy

toward Ukraine.

34. On August 21, 2016, using@RogerJStoneJR, Stone tweeted stating: "Trust me, it

will soon the [sic] Podesta' s time in the barrel. #CrookedHillary ." In a C-SPAN interview that

same day, Stone reiterated that because of the work of a "'mutual acquaintance' of both his and

[Assange], the public [could] expect to see much more from the exiled whistleblower in the form

of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

35. On September 16, 2016 Stone said in a radio interview with Boston Herald Radio

that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly basis

fairly soon. And that of course will answer the question as to what exactly what was erased on

that email server."

36. On Saturday, October 1, 2016, using@RogerJStoneJr, Stone Tweeted,

"Wednesday@ HillaryClinton is done. #WikiLeaks."

37. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

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tweeted regarding an announcement Julian Assange had scheduled for the next day from the

balcony of the Ecuadoran Embassy in London. On the day of the Assange armouncement -

which was part ofWikiLeaks' 10-year armiversary celebration- Stone told Infowars that his

intermediary described this release as the "mother load." On October 5, 2016, Stone used

@RogerJStoneJr to tweet: "Payload coming. #Lockthemup."

38. On Friday, October 7, 2016, at approximately 4:03 P.M., the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series oflewd remarks.

39. Approximately a half hour later, at 4:32 P.M., WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #imWithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

40. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, John Podesta-referring back to Stone's August

21, 2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption

to - or at least a reasonable conclusion - that [Stone] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[Stone]." Commenting to the NBC News, Stone responded: "I have never met or spoken with

Assange, we have a mutual friend who's traveled to London several times, and everything I

know is through that channel of communications. I'm not implying I have any influence with

him or that I have advanced knowledge of the specifics of what he is going to do. I do believe he

has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides, thought were

deleted. I hear that through my emissary."

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41. · On March 27, 2017, CNN reported that a representative ofWikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between Stone and WikiLeaks. The same article quoted

Stone as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew a.bout the hacking ofPodesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

E. Roger Stone's Private Twitter Direct Messages with WikiLeaks and Julian Assange.

42. On August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the

Twitter account @RogerJStoneJr.

43. On October 13, 2016, while WikiLeaks was in the midst of releasing the hacked

Podesta emails, @RogerJStoneJr sent a private direct message to the Twitter account

@wikileaks. This account is the official Twitter account of WikiLeaks and has been described as

such by numerous news reports. The message read: "Since I was all over national TV, cable and

print defending WikiLeaks and assange against the claim that you are Russian agents and

debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

44. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

45. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

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46. On or about November 9, 2016, one day after the presidential election,

@wiki!eaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

4 7. In addition, @RogerJStoneJr also exchanged direct messages with Julian

Assange, the founder of WikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly

messaged @JulianAssange, an address associated with Julian Assange in numerous public

reports, stating: "Still nonsense. As a journalist it doesn't matter where you get information only

that it is accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

48. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@wikileaks, reading: "I am doing everything possible to address the issues at the highest level of

Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

F. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks.

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49. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, On October

17, 2017, Chief Judge Beryl A. Howell issued a search warrant for STONE's address,

On or about December 19, 2017 Chief Judge Beryl A. Howell issued a

search warrant for email account. On or about March 14, 2018, Chief Judge Beryl

A. Howell issued a search watTant for STONE's iCloud account. Information recovered pursuant

to those search warrants indicated the following:

50. On or about May 15, 2016, emailed CORSI at Target Account 3:

"Here is my flight schedule. Need to get something confirmed now .... " CORSI responded, "I

copied Roger Stone so he knows your availability to meet Manafort and DT this coming week."

CORSI appears to have forwarded the message to STONE, who replied to CORSI that, "May

meet Manafort -guarantee nothing."

51. On or about May 16, 2016, emailed CORSI on Target Account 3:

"Outside of Wednesday 2-4 ... I am open. Do you have times for meeting on other things?

Flexible re DJT. How about the head of finance for them?" CORSiresponded, "I will work on

other meetings today." replied, "Do you [want] me to bring you anything from the

Old Country? I have a meeting now from 2-6 on Wednesday. Open all other times!!!"

52. On or about May 18, 2016, CORSI, using Target Account 3, emailed STONE

with the Title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

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53. On July 25, 2016, STONE sent an email to CORSI at Target Account 1 with the

subj~ct line, "Get to Assange." The body of the message read: "Get to Assange [a]t Ecuadorian

Embassy in London and get the pending WikiLeaks emails ... they deal with Foundation,

allegedly."

54. On or about July 31, 2016, STONE emailed CORSI at Target Account 1 with the

subject line, "Call me MON." The body of the email read: " should see Assange[.]

should find Bernie [S]anders brother who called Bill a Rapist-turn him for Trump[.]

should find or more proof of Bill getting kicked out."

55. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE using Target Account 1,

"Word is friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct. Impact

planned to be very damaging. Signs are Fox will have me on mid-Aug. more post Ailes shakeup

underway. Expect Shine to surface victor, for now. Post-DNC bump for HRC an artifact of

rigged polling. Won't last. I expect presidential campaign to get serious starting Sept. Still in pre-

season games. Time to let more than Podesta to be exposed as in bed w enemy if they are not

ready to drop HRC. That appears to be the game hackers are now about. Would not hurt to start

suggesting HRC old, memory bad, has stroke -- neither he nor she well. I expect that much of

next dump focus, setting stage for Foundation debacle." Investigators believe that CORSI's

reference to a "friend in embassy [who] plans 2 more. dumps" refers to Julian ASSANGE, the

founder ofWikiLeaks, who resided in Ecuador's London Embassy in 2016.

56. On or about August 5, 2016 an associate ofSTONE's, emailed

him a link to a poll indicating that Clinton led Trump by 15 points. STONE responded "enjoy it

while u can[.] I dined with my new pal Julian Assange last night." subsequently

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stated to investigators that, around the same time, STONE told him he had gone to London to

meet ASSANGE. also stated that in 2018, told STONE he would be

interviewed by the FBI and would have to divulge the conversation about meeting ASSANGE.

STONE told he was joking and had not actually met Assange.

57. On or about August 15, 2016, CORSI messaged STONE using Target Account

3: "Give me a call today if you can. Despite MSM drumroll that HRC is already elected, it's not

over yet. More to come than anyone realizes. Won't really get started until after Labor Day. I'm

in NYC this week. Jerry."

58. On or about August 31, 2016, CORSI using Target Account 1 emailed STONE:

"Did you get the PODESTA writeup." STONE replied "yes."

59. On or about August 31, 2016, CORSI, using Target Account 2, messaged

STONE, "Podesta paid $180k to invest in Uranium One - was hired by Rosatom in Giustra

scandal. Podesta now under FBI investigation - tied to Ukraine Yanukovych - Panama papers

reveals Podesta hired by S[b]erbank, Russia's largest financial institution-Podesta$$$ ties to

Russia undermine Clinton false narrative attempting to tie Trump to Putin."

60. On or about September 6, 2016, CORSI emailed STONE using Target Account

3: "Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

61. On or about September 24, 2016 emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded using Target

Account 3, "We have secure back channel through Roger. I saw him again in NYC last Friday

and spoke to him about it again today." wrote back, "Awaiting secret file.

Explosive ... Hope you are well. Can't wait for the debate. Channeling Reagan, I hope!" CORSI

responded, "Keep me posted about file[.]" In a subsequent meeting with investigators,

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 25 of 57

indicated this conversation concerned possible derogatory information he was trying

to obtain from Turkey.

62. On or about October 3, 2016, an associate of STONE emailed STONE and asked:

"Assange - what's he got? Hope it's good." Stone wrote back, "It is. I'd tell Bannon but he

doesn't call me back. My book on the TRUMP campaign will be out in Jan. Many scores will be

settled." The associate forwarded the email to Steve BANNON and wrote: "You should call

Roger. See below. You didn't get from me." BANNON wrote back, "I've got important stuff to

worry about." The associate responded, "Well clearly he knows what Assange has. I'd say that's

important."

63. .On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

AS SANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, AS SANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

64. On or about October 4, 2016, CORSI messaged STONE using Target Account 2,

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

65. That same day, BANNON emailed STONE, "What was that this morning???"

STONE replied, "Fear. Serious security concern. He thinks they are going to kill him and the

London police are standing done [sic]." BANNON wrote back, "He didn't cut deal w/

clintons???" Stone replied, "Don't think so BUT his lawyer is a big democrat."

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66. When BANNON spoke with investigators during a volunt~y proffer on February

14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE was about

WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking STONE

about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

G. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

67. According to a publicly available news article, 1 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same article,

"Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage from a

2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone, calling

Trump's campaign, 'Access Hollywood' and NBC for reaction."

68. According to phone records , at approximately

11 :27 AM, CORSI placed a call to STONE which STONE did not answer.

69. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

70. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

71. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

1 https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-then-the-race-was-

on/2016/10/07/31 d747 l 4-8ce5- l l e6-875e-2c 1bfe943b66_story.html

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72. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

73. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, when CORSI emailed STONE on Target Account 1, he wrote "I

expect that much of next dump focus, setting stage for Foundation debacle."

74. At approximately 6:27PM, sent STONE an email titled,

"WikiLeaks - The Podesta Emails" with a link to the newly-released Podesta emails.

Approximately ten minutes later, STONE forwarded message to CORSI at Target

Account 1 without comment. STONE does not appear to have forwarded the email to any other

individual.

H. STONE Requests to CORSI for "SOMETHING" to Post About Podesta After


STONE Is Accused of Advance Knowledge of the Leak

75. On or about October 8, 2016, STONE messaged CORSI at Target Account 2,

"Lunch postponed- have to go see T." CORSI responded to STONE, "Ok. I understand."

Approximately twenty minutes later, CORSI texted, "Clintons know they will lose a week of

Paula Jones media with T attacking Foundation, using Wikileaks Goldman Sachs speech

comments, attacking bad job numbers."

76. On or about Wednesday, October 12, 2016, at approximately 8:17 EDT, STONE

emailed CORSI at Target Account 1, asking him to "send me your best podesta links." STONE

emailed CORSI at approximately 8:$$ EDT, "need yourBEST podesta pieces." CORSI wrote

back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on Podesta is

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complicated. Two articles in length. I can give you in raw form the stuff I got in Russian

translated but to write it up so it's easy to understand will take weekend. Your choice?"

77. On or about that same day October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI,

using Target Account 1, emailed STONE with a subject line "Podesta talking points." Attached

to the email was a file labeled, "ROGER STONE podesta talking points Oct 12 2016.docx." The

"talking points" included the statement that "Podesta is at the heart of a Russian-government

money laundering operation that benefits financially Podesta personally and the Clintons through

the Clinton Foundation."

78. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Account, "Got them and used them."

79. On or about Thursday, October 13, 2016, CORSI, using Target Account 3,

emailed STONE: "PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI wrote

back to STONE, "I'll give you one more-NOBODY YET HAS THIS[:] It looks to me like
'
skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 29 of 57

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

80. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email with the Subject, "ROGER STONE article RUSSIAN MAFIA STYLE

MONEY-LAUNDERING, the CLINTON FOUNDATION, and JOHN PODESTA." The text

stated: "Roger[,] You are free to publish this under your own name." That same day, STONE

posted a blog post with the title, "Russian Mafia money laundering, the Clinton Foundation and

John Podesta." In that post, STONE wrote, "although I have had some back-channel

communications with Wikileaks I had no advance notice about the hacking of Mr. Podesta nor I

have I ever received documents or.data from Wikileaks." The post then asked, "Just
;
how much

money did , a controversial Russian billionaire investor with ties to the

Vladimir Putin and the Russian government, launder through Metcombank, a Russian regional

bank owned 99.978 percent by , with the money transferred via Deutsche Bank and

Trust Company Americas in New York City, with the money ending up in a private bank

account in the Bank of America that is operated by the Clinton Foundation?"

81. On or about October 14, 2016, CORSI sent a message using Target Account 2 to

STONE, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

82. On or about October 17, 2016, CORSI messaged STONE using Target Account

2, "On Assange, can you call me now - before 2pm[.]" STONE responded, "Missed u - just

landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

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83. On or about October 17, 2016, CORSI, using Target Account 1, emailed STONE

with the subject, "Fwd: ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted source,"

and forwarded an email with the header information stripped out, showing only the body text.

The email read, "Yes[.] I figured this. Assange is threatening Kerry, Ecuador and U.K. He will

drop the goods on them if they move to extradite him. My guess is that he has a set of dead man

files that include Hillary. It's what they used to call a 'Mexican stand offl.]' Only hope is that if

Trump speaks out to save him[.] Otherwise he's dead anyway, once he's dropped what he has. If

HRC wins, Assange can kiss his life away. Interesting gambit Assange has to play out. He's

called Podesta' s bluff and raised him the election."

84. On or about October 18, 2016, CORSI messaged STONE using Target Account

2, "Pls call. Important."

85. . On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice ofWikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta' s business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

86. On or about November 8, 2016, the United States presidential election took place.

87. On or about November 9, 2016, CORSI, using Target Account 2, messaged

STONE, "Congratulations, Roger. He could not have done it without you."

88. On or about November 10, 2016, CORSI messaged STONE using Target

Account 2, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm

in London. Have some interesting news for you."

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I
1'

I
I
11

!I

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 33 of 57

BACKGROUND CONCERNING EMAIL

96. In my training and experience, I have learned the Providers provide a variety of

on-line services, including electronic mail ("email") to the public. The Providers allow

subscribers to obtain email accounts at the domain names identified in the email address

contained in Attachment A and C. Subscribers obtain an account by registering with the

Providers. During the registration process, the Providers ask subscribers to provide basic

personal information. Therefore, the computers of the Providers are likely to contain stored

electronic communications (including retrieved and unretrieved email) for their subscribers and

information concerning subscribers and their use of services, such as account access information,

email transaction information, and account application information. In my training and

experience, such information may constitute evidence of the crimes under investigation because

the information can be used to identify the account's user or users.

97. In my training and experience, email Providers generally ask their subscribers to

provide certain personal identifying information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and

other identifiers, alternative email addresses, and, for paying subscribers, means and source of

payment (including any credit or bank account number). ·In my training and experience, such

information may constitute evidence of the crimes under investigation because the information

can be used to identify the account's user or users. Based on my training and my experience, I

know that, even if subscribers insert false information to conceal their identity, this information

often provides clues to their identity, location, or illicit activities.

98. In my training and experience, email Providers typically retain certain

transactional information about the creation and use of each account on their systems. This

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 34 of 57
I

II

f
I
information can include the date on which the account was created, the length of service, records I
'

oflog-in (i.e., session) times and durations, the types of service utilized, the status of the account

(including whether the account is inactive or closed), the methods used to connect to the account

(such as logging into the account via the Providers' website), and other log files that reflect

usage of the account. In addition, email Providers often have records of the Internet Protocol

address ("IP address") used to register the account and the IP addresses associated with particular

logins to the account. Because every device that connects to the Internet must use an IP address,

IP address information can help to identify which computers or other devices were used to access

the email account.

99. In my training and experience, in some cases, email account users will

communicate directly with an email service Providers about issues relating to the account, such

as technical problems, billing inquiries, or complaints from other users. Email Providers

typically retain records about such communications, including records of contacts between the

user and the Providers' support services, as well as records of any actions taken by the Providers

or user as a result of the communications. In my training and experience, such information may

constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users.

100. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 35 of 57

occupancy" while executing a search warrant at a·residence. For example, email

communications, contacts lists, and images sent (and the data associated with the foregoing, such

as date and time) may indicate who used or controlled the account at a relevant time. Further,

information maintained by the email Providers can show how and when the account was

accessed or used. For example, as described below, email Providers typically log the Internet

Protocol (IP) addresses from which users access the email account, along with the time and date

of that access. By determining the physical location associated with the logged IP addresses,

investigators can understand the chronological and geographic context of the email account

access and use relating to the crime under investigation. This geographic and timeline

information may tend to either inculpate or exculpate the account owner. Additionally,

information stored at the user's account may further indicate the geographic location of the

account user at a particular time (e.g., location information integrated into an image or video sent

via email). Last, stored electronic data may provide relevant insight into the email account

owner's state of mind as it relates to the offense under investigation. For example, information in

the email account may indicate the owner's motive and intent to commit a crime (e.g.,

communications relating to the crime), or consciousness of guilt (e.g., deleting communications

in an effort to conceal them from law enforcement).

101. In my training and experience, information such as search history can help to

show the state of mind of an individual at the time the search was made, as well as the

individuals potential advance knowledge of events, as they search to see if the anticipated event

has occurred.

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INFORMATION REGARDiNG APPLE ID AND iCLOUD 2

102. Apple is a United States company that produces the iPhone, iPad, and iPod

Touch, all of which use the iOS operating system, and desktop and laptop computers based on

the Mac OS operating system.

103. Apple provides a variety of services that can be accessed from Apple devices or,

in some cases, other devices via web browsers or mobile and desktop applications ("apps"). As

described in further detail below, the services include email, instant messaging, and file storage:

• Apple provides email service to its users through email addresses at the

domain names mac.com, me.com, and icloud.com.

• iMessage and FaceTime allow users of Apple devices to communicate in

real-time. iMessage enables users of Apple devices to exchange instant messages ("iMessages")

containing text, photos, videos, locations, and contacts, while Face Time enables those users to

conduct video calls.

• iCloud is a file hosting, storage, and sharing service provided by Apple.

iCloud can be utilized through numerous iCloud-connected services, and can also be used to

store iOS device backups and data associated with third-party apps.

2 The information in this section is based on information published by Apple on its website, including, but
not limited to, the following document and webpages: "U.S. Law Enforcement Legal Process Guidelines," available
at http://images.apple.com/privacy/docs/legal-process-guidelines-us.pdf; "Create and start using an Apple ID,"
available at https://support.apple.com/en-us/HT203993; "iCloud," available at http://www.apple.com/icloud/; "What
does iCloud back up?," available at https://support.apple.com/kb/PH12519; "iOS Security," available at
https://www.apple.com/business/docs/iOS Security Guide.pdf, and "iCloud: How Can I Use iCloud?," available at
https://support.apple.com/kb/PH26502.

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• iCloud-connected services allow users to create, store, access, share, and

synchronize data on Apple devices or via icloud.com on any Internet-connected device. For

example, iCloud Mail enables a user to access Apple-provided email accounts on multiple Apple

devices and on icloud.cotn.. iCloud Photo Library and My Photo Stream can be used to store and

manage images and videos taken from Apple devices, and iCloud Photo Sharing allows the user

to share those images and videos with other Apple subscribers. iCloud Drive can be used to

store presentations, spreadsheets, and other documents. iCloud Tabs and bookmarks enable

iCloud to be used to synchronize bookmarks and webpages opened in the Safari web browsers

on all of the user's Apple devices. iWork Apps, a suite of productivity apps (Pages, Numbers,

Keynote, and Notes), enables iCloud to be used to create, store, and share documents,

spreadsheets, and presentations. iCloud Keychain enables a user to keep website usemame and

passwords, credit card information, and Wi-Fi network information synchronized across multiple

Apple devices.

• Game Center, Apple's social gaming network, allows users of Apple

devices to play and share games with each other.

• Find My iPhone allows owners of Apple devices to remotely identify and

track the location of, display a message on, and wipe the contents of those devices. Find My

Friends allows owners of Apple devices to share locations.

• Location Services allows apps and websites to use information from

cellular, Wi-Fi, Global Positioning System ("GPS") networks, and Bluetooth, to determine a

user's approximate location.

• App Store and iTunes Store are used to purchase and download digital

content. iOS apps can be purchased and downloaded through App Store on iOS devices, or
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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 38 of 57

through iTunes Store on desktop and laptop computers running either Microsoft Windows or

Mac OS. Additional digital content, including music, movies, and television shows, can be

purchased through iTunes Store on iOS devices and on desktop and laptop computers running

either Microsoft Windows or Mac OS.

104. Apple services are accessed through the use of an "Apple ID," an account created·

during the setup of an Apple device or through the iTunes or iCloud services. A single Apple ID

can be linked to multiple Apple services and devices, serving as a central authentication and

syncing mechanism.

105. An Apple ID takes the form ofthe full email address submitted by the user to

create the account; it can later be changed. Users can submit an Apple-provided email address

(often ending [email protected], @me.com, [email protected]) or an email address associated with a

third-party email provider (such as Gmail, Yahoo, or Hotmail). The Apple ID can be used to

access most Apple services (including iCloud, iMessage, and FaceTime) only after the user

accesses and responds to a "verification email'.' sent by Apple to that "primary" email address.

Additional email addresses ("alternate," "rescue," and "notification" email addresses) can also be

associated with an Apple ID by the user.

106. Apple captures information associated with the creation and use of an Apple ID.

During the creation of an Apple ID, the user must provide basic personal information including

the user's full name, physical address, and telephone numbers. The user may also provide means

of payment for products offered by Apple. The subscriber information and password associated

with an Apple ID can be changed by the user through the "My Apple ID" and "iForgot" pages on

Apple's website. In addition; Apple captures the date on which the account was created, the

length of service, records oflog-in times and durations, the types of service utilized, the status of

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 39 of 57

the account (including whether the account is inactive or closed), the methods used to connect to

and utilize the account, the Internet Protocol address ("IP address") used to register and access

the account, and other log files that reflect usage of the account.

107. Additional information is captured by Apple in connection with the use of an

Apple ID to access certain services. For example, Apple maintains connection logs with IP

addresses that reflect a user's sign-on activity for Apple services such as iTunes Store and App

Store, iCloud, Game Center, and the My Apple ID and iForgot pages on Apple's website. Apple

also maintains records reflecting a user's app purchases from App Store and iTunes Store, "call

invitation logs" for FaceTime calls, "query logs" for iMessage, and "mail logs" for activity over

an Apple-provided email account. Records relating to the use of the Find My iPhone service,

including connection logs and requests to remotely lock or erase a device, are also maintained by

Apple.

108. Apple also maintains information about the devices associated with an Apple ID.

When a user activates or upgrades an iOS device, Apple captures and retains the user's IP

address and identifiers such as the Integrated Circuit Card ID number ("ICCID"), which is the

serial number of the device's SIM card. Similarly, the telephone number of a user's iPhone is

linked to an Apple ID when the user signs in to FaceTime or iMessage. Apple also may

maintain records of other device identifiers, including the Media Access Control address ("MAC

address"), the unique device identifier ("UDID"), and the serial number. In addition,

information about a user's computer is captured when iTunes is used on that computer to play

content associated with an Apple ID, and information about a user's web browser may be

captured when used to access services through icloud.com and apple.com. Apple also retains

records related to communications between users and Apple customer service, including

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 40 of 57
I
I
communications regarding a particular Apple device or service, and the repair history for a

device.
I
I 09. Apple provides users with five gigabytes of free electronic space on iC!oud, and

users can purchase additional storage space. That storage space, located on servers controlled by

Apple, may contain data associated with the use of iC!oud-connected services, including: email

(iC!oud Mail); images and videos (iC!oud Photo Library, My Photo Stream, and iC!oud Photo

Sharing); documents, spreadsheets, presentations, and other files (iWork and iC!oud Drive); and

web browser settings and Wi-Fi network information (iC!oud Tabs and iC!oud Keychain).

iCloud can also be used to store iOS device backups, which can contain a user's photos and

videos, iMessages, Short Message Service ("SMS") and Multimedia Messaging Service

("MMS") messages, voicemail messages, call history, contacts, calendar events, reminders,

notes, app data and settings, Apple Watch backups, and other data. Records and data associated

with third-party apps may also be stored on iC!oud; for example, the iOS app for WbatsApp, an

instant messaging service, can be configured to regularly back up a user's instant messages on

iCloud Drive. Some of this data is stored on Apple's servers in an encrypted form but can

nonetheless be decrypted by Apple.

110. Inmy training and experience, evidence of who was using an Apple ID and from

where, and evidence related to criminal activity of the kind described above, may be found in the

files and records described above. This evidence may establish the "who, what, why, when,

where, and how" of the criminal conduct under investigation, thus enabling the United States to

establish and prove each element or, alternatively, to exclude the innocent from further

suspicion.

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I
INFORMATION TO BE SEARCHED AND THINGS TO BE SEIZED I
'I

111. I anticipate executing this warrant under the Electronic Communications Privacy !
1,

Act, in particular 18 U.S.C. §§ 2703(a), 2703(b)(l)(A) and 2703(c)(l)(A), by using the warrant
I
to require Google to disclose to the government copies of the records and other information

(including the content of commuuications) associated with the accounts in Attachment A, C, and

E and particularly described in Section I of Attachment B, D, and E. Upon receipt of the

information described in Section I of Attachments B, D, and F, government-authorized persons

will rev1ew that information to locate the items described in Section II of Attachment B, D, and

F. The items identified in Attachments A-F will also be screened by reviewers not on the

prosecution team to identify and filter out privileged material.

CONCLUSION

112. Based on the forgoing, I request that the Court issue the proposed search warrant.

113. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 42 of 57

REQUEST FOR SEALING

114. I further request thatthe Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

~~
Andrew Mitchell
Special Agent
Federal Bureau ofinvestigation

~
Subscribed and sworn to before me on thisB day of July, 2018.

~&~~
The Honorable Beryl A. Howell
Chief United States District Judge

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I
ATTACHMENT A

Property to be Searched
I
I!
11

This warrant applies to information associated with the following email account:
II
I
1.
I
that is stored at premises owned, maintained, controlled, or operated by CSC Holdings, LLC,

1111 StewartAvenue, Bethpage, NY 11714.

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 44 of 57

ATTACHMENT B

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to the Provider or have been
preserved pursuant to a preservation request under 18 U.S.C. § 2703(f), the Provideris required
to disclose the following information to the government for each account or identifier listed in
Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail described above
in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above in Section I.A,
including log files, dates, times, methods of connecting, ports, dial ups, and/or locations;

e. All records or other information stored by an individual using the account, including
address books, contact and buddy lists, calendar data, pictures, and files;

f. Records or other information regarding the identification of the account described above
in Section I.A, to include application, full name, physical address, telephone numbers and
other identifiers, records of session times and durations, log-in IP addresses associated
with session times and dates, account status, alternative e-mail addresses provided during
registration, all screen names associated with subscribers and/or accounts, all account
names associated with the subscriber,

g. All records indicating the services available to subscribers of the electronic mail address
described above in Section I.A.;

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 45 of 57
I
I
I
II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A
l
Ii
!
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 1030 (fraud
and related activities in connection with computers and 18 U.S.C. § 371 (conspiracy to commit I!
an offense against the United States) for the period from June 15, 2016 to November 10, 2016.
including:
I
a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
'
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone, Julian Assange, or
any individual associated with the Trump Campaign;

All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

c. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

d. Evidence of the times the account was used;

e. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

f. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

g. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

h. All existing printouts from original storage which concern the categories identified in
subsection II.A;

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ATTACHMENT C

Property to be Searched

This warrant applies to information associated with the following Apple account:

1.

that is stored at premises owned, maintained, controlled, or operated by Apple, Inc., located at

One Apple Park Way, Cupertino, California 95014.

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Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 47 of 57

l
ATACHMENTD l
l
Particular Things to be Seized I
I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of Apple, regardless of whether such information is located within or outside
of the United States, including any messages, records, files, logs, or information that have been
deleted but are still available to Apple, or have been preserved pursuant to a request made under
18 U.S.C. § 2703(f), Apple is required to disclose the following information to the government,
in unencrypted form whenever available, for each account or identifier listed in Attachment A:

a All records or other information regarding the identification of the account, to


include full name, physical address, telephone numbers, email addresses (including primary,
alternate, rescue, and notification email addresses, and verification information for each email
address), the date on which the account was created, the length of service, the IP address used to
register the account, account status, associated devices, methods of connecting, and means and
source of payment (including any credit or bank account numbers);

b. All records or other information regarding the devices associated with, or used in
connection with, the account (including all current and past trusted or authorized iOS devices
and computers, and any devices used to access Apple services), including serial numbers, Unique
Device Identifiers ("UDID"), Advertising Identifiers ("IDFA"), Global Unique Identifiers
("GUID"), Media Access Control ("MAC") addresses, Integrated Circuit Card ID numbers
("ICCID"), Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),
Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber
Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Numbers
("MSISDN"), International Mobile Subscriber Identities ("IMSI"), and International Mobile
Station Equipment Identities ("IMEI");

c. The contents of all emails associated with the account, including stored or
preserved copies of emails sent to and from the account (including all draft emails and deleted
emails), the source and destination addresses associated with each email, the date and time at
which each email was sent, the size and length of each email, and the true and accurate header
information including the actual IP addresses of the sender and the recipient of the emails, and
all attachments;

d. The contents of all instant messages associated with the account, including stored
or preserved copies of instant messages (including iMessages, SMS messages, and MMS
messages) sent to and from the account (including all draft and deleted messages), the source and
destination account or phone number associated with each instant message, the date and time at
which each instant message was sent, the size and length of each instant message, the actual IP
addresses of the sender and the recipient of each instant message, and the media, if any, attached
to each instant message;

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e. The contents of all files and other records stored on iCloud, including all iOS
device backups, all Apple and third-party app data, all files and other recordi related to iCloud
Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWork
(including Pages, Numbers, Keynote, and Notes), iCloud Tabs and bookmarks, and iCloud
Keychain, and all address books, contact and buddy lists, notes, reminders, calendar entries,
images, videos, voicemails, device settings, and bookmarks;

f. All activity, connection, and transactional logs for the account (with associated IP
addresses including source port numbers), including FaceTime call invitation logs, messaging
and query logs (including iMessage, SMS, and MMS messages), mail logs, iCloud logs, iTunes ·
Store and App Store logs (including purchases, downloads, and updates of Apple and third-party
apps), My Apple ID and iForgot logs, sign-on logs for all Apple services, Game Center logs,
Find My iPhone and Find My Friends logs, logs associated with web-based access of Apple
services (including all associated identifiers), and logs associated with iOS device purchase,
activation, and upgrades;

g. All records and information regarding locations where the account or devices
associated with the account were accessed, including all data stored in connection with Location
Services, Find My iPhone, Find My Friends, and Apple Maps;

h. All records pertaining to the types of service used;

i. All records pertaining to communications between Apple and any person


regarding the account, including contacts with support services and records of actions taken; and

j. All files, keys, or other information necessary to decrypt any data produced in an
encrypted form, when available to Apple (including, but not limited to, the keybag.txt and
fileinfolist.txt files).

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II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attaclunent A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 1030 (fraud
and related a9tivities in connection with computers and 18 U.S.C. § 371 (conspiracy to conunit
an offense against the United States) for the period from June 15, 2016 to November 10, 2016.
including:

a. All records, information, documents or tangible materials that relate in any way to
conununications regarding hacking, release of hacked material, conununications
with persons or entities associated with WikiLeaks, including but not limited to
Julian Assange, or conununications regarding disinformation, denial, dissembling
or other obfuscation about knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
conununications or meetings involving Roger Stone, Julian
Assange, or any individual associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, and


contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Conununication, information, documentation and records relating to who created,


used, or conununicated with the account or identifier, including records about
their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and conununications regarding wiping software, encryption


or other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be
necessary to access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

i. All existing printouts from original storage which concern the categories
identified in subsection II.A; and

J. All "address books" or other lists of contacts.

41
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 50 of 57

ATTACHMENTE

Property to be Searched

This warrant applies to information associated with the following email account:

that is stored at premises owned, maintained, controlled, or operated by Windstream

Communications, Inc, with offices located at 11001 Executive Center Drive, Little Rock,

Arkansas, 72211.

42
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 51 of 57

ATTACHMENTF

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to the Provider or have been
preserved pursuant to a preservation request under 18 U.S.C. § 2703(f), the Provider is required
to disclose the following information to the government for each account or identifier listed in
Attachment E:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail described above
in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above in Section I.A,
including log files, dates, times, methods of connecting, ports, dial ups, and/or locations;

e. All records or other information stored by an individual using the account, including
address books, contact and buddy lists, calendar data, pictures, and files;

f. Records or other information regarding the identification of the account described above
in Section I.A, to include application, full riame, physical address, telephone numbers and
other identifiers, records of session times and durations, log-in IP addresses associated
with session times and dates, account status, alternative e-mail addresses provided during
registration, all screen names associated with subscribers and/or accounts, all account
names associated with the subscriber,

g. All records indicating the services available to subscribers of the electronic mail address
described above in Attachment E;

43
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 52 of 57

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attaclnnent A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 1030 (fraud
and related activities in connection with computers and 18 U.S.C. § 371 (conspiracy to commit
an offense against the United States) for the period from June 15, 2016 to November 10, 2016.
including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone, Julian Assange, or
any individual associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

i. All existing printouts from original storage which concern the categories identified
above;

44
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 53 of 57

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF Case: 1:18-sc-02403


INFORMATION ASSOCIATED WITH Assigned To: Howell, Beryl A.
Assign. Date: 7/12/2018
Description: Search & Seizure Warrant

MOTION TO SEAL WARRANT AND RELATED DOCUMENTS AND


TO REQUIRE NON-DISCLOSURE UNDER 18 U.S.C. § 2705(b)

The United States of America, moving by and through its undersigned counsel, respectfully

moves the Court for an Order placing the above-captioned warrant and the application and affidavit

in support thereof (collectively herein the "Warrant") under seal, and precluding the provider from

notifying any person of the WmTant pursuant to 18 U.S.C. § 2705(b). In regard to the non-

disclosure, the proposed Order would direct CSC Holdings, an electronic communication and/or

remote computing services provider headquartered in Bethpage, NY not to notify any other person

(except attorneys for CSC Holdings for the purpose of receiving legal advice) of the existence or

content of the Warrant for a period of one year or until further order of the Court.

JURISDICTION AND LEGAL BACKGROUND

1. The Court has the inherent power to seal court filings when appropriate,

including the Warrant. United States v. Hubbard, 650 F.2d 293, 315-16 (D.C. Cir. 1980) (citing

Nixon v. Warner Communications, Inc., 435 U.S. 589, 598 (1978)). The Court may also seal the

Wa!1"ant to prevent serious jeopardy to an ongoing criminal investigation when, as in the present

case, such jeopardy creates a compelling governmental interest in preserving the confidentiality of

the Warrant. See WashingtonPostv. Robinson, 935 F.2d 282, 287-89 (D.C. Cir. 1991).

2. In addition, this Cami has jurisdiction to issue the requested order because it is "a

court of competent jurisdiction" as defined by 18 U.S.C. § 2711. Specifically, the Court is a

"district court of the United States ... that - has jurisdiction over the offense being investigated."
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 54 of 57

18 U.S.C. § 2711(3)(A)(i). As discussed fully below, acts or omissions in furtherance of the

offense under investigation occu1Ted within Washington, D.C. See 18 U.S.C. § 3237.

3. Further, the Court has authority to require non-disclosure of the Warrant under 18

U.S.C. § 2705(b). CSC Holdings provides an "electronic communications service," as defined in

18 U.S.C. § 2510(15), and/or "remote computing service," as defined in 18 U.S.C. § 2711(2). The

Stored Communications Act ("SCA"), 18 U.S.C. §§ 2701-2712, governs how CSC Holdings may

be compelled to supply communications and other records using a subpoena, court order, or search

warrant. Specifically, Section 2703(c)(2) authorizes the Government to obtain certain basic

"subscriber information" using a subpoena, Section 2703(d) allows the Government to obtain other

"non-content" information using a comi order, and Section 2703(a)-(b)(l)(A) allows the

Government to obtain contents of communications using a search warrant. See 18 U.S.C. § 2703.

4. The SCA does not set forth any obligation for providers to notify subscribers about

subpoenas, court orders, or search warrants under Section 2703. However, many have voluntarily

adopted policies of notifying subscribers about such legal requests. Accordingly, when necessary,

Section 2705(b) of the SCA enables the Government to obtain a cou1i order to preclude such

notification. In relevant part, Section 2705(b) provides as follows: 1

(b) Preclusion of notice to subject of governmental access. - A governmental


entity acting under section 2703 ... may apply to a court for an order commanding
a provider ·of electronic communications service or remote computing service to
whom a warrant, subpoena, or court order is directed, for such period as the court
deems appropriate, not to notify any other person of the existence of the wa1Tant,
subpoena, or court order. The court shall enter such an order if it determines that
there is reason to believe that notification of the existence of the warrant, subpoena,
or court order will result in-
(1) endangering the life or physical safety of an individual;
(2) flight from prosecution;

1 Section2705(b) contains additional requirements for legal process obtained pursuant to 18 U.S.C.
§ 2703(b)(1 )(B), but the Government does not seek to use the proposed Order for any legal process
under that provision.

2
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 55 of 57

(3) destruction of or tampering with evidence;


(4) intimidation of potential witnesses; or
(5) otherwise seriously jeopardizing an investigation or unduly delaying a trial.

18 U.S:C. § 2705(b ). The United States District Court for the District of Columbia has made clear

that a nondisclosure order under Section 2705(b) must be issued once the Government makes the

requisite showing about potential consequences of notification:.

The explicit terms of section 2705(b) make clear that if a courts [sic] finds that there
is reason to believe that notifying the customer or subscriber of the court order or
subpoena may lead to one of the deleterious outcomes listed under § 2705(b), the
court must enter an order commanding a service provider to delay notice to a
customer for a period of time that the court dete1mines is appropriate. Once the
government makes the required showing under § 2705(b), the court is required to
issue the non-disclosure order.

In re Application for Order of Nondisclosure Pursuant to 18 US.C. § 2705(b) for Gran_d Jury

Subpoena #GJ2014031422765, 41 F. Supp. 3d 1, 5 (D.D.C. 2014).

5. Accordingly, this motion to seal sets forth facts showing reasonable grounds to

command CSC Holdings not to notify any other person (except attorneys for CSC Holdings for

the purpose of receiving legal advice) of the existence ofthe Subpoena for a period of one year or

until further order of the Comi.

FACTS SUPPORTING SEALING AND NON-DISCLOSURE

6. At the present time, law enforcement officers of the FBI are conducting an

investigation into violations related to 18 U.S.C. § 1030 (unauthorized access of a protected

computer) and 18 U.S.C. § 371 (conspiracy) arising out of the conduct of Roger Stone, Jerome

Corsi, and others. It does not appear that Stone and Corsi are currently aware of the full nature and

scope of the ongoing FBI investigation. Disclosure of this warrant to Corsi could lead him to

destroy evidence or notify others who may delete info1mation relevant to the investigation.

3
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 56 of 57

REQUEST FOR SEALING AND NON-DISCLOSURE

7. In this matter, the government requests that the Warrant be sealed until further order

of the Court and that CSC Holdings and its employees be directed not to notify any other person

of the existence or cof\tent of the Warrant (except attorneys for CSC Holdings for the purpose of

receiving legal advice) for a period of one year or until further order of the Court. Such an order ·

is appropriate because the Warrant relates to an ongoing criminal investigation, the full scope of

which is neither public nor known to the targets of the investigation, and its disclosure may alert

these targets to the ongoing investigation and its scope. Once ale1ied to this investigation, potential

targets would be immediately prompted to destroy or conceal incriminating evidence, alter their

operational tactics to avoid future detection, and otherwise take steps to undermine the

investigation and avoid future prosecution. In patiicular, given that they are known to use

electronic communication and remote computing services, the potential target could quickly and

easily destroy or encrypt digital evidence relating to their criminal activity.

8. Given the complex and sensitive nature of the criminal activity under investigation,

and also given that the criminal scheme may be ongoing, the Government anticipates that this

confidential investigation will continue for the next year or longer. However, should

circumstances change such that court-ordered nondisclosure under Section 2705(b) becomes no

longer needed, the Government will notify the Court and seek appropriate relief.

9. There is, therefore, reason to believe that notification of the existence of the

WmTant will seriously jeopardize the investigation, including by giving the targets an opportunity

to flee from prosecution, destroy or tamper with evidence, and intimidate witnesses. See 18 U.S.C.

§ 2705(b)(2)-(5). Because of such potential jeopardy to the investigation, there also exists a

4
Case 1:19-mc-00029-CRC Document 29-10 Filed 04/28/20 Page 57 of 57

compelling governmental interest in confidentiality to justify the government's sealing request.

See Robinson, 935 F.2d at 287-89.

10. Based on prior dealings with CSC Holdings the United States is aware that, absent

a court order under Section 2705(b) commanding CSC Holdings not to notify anyone about a legal

request, it is CSC Holdings's policy and practice, upon receipt of a warrant seeking the contents

of electronically stored wire or electronic communications for a certain account, to notify the

subscriber or customer of the existence of the warrant prior to producing the material sought.

WHEREFORE, for all the foregoing reasons, the government respectfully requests that the

above-captioned warrant, the application and affidavit in support thereof, and all attachments

thereto and other related materials be placed under seal, and furthermore, that the Court command

CSC Holdings not to notify any other person of the existence or contents of the above-captioned

warrant (except attorneys for CSC Holdings for the purpose of receiving legal advice) for a period

of one year or until further order of the Court.

Respectfully submitted,

ROBERTS. MUELLER, III


Special Counsel

Dated: 1/fZ/?_of'<j By:


Aaron S.J. ZeJi
The Special G, nsel' s Office
(202)-514-0637

5
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 1 of 38

AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


case: 1:18-sc-02524
(Briefly describe the property to be searched )
or identify the person by name and address)
Assigned To : Howell, Beryl A.
)
) Assign . Date: 7/27/2018
INFORMATION ASSOCIATED WITH THREE Description: Search & Seizure Warrant
ACCOUNT STORED AT PREMISES )
CONTROLLED BY GOOGLE )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before August 10, 2018 (not to exceed 14 days)
(;t in the daytime 6:00 a.m. to 10:00 p.m.
0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly retum this warrant and inventory to Hon. Beryl A Howell, Chief U.S. District Judge
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued:

Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge


City and state:
Printed name and title
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 2 of 38

AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 3 of 38

ATTACHMENT A

Property to be Searched

This warrant applies to search history information associated with the following accounts

stored at premises owned, maintained, controlled, or operated by Google, LLC, in Mountain

View, California:
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 4 of 38

ATTACHMENT B

Particular Things to he Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,

custody, or control of the Provider including any messages, records, files, logs, images, videos,

or information that have been deleted but are still available to the Provider or have been

preserved pursuant to a preservation request under 18 U.S.C. § 2703(f), the Provider is required

to disclose the following information to the government for each account or identifier listed in

Attachment A:

a. All search history information associated with each account.

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1030 (unauthorized access of a protected computer); 18

U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud),

and 52 U.S.C. § 30121 (foreign contribution ban) for the period from June 2015 to the present,

including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

2
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 5 of 38

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone, Julian Assange, or
any individual associated with the Trump Campaign;

e. Evidence indicating the account owner's state of mind as it relates to the crimes under
investigation;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Information, documentation and records relating to who created, used, or communicated


with the account or identifier concerning the messages identified above, including records
about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All evidence of wiping software, encryption or other methods to avoid detection by law
enforcement;

g. Evidence of passwords and encryption keys, and other access information that may be
necessary to access the account and other associated accounts;

h. Evidence of credit card and other financial information, including but not limited to, bills
and payment records evidencing ownership of the subject account;

I. Review Protocols

Review of the items described in Attachment A and Attachment B shall be conducted

pursuant to established procedures designed to collect evidence in a manner consistent with

professional responsibility requirements concerning the maintenance of attorney-client and other

operative privileges. When appropriate, the procedures shall include use of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

3
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 6 of 38
AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT


for the JUL 2 7 2018
District of Columbia Clerk, U.S. District & Bankruptcy
Courts for the District of Columbia
In the Matter of the Search of )
(Briefly describe lltc property I Q be search d Case: 1 :18-sc-02524
or ide11tify th person by name and a ldres:;) )
INFORMATION ASSOCIATED WITH THREE ACCOUNTS )
Assigned To : Howell, Beryl A.
STORED AT PREMISES CONTROLLED BY GOOGLE ) Assign. Date: 7/27/2018
) Description: Search & Seizure Warrant

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A
located in the
- - --- District of - - - --California
Northern
- --
person or describe the property to be seized):
- - -- - - - , there is now concealed (identify the
See Attachment B

The basis for the search under Fed. R. Crim. P. 4l(c) is (check one or more):
fi evidence of a crime;
fi contraband, fruits of crime, or other items illegally possessed;
~ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
18 u.s.c. §§ 2, 3, 4, 371 Aiding & Abetting, Accessory after the Fact, Misprision of a Felony, Conspiracy
18 u.s.c. §§ 1030, 1343, 1349 Unauthorized Access of Protected Computer, Wire Fraud, Wire Fraud Conspiracy
52 u.s.c. § 30121 Foreign Contribution Ban
The application is based on these facts:
See attached Affidavit.

t;/ Continued on the attached sheet.


0 Delayed notice of days (give exact ending date if more than 30 days: ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth o~

Reviewed by AUSA/SAUSA: Applicant's signature

jKyle R. Freeny (ASC) Andrew Mitchell, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date:

City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 7 of 38
rl i1
fr i
JUL 21 20!U
Clork, U,s, Ui»trlut l"'4 Dunkruptcy
IN THE UNITED STATES DISTRICT COURT Courts for iha District of Columbia
FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF


Case: 1: 18-sc-02524
INFORMATION ASSOCIATED WITH
THREE ACCOUNTS STORED AT Ass!gned To: Howell, Beryl A
Assign. Date: 7/27/2018 .
PREMISES CONTROLLED BY GOOGLE
Description : Search & Seizure Warrant
AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for search

history information associated with the following Google accounts

("Target Accounts"), stored at

premises owned, maintained, controlled, or operated by Google, LLC ("Google"), a business

with offices located at 1600 Amphitheatre Parkway, Mountain View, CA 94043. The

information to be disclosed by Google and searched by the government is described in the

following paragraphs and in Attachments A and B.

2. I am a Special Agent with the Federal Bureau of Investigation (FBI), and have

been since 2011. As a Special Agent of the FBI, I have received training and experience in

investigating criminal and national security matters.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Accounts contain information relevant to
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 8 of 38

violations of 18 U.S.C. § 2 (aiding and abetting); 18 U.S.C. § 3 (accessory after the fact); 18

U.S .C. § 4 (misprision of a felony); 18 U.S.C. § 371 (conspiracy); 18 U.S.C. § 1030

(unauthorized access of a protected computer); 18 U.S.C. § 1343 (wire fraud); 18 U.S .C. § l 349

(attempt and conspiracy to commit wire fraud); and 52 U.S.C. § 30121 (foreign contribution ban)

(the "Subject Offenses").

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competentjurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), & (c)(l)(A).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below,

including in paragraph 19.

SUMMARY

6. The Special Counsel's Office, with FBI's assistance, is investigating the Russian

government's efforts to interfere in the 2016 presidential election, as well as any links and/or

coordination between the Russian government and individuals associated with the campaign of

President Donald Trump. This includes investigating Roger Stone (STONE) and others known

and unknown, in connection with the hacking of email accounts associated with the Democratic

National Committee (DNC), Democratic Congressional Campaign Committee (DCCC), and

individuals involved in the presidential campaign of Hillary Clinton, as well as the subsequent

dissemination of hacked materials via the persona Guccifer 2.0 and the organization WikiLeaks,

among others.

2
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 9 of 38

7. On or about July 25, 2016, STONE emailed Jerome CORSI to "Get to Assange"

at the Ecuadorian Embassy and "get pending WikiLeaks emails[.]" On or about July 31, 2016,

STONE also instructed CORSI to have contact Julian ASSANGE. On or

. about August 2, 2016, CORSI responded to STONE that the "word is friend in embassy

[ASSANGE] plans 2 more dumps. One shortly after I'm back. 2nd in October. Impact planned

to be very damaging .... Time to let more than Podesta to be exposed as in bed w enemy if they

are not ready to drop HRC." After receipt of that message, on or about August 21, 2016, using

@RogerJStoneJR, Stone tweeted: "Trust me, it will soon the [sic] Podesta's time in the barrel.

#CrookedHillary."

8. Information disclosures subsequently occurred on or about the times CORSI

predicted: On or about August 12, 2016, the day CORSI was scheduled to return to the United

States ("shortly after I'm back"), Guccifer 2.0 released hacked information related to the DCCC.

On or about October 7, 2016, the day the Washington Post published a breaking story about an

Access Hollywood videotape of then-candidate Trump making disparaging remarks about

women, WikiLeaks released emails hacked from the account of John Podesta.

9. Furthermore, on the day of the Access Hollywood video disclosure, there were

phone calls between STONE and CORSI after the Washington Post contacted STONE prior to

publication. At approximately 11 :OOAM, the Washington Post received a tip regarding the

Access Hollywood video. Approximately one hour later, shortly before noon, STONE received

a call from the Washington Post. Approximately ninety minutes later, before 2:00 PM, STONE

called CORSI and they spoke. Approximately forty minutes later, CORSI called STONE and the

two spoke again at length. At approximately 4:00PM, the Washington Post published its story

3
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 10 of 38

regarding the Access Hollywood tape. By approximately 4:30PM, WikiLeaks tweeted out its

first release of emails hacked from John Podesta.

PROBABLE CAUSE

A. Background on Relevant Individuals

i. Roger STONE

11. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of Trump's presidential campaign. As

described further below, STONE also maintained contact with individuals employed by the

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Campaign, including then-campaign chairman Paul MAN AF ORT and deputy chairman Rick

GATES.

ii. Jerome CORSI

12. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WND.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

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B. Russian Government-Backed Hacking Activity During the 2016 Presidential


Election

14. On October 7, 2016, the U.S. Department of Homeland Security and the Office of

the Director of National Intelligence released a joint statement of an intelligence assessment of

Russian activities and intentions during the 2016 presidential election. In the report, the USIC

assessed the following, with emphasis added:

The U.S. Intelligence Community (USIC) is confident that the Russian Government
directed the recent compromises of emails from US persons and institutions, including
from US political organizations. The recent disclosures of alleged hacked emails on sites
like DCLeaks.com and WikiLeaks and by the Guccifer 2.0 online persona are consistent
with the methods and motivations of Russian-directed efforts. These thefts and
disclosures are intended to interfere with the US election process. Such activity is not
new to Moscow-the Russians have used similar tactics and techniques across Europe
and Eurasia, for example, to influence public opinion there. We believe, based on the
scope and sensitivity of these efforts, that only Russia's senior-most officials could have
authorized these activities.

15. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, arid harm her
electability and potential presidency. We further assess Putin and the Russian
Government developed a clear preference for President-elect Trump.

16. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber


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activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls.'"

17. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities

to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

18. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

19. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

20. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

21. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

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those accounts.

22. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

23. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

24. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the

2016 presidential election, including conspiracy to commit authorized access to protected

computers. (Case No . l:18-cr-00125).

C. Roger Stone's Public Interactions with Guccifer 2.0 and WikiLeaks

25. On June 14, 2016, Crowdstrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main paii

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

26. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

27. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem ·

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to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Gucci fer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

28. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

aimed at the Hillary Clinton presidential campaign. Specifically, Stone was asked: "With regard

to the October surprise, what would be your forecast on that given what Julian Assange has

intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with AS SANGE. I believe the next tranche of his documents

pertain to the Clinton Foundation but there's no telling what the October surprise may be." A

few days later, STONE clarified that while he was not personally in touch with ASSANGE, he

had a close friend who served as an intermediary.

29. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

30. On August 13, 2016, STONE posted a tweet using@RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

31. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

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Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 16 of 38

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

32. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chainnan of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

33. On August 21, 2016, using @RogerJStoneJR, STONE tweeted stating: "Trust me,

it will soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview

that same day, STONE reiterated that because of the work of a '"mutual acquaintance' of both

his and [Assange], the public [could] expect to see much more from the exiled whistleblower in

the form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think

Julian Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat.

I believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

34. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

35. On Saturday, October 1, 2016, using@RogerJStoneJr, STONE tweeted,

"Wednesday@ HillaryClinton is done. #WikiLeaks."

36. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement ASSANGE had scheduled for the next day from the balcony

of the Ecuadoran Embassy in London. On the day of the AS SAN GE announcement- which was

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part of WikiLeaks' 10-year anniversary celebration - STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used @RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

37. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

38. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

39. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, John Podesta-referring back to STONE's

August 21, 2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable

assumption to - or at least a reasonable conclusion - that [STONE] had advanced warning [of the

release of his emails] and the Trump campaign had advanced warning about what Assange was

going to do. I think there's at least a reasonable belief that [Assange] may have passed this

information on to [STONE]." Commenting to the NBC News, STONE responded: "I have never

met or spoken with Assange, we have a mutual friend who's traveled to London several times,

and everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

40. On March 27, 2017, CNN reported that a representative ofWikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

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communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

41. On October 13, 2016, while WikiLeaks was in the midst ofreleasing the hacked

Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

account @wikileaks. 1 The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

to rexamine the strategy of attacking me- cordially R."

42. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false ciaims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

43. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

44. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

1
On August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the Twitter
account @RogerJStoneJr.
12
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 19 of 38

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

45. In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE,

the founder of WikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with Julian Assange in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is accurate

and authentic. The New York Times printed the Pentagon Papers which were indisputably stolen

from the government and the courts ruled it was legal to do so and refused to issue an order

restraining the paper from publishing additional articles. If the US government moves on you I

will bring down the entire house of cards. With the trumped-up sexual assault charges dropped I

don't know of any crime you need to be pardoned for - best regards. R." That same day,

@JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the DoJ side

that's coming most strongly from those obsessed with taking down Trump trying to squeeze us

into a deal."

46. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@wikileaks, reading: "I am doing everything possible to address the issues at the highest level of

Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE and Others Regarding


Forthcoming Leaks

4 7. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address On October

17, 2017, Chief Judge Beryl A. Howell issued a search warrant for one of STONE'

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addresses, On or about December 19, 2017, Chief Judge Beryl A.

Howell issued a search warrant for email account. On or about March 14, 2018,

Chief Judge Beryl A. Howell issued a search warrant for STONE's iC!oud account. Information

recovered pursuant to those search warrants indicated the following:

48. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger Stone

so he knows your availability to meet Manafort and DT this coming week." CORSI appears to

have forwarded the message to STONE at who replied to CORSI that,

"May meet Manafort -guarantee nothing."

49. On or about May 18, 2016, CORSI emailed STONE at

with the title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were·

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

50. On July 25, 2016, STONE, using sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

51. On or about July 31, 2016, STONE, using , emailed

CORSI with the subject line, "Call me MON." The body of the email read: should see

Assange[.] should find Bernie [S]anders brother who called Bill a Rapist- turn him for

Trump[.] should find or more proof of Bill getting kicked out."

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52. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at

"Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging. Signs are Fox will have me on mid-Aug.

more post Ailes shakeup underway. Expect Shine to surface victor, for now. Post-DNC bump for

HRC an artifact ofrigged polling. Won't last. I expect presidential campaign to get serious

starting Sept. Still in pre-season games. Time to let more than Podesta to be exposed as in bed w
' .
enemy if they are not ready to drop HRC. That appears to be the game hackers are now about.

Would not hurt to start suggesting HRC old, memory bad, has stroke -- neither he nor she well. I

expect that much of next dump focus, setting stage for Foundation debacle." Investigators

believe that CORSI's reference to a "friend in embassy [who] plans 2 more dumps" refers to

Julian AS SANGE, the founder of WikiLeaks, who resided in Ecuador's London Embassy in

2016.

53. On or about August 5, 2016, an associate of STONE's, emailed

STONE at The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the same

time, STONE told him he had gone to London to meet AS SAN GE. also stated that

in 2018, told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SANGE. STONE told he was joking and

had not actually met AS SANGE.

54. On or about August 15, 2016, CORSI emailed STONE at

"Give me a call today if you can. Despite MSM drumroll that HRC is

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Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 22 of 38

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

55. On or about August 31, 2016, CORSI emailed STONE at

"Did you get the PODESTA writeup." STONE replied "yes."

56. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Yanukovych - Panama papers reveals Podesta hired by

S[b]erbank, Russia's largest financial institution - Podesta$$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

57. On or about September 6, 2016, CORSI emailed STONE at

: "Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

58. On or about September 24, 2016, emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have

secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today." wrote back, "Awaiting secret file. Explosive ... Hope you are well.

Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators, indicated this conversation

concerned possible derogatory information he was trying to obtain from Turkey.

59. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange-what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON and wrote: "You should call Roger. See below. You didn't get from me." BANNON

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Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 23 of 38

wrote back, "I've got important stuff to worry about." The associate responded, "Well clearly he

knows what Assange has. I'd say that's important."

60. On or about October 4, 2016, AS SAN GE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

ASSANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out.before Election Day.

61. On or about October 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

62. That same day, BANNON emailed STONE at "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" Stone replied, "Don't think so BUT his lawyer is a big

democrat."

63. When BANNON spoke with investigators during a voluntary proffer on February

14, 201'8, he initially denied knowing whether the October 4, 2016 email to STONE was about

WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking STONE

about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

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F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

64. According to a publicly available news article,2 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same article,

"Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage from a

2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone, calling

Trump's campaign, 'Access Hollywood,' and NBC for reaction."

65. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

66. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

67. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

68. At approximately 2: 18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

69. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

70. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

2
https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07 /31d747 l 4-8ce5-l l e6-875e-2cl bfe943b66 _ story.html

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On or about August 2, 2016, when CORSI emailed STONE on he

wrote, "I expect that much of next dump focus, setting stage for Foundation debacle."

71. At approximately 6:27PM, sent STONE an email titled,

"WikiLeaks - The Podesta Emails," with a link to the newly-released Podesta emails.

Approximately ten minutes later, STONE, using forwarded

message to CORSI without comment. STONE does not appear to have forwarded the email to

any other individual.

G. STONE Requests to CORSI for "SOMETHING" to Post About Podesta After


STONE Is Accused of Advance Knowledge of the Leak

72. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed-

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will Jose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job

numbers."

73. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

using emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

74. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at both , with a subject line

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"Podesta talking points." Attached to the email was a file labeled, "ROGER STONE podesta

talking points Oct 12 2016.docx." The "talking points" included the statement that "Podesta is at

the heart of a Russian-government money laundering operation that benefits financially Podesta

personally and the Clintons through the Clinton Foundation."

75. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Hotmail Account, "Got them and used them."

76. On or about Thursday, October 13, 2016, CORSI emailed STONE at

"PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I' 11 give you one more - NOBODY YET HAS THIS[:] It looks to me

like skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

77. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

20
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name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

have had some back-channel communications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money did a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through

Metcombank, a Russian regional bank owned 99.978 percent by with the money

transferred via Deutsche Bank and Trust Company Americas in New York City, with the money

ending up in a private bank account in the Bank of America that is operated by the Clinton

Foundation?"

78. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

79. On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now- before 2pm[.]" STONE responded, "Missed u- just landed

JFK - on Infowars now." CORSI wrote back, "Call afterwards. Have some important intel to

share."

80. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

21
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 28 of 38

It's what they used to call a 'Mexican stand offT.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. If HRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election."

81. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

82. On or about October 19, 2016, STONE published an article on Breitbart.corn in

which he claimed he had, "no advance notice of Wikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta's business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

83. On or about November 8, 2016, the United States presidential election took place.

84. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

85. On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in

London. Have some interesting news for you."

22
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 29 of 38

23
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 30 of 38

I. Evidence of Google Searches Relating to the Conduct Under Investigation

92. The search history associated with the account which was

obtained pursuant to search warrant, shows that STONE searched for terms that appear to be

related to the DNC hack and the stolen emails, including his nexus thereto, while logged into the

For example, on or about October 13, 2016, STONE searched for the

words "Roger Stone john Podesta." The search history for appears to

have been deleted between January 18, 2016, and July 23, 2016.

93. During the course of its investigation, the FBI has also identified a series of

searches that appear to relate to the personas Guccifer 2.0 and DCLeaks, which predate the

public unveiling of those two personas. In particular, between May 17, 2016, and June 15, 2016

24
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 31 of 38

(prior to the publication of the Guccifer 2.0 WordPress blog), records from Google show that

searches were conducted for the terms "dcleaks," "guccifer," and ''guccifer june," from IP

addresses within one of two ranges: 172.56.26.0/24, 107.77.216.0/24. 3 These IP ranges are

assigned to T-Mobile USA, Inc., and AT&T Mobility LLC, respectively, and, according to

Google, the searches were all conducted from Florida. On or about June 13, 2018, this Court

issued a search warrant for information associated with these searches and, in particular, for the

full search histories associated with the CookieIDs that conducted the search. 4 As set forth in the

affidavit submitted in support of that search warrant, IP logs obtained from Twitter showed that

STONE used multiple IP addresses within the ranges 172.56.26.0/24 and 107.77.216.0/24 to log

into his Twitter account @RogerJStoneJr. A Facebook account controlled by STONE also used

an IP address within the range 172.56.26.0/24 on or about June 13, 2016, to purchase a Facebook

advertisement.

J. The Target Accounts

94. Subscriber records show that, in addition to STONE

maintains at least two additional Google accounts registered in his name:

a. ("Target Account 1") was created on July 28, 2016,

and uses the recovery email address . According to subscriber records,

Target Account 1 was last accessed on July 5, 2017. Search warrant returns for

how that on or about August 3, 2016, STONE sent an email from

3
Google does not retain full IP addresses for searches conducted more than one year ago. The
truncated IP addresses designated here as 107.77.216.0/24 and 17.56.26.0/24 each encompass a
range .of up to 256 IP addresses.
4
Google assigns unique CookieIDs to searches conducted while a user is not logged into a
Google account. All searches conducted from the same device and browser during a 24-hour
window are associated with the same CookieID.
25
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 32 of 38

to Target Account 1, with no subject, attaching what appears to be an

advertisement for his book tour, entitled, "Clinton's War on Women."

b. "Target Account 2") was created on or about

October 26, 2016, and uses Target Account 1 as the recovery email. Target Account 2 was last

accessed on or about August 8, 2017.

95. The search of STONE's Hotmail account indicates that STONE uses the address

"Target Account 3"). For example, on or about June 27, 2016, Stone

received an email in his account from the "Gmail Team" with the subject,

"Your Gmail address, , has been created." Subscriber records show that

Target Account 3 was created on June 27, 2016, and is registered in the name of"Swash

Buckler." On or about April 16, 2018, this Court issued an order pursuant to 18 U .S.C.

§ 2703(d) for non-content information associated with Target Account 3. Based on a review of

the header information obtained from Google pursuant to that Order, it appears that STONE

frequently used Target Account 3 to communicate with others via the classified advertisement

website Craigslist.org ("Craigslist").

96. This warrant application seeks only search history for the Target Accounts; it

does not seek the content of email communications to and from the Target Accounts. 5 Google

maintains records of the Google searches that a user conducts while signed into a particular

Google email account (provided the user has not disabled the retention of this information). In

my training and experience, I know that users are often not aware of whether or not they are

5
The government is also contemporaneously seeking an order pursuant to 18 U.S.C. § 2703(d)
for non-content information associated with Target Accounts 1 and 2, including header
information.

26
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 33 of 38

experience, such information may constitute evidence of the crimes under investigation because

the information can be used to identify the account's user or users.

99. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with a Google account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of

occupancy" while executing a search warrant at a residence. For example, an account's search

history may indicate who used or controlled the account at a relevant time. Further, information

maintained by the email Providers can show how and when the account was accessed or used.

Additionally, information stored in an account's search history may indicate the geographic

location of the account user at a particular time (e.g., location information integrated into an

image or video sent via email). Lastly, stored electronic data, including search history

information, may provide relevant insight into the email account owner's state of mind as it

relates to the offense under investigation. For example, information in the email account may

indicate the owner's motive and intent to commit a crime (e.g., searches relating to the crime), or

consciousness of guilt (e.g., deleting search history in an effort to conceal information from law

enforcement).

FILTER REVIEW PROCEDURES

100. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

with professional responsibility requirements concerning the maintenance of attorney-client and

28
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 34 of 38

other operative privileges. The procedures include use, if necessary, of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

The government, however, does not at this time anticipate that any of the items described in

Attachment A will contain materials requiring review by a designated filter team .

CONCLUSION

101. Based on the forgoing, I request that the Court issue the proposed search warrant.

102. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

103. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

29
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 35 of 38

Respectfully sHbmitted,

~
Andrew Mitchell
Special Agent
Federal Bureau oflnvestigation

. 1 It',
Subscribed and sworn to before me on thisll_ day of July, 2018.

/1;t4 &irLt/
The Honorable Beryl A. Howell
Chief United States District Judge

30
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 36 of 38

ATTACHMENT A

Property to be Searched

This warrant applies to search history information associated with the following accounts

stored at premises owned, maintained, controlled, or operated by Google, LLC, in Mountain

View; California:
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 37 of 38

ATTACHMENT B

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,

custody, or control of the Provider including any messages, records, tiles, logs, images, videos,

or information that have been deleted but are still available to the Provider or have been

preserved pursuant to a preservation request under 18 U.S.C. § 2703(£), the Provider is required

to disclose the following information to the government for each account or identifier listed in

Attachment A:

a. All search history information associated with each account.

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1030 (unauthorized access of a protected computer); 18

U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud),

and 52 U.S.C. § 30121 (foreign contribution ban) for the period from June 2015 to the present,

including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

2
Case 1:19-mc-00029-CRC Document 29-11 Filed 04/28/20 Page 38 of 38

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Roger Stone, Julian Assange, or
any individual associated with the Trump Campaign;

e. Evidence indicating the account owner's state of mind as it relates to the crimes under
investigation;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Information, documentation and records relating to who created, used, or communicated


with the account or identifier concerning the messages identified above, including records
about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All evidence of wiping software, encryption or other methods to avoid detection by law
enforcement;

g. Evidence of passwords and encryption keys, and other access information that may be
necessary to access the account and other associated accounts;

h. Evidence of credit card and other financial information, including but not limited to, bills
and payment records evidencing ownership of the subject account;

I. Review Protocols

Review of the items described in Attachment A and Attachment B shall be conducted

pursuant to established procedures designed to collect evidence in a manner consistent with

professional responsibility requirements concerning the maintenance of attorney-client and other

operative privileges. When appropriate, the procedures shall include use of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

3
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 1 of 47
AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of ) Case: 1:18-sc-02570


(Rriejly describe the property to be searched )
or identify the person by name and address)
Assigned To: Howell, Beryl A.
)
Assign. Date : 8/2/2018
INFORMATION ASSOCIATED WITH THREE )
) Description: Search & Seizure Warrant
ACCOUNTS STORED AT PREMISES
CONTROLLED BY FACEBOOK )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before August 15, 2018 (nottoexceed /4 days)
~ in the daytime 6:00 a.m. to 10:00 p.m. CJ at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by Jaw and promptly return this warrant and inventory to Hon. Beryl A. Howell, Chief U.S. District Judge
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, wiJJ be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) l'.:J until, the facts justifying, the later specific date of

Date and time issued:

City and state : Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 2 of 47
AO 93 (Rev. I 1/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

11

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer 's signature

PrinJed name and title


Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 3 of 47

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Facebook accounts,

which are stored at premises owned, maintained, controlled, or operated by Facebook, lnc.

("Facebook"), a company headquartered at 1 Hacker Way, Menlo Park, California 94025:

- 1-
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 4 of 47

ATTACHMENT B
I. Information to be disclosed by Facebook

To the extent that the infonnation described in Attachment A is within the possession,

custody, or control of Facebook Inc. ("Face book"), including any messages, records, files, logs, or

information that have been deleted but are still available to Facebook, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(f), Facebook is required to disclose the

following infonnation to the government for each user ID listed in Attachment A:

(a) All contact and personal identifying infonnation, including full name, user

identification number, birth date, gender, contact e-mail addresses, physical address

(including city, state, and zip code), telephone numbers, screen names, websites,

and other personal identifiers.

(b) All activity logs for the account and all other documents showing the user's posts

and other Facebook activities;

(c) All photos and videos uploaded by that user ID and all photos and videos uploaded

by any user that have that user tagged in them, including Exchangeable Image File

("EXIF") data and any other metadata associated with those photos and videos;

(d) All profile information; News Feed information; status updates; videos,

photographs, articles, and other items; Notes; Wall postings; friend lists, including

the friends' Facebook user identification numbers; groups and networks of which

the user is a member, including the groups' Facebook group identification numbers;

future and past event postings; rejected "Friend" requests; comments; gifts; pokes;

tags; and information about the user's access and use of Facebook applications;

-2-
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 5 of 47

(e) All other records of communications and messages made or received by the user,

including all private messages, chat history, video calling history, and pending

"Friend" requests;

(f) All records relating to machine cookies;

(g) All "check ins" and other location information, including records of the user's

latitude and longitude;

(h) All IP logs, including all records of the IP addresses that logged into the account;

(i) All records of the account's usage of the "Like" feature, including all Facebook

posts and all non-Facebook webpages and content that the user has "liked";

(j) All information about the Facebook pages that the account is or was a "fan" of;

(k) All past and present lists of friends created by the account;

(l) All records of Facebook searches performed by the account;

(m) All information about the user's access and use ofFacebook Marketplace;

(n) The types of service utilized by the user;

(o) The length of service (including start date) and the means and source of any

payments associated with the service (including any credit card or bank account

number);

(p) Group identification numbers; a list of users currently registered to the group; a list

of users who like the page; group or page contact information, including all contact

information for the creator and/or administrator of the group and a PDF of the

current status of the group profile page;

(q) All past and present Admins for the group;

(r) The "Creator" of the group;

-3-
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 6 of 47

(s) All privacy settings and other account settings, including privacy settings for

individual Facebook posts and activities, and all records showing which Facebook

users have been blocked by the account;

(t) All records pertaining to communications between Facebook and any person

regarding the user or the user's Facebook account, including contacts with support

services and records of actions taken;

(u) All records related to advertisements and advertising conducted through the

accounts, including advertisements purchased, advertising parameters (search

terms, groups, geographic areas) selected and queried.

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S .C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1030 (unauthorized access of a protected computer); 18

U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud),

and 52 U.S.C. § 30121 (foreign contributions ban) for the period from June 2015 to the present,

including:

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

-4-
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 7 of 47

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Roger Stone, Jerome

Corsi, Julian Assange, and individual associated with WikiLeaks and/or with the

Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

f. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

g. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

h. The source of all funds used to purchase advertisements or make other expenditures

or disbursements in these accounts;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

-5-
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 8 of 47

J. The identity of any non-U.S. person(s)- including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

k. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

-6-
Case
AO 106 (Rev . 04/10) 1:19-mc-00029-CRC
Application for a Search Warrant Document 29-12 Filed 04/28/20 Page 9 of 47

UNITED STATES DISTRICT COURT


for the
District of Columbia
AUG - 2 2018
/lark, U.S. District & Bankruptcy
ourts for the District of Cil/!!mb/a
In the Matter of the Search of )
(Br iefly describe the p roperty to be Searched ) Case: 1: 18-sc-02570
or ;aentify 1he person by name and address) ) Ass!gned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH THREE ACCOUNTS )
STORED AT PREMISES CONTROLLED BY FACEBOOK ,
Assign. Date : 8/2/2018
Description: Search & Seizure Warrant

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A
located in the Northern
- - - -- - - -
District of - - -- --
California
------
, there is now concealed (identify the
person or describe the property to be seized):
See Attachment B

The basis for the search under Fed. R. Crim. P. 41 ( c) is (check one or more):
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
rif property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
18 U.S.C. §§ 2, 3, 4, 371 Aiding & Abetting, Accessory after the Fact, Misprision of a Felony, Conspiracy
18 u.s.c. §§ 1030, 1343, 1349 Unauthorized Access of Protected Computer, Wire Fraud, Wire Fraud Conspiracy
52 U.S.C. § 30121 Foreign Contribution Ban
The application is based on these facts:
See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of days (give exact ending date if more than 30 days: ) is requested ·
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

~___-/
Reviewed by AUSA/SAUSA: Applicant's signature

!Kyle R. Freeny (ASC) Andrew Mitchell, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date:

City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 10 of 47

I
IN THE UNITED STATES DISTRICT COURT AUG - 2 2018
FOR THE DISTRICT OF COLUMBIA Clerk, U.S. District & Bankruptc
Courts for the District of Co/umbra
IN THE MATTER OF THE SEARCH OF
INFORMATION ASSOCIATED WITH Case: 1:18-sc- 02570
THREE FACEBOOK ACCOUNTS Ass!gned To: Howell, Beryl A
STORED AT PREMISES CONTROLLED Assign. Date: 8/2/2o 18
BY FACEBOOK, INC. Description : Search & Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the Facebook accounts associated with the following user IDs:

which are stored at premises owned, maintained, controlled or operated by Facebook Inc., a social

networking company headquartered in Menlo Park, California ("Facebook"). The information to

be disclosed by Facebook and searched by the government is described in the following paragraphs

and in Attachments A and B.

2. I am a Special Agent with the Federal Bureau of Investigation (FBI), and have

been since 2011. As a Special Agent of the FBI, I have received training and experience in

investigating criminal and national security matters.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

-1 -
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 11 of 47

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Accounts contain evidence, fruits, or

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision ofa felony), 18

U.S.C. § 1030 (unauthorized access of a protected computer), 18 U.S.C. § 1343 (wire fraud), and

18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud), and 52 U.S.C.

§ 30121(a)(l)(C) (foreign expenditure ban). There also is probable cause to search the

information described in Attachment A for evidence, contraband, fruits, and/or instrumentalities

of the Subject Offenses, further described in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competentjurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(l)(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) . .. that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

PROBABLE CAUSE

A. Background on Relevant Individuals

i. Roger STONE

6. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

-2-
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 12 of 47

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of Trump's presidential campaign. As

described further below, STONE also maintained contact with individuals employed by the

Campaign, including then-campaign chairman Paul MANAFORT and deputy chairman Rick

GATES.

ii. Jerome CORSI

7. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WNO.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

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B. Russian Government-Backed Hacking Activity During the 2016 Presidential


Election

9. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Government developed a clear preference for President-elect Trump.

10. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls.'"

11. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to _Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities

to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

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in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

12. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

13. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

14. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

15. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

, the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

16. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

17. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

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18. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

presidential election, including conspiracy to comrriit authorized access to protected computers.

(Case No. 1: 18-cr-OO 125).

C. STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

19. On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

20. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.

21. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

22. On August 8, 2016, STONE addressed the Southwest Broward Republican

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Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

aimed at the Hillary Clinton presidential campaign. Specifically, Stone was asked: "With regard

to the October surprise, what would be your forecast on that given what Julian Assange has

intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with AS SAN GE. I believe the next tranche of his documents

pertain to the Clinton Foundation but there's no telling what the October surprise may be." A

few days later, STONE clarified that while he was not personally in touch with ASSANGE, he

had a close friend who served as an intermediary.

23. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

24. On August 13, 2016, STONE posted a tweet using @RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

25. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

26. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washi1;1gton D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

27. On August 21, 2016, using@RogerJStoneJR, STONE tweeted stating: "Trust me,

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it will soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview

that same day, STONE reiterated that because of the work of a "'mutual acquaintance' of both

his and [Assange], the public [could] expect to see much more from the exiled whistleblower in

the form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think

Julian Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat.

I believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

28. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

29. On Saturday, October 1, 2016, using @RogerJStoneJr, STONE tweeted,

"Wednesday @ HillaryClinton is done. #WikiLeaks."

30. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement ASSANGE had scheduled for the next day from the balcony

of the Ecuadoran Embassy in London. On the day of the ASSANGE announcement-which was

part of WikiLeaks' 10-year anniversary celebration - STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used @RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

31. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

32. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

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"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

33. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, John Podesta-referring back to STONE's

August 21, 2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable

assumption to - or at least a reasonable conclusion - that [STONE] had advanced warning [of the

release of his emails] and the Trump campaign had advanced warning about what Assange was

going to do. I think there's at least a reasonable belief that [Assange] may have passed this

information on to [STONE]." Commenting to the NBC News, STONE indicated that he had

never met or spoken with Assange, saying that "we have a mutual friend who's traveled to

London several times, and everything I know is through that channel of communications. I'm not

implying I have any influence with him or that I have advanced knowledge of the specifics of

what he is going to do. I do believe he has all of the e-mails that Hu'ma Abedin and Cheryl Mills,

the Clinton aides, thought were deleted. I hear that through my emissary."

34. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

35. On October 13, 2016, while WikiLeaks was in the midst ofreleasing the hacked

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Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

account @wikileaks. 1 The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

to rexamine the strategy of attacking me- cordially R."

36. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

37. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

38. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

39. In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE,

the founder of WikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with Julian Assange in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is accurate

and authentic. The New York Times printed the Pentagon Papers which were indisputably stolen

1
On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
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from the government and the courts ruled it was legal to do so and refused to issue an order

restraining the paper from publishing additional articles. If the US government moves on you I

will bring down the entire house of cards. With the trumped-up sexual assault charges dropped I

don't know of any crime you need to be pardoned for - best regards. R." That same day,

@JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the DoJ side

that's coming most strongly from those obsessed with taking down Trump trying to squeeze us

into a deal."

40. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@wikileaks, reading: "I am doing everything possible to address the issues at the highest level of

Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks

41. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, On October

17, 2017, Chief Judge Beryl A. Howell issued a search warrant for one of STONE's

addresses, . On or about December 19, 2017, Chief Judge Beryl A.

Howell issued a search warrant for email account. On or about March 14, 2018,

Chief Judge Beryl A. Howell issued a search warrant for STONE's iCloud account. Information

recovered pursuant to those search warrants indicated the following:

42. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger

Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 21 of 47

appears to have forwarded the message to STONE at who replied to

CORSI that, "May meet Manafort -guarantee nothing."

43. On or about May 18, 2016, CORSI emailed STONE at

with the title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

44. On July 25, 2016, STONE, using sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

45. On or about July 31, 2016, STONE, using , emailed

CORSI with the subject line, "Call me MON." The body of the email read: " should see

Assange[.] should find Bernie [S]anders brother who called Bill a Rapist-tum him for

Trump[.] should find or more proof of Bill getting kicked out."

46. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at

"Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging. Signs are Fox will have me on mid-Aug.

more post Ailes shakeup underway. Expect Shine to surface victor, for now. Post-DNC bump for

HRC an artifact of rigged polling. Won't last. I expect presidential campaign to get serious

starting Sept. Still in pre-season games. Time to let more than Podesta to be exposed as in bed w

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enemy if they are not ready to drop HRC. That appears to be the game hackers are now about.

Would not hurt to start suggesting HRC old, memory bad, has stroke -- neither he nor she well. I

· expect that much of next dump focus, setting stage for Foundation debacle." Investigators

believe that CORSI's reference to a "friend in embassy [who] plans 2 more dumps" refers to

Julian AS SAN GE, the founder of WikiLeaks, who resided in Ecuador's London Embassy in

2016.

47. On or about August 5, 2016, an associate of STONE's, emailed

STONE at The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet AS SAN GE. also stated

that in 2018, told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SAN GE. STONE told he was joking and

had not actually met ASSANGE.

48. On or about August 15, 2016, CORSI emailed STONE at

: "Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

49. On or about August 31, 2016, CORSI emailed STONE at

: "Did you get the PODESTA writeup." STONE replied "yes."

50. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Yanukovych - Panama papers reveals Podesta hired by

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 23 of 47

S [b ]erbank, Russia's largest financial institution - Podesta $$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

51. On or about September 6, 2016, CORSI emailed STONE at

: "Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

52. On or about September 24, 2016, emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have

secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today." wrote back, "Awaiting secret file. Explosive ... Hope you are well.

Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators, indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

53. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange-what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON and wrote: "You should call Roger. See below. You didn't get from me." BANNON

wrote back, "I've got important stuff to worry about." The associate responded, "Well clearly he

knows what Assange has. I'd say that's important."

54. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

ASSANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

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information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

55. On or about October 4, 2016, CORSI messaged STONE at his iClciud account:

"Assange made a fool of himself. Has nothing or he would have released it. Tota! BS hype."

56. That same day, BANNON emailed STONE a "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" Stone replied, "Don't think so BUT his lawyer is a big

democrat."

57. When BANNON spoke with investigators during a voluntary proffer on February

14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE was about

WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking STONE

about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

58. According to a publicly available news article, 2 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

2
https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07/3 ld74714-8ce5-1 le6-875e-2cl bfe943b66_story.html

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 25 of 47

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."

59. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

60. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

61. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

62. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

63. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

64. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, when CORSI emailed STONE on , he

wrote, "I expect that much of next dump focus, setting stage for Foundation debacle."

65. At approximately 6:27PM sent STONE an email titled,

"WikiLeaks -The Podesta Emails," with a link to the newly-released Podesta emails.

Approximately ten minutes later, STONE, using , forwarded

message to CORSI without comment. STONE does not appear to have forwarded the email to

any other individual.

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G. STONE Requests to CORSI for "SOMETHING" to Post About Podesta After


STONE Is Accused of Advance Knowledge of the Leak

66. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed -

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job

numbers."

67. On or about Wednesday, October 12, 2016, at approximately 8: 17 AM, STONE,

using emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

68. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at both , with a subject line

"Podesta talking points." Attached to the email was a file labeled, "ROGER STONE podesta

talking points Oct 12 2016.docx." The "talking points" included the statement that "Podesta is at

the heart of a Russian-government money laundering operation that benefits financially Podesta

personally and the Clintons through the Clinton Foundation."

69. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Hotmail Account, "Got them and used them."

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70. On or about Thursday, October 13, 2016, CORSI emailed STONE at

: "PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I'll give you one more - NOBODY YET HAS THIS[:] It looks to me

like skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

71. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

have had some back-channel communications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money did a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through

Metcombank, a Russian regional bank owned 99.978 percent by with the money

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transferred via Deutsche Bank and Trust Company Americas in New York City, with the money

ending up in a private bank account in the Bank of America that is operated by the Clinton

Foundation?"

72. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

a..:..:uuul, 'Tm iu NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

73. On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now- before 2pm[.]" STONE responded, "Missed u - just

landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

74. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

AS SANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand off[.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. IfHRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election."

75. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

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76. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice of Wikileaks' hacking of Podesta' s e-mails."

STONE stated that, "I predicted that Podesta's business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

77. On or about November 8, 2016, the United States presidential election took place.

78. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

79. On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'1? in

London. Have some interesting news for you."

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 30 of 47

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 31 of 47

I. Statements Regarding STONE's Use of Facebook

86. On or about Friday, May 18, 2016, was voluntarily interviewed

by investigators from the Special Counsel's Office. told investigators that he became

STONE's assistant in Florida in 2015, and that during the summer of 2016, he acted as STONE's

right-hand man.

87. According to STONE utilized the services of several individuals to

post social media content to Facebook and Twitter, and that he and STONE both

instructed these individuals about what to post. stated that he purchased a couple

hundred fake Facebook accounts as part of this work (including both new and existing accounts),

and that bloggers working for STONE would try to build what looked like real Facebook

accounts. 3 According to one of the individuals who did work for STONE on

Facebook in 2016 was Everett WILKINSON, a social media marketer and IT expert.

88. further stated that STONE wanted to push out WikiLeaks content

through his Facebook and Twitter accounts, and that content related to the stolen Podesta emails

was pushed out through STONE's Facebook and Twitter accounts.

3
Facebook requires that all users of Facebook accounts use their actual name while registering
and operating their accounts. The terms of service explicitly require that "Facebook users
provide their real names and information .... You will not provide any false personal
information on Facebook, or create an account for anyone other than yourself without
permission."

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 32 of 47

J. The Target Accounts

89. According to subscriber records obtained from Facebook, Target Account 1,

with Facebook user ID , is registered with the vanity name "rogerstone" and

the email address Target Account 1 is associated with

. Based on search warrant returns for STONE's account

, between on or about October 31, 2016 and November 3, 2016,

received receipts from Facebook for the purchase of a number of

advertisements associated with the Target Account, including advertisements with the following

excerpted titles (as set forth in the receipts):

• "BREAKING: New #Wikileaks emails prove that Team ... "

• "Roger Stone talked about WikiLeaks, Donald Trump, ... "

90. Additionally, on or about March 31, 2017, STONE received a Facebook receipt at

his Hotmail account for advertisements associated with Target Account 1, with the following

excerpted titles (as set forth in the receipt):

• "Stone Rebuts Charge of Russian Collusion"

• "I am not in touch with any Russians, don't have ... ,"

• "The charge that I am working for Russian ... ,"

• "In fullest statement yet on DNC hacking ... "

• "ROGER STONE - NO consensus that Guccifer 2.0 is a ... "

91. Target Account 2, with Facebook user ID , is registered

with the vanity name "rogerstone," using the email account . On or

about August 13, 2017, STONE received a receipt from Facebook for several advertisements

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 33 of 47

associated with Target Account 2, including an advertisement with the excerpted title, "I am not

in touch with any Russians ... "

92. Target Account 3 has the Facebook user ID and was created

on or about October 27, 2015. The account is registered in the name of using

the email address and the verified telephone number

According to a public records database, the telephone number is linked to

Search warrant returns for STONE's account contain a notification from

Google indicating that is listed as the recovery email for

Search warrant returns for STONE's account also

contain a number of emails from Facebook to relating to Target

Account 3, which may have bee.n auto-forwarded to STONE's Hotmail account. These emails

include a notification of a password change to Target Account 3 and at least one receipt for a

Facebook advertisement associated with Target Account 3, sent on or about June 30, 2016. At

least one of these emails was then forwarded to account .4

93. As explained further below, in my training and experience, I know that, in

addition to posting content and purchasing advertisements, Facebook accounts can be used to

communicate privately and directly with other users through Facebook's messaging function.

This function is similar to the direct messaging function of Twitter, which STONE used to

communicate with WikiLeaks and ASSANGE in 2016 and 2017.

BACKGROUND CONCERNING FACEBOOK

94. Facebook owns and operates a free-access social networking website of the same

name that can be accessed at http://www.facebook.com. Facebook allows its users to establish

4
told investigators that he would sometimes send emails from STONE's account.

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 34 of 47

accounts with Facebook, and users can then use their accounts to share written news, photographs,

videos, and other information with other Facebook users, and sometimes with the general public.

95. Facebook asks users to provide basic contact and personal identifying information

to Facebook, either during the registration process or thereafter. This information may include the

user's full name, birth date, gender, contact e-mail addresses, Facebook passwords, Facebook

security questions and answers (for password retrieval), physical address (including city, state, and

zip code), telephone numbers, screen names, websites, and other personal identifiers. Facebook

also assigns a user identification number to each account.

96. Facebook users may join one or more groups or networks to connect and interact

with other users who are members of the same group or network. Facebook assigns a group

identification number to each group. A Facebook user can also connect directly with individual

Facebook users by sending each user a "Friend Request." If the recipient of a "Friend Request"

accepts the request, then the two users will become "Friends" for purposes of Facebook and can

exchange communications or view information about each other. Each Facebook user's account

includes a list of that user's "Friends" and a "News Feed," which highlights information about the

user's "Friends," such as profile changes, upcoming events, and birthdays.

97. Facebook users can select different levels of privacy for the communications and

information associated with their Facebook accounts. By adjusting these privacy settings, a

Facebook user can make information available only to himself or herself, to particular Facebook

users, or to anyone with access to the Internet, including people who are not Facebook users. A

Facebook user can also create "lists" of Facebook friends to facilitate the application of these

privacy settings. Facebook accounts also include other account settings that users can adjust to

control, for example, the types of notifications they receive from Facebook.

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 35 of 47

98. Facebook users can create profiles that include photographs, lists of personal

interests, and other information. Facebook users can also post "status" updates about their

whereabouts and actions, as well as links to videos, photographs, articles, and other items available

elsewhere on the Internet. Facebook users can also post information about upcoming "events,"

such as social occasions, by listing the event's time, location, host, and guest list. In addition,

Facebook users can "check in" to particular locations or add their geographic locations to their

Facebook posts, thereby revealing their geographic locations at particular dates and times. A

particular user's profile page also includes a "Wall," which is a space where the user and his or

her "Friends" can post messages, attachments, and links that will typically be visible to anyone

who can view the user's profile.

99. Facebook allows users to upload photos and videos, which may include any

metadata such as location that the user transmitted whens/he uploaded the photo or video. It also

provides users the ability to "tag" (i.e., label) other Facebook users in a photo or video. When a

user is tagged in a photo or video, he or she receives a notification of the tag and a link to see the

photo or video. For Facebook's purposes, the photos and videos associated with a user's account

will include all photos and videos uploaded by that user that have not been deleted, as well as all

photos and videos uploaded by any user that have that user tagged in them.

100. Facebook users can exchange private messages on Facebook with other users.

These messages, which are similar to e-mail messages, are sent to the recipient's "Inbox" on

Facebook, which also stores copies of messages sent by the recipient, as well as other information.

Facebook users can also post comments on the Facebook profiles of other users or on their own

profiles; such comments are typically associated with a specific posting or item on the profile. In

addition, Facebook has a Chat feature that allows users to send and receive instant messages

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 36 of 47

through Facebook. These chat communications are stored in the chat history for the account.

Facebook also has a Video Calling feature, and although Facebook does not record the calls

themselves, it does keep records of the date of each call.

101. If a Facebook user does not want to interact with another user on Facebook, the

first user can "block" the second user from seeing his or her account.

102. Facebook has a "like" feature that allows users to give positive feedback or connect

to particular pages. Facebook users can "like" Facebook posts or updates, as well as webpages or

content on third-party (i.e., non-Facebook) websites. Facebook users can also become "fans" of

particular Facebook pages.

103. Facebook has a search function that enables its users to search Facebook for

keywords, usemames, or pages, among other things.

104. Each Facebook account has an activity log, which is a list of the user's posts and

other Facebook activities from the inception of the account to the present. The activity log includes

stories and photos that the user has been tagged in, as well as connections made through the

account, such as "liking" a Facebook page or adding someone as a friend. The activity log is

visible to the user but cannot be viewed by people who visit the user's Facebook page.

105. Facebook Notes is a blogging feature available to Facebook users, and it enables

users to write and post notes or personal web logs ("blogs"), or to import their blogs from other

services, such as Xanga, LiveJoumal, and Blogger.

106. The Facebook Gifts feature allows users to send virtual "gifts" to their friends that

appear as icons on the recipient's profile page. Gifts cost money to purchase, and a personalized

message can be attached to each gift. Facebook users can also send each other "pokes," which are

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 37 of 47

free and simply result in a notification to the recipient that he or she has been "poked" by the

sender.

107. Face book also has a Marketplace feature, which allows users to post free classified

ads. Users can post items for sale, housing, jobs, and other items on the Marketplace.

108. In addition to the applications described above, Facebook also provides its users

with access to thousands of other applications ("apps") on the Facebook platform. When a

Facebook user accesses or uses one of these applications, an update about that the user's access or

use of that application may appear on the user's profile page.

109. Some Facebook pages are affiliated with groups of users, rather than one individual

user. Membership in the group is monitored and regulated by the administrator or head of the

group, who can invite new members and reject or accept requests by users to enter. Facebook can

identify all users who are currently registered to a particular group and can identify the

administrator and/or creator of the group. Facebook uses the term "Group Contact Info" to

describe the contact information for the group's creator and/or administrator, as well as a PDF of

the current status of the group profile page.

110. Facebook uses the term "Neoprint" to describe an expanded view of a given user

profile. The "Neoprint" for a given user can include the following information from the user' s

profile: profile contact information; News Feed information; status updates; links to videos,

photographs, articles, and other items; Notes; Wall postings; friend lists, including the friends'

Facebook user identification numbers; groups and networks of which the user is a member,

including the groups' Facebook group identification numbers; future and past event postings;

rejected "Friend" requests; comments; gifts; pokes; tags; and information about the user's access

and use of Facebook applications.

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 38 of 47

111. Facebook also retains Internet Protocol ("IP") logs for a given user ID or IP address.

These logs may contain information about the actions taken by the user ID or IP address on

Facebook, including information about the type of action, the date and time of the action, and the

user ID and IP address associated with the action. For example, if a user views a Facebook profile,

that user's IP log would reflect the fact that the user viewed the profile, and would show when and

from what IP address the user did so.

112. Social networking providers like Facebook typically retain additional information

about their users' accounts, such as information about the length of service (including start date),

the types of service utilized, and the means and source of any payments associated with the service

(including any credit card or bank account number). In some cases, Facebook users may

communicate directly with Facebook about issues relating to their accounts, such as technical

problems, billing inquiries, or complaints from other users. Social networking providers like

Facebook typically retain records about such communications, including records of contacts

between the user and the provider's support services, as well as records of any actions taken by

the provider or user as a result of the communications.

113. As explained herein, information stored in connection with a Facebook account

may provide crucial evidence of the "who, what, why, when, where, and how" of the criminal

conduct under investigation, thus enabling the United States to establish and prove each element

or alternatively, to exclude the innocent from further suspicion. In my training and experience, a

Facebook user's "Neoprint," IP log, stored electronic communications, and other data retained by

Facebook, can indicate who has used or controlled the Facebook account. This "user attribution"

evidence is analogous to the search for "indicia of occupancy" while executing a search warrant

at a residence. For example, profile contact information, private messaging logs, status updates,

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 39 of 47

and tagged photos (and the data associated with the foregoing, such as date and time) may be

evidence of who used or controlled the Facebook account at a relevant time. Further, Facebook

account activity can show how and when the account was accessed or used. For example, as

described herein, Facebook logs the Internet Protocol (IP) addresses from which users access their

accuunls along with the time and date. By determining the physical location associated with the

logged IP addresses, investigators can understand the chronological and geographic context of the

account access and use relating to the crime under investigation. Such .information allows

investigators to understand the geographic and chronological context ofFacebook access, use, and

events relating to the crime under investigation. Additionally, Facebook builds geo-location into

some of its services. Geo-location allows, for example, users to "tag" their location in posts and

Facebook "friends" to locate each other. This geographic and timeline information may tend to

either inculpate or exculpate the Facebook account owner. Last, Facebook account activity may

provide relevant insight into the Facebook account owner's state of mind as it relates to the offense

under investigation. For example, information on the Facebook account may indicate the owner's

motive and intent to commit a crime (e.g., information indicating a plan to commit a crime), or

consciousness of guilt (e.g., deleting account information in an effort to conceal evidence from

law enforcement).

114. Therefore, the computers of Facebook are likely to contain all the material

described above, including stored electronic communications and information concerning

subscribers and their use of Facebook, such as account access information, transaction information,

and other account information.

FILTER REVIEW PROCEDURES

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 40 of 47

115. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

with professional responsibility requirements concerning the maintenance of attorney-client and

other operative privileges. The procedures include use, if necessary, of a designated "filter

kaa1," separate aml apart from the investigative team, in order to address potential privileges.

CONCLUSION

116. Based on the forgoing, I request that the Court issue the proposed search warrant.

117. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

118. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 41 of 47

Respectfully submitted,

~
Andrew Mitchell
Special Agent
Federal Bureau of Investigation

8uhscrihecl flnd sworn to before me on this


·?!of August, 2018.
_Ld-ay

The Honorable eryl A. Howell


Chief United States District Judge

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 42 of 47

ATTACHME NT A

Property to be Searched

This warrant applies to information associated with the following Facebook accounts,

which are stored at premises owned, maintained, controlled, or operated by Facebook, Inc.

("Facebook"), a company headquartered at 1 Hacker Way, Menlo Park, California 94025:

-1-
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 43 of 47

ATTACHMENT B

I. Information to be disclosed by Facebook

To the extent that the information described in Attachment A is within the possession,

custody, or control of Facebook Inc. ("Facebook"), including any messages, records, files, logs, or

information that have been deleted but are slill available lo Facebook, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(:t), Facebook is required to disclose the

following information to the government for each user ID listed in Attachment A:

(a) All contact and personal identifying information, including full name, user

identification number, birth date, gender, contact e-mail addresses, physical address

(including city, state, and zip code), telephone numbers, screen names, websites,

and other personal identifiers.

(b) All activity logs for the account and all other documents showing the user's posts

and other Facebook activities;

(c) All photos and videos uploaded by that user ID and all photos and videos uploaded

by any user that have that user tagged in them, including Exchangeable Image File

("EXIF") data and any other metadata associated with those photos and videos;

(d) All profile information; News Feed information; status updates; videos,

photographs, articles, and other items; Notes; Wall postings; friend lists, including

the friends' Facebook user identification numbers; groups and networks of which

the user is a member, including the groups' Facebook group identification numbers;

future and past event postings; rejected "Friend" requests; comments; gifts; pokes;

tags; and information about the user's access and use of Facebook applications;

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Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 44 of 47

(e) All other records of communications and messages made or received by the user,

including all private messages, chat history, video calling history, and pending

"Friend" requests;

(f) All records relating to machine cookies;

(g) All "check ins" and other location information, including records of the user's

lalitude and longitude;

(h) All IP logs, including all records of the IP addresses that logged into the account;

(i) All records of the account's usage of the "Like" feature, including all Facebook

posts and all non-Facebook webpages and content that the user has "liked";

G) All information about the Facebook pages that the account is or was a "fan" of;

(k) All past and present lists of friends created by the account;

(1) All records of Facebook searches performed by the account;

(m) All information about the user's access and use of Facebook Marketplace;

(n) The types of service utilized by the user;

(o) The length of service (including start date) and the means and source of any

payments associated with the service (including any credit card or bank account

number);

(p) Group identification numbers; a list of users currently registered to the group; a list

of users who like the page; group or page contact information, including all contact

information for the creator and/or administrator of the group and a PDF of the

current status of the group profile page;

(q) All past and present Admins for the group;

(r) The "Creator" of the group;

-3-
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 45 of 47

(s) All pnvacy settings and other account settings, including privacy settings for

individual Facebook posts and activities, and all records showing which Facebook

users have been blocked by the account;

(t) All records pertaining to communications between Facebook and any person

regarding the user or the user's Facebook account, including contacts with support

services and records of actions taken;

(u) All records related to advertisements and advertising conducted through the

accounts, including advertisements purchased, advertising parameters (search

terms, groups, geographic areas) selected and queried.

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision ofa felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1030 (unauthorized access of a protected computer); 18

U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud),

and 52 U.S.C. § 30121 (foreign contributions ban) for the period from June 2015 to the present,

including:

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

-4-
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 46 of 47

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Roger Stone, Jerome

Corsi, Julian Assange, and individual associated with WikiLeaks and/or with the

Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

f. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

g. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

h. The source of all funds used to purchase advertisements or make other expenditures

or disbursements in these accounts;

i. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

-5-
Case 1:19-mc-00029-CRC Document 29-12 Filed 04/28/20 Page 47 of 47

J. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

k. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

-6-
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 1 of 189

AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1: 18-sc-02581
or identify the person by name and address) ) Assigned To: Howell, Beryl A.
INFORMATION ASSOCIATED WITH THREE ) Assign. Date : 8/3/2018
ACCOUNTS STORED AT PREMISES CONTROLLED ) Description: Search & Seizure Warrant
BY MICROSOFT, GOOGLE, AND APPLE )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment E

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment F

YOU ARE COMMANDED to execute this warrant on or before August 15, 2018 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to 10:00 p.m. l'J at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell, Chief U.S. District Judge
(United States Magistrate Judge)

l'J Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
['J for _ _ days (not to exceed 30) ['J until, the facts justifying, the later specific date of

Date and time issued: <7/;1/~/ r ~ z :s:r/A_ ____~~


.--~
- "_A_~- - - ' . ! u d ge 's signature

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 2 of 189

AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 3 of 189

ATTACHMENT E

Property to be Searched

This warrant applies to information associated with the following Apple DSID:

created or maintained between March 14, 2018 and the present, that is stored at premises owned,

maintained, controlled, or operated by Apple, Inc., located at One Apple Park Way, Cupertino,

California 95014.

53
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 4 of 189

ATACHMENTF

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment E is within the possession,
custody, or control of Apple, regardless of whether such information is located within or outside
of the United States, including any messages, records, files, logs, or information that have been
deleted but are stilJ available to Apple, or have been preserved pursuant to a request made under
18 U.S.C. § 2703(f), Apple is required to disclose the following information to the government,
in unencrypted form whenever available, for each account or identifier listed in Attachment E:

a. All records or other information regarding the identification of the account, to


include full name, physical address, telephone numbers, email addresses (including primary,
alternate, rescue, and notification email addresses, and verification information for each email
address), the date on which the account was created, the length of service, the IP address used to
register the account, account status, associated devices, methods of connecting, and means and
source of payment (including any credit or bank account numbers);

b. All records or other information regarding the devices associated with, or used in
connection with, the account (including all current and past trusted or authorized iOS devices
and computers, and any devices used to access Apple services), including serial numbers, Unique
Device Identifiers ("UDID"), Advertising Identifiers ("IDFA"), Global Unique Identifiers
("GUID"), Media Access Control ("MAC") addresses, Integrated Circuit Card ID numbers
("ICCID"), Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),
Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber
Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Numbers
("MSISDN"), International Mobile Subscriber Identities ("IMSI"), and International Mobile
Station Equipment Identities ("IMEi");

c. The contents of all emails associated with the account, including stored or
preserved copies of emails sent to and from the account (including all draft emails and deleted
emails), the source and destination addresses associated with each email, the date and time at
which each email was sent, the size and length of each email, and the true and accurate header
information including the actual IP addresses of the sender and the recipient of the emails, and
all attachments;

d. The contents of all instant messages associated with the account, including stored
or preserved copies of instant messages (including iMessages, SMS messages, and MMS
messages) sent to and from the account (including all draft and deleted messages), the source and
destination account or phone number associated with each instant message, the date and time at
which each instant message was sent, the size and length of each instant message, the actual IP
addresses of the sender and the recipient of each instant message, and the media, if any, attached
to each instant message;

54
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 5 of 189

e. The contents of all files and other records stored on iCloud, including all iOS
device backups, all Apple and third-party app data, all files and other records related to iCloud
Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWork
(including Pages, Numbers, Keynote, and Notes), iCloud Tabs and bookmarks, and iCloud
Keychain, and all address books, contact and buddy lists, notes, reminders, calendar entries,
images, videos, voicemails, device settings, and bookmarks;

f. All activity, connection, and transactional logs for the account (with associated IP
addresses including source port numbers), including FaceTime call invitation logs, messaging
and query logs (including iMessage, SMS, and MMS messages), mail logs, iCloud logs, iTunes
Store and App Store logs (including purchases, downloads, and updates of Apple and third-party
apps), My Apple ID and iForgot logs, sign-on logs for all Apple services, Game Center logs,
Find My iPhone and Find My Friends logs, logs associated with web-based access of Apple
services (including all associated identifiers), and logs associated with iOS device purchase,
activation, and upgrades;

g. All records and information regarding locations where the account or devices
associated with the account were accessed, including all data stored in connection with Location
Services, Find My iPhone, Find My Friends, and Apple Maps;

h. All records pertaining to the types of service used;

i. All records pertaining to communications between Apple and any person


regarding the account, including contacts with support services and records of actions taken; and

j. All files, keys, or other information necessary to decrypt any data produced in an
encrypted form, when available to Apple (including, but not limited to, the keybag.txt and
fileinfolist.txt files).

55
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 6 of 189

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A which
consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision ofa felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban), from June
1, 2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

1. All existing printouts from original storage which concern the categories identified in
subsection II.a

56
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 7 of 189
AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT


for the AUG -· 3 2018
District of Columbia
Clerk, U.S. D1strict & BankruptcJr
Courts for t~e District of Golumliia
In the Matter of the Search of )
(Brie.fly describe 1/,e property lu be searched ) Case: 1:18-sc-02581
or identify lh.e person by nam ond addres~) )
INFORMATION ASSOCIATED WITH THREE ACCOUNTS Assigned To : Howell, Beryl A.
STORED AT PREMISES CONTROLLED BY MICROSOFT, j Assign. Date: 8/3/2018
GOOGLE, AND APPLE ) Description: Search & Seizure Warrant

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of pe1jllly that I have reason to believe that on the following person or property (identifjl the person or describe the
properly to be searched and give its location):

See Attachment E
located in the --------
Northern District of California
- - - - - - - - -- - -
, there is now concealed (identify the
person or describe the property to be seized):
See Attachment F

The basis for the search under Fed. R. Crim. P. 4I(c) is (check one or more):
~ evidence of a crime;
~ contraband, fruits of crime, or other i~ems illegally possessed;
ref property designed for use, intended for use, or used in committing a crime;
0 a person to be an-ested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
18 U.S.C. §§ 1505, 1512, 1513 Obstruction of justice, Witness tampering
18 u.s.c. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

r/ Continued on the attached sheet.


0 Delayed notice of _ _ days (give exact ending date if more than 30 days: _ _ _ _ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the arta ed sheet.

Reviewed by AUSA/SAUSA: Applicant's signature

!Aaron Zelinsky {ASC) Andrew Mitchell, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date:

City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 8 of 189

AUG - 3 2018
Cferk, U.S. Dlstrlci & Bankruptcy
Courts for the District of Columbia
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF


INFORMATION ASSOCIATED WITH Case: 1:18-sc-02581
THREE ACCOUNTS STORED AT Assigned Tu : Howell, Beryl A.
PREMISES CONTROLLED BY Assign. Date : 8/3/2018
MICROSOFT, GOOGLE, AND APPLE Description: Search & Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the following:

a. The email account (hereafter "Target Account 1), that is

stored at premises owned, maintained, controlled, or operated by Microsoft, Inc., a business with

offices located at One Microsoft Way, Redmond, Washington, 98052. The information to be

disclosed by Microsoft and searched by the government is described in the following paragraphs

and in Attachments A and B.

b. The email account (hereafter "Target Account 2"), that is

stored at premises owned, maintained, controlled, or operated by Google, Inc., a business with

offices located at 1600 Amphitheatre Parkway, Mountain View, California, 94043. The

information to be disclosed by Google and searched by the government is described in the

following paragraphs and in Attachments C and D.

c. The iCloud account associated with the Apple ~mail account

(hereafter "Target Account 3"), that is stored at premises owned,


Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 9 of 189

maintained, controlled, or operated by Apple, Inc., a business with offices located at I Infinite

Loop, Cupe1iino, California 95014. The information to be disclosed by Apple and searched by

the government is described in the following paragraphs and in Attachment E and F.

2. I, Andrew Mitchell, am a Special Agent with the Federal Bureau of Investigation

(FBI), and have been since 2011. As a Special Agent of the FBI, I have received training and

experience in investigating criminal and national security matters.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Accounts contain communications relevant to

18 U.S.C. § 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4

(misprision of a felony), 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18

U.S.C. § 1030 (unauthorized access of a protected computer); 18 U.S.C. §§ 1505 and 1512

(obstruction of justice), 18 U.S.C. § 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18

U.S.C. § 1349 (attempt and conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign

contribution ban) (the "Subject Offenses").

5. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for Roger STONE's Hotmail address, (Target

Account 1). On October 17, 2017, Chief Judge Howell issued a search warrant for STONE's

Gmail address, (Target Account 2). On or about March 14, 2018, Chief

Judge Howell issued a search warrant for STONE's iCloud account (Target Account 3). This

2
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 10 of 189

warrant seeks to search those accounts from the date each respective warrant was issued to the

present.

JURISDICTION

6. This Court has jurisdiction to issue the requested warrant because it is "a court of

competentjurisdiction" as defined by 18 U.S.C. § 2711. Id.§§ 2703(a), (b)(l)(A), & (c)(l)(A).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below,

including in paragraphs 14, 19, and 61.

SUMMARY

7. This application seeks authority to search, from the date of search warrants

previously issued by the Court to the present, three accounts believed to be used by Roger

STONE: Target Account 1, which is STONE's account; Target Account 2, which is

STONE's account; and Target Account 3, which is STONE's iCloud account. As set

forth herein, there is probable cause to believe that each of the Subject Accounts contains

evidence of the Subject Offenses, including ongoing efforts to obstruct justice, tamper with

witnesses, and make false statements.

8. For example, as set forth in more detail below, in recent months STONE has

reached out to communicate with multiple witnesses he knew or had reason to believe were

scheduled to testify before Congress about interactions with STONE during the 2016 presidential

campaign or were scheduled to meet with the Special Counsel's Office

. After STONE learned that one witness, Randy

CREDICO, was prepared to contradict STONE's congressional testimony, STONE repeatedly

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Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 11 of 189

urged CREDICO to assert the Fifth Amendment and decline to answer questions, and did so

through multiple text messages. In June 2018, STONE instructed his private investigator to

provide him with a full background investigation on another witness, who had

done information technology work for STONE during the campaign

9. In September 2017, STONE released a statement he said he provided to Congress

in which he denied having advance knowledge of "the source or actual content of the Wikileaks

disclosures regarding Hillary Clinton." He also stated publicly that when he tweeted during the

campaign, on August 21, 2016, "it will soon the Podesta's time in the barrel," he was not

referring to the hacking or publication of John Podesta's emails, but rather to "Podesta's business

dealings with Russia." Evidence obtained in the investigation, however, shows the following:

a. On or about July 25, 2016, Roger STONE emailed Jerome CORSI to "Get

to Assange" at the Ecuadorian Embassy and "get pending WikiLeaks emails[.]" Julian

ASSANGE is the founder ofWikiLeaks. On or about July 31, 2016, STONE also instructed

CORSI to have contact ASSANGE. On or about August 2, 2016, CORSI

responded to STONE that the "[w]ord is friend in embassy plans 2 more dumps. One shortly

after I'm back. 2nd in Oct. Impact planned to be very damaging .... Time to let more than

Podesta to be exposed as in bed w enemy if they are not ready to drop HRC." After receipt of

that message, on or about August 21, 2016, using @RogerJStoneJR, STONE tweeted: "Trust me,

it will soon the Podesta's time in the barrel. #CrookedHillary."

b. Information disclosures subsequently occurred on or about the times

CORSI predicted: On or about August 12, 2016, the day CORSI was scheduled to return to the

United States ("shortly after I'm back"), Guccifer 2.0 released hacked information related to the

4
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 12 of 189

Democratic Congressional Campaign Committee (DCCC). On or about October 7, 2016, the day

the Washington Post published a breaking story about an Access Hollywood videotape of then-

candidate Trump making disparaging remarks about women, WikiLeaks released emails hacked

from the account of John Podesta.

c. Furthermore, on the day of the Access Hollywood video disclosure, there

were phone calls between STONE and CORSI after the Washington Post contacted STONE

prior to publication. At approximately 11 :OOAM, the Washington Post received a tip regarding

the Access Hollywood video. Approximately one hour later, shortly before noon, STONE

received a call from the Washington Post. Approximately ninety minutes later, before 2:00PM,

STONE called CORSI and they spoke. Approximately forty minutes later, CORSI called

STONE and the two spoke again at length. At approximately 4:00PM, the Washington Post

published its story regarding the Access Hollywood tape. By approximately 4:30PM, WikiLeaks

tweeted out its first release of emails hacked from John Podesta.

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Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 13 of 189

PROBABLE CAUSE.

A. Background on Relevant Individuals

i. Roger STONE

10. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

11. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WND.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

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Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 14 of 189

B. U.S. Intelligence Community Assessment of Russian Government-Backed Hacking


Activity during the 2016 Presidential Election

13. On October 7, 2016, the U.S. Department of Homeland Security and the Office of

the Director of National Intelligence released a joint statement of an intelligence assessment of

Russian activities and intentions during the 2016 presidential election. In the report, the USIC

assessed the following:

a. The U.S. Intelligence Community ("USIC") is confident that the Russian

Government directed the recent compromises of emails from US persons and institutions,

including from US political organizations. The recent disclosures of alleged hacked emails on

sites like DCLeaks.com and WikiLeaks and by the Guccifer 2.0 online persona are consistent

with the methods and motivations of Russian-directed efforts. These thefts and disclosures were

7
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 15 of 189

intended to interfere with the U.S. election process. Such activity is not new to Moscow-the

Russians have used similar tactics and techniques across Europe and Eurasia, for example, to .

influence public opinion there. We believe, based on the scope and sensitivity of these efforts,

that only Russia's senior-most officials could have authorized these activities.

14. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

a. "Russian President Vladimir Putin ordered an influence campaign in 2016

aimed at the US presidential election. Russia's goals were to undermine public faith in the US

democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her

electability and potential presidency. We further assess Putin and the Russian Government

developed a clear preference for President-elect Trump."

b. · The USIC also described, at a high level, some of the techniques that the

Russian government employed during its interference. The USIC summarized the efforts as a

"Russian messaging strategy that blends covert intelligence operations-such as cyber activity-

with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

c. With respect to "cyber activity," the USIC assessed that "Russia's

intelligence services conducted cyber operations against targets associated with the 2016 US

presidential election, including targets associated with both major US political parties." Further,

"[i]n July 2015, Russian intelligence gained access to Democratic National Committee (DNC)

networks and maintained that access until at least June 2016." The USIC attributed these cyber

8
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 16 of 189

activities to the Russian GRU, also known as the Main Intelligence Directorate: "GRU

operations resulted in the compromise of the personal e-mail accounts of Democratic Party

officials and political figures. By May, the GRU had exfiltrated large volumes of data from the

DNC." The GRU is the foreign military intelligence agency of the Russian Ministry of Defense,

and is Russia's largest foreign intelligence agency.

d. With respect to the release of stolen materials, the USIC assessed "with

high confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

e. Guccifer 2.0, who claimed to be an independent Romanian hacker, made

multiple contradictory statements and false claims about his identity throughout the election.

C. Additional Hacking Activity by Individuals Associated with the GRU

15. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 campaign through at least

November 1, 2016.

16. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

17. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later posted on DCLeaks.

9
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 17 of 189

18. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

19. On or about July 13, 2018, a grand jury in this District indicted eleven GRU

officers for knowingly and intentionally conspiring to hack into the computers of U.S. persons

and entities involved in the 2016 U.S. presidential election, steal documents from those

computers, and stage releases of stolen documents in order to interfere with the election. The

victims of the hacking and releases included the DNC, the Democratic Congressional Campaign

Committee ("DCCC"), and the chairman of the Clinton campaign (John Podesta). See United

States v. Viktor Borisovich Netyksho, et al. (I: 18-cr-215) (D.D.C.). 1

D. Roger STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

20. On June 14, 2016, Crowdstrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors. The media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

21. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

1A twelfth defendant was charged with conspiring to infiltrate computers of organizations responsible for
administering elections, including state boards of election, secretaries of state, and companies that supply software
and other technology used to administer elections.

10
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 18 of 189

22. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world

would see for themselves how the Democrats had rigged the game."

23. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by ASSANGE to Russia

Today (RT) several days earlier about an upcoming "October Surprise" aimed at the Hillary

Clinton presidential campaign. Specifically, STONE was asked: "With regard to the October

surprise, what would be your forecast on that given what Julian Assange has intimated he's

going to do?" STONE responded: "Well, it could be any number of things. I actually have

communicated with Assange. I believe the next tranche of his documents pertain to the Clinton

Foundation but there's no telling what the October surprise may be." A few days later, STONE

clarified that while he was not personally in touch with ASSANGE, he had a close friend who

served as an intermediary.

24. On August 12, 2016, Gucci fer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

25. On August 13, 2016, Stone posted a tweet using @RogerJStoneJr calling Guccifer

2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day, Guccifer 2.0's

11
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 19 of 189

Twitter account was reinstated.

26. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

27. On August 18, 2016, Paul Manafort, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign.

28. As noted above, on August 21, 2016, using@RogerJStoneJR, STONE tweeted:

"Trust me, it will soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN

interview that same day, STONE reiterated that because of the work of a "'mutual acquaintance'

of both his and [ASSANGE], the public [could] expect to see much more from the exiled

whistleblower in the form of strategically-dumped Clinton email batches." He added: "Well,

first of all, I think Julian Assange is a hero ... I think he's taking on the deep state, both

Republican and Democrat. I believe that he is in possession of all of those emails that Huma

Abedin and Cheryl Mills, the Clinton aides, believe they deleted. That and a lot more. These are

like the Watergate tapes."

29. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a wee~ly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

30. On Saturday, October 1, 2016, using@RogerJStoneJr, STONE tweeted,

"Wednesday @ HillaryClinton is done. #WikiLeaks."

31. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement AS SAN GE had scheduled for the next day from the balcony

12
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 20 of 189

of the Ecuadoran Embassy in London. On the day of the ASSANGE announcement- which was

part of WikiLeaks' I 0-year anniversary celebration - STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used@RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

32. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

33. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

34. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta- referring back to STONE's August 21,

2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

35. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

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Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 21 of 189

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

E. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

36. On August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the

Twitter account @RogerJStoneJr. Information recovered from the search of that account

includes the following:

a. On October 13, 2016, while WikiLeaks was in the midst of releasing the

hacked Podesta emails, @RogerJStoneJr sent a private direct message to the Twitter account

@wikileaks. Thi~ account is the official Twitter account of WikiLeaks and has been described as

such by numerous news reports. The message read: "Since I was all over national TV, cable and

print defending WikiLeaks and assange against the claim that you are Russian agents and

debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

b. Less than an hour later, @wikileaks responded by direct message: "We

appreciate that. However, the false claims of association are being used by the democrats to

undermine the impact of our publications. Don't go there if you don't want us to correct you."

c. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"c01Tect\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

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d. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

e. In addition, @RogerJStoneJr also exchanged direct messages with

ASSANGE. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with ASSANGE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

f. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

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F. STONE's Communications with STONE, and Others Regarding


Forthcoming Leaks

37. As indicated above, on September 11, 2017, Chief Judge Howell issued a search

warrant for STONE's address, (Target Account 1); on

October 17, 2017, Chief Judge Howell issued a search warrant for STONE's address,

(Target Account 2); and on or about March 14, 2018, Chief Judge

Howell issued a search warrant for STONE's iCloud account (Target Account 3). In addition,

on or about December 19, 2017, Chief Judge Howell issued a search warrant for

email account. Information recovered pursuant to those search warrants includes the following:

a. On or about May 15, 2016, emailed CORSI: "Here is my

flight schedule. Need to get something confirmed now .... " CORSI responded, "I copied

Roger Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

appears to have forwarded the message to STONE at Target Account 1, who replied to CORSI

that, "May meet Manafort -guarantee nothing."

b. On or about May 18, 2016, CORSI emailed STONE at Target Account 1

with the title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

c. On July 25, 2016, STONE, using Target Account 1, sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

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[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

d. On or about July 31, 2016, STONE, using Target Account 1, emailed

CORSI with the subject line, "Call me MON." The body of the email read: ,should see

Assange[.] should find Bernie [SJ anders brother who called Bill a Rapist - turn him for

Trump[.] should find or more proof of Bill getting kicked out."

e. As noted above, on or about August 2, 2016 (approximately 19 days

before STONE publicly tweeted about "Podesta's time in the barrel"), CORSI emailed STONE

at Target Account 1: "Word is friend in embassy plans 2 more dumps. One shottly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued: "Signs are Fox

will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HRC an artifact of rigged polling. Won't last. I expect

presidential campaign to get serious starting Sept. Still in pre-season games. Time to let more

than Podesta to be exposed as in bed w enemy if they are not ready to drop HRC. That appears

to be the game hackers are now about. Would not hurt to start suggesting HRC old, memory

bad, has stroke -- neither he nor she well. I expect that much of next dump focus, setting stage

for Foundation debacle." Investigators believe that CORSI's reference to a "friend in embassy

[who] plans 2 more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in

2016.

f. On or about August 5, 2016, , an associate of STONE's,

emailed Stone at Target Account 1. The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded, "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

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same time, STONE told him he had gone to London to meet ASSANGE. also stated

that in 2018 told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SAN GE. STONE tol he was joking and

had not actually met ASSANGE. 2

g. On or about August 15, 2016, CORSI emailed STONE at Target Account

1: "Give me a call today if you can. Despite MSM drumroll that HRC is already elected, it's not

over yet. More to come than anyone realizes. Won't really get started until after Labor Day. I'm

in NYC this week. Jerry."

h. On or about August 31, 2016, CORSI emailed STONE at Target Account

1: "Did you get the PODESTA writeup." STONE replied "[y]es."

1. On or about August 31, 2016, CORSI messaged STONE at Target

Account 3, "Podesta paid $I 80k to invest in Uranium One - was hired by Rosatom in Giustra

scandal. Podesta now under FBI investigation - tied to Ukraine Yanukovych - Panama papers

reveals Podesta hired by S[b]erbank, Russia's largest financial institution - Podesta$$$ ties to

Russia undermine Clinton false narrative attempting to tie Trump to Putin."

J. On or about September 6, 2016, CORSI emailed STONE at Target

Account 1: "Roger[,] Is NY Post going to ~se the Pedesta [sic] stuff?"

k. On or about September 24, 2016, emailed CORSI, "I will

have much more on Turkey. Need a back channel highly sensitive stuff." CORSI responded,

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"We have secure back channel through Roger. I saw him again in NYC last Friday and spoke to

him about it again today." wrote back, "Awaiting secret file. Explosive ... Hope you

are well. Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me

posted about file[.]" In a subsequent meeting with investigators, indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

I. On or about October 3, 2016, an associate of STONE emailed STONE at

Target Account 2 and asked: "Assange - what's he got? Hope it's good." STONE wrote back,

"It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will be

out in Jan. Many scores will be settled." The associate forwarded the email to Steve BANNON,

who was CEO of the Campaign at the time, and wrote: "You should call Roger. See below. You

didn't get from me." BANNON wrote back, "I've got important stuff to worry about." The

associate responded, "Well clearly he knows what Assange has. I'd say that's important."

m. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

ASSANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

n. On or about October 4, 2016, CORSI messaged STONE at Target

Account 3, "Assange made a fool of himself. Has nothing or he would have released it. Total

BS hype."

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o. That same day, BANNON emailed STONE at Target Account 2, "What

was that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are

going to kill him and the London police are standing done [sic]." BANNON wrote back, "He

didn't cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawyer is a

big democrat."

p. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

G. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released

38. According to a publicly available news article, 3 at approximately 11AM on

Friday, October 7, 2016, Washington Pos.t reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood' and NBC for reaction."

39. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE which STONE did not answer.

3
https://www.washingtonpost.com/lifestyle/style/the-cal\er-had-a-lewd-tape-of-donald-trump-then-the-race-was-
on/2016/10/07/31 d74714-8ce5-l le6-875e-2c 1bfe943b66_story.html

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40. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

41. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

42. At approximately 2: 18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

43. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

44. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE on Target Account 1, "I expect that much

of next dump focus, setting stage for Foundation debacle."

45. At approximately 6:27PM, an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks - The Podesta Emails," with a link to the .

newly-released Podesta emails. Approximately ten minutes later, STONE, using Target

Account 2, forwarded message to CORSI without comment. STONE does not appear

to have forwarded the email to any other individual.

H. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

46. On or about October 8, 2016, STONE, using Target Account 3, messaged

CORSI, "Lunch postponed-have to go see T." CORSI responded to STONE, "Ok. I

understand." Approximately twenty minutes later, CORSI texted, "Clintons know they will lose

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a week of Paula Jones media with T attacking Foundation, using Wikileaks Goldman Sachs

speech comments, attacking badjob numbers."

47. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

using Target Account 2, emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM, "need your BEST podesta pieces." CORSI

wrote back at approximately 8:54AM, "Ok. Monday. The remaining stuff on Podesta is

complicated. Two articles in length. I can give you in raw form the stuff I got in Russian

translated but to write it up so it's easy to understand will take weekend. Your choice?"

48. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails, as noted above. At approximately 3:25PM,

CORSI emailed STONE at both Target Account 1 and 2 with the subject line "Podesta talking

points." Attached to the email was a file labeled, "ROGER STONE podesta talking points Oct

122016.docx." The "talking points" included the statement that "Podesta is at the heart of a

Russian-government money laundering operation that benefits financially Podesta personally and

the Clintons through the Clinton Foundation."

49. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via Target Account 1: "Got them and used them."

50. On or about Thursday, October 13, 2016, CORSI emailed STONE at Target

Account 2: "PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to CLINTON

FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could post under my

by-line since I am the one under attack by Podesta and now Mook." CORSI wrote back to

STONE, "I'll give you one more -NOBODY YET HAS THIS[:] It looks to me like

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Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 30 of 189

skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation(.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about $$$ received via

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

51. On or about Thursday, October 13, 2016, at approximately 6:30PM, CORSI sent

STONE an email at Target Account 2, with the subject, "ROGER STONE article RUSSIAN

MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and JOHN

PODESTA." The text stated: "Roger[,] You are free to publish this under your own name."

That same day, STONE posted a blog post with the title, "Russian Mafia money laundering, the

Clinton Foundation and John Podesta." In that post, STONE wrote, "although I have had some

back-channel communications with Wikileaks I had no advance notice about the hacking of Mr.

Podesta nor I have I ever received documents or data from Wikileaks." The post then asked,

"Just how mucl:i money did , a controversial Russian billionaire investor with

ties to the Vladimir Putin and the Russian government, launder through Metcombank, a Russian

regional bank owned 99.978 percent by , with the money transferred via Deutsche

Bank and Trust Company Americas in New York City, with the money ending up in a private

bank account in the Bank of America that is operated by the Clinton Foundation?"

52. On or about October 14, 2016, CORSI sent a message to STONE at Target

Account 3, "I'm in.NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

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53. On or about October 17, 2016, CORSI messaged STONE at Target Account 3,

"On Assange, can you call me now- before 2pm[.]" STONE responded, "Missed u - just

landed JFK - on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

54. On or about October 17, 2016, CORSI emailed STONE at Target Accounts 1

and 2 with the subject, "Fwd: ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted

source," and forwarded an email with the header information stripped out, showing only the

body text. The email read, "Yes[.] I figured this. Assange is threatening Kerry, Ecuador and

U.K. He will drop the goods on them if they move to extradite him. My guess is that he has a set

of dead man files that include Hillary. It's what they used to call a 'Mexican stand offl.]' Only

hope is that if Trump speaks out to save him[.] Otherwise he's dead anyway, once he's dropped

what he has. If HRC wins, Assange can kiss his life away. Interesting gambit Assange has to

play out. He's called Podesta's bluff and raised him the election."

55. On or about October 18, 2016, CORSI messaged STONE at Target Account 3,

"Pis call. Important."

56. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had "no advance notice of Wikileaks' hacking of Podesta's e-mails."

STONE stated, "I predicted that Podesta's business dealings would be exposed. I didn't hear it

from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

57. On or about November 8, 2016, the United States presidential election took place.

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58. On or about November 9, 2016, CORSI messaged STONE at Target Account 3,

"Congratulations, Roger. He could not have done it without you."

59. On or about November 10, 2016, CORSI messaged STONE at Target Account 3,

"Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in London.

Have some interesting news for you."

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J. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikileaks

61. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCI). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic assertions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta's email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such assertions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trust me, it will soon be the Podesta' s
time in the barrel. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but
does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrutiny ....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.

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I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
Assange to independently confirm this repot1, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
info11nation proved to be correct. I have referred publicly to this journalist as an,
"intermediary" , "go-between" and "mutual friend." All of these monikers are equally
true.

62. Tn a document dated March 26, 2018 titled "Minority Views," Democratic

members of HPSCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in
communication with Assange or communication through an intermediary with Assange,
you were only referring to a single fact that you had confirmed with the intermediary -
MR. STONE: That-
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is correct, even though it was repeated to me on numerous separate
occasions.

63. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an article on his website, stonecoldtruth.com, titled "Is it the Podesta's

Time in the Barrel Yet?" In that article, STONE stated: "[I]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

K. STONE's Use of Target Account 3 to Message Randy CREDICO about STONE's


"Back channel"

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64. On November 19,2017, Randy CREDICO (who, as described further below,

STONE publicly identified as his "intermediary" to ASSANGE), messaged STONE on Target

Account 3, "My lawyer wants to see me today." STONE responded, "'Stonewall it. Plead the

fifth. Anything to save the plan' ........ Richard Nixon[.]" CREDI CO responded, "Ha ha."

65. On or about November 21, 2017, CREDICO messaged STONE on Target

Account 3, "I was told that the house committee lawyer told my lawyer that I will be getting a

subpoena[.]" STONE wrote back, "That was the point at which your lawyers should have told

them you would assert your 5th Amendment rights if compelled to appear." They continued to

message, and CREDICO wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To

do what ? Nothing happening in DC the day before Thanksgiving - why are u busting my

chops?"

66. On or about November 24, 2017, STONE, using Target Account 3, texted

CREDICO, "Assange is a journalist and a damn good one- meeting with him is perfectly legal

and all you ever told me was he had the goods [o]n Hillary and would publish them - which he

himself said in public b4 u told me. It's a fucking witchunt [sic]." CREDICO replied, "I told

you to watch his tweets. That's what I was basing it on. I told you to watch his Tweets in

October not before that I knew nothing about the DNC stuffT,] I just followed his tweets[.]"

STONE responded, "U never said anything about the DNC but it was August." CREDICO

wrote back, "It was not August because I didn't interview him or meet him until August 26th[.]

That was my first communication with his secretary in London, August 26th." STONE wrote

back, "Not the way I remember it- oh well I guess Schiff will try to get one of us indicted for

perjury[.]"

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67. STONE and CREDICO continued to exchange messages via Target Account 3,

and on November 24, 2017, CREDICO wrote to STONE, "Forensic evidence proves that there is

no back Channel. So now you can relax."

68. On or about November 28, 2017, CREDICO tweeted a copy of a subpoena he

received from HPSCI that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

69. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that, "Credico merely[]

confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credico never said he knew or had any information as to source or

content of the material."

70. On or about December 1, 2017, CREDICO messaged STONE on Target

Account 3, stating, "I don't know why you had to lie and say you had a back Channel now I had

to give all of my forensic evidence to the FBI today what a headache[.] 4 You could have just told

him the truth that you didn't have a back Channel they now know that I was not in London until

September of this year[.] You had no back-channel and you could have just told the truth ...

You want me to cover you for perjury now[.]" STONE responded, "What the fuck is your

problem? Neither of us has done anything wrong or illegal. You got the best press of your life

and you can get away with asserting for 5th Amendment rights if u don't want talk about AND if

4 Contrary to his statement, CREDICO has not provided any forensic evidence to the FBI.

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you turned over anything to the FBI you're a fool." CREDICO responded, "You open yourself

up to six counts of perjury[.] But I'm sure that wasn't sworn testimony so you're probably

clear[.] Council for the committee knows you never had a back Channel and if you had just told

the truth wouldn't have put me in this bad spot ... you should go back ... and amend your

testimony and tell them the truth." CREDICO repeated: "you need to amend your testimony

before I testify on the 15th." STONE replied, "If you testify you're a fool. Because of tromp

[sic] I could never get away with a ce1iain [sic] my Fifth Amendment rights but you can. I

guarantee you you [sic] are the one who gets indicted for perjury if you're stupid enough to

testify[.]"

71. STONE and CREDICO continued to message each other on or about December 1,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fuck off good night." CREDI CO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

72. On or about December 13, 2017, according to public reporting, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

73. STONE and CREDICO continued to exchange messages via Target Account 3,

and on or about January 6, 2018, CREDICO indicated to STONE that he was having dinner with

a reporter. STONE responded, "Hope u don't fuck Up my efforts to get Assange a pardon[.]"

CREDICO messaged STONE, "I have the email from his chief of staff August 25th 2016

responding to an email I sent to WikiLeaks website email address asking you would do my

show[.] That was my initial contact."

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74. On or about January 8, 2018, CREDTCO messaged STONE on Target Account 3

stating: "Embassy logs ... + 17 other pieces of information prove that I did not have any

conversations with Assange until September of last year."

75. CREDICO and STONE continued to message each other, and on or about January

25, 2018, CREDICO wrote to STONE on Target Account 3: "You lied to the house Intel

committee ... But you'll get off because you're friends with Trump so don't wo1Ty. I have all

the forensic evidence[.] I was not a ba[ck] Channel and I have all those emails from September

of 2016 to prove it[.]"

76. On or about April 13, 2018, news reports stated that CREDICO had shown

reporters copies of email messages he had received from STONE in the prior few days that

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

from you," referring to CREDICO's therapy dog. CREDICO stated that it was "certainly scary .

. . When you start bringing up my dog, you're crossing the line[.]" 5

77. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

5
https://www.yahoo.com/news/comedian-randy-credico-says-trump-adviser-roger-stone-threatened-dog-
135911370.html

6
https ://www.motherjones.com/ po Iitics/2018/0 5/ro ger-stone-to-associate-prepare-to-die/

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He was depressed about it. Or was he lying." The article noted that CREDICO stated he did not

have prostate cancer and did not have any such discussion with STONE.

L. STONE's Use of the Target Accounts to Communicate with Individuals Related to


the Investigation

78. On May 17, 2018, Chief Judge Howell issued an order for the use of pen-trap

devices on Target Account 1 and Target Account 2. The information obtained from that order,

along with information obtained from toll records, revealed that STONE has continued to use

Target Account 1 and Target Account 2, and that he has used them to communicate with

individuals related to the investigation.

79. For example, STONE and communicated twice on May 28 and May

29, 2018 using Target Account 1. , a former associate of STONE's, was

interviewed by the Special Counsel's Office on or aboi1t May 2, 2018. Toll records _show that

and STONE communicated multiple times on May 5, 2018, and STONE

communicated with using Target Account 1 on June 1, 2018 and June 6, 2018.

, a private investigator who had previously worked with STONE and who was hired

by STONE to research individuals associated with this case (as described further below),

communicated with STONE on Target Account 1 at least four times between May 27, 2018 and

July 12, 2018.

80. STONE has also used Target Account 2 to communicate with individuals

associated with this investigation.

a. For example, between May 23, 2018 and the present, STONE and CORSI

exchanged at least five messages using Target Account 2. In the same time period, STONE

exchanged at least 75 emails with CREDICO using Target Account 2.

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b. Also in this same time period, STONE emailed at least

ten times using Target Account 2. is a former employee of STONE. On May 9,

2018, FBI agents approached and That day,

and again on May 10, 2018, communicated by phone with

STONE. Overall, between May 23, 2018 and the present, STONE exchanged over 100 emails

wit , using Target Account 2. In addition, between on or about June 14, 2018 and

June 17, 2018, and STONE exchanged five emails using Target Account 2.

81. STONE has also used a phone number associated with Target Account 3 to

communicate with a private investigator hired by STONE. was

interviewed by investigators on June 7, 2018, and subsequently info1med investigators that in

June 2018, STONE instructed him to conduct a full background investigation on

who had been employed by STONE during the Campaign as an info1mation technology

specialist.

also told investigators that in June 2018, STONE instructed him to find

an address for CREDICO that could be used to serve CREDICO with legal process.

told investigators that his primary form of communication with STONE is by text

message on Target Account 3.

BACKGROUND CONCERNING EMAIL

82. In my training and experience, I have learned the Providers provide a variety of

on-line services, including electronic mail ("email") to the public. The Providers allow

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subscribers to obtain email accounts at the domain names identified in the email address

contained in Attachment A and C. Subscribers obtain an account by registering with the

Providers. During the registration process, the Providers ask subscribers to provide basic

personal information. Therefore, the computers of the Providers are likely to contain stored

electronic communications (including retrieved and unretrieved email) for their subscribers and

information concerning subscribers and their use of services, such as account access information,

email transaction information, and account application information. In my training and

experience, such information may constitute evidence of the crimes under investigation because

the information can be used to identify the account's user or users.

83. In my training and experience, email Providers generally ask their subscribers to

provide certain personal identifying information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and

other identifiers, alternative email addresses, and, for paying subscribers, means and source of

payment (including any credit or bank account number). In my training and experience, such

information may constitute evidence of the crimes under investigation because the information

can be used to identify the account's user or users. Based on my training and my experience, I

know that, even if subscribers insert false information to conceal their identity, this information

often provides clues to their identity, location, or illicit activities.

84. In my training and experience, email Providers typically retain certain

transactional information about the creation and use of each account on their systems. This

information can include the date on which the account was created, the length of service, records

of log-in (i.e., session) times and durations, the types of service utilized, the status of the account

(including whether the account is inactive or closed), the methods used to connect to the account

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(such as logging into the account via the Providers' website), and other log files that reflect

usage of the account. In addition, email Providers often have records of the Internet Protocol

address ("IP address") used to register the account and the IP addresses associated with particular

logins to the account. Because every device that connects to the Internet must use an IP address,

IP address infonnation can help to identify which computers or other devices were used to access

the email account.

85. In my training and experience, in some cases, email account users will

communicate directly with an email service Providers about issues relating to the account, such

as technical problems, billing inquiries, or complaints from other users. Email Providers

typically retain records about such communications, including records of contacts between the

user and the Providers' support services, as well as records of any actions taken by the Providers

or user as a result of the communications. In my training and experience, such information may

constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users.

86. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of

occupancy" while executing a search warrant at a residence. For example, email

communications, contacts lists, and images sent (and the data associated with the foregoing, such

as date and time) may indicate who used or controlled the account at a relevant time. Further,

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infonnation maintained by the email Providers can show how and when the account was

accessed or used. For example, as described below, email Providers typically log the Internet

Protocol (IP) addresses from which users access the email account, along with the time and date

of that access. By determining the physical location associated with the logged IP addresses,

investigators can understand the chronological and geographic context of the email account

access and use relating to the crime under investigation. This geographic and timeline

information may tend to either inculpate or exculpate the account owner. Additionally,

information stored at the user's account may further indicate the geographic location of the

account user at a particular time (e.g., location information integrated into an image or video sent

via email). Last, stored electronic data may provide relevant insight into the email account

owner's state of mind as it relates to the offense under investigation. For example, information in

the email account may indicate the owner's motive and intent to commit a crime (e.g.,

communications relating to the crime), or consciousness of guilt (e.g., deleting communications

in an effort to conceal them from law enforcement).

87. In my training and experience, information such as search history can help to

show the state of mind of an individual at the time the search was made, as well as the

individuals potential advance knowledge of events, as they search to see if the anticipated event

has occurred.

INFORMATION REGARDING APPLE ID AND iCLOUD 7

The information in this section is based on information published by Apple on its website, including, but
not limited to, the following document and webpages: "U.S. Law Enforcement Legal Process Guidelines," available
at htip://images.apple.com/ privacy/docs/.l cgal-process-guidelines-us.pdf; "Create and start using an Apple ID,"
available at https://support.apple.com/en-us/HT203993; "iCioud," available at htlj ://www.apple.com/ icloud/; "What
does iCloud back up?," available at https://suppo1i .app le.corn/kb/PHJ 25 19; "iOS Security," available at
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88. Apple is a United States company that produces the iPhone, iPad, and iPod

Touch, all of which use the iOS operating system, and desktop and laptop computers based on

the Mac OS operating system.

89. Apple provides a variety of services that can be accessed from Apple devices or,

in some cases, other devices via web browsers or mobile and desktop applications ("apps"). As

described in further detail below, the services include email, instant messaging, and file storage:

a. Apple provides email service to its users through email addresses at the

domain names mac.com, me.corn, and icloud.com.

b. iMessage and FaceTirne allow users of Apple devices to communicate in

real-time. iMessage enables users of Apple devices to exchange instant messages ("iMessages")

containing text, photos, videos, locations, and contacts, while FaceTime enables those users to

conduct video calls.

c. iCloud is a file hosting, storage, and sharing service provided by Apple.

iCloud can be utilized through numerous iCloud-connected services, and can also be used to

store iOS device backups and data associated with third-party apps.

d. iCloud-connected services allow users to create, store, access, share, and

synchronize data on Apple devices or via icloud.com on any Internet-connected device. For

example, iCloud Mail enables a user to access Apple-provided email accounts on multiple Apple

devices and on icloud.com. iCloud Photo Library and My Photo Stream can be used to store and

manage images and videos taken from Apple devices, and iCloud Photo Sharing allows the user

https://www.appl e.com/business/docs/iOS Security Guide.pdt: and "iCloud: How Can I Use iCloud?," available at
https://suppo1t.apple.com/kb/PH26502.

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to share those images and videos with other Apple subscribers. iCloud Drive can be used to

store presentations, spreadsheets, and other documents. iCloud Tabs and bookmarks enable

iCloud to be used to synchronize bookmarks and webpages opened in the Safari web browsers

on all of the user's Apple devices. iWork Apps, a suite of productivity apps (Pages, Numbers,

Keynote, and Notes), enables iCloud to be used to create, store, and share documents,

spreadsheets, and presentations. iCloud Keychain enables a user to keep website username and

passwords, credit card information, and Wi-Fi network information synchronized across multiple

Apple devices.

e. Game Center, Apple's social gaming network, allows users of Apple

devices to play and share games with each other.

f. Find My iPhone allows owners of Apple devices to remotely identify and

track the location of, display a message on, and wipe the contents of those devices. Find My

Friends allows owners of Apple devices to share locations.

g. Location Services allows apps and websites to use information from

cellular, Wi-Fi, Global Positioning System ("GPS") networks, and Bluetooth, to determine a

user's approximate location.

h. App Store and iTunes Store are used to purchase and download digital

content. iOS apps can be purchased and downloaded through App Store on iOS devices, or

through iTunes Store on desktop and laptop computers running either Microsoft Windows or

Mac OS. Additional digital content, including music, movies, and television shows, can be

purchased through iTunes Store on iOS devices and .on desktop and laptop computers running

either Microsoft Windows or Mac OS.

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90. Apple services are accessed through the use of an "Apple ID," an account created

during the setup of an Apple device or through the iTunes or iCloud services. A single Apple ID

can be linked to multiple Apple services and devices, serving as a central authentication and

syncing mechanism.

91. An Apple ID takes the form of the full email address submitted by the user to

create the account; it can later be changed. Users can submit an Apple-provided email address

(often ending in @icloud.com, @me.com, [email protected]) or an email address associated with a

third-party email provider (such as Gmail, Yahoo, or Hotmail). The Apple ID can be used to

access most Apple services (including iCloud, iMessage, and FaceTime) only after the user

accesses and responds to a "verification email" sent by Apple to that "primary" email address.

Additional email addresses ("alternate," "rescue," and "notification" email addresses) can also be

associated with an Apple ID by the user.

92. Apple captures information associated with the creation and use of an Apple ID.

During the creation of an Apple ID, the user must provide basic personal information including

the user's full name, physical address, and telephone numbers. The user may also provide means

of payment for products offered by Apple. The subscriber information and password associated

with an Apple ID can be changed by the user through the "My Apple ID" and "iForgot" pages on

Apple's website. In addition, Apple captures the date on which the account was created, the

length of service, records of log-in times and durations, the types of service utilized, the status of

the account (including whether the account is inactive or closed), the methods used to connect to

and utilize the account, the Internet Protocol address ("IP address") used to register and access

the account, and other log files that reflect usage of the account.

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93. Additional information is captured by Apple in connection with the use of an

Apple ID to access certain services. For example, Apple maintains connection logs with IP

addresses that reflect a user's sign-on activity for Apple services such as iTunes Store and App

Store, iC!oud, Game Center, and the My Apple ID and iForgot pages on Apple's website. Apple

also maintains records reflecting a user's app purchases from App Store and iTunes Store, "call

invitation logs" for FaceTime calls, "query logs" for iMessage, and "mail logs" for activity over

an Apple-provided email account. Records relating to the use of the Find My iPhone service,

including connection logs and requests to remotely lock or erase a device, are also maintained by

Apple.

94. Apple also maintains information about the devices associated with an Apple ID.

When a user activates or upgrades an iOS device, Apple captures and retains the user's IP

address and identifiers such as the Integrated Circuit Card ID number ("ICCID"), which is the

serial number of the device's SIM card. Similarly, the telephone number of a user's iPhone is

linked to an Apple ID when the user signs in to FaceTime or iMessage. Apple also may

maintain records of other device identifiers, including the Media Access Control address ("MAC

address"), the unique device identifier ("UDID"), and the serial number. In addition,

information about a user's computer is captured when iTunes is used on that computer to play

content associated with an Apple ID, and information about a user's web browser may be

captured when used to access services through icloud.com and apple.com. Apple also retains

records related to communications between users and Apple customer service, including

communications regarding a particular Apple device or service, and the repair history for a

device.

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95. Apple provides users with five gigabytes of free electronic space on iCloud, and

users can purchase additional storage space. That storage space, located on servers controlled by

Apple, may contain data associated with the use of iCloud-connected services, including: email

(iCloud Mail); images and videos (iCloud Photo Library, My Photo Stream, and iCloud Photo

Sharing); documents, spreadsheets, presentations, and other files (iWork and iCloud Drive); and

web browser settings and Wi-Fi network information (iCloud Tabs and iCloud Keychain).

iCloud can also be used to store iOS device backups, which can contain a user's photos and

videos, iMessages, Short Message Service ("SMS") and Multimedia Messaging Service

("MMS") messages, voicemail messages, call history, contacts, calendar events, reminders,

notes, app data and settings, Apple Watch backups, and other data. Records and data associated

with third-party apps may also be stored on iCloud; for example, the iOS app for WhatsApp, an

instant messaging service, can be configured to regularly back up a user's instant messages on

iCloud Drive. Some of this data is stored on Apple's servers in an encrypted form but can

nonetheless be decrypted by Apple.

96. In my training and experience, evidence of who was using an Apple ID and from

where, and evidence related to criminal activity of the kind described above, may be found in the

files and records described above. This evidence may establish the "who, what, why, when,

where, and how" of the criminal conduct under investigation, thus enabling the United States to

establish and prove each element or, alternatively, to exclude the innocent from further

susp1c10n.

INFORMATION TO BE SEARCHED AND THINGS TO BE SEIZED

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97. l anticipate executing this warrant under the Electronic Communications Privacy

Act, in particular 18 U.S.C. §§ 2703(a), 2703(b)(l)(A) and 2703(c)(l)(A), by using the warrant

to require Google to disclose to the government copies of the records and other information

(including the content of communications) associated with the accounts in Attachment A, C, and

E and particularly described in Section I of Attachment B, D, and F. Upon receipt of the

information described in Section I of Attachments B, D, and F, government-authorized persons

will review that information to locate the items described in Section II of Attachment B, D, and

F. The items identified in Attachments A-F will also be screened by reviewers not on the

prosecution team to identify and filter out privileged material.

CONCLUSION

98. Based on the forgoing, I request that the Court issue the proposed search warrant.

99. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

100. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

k~___/
Andrew Mitchel l
Special Agent
Federal Bureau of Investigation

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Subscribed and sworn to before me on this .P'{ y of August, 2018.

/ )/ ~_./ ,

- ~-~ /;Arr-Cz,1/
The Honorable Beryl A. Howell
Chief United States District Judge

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ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the email address:

created or maintained between September 11, 2017 and present, that is stored at premises owned,

maintained, controlled, or operated by Microsoft Corp., d/b/a Hotmail, a company headquartered

at One Microsoft Way, Redmond, WA 98052.

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ATTACHMENT B

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to the Provider or have been
preserved pursuant to a preservation request under 18 U.S.C. § 2703(f), the Provider is required
to disclose the following infor1!1ation to the government for each account or identifier listed in
Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail described above
in Section I.A. above;

c. AJI internet search data including all queries and location data;

d. All transactional information of all activity of the account described above in Section I.A,
including log files, dates, times, methods of connecting, ports, dial ups, and/or locations;

e. All records or other information stored by an individual using the account, including
address books, contact and buddy lists, calendar data, pictures, and files;

f. Records or other information regarding the identification of the account described above
in Section I.A, to include application, full name, physical address, telephone numbers and
other identifiers, records of session times and durations, log-in IP addresses associated
with session times and dates, account status, alternative e-mail addresses provided during
registration, all screen names associated with subscribers and/or accounts, all account
names associated with the subscriber,

g. All records indicating the services available to subscribers of the electronic mail address
described above in Section I.A.;

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II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C . § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban) from June 1,
2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, , Julian Assange,
Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

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1. All existing printouts from original storage which concern the categories identified in
subsection II.a

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ATTACHMENT C

Property to be Searched

This warrant applies to information associated with the following Google account:

created or maintained between October 17, 2017 and the present, that is stored at premises

owned, maintained, controlled, or operated by Google, Inc., a business with offices located at

1600 Amphitheatre Parkway, Mountain View, CA 94043.

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ATTACHMENT D

Particular Things to be Seized

I. Files and Accounts to be produced by Google, Inc.

To the extent that the information described in Attachment C is within the possession,
custody, or control of Google, Inc. including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to Google or have been preserved
pursuant to a preservation request under 18 U.S .C. § 2703(f), Google is required to disclose the
following information to the government for each account or identifier listed in Attachment C:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail
described above in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above


in Section I.A, including log files, dates, times, methods of connecting, ports, dial ups,
and/or locations;

e. All records or other information stored by an individual using the account,


including address books, contact and buddy lists, calendar data, pictures, and files;

f. All records or other information regarding the identification of the account


described above in Section I.A, to include application, full name, physical address,
telephone numbers and other identifiers, records of session times and durations, the date
on which the account was created, the length of service, the types of service utilized, the
IP address used to register the account, log-in IP addresses associated with session times
and dates, account status, alternative e-mail addresses provided during registration, all
screen names associated with subscribers and/or accounts, all account names associated
with the subscriber, methods of connecting, log files, means and source of payment
(including any credit or bank account number), and detailed billing records;

g. All records indicating the services available to subscribers of the


electronic mail address described above in Section I.A.;

h. Google+ subscriber information, circle information, including name of


circle and members, contents of posts, comments, and photos, to include date and
timestamp;

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1. Google Drive files created, accessed or owned by the account;

j. YouTube subscriber information, private videos and files, private


messages, and comments;

k. Google+ Photos contents to include all images, videos and other files, and
associated upload/download date and timestamp;

l. Google Talk and Google Hangouts conversation logs associated with the
account.

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II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment C which
consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban), from June
1, 2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

1. All existing printouts from original storage which concern the categories identified in
subsection II.a

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ATTACHMENTE

Property to be Searched

This warrant applies to information associated with the following Apple DSID:

created or maintained between March 14, 2018 and the present, that is stored at premises owned,

maintained, controlled, or operated by Apple, Inc., located at One Apple Park Way, Cupertino,

California 95014.

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ATACHMENTF

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment E is within the possession,
custody, or control of Apple, regardless of whether such information is located within or outside
of the United States, including any messages, records, tiles, logs, or information that have been
deleted but are still available to Apple, or have been preserved pursuant to a request made under
18 U.S.C. § 2703(£), Apple is required to disclose the following infonnation to the government,
in unencrypted form whenever available, for each account or identifier listed in Attachment E:

a. All records or other information regarding the identification of the account, to


include full name, physical address, telephone numbers, email addresses (including primary,
alternate, rescue, and notification email addresses, and verification information for each email
address), the date on which the account was created, the length of service, the IP address used to
register the account, account status, associated devices, methods of connecting, and means and
source of payment (including any credit or bank account numbers);

b. All records or other information regarding the devices associated with, or used in
connection with, the account (including all current and past trusted or authorized iOS devices
and computers, and any devices used to access Apple services), including serial numbers, Unique
Device Identifiers ("UDID"), Advertising Identifiers ("IDFA"), Global Unique Identifiers
("GUID"), Media Access Control ("MAC") addresses, Integrated Circuit Card ID numbers
("ICCID"), Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),
Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber
Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Numbers
("MSISDN"), International Mobile Subscriber Identities ("IMSI"), and International Mobile
Station Equipment Identities ("IMEI");

c. The contents of all emails associated with the account, including stored or
preserved copies of emails sent to and from the account (including all draft emails and deleted
emails), the source and destination addresses associated with each email, the date and time at
which each email was sent, the size and length of each email, and the true and accurate header
information including the actual IP addresses of the sender and the recipient of the emails, and
all attachments;

d. The contents of all instant messages associated with the account, including stored
or preserved copies of instant messages (including iMessages, SMS messages, and MMS
messages) sent to and from the account (including all draft and deleted messages), the source and
destination account or phone number associated with each instant message, the date and time at
which each instant message was sent, the size and length of each instant message, the actual IP
addresses of the sender and the recipient of each instant message, and the media, if any, attached
to each instant message;

54
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e. The contents of all files and other records stored on iCloud, including all iOS
device backups, all Apple and third-party app data, all files and other records related to iCloud
Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWork
(including Pages, Numbers, Keynote, and Notes), iCloud Tabs and bookmarks, and iCloud
Keychain, and all address books, contact and buddy lists, notes, reminders, calendar entries,
images, videos, voicemails, device settings, and bookmarks;

f. All activity, connection, and transactional logs for the account (with associated IP
addresses including source port numbers), including FaceTime call invitation logs, messaging
and query logs (including iMessage, SMS, and MMS messages), mail logs, iCloud logs, iTunes
Store and App Store logs (including purchases, downloads, and updates of Apple and third-party
apps), My Apple ID and iForgot logs, sign-on logs for all Apple services, Game Center logs,
Find My iPhone and Find My Friends logs, logs associated with web-based access of Apple
services (including all associated identifiers), and logs associated with iOS device purchase,
activation, and upgrades;

g. All records and information regarding locations where the account or devices
associated with the account were accessed, including all data stored in connection with Location
Services, Find My iPhone, Find My Friends, and Apple Maps;

h. All records pertaining to the types of service used;

i. All records pertaining to communications between Apple and any person


regarding the account, including contacts with support services and records of actions taken; and

j. All files, keys, or other information necessary to decrypt any data produced in an
encrypted form, when available to Apple (including, but not limited to, the keybag.txt and
fileinfolist.txt files).

55
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II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A which
consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction.of justice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban), from June
1, 2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

1. All existing printouts from original storage which concern the categories identified in
subsection II.a

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AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1: 18-sc-02583
or identify the person by name and address) ) Ass!gned To: Howell, Beryl A.
INFORMATION ASSOCIATED WITH THREE ) Assign. Date : 8/3/2018
ACCOUNTS STORED AT PREMISES CONTROLLED )
BY MICROSOFT, GOOGLE, AND APPLE ) Description: Search & Seizure Warrant

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property lo be searched and give its location):

See Attachment C

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment D

YOU ARE COMMANDED to execute this warrant on or before August 15, 2018 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to I 0:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell, Chief U.S. District Judge
(United States Magistrale Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued:

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 128 of 189

AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of :

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 129 of 189

ATTACHMENT C

Property to be Searched

This warrant applies to information associated with the following Google account:

created or maintained between October 17, 2017 and the present, that is stored at premises

owned, maintained, controlled, or operated by Google, Inc., a business with offices located at

1600 Amphitheatre Parkway, Mountain View, CA 94043.

49
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ATTACHMENTD

Particular Things to be Seized

I. Files and Accounts to be produced by Google, Inc.

To the extent that the information described in Attachment C is within the possession,
custody, or control of Google, Inc. including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to Google or have been preserved
pursuant to a preservation request under 18 U.S.C. § 2703(f), Google is required to disclose the
following information to the government for each account or identifier listed in Attachment C:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail
described above in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above


in Section I.A, including log files, dates, times, methods of connecting, ports, dial ups,
and/or locations;

e. All records or other information stored by an individual using the account,


including address books, contact and buddy lists, calendar data, pictures, and files;

f. All records or other information regarding the identification of the account


described above in Section I.A, to include application, full name, physical address,
telephone numbers and other identifiers, records of session times and durations, the date
on which the account was created, the length of service, the types of service utilized, the
IP address used to register the account, log-in IP addresses associated with session times
and dates, account status, alternative e-mail addresses provided during registration, all
screen names associated with subscribers and/or accounts, all account names associated
with the subscriber, methods of connecting, log files, means and source of payment
(including any credit or bank account number), and detailed billing records;

g. All records indicating the services available to subscribers of the


electronic mail address described above in Section I.A.;

h. Google+ subscriber information, circle information, including name of


circle and members, contents of posts, comments, and photos, to include date and
timestamp;

50
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i. Google Drive files created, accessed or owned by the account;

j. YouTube subscriber infonnation, private videos and files, private


messages, and comments;

k. Google+ Photos contents to include all images, videos and other files, and
associated upload/download date and timestamp;

I. Google Talk and Google Hangouts conversation logs associated with the
account.

51
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II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment C which
consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban), from June
1, 2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

1. All existing printouts from original storage which concern the categories identified in
subsection II.a

52
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AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT f


for the AUG ._ 3 201H
District of Columbia Clerk, U. S, lllstrlct & Bankrupic}
Courts for t~e District of Columola
In the Matter of the Search of ) Case: 1:18-sc-02583
(Briefly describe rhe property to be searched )
or ide11tifj1 l11e person by name a11d,addrcss) ) Assigned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH THREE ACCOUNTS ) Assign. Date : 8/3/2018
STORED AT PREMISES CONTROLLED BY MICROSOFT, )
GOOGLE, AND APPLE )
Description: Search & Seizure Warrant

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its localion):

See Attachment C
located in the - - - - - District of
- - -Northern California
- -- - - - - - - - - -
, there is now concealed (identify the
person or describe the property to be seized):
See Attachment D

The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
~ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
18 u.s.c. §§ 1505, 1512, 1513 Obstruction of justice, Witness tampering
18 U.S.C. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of _ _ days (give exact ending date if more than 30 days: _ _ _ _ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on ~

Reviewed by AUSA/SAUSA: Applicam's signature

!Aaron Zelinsky (ASC) Andrew Mitchell, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date:
.Judge 's signature

City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and litle
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 134 of 189

]: i,'
AUG - 3 2018
Clerk, U.S. ()istrlc:t & Bunkruptc}'
Courts tor the District of Columbia
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

lN THE MATTER OF THE SEARCH OF Case: 1: 18-sc-02583


INFORMATION AS SOCIATED WITH Assigned To : Howell, Beryl A.
THREE ACCOUNTS STORED AT Assign . Date : 8/3/2018 .
PREMISES CONTROLLED BY Descript ion: Search & Seizure Warrant
MICROSOFT, GOOGLE, AND APPLE

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the following:

a. The email accoun (hereafter "Target Account 1), that is

stored at premises owned, maintained, controlled, or operated by Microsoft, Inc., a business with

offices located at One Microsoft Way, Redmond, Washington, 98052. The information to be

disclosed by Microsoft and searched by the government is described in the following paragraphs

and in Attachments A and B.

b. The email accoun (hereafter "Target Account 2"), that is

stored at premises owned, maintained, controlled, or operated by Google, Inc., a business with

offices located at 1600 Amphitheatre Parkway, Mountain View, California, 94043. The

information to be disclosed by Google and searched by the government is described in the

following paragraphs and in Attachments C and D.

c. The iCloud account associated with the Apple email account

(hereafter "Target Account 3"), that is stored at premises owned,


Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 135 of 189

maintained, controlled, or operated by Apple, Inc., a business with offices located at I Infinite

Loop, Cupertino, California 95014. The information to be disclosed by Apple and searched by

the government is described in the following paragraphs and in Attachment E and F.

2. I, Andrew Mitchell, am a Special Agent with the Federal Bureau of Investigation

(FBI), and have been since 2011. As a Special Agent of the FBI, I have received training and

experience in investigating criminal and national security matters.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Accounts contain communications relevant to

18 U.S.C. § 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4

(misprision of a felony), 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18

U.S.C. § J 030 (unauthorized access of a protected computer); 18 U.S.C. §§ 1505 and 1512

(obstruction of justice), 18 U.S.C. § 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18

U.S.C. § 1349 (attempt and conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign

contribution ban) (the "Subject Offenses").

5. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for Roger STONE' address, (Target

Account 1). On October 17, 2017, Chief Judge Howell issued a search warrant for STONE's

address, (Target Account 2). On or about March 14, 2018, Chief

Judge Howell issued a search warrant for STONE's iCloud account (Target Account 3). This

2
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warrant seeks to search those accounts from the date each respective warrant was issued to the

present.

JURISDICTION

6. This Court has jurisdiction to issue the requested warrant because it is "a court of

competentjurisdiction" as defined by 18 U.S.C. § 2711. Id.§§ 2703(a), (b)(l)(A), & (c)(l)(A).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 27I 1(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below,

including in paragraphs 14, 19, and 61.

SUMMARY

7. This application seeks authority to search, from the date of search warrants

previously issued by the Court to the present, three accounts believed to be used by Roger

STONE: Target Account 1, which is STONE's Hotmail account; Target Account 2, which is

STONE's Gmail account; and Target Account 3, which is STONE's iCloud account. As set
"
forth herein, there is probable cause to believe that each of the Subject Accounts contains

evidence of the Subject Offenses, including ongoing efforts to obstruct justice, tamper with

witnesses, and make false statements.

8. For example, as set forth in more detail below, in recent months STONE has

reached out to communicate with multiple witnesses he knew or had reason to believe were

scheduled to testify before Congress about interactions with STONE during the 2016 presidential

campaign or were scheduled to meet with the Special Counsel's Office

. After STONE learned that one witness, Randy

CREDICO, was prepared to contradict STONE's congressional testimony, STONE repeatedly

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urged CREDICO to assert the Fifth Amendment and decline to answer questions, and did so

through multiple text messages. In June 2018, STONE instructed his private investigator to

provide him with a full background investigation on another witness who had

done information technology work for STONE during the campaign and

9. In September 2017, STONE released a statement he said he provided to Congress

in which he denied having advance knowledge of "the source or actual content of the Wikileaks

disclosures regarding Hillary Clinton." He also stated publicly that when he tweeted during the

campaign, on August 21, 2016, "it will soon the Podesta's time in the barrel," he was not

referring to the hacking or publication of John Podesta's emails, but rather. to "Podesta's business

dealings with Russia." Evidence obtained in the investigation, however, shows the following:

a. On or about July 25, 2016, Roger STONE emailed Jerome CORSI to "Get

to Assange" at the Ecuadorian Embassy and "get pending WikiLeaks emails[.]" Julian

ASSANGE is the founder ofWikiLeaks. On or about July 31, 2016, STONE also instructed

CORSI to have contact ASSANGE. On or about August 2, 2016, CORSI

responded to STONE that the "[w]ord is friend in embassy plans 2 more dumps. One shortly

after I'm back. 2nd in Oct. Impact planned to be very damaging .... Time to let more than

Podesta to be exposed as in bed w enemy if they are not ready to drop HRC." After receipt of

that message, on or about August 21, 2016, using@RogerJStoneJR, STONE tweeted: "Trust me,

it will soon the Podesta's time in the barrel. #CrookedHillary."

b. Information disclosures subsequently occurred on or about the times

CORSI predicted: On or about August 12, 2016, the day CORSI was scheduled to return to the

United States ("shortly after I'm back"), Guccifer 2.0 released hacked information related to the

4
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Democratic Congressional Campaign Committee (DCCC). On or about October 7, 2016, the day

the Washington Post published a breaking story about an Access Hollywood videotape ofthen-

candidate Trump making disparaging remarks about women, WikiLeaks released emails hacked

from the account of John Podesta.

c. Furthermore, on the day of the Access Hollywood video disclosure, there

were phone calls between STONE and CORSI after the Washington Post contacted STONE

prior to publication. At approximately 11 :OOAM, the Washington Post received a tip regarding

the Access Hollywood video. Approximately one hour later, shortly before noon, STONE

received a call from the Washington Post. Approximately ninety minutes later, before 2:00PM,

STONE called CORSI and they spoke. Approximately forty minutes later, CORSI called

STONE and the two spoke again at length. At approximately 4:00PM, the Washington Post

published its story regarding the Access Hollywood tape. By approximately 4:30PM, WikiLeaks

tweeted out its first release of emails hacked from John Podesta.

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PROBABLE CAUSE.

A. Background on Relevant Individuals

i. Roger STONE

10. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

11. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WND.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

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B. U.S. Intelligence Community Assessment of Russian Government-Backed Hacking


Activity during the 2016 Presidential Election

13. On October 7, 2016, the U.S. Department of Homeland Security and the Office of

the Director of National Intelligence released a joint statement of an intelligence assessment of

Russian activities and intentions during the 2016 presidential election. In the report, the USIC

assessed the following:

a. The U.S. Intelligence Community ("USIC") is confident that the Russian

Government directed the recent compromises of emails from US persons and institutions,

including from US political organizations. The recent disclosures of alleged hacked emails on

sites like DCLeaks.com and WikiLeaks and by the Guccifer 2.0 online persona are consistent

with the methods and motivations of Russian-directed efforts. These thefts and disclosures were

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intended to interfere with the U.S. election process. Such activity is not new to Moscow-the

Russians have used similar tactics and techniques across Europe and Eurasia, for example, to

influence public opinion there. We believe, based on the scope and sensitivity of these efforts,

that only Russia's senior-most officials could have authorized these activities.

14. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

a. "Russian President Vladimir Putin ordered an influence campaign in 2016

aimed at the US presidential election. Russia's goals were to undermine public faith in the US

democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her

electability and.potential presidency. We further assess Putin and the Russian Government

developed a clear preference for President-elect Trump."

b. The USIC also described, at a high level, some of the techniques that the

Russian government employed during its interference. The USIC summarized the efforts as a

"Russian messaging strategy that blends covert intelligence operations-such as cyber activity-

with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls.'"

c. With respect to "cyber activity," the USIC assessed that "Russia's

intelligence services conducted cyber operations against targets associated with the 2016 US

presidential election, including targets associated with both major US political parties." Further,

"[i]n July 2015, Russian intelligence gained access to Democratic National Committee (DNC)

networks and maintained that access until at least June 2016." The USIC attributed these cyber

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activities to the Russian GRU, also known as the Main Intelligence Directorate: "GRU

operations resulted in the compromise of the personal e-mail accounts of Democratic Party

officials and political figures. By May, the GRU had exfiltrated large volumes of data from the

DNC." The GRU is the foreign military intelligence agency of the Russian Ministry of Defense,

and is Russia's largest foreign intelligence agency.

d. With respect to the release of stolen materials, the USIC assessed "with

high confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

e. Guccifer 2.0, who claimed to be an independent Romanian hacker, made

multiple contradictory statements and false claims about his identity throughout the election.

C. Additional Hacking Activity by Individuals Associated with the GRU

15. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 campaign through at least

November 1, 2016.

16. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the."snapshots" to

those accounts.

17. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later posted on DCLeaks.

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18. On or about November I, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

19. On or about July 13, 2018, a grand jury in this District indicted eleven GRU

officers for knowingly and intentionally conspiring to hack into the computers of U.S. persons

and entities involved in the 2016 U.S. presidential election, steal documents from those

computers, and stage releases of stolen documents in order to interfere with the election. The

victims of the hacking and releases included the DNC, the Democratic Congressional Campaign

Committee ("DCCC"), and the chairman of the Clinton campaign (John Podesta). See United

States v. Viktor Borisovich Netyksho, et al. (1: 18-cr-215) (D.D.C.). 1

D. Roger STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

20. On June 14, 2016, Crowdstrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors. The media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

21. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.

1
A twelfth defendant was charged with conspiring to infiltrate computers of organizations responsible for
administering elections, including state boards of election, secretaries of state, and companies that supply software
and other technology used to administer elections.

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22. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world

would see for themselves how the Democrats had rigged the game."

23. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by AS SAN GE to Russia

Today (RT) several days earlier about an upcoming "October Surprise" aimed at the Hillary

Clinton presidential campaign. Specifically, STONE was asked: "With regard to the October

surprise, what would be your forecast on that given what Julian Assange has intimated he's

going to do?" STONE responded: "Well, it could be any number of things. I actually have

communicated with Assange. I believe the next tranche of his documents pertain to the Clinton

Foundation but there's no telling what the October surprise may be." A few days later, STONE

clarified that while he was not personally in touch with ASSANGE, he had a close friend who

served as an intermediary.

24. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

25. On August 13, 2016, Stone posted a tweet using @RogerJStoneJr calling Guccifer

2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day, Guccifer 2.0's

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Twitter account was reinstated.

26. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJ r paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

27. On August 18, 2016, Paul Manafort, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign.

28. As noted above, on August 21, 2016, using @RogerJStoneJR, STONE tweeted:

"Trust me, it will soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN

interview that same day, STONE reiterated that because of the work of a '"mutual acquaintance'

of both his and [ASSANGE], the public [could] expect to see much more from the exiled

whistleblower in the form of strategically-dumped Clinton email batches." He added: "Well,

first of all, I think Julian Assange is a hero ... I think he's taking on the deep state, both

Republican and Democrat. I believe that he is in possession of all of those emails that Huma

Abedin and Cheryl Mills, the Clinton aides, believe they deleted. That and a lot more. These are

like the Watergate tapes."

29. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

30. On Saturday, October 1, 2016, using @RogerJStoneJr, STONE tweeted,

"Wednesday @HillaryClinton is done. #WikiLeaks."

31. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement ASSANGE had scheduled for the next day from the balcony

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of the Ecuadoran Embassy in London. On the day of the ASSANGE announcement -which was

part of WikiLeaks' 10-year anniversary celebration - STONE told Info wars that his intennediary

described this release as the "mother load." On October 5, 2016, STONE used @RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

32. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

33. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

34. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta- referring back to STONE's August 21,

2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

35. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

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from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "S\nce I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

E. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

36. On August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the

Twitter account @RogerJStoneJr. Information recovered from the search of that account

includes the following:

a. On October 13, 2016, while WikiLeaks was in the midst ofreleasing the

hacked Podesta emails, @RogerJStoneJr sent a private direct message to the Twitter account

@wikileaks. This account is the official Twitter account of WikiLeaks and has been described as

such by numerous news reports. The message read: "Since I was all over national TV, cable and

print defending WikiLeaks and assange against the claim that you are Russian agents and

debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

b. Less than an hour later, @wikileaks responded by direct message: "We

appreciate that. However, the false claims of association are being used by the democrats to

undermine the impact of our publications. Don't go there if you don't want us to correct you."

c. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

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d. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

e. In addition, @RogerJStoneJr also exchanged direct messages with

ASSANGE. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with ASSANGE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

f. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

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F. STONE's Communications with STONE , and Others Regarding


Forthcoming Leaks

37. As indicated above, on September 11, 2017, Chief Judge Howell issued a search

warrant for STONE's address, (Target Account 1); on

October 17, 2017, Chief Judge Howell issued a search warrant for STONE' address,

(Target Account 2); and on or about March 14, 2018, Chief Judge

Howell issued a search warrant for STONE's iCloud account (Target Account 3). In addition,

on or about December 19, 2017, Chief Judge Howell issued a search warrant for

email account. Information recovered pursuant to those search warrants includes the following:

a. On or about May 15, 2016, emailed CORSI: "Here is my

flight schedule. Need to get something confirmed now .... " CORSI responded, ."! copied

Roger Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

appears to have forwarded the message to STONE at Target Account 1, who replied to CORSI

that, "May meet Manafort -guarantee nothing."

b. On or about May 18, 2016, CORSI emailed STONE at Target Account 1

with the title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

c. On July 25, 2016, STONE, using Target Account 1, sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

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[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

d. On or about July 31, 2016, STONE, using Target Account 1, emailed

CORSI with the subject line, "Call me MON." The body of the email read: should see

Assange[.] should find Bernie [S]anders brother who called Bill a Rapist- tum him for

Trump[.] should fin e or more proof of Bill getting kicked out."

e. As noted above, on or about August 2, 2016 (approximately 19 days

before STONE publicly tweeted about "Podesta's time in the barrel"), CORSI emailed STONE

at Target Account 1: "Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued: "Signs are Fox

will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HR.Can artifact ofrigged polling. Won't last. I expect

presidential campaign to get serious starting Sept. Still in pre-season games. Time to let more

than Podesta to be exposed as in bed w enemy if they are not ready to drop HRC. That appears

to be the game hackers are now about. Would not hurt to start suggesting HRC old, memory

bad, has stroke -- neither he nor she well. I expect that much of next dump focus, setting stage

for Foundation debacle." Investigators believe that CORSI's reference to a "friend in embassy

[who] plans 2 more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in

2016.

f. On or about August 5, 2016, an associate of STONE's,

emailed Stone at Target Account 1. The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded, "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

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same time, STONE told him he had gone to London to meet ASSANGE also stated

that in 2018 told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SAN GE. STONE tol he was joking and

had not actually met ASSANGE. 2

g. On or about August 15, 2016, CORSI emailed STONE at Target Account

1: "Give me a call today if you can. Despite MSM drumroll that HRC is already elected, it's not

over yet. More to come than anyone realizes. Won't really get started until after Labor Day. I'm

in NYC this week. Jerry."

h. On or about August 31, 2016, CORSI emailed STONE at Target Account

1: "Did you get the PODESTA writeup." STONE replied "[y]es."

1. On or about August 31, 2016, CORSI messaged STONE at Target

Account 3, "Podesta paid $ l 80k to invest in Uranium One - was hired by Rosatom in Giustra

scandal. Podesta now under FBI investigation - tied to Ukraine Y anukovych - Panama papers

reveals Podesta hired by S[b]erbank, Russia's largest financial institution - Podesta$$$ ties to

Russia undermine Clinton false narrative attempting to tie Trump to Putin."

J. On or about September 6, 2016, CORSI emailed STONE at Target

Account 1: "Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

k. On or about September 24, 2016, emailed CORSI, "I will

have much more on Turkey. Need a back channel highly sensitive stuff." CORSI responded,

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"We have secure back channel through Roger. I saw him again in NYC last Friday and spoke to

him about it again today." wrote back, "Awaiting secret file. Explosive ... Hope you

are well. Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me

posted about file[.]" In a subsequent meeting with investigators, indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

I. On or about October 3, 2016, an associate of STONE emailed STONE at

Target Account 2 and asked: "Assange -what's he got? Hope it's good." STONE wrote back,

"It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will be

out in Jan. Many scores will be settled." The associate forwarded the email to Steve BANNON,

who was CEO of the Campaign at the time, and wrote: "You should call Roger. See below. You

didn't get from me." BANNON wrote back, "I've got important stuff to worry about." The

associate responded, "Well clearly he knows what Assange has. I'd say that's important."

m. On or about October 4, 2016, ASS ANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

AS SAN GE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

n. On or about October 4, 2016, CORSI messaged STONE at Target

Account 3, "Assange made a fool of himself. Has nothing or he would have released it. Total

BS hype."

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o. That same day, BANNON emailed STONE at Target Account 2, "What

was that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are

going to kill him and the London police are standing done [sic]." BANNON wrote back, "He

didn't cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawye is a

big democrat."

p. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had b~en hoping for releases of damaging information that morning.

G. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released

38. According to a publicly available news article, 3 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold rece_ived a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood' and NBC for reaction."

39. According to phone record , at approximately

11 :27 AM, CORSI placed a ca.JI to STONE which STONE did not answer.

3
https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-then-the-race-was-
on/2016/10/07/3 ld74 7l 4-8ce5- l l e6-875e-2cl bfe943b66_story.html

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40. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

41. At approximately 1 :42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

42. At approximately 2: 18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

43. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

44. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE on Target Account 1, "I expect that much

of next dump focus, setting stage for Foundation debacle."

45. At approximately 6:27PM, an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks -The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using Target

Account 2, forwarded message to CORSI without comment. STONE does not appear

to have forwarded the email to any other individual.

H. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

46. On or about October 8, 2016, STONE, using Target Account 3, messaged

CORSI, "Lunch postponed- have to go see T." CORSI responded to STONE, "Ok. I

understand." Approximately twenty minutes later, CORSI texted, "Clintons know they will lose

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a week of Paula Jones media with T attacking Foundation, using Wikileaks Goldman Sachs

speech comments, attacking bad job numbers."

47. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

using Target Account 2, emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM, "need your BEST podesta pieces." CORSI

wrote back at approximately 8:54AM, "Ok. Monday. The remaining stuff on Podesta is

complicated. Two articles in length. I can give you in raw form the stuff I got in Russian

translated but to write it up so it's easy to understand will take weekend. Your choice?"

48. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails, as noted above. At approximately 3:25PM,

CORSI emailed STONE at both Target Account 1 and 2 with the subject line "Podesta talking

points." Attached to the email was a file labeled, "ROGER STONE podesta talking points Oct

12 2016.docx." The "talking points" included the statement that "Podesta is at the heart of a

Russian-government money laundering operation that benefits financially Podesta personally and

the Clintons through the Clinton Foundation."

49. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via Target Account 1: "Got them and used them."

50. On or about Thursday, October 13, 2016, CORSI emailed STONE at Target

Account 2: "PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to CLINTON

FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could post under my

by-line since I am the one under attack by Podesta and now Mook." CORSI wrote back to

STONE, "I'll give you one more -NOBODY YET HAS THIS[:] It looks to me like

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skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation(.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have no.w promised it to a dozen MSM reporters[.]"

51. On or about Thursday, October 13, 2016, at approximately 6:30PM, CORSI sent

STONE an email at Target Account 2, with the subject, "ROGER STONE article RUSSIAN

MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and JOHN

PODESTA." The text stated: "Roger[,] You are free to publish this under your own name."

That same day, STONE posted a blog post with the title, "Russian Mafia money laundering, the

Clinton Foundation and John Podesta." In that post, STONE wrote, "although I have had some

back-channel communications with Wikileaks I had no advance notice about the hacking of Mr.

Podesta nor I have I ever received documents or data from Wikileaks." The post then asked,

"Just how much money did , a controversial Russian billionaire investor with

ties to the Vladimir Putin and the Russian government, launder through Metcombank, a Russian

regional bank owned 99.978 percent by , with the money transferred via Deutsche

Bank and Trust Company Americas in New York City, with the money ending up in a private

bank account in the Bank of America that is operated by the Clinton Foundation?"

52. On or about October 14, 2016, CORSI sent a message to STONE at Target

Account 3, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

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53. On or about October 17, 2016, CORSI messaged STONE at Target Account 3,

"On Assange, can you call me now - before 2pm[.]" STONE responded, "Missed u - just

landed JFK - on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

54. On or about October 17, 2016, CORSI emailed STONE at Target Accounts 1

and 2 with the subject, "Fwd: ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted

source," and forwarded an email with the header information stripped out, showing only the

body text. The email read, "Yes[.J I figured this. Assange is threatening Kerry, Ecuador and

U.K. He will drop the goods on them if they move to extradite him. My guess is that he has a set

of dead man files that include Hillary. It's what they used to call a 'Mexican stand off[.]' Only

hope is that if Trump speaks out to save him[.] Otherwise he's dead anyway, once he's dropped

what he has. If HRC wins, Assange can kiss his life away. Interesting gambit Assange has to

play out. He's called Podesta's bluff and raised him the election."

55. On or about October 18, 2016, CORSI messaged STONE at Target Account 3,

"Pis call. Important."

56. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had "no advance notice of Wikileaks' hacking of Podesta's e-mails."

STONE stated, "I predicted that Podesta's business dealings would be exposed. I didn't hear it

from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

57. On or about November 8, 2016, the United States presidential election took place.

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58. On or about November 9, 2016, CORSI messaged STONE at Target Account 3,

"Congratulations, Roger. He could not have done it without you."

59. On or about November 10, 2016, CORSI messaged STONE at Target Account 3,

"Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in London.

Have some interesting news for you."

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J. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikileaks

61. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCI). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic assertions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta's email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such assertions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trust me, it will soon be the Podesta' s
time in the barrel. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but
does accurately predict that the Pode_sta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrutiny....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.

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I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
Assange to independently confirm this rep011, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
infotmation proved to be correct. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

62. In a document dated March 26, 2018 titled "Minority Views," Democratic

members of HP SCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in_
communication with Assange or communication through an intermediary with Assange,
you were only referring to a single fact that you had confirmed with the intermediary -
MR. STONE: That-
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is c01Tect, even though it was repeated to me on numerous separate
occasions.

63. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an article on his website, stonecoldtruth.com, titled "Is it the Podesta's

Time in the Barrel Yet?" In that article, STONE stated: "[I]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

K. STONE's Use of Target Account 3 to Message Randy CREDI CO about STONE's


"Back channel"

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64. On November 19, 2017, Randy CREDI CO (who, as described further below,

STONE publicly identified as his "intermediary'' to ASSANGE), messaged STONE on Target

Account 3, "My lawyer wants to see me today." STONE responded, '"Stonewall it. Plead the

fifth. Anything to save the plan' ........ Richard Nixon[.]" CREDI CO responded, "Ha ha."

65. On or about November 21, 2017, CREDICO messaged STONE on Target

Account 3, "I was told that the house committee lawyer told my lawyer that I will be getting a

subpoena[.]" STONE wrote back, "That was the point at which your lawyers should have told

them you would assert your 5th Amendment rights if compelled to appear." They continued to

message, and CREDICO wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To

do what ? Nothing happening in DC the day before Thanksgiving - why are u busting my

chops?'.'

66. On or about November 24, 2017, STONE, using Target Account 3, texted

CREDICO, "Assange is a journalist and a damn good one- meeting with him is perfectly legal

and all you ever told me was he had the goods [o]n Hillary and would publish them - which he

himself said in public b4 u told me. It's a fucking witchunt [sic]." CREDI CO replied, "I told

you to watch his tweets. That's what I was basing it on. I told you to watch his Tweets in

October not before that I knew nothing about the DNC stuff[.] I just followed his tweets[.]"

STONE responded, "U never said anything about the DNC but it was August." CREDICO

wrote back, "It was not August because I didn't interview him or meet him until August 26th[.]

That was my first communication with his secretary in London, August 26th." STONE wrote

back, "Not the way I remember it- oh well I guess Schiff will try to get one ofus indicted for

perjury[.]"

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67. STONE and CREDICO continued to exchange messages via Target Account 3,

and on November 24, 2017, CREDICO wrote to STONE, "Forensic evidence proves that there is

no back Channel. So now you can relax."

68. On or about November 28, 2017, CREDICO tweeted a copy of a subpoena he

received from HPSCI that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

69. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that, "Credico merely[]

confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credico never said he knew or had any information as to source or

content of the material."

70. On or about December 1, 2017, CREDICO messaged STONE on Target

Account 3, stating, "I don't know why you had to lie and say you had a back Channel now I had

to give all of my forensic evidence to the FBI today what a headache[.] 4 You could have just told

him the truth that you didn't have a back Channel they now know that I was not in London until

September of this year[.] You had no back-channel and you could have just told the truth ...

You want me to cover you for pe1jury now[.]" STONE responded, "What the fuck is your

problem? Neither of us has done anything wrong or illegal. You got the best press of your life

and you can get away with asserting for 5th Amendment rights if u don't want talk about AND if

4
Contrary to his statement, CREDICO has not provided any forensic evidence to the FBI.

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you ·turned over anything to the FBI you're a fool." CREDICO responded, "You open yourself

up to six counts of perjury[.] But I'm sure that wasn't sworn testimony so you're probably

clear[.] Council for the committee knows you never had a back Channel and if you had just told

the truth wouldn't have put me in this bad spot ... you should go back ... and amend your

testimony and tell them the truth." CREDI CO repeated: "you need to amend your testimony

before I testify on the 15th." STONE replied, "If you testify you're a fool. Because of tromp

[sic] I could never get away with a certain [sic] my Fifth Amendment rights but you can. I

guarantee you you [sic] are the one who gets indicted for perjury if you're stupid enough to

testify(.]"

71. STONE and CREDICO continued to message each other on or about December 1,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

STONE: "Whatever you want to say 1 have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fuck off good night." CREDICO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th(.]" STONE responded: "You got nothing."

72. On or about December 13, 2017, according to public reporting, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

73. STONE and CREDICO continued to exchange messages via Target Account 3,

and on or about January 6, 2018, CREDICO indicated to STONE that he was having dinner with

a reporter. STONE responded, "Hope u don't fuck Up my efforts to get Assange a pardon[.]"

CREDICO messaged STONE, "I have the email from his chief of staff August 25th 2016

responding to an email I sent to WikiLeaks website email address asking you would do my

show[.] That was my initial contact."

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74. On or about January 8, 2018, CREDICO messaged STONE on Target Account 3

stating: "Embassy logs ... + 17 other pieces of information prove that I did not have any

conversations with Assange until September of last year."

75. CREDICO and STONE continued to message each other, and on or about January

25, 2018, CREDICO wrote to STONE on Target Account 3: "You lied to the house Intel

committee ... But you'll get off because you're friends with Trump so don't worry. I have all

the forensic evidence[.] I was not a ba[ck] Channel and I have all those emails from September

of 2016 to prove it[.]"

76. On or about April 13, 2018, news reports stated that CREDICO had shown

reporters copies of email messages he had received from STONE in the prior few days that

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

from you," referring to CREDICO's therapy dog. CREDICO stated that it was "cetiainly scary .

. . When you start bringing up my dog, you're crossing the line[.]" 5

77. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

5
https://www.yahoo.com/news/comedian-randy-credico-says-trump-adviser-roger-stone-threatened-dog-
135911370.html

6
https://www.motherjones.com/politics/2018/05/roger-stone-to-associate-prepare-to-die/

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He was depressed about it. Or was he lying." The article noted that CREDTCO stated he did not

have prostate cancer and did not have any such discussion with STONE.

L. STONE's Use of the Target Accounts to Communicate with Individuals Related to


the Investigation

78. On May I 7, 2018, Chief Judge Howell issued an order for the use of pen-trap

devices on Target Account 1 and Target Account 2. The information obtained from that order,

along with information obtained from toll records, revealed that STONE has continued to use

Target Account 1 and Target Account 2, and that he has used them to communicate with

individuals related to the investigation.

79. For example, STONE and communicated twice on May 28 and May

29, 2018 using Target Account 1. , a former associate of STONE's, was

interviewed by the Special Counsel's Office on or about May 2, 2018. Toll records show that '

and STONE communicated multiple times on May 5, 2018, and STONE

communicated wit using Target Account 1 on June 1, 2018 and June 6, 2018.

a private investigator who had previously worked with STONE and who was hired

by STONE to research individuals associated with this case (as described further below),

communicated with STONE on Target Account 1 at least four times between May 27, 2018 and

July 12,2018.

80. STONE has also used Target Account 2 to communicate with individuals

associated with this investigation.

a. For example, between May 23, 2018 and the present, STONE and CORSI

exchanged at least five messages using Target Account 2. In the same time period, STONE

exchanged at least 75 emails with CREDICO using Target Account 2.

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b. Also in this same time period, STONE emailed at least

ten times using Target Account 2. is a former employee of STONE. On May 9,

2018, FBI agents approached and That day,

and again on May 10, 2018, communicated by phone with

STONE. Overall, between May 23, 2018 and the present, STONE exchanged over 100 emails

with using Target Account 2. In addition, between on or about June 14, 2018 and

June 17, 2018, and STONE exchanged five emails using Target Account 2.

81. STONE has also used a phone number associated with Target Account 3 to

communicate with , a private investigator hired by STONE. was

interviewed by investigators on June 7, 2018, and subsequently informed investigators that in

June 2018, STONE instructed him to conduct a full background investigation on

who had been employed by STONE during the Campaign as an information technology

specialist.

also told investigators that in June 2018, STONE instructed him to find

an address for CREDICO that could be used to serve CREDICO with legal process.

told investigators that his primary fmm of communication with STONE is by text

message on Target Account 3.

BACKGROUND CONCERNING EMAIL

82. In my training and experience, I have learned the Providers provide a variety of

on-line services, including electronic mail ("email") to the public. The Providers allow

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subscribers to obtain email accounts at the domain names identified in the email address

contained in Attachment A and C. Subscribers obtain an account by r~gistering with the

Providers. During the registration process, the Providers ask subscribers to provide basic

personal information. Therefore, the computers of the Providers are likely to contain stored

electronic communications (including retrieved and unretrieved email) for their subscribers and

information concerning subscribers and their use of services, such as account access information,

email transaction information, and account application information. In my training and

experience, such information may constitute evidence of the crimes under investigation because

the information can be used to identify the account's user or users.

83. In my training and experience, email Providers generally ask their subscribers to

provide certain personal identifying information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and

other identifiers, alternative email addresses, and, for paying subscribers, means and source of

payment (including any credit or bank account number). In my training and experience, such

information may constitute evidence of the crimes under investigation because the information

can be used to identify the account's user or users. Based on my training and my experience, I

know that, even if subscribers insert false information to conceal their identity, this information

often provides clues to their identity, location, or illicit activities.

84. In my training and experience, email Providers typically retain certain

transactional information about the creation and use of each account on their systems. This

information can include the date on which the account was created, the length of service, records

of log-in (i.e., session) times and durations, the types of service utilized, the status of the account

(including whether the account is inactive or closed), the methods used to connect to the account

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(such as logging into the account via the Providers' website), and other log files that reflect

usage of the account. In addition, email Providers often have records of the Internet Protocol

address ("IP address") used to register the account and the IP addresses associated with particular

logins to the account. Because every device that connects to the Internet must use an IP address,

IP address information can help to identify which computers or other devices were used to access

the email account.

85. In my training and experience, in some cases, email account users will

communicate directly with an email service Providers about issues relating to the account, such

as technical problems, billing inquiries, or complaints from other users. Email Providers

typically retain records about such communications, including records of contacts between the

user and the Providers' support services, as well as records of any actions taken by the Providers

or user as a result of the communications. In my training and experience, such information may

constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users.

86. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of

occupancy" while executing a search warrant at a residence. For ~xample, email

communications, contacts lists, and images sent (and the data associated with the foregoing, such

as date and time) may indicate who used or controlled the account at a relevant time. Further,

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information maintained by the email Providers can show how and when the account was

accessed or used. For example, as described below, email Providers typically log the Internet

Protocol (IP) addresses from which users access the email account, along with the time and date

of that access. By determining the physical location associated with the logged IP addresses,

investigators can understand the chronological and geographic context of the email account

access and use relating to the crime under investigation. This geographic and timeline

information may tend to either inculpate or exculpate the account owner. Additionally,

information stored at the user's account may further indicate the geographic location of the

account user at a particular time (e.g., location information integrated into an image or video sent

via email). Last, stored electronic data may provide relevant insight into the email account

owner's state of mind as it relates to the offense under investigation. For example, information in

the email account may indicate the owner's motive and intent to commit a crime (e.g.,

communications relating to the crime), or consciousness of guilt (e.g., deleting communications


~

in an effort to conceal them from law enforcement).

87. In my training and experience, information such as search history can help to

show the state of mind of an individual at the time the search was made, as well as the

individuals potential advance knowledge of events, as they search to see if the anticipated event

has occurred.

INFORMATION REGARDING APPLE ID AND iCLOUD 7

The information in this section is based on information published by Apple on its website, including, but
not limited to, the following document and webpages: "U.S. Law Enforcement Legal Process Guidelines," available
at htip:/limages.apple.com/orivacy/docs/ legal-process-guiclelines-us.pd_f; "Create and start using an Apple ID,"
available at https://suppoct.app.Je.com/en-us/HT203993; "iCloud," available at http://www.apple.com/icloud/; "What
does iCloud back up?," available at https://support.aople.com/ kb/PH12519; "iOS Security," available at
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88. Apple is a United States company that produces the iPhone, iPad, and iPod

Touch, all of which use the iOS operating system, and desktop and laptop computers based on

the Mac OS operating system.

89. Apple provides a variety of services that can be accessed from Apple devices or,

in some cases, other devices via web browsers or mobile and desktop applications ("apps"). As

described in further detail below, the services include email, instant messaging, and file storage:

a. Apple provides email service to its users through email addresses at the

domain names mac.com, me.com, and icloud.com.

b. iMessage and FaceTime allow users of Apple devices to communicate in

real-time. iMessage enables users of Apple devices to exchange instant messages ("iMessages")

containing text, photos, videos, locations, and contacts, while FaceTime enables those users to

conduct video calls.

c. iCloud is a file hosting, storage, and sharing service provided by Apple.

iCloud can be utilized through numerous iCloud-connected services, and can also be used to

store iOS device backups and data associated with third-party apps.

d. iCloud-connected services allow users to create, store, access, share, and

synchronize data on Apple devices or via icloud.com on any Internet-connected device. For

example, iCloud Mail enables a user to access Apple-provided email accounts on multiple Apple

devices and on icloud.com. iCloud Photo Library and My Photo Stream can be used to store and

manage images and videos taken from Apple devices, and iCloud Photo Sharing allows the user

https://www.apple.com/business/docs/iOS Security Guid.e. pdf, and "iCloud: How Can I Use iCloud?," available at
https: //support.apple.com/kb/PH26502.

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to share those images and videos with other Apple subscribers. iCloud Drive can be used to

store presentations, spreadsheets, and other documents. iCloud Tabs and bookmarks enable

iCloud to be used to synchronize bookmarks and webpages opened in the Safari web browsers

on all of the user's Apple devices. iWork Apps, a suite of productivity apps (Pages, Numbers,

Keynote, and Notes), enables iCloud to be used to create, store, and share documents,

spreadsheets, and presentations. iCloud Keychain enables a user to keep website username and

passwords, credit card information, and Wi-Fi network information synchronized across multiple

Apple devices.

e. Game Center, Apple's social gaming network, allows users of Apple

devices to play and share games with each other.

f. Find My iPhone allows owners of Apple devices to remotely identify and

track the location of, display a message on, and wipe the contents of those devices. Find My

Friends allows owners of Apple devices to share locations.

g. Location Services allows apps and websites to use information from

cellular, Wi-Fi, Global Positioning System ("GPS") networks, and Bluetooth, to determine a

user's approximate location.

h. App Store and iTunes Store are used to purchase and download digital

content. iOS apps can be purchased and downloaded through App Store on iOS devices, or

through iTunes Store on desktop and laptop computers running either Microsoft Windows or

Mac OS. Additional digital content, including music, movies, and television shows, can be

purchased through iTunes Store on iOS devices and on desktop and laptop computers running

either Microsoft Windows or Mac OS.

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90. Apple services are accessed through the use of an "Apple ID," an account created

during the setup of an Apple device or through the iTunes or iCloud services. A single Apple ID

can be linked to multiple Apple services and devices, serving as a central authentication and

syncing mechanism.

91. An Apple ID takes the form of the full email address submitted by the user to

create the account; it can later be changed. Users can submit an Apple-provided email address

(often ending [email protected], @me.com, [email protected]) or an email address associated with a

third-party email provider (such as Gmail, Yahoo, or Hotmail). The Apple ID can be used to

access most Apple services (including iCloud, iMessage, and FaceTime) only after the user

accesses and responds to a "verification email" sent by Apple to that "primary" email address.

Additional email addresses ("alternate," "rescue," and "notification" email addresses) can also be

associated with an Apple ID by the user.

92. Apple captures information associated with the creation and use of an Apple ID.

During the creation of an Apple ID, the user must provide basic personal information including

the user's full name, physical address, and telephone numbers. The user may also provide means

of payment for products offered by Apple. The subscriber information and password associated

with an Apple ID can be changed by the user through the "My Apple ID" and "iForgot" pages on

Apple's website. In addition, Apple captures the date on which the account was created, the

length of service, records of log-in times and durations, the types of service utilized, the status of

the account (including whether the account is inactive or closed), the methods used to connect to

and utilize the account, the Internet Protocol address ("IP address") used to register and access

the account, and other log files that reflect usage of the account.

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93. Additional information is captured by Apple in connection with the use of an

Apple ID to access certain services. For example, Apple maintains connection logs with IP

addresses that reflect a user's sign-on activity for Apple services such as iTunes Store and App

Store, iCloud, Game Center, and the My Apple ID and iForgot pages on Apple's website. Apple

also maintains records reflecting a user's app purchases from App Store and iTunes Store, "call

invitation logs" for FaceTime calls, "query logs" for iMessage, and "mail logs" for activity over

an Apple-provided email account. Records relating to the use of the Find My iPhone service,

including connection logs and requests to remotely lock or erase a device, are also maintained by

Apple.

94. Apple also maintains information about the devices associated with an Apple ID.

When a user activates or upgrades an iOS device, Apple captures and retains the user's IP

address and identifiers such as the Integrated Circuit Card ID number ("ICCID"), which is the

serial number of the device's SIM card. Similarly, the telephone number of a user's iPhone is

linked to an Apple ID when the user signs in to FaceTime or iMessage. Apple also may

maintain records of other device identifiers, including the Media Access Control address ("MAC

address"), the unique device identifier ("UDID"), and the serial number. In addition,

information about a user's computer is captured when iTunes is used on that computer to play

content associated with an Apple ID, and information about a user's web browser may be

captured when used to access services through icloud.com and apple.com. Apple also retains

records related to communications between users and Apple customer service, including

communications regarding a particular Apple device or service, and the repair history for a

device.

41
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 175 of 189

95. Apple provides users with five gigabytes of free electronic space on iCloud, and

users can purchase additional storage space. That storage space, located oµ servers controlled by

Apple, may contain data associated with the use of iCloud-connected services, including: email

(iCloud Mail) ; images and videos (iCloud Photo Library, My Photo Stream, and iCloud Photo

Sharing); documents, spreadsheets, presentations, and other files (iWork and iCloud Drive); and

web browser settings and Wi-Fi network information (iCloud Tabs and iCloud Keychain).

iCloud can also be used to store iOS device backups, which can contain a user's photos and

videos, iMessages, Short Message Service ("SMS") and Multimedia Messaging Service

("MMS") messages, voicemail messages, call history, contacts, calendar events, reminders,

notes, app data and settings, Apple Watch backups, and other data. Records and data associated

with third-party apps may also be stored on iCloud; for example, the iOS app for WhatsApp, an

instant messaging service, can be configured to regularly back up a user's instant messages on

iCloud Drive. Some of this data is stored on Apple's servers in an encrypted form but can

nonetheless be decrypted by Apple.

96. In my training and experience, evidence of who was using an Apple ID and from

where, and evidence related to criminal activity of the kind described above, may be found in the

files and records described above. This evidence may establish the "who, what, why, when,

where, and how" of the criminal conduct under investigation, thus enabling the United States to

establish and prove each element or, alternatively, to exclude the innocent from further

suspicion.

INFORMATION TO BE SEARCHED AND THINGS TO BE SEIZED

42
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 176 of 189

97. I anticipate executing this warrant under the Electronic Communications Privacy

Act, in particular 18 U.S.C. §§ 2703(a), 2703(b)(l)(A) and 2703(c)(l)(A), by using the warrant

to require Google to disclose to the government copies of the records and other information

(including the content of communications) associated with the accounts in Attachment A, C, and

E and particularly described in Section I of Attachment B, D, and F. Upon receipt of the

information described in Section I of Attachments B, D, and F, government-authorized persons

will review that information to locate the items described in Section II of Attachment B, D, and

F. The items identified in Attachments A-F will also be screened by reviewers not on the

prosecution team to identify and filter out privileged material.

CONCLUSION

98. Based on the forgoing, I request that the Court issue the proposed search warrant.

99. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

100. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respe~

Andrew Mitchell
Special Agent
Federal Bureau of Investigation

43
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 177 of 189

Subscribed and sworn lo before me on this 1f { of Augus~ 2018.

/ $
/711 !l l(,t1Lt
The Honorable Beryl A. Howell
Chief United States District Judge

44
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 178 of 189

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the email address:

created or maintained between September 11, 2017 and present, that is stored at premises owned,

maintained, controlled, or operated by Microsoft Corp., d/b/a Hotmail, a company headquartered

at One Microsoft Way, Redmond, WA 98052.

45
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 179 of 189

ATTACHMENT B

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to the Provider or have been
preserved pursuant to a preservation request under 18 U.S.C. § 2703(f), the Provider is required
to disclose the following information to the government for each account or identifier listed in
Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail described above
in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above in Section I.A,
including log files, dates, times, methods of connecting, ports, dial ups, and/or locations;

e. All records or other information stored by an individual using the account, including
address books, contact and buddy lists, calendar data, pictures, and files;

f. Records or other information regarding the identification of the account described above
in Section LA, to include application, full name, physical address, telephone numbers and
other identifiers, records of session times and durations, log-in IP addresses associated
with session times and dates, account status, alternative e-mail addresses provided during
registration, all screen names associated with subscribers and/or accounts, all account
names associated with the subscriber,

g. All records indicating the services available to subscribers of the electronic mail address
described above in Section LA.;

46
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 180 of 189

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban) from June 1,
2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

47
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 181 of 189

i. All existing printouts from original storage which concern the categories identified in
subsection II.a

48
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 182 of 189

ATTACHMENT C

Property to be Searched

This warrant applies to information associated with the following Google account:

created or maintained between October 17, 2017 and the present, that is stored.at premises

owned, maintained, controlled, or operated by Google, Inc., a business with offices located at

1600 Amphitheatre Parkway, Mountain View, CA 94043.

49
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 183 of 189

ATTACHMENT D

Particular Things to be Seized

I. Files and Accounts to be produced by Google, Inc.

To the extent that the information described in Attachment C is within the possession,
custody, or control of Google, Inc. including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to Google or have been preserved
pursuant to a preservation request under 18 U.S.C. § 2703(£), Google is required to disclose the
following information to the government for each account or identifier listed in Attachment C:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail
described above in Section LA. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above


in Section LA, including log files, dates, times, methods of connecting, ports, dial ups,
and/or locations;

e. All records or other information stored by an individual using the account,


including address books, contact and buddy lists, calendar data, pictures, and files;

f. All records or other information regarding the identification of the account


described above in Section I.A, to include application, full name, physical address,
telephone numbers and other identifiers, records of session times and durations, the date
on which the account was created, the length of service, the types of service utilized, the
IP address used to register the account, log-in IP addresses associated with session times
and dates, account status, alternative e-mail addresses provided during registration, all
screen names associated with subscribers and/or accounts, all account names associated
with the subscriber, methods of connecting, log files, means and source of payment
(including any credit or bank account number), and detailed billing records;

g. All records indicating the services available to subscribers of the


electronic mail address described above in Section LA.;

h. Google+ subscriber information, circle information, including name of


circle and members, contents of posts, comments, and photos, to include date and
timestamp;

50
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 184 of 189

1. Google Drive files created, accessed or owned by the account;

J. YouTube subscriber information, private videos and files, private


messages, and comments;

k. Google+ Photos contents to include all images, videos and other files, and
associated upload/download date and timestamp;

1. Google Talk and Google Hangouts conversation logs associated with the
account.

51
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 185 of 189

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment C which
consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban), from June
1, 2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

1. All existing printouts from original storage which concern the categories identified in
subsection II.a

52
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 186 of 189

ATTACHMENT E

Property to be Searched

This warrant applies to information associated with the following Apple DSID:

created or maintained between March 14, 2018 and the present, that is stored at premises owned,

maintained, controlled, or operated by Apple, Inc., located at One Apple Park Way, Cupertino,

California 95014.

53
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 187 of 189

ATACHMENTF

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment Eis within the possession,
custody, or control of Apple, regardless of whether such information is located within or outside
ofthe United States, including any messages, records, files, logs, or infonnation that have been
deleted but are still available to Apple, or have been preserved pursuant to a request made under
18 U.S.C. § 2703(f), Apple is required to disclose the following information to the government,
in unencrypted form whenever available, for each account or identifier listed in Attachment E:

a. All records or other information regarding th~ identification of the account, to


include full name, physical address, telephone numbers, email addresses (including primary,
alternate, rescue, and notification email addresses, and verification information for each email
address), the date on which the account was created, the length of service, the IP address used to
register the account, account status, associated devices, methods of connecting, and means and
source of payment (including any credit or bank account numbers);

b. All records or other information regarding the devices associated with, or used in
connection with, the account (including all current and past trusted or authorized iOS devices
and computers, and any devices used to access Apple services), including serial numbers, Unique
Device Identifiers ("UDID"), Advertising Identifiers ("IDFA"), Global Unique Identifiers
("GUID"), Media Access Control ("MAC") addresses, Integrated Circuit Card ID numbers
("ICCID"), Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),
Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber
Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Numbers
("MSISDN"), International Mobile Subscriber Identities ("IMSI"), and International Mobile
Station Equipment Identities ("IMEI");

c. The contents of all emails associated with the account, including stored or
preserved copies of emails sent to and from the account (including all draft emails and deleted
emails), the source and destination addresses associated with each email, the date and time at
which each email was sent, the size and length of each email, and the true and accurate header
information including the actual IP addresses of the sender and the recipient of the emails, and
all attachments;

d. The contents of all instant messages associated with the account, including stored
or preserved copies of instant messages (including iMessages, SMS messages, and MMS
messages) sent to and from the account (including all draft and deleted messages), the source and
destination account or phone number associated with each instant message, the date and time at
which each instant message was sent, the size and length of each instant message, the actual IP
addresses of the sender and the recipient of each instant message, and the media, if any, attached
to each instant message;

54
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 188 of 189

e. The contents of all files and other records stored on iCloud, including all iOS
device backups, all Apple and third-party app data, all files and other records related to iCloud
Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWork
(including Pages, Numbers, Keynote, and Notes), iCloud Tabs and bookmarks, and iCloud
Keychain, and all address books, contact and buddy lists, notes, reminders, calendar entries,
images, videos, voicemails, device settings, and bookmarks;

f. All activity, connection, and transactional logs for the account (with associated IP
addresses including source port numbers), including FaceTime call invitation logs, messaging
and query logs (including iMessage, SMS, and MMS messages), mail logs, iCloud logs, iTunes
Store and App Store logs (including purchases, downloads, and updates of Apple and third-party
apps), My Apple ID and iForgot logs, sign-on logs for all Apple services, Game Center logs,
Find My iPhone and Find My Friends logs, Jogs associated with web-based access of Apple
services (including all associated identifiers), and logs associated with iOS device purchase,
activation, and upgrades;

g. All records and information regarding locations where the account or devices
associated with the account were accessed, including all data stored in connection with Location
Services, Find My iPhone, Find My Friends, and Apple Maps;

h. All records pertaining to the types of service used;

i. All records pertaining to communications between Apple and any person


regarding the account, including contacts with support services and records of actions taken; and

j. All files, keys, or other information necessary to decrypt any data produced in an
encrypted form, when available to Apple (including, but not limited to, the keybag.txt and
fileinfolist.txt files).

55
Case 1:19-mc-00029-CRC Document 29-13 Filed 04/28/20 Page 189 of 189

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A which
consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction ofjustice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban), from June
I, 2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

1. All existing printouts from original storage which concern the categories identified in
subsection II.a

56
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 1 of 61

AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the properly lo be searched ) Case: 1: 18-sc-02582
or identify the person by name and address) ) Assigned To: Howell, Beryl A.
INFORMATION ASSOCIATED WITH THREE ) Assign . Date: 8/3/2018
ACCOUNTS STORED AT PREMISES CONTROLLED ) Description: Search & Seizure Warrant
BY MICROSOFT, GOOGLE, AND APPLE )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Western District of Washington
(identify the person or describe the properly to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before August 15, 2018 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to I 0:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell, Chief U.S. District Judge
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued:

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 2 of 61

AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No. : Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of :

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 3 of 61

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the email address:

created or maintained between September 11, 2017 and present, that is stored at premises owned,

maintained, controlled, or operated by Microsoft Corp., d/b/a Hotmail, a company headquartered

at One Microsoft Way, Redmond, WA 98052.

45
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 4 of 61

ATTACHMENTB

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to the Provider or have been
preserved pursuant to a preservation request under 18 U.S.C. § 2703(f), the Provider is required
to disclose the following information to the government for each account or identifier listed in
Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail described above
in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above in Section I.A,
including log files, dates, times, methods of connecting, ports, dial ups, and/or locations;

e. All records or other information stored by an individual using the account, including
address books, contact and buddy lists, calendar data, pictures, and files;

f. Records or other information regarding the identification of the account described above
in Section I.A, to include application, full name, physical address, telephone numbers and
other identifiers, records of session times and durations, log-in IP addresses associated
with session times and dates, account status, alternative e-mail addresses provided during
registration, all screen names associated with subscribers and/or accounts, all account
names associated with the subscriber,

g. All records indicating the services available to subscribers of the electronic mail address
described above in Section I.A.;

46
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 5 of 61

II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. §4(misprisionofafelony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban) from June 1,
2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

47
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 6 of 61

i. All existing printouts from original storage which concern the categories identified in
subsection II.a

48
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 7 of 61
AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT f


for the AUG ._ 3 201H
District of Columbia Clerk, U. S, lllstrlct & Bankrupic}
Courts for t~e District of Columola
In the Matter of the Search of ) Case: 1:18-sc-02583
(Briefly describe rhe property to be searched )
or ide11tifj1 l11e person by name a11d,addrcss) ) Assigned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH THREE ACCOUNTS ) Assign. Date : 8/3/2018
STORED AT PREMISES CONTROLLED BY MICROSOFT, )
GOOGLE, AND APPLE )
Description: Search & Seizure Warrant

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its localion):

See Attachment C
located in the - - - - - District of
- - -Northern California
- -- - - - - - - - - -
, there is now concealed (identify the
person or describe the property to be seized):
See Attachment D

The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
~ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
18 u.s.c. §§ 1505, 1512, 1513 Obstruction of justice, Witness tampering
18 U.S.C. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of _ _ days (give exact ending date if more than 30 days: _ _ _ _ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on ~

Reviewed by AUSA/SAUSA: Applicam's signature

!Aaron Zelinsky (ASC) Andrew Mitchell, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date:
.Judge 's signature

City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and litle
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 8 of 61

]: i,'
AUG - 3 2018
Clerk, U.S. ()istrlc:t & Bunkruptc}'
Courts tor the District of Columbia
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

lN THE MATTER OF THE SEARCH OF Case: 1: 18-sc-02583


INFORMATION AS SOCIATED WITH Assigned To : Howell, Beryl A.
THREE ACCOUNTS STORED AT Assign . Date : 8/3/2018 .
PREMISES CONTROLLED BY Descript ion: Search & Seizure Warrant
MICROSOFT, GOOGLE, AND APPLE

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the following:

a. The email accoun (hereafter "Target Account 1), that is

stored at premises owned, maintained, controlled, or operated by Microsoft, Inc., a business with

offices located at One Microsoft Way, Redmond, Washington, 98052. The information to be

disclosed by Microsoft and searched by the government is described in the following paragraphs

and in Attachments A and B.

b. The email account (hereafter "Target Account 2"), that is

stored at premises owned, maintained, controlled, or operated by Google, Inc., a business with

offices located at 1600 Amphitheatre Parkway, Mountain View, California, 94043. The

information to be disclosed by Google and searched by the government is described in the

following paragraphs and in Attachments C and D.

c. The iCloud account associated with the Apple email account

(hereafter "Target Account 3"), that is stored at premises owned,


Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 9 of 61

maintained, controlled, or operated by Apple, Inc., a business with offices located at 1 Infinite

Loop, Cupertino, California 95014. The information to be disclosed by Apple and searched by

the government is described in the following paragraphs and in Attachment E and F.

2. I, Andrew Mitchell, am a Special Agent with the Federal Bureau of Investigation

(FBI), and have been since 2011. As a Special Agent of the FBI, I have received training and

experience in investigating criminal and national security matters.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Accounts contain communications relevant to

18 U.S.C. § 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4

(misprision of a felony), 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18

U.S.C. § 1030 (unauthorized access of a protected computer); 18 U.S.C. §§ 1505 and 1512

(obstruction of justice), 18 U.S.C. § 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18

U.S.C. § 1349 (attempt and conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign

contribution ban) (the "Subject Offenses").

5. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for Roger STONE' address, (Target

Account 1). On October 17, 2017, Chief Judge Howell issued a search warrant for STONE's

address, (Target Account 2). On or about March 14, 2018, Chief

Judge Howell issued a search warrant for STONE's iCloud account (Target Account 3). This

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 10 of 61

warrant seeks to search those accounts from the date each respective warrant was issued to the

present.

JURISDICTION

6. This Court has jurisdiction to issue the requested warrant because it is "a comt of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id.§§ 2703(a), (b)(l)(A), & (c)(l)(A).

Specifically, the Court is "a district court of the United States (including a magistrate judge of

such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below,

including in paragraphs 14, 19, and 61.

SUMMARY

7. This application seeks authority to search, from the date of search warrants

previously issued by the Court to the present, three accounts believed to be used by Roger

STONE: Target Account 1, which is STONE's Hotmail account; Target Account 2, which is

STONE's Gmail account; and Target Account 3, which is STONE's iCloud account. As set

forth herein, there is probable cause to believe that each of the Subject Accounts contains

evidence of the Subject Offenses, including ongoing efforts to obstruct justice, tamper with

witnesses, and make false statements.

8. For example, as set forth in more detail below, in recent months STONE has

reached out to communicate with multiple witnesses he knew or had reason to believe were

scheduled to testify before Congress about interactions with STONE during the 2016 presidential

campaign or were scheduled to meet with the Special Counsel's Office

. After STONE learned that one witness, Randy

CREDICO, was prepared to contradict STONE's congressional testimony, STONE repeatedly

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 11 of 61

urged CREDICO to assert the Fifth Amendment and decline to answer questions, and did so

through multiple text messages. In June 2018, STONE instructed his private investigator to

provide him with a full background investigation on another witness who had

done information technology work for STONE during the campaig

9. In September 2017, STONE released a statement he said he provided to Congress

in which he denied having advance knowledge of "the source or actual content of the Wikileaks

disclosures regarding Hillary Clinton." He also stated publicly that when he tweeted during the

campaign, on August 21, 2016, "it will soon the Podesta's time in the barrel," he was not

referring to the hacking or publication of John Podesta's emails, but rather to "Podesta's business

dealings with Russia." Evidence obtained in the investigation, however, shows the following:

a. On or about July 25, 2016, Roger STONE emailed Jerome CORSI to "Get

to Assange" at the Ecuadorian Embassy and "get pending WikiLeaks emails[.]" Julian

AS SAN GE is the founder of WikiLeaks. On or about July 31, 2016, STONE also instructed

CORSI to have contact ASSANGE. On or about August 2, 2016, CORSI

responded to STONE that the "[w]ord is friend in embassy plans 2 more dumps. One shortly

after I'm back. 2nd in Oct. Impact planned to be very damaging .... Time to let more than

Podesta to be exposed as in bed w enemy if they are not ready to drop HRC." After receipt of

that message, on or about August 21, 2016, using@RogerJStoneJR, STONE tweeted: "Trust me,

it will soon the Podesta's time in the barrel. #CrookedHillary."

b. Information disclosures subsequently occurred on or about the times

CORSI predicted: On or about August 12, 2016, the day CORSI was scheduled to return to the

United States ("shortly after I'm back"), Guccifer 2.0 released hacked information related to the

4
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 12 of 61

Democratic Congressional Campaign Committee (DCCC). On or about October 7, 2016, the day

the Washington Post published a breaking story about an Access Hollywood videotape of then-

candidate Trump making disparaging remarks about women, WikiLeaks released emails hacked

from the account of John Podesta.

c. Furthermore, on the day of the Access Hollywood video disclosure, there

were phone calls between STONE and CORSI after the Washington Post contacted STONE

prior to publication. At approximately 11 :OOAM, the Washington Post received a tip regarding

the Access Hollywood video. Approximately one hour later, shortly before noon, STONE

received a call from the Washington Post. Approximately ninety minutes later, before 2:00PM,

STONE called CORSI and they spoke. Approximately forty minutes later, CORSI called

STONE and the two spoke again at length. At approximately 4:00PM, the Washington Post

published its story regarding the Access Hollywood tape. By approximately 4:30PM, WikiLeaks

tweeted out its first release of emails hacked from John Podesta.

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 13 of 61

PROBABLE CAUSE.

A. Background on Relevant Individuals

i. Roger STONE

10. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

11. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WND.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 14 of 61

B. U.S. Intelligence Community Assessment of Russian Government-Backed Hacking


Activity during the 2016 Presidential Election

13. On October 7, 2016, the U.S. Department of Homeland Security and the Office of

the Director of National Intelligence released a joint statement of an intelligence assessment of

Russian activities and intentions during the 2016 presidential election. In the report, the USIC

assessed the following:

a. The U.S. Intelligence Community ("USIC") is confident that the Russian

Government directed the recent compromises of emails from .US persons and institutions,

including from US political organizations. The recent disclosures of alleged hacked emails on

sites like DCLeaks.com and WikiLeaks and by the Guccifer 2.0 online persona are consistent

with the methods and motivations of Russian-directed efforts. These thefts and disclosures were

7
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 15 of 61

intended to interfere with the U.S. election process. Such activity is not new to Moscow-the

Russians have used similar tactics and techniques across Europe and Eurasia, for example, to

influence public opinion there. We believe, based on the scope and sensitivity of these efforts,

that only Russia's senior-most officials could have authorized these activities.

14. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

a. "Russian President Vladimir Putin ordered an influence campaign in 2016

aimed at the US presidential election. Russia's goals were to undermine public faith in the US

democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her

electability and potential presidency. We further assess Putin and the Russian Government

developed a clear preference for President-elect Trump."

b. The USIC also described, at a high level, some of the techniques that the

Russian government employed during its interference. The USIC summarized the efforts as a

"Russian messaging strategy that blends covert intelligence operations-·such as cyber activity-

with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

c. With respect to "cyber activity," the USIC assessed that "Russia's

intelligence services conducted cyber operations against targets associated with the 2016 US

presidential election, including targets associated with both major US political parties." Further1

"[i]n July 2015, Russian intelligence gained access to Democratic National Committee (DNC)

networks and maintained that access until at least June 2016." The USIC attributed these cyber

8
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activities to the Russian GRU, also known as the Main Intelligence Directorate: "GRU

operations resulted in the compromise of the personal e-mail accounts of Democratic Party

officials and political figures. By May, the GRU had exfiltrated large volumes of data from the

DNC." The GRU is the foreign military intelligence agency of the Russian Ministry of Defense,

and is Russia's largest foreign intelligence agency.

d. With respect to the release of stolen materials, the USIC assessed "with

high confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

e. Guccifer 2.0, who claimed to be an independent Romanian hacker, made

multiple contradictory statements and false claims about his identity throughout the election.

C. Additional Hacking Activity by Individuals Associated with the GRU

15. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 campaign through at least

November 1, 2016.

16. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September,"these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

17. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later posted on DCLeaks.

9
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I 8. On or about November I, 20 I 6, individuals associated with the GRU

spearphished over I 00 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

19. On or about July 13, 2018, a grand jury in this District indicted eleven GRU

officers for knowingly and intentionally conspiring to hack into the computers of U.S. persons

and entities involved in the 2016 U.S. presidential election, steal documents from those

computers, and stage releases of stolen documents in order to interfere with the election. The

victims of the hacking and releases included the DNC, the Democratic Congressional Campaign

Committee ("DCCC"), and the chairman of the Clinton campaign (John Podesta). See United

States v. Viktor Borisovich Netyksho, et al. (l: I 8-cr-215) (D.D.C.). 1

D. Roger STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

20. On June 14, 2016, Crowdstrike, the forensic firm that sought to remediate an
I

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors. The media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

-In that post, Guccifer 2.0 also began releasing hacked DNC documents.

21. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

1
A twelfth defendant was charged with conspiring to infiltrate computers of organizations responsible for
administering elections, including state boards of election, secretaries of state, and companies that supply software
and other technology used to administer elections.

10
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 18 of 61

22. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Gucci fer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world

would see for themselves how the Democrats had rigged the game."

23. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by ASSANGE to Russia

Today (RT) several days earlier about an upcoming "October Surprise" aimed at the Hillary

Clinton presidential campaign. Specifically, STONE was asked: "With regard to the October

surprise, what would be your forecast on that given what Julian Assange has intimated he's

going to do?" STONE responded: "Well, it could be any number of things. I actually have

communicated with Assange. I believe the next tranche of his documents pertain to the Clinton

Foundation but there's no telling what the October surprise may be." A few days later, STONE

clarified that while he was not personally in touch with ASSANGE, he had a close friend who

served as an intermediary.

24. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

25. On August 13, 2016, Stone posted a tweet using @RogerJStoneJr calling Guccifer

2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day, Guccifer 2.0's

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Twitter account was reinstated.

26. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

27. On August 18, 2016, Paul Manafort, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign.

28. As noted above, on August 21, 2016, using@RogerJStoneJR, STONE tweeted:

"Trust me, it will soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN

interview that same day, STONE reiterated that because of the work of a '"mutual acquaintance'

of both his and [ASSANGE] , the public [could] expect to see much more from the exiled

whistleblower in the form of strategically-dumped Clinton email batches." He added: "Well,

first of all, I think Julian Assange is a hero ... I think he's taking on the deep state, both

Republican and Democrat. I believe that he is in possession of all of those emails that Huma

Abedin and Cheryl Mills, the Clinton aides, believe they deleted. That and a lot more. These are

like the Watergate tapes."

29. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

30. On Saturday, October 1, 2016, using @RogerJStoneJr, STONE tweeted,

"Wednesday @ HillaryClinton is done. #WikiLeaks."

31. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement ASSANGE had schec;luled for the next day from the balcony

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of the Ecuadoran Embassy in London. On the day of the AS SAN GE announcement - which was

part of WikiLeaks' 10-year anniversary celebration - STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used @RogerJStoneJ r

to tweet: "Payload coming. #Lockthemup."

32. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

33. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

34. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta- referring back to STONE's August 21,

2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

35. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

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from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

E. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

36. On August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the

Twitter account @RogerJStoneJr. Information recovered from the search of that account

includes the following:

a. On October 13, 2016, while WikiLeaks was in the midst ofreleasing the

hacked Podesta emails, @RogerJStoneJr sent a private direct message to the Twitter account

@wikileaks. This account is the official Twitter account of WikiLeaks and has been described as

such by numerous news reports. The message read: "Since I was all over national TV, cable and

print defending WikiLeaks and assange against the claim that you are Russian agents and

debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

b. Less than an hour later, @wikileaks responded by direct message: "We

appreciate that. However, the false claims of association are being used by the democrats to

undermine the impact of our publications. Don't go there if you don't want us to correct you."

c. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends ar·e."

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d. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

e. In addition, @RogerJStoneJr also exchanged direct messages with

ASSANGE. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with ASSANGE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

f. On Saturday, June I 0, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

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F. STONE's Communications with STONE and Others Regarding


Forthcoming Leaks

37. As indicated above, on September 11, 2017, Chief Judge Howell issued a search

warrant for STONE' address (Target Account 1); on

October 17, 2017, Chief Judge Howell issued a search warrant for STONE' address,

(Target Account 2); and on or about March 14, 2018, Chief Judge

Howell issued a search warrant for STONE's iCloud account (Target Account 3). In addition,

on or about December I 9, 2017, Chief Judge Howell issued a search warrant fo

email account. Information recovered pursuant to those search warrants includes the following:

a. On or about May 15, 2016, emailed CORSI: "Here is my

flight schedule. Need to get something confirmed now .... " CORSI responded, "I copied

Roger Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

appears to have forwarded the message to STONE at Target Account 1, who replied to CORSI

that, "May meet Manafort -guarantee nothing."

b. On or about May 18, 2016, CORSI emailed STONE at Target Account 1

with the title, "Roger -- why don't you look this over before I send i I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

c. On July 25, 2016, STONE, using Target Account 1, sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

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[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

d. On or about July 3I,2016, STONE, using Target Account 1, emailed

CORSI with the subject line, "Call me MON." The body of the email read: should see

Assange[.] should find Bernie [S]anders brother who called Bill a Rapist- turn him for

Trump[.] should find or more proof of Bill getting kicked out."

e. As noted above, on or about August 2, 2016 (approximately 19 days

before STONE publicly tweeted about "Podesta's time in the barrel"), CORSI emailed STONE

at Target Account 1: "Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued: "Signs are Fox

will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HRC an artifact ofrigged polling. Won't last. I expect

presidential campaign to get serious starting Sept. Still in pre-season games. Time to let more

than Podesta to be exposed as in bed w enemy if they are not ready to drop HRC. That appears

to be the game hackers are now about. Would not hurt to start suggesting HRC old, memory

bad, has stroke -- neither he nor she well. I expect that much of next dump focus, setting stage

for Foundation debacle." Investigators believe that CORSI's reference to a "friend in embassy

[who] plans 2 more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in

2016.

f. On or about August 5, 2016, an associate of STONE's,

emailed Stone at Target Account 1. The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded, "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

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same time, STONE told him he had gone to London to meet ASSANGE. also stated

that in 2018, told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting ASSANGE. STONE tol he was joking and

had not actually met ASSANGE. 2

g. On or about August 15, 2016, CORSI emailed STONE at Target Account

1: "Give me a call today if you can. Despite MSM drumroll that HRC is already elected, it's not

over yet. More to come than anyone realizes. Won't really get started until after Labor Day. I'm

in NYC this week. Jerry."

h. On or about August 31, 2016, CORSI emailed STONE at Target Account

1: "Did you get the PODESTA writeup." STONE replied "[y]es."

i. On or about August 31, 2016, CORSI messaged STONE at Target

Account 3, "Podesta paid $180k to invest in Uranium One - was hired by Rosatom in Giustra

scandal. Podesta now under FBI investigation - tied to Ukraine Y anukovych - Panama papers

reveals Podesta hired by S[b]erbank, Russia's largest financial institution - Podesta$$$ ties to

Russia undermine Clinton false narrative attempting to tie Trump to Putin."

J. On or about September 6, 2016, CORSI emailed STONE at Target

Account 1: "Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

k. On or about September 24, 2016, emailed CORSI, "I will

have much more on Turkey. Need a back channel highly sensitive stuff." CORSI responded,

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 26 of 61

"We have secure back channel through Roger. I saw him again in NYC last Friday and spoke to

him about it again today." wrote back, "Awaiting secret file. Explosive ... Hope you

are well. Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me

posted about file[.]" ln a subsequent meeting with investigators indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

I. On or about October 3, 2016, an associate of STONE emailed STONE at

Target Account 2 and asked: "Assange -what's he got? Hope it's good." STONE wrote back,

"It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will be

out in Jan. Many scores will be settled." The associate forwarded the email to Steve BANNON,

who was CEO of the Campaign at the time, and wrote: "You should call Roger. See below. You

didn't get from me." BANNON wrote back, "I've got important stuff to worry about." The

associate responded, "Well clearly he knows what Assange has. I'd say that's important."

m. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

AS SANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

n. On or about October 4, 2016, CORSI messaged STONE at Target

Account 3, "Assange made a fool of himself. Has nothing or he would have released it. Total

BS hype."

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 27 of 61

o. That same day, BANNON emailed STONE at Target Account 2, "What

was that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are

going to kill him and the London police are standing done [sic]." BANNON wrote back, "He

didn't cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawyer is a

big democrat."

p. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

G. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released

38. According to a publicly available news article, 3 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood' and NBC for reaction."

39. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE which STONE did not answer.

3
https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-then-the-race-was-
on/2016/10/07/3 ld74714-8ce5-1 Ie6-875e-2cl bfe943b66_story.html

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40. At approximately I I :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

41. At approximately I :42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

42. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

43. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

44. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE on Target Account 1, "I expect that much

of next dump focus, setting stage for Foundation debacle."

45. At approximately 6:27PM, an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks - The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using Target

Account 2, forwarded message to CORSI without comment. STONE does not appear

to have forwarded the email to any other individual.

H. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

46. On or about October 8, 2016, STONE, using Target Account 3, messaged

CORSI, "Lunch postponed-have to go see T." CORSI responded to STONE, "Ok. I

understand." Approximately twenty minutes later, CORSI texted, "Clintons know they will lose

21
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 29 of 61

a week of Paula Jones media with T attacking Foundation, using Wikileaks Goldman Sachs

speech comments, attacking bad job numbers."

47. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

using Target Account 2, emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM, "need your BEST podesta pieces." CORSI

wrote back at approximately 8:54AM, "Ok. Monday. The remaining stuff on Podesta is

complicated. Two articles in length. I can give you in raw form the stuff I got in Russian

translated but to write it up so it's easy to understand will take weekend. Your choice?"

48. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails, as noted above. At approximately 3:25PM,

CORSI emailed STONE at both Target Account 1 and 2 with the subject line "Podesta talking

points." Attached to the email was a file labeled, "ROGER STONE podesta talking points Oct

12 2016.docx." The "talking points" included the statement that "Podesta is at the heart of a

Russian-government money laundering operation that benefits financially Podesta personally and

the Clintons through the Clinton Foundation."

49. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via Target Account 1: "Got them and used them."

50. On or about Thursday, October 13, 2016, CORSI emailed STONE at Target

Account 2: "PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to CLINTON

FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could post under my

by-line since I am the one under attack by Podesta and now Mook." CORSI wrote back to

STONE, "I'll give you one more-NOBODY YET HAS THIS[:] It looks to me like

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 30 of 61

skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.J The Russians launched a criminal investigation[.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

51. On or about Thursday, October 13, 2016, at approximately 6:30PM, CORSI sent

STONE an email at Target Account 2, with the subject, "ROGER STONE article RUSSIAN

MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and JOHN

PODESTA." The text stated: "Roger[,] You are free to publish this under your own name."

That same day, STONE posted a blog post with the title, "Russian Mafia money laundering, the

Clinton Foundation and John Podesta." In that post, STONE wrote, "although I have had some

back-channel communications with Wikileaks I had no advance notice about the hacking of Mr.

Podesta nor I have I ever received documents or data from Wikileaks." The post then asked,

"Just how much money did a controversial Russian billionaire investor with

ties to the Vladimir Putin and the Russian government, launder through Metcombank, a Russian

regional bank owned 99.978 percent by with the money transferred via Deutsche

Bank and Trust Company Americas in New York City, with the money ending up in a private

bank account in the Bank of America that is operated by the Clinton Foundation?"

52. On or about October 14, 2016, CORSI sent a message to STONE at Target

Account 3, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

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53. On or about October 17, 2016, CORSI messaged STONE at Target Account 3,

"On Assange, can you call me now - before 2pm[.]" STONE responded, "Missed u - just

landed JFK - on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

54. On or about October 17, 2016, CORSI emailed STONE at Target Accounts 1

and 2 with the subject, "Fwd: ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted

source," and forwarded an email with the header information stripped out, showing only the

body text. The email read, "Yes[.] I figured this. Assange is threatening Kerry, Ecuador and

U.K. He will drop the goods on them if they move to extradite him. My guess is that he has a set

of dead man files that include Hillary. It's what they used to call a 'Mexican stand offT.]' Only

hope is that if Trump speaks out to save him[.] Otherwise he's dead anyway, once he's dropped

what he has. If HRC wins, Assange can kiss his life away. Interesting gambit Assange has to

play out. He's called Podesta's bluff and raised him the election."

55. On or about October 18, 2016, CORSI messaged STONE at Target Account 3,

"Pls call. Important."

56. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had "no advance notice of Wikileaks' hacking of Podesta' s e-mails."

STONE stated, "I predicted that Podesta's business dealings would be exposed. I didn't hear it

from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

57. On or about November 8, 2016, the United States presidential election took place.

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 32 of 61

58. On or about November 9, 2016, CORSI messaged STONE at Target Account 3,

"Congratulations, Roger. He could not have done it without you."

59. On or about November I 0, 2016, CORSI messaged STONE at Target Account 3,

"Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in London.

Have some interesting news for you."

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J. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikileaks

61. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCI). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic asse1tions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta's email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such assertions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trust me, it will soon be the Podesta's
time in the ban-el. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta' s email, but
does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrutiny ....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 35 of 61

I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
. Assange to independently confirm this report, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
information proved to be correct. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

62. In a document dated March 26, 2018 titled "Minority Views," Democratic

members of HPSCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in
communication with Assange or communication through an intermediary with Assange,
you were only refe1Ting to a single fact that you had confirmed with the intermediary -
MR. STONE: That -
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is correct, even though it was repeated to me on numerous separate
occasions.

63. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an miicle on his website, stonecoldtruth.com, titled "Is it the Podesta's

Time in the Barrel Yet?" In that article, STONE stated: "[I]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

K. STONE's Use of Target Account 3 to Message Randy CREDI CO about STONE's


"Back channel"

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64. On November 19, 2017, Randy CREDICO (who, as described further below,

STONE publicly identified as his "intermediary" to ASSANGE), messaged STONE on Target

Account 3, "My lawyer wants to see me today." STONE responded, '"Stonewall it. Plead the

fifth. Anything to save the plan' ........ Richard Nixon[.]" CREDlCO responded, "Ha ha."

65. On or about November 21, 2017, CRED ICO messaged STONE on Target

Account 3, "I was told that the house committee lawyer told my lawyer that I will be getting a

subpoena[.]" STONE wrote back, "That was the point at which your lawyers should have told

them you would assert your 5th Amendment rights if compelled to appear." They continued to

message, and CREDICO wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To

do what ? Nothing happening in DC the day before Thanksgiving - why are u busting my

chops?"

66. On or about November 24, 2017, STONE, using Target Account 3, texted

CREDICO, "Assange is a journalist and a damn good one- meeting with him is perfectly legal

and all you ever told me was he had the goods [o]n Hillary and would publish them - which he

himself said in public b4 u told me. It's a fucking witchunt [sic]." CREDICO replied, "Itold

you to watch his tweets. That's what I was basing it on. I told you to watch his Tweets in

October not before that I knew nothing about the DNC stuffl.] I just followed his tweets[.]"

STONE responded, "U never said anything about the DNC but it was August." CREDICO

wrote back, "It was not August because I didn't interview him or meet him until August 26th[.]

That was my first communication with his secretary in London, August 26th." STONE wrote

back, "Not the way I remember it- oh well I guess Schiff will try to get one of us indicted for

perjury[.]"

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 37 of 61

67. STONE and CREDICO continued to exchange messages via Target Account 3,

and on November 24, 2017, CREDI CO wrote to STONE, "Forensic evidence proves that there is

no back Channel. So now you can relax."

68. On or about November 28, 2017, CREDI CO tweeted a copy of a subpoena he

received from HPSCT that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

69. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that, "Credico merely []

confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credico never said he knew or had any information as to source or

content of the material."

70. On or about December 1, 2017, CREDICO messaged STONE on Target

Account 3, stating, "I don't know why you had to lie and say you had a back Channel now I had

to give all of my forensic evidence to the FBI today what a headache[.] 4 You could have just told

him the truth that you didn't have a back Channel they now know that I was not in London until

September of this year[.] You had no back-channel and you could have just told the truth ...

You want me to cover you for pe1jury now[.]" STONE responded, "What the fuck is your

problem? Neither of us has done anything wrong or illegal. You got the best press of your life

and you can get away with asserting for 5th Amendment rights if u don't want talk about AND if

4
Contrary to his statement, CREDICO has not provided any forensic evidence to the FBI.

30
Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 38 of 61

you turned over anything to the FBI you're a fool." CREDICO responded, "You open yourself

up to six counts of perjury[.] But I'm sure that wasn't sworn testimony so you're probably

clear[.] Council for the committee knows you never had a back Channel and if you had just told

the truth wouldn't have put me in this bad spot ... you should go back ... and amend your

testimony and tell them the truth." CREDICO repeated: "you need to amend your testimony

before I testify on the 15th." STONE replied, "If you testify you 're a fool. Because of tromp

[sic] I could never get away with a certain [sic] my Fifth Amendment rights but you can. I

guarantee you you [sic] are the one who gets indicted for perjury if you're stupid enough to

testify[.]"

71. STONE and CREDICO continued to message each other on or about December I,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fuck off good night." CREDI CO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

72. On or about December 13, 2017, according to public reporting, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

73. STONE and CREDICO continued to exchange messages via Target Account 3,

and on or about January 6, 2018, CREDICO indicated to STONE that he was having dinner with

a reporter. STONE responded, "Hope u don't fuck Up my efforts to get Assange a pardon[.]"

CREDICO messaged STONE, "I have the email from his chief of staff August 25th 2016

responding to an email I sent to WikiLeaks website email address asking you would do my

show[.] That was my initial contact."

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74. On or about January 8, 2018, CREDI CO messaged STONE on Target Account 3

stating: "Embassy logs ... + 17 other pieces of information prove that r did not have any

conversations with Assange until September of last year."

75. CREDICO and STONE continued to message each other, and on or about January

25, 2018, CREDICO wrote to STONE on Target Account 3: "You lied to the house Intel

committee . .. But you' 11 get off because you' re friends with Trump so don't worry. I have all

the forensic evidence[.] I was not a ba[ck] Channel and I have all those emails from September

of 2016 to prove it[.]"

76. On or about April 13, 2018, news reports stated that CREDICO had shown

reporters copies of email messages he had received from STONE in the prior few days that

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

. from you," referring to CREDICO's therapy dog. CREDICO stated that it was "ce1iainly scary .

. . When you start bringing up my dog, you're crossing the Jine[.]" 5

77. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

5
https://www.yahoo.com/news/comedian-randy-credico-says-trump-adviser-roger-stone-threatened-dog-
l 359 l l370.html

6
https ://www.motherjones.com/politics/20 18/05/ro ger-stone-to-associate-prepare-to-d ie/

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He was depressed about it. Or was he lying." The article noted that CREDICO stated he did not

have prostate cancer and did not have any such discussion with STONE.

L. STONE's Use of the Target Accounts to Communicate with Individuals Related to


the Investigation

78. On May 17, 2018 , Ghief Judge Howell issued an order for the use of pen-trap

devices on Target Account 1 and Target Account 2. The information obtained from that order,

along with information obtained from toll records, revealed that STONE has continued to use

Target Account 1 and Target Account 2, and that he has used them to communicate with

individuals related to the investigation.

79. For example, STONE and communicated twice on May 28 and May

29, 2018 using Target Account 1. , a former associate of STONE's, was

interviewed by the Special Counsel's Office on or about May 2, 2018. Toll records show that

and STONE communicated multiple times on May 5, 2018, and STONE

communicated wit using Target Account 1 on June 1, 2018 and June 6, 2018

a private investigator who had previously worked with STONE and who was hired

by STONE to research individuals associated with this case (as described fmther below),

communicated with STONE on Target Account 1 at least four times between May 27, 2018 and

July 12, 2018.

80. STONE has also used Target Account 2 to communicate with individuals

associated with this investigation.

a. For example, between May 23, 2018 and the present, STONE and CORSI

exchanged at least five messages using Target Account 2. In the same time period, STONE

exchanged at least 75 emails with CREDICO using Target Account 2.

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 41 of 61

b. Also in this same time period, STONE emailed at least

ten times using Target Account 2. is a former employee of STONE. On May 9,

2018, FBI agents approache and That day,

and again on May 10, 2018 communicated by phone with

STONE. Overall, between May 23, 2018 and the present, STONE exchanged over 100 emails

wit using Target Account 2. In addition, between on or about June 14,2018 and

June 17, 2018 and STONE exchanged five emails using Target Account 2.

81. STONE has also used a phone number associated with Target Account 3 to

communicate with a private investigator hired by STONE. was

interviewed by investigators on June 7, 2018, and subsequently informed investigators that in

June 2018, STONE instructed him to conduct a full background investigation on

who had been employed by STONE during the Campaign as an information technology

specialist.

also told investigators that in June 2018, STONE instructed him to find

an address for CREDICO that could be used to serve CREDICO with legal process.

told investigators that his primary form of communication with STONE is by text

message on Target Account 3.

BACKGROUND CONCERNING EMAIL

82. In my training and experience, I have learned the Providers provide a variety of

on-line services, including electronic mail ("email") to the public. The Providers allow

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Case 1:19-mc-00029-CRC Document 29-14 Filed 04/28/20 Page 42 of 61

subscribers to obtain email accounts at the domain names identified in the email address

contained in Attachment A and C. Subscribers obtain an account by registering with the

Providers. During the registration process, the Providers ask subscribers to provide basic

personal information. Therefore, the computers of the Providers are likely to contain stored

electronic communications (including retrieved and unretrieved email) for their subscribers and

information concerning subscribers and their use of services, such as account access information,

email transaction information, and account application information. In my training and

experience, such information may constitute evidence of the crimes under investigation because

the information can be used to identify the account's user or users.

83. In my training and experience, email Providers generally ask their subscribers to

provide certain personal identifying information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and

other identifiers, alternative email addresses, and, for paying subscribers, means and source of

payment (including any credit or bank account number). In my training and experience, such

information may constitute evidence of the crimes under investigation because the information

can be used to identify the account's user or users. Based on my training and my experience, I

know that, even if subscribers insert false information to conceal their identity, this information

often provides clues to their identity, location, or illicit activities.

84. In my training and experience, email Providers typically retain certain

transactional information about the creation and use of each account on their systems. This

info1mation can include the date on which the account was created, the length of service, records

of log-in (i.e., session) times and durations, the types of service utilized, the status of the account

(including whether the account is inactive or closed), the methods used to connect to the account

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(such as logging into the account via the Providers ' website), and other log files that reflect

usage of the account. In addition, email Providers often have records of the Internet Protocol

address ("IP address") used to register the account and the IP addresses associated with particular

logins to the account. Because every device that connects to the Internet must use an IP address,

IP address information can help to identify which computers or other devices were used to access

the email account.

85. In my training and experience, in some cases, email account users will

communicate directly with an email service Providers about issues relating to the account, such

as technical problems, billing inquiries, or complaints from other users. Email Providers

typically retain records about such communications, including records of contacts between the

user and the Providers' support services, as well as records of any actions taken by the Providers

or user as a result of the communications. In my training and experience, such information may

constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users.

86. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of

occupancy" while executing a search warrant at a residence. For example, email

communications, contacts lists, and images sent (and the data associated with the foregoing, such

as date and time) may indicate who used or controlled the account at a relevant time. Further,

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info1mation maintained by the email Providers can show how and when the account was

accessed or used. For example, as described below, email Providers typically log the Internet

Protocol (IP) addresses from which users access the email account, along with the time and date

of that access. By determining the physical location associated with the logged IP addresses,

investigators can understand the chronological and geographic context of the email account

access and use relating to the crime under investigation. This geographic and timeline

information may tend to either inculpate or exculpate the account owner. Additionally,

information stored at the user's account may further indicate the geographic location of the

account user at a particular time (e.g., location information integrated into an image or video sent

via email). Last, stored electronic data may provide relevant insight into the email account

owner's state of mind as it relates to the offense under investigation. For example, information in

the email account may indicate the owner's motive and intent to commit a crime (e.g.,

communications relating to the crime), or consciousness of guilt (e.g., deleting communications

in an effort to conceal them from law enforcement).

87. In my training and experience, information such as search history can help to

show the state of mind of an individual at the time the search was made, as well as the

individuals potential advance knowledge of events, as they search to see if the anticipated event

has occurred.

INFORMATION REGARDING APPLE ID AND iCLOUD 7

The information in this section is based on information published by Apple on its website, including, but
not limited to, the following document and webpages: "U.S. Law Enforcement Legal Process Guidelines," available
at http://images.apple.com/ privacy/docs/lee.al-process-guidelines-us.pdf; "Create and start using an Apple ID,"
available at https://support.app le.oom/en-us/HT203993; "iCloud," available at http://www.appl e.com/icloud/; "What
does iCloud back up?," available at https://supporl.apple.com/kb/PH125 l9; "iOS Security," available at
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88. Apple is a United States company that produces the iPhone, iPad, and iPod

Touch, all of which use the iOS operating system, and desktop and laptop computers based on

the Mac OS operating system.

89. Apple provides a variety of services that can be accessed from Apple devices or,

in some cases, other devices via web browsers or mobile and desktop applications ("apps"). As

described in further detail below, the services include email, instant messaging, and file storage:

a. Apple provides email service to its users through email addresses at the

domain names mac.corn, me.com, and icloud.com.

b. iMessage and FaceTime allow users of Apple devices to communicate in

real-time. iMessage enables users of Apple devices to exchange instant messages ("iMessages")

containing text, photos, videos, locations, and contacts, while FaceTime enables those users to

conduct video calls.

c. iCloud is a file hosting, storage, and sharing service provided by Apple.

iCloud can be utilized through numerous iCloud-connected services, and can also be used to

store iOS device backups and data associated with third-party apps.

d. iCloud-connected services allow users to create, store, access, share, and

synchronize data on Apple devices or via icloud.com on any Internet-connected device. For

example, iCloud Mail enables a user to access Apple-provided email accounts on multiple Apple

devices and on icloud.com. iCloud Photo Library and My Photo Stream can be used to store and

manage images and videos taken from Apple devices, and iCloud Photo Sharing allows the user

https://"1ww.apple.com/business/docs/iOS Security Guide.pd£, and "iCloud: How Can I Use iCloud?," available at
l1t1ps://supporl.npple.com/kb/PH26502.

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to share those images and videos with other Apple subscribers. iCloud Drive can be used to

store presentations, spreadsheets, and other documents. iCloud Tabs and bookmarks enable

iCloud to be used to synchronize boolanarks and webpages opened in the Safari web browsers

on all of the user's Apple devices. iWork Apps, a suite of productivity apps (Pages, Numbers,

Keynote, and Notes), enables iCloud to be used to create, store, and share documents,

spreadsheets, and presentations. iCloud Keychain enables a user to keep website username and

passwords, credit card information, and Wi-Fi network information synchronized across multiple

Apple devices.

e. Game Center, Apple's social gaming network, allows users of Apple

devices to play and share games with each other.

f. Find My iPhone allows owners of Apple devices to remotely identify and

track the location of, display a message on, and wipe the contents of those devices. Find My

Friends allows owners of Apple devices to share locations.

g. Location Services allows apps and websites to use information from

cellular, Wi-Fi, Global Positioning System ("GPS") networks, and Bluetooth, to determine a

user's approximate location.

h. App Store and iTunes Store are used to purchase and download digital

content. iOS apps can be purchased and downloaded through App Store on iOS devices, or

through iTunes Store on desktop and laptop computers running either Microsoft Windows or

Mac OS. Additional digital content, including music, movies, and television shows, can be

purchased through iTunes Store on iOS devices and on desktop and laptop computers running

either Microsoft Windows or Mac OS.

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90. Apple services are accessed through the use of an "Apple ID," an account created

during the setup of an Apple device or through the iTunes or iCloud services. A single Apple ID

can be linked to multiple Apple services and devices, serving as a central authentication and

syncing mechanism.

91. An Apple ID takes the form of the full email address submitted by the user to

create the account; it can later be changed. Users can submit an Apple-provided email address

(often ending in @icloud.com, @me.com, or @mac.com) or an email address associated with a

third-party email provider (such as Gmail, Yahoo, or Hotmail). The Apple ID can be used to

access most Apple services (including iCloud, iMessage, and FaceTime) only after the user

accesses and responds to a "verification email" sent by Apple to that "primary" email address.

Additional email addresses ("alternate," "rescue," and "notification" email addresses) can also be

associated with an Apple ID by the user.

92. Apple captures information associated with the creation and use of an Apple ID.

During the creation of an Apple ID, the user must provide basic personal information including

the user's full name, physical address, and telephone numbers. The user may also provide means

of payment for products offered by Apple. The subscriber information and password associated

with an Apple ID can be changed by the user through the "My Apple ID" and "iForgot" pages on

Apple's website. In addition, Apple captures the date on which the account was created, the

length of service, records of log-in times and durations, the types of service utilized, the status of

the account (including whether the account is inactive or closed), the methods used to connect to

and utilize the account, the Internet Protocol address ("IP address") used to register and access

the account, and other log files that reflect usage of the account.

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93. Additional information is captured by Apple in connection with the use of an

Apple ID to access certain services. For example, Apple maintains connection logs with IP

addresses that reflect a user's sign-on activity for Apple services such as iTunes Store and App

Store, iCloud, Game Center, and the My Apple ID and iForgot pages on Apple's website. Apple

also maintains records reflecting a user's app purchases from App Store and iTunes Store, "call

invitation logs" for FaceTime calls, "query logs" for iMessage, and "mail logs" for activity over

an Apple-provided email account. Records relating to the use of the Find My iPhone service,

including connection logs and requests to remotely lock or erase a device, are also maintained by

Apple.

94. Apple also maintains information about the devices associated with an Apple ID.

When a user activates or upgrades an iOS device, Apple captures and retains the user's IP

address and identifiers such as the Integrated Circuit Card ID number ("ICCID"), which is the

serial number of the device's SIM card. Similarly, the telephone number of a user's iPhone is

linked to an Apple ID when the user signs in to FaceTime or iMessage. Apple also may

maintain records of other device identifiers, including the Media Access Control address ("MAC

address"), the unique device identifier ("UDID"), and the serial number. In addition,

information about a user's computer is captured when iTunes is used on that computer to play

content associated with an Apple ID, and information about a user's web browser may be

captured when used to access services through icloud.com and apple.com. Apple also retains

records related to communications between users and Apple customer service, including

communications regarding a particular Apple device or service, and the repair history for a

device.

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95. Apple provides users with five gigabytes of free electronic space on iC[oud, and

users can purchase additional storage space. That storage space, located on servers controlled by

Apple, may contain data associated with the use of iCloud-connected services, including: email

(iCloud Mail); images and videos (iCloud Photo Library, My Photo Stream, and iCloud Photo

Sharing); documents, spreadsheets, presentations, and other files (iWork and iCloud Drive); and

web browser settings and Wi-Fi network information (iCloud Tabs and iCloud Keychain).

iCloud can also be used to store iOS device backups, which can contain a user's photos and

videos, iMessages, Short Message Service ("SMS") and Multimedia Messaging Service

("MMS") messages, voicemail messages, call history, contacts, calendar events, reminders,

notes, app data and settings, Apple Watch backups, and other data. Records and data associated

with third-party apps may also be stored on iCloud; for example, the iOS app for WhatsApp, an

instant messaging service, can be configured to regularly back up a user's instant messages on

iCloud Drive. Some of this data is stored on Apple's servers in an encrypted form but can

nonetheless be decrypted by Apple.

96. In my training and experience, evidence of who was using an Apple ID and from

where, and evidence related to criminal activity of the kind described above, may be found in the

files and records described above. This evidence may establish the "who, what, why, when,

where, and how" of the criminal conduct under investigation, thus enabling the United States to

establish and prove each element or, alternatively, to exclude the innocent from further

suspicion.

INFORMATION TO BE SEARCHED AND THINGS TO BE SEIZED

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97. I anticipate executing this warrant under the Electronic Communications Privacy

Act, in particular 18 U.S.C. §§ 2703(a), 2703(b)(l)(A) and 2703(c)(l)(A), by using the warrant

to require Google to disclose to the government copies of the records and other information

(including the content of communications) associated with the accounts in Attachment A, C, and

E and particularly described in Section I of Attachment B, D, and F. Upon receipt of the

information described in Section I of Attachments B, D, and F, government-authorized persons

will review that information to locate the items clescribed in Section II of Attachment B, D, and

F. The items identified in Attachments A-F will also be screened by reviewers not on the

prosecution team to identify and filter out privileged material.

CONCLUSION

98. Based on the forgoing, I request that the Court issue the proposed search warrant.

99. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

100. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Res~ ~

Andrew M i t c h e l l ~
Special Agent
Federal Bureau of Investigation

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Subscribed and sworn to before me on this i!~


lf August, 2018.

k//~fdttt7~
fe 1
The Honora Ber; l A. Howell
Chief United States District Judge

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ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the email address:

created or maintained between September 11, 2017 and pr~sent, that is stored at premises owned,

maintained, controlled, or operated by Microsoft Corp., d/b/a Hotmail, a company headquartered

at One Microsoft Way, Redmond, WA 98052.

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ATTACHMENT B

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to the Provider or have been
preserved pursuant to a preservation request under 18 U.S.C. § 2703(£), the Provider is required
to disclose the following information to the government for each account or identifier listed in
Attachment A:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail described above
in Section LA. above;

c; All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above in Section LA,
including log files, dates, times, methods of connecting, ports, dial ups, and/or locations;

e. All records or other information stored by an individual using the account, including
address books, contact and buddy lists, calendar data, pictures, and files;

f. Records or other information regarding the identification of the account described above
in Section LA, to include application, full name, physical address, telephone numbers and
other identifiers, records of session times and durations, log-in IP addresses associated
with session times and dates, account status, alternative e-mail addresses provided during
registration, all screen names associated with subscribers and/or accounts, all account
names associated with the subscriber,

g. All records indicating the services available to subscribers of the electronic mail address
described above in Section I.A.;

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II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A
which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S .C. § 3 (accessory after the fact) , 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access ofa protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban) from June I,
2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
Randy Credico, or any individual

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

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ATTACHMENT D

Particular Things to be Seized

I. Files and Accounts to be produced by Google, Inc.

To the extent that the information described in Attachment C is within the possession,
custody, or control of Google, Inc. including any messages, records, files, logs, images, videos,
or information that have been deleted but are still available to Google or have been preserved
pursuant to a preservation request under 18 U.S.C. § 2703(f), Google is required to disclose the
following information to the government for each account or identifier listed in Attachment C:

a. The contents of all e-mails, attachments and chat messages stored in the account,
including copies of e-mails sent to and from the account, draft e-mails, the source and
destination e-mails sent addresses associated with each e-mail, the date and time at which
each e-mail was sent, and the size and length of each e-mail;

b. All existing printouts from original storage of all of the electronic mail
described above in Section I.A. above;

c. All internet search data including all queries and location data;

d. All transactional information of all activity of the account described above


in Section I.A, including log files, dates, times, methods of connecting, ports, dial ups,
and/or locations;

e. All records or other information stored by an individual using the account,


including address books, contact and buddy lists, calendar data, pictures, and files;

f. All records or other information regarding the identification of the account


described above in Section I.A, to include application, full name, physical address,
telephone numbers and other identifiers, records of session times and durations, the date
on which the account was created, the length of service, the types of service utilized, the
IP address used to register the account, log-in IP addresses associated with session times
and dates, account status, alternative e-mail addresses provided during registration, all
screen names associated with subscribers and/or accounts, all account names associated
with the subscriber, methods of connecting, log files, means and source of payment
(including any credit or bank account number), and detailed billing records;

g. All records indicating the services available to subscribers of the


electronic mail address described above in Section I.A.;

h. Google+ subscriber information, circle information, including name of


circle and members, contents of posts, comments, and photos, to include date and
timestamp;

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i. Google Drive files created, accessed or owned by the account;

J. YouTube subscriber information, private videos and files, private


messages, and comments;

k. Google+ Photos contents to include all images, videos and other files, and
associated upload/download date and timestamp;

1. Google Talk and Google Hangouts conversation logs associated with the
account.

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II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment C which
consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); ·1s U.S.C. §§ 1505 and 1512 (obstruction ofjustice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban), from June
1, 2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
, Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

1.. All existing printouts from original storage which concern the categories identified in
subsection II.a

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ATTACHMENT E

Property to be Searched

This warrant applies to information associated with the following Apple DSID:

created or maintained between March 14, 2018 and the present, that is stored at premises owned,

maintained, controlled, or operated by Apple, Inc., located at One Apple Park Way, Cupertino,

California 95014.

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ATACHMENTF

Particular Things to be Seized

I. Files and Accounts to be produced by the Provider:

To the extent that the information described in Attachment E is within the possession,
custody, or control of Apple, regardless of whether such information is located within or outside
of the United States, including any messages, records, files, logs, or information that have been
deleted but are still available to Apple, or have been preserved pursuant to a request made under
18 U.S.C. § 2703(£), Apple is required to disclose the following information to the government,
in unencrypted form whenever available, for each account or identifier listed in Attachment E:

a. All records or other information regarding the identification of the account, to


include full name, physical address, telephone numbers, email addresses (including primary,
alternate, rescue, and notification email addresses, and verification information for each email
address), the date on which the account was created, the length of service, the IP address used to
register the account, account status, associated devices, methods of connecting, and means and
source of payment (including any credit or bank account numbers);

b. All records or other information regarding the devices associated with, or used in
connection with, the account (including all current and past trusted or authorized iOS devices
and computers, and any devices used to access Apple services), including serial numbers, Unique
Device Identifiers ("UDID"), Advertising Identifiers ("IDF A"), Global Unique Identifiers
("GUID"), Media Access Control ("MAC") addresses, Integrated Circuit Card ID numbers
("ICCID"), Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),
Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber
Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Numbers
("MSISDN"), International Mobile Subscriber Identities ("IMSI"), and International Mobile
Station Equipment Identities ("IMEi");

c. The contents of all emails associated with the account, including stored or
preserved copies of emails sent to and from the account (including all draft emails and deleted
emails), the source and destination addresses associated with each email, the date and time at
which each email was sent, the size and length of each email, and the true and accurate header
information including the actual IP addresses of the sender and the recipient of the emails, and
all attachments;

d. The contents of all instant messages associated with the account, including stored
or preserved copies of instant messages (including iMessages, SMS messages, and MMS
messages) sent to and from the account (including all draft and deleted messages), the source and
destination account or phone number associated with each instant message, the date and time at
which each instant message was sent, the size and length of each instant message, the actual IP
addresses of the sender and the recipient of each instant message, and the media, if any, attached
to each instant message;

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e. The contents of all files and other records stored on iCloud, including all iOS
device backups, all Apple and third-party app data, all files and other records related to iCJoud
Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWork
(including Pages, Numbers, Keynote, and Notes), iCloud Tabs and book.marks, and iCloud
Keychain, and all address books, contact and buddy lists, notes, reminders, calendar entries,
images, videos, voicemails, device settings, and book.marks;

f. . All activity, connection, and transactional logs for the account (with associated IP
addresses including source port numbers), including FaceTime call invitation logs, messaging
and query logs (including iMessage, SMS, and MMS messages), mail logs, iCloud logs, iTunes
Store and App Store logs (including purchases, downloads, and updates of Apple and third-party
apps), My Apple ID and iForgot logs, sign-on logs for all Apple services, Game Center logs,
Find My iPhone and Find My Friends logs, logs associated with web-based access of Apple
services (including all associated identifiers), and logs associated with iOS device purchase,
activation, and upgrades;

g. All records and information regarding locations where the account or devices
associated with the account were accessed, including all data stored in connection with Location
Services, Find My iPhone, Find My Friends, and Apple Maps;

h. All records pertaining to the types of service used;

i. All records pertaining to communications between Apple and any person


regarding the account, including contacts with support services and records of actions taken; and

j. . All files, keys, or other information necessary to decrypt any data produced in an
encrypted form, when available to Apple (including, but not limited to, the keybag.txt and
fileinfolist.txt files).

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II. Information to be Seized by Law Enforcement Personnel

Any and all records that relate in any way to the accounts described in Attachment A which
consists of evidence, fruits, or instrumentalities of violations of 18 U .S.C. § 2 (aiding and
abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18
U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized
access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of_justice), 18 U.S.C.
§ 1513 (witness tampering); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and
conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contribution ban), from June
1, 2015 to present, including:

a. All records, information, documents or tangible materials that relate in any way to
communications regarding hacking, release of hacked material, communications with
persons or entities associated with WikiLeaks, including but not limited to Julian Assange, or
communications regarding disinformation, denial, dissembling or other obfuscation about
knowledge of, or access to hacked material;

b. All records, information, documents or tangible materials that relate in any way to
communications or meetings involving Jerome Corsi, Julian Assange,
Randy Credico, or any individual
associated with the Trump Campaign;

c. All images, messages, communications, calendar entries, search terms, "address book"
entries and contacts, including any and all preparatory steps taken in furtherance of the
above-listed offenses;

d. Communication, information, documentation and records relating to who created, used, or


communicated with the account or identifier concerning the messages identified above,
including records about their identities and whereabouts;

e. Evidence of the times the account was used;

f. All images, messages and communications regarding wiping software, encryption or


other methods to avoid detection by law enforcement;

g. Passwords and encryption keys, and other access information that may be necessary to
access the account and other associated accounts;

h. Credit card and other financial information, including but not limited to, bills and
payment records evidencing ownership of the subject account;

i. All existing printouts from original storage which concern the categories identified in
subsection II.a

56
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 1 of 48

AO 93 (Rev l l/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1 :18-sc-02595
or identify the person by name and address) )
Ass!gned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH ONE ACCOUNT )
Assign. Date : 8/8/2018
STORED AT PREMISES )
CONTROLLED BY GOOGLE ) Description: Search & Seizure Warrant

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before August 21, 2018 (not to exceed 14 days)
r/ in the daytime 6:00 a.m. to 10:00 p.m. D at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell , Chief U.S. District Judge
(United States Magistrate Judge)

D Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriale box)
D for _ _ days (not to exceed 30) D until, the facts justifying, the later specific date of

Date and time issued ~/ ~/ j cl-} ~Df"1 :Judge 's signature

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
- - - - - - - - - - -- - - Printed name and title
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 2 of 48

AO 93 (Rev, l l/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of :

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 3 of 48

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Google accounts, which

are stored at premises owned, maintained, controlled, or operated by Google, LLC ("Google"), a

company headquartered in Mountain View, California:

-1-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 4 of 48

ATTACHMENT B

I. Information to be disclosed by Google

To the extent that the information described in Attachment A is within the possession,

custody, or control of Google, LLC ("Google"), including any messages, records, files, logs, or

information that have been deleted but are still available to Google, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(±), Google is required to disclose the following

information to the government for each account listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date and time at which each

email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the account, to

include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the

account, including address books, contact and buddy lists, calendar data, pictures,

and files;

-2-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 5 of 48

e. All records pertaining to communications between the Provider and any person

regarding the account, including contacts with support services and records of

actions taken;

f. All subscriber "change history" associated with the account;

g. All search history and web history associated with the account;

h. All location and maps information associated with the account;

1. All Google Analytics information associated with the account (including all

properties and UA codes associated with the account, and, for each of these

proprieties and UA codes, all usemames and email accounts associated with them);

J. All Google Developers Console information associated with the account;

k. All Minutemaid information associated with the account;

1. All Android information associated with the account;

m. All Google Docs associated with the account;

n. All YouTube information associated with the account;

o. All Google Hangouts information associated with the account;

p. All Google Voice information associated with the account;

q. All Web & App Activity associated with the account;

r. All Google Drive information associated with the account;

s. All Google+ information associated with the account;

t. All device information associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

-3-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 6 of 48

Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Number

("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), or

International Mobile Equipment Identities ("IMEi")); and

u. For any accounts linked to the accounts listed in Attachment A, including accounts

linked by cookie, SMS number, or recovery email address, and for accounts for

which the accounts described in Attachment A are the recovery email address,

provide all records or other information regarding the identification of the account,

to include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number).

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June 1, 2015 to the present, including:

-4-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 7 of 48

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or acces~ to, hacked material;

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Randy Credico, or any

individual associated with the Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

-5-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 8 of 48

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

1. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s}-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 9 of 48
AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES D ISTRICT C OURT D


for the AUG.. 8 2018
District of Columbia
CJ.rk, U.S. District and
01nkrupt · · ~
In the Matter of the Search of
5· Case: 1: 18-sc-02595
(Briefly describe the prop erty to be searched
or identify the person by nam e and address)
IN FORMATION ASSOCIATED WITH
ONE ACCOUNT STORED AT PREMISES CONTROLLED
l Assigned To: Howell, Beryl A
Assign. Date : 8/8/2018
Description: Search & Seizure Warrant
BY GOOGLE

APPLICATION FOR A SEARCH WARRANT


I, a fed eral law enforcement officer or an attorney for the government, request a searc h warrant and state under
penalty of pe1jw·y that I have reason to bel ieve that on the following person or property (idrmrify /he p erson or describe the
property to be searched and give its location) :

See Attachment A
located in the District of California , there is now concealed (identify the
- - - Northern
- - --- ---- -- -- -- - -
person or describe the property to be seized) :
See Attachment B

The basis for the search under Fed. R. Crim. P. 41 ( c) is (check one or more):
~ evidence of a crime;
ref contraband, fruits of crime, or other items illegally possessed;
~ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
52 U.S.C. § 30121 Foreign Contribution Ban
18 u.s.c. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts :
See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of days (give exact ending date if more than 30 days: _ _ _ _ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attache heet.

Reviewed by AUSA/SAUSA:
jl<yle R. Freeny (ASC) Andrew Mitchell, Special Agent, FBI
Printed name and title

Sworn to before me and signed in my presence.

Date ~/LhJ!J Judge's signature

City and state: Washington, D.C. Hon . Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 10 of 48

FILE
AUG -8 2018
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA Clerk, U.S. District and
Bankruptcy Courts

IN THE MATTER OF THE SEARCH OF Ca~e: 1: 18-sc-02595


INFORMATION ASSOCIATED WITH Ass!gned To : Howell, Beryl A
ONE ACCOUNTS STORED AT PREMISES Ass,g~. ~ate: 8/8/2018 .
CONTROLLED BY GOOGLE Descnpt,on: Search & S .
e1zure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the Google account ("Target

Account"), stored at premises owned, maintained, controlled or operated by Google, LLC

("Google"), a company headquartered in Mountain View, California. The information to be

disclosed by Google and searched by the government is described in the following paragraphs and

in Attachments A and B.

2. I am a Special Agent with the Federal Bureau of Investigation (FBI), and have

been since 2011. As a Special Agent of the FBI, I have received training and experience in

investigating criminal and national security matters.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. ,Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Account contain evidence, fruits, or

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

-: 1-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 11 of 48

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a protected

computer), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud), 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C. § 1513 (witness

tampering), and 52 U.S.C. § 30121 (a)(I )(C) (foreign expenditure ban). There also is probable

cause to search the information described in Attachment A for evidence, contraband, fruits,

and/or instrumentalities of the Subject Offenses, further described in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competentjurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(l)(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18 U .S.C.

§ 271 I (3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

PROBABLE CAUSE

A. Background on Relevant Individuals

i. Roger STONE

6. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

-2-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 12 of 48

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

7. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WNO.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

-3-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 13 of 48

B. Russian Government-Backed Hacking Activity During the 2016 Presidential


Election

9. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Government developed a clear preference for President-elect Trump.

10. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

11. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these tyber activities

to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

-4-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 14 of 48

12. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

13. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

14. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

15. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to mbve the "snapshots" to

those accounts.

16. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

17. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

18. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

-5-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 15 of 48

presidential election, including conspiracy to commit authorized access to protected computers.

See United States v. Viktor Borisovich Netyksho, et al. (Case No. 1:l 8-cr-00125).

C. STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

19. On June 14, 2016, Crowd Strike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[tJhe main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

20. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

21. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

22. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

-6-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 16 of 48

aimed at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With

regard to the October surprise, what would be your forecast on that given what Julian Assange

has intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain

to the Clinton Foundation but there's no telling what the October surprise may be." A few days

later, STONE clarified that while he was not personally in touch with ASSANGE, he had a close

friend who served as an intermediary.

23. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

24. On August 13, 2016, STONE posted a tweet using @RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

25. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

26. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

27. On August 21, 2016, using@RogerJStoneJR, STONE tweeted: "Trust me, it will

soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same

day, STONE reiterated that because of the work of a "'mutual acquaintance' of both his and

-7-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 17 of 48

[ASSANGE], the public [could] expect to see much more from the exiled whistleblower in the

form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

28. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

29. On Saturday, October 1, 2016, using @RogerJStoneJr, STONE tweeted,

"Wednesday@HillaryClinton is done. #WikiLeaks."

30. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement ASSANGE had scheduled for the next day from the balcony

of the Ecuadoran Embassy in London. On the day of the ASSANGE announcement-which was

part of WikiLeaks' IO-year anniversary celebration - STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used @RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

31. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series oflewd remarks.

32. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

-8-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 18 of 48

33. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta- referring back to STONE's August 21,

2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

th.ought were deleted. I hear that through my emissary."

34. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

35. On October 13, 2016, while WikiLeaks was in the midst ofreleasing the hacked

Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

-9-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 19 of 48

account @wikileaks. 1 The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

to rexamine the strategy of attacking me- cordially R."

36. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

37. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

38. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

39. In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE,

the founder of WikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with ASSANGE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

1
On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 20 of 48

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

40. On Saturday, June I 0, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE and Others Regarding


Forthcoming Leaks

41. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address . On October

17, 2017, Chief Judge Howell issued a search warrant for one of STONE's l addresses,

On or about December 19, 2017, Chief Judge Howell issued a search

warrant for s email account. On or about March 14, 2018, Chief Judge Howell

issued a search warrant for STONE's iCloud account. Information recovered pursuant to those

search warrants indicated the following:

42. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger

Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

appears to have forwarded the message to STONE at who replied to

CORSI that, "May meet Manafort -guarantee nothing."

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 21 of 48

43. On or about May 18, 2016, CORSI emailed STONE

with the title, "Roger -- why don't you look this over before I send " I believe that

. CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

44. On July 25, 2016, STONE, usin , sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

45. On or about July 31, 2016, STONE, usin , emailed

CORSI with the subject line, "Call me MON." The body of the email read: h should see

Assange[.] should find Bernie [S]anders brother who called Bill a Rapist - turn him for

Trump[.] should find or more proof of Bill getting kicked out."

46. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at

, "Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued, "Signs are Fox

will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HRC an artifact ofrigged polling. Won't last. I expect presidential

campaign to get serious starting Sept. Still in pre-season games. Time to let more than Podesta to

be exposed as in bed w enemy if they are not ready to drop HRC. That appears to be the game

hackers are now about. Would not hurt to start suggesting HRC old, memory bad, has stroke --

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 22 of 48

neither he nor she well. I expect that much of next dump focus, setting stage for Foundation

debacle." Investigators believe that CORSI's reference to a "friend in embassy [who] plans 2

more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in 2016.

47. On or about August 5, 2016 , an associate of STONE's, emailed

STONE . The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet ASSANGE. also stated

that in 2018 told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SAN GE. STONE told he was joking and

had not actually met ASSANGE. 2

48. On or about August 15, 2016, CORSI emailed STONE at

: "Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

49. On or about August 31, 2016, CORSI emailed STONE at

: "Did you get the PODESTA writeup." STONE replied "[y]es."

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 23 of 48

50. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Y anukovych - Panama papers reveals Podesta hired by

S[b]erbank, Russia's largest financial institution - Podesta$$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

51. On or about September 6, 2016, CORSI emailed STONE at

: "Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

52. On or about September 24, 2016 emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have

secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today. wrote back, "Awaiting secret file. Explosive ... Hope you are well.

Can't ~ait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators, indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

53. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange - what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON, who was CEO of the Campaign at the time, and wrote: "You should call Roger. See

below. You didn't get from me." BANNON wrote back, "I've got important stuff to worry

about." The associate responded, "Well clearly he knows what Assange has. I'd say that's

important."

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 24 of 48

54. On or about October 4, 2016, AS SAN GE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

ASSANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

55. On or about October 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

56. That same day, BANNON emailed STONE a , "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawye is a big

democrat."

57. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 25 of 48

58. According to a publicly available news article, 3 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn 't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."

59. According to phone record , at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

60. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

61. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

62. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

63. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

64. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE using , "I expect

that much of next dump focus, setting stage for Foundation debacle."

3
https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-Iewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07/31 d74714-8ce5-l l e6-875e-2cl bfe943b66_story.html

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 26 of 48

65. At approximately 6:27P L, an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks - The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using

, forwarded s message to CORSI without comment. STONE

does not appear to have forwarded the email to any other individual.

G. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

66. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed -

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job

numbers."

67. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

using emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

68. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at both , with the subject

line "Podesta talking points." Attached to the email was a file labeled, "ROGER STONE

podesta talking points Oct 12 2016.docx." The "talking points" included the statement that

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 27 of 48

"Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation."

69. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via t l Account, "Got them and used them."

70. On or about Thursday, October 13, 2016, CORSI emailed STONE at

: "PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I'll give you one more-NOBODY YET HAS THIS[:] It looks to me

lik skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Onc

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

71. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email a with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 28 of 48

have had some back-channel communications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money di , a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through

Metcombank, a Russian regional bank owned 99.978 percent b , with the money

transferred via Deutsche Bank and Trust Company Americas in New York City, with the money

ending up in a private bank account in the Bank of America that is operated by the Clinton

Foundation?"

72. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

73. On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now - before 2pm[.]" STONE responded, "Missed u - just

landed JFK - on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

74. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand off[.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. lf HRC wins, Assange can

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 29 of 48

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election."

75. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

76. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice of Wikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta's business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

77. On or about November 8, 2016, the United States presidential election took place.

78. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

79. On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in

London. Have some interesting news for you."

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 30 of 48

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 31 of 48

t STONE's Congressional Testimony and Public Statements About His Relationship


with Wikileaks

87. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCI). Although the hearing"was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic assertions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta's email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 32 of 48

such asse11ions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trust me, it will soon be the Podesta's
time in the barrel. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but
does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrutiny ....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.
I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
Assange to independently confirm this report, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
information proved to be correct. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

88. In a document dated March 26, 2018 titled "Minority Views," Democratic

members of HP SCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in
communication with Assange or communication through an intermediary with Assange,
you were only referring to a single fact that you had confamed with the intermediary -
MR. STONE: That -
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is correct, even though it was repeated to me on numerous separate
occasions.

89. In the month that followed his testimony before HP SCI, on or about October 24,

2017, STONE published an ai1icle on his website, stonecoldtruth.com, titled "Is it the Podesta's

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 33 of 48

Time in the Barrel Yet?" In that article, STONE stated: "[J]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

J. STONE's Messaging to Randy CREDICO about STONE's "Back channel"

90. On or about November 19, 2017, Randy CREDICO (who, as described further

below, STONE publicly identified as his "intermediary" to ASSANGE), messaged STONE, "My

lawyer wants to see me today." STONE responded, "'Stonewall it. Plead the fifth. Anything to

save the plan' ........ Richard Nixon[.]" CREDI CO responded, "Ha ha."

91. On or about November 21, 2017, CREDICO messaged STONE, "I was told that

the house committee lawyer told my lawyer that I will be getting a subpoena[.]" STONE wrote

back, "That was the point at which your lawyers should have told them you would assert your

5th Amendment rights if compelled to appear." They continued to message, and CREDI CO

wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To do what? Nothing

happening in DC the day before Thanksgiving - why are u busting my chops?"

92. On or about November 24, 2017, STONE, texted CREDICO, "Assange is a

journalist and a damn good one- meeting with him is perfectly legal and all you ever told me was

he had the goods [o]n Hillary and would publish them - which he himself said in public b4 u told

me . It's a fucking witchunt [sic]." CREDICO replied, "I told you to watch his tweets. That's

what I was basing it on. I told you to watch his Tweets in October not before that I knew nothing

about the DNC stuff[.] I just followed his tweets[.]" STONE responded, "U never said anything

about the DNC but it was August." CREDICO wrote back, "It was not August because I didn't

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 34 of 48

interview him or meet him until August 26th[.] That was my first communication with his

secretary in London, August 26th." STONE wrote back, "Not the way I remember it- oh well I

guess Schiff will try to get one of us indicted for perjury[.]"

93. STONE and CREDICO continued to exchange messages and on November 24,

2017, CREDICO wrote to STONE, "Forensic evidence proves that there is no back Channel. So

now you can relax."

94. On or about November 28, 2017, CREDICO tweeted a copy of a subpoena he

received from HPSCI that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

95. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that "Credico merely []

confirmed for Mr. Stone the accuracy of Julian Assange's interview of June i2, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credi co never said he knew or had any information as to source or

content of the material."

96. On or about December 1, 2017, CREDI CO messaged STONE, "I don't know why

you had to lie and say you had a back Channel now I had to give all of my forensic evidence to

the FBI today what a headache[.] 4 You could have just told him the truth that you didn't have a

back Channel they now know that I was not in London until September of this year[.] You had

no back-channel and you could have just told the truth ... You want me to cover you for petjury

now[.]" STONE responded, "What the fuck is your problem? Neither of us has done anything

4
Contrary to his statement, CREDICO has not provided any forensic evidence to the FBI.

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 35 of 48

wrong or illegal. You got the best press of your life and you can get away with asserting for 5th

Amendment rights ifu don't want talk about AND if you turned over anything to the FBI you're

a fool." CREDI CO responded, "You open yourself up to six counts of petjury[.] But I'm sure

that wasn't sworn testimony so you're probably clear[.] Council for the committee knows you

never had a back Channel and if you had just told the truth wouldn't have put me in this bad spot

... you should go back .. ·. and amend your testimony and tell them the truth." CREDI CO

repeated: "you need to amend your testimony before I testify on the 15th." STONE replied, "If

you testify you're a fool. Because of tromp [sic] I could never get away with a certain [sic] my

Fifth Amendment rights but you can. I guarantee you you [sic] are the one who gets indicted for

perjury if you're stupid enough to testify[.]"

97. STONE and CREDICO continued to message each other on or about December 1,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fuck off good night." CREDI CO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

98. On or about December 13, 2017, according to public reporting, CREDI CO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

99. STONE and CREDICO continued to exchange text messages, and on or about

January 6, 2018, CREDI CO indicated to STONE that he was having dinner with a reporter.

STONE responded, "Hope u don't fuck Up my efforts to get Assange a pardon[.]" CREDICO

messaged STONE, "I have the email from his chief of staff August 25th 2016 responding to an

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Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 36 of 48

email I sent to WikiLeaks website email address asking you would do my show[.] That was my

initial contact."

100. On or about January 8, 2018, CREDICO messaged STONE, stating: "Embassy

logs ... + 17 other pieces of information prove that I did not have any conversations with

Assange until September of last year."

101. CREDICO and STONE continued to message each other, and on or about January

25, 2018, CREDICO wrote to STONE: "You lied to the house Intel committee ... But you'll get

off because you're friends with Trump so don't worry. I have all the forensic evidence[.] I was

not a ba[ck] Channel and I have all those emails from September of2016 to prove it[.]"

102. On or about April 13, 2018, news reports stated that CREDICO had shown

reporters copies of email messages he had received from STONE in the prior few days that

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

from you," referring to CREDICO's therapy dog. CREDICO stated that it was "certainly scary .

. . When you sta11 bringing up my dog, you're crossing the line[.]" 5

103. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the a11icle, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

5
https://www.yahoo.com/news/comedian-randy-credico-says-trump-adviser-roger-stone-
threatened-dog-135911370.html
6
https ://www .motherjones.com/politics/2018/0 5/roger-stone-to-associate-prepare-to-die/

-27-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 37 of 48

He was depressed about it. Or was he lying." The article noted that CREDICO stated he did not

have prostate cancer and did not have any such discussion with STONE.

K. The Target Account

104. According to subscriber records obtained from Google, Target Account

was created on October 27, 2015, in the name o

" The recovery email for the Target Account is STONE' l account,

. Subscriber records obtained in approximately August 2018 indicate

that the last login to the Target Account occurred on May 17, 2018.

105. According to subscriber records obtained from Facebook, Target Account

was used to register a Facebook account in the name o

which was created on October 27, 2015, with the verified telephone numbe

According to a public records database, the telephone numbe is linked

106. was voluntarily interviewed by investigators from the Special

Counsel's Office on or about Friday, May 18, 201 told investigators that he

became STONE's assistant in Florida in 2015, and that during the summer of 2016, he acted as

STONE's right-hand man. According to STONE utilized the services of several

individuals to post social media content to Facebook and Twitter, and that he ) and

STONE both instructed these individuals about what to post. stated that he

purchased a couple hundred fake Face book accounts as part of this work (including both new

and existing accounts), and that bloggers working for STONE would try to build what looked

like real Facebook accounts. 7 further stated that STONE wanted to push out

7
Face book requires that all users of Facebook accounts use their actual name while registering
-28-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 38 of 48

WikiLeaks content through his Facebook and Twitter accounts, and that content related to the

stolen Podesta emails was pushed out through STONE's Facebook and Twitter accounts.

107. On or about August 2, 2018, Chief Judge Howell issued a search warrant for the

Facebook account registered to Target Accou . (1: 18-sw-

2570).

108. Search warrant returns for STONE's Hotmail account contain a number of emails

that appear to have been sent to Target Accoun from various

entities, including Facebook and Twitter. Although it is not clear from the face of the emails

how they ended up in STONE l account, 8 they may have been auto-forwarded or

otherwise imported from the Target Account into th l account. These emails include at

least one receipt sent on or about June 30, 2016, from Facebook to the Target Account for a

Facebook advertisement, which was then forwarded from STONE account to

Google account. 9 They also include several emails sent from

to the Target Account in early 2017.

BACKGROUND CONCERNING GOOGLE

109. In my training and experience, I have learned that Google provides a variety of on-

line services, including electronic mail ("email") access, to the public. Google allows subscribers

to obtain email accounts at the domain name gmail.com, like the Target Account. Subscribers

and operating their accounts. The terms of service explicitly require that "Facebook users
provide their real names and information .... You will not provide any false personal
information on Facebook, or create an account for anyone other than yourself without
permission."

8
Investigators have been unable to access the full headers for these emails.
9
told investigators that he would sometimes send emails from STONE's account.

-29-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 39 of 48

obtain an account by registering with Google. During the registration process, Google asks

subscribers to provide basic personal information. Therefore, the computers of Google are likely

to contain stored electronic communications (including retrieved and unretrieved email) for

Google Mail subscribers and information concerning subscribers and their use of Google Mail

services, such as account access information, email transaction information, and account

application information. In my training and experience, such information may constitute evidence

of the crimes under investigation because the information can be used to identify the account's

user or users.

110. In my training and experience, email providers generally ask their subscribers to

provide certain personal identifying information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and other

identifiers, alternative email addresses, and, for paying subscribers, means and source of payment

(including any credit or bank account number). In my training and experience, such information

may constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users. Based on my training and my experience, I know that, even if

subscribers insert false information to conceal their identity, this information often provides clues

to their identity, location, or illicit activities.

111. In my training and experience, email providers typically retain certain transactional

information about the creation and use of each account on their systems. This information can

include the date on which the account was created, the length of service, records of log-in

(i.e., session) times and durations, the types of service utilized, the status of the account (including

whether the account is inactive or closed), the methods used to connect to the account (such as

logging into the account via the provider's website), and other log files that reflect usage of the

-30-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 40 of 48

account. In addition, email providers often have records of the IP address used to register the

account and the IP addresses associated with particular logins to the account. Because every device

that connects to the Internet must use an IP address, IP address information can help to identify

which computers or other devices were used to access the email account.

112. In my training and experience, in some cases, email account users will

communicate directly with an email service provider about issues relating to the account, such as

technical problems, billing inquiries, or complaints from other users. Email providers typically

retain records about such communications, including records of contacts between the user and the

provider's support services, as well as records of any actions taken by the provider or user ::is ::i

result of the communications. In my training and experience, such information may constitute

evidence of the crimes under investigation because the information can be used to identify the

account's user or users.

113. This application seeks a warrant to search all responsive records and information

under the control of Google, a provider subject to the jurisdiction of this court, regardless of where

Google has chosen to store such information. The government intends to require the disclosure

pursuant to the requested warrant of the contents of wire or electronic communications and any

records or other information pertaining to the customers or subscribers if such communication,

record, or other information is within Google's possession, custody, or control, regardless of

whether such communication, record, or other information is stored, held, or maintained outside

the United States.

114. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

-31-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 41 of 48

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of occupancy"

while executing a search warrant at a residence. For example, email communications, contacts

lists, and images sent (and the data associated with the foregoing, such as date and time) may

indicate who used or controlled the account at a relevant time. Further, information maintained by

the email provider can show how and when the account was accessed or used. For example, as

described below, email providers typically log the Internet Protocol (IP) addresses from which

users access the email account, along with the time and date of that access. By determining the

physical location associated with the logged IP addresses, investigators can understand the

chronological and geographic context of the email account access and use relating to the crime

under investigation. This geographic and timeline information may tend to either inculpate or

exculpate the account owner. Additionally, information stored at the user's account may further

indicate the geographic location of the account user at a particular time (e.g., location information

integrated into an image or video sent via email). Last, stored electronic data may provide relevant

insight into the email account owner's state of mind as it relates to the offense under investigation.

For example, information in the email account may indicate the owner's motive and intent to

commit a crime (e.g., communications relating to the crime), or consciousness of guilt

(e.g., deleting communications in an effort to conceal them from law enforcement).

FILTER REVIEW PROCEDURES

115. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

with professional responsibility requirements concerning the maintenance of attorney-client and

-32-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 42 of 48

other operative privileges. The procedures include use, if necessary, of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

CONCLUSION

116. Based on the forgoing, I request that the Court issue the proposed search warrant.

117. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

118. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

~ape ~
Andrew Mitchell
Special Agent
Federal Bureau oflnvestigation

Subscribed and sworn to before me on thief' day of August, 2018.

6//W
The Honorable Beryl A. Howell
Chief United States District Judge

-33-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 43 of 48

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Google accounts, which

are stored at premises owned, maintained, controlled, or operated by Google, LLC ("Google"), a

company headquartered in Mountain View, California:

-1-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 44 of 48

ATTACHMENTB

I. Information to be disclosed by Google

To the extent that the information described in Attachment A is within the possession,

custody, or control of Google, LLC ("Google"), including any messages, records, files, logs, or

information that have been deleted but are still available to Google, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(f), Google is required to disclose the following

information to the government for each account listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date and time at which each

email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the account, to

include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the

account, including address books, contact and buddy lists, calendar data, pictures,

and files;

-2-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 45 of 48

e. All records pertaining to communications between the Provider and any person

regarding the account, including contacts with support services and records of

actions taken;

f. All subscriber "change history" associated with the account;

g. All search history and web history associated with the account;

h. All location and maps information associated with the account;

i. All Google Analytics information associated with the account (including all

properties and UA codes associated with the account, and, for each of these

proprieties and UA codes, all usernames and email accounts associated with them);

J. All Google Developers Console information associated with the account;

k. All Minutemaid information associated with the account;

I. All Android information associated with the account;

m. All Google Docs associated with the account;

n. All Y ouTube information associated with the account;

o. All Google Hangouts information associated with the account;

p. All Google Voice information associated with the account;

q. All Web & App Activity associated with the account;

r. All Google Drive information associated with the account;

s. All Google+ information associated with the account;

t. All device information associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

-3-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 46 of 48

Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Number

("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), or

International Mobile Equipment Identities ("IMEi")); and

u. For any accounts linked to the accounts listed in Attachment A, including accounts

linked by cookie, SMS number, or recovery email address, and for accounts for

which the accounts described in Attachment A are the recovery email address,

provide all records or other information regarding the identification of the account,

to include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number).

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June 1, 2015 to the present, including:

-4-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 47 of 48

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, , Julian

Assange , Randy Credico, or any

individual associated with the Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

-5-
Case 1:19-mc-00029-CRC Document 29-15 Filed 04/28/20 Page 48 of 48

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

I. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 1 of 50

AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1: 18-sc-02596
or identify the person by name and address) )
Assigned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH ONE ACCOUNT )
Assign. Date : 8/8/2018
STORED AT PREMISES )
CONTROLLED BY TWITTER ) Description: Search & Seizure Warrant

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before August 21, 2018 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to 10:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell, Chief U.S. District Judge
(United Stales Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b ), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued: ----~ /~ -- /?'/7~~/


Judge 's signature

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 2 of 50

AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No .: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized :

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 3 of 50

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Twitter accounts, which

are stored at premises owned, maintained, controlled, or operated by Twitter, Inc. ("Twitter"), a

company headquartered in San Francisco, California:

-1-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 4 of 50

ATTACHMENT B

I. Information to be disclosed by Twitter

To the extent that the information described in Attachment A is within the possession,

custody, or control of Twitter, Inc. ("Twitter"), including any messages, records, files, logs, or

information that have been deleted but are still available to Twitter, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(f), Twitter is required to disclose the following

information to the government for each account listed in Attachment A:

A. All "Tweets" and Direct Messages sent, received, "favorited," or retweeted by the account,
and all photographs or images included in those Tweets and Direct Messages;

B. The content of all communications (public or private) sent to or from, stored in draft form
in, or otherwise associated with the account, including the content of all messages,
attachments, and header information;

C. All data and information associated with the profile page, including photographs, "bios,"
and profile backgrounds and themes;

D. All other content associated with the account, including, but not limited to, posts,
documents, spreadsheets, photos, and videos;

E. All information from the "Connect" tab for the account, including all lists of Twitter users
who have favorited or retweeted Tweets posted by the account, as well as a list of all Tweets
that include the usemame associated with the account (i.e., "mentions" or "replies");

F. All photographs and images in the user gallery for the account;

G. All location data associated with the account, including all information collected by the
"Tweet With Location" service;

H. All information about the account's use of Twitter's link service, including all longer
website links that were shortened by the service, all resulting shortened links, and all
information about the number of times that a link posted by the account was clicked;

I. All data and information that has been deleted by the user;

J. A list of all of the people that the user follows on Twitter and all people who are following
the user (i.e., the user's "following" list and "followers" list);

K. A list of all users that the account has "unfollowed" or blocked;

L. All "lists" created by the account;

-2-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 5 of 50

M. All information on the "Who to Follow" list for the account;

N. All privacy and account settings;

0. All records of Twitter searches performed by the account, including all past searches saved
by the account;

P. All current and historical subscriber and payment information, including full name, e-mail
address (including any secondary or recovery email addresses), physical address (including
city, state, and zip code), date of birth, gender, hometown, occupation, telephone number,
websites, screen names, user identification numbers, security questions and answers,
registration IP address, payment history, and other personal identifiers;

Q. All email addresses and telephone numbers ever registered (whether successfully or not)
to the account, including dates of any changes and the IP addresses used for any changes;

R. All past and current usernames, account passwords, and names associated with the account,
including dates of any changes and the IP addresses used for any changes;

S. All data and information associated with the profile page, including photographs;

T. All advertising data relating to the account, including, but not limited to, information
regarding unique advertising IDs associated with the user, any devices used to access the
account, application IDs, UDIDs, payment information (including, but not limited to, full
credit card numbers and expiration dates and PayPal accounts), ads clicked, and ads
created;

U. The dates and times at which the account and profile were created, and the Internet Protocol
("IP") address at the time of sign-up;

V. All transactional records associated with the account, including any IP logs or other records
of session times and durations;

W. Any information identifying the device or devices used to access the account, including a
device serial number, a GUID or Global Unique Identifier, a phone number, serial numbers,
MAC addresses, Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers
("MEIN"), Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers
("MIN"), Subscriber Identity Modules ("SIM"), Mobile Subscriber Integrated Services
Digital Network Number ("MSISDN"), International Mobile Subscriber Identifiers
("IMSI"), or International Mobile Equipment Identities ("IMEI"), and any other
information regarding the types of devices used to access the account;

X. All activity logs for the account;

Y. All location information for the account, including all location data collected by any
plugins or widgets;

Z. The types of service utilized by the user;

-3-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 6 of 50

AA. All information about the account's use ofTwitter's link service, including all website links
embedded in, exporting data to, or importing data from, the account's website or blog;

BB. All full website links that were shortened by Twitter's link service, all resulting shortened
links, and all information about the number of times that a link posted by the account was
clicked;

CC. All information about connections between the account and third-party websites and
applications, including any Twitter, Facebook or other social networking accounts to which
posts from the account are sent;

DD. All data and information that has been deleted by the user;

EE. The length of service (including start date) and the means and source of any payments
associated with the service (including any credit card or bank account number);

FF. All privacy settings and other account settings, including email addresses or other accounts
that the account has blocked;

GG. Information regarding linked accounts, including accounts linked by cookie, IP address
(including registration IP address), advertising ID, User Client UUID, User Guest Cookie
ID, Known Device Token, Normalized Email Address, Android ID, IMEI, GUID, device
identifier, or any other account or device identifier;

HH. Information regarding accounts linked to accounts to which the Target Accounts are linked;

II. All records pertaining to communications between the Service Provider and any person
regarding the user or the user's account with the Service Provider, including contacts with
support services, records of actions taken, and investigative or user complaints concerning
the subscriber.

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June 1, 2015 to the present, including:

-4-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 7 of 50

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, or any

individual associated with the Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

-5-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 8 of 50

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

1. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 9 of 50
AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT


FILED
for the AUG .. 8 2018
District of Columbia Clerk, U.S. District and
Bankrupt.C¥i;lOIU~.:-::-~~
In the Matter of the Search of )
(Briefly describe the property lo be searched ~
Case: 1:18-sc-02596
or identify the person by name and add1·es~~ ) Assigned To : Howell , Beryl A.
INFORMATION ASSOCIATED WITH
Assign. Date: 8/8/2018
ONE ACCOUNT STORED AT PREMISES CONTROLLED )
BY TWITTER )
Description: Search & Seizure Warrant

APPLICATION FOR A SEARCH WARRANT


I, a federal Jaw enforcement officer or an attorney for the government, request a search wanant and state under
penalty of pe1jury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A
located in the
- - -Northern
- - -- - District of
---- -California
-- -- - -- , there is now concealed (identify the
person or describe the property to be seized):
See Attachment B '

The basis for the search under Fed. R. Crim. P. 41 ( c) is (check one or more):
ri evidence of a crime;
ri contraband, fruits of crime, or other items illegally possessed;
~ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
52 U.S.C. § 30121 Foreign Contribution Ban
18 U.S .C. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of _ _ days (give exact ending date if more than 30 days:
under 18 U.S.C. § 3103a, the basis of which is set forth on z-~ ) is requested

Reviewed by A USA/SA USA: Applicant's signature

jKyle R. Freeny (ASC) Andrew Mitchell, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

---- 4,t;,u~
City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 10 of 50

FILE D
IN THE UNITED STATES DISTRICT COURT AUG -8 201B
F R TI-IB !STRICT OF OLUMBIA Clertc, U.S. District and
Bankrupt~y Cour-t
IN THE MATIER F 1 J' SEARCH OF Case: 1:18- sc- 02596
INFORMATION A S CIATED WITH Ass!gned To : Howell, Beryl A.
ONE ACCOUN1 STORED AT PREMISES Assrgn. Date : 8/8/2018
CONTROLLED BY TWITTER Description: Search & Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the Twitter account ("Target Account"), stored

at premises owned, maintained, controlled or operated by Twitter, Inc. ("Twitter"), a company

headquartered in San Francisco, California. The information to be disclosed by Twitter and

searched by the government is described in the following paragraphs and in Attachments A and B.

2. I am a Special Agent with the Federal Bureau oflnvestigation (FBI), and have

been since 2011. As a Special Agent of the FBI, I have received training and experience in

investigating criminal and national security matters.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Account contain evidence, fruits, or

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

-1-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 11 of 50

U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a protected

computer), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud), 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C. § 1513 (witness

tampering), and 52 U.S.C. § 30121(a)(l)(C) (foreign expenditure ban). There also is probable

cause to search the information described in Attachment A for evidence, contraband, fruits,

and/or instrumentalities of the Subject Offenses, further described in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competentjurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(l)(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

PROBABLE CAUSE

A. Background on Relevant Individuals

i. Roger STONE

6. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 12 of 50

7. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WNO.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

B. Russian Government-Backed Hacking Activity During the 2016, Presidential


Election

9. On January 6, 2017, the USIC released a declassified version of an intelligence

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 13 of 50

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Government developed a clear preference for President-elect Trump.

10. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

11. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities

to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

12. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

13. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 14 of 50

contradictory statements and false claims about his identity throughout the election.

14. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

15. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

16. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

17. On or about November I, 2016, individuals associated with the GRU

spearphished over I 00 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

18. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

presidential election, including conspiracy to commit authorized access to protected computers.

See United States v. Viktor Borisovich Netyksho, et al. (Case No. 1:18-cr-00125).

C. STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

19. On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 15 of 50

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

20. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

21. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

22. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

aimed at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With

regard to the October surprise, what would be your forecast on that given what Julian Assange

has intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain

to the Clinton Foundation but there's no telling what the October surprise may be." A few days

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 16 of 50

later, STONE clarified that while he was not personally in touch with ASSANGE, he had a close

friend who served as an intermediary.

23. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

24. On August 13, 2016, STONE posted a tweet using @RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

25. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

26. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

27. On August 21, 2016, using@RogerJStoneJR, STONE tweeted: "Trust me, it will

soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same

day, STONE reiterated that because of the work of a '"mutual acquaintance' of both his and

[ASSANGE], the public [could] expect to see much more from the exiled whistleblower in the

form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 17 of 50

28. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

29. On Saturday, October I, 2016, using@RogerJStoneJr, STONE tweeted,

"Wednesday @HillaryClinton is done. #WikiLeaks."

30. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement AS SANGE had scheduled for the next day from the balcony

of the Ecuadoran Embassy in London. On the day of the ASSANGE announcement-which was

part of WikiLeaks' 10-year anniversary celebration - STONE told lnfowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used @RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

31. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

32. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

33. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta- referring back to STONE's August 21,

2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 18 of 50

think there's at least a reasonable belief that (Assange] may have passed this information on to

(STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

34. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

35. On October 13, 2016, while WikiLeaks was in the midst ofreleasing the hacked

Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

account @wikileaks. 1 The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

1
On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
-9-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 19 of 50

to rexamine the strategy of attacking me- cordially R."

36. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

37. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

38. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

39. In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE,

the founder ofWikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with ASSANGE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 20 of 50

40. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

E. CORSI's Communications with STONE and Others Regarding


Forthcoming Leaks

41. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE' address . On October

17, 2017, Chief Judge Howell issued a search warrant for one of STONE' addresses,

On or about December 19, 2017, Chief Judge Howell issued a search

warrant fo email account. On or about March 14, 2018, Chief Judge Howell

issued a search warrant for STONE's iCloud account. Information recovered pursuant to those

search warrants indicated the following:

42. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger

Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

appears to have forwarded the message to STONE at , who replied to

CORSI that, "May meet Manafort -guarantee nothing."

43. On or about May 18, 2016, CORSI emailed STONE a

with the title, "Roger -- why don't you look this over before I send i I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 21 of 50

44. On July 25, 2016, STONE, usin , sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

45. On or about July 31, 2016, STONE, using , emailed

CORSI with the subject line, "Call me MON." The body of the email read should see

Assange[.] should find Bernie [S]anders brother who ·called Bill a Rapist - tum him for

Trump[.] should find or more proof of Bill getting kicked out."

46. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at

, "Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued, "Signs are Fox

will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HRC an artifact ofrigged polling. Won't last. I expect presidential

campaign to get serious starting Sept. Still in pre-season games. Time to let more than Podesta to

be exposed as in bed w enemy if they are not ready to drop HRC. That appears to be the game

hackers are now about. Would not hurt to start suggesting HRC old, memory bad, has stroke --

neither he nor she well. I expect that much of next dump focus, setting stage for Foundation

debacle." Investigators believe that CORSJ's reference to a "friend in embassy [who] plans 2

more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in 2016.

47. On or about August 5, 2016, an associate ofSTONE's, emailed

STONE at The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 22 of 50

Julian Assange last night." subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet ASSANGE also stated

that in 2018 told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SAN GE. STONE tol he was joking and

had not actually met ASSANGE. 2

48. On or about August 15, 2016, CORSI emailed STONE at

"Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

49. On or about August 31, 2016, CORSI emailed STONE at

: "Did you get the PODESTA writeup." STONE replied "[y]es."

50. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Yanukovych - Panama papers reveals Podesta hired by

S[b]erbank, Russia's largest financial institution-Podesta$$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

51. On or about September 6, 2016, CORSI emailed STONE at

"Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 23 of 50

52. On or about September 24, 2016 emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have

secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today wrote back, "Awaiting secret file. Explosive ... Hope you are well.

Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

53. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange - what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON, who was CEO of the Campaign at the time, and wrote: "You should call Roger. See

below. You didn't get from me." BANNON wrote back, "I've got important stuff to worry

about." The associate responded, "Well clearly he knows what Assange has. I'd say that's

important."

54. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

ASSANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 24 of 50

55. On or about October 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

56. That same day, BANNON emailed STONE a , "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawye is a big

democrat."

57. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

58. According to a publicly available news article, 3 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."

3
https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07 /31d74714-8ce5-11 e6-875e-2c 1bfe943b66_story.html

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 25 of 50

59. According to phone record a, at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

60. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

61. At approximately l :42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

62. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

63. At approximately 4:00PM, the Washington Post published a story regarding the

~ccess Hollywood tape.

64. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE usin , "I expect

that much of next dump focus, setting stage for Foundation debacle."

65. At approximately 6:27PM , an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks -The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using

forwarded message to CORSI without comment. STONE

does not appear to have forwarded the email to any other individual.

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 26 of 50

G. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

66. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed-

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job

numbers."

67. On or about Wednesday, October 12, 2016, at approximately 8: 17AM, STONE,

usin emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

68. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at both , with the subject

line "Podesta talking points." Attached to the email was a file labeled, "ROGER STONE

podesta talking points Oct 12 2016.docx." The "talking points" included the statement that

"Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation."

69. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Hotmail Account, "Got them and used them."

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 27 of 50

70. On or about Thursday, October 13, 2016, CORSI emailed STONE at

: "PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I'll give you one more -NOBODY YET HAS THIS[:] It looks to me

like skimmed maybe billions off Skolkovo-Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about $$$ received via

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to.post on Podesta since I have now promised it to a dozen MSM reporters[.]"

71. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

have had some back-channel communications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money did a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through

Metcombank, a Russian regional bank owned 99.978 percent by with the money

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 28 of 50

transferred via Deutsche Bank and Trust Company Americas in New York City, with the money

ending up in a private bank account in the Bank of America that is operated by the Clinton

Foundation?"

72. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

73. On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now - before 2pm[ .]" STONE responded, "Missed u - just

landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

74. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand offT.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. If HRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election."

75. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 29 of 50

76. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice of Wikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta's business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

77. On or about November 8, 2016, the United States presidential election took place.

78. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

79. On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in

London. Have some interesting news for you."

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I. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikileaks

87. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCI). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic assertions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta's email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such assertions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21 , 2016, in which I said, "Trust me, it will soon be the Podesta's
time in the barrel. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 32 of 50

does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrutiny....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.
I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
Assange to independently confirm this report, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
info1mation proved to be correct. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

88. In a document dated March 26, 2018 titled "Minority Views," Democratic

members ofHPSCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in
communication with Assange or communication through an intermediary with Assange,
you were only referring to a single fact that you had confomed with the intermediary -
MR. STONE: That -
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is correct, even though it was repeated to me on numerous separate
occasions.

89. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an article on his website, stonecoldtruth.com, titled "Is it the Podesta's

Time in the Barrel Yet?" In that article, STONE stated: "[I]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

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J. STONE's Messaging to Randy CREDICO about STONE's "Back channel"

90. On or about November 19, 2017, Randy CREDICO (who, as described further

below, STONE publicly identified as his "intermediary" to ASSANGE), messaged STONE, "My

lawyer wants to see me today." STONE responded, '"Stonewall it. Plead the fifth. Anything to

save the plan' ........Richard Nixon[.]" CREDI CO responded, "Ha ha."

91. On or about November 21, 2017, CREDICO messaged STONE, "I was told that

the house committee lawyer told my lawyer that I will be getting a subpoena[.]" STONE wrote

back, "That was the point at which your lawyers should have told them you would assert your

5th Amendment rights if compelled to appear." They continued to message, and CREDI CO

wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To do what? Nothing

happening in DC the day before Thanksgiving - why are u busting my chops?"

92. On or about November 24, 2017, STONE, texted CREDICO, "Assange is a

journalist and a damn good one- meeting with him is perfectly legal and all you ever told me was

he had the goods [o]n Hillary and would publish them - which he himself said in public b4 u told

me. It's a fucking witchunt [sic]." CREDICO replied, "I told you to watch his tweets. That's

what I was basing it on. I told you to watch his Tweets in October not before that I knew nothing

about the UNC stutll.J 1just followed his tweetsl.J" STONE responded, "U never said anything

about the DNC but it was August." CREDICO wrote back, "It was not August because I didn't

interview him or meet him until August 26th[.] That was my first communication with his

secretary in London, August 26th." STONE wrote back, "Not the way I remember it - oh well I

guess Schiff will try to get one of us indicted for perjury[.]"

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 34 of 50

93. STONE and CREDICO continued to exchange messages and on November 24,

2017, CREDICO wrote to STONE, "Forensic evidence proves that there is no back Channel. So

now you can relax."

94. On or about November 28, 2017, CREDI CO tweeted a copy of a subpoena he

received from HPSCI that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

95. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that "Credico merely[]

confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credico never said he knew or had any information as to source or

content of the material."

96. On or about December 1, 2017, CREDICO messaged STONE, "I don't know why

you had to lie and say you had a back Channel now I had to give all of my forensic evidence to

the FBI today what a headache[.] 4 You could have just told him the truth that you didn't have a

back Channel they now know that I was not in London until September of this year[.] You had

no back-channel and you could have just told the truth ... You want me to cover you for pe1jury

now[.]" STONE responded, "What the fuck is your problem? Neither of us has done anything

wrong or illegal. You got the best press of your life and you can get away with asserting for 5th

Amendment rights if u don't want talk about AND if you turned over anything to the FBI you're

a fool." CREDI CO responded, "You open yourself up to six counts of perjury[.] But I'm sure

4
Contrary to his statement, CREDICO has not provided any forensic evidence to the FBI.

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 35 of 50

that wasn't sworn testimony so you're probably clear[.]' Council for the committee knows you

never had a back Channel and if you had just told the truth wouldn't have put me in this bad spot

... you should go back ... and amend your testimony and tell them the truth." CREDICO

repeated: "you need to amend your testimony before I testify on the 15th." STONE replied; "If

you testify you're a fool. Because of tromp [sic] I could never get away with a certain [sic] my

Fifth Amendment rights but you can. I guarantee you you [sic] are the one who gets indicted for

perjury if you're stupid enough to testify[.]"

97. STONE and CREDICO continued to message each other on or about December 1,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fuck off good night." CREDI CO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

98. On or about December 13, 2017, according to public reporting, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

99. STONE and CREDICO continued to exchange text messages, and on or about

January 6, 2018, CREDICO indicated to STONE that he was having dinner with a reporter.

STONE responded, "Hope u don't fuck Up my efforts to get Assange a pardon[.]" CREDICO

messaged STONE, "I have the email from his chief of staff August 25th 2016 responding to an

email I sent to WikiLeaks website email address asking you would.do my show[.] That was my

initial contact."

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 36 of 50

I 00. On or about January 8,2018, CREDJCO messaged STONE, stating: "Embassy

logs ... + 17 other pieces of information prove that I did not have any conversations with

Assange until September of last year."

101. CREDI CO and STONE continued to message each other, and on or about January

25, 2018, CREDICO wrote to STONE: "You lied to the house Intel committee ... But you'll get

off because you're friends with Trump so don't worry. I have all the forensic evidence[.] I was

not a ba[ck] Channel and I have all those emails from September of 2016 to prove it[.]"

102. On or about April 13, 2018, news reports stated that CREDICO had shown

reporters copies of email messages he had received from STONE in the prior few days that

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

from you," referring to CREDICO's therapy dog. CREDICO stated that it was "certainly scary .

. . When you start bringing up my dog, you're crossing the line[.]" 5

103. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

He was depressed about it. Or was he lying." The article noted that CREDI CO stated he did not

have prostate cancer and did not have any such discussion with STONE.

5
https ://www.yahoo.com/news/comedian-randy-credico-says-trump-adviser-roger-stone-
threatened-dog-l359113 70.html
6
https://www .motherjones.com/politics/2018/05/roger-stone-to-associate-prepare-to-die/

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 37 of 50

K. s Statements Regarding STONE's Use of Social Media

104. On or about Friday, May 18, 2018 S was voluntarily interviewed

by investigators from the Special Counsel's Office told investigators that he became

STONE's assistant in Florida in 2015, and that during the summer of 2016, he acted as STONE's

right-hand man.

105. According t , STONE utilized the services of several individuals to

post social media content to Facebook and Twitter, and that he ) and STONE both

instructed these individuals about what to post. stated that he purchased a couple

hundred fake Facebook accounts as part of this work (including both new and existing accounts),

and that bloggers working for STONE would try to build what looked like real Facebook

accounts.

106. further stated that STONE wanted to push out WikiLeaks content

through his Facebook and Twitter accounts, and that content related to the stolen Podesta emails

was pushed out through STONE's Facebook and Twitter accounts.

L. The Target Account

107. The Target Account is a Twitter account with usemam

Search warrant returns for STONE's Hotmail account contain emails from Twitter about Target

which appear to have originally been sent to

. Although it is not clear from the face of the emails how they

ended up in STONE's Hotmail account, 7 they may have been auto-forwarded or otherwise

imported from to the Hotmail account. Subscriber records

7
Investigators have been unable to access the full headers for these emails.

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Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 38 of 50

obtained from Google show th m was registered using STONE's

Hotmail address , as the recovery account. 8

108. Tweets associated with the Target Account, which are publicly available, include

the retweeting of content related to WikiLeaks, STONE's testimony before the House

Intelligence Committee, and the hacking of the DNC. The Target Account was also used to

retweet content with the hashtag #FreeAssange! The Target Account is listed as having been

created in March 2016 and bears the picture of a person purporting to b

109. In my training and experience, I know that, in addition to posting content and

purchasing advertisements, Twitter accounts can be used to communicate privately and directly

with other users through Twitter's direct messaging function. As noted above, STONE used at

least one other Twitter account, @RogerJStoneJr, to communicate with WikiLeaks and

ASSANGE in 2016 and 2017.

BACKGROUND CONCERNING TWITTER

110. Twitter owns and operates a free-access social-networking website of the same

name that can be accessed at http://www.twitter.com. Twitter allows its users to create their own

profile pages, which can include a short biography, a· photo of themselves, and location

information. Twitter also permits users create and read 140-character messages called "Tweets,"

and to restrict their "Tweets" to individuals whom they approve. These features are described in

more detail below.

11 I. Upon creating a Twitter account, a Twitter user must create a unique Twitter

usemame and an account password, and the user may also select a different name of 20

8
was also used to register a Facebook account. This Court
authorized a search of that Facebook account on or about August 2, 20 I 8 (I: 18-sw-2570).

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characters or fewer to identify his or her Twitter account. The Twitter user may also change this

username, password, and name without having to open a new Twitter account.

112. Twitter asks users to provide basic identity and contact information, either during

the registration process or thereafter. This information may include the user's full name, e-mail

addresses, physical address (including city, state, and zip code), date of birth, gender, hometown,

occupation, and other personal identifiers. For each user, Twitter may retain information about

the date and time at which the user's profile was created, the date and time at which the account

was created, and the Internet Protocol ("IP") address at the time of sign-up. Because every

device that connects to the Internet must use an IP address, IP address information can help to

identify which computers or other devices were used to access a given Twitter account.

113. A Twitter user can post a personal photograph or image (also known as an

"avatar") to his or her profile, and can also change the profile background or theme for his or her.

account page. In addition, Twitter users can post ·"bios" of 160 characters or fewer to their profile

pages.

114. Twitter also keeps IP logs for each user. These Jogs contain information about the

user's logins to Twitter including, for each access, the IP address assigned to the user and the

date stamp at the time the user accessed his or her profile.

115. As discussed above, Twitter users can use their Twitter accounts to post "Tweets"

of 140 characters or fewer. Each Tweet includes a timestamp that displays when the Tweet was

posted to Twitter. Twitter users can also "favorite," "retweet," or reply to the Tweets of other

users. In addition, when a Tweet includes a Twitter username, often preceded by the @ sign,

Twitter designates that Tweet a "mention" of the identified user. In the "Connect" tab for each

account, Twitter provides the user with a list of other users who have "favorited" or "retweeted"

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the user's own Tweets, as well as a list of all Tweets that include the user's username (i.e., a list

of all "mentions" and "replies" for that username ).

116. Twitter users can include photographs or images in their Tweets. Each Twitter

account also is provided a user gallery that includes images that the user has shared on Twitter,

including images uploaded by other services.

117. Twitter users can also opt to include location data in their Tweets, which will

reveal the users' locations at the time they post each Tweet. This "Tweet With Location"

function is off by default, so Twitter users must opt in to the service. In addition, Twitter users

may delete their past location data.

118. When Twitter users want to post a Tweet that includes a link to a website, they

can use Twitter's link service, which converts the longer website link into a shortened link that

begins with http://t.co. This link service measures how many times a link has been clicked.

119. A Twitter user can "follow" other Twitter users, which means subscribing to

those users' Tweets and site updates. Each user profile page includes a list of the people who are

following that user (i.e., the user's "followers" list) and a list of people whom that user follows

(i.e., the user's "following" list). Twitters users can "unfollow" users whom they previously

followed, and they can also adjust the privacy settings for their profile so that their Tweets are

visible only to the people whom they approve, rather than to the public (which is the default

setting). A Twitter user can also group other Twitter users into "lists" that display on the right

side of the user's home page on Twitter. Twitter also provides users with a list of "Who to

Follow," which includes a few recommendations of Twitter accounts that the user may find

interesting, based on the types of accounts that the user is already following and who those

people follow.

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120. In addition to posting Tweets, a Twitter user can also send Direct Messages

(DMs) to one of his or her followers. These messages are typically visible only to the sender and

the recipient, and both the sender and the recipient have the power to delete the message from the

inboxes of both users. As of January 2012, Twitter displayed only the last 100 DMs for a

particular user, but older DMs are stored on Twitter's database.

121. Twitter users can configure the settings for their Twitter accounts in numerous

ways. For example, a Twitter user can configure his or her Twitter account to send updates to the

user's mobile phone, and the user can also set up a "sleep time" during which Twitter updates

will not be sent to the user'~ phone.

122. Twitter includes a search function that enables its users to search all public

Tweets for keywords, usernames, or subject, among other things. A Twitter user may save up to

25 past searches.

123. Twitter users can connect their Twitter accounts to third-party websites and

applications, which may grant these websites and applications access to the users' public Twitter

profiles.

124. If a Twitter user does not want to interact with another user on Twitter, the first

user can "block" the second user from following his or her account.

125. In some cases, Twitter users may communicate directly with Twitter about issues

relating to their account, such as technical problems or complaints. Social-networking providers

like Twitter typically retain records about such communications, including records of contacts

between the user and the provider's support services, as well as records of any actions taken by

the provider or user as a result of the communications. Twitter may also suspend a particular user

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for breaching Twitter's terms of service, during which time the Twitter user will be prevented

from using Twitter's services.

126. As explained herein, information stored in connection with a Twitter account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, a

Twitter user's account information, IP log, stored electronic communications, and other data

retained by Twitter, can indicate who has used or controlled the Twitter account. This "user

attribution" evidence is analogous to the search for "indicia of occupancy" while executing a

search warrant at a residence. For example, profile contact information, communications,

"tweets" (status updates) and "tweeted" photos (and the data associated with the foregoing, such

as date and time) may be evidence of who used or controlled the Twitter account at a relevant

time. Further, Twitter account activity can show how and when the account was accessed or

used. For example, as described herein, Twitter logs the Internet Protocol (IP) addresses from

which users access their accounts along with the time and date. By determining the physical

location associated with the logged IP addresses, investigators can understand the chronological

and geographic context of the account access and use relating to the crime under investigation.

Such information allows investigators to understand the geographic and chronological context of

Twitter access, use, and events relating to the crime under investigation. Additionally, Twitter

builds geo-location into some of its services. If enabled by the user, physical location is

automatically added to "tweeted" communications. This geographic and timeline information

may tend to either inculpate or exculpate the Twitter account owner. Last, Twitter account

activity may provide relevant insight into the Twitter account owner's state of mind as it relates

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to the offense under investigation. For example, information on the Twitter account may

indicate the owner's motive and intent to commit a crime (e.g., information indicating a criminal

plan) or consciousness of guilt (e.g., deleting account information in an effort to conceal

evidence from law enforcement).

127. Therefore, the computers of Twitter are likely to contain all the material described

above, including stored electronic communications and information concerning subscribers and

their use of Twitter, such as account access information, transaction information, and other account

information.

FILTER REVIEW PROCEDURES

128. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

with professional responsibility requirements concerning the maintenance of attorney-client and

other operative privileges. The procedures include use, if necessary, of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

CONCLUSION

129. Based on the forgoing, I request that the Court issue the proposed search warrant.

130. Pursuant to 18 U .S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

131. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

-34-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 44 of 50

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Andrew Mitchell
Special Agent
Federal Bureau of Investigation

Subscribed and sworn to before me on ~hist~ day of August, 2018.

~!fA;qp
The Honorable Beryl A. Howell
Chief United States District Judge

-35-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 45 of 50

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Twitter accounts, which

are stored at premises owned, maintained, controlled, or operated by Twitter, Inc. ("Twitter"), a

company headquartered in San Francisco, California:

-1-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 46 of 50

ATTACHMENT B

I. Information to be disclosed by Twitter

To the extent that the information described in Attachment A is within the possession;

custody, or control of Twitter, Inc. ("Twitter"), including any messages, records, files, logs, or

information that have been deleted but are still available to Twitter, or have been preserved

pursuant to a request made under 18 U .S.C. § 2703(f), Twitter is required to disclose the following

information to the government for each account listed in Attachment A:

A. All "Tweets" and Direct Messages sent, received, "favorited," or retweeted by the account,
and all photographs or images included in those Tweets and Direct Messages;

B. The content of all communications (public or private) sent to or from, stored in draft form
in, or otherwise associated with the account, including the content of all messages,
attachments, and header information;

C. All data and information associated with the profile page, including photographs, "bios,"
and profile backgrounds and themes;

D. All other content associated with the account, including, but not limited to, posts,
documents, spreadsheets, photos, and videos;

E. All information from the "Connect" tab for the account, including all lists of Twitter users
who have favorited or retweeted Tweets posted by the account, as well as a list of all Tweets
that include the username associated with the account (i.e., "mentions" or "replies");

F. All photographs and images in the user gallery for the account;

G. All location data associated with the account, including all information collected by the
"Tweet With Location" service;

H. All information about the account's use of Twitter's link service, including all longer
website links that were shortened by the service, all resulting shortened links, and all
information about the number of times that a link posted by the account was clicked;

I. All data and information that has been deleted by the user;

J. A list of all of the people that the user follows on Twitter and all people who are following
the user (i.e., the user's "following" list and "followers" list);

K. A list of all users that the account has "unfollowed" or blocked;

L. All "lists" created by the account;

-2-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 47 of 50

M. All information on the "Who to Follow" list for the account;

N. All privacy and account settings;

0. All records of Twitter searches performed by the account, including all past searches saved
by the account;

P. All current and historical subscriber and payment information, including full name, e-mail
address (including any secondary or recovery email addresses), physical address (including
city, state, and zip code), date of birth, gender, hometown, occupation, telephone number,
websites, screen names, user identification numbers, security questions and answers,
registration IP address, payment history, and other personal identifiers;

Q. All email addresses and telephone numbers ever registered (whether successfully or not)
to the account, including dates of any changes and the IP addresses used for any changes;

R. All past and current usemames, account passwords, and names associated with the account,
including dates of any changes and the IP addresses used for any changes;

S. All data and information associated with the profile page, including photographs;

T. All advertising data relating to the account, including, but not limited to, information
regarding unique advertising IDs associated with the user, any devices used to access the
account, application IDs, UDIDs, payment information (including, but not limited to, full
credit card numbers and expiration dates and PayPal accounts), ads clicked, and ads
created;

U. The dates and times at which the account and profile were created, and the Internet Protocol
("IP") address at the time of sign-up;

V. All transactional records associated with the account, including any IP logs or other records
of session times and durations;

W. Any information identifying the device or devices used to access the account, including a
device serial number, a GUID or Global Unique Identifier, a phone number, serial numbers,
MAC addresses, Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers
("MEIN"), Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers
("MIN"), Subscriber Identity Modules ("SIM"), Mobile Subscriber Integrated Services
Digital Network Number ("MSISDN"), International Mobile Subscriber Identifiers
("IMSI"), or International Mobile Equipment Identities ("IMEi"), and any other
information regarding the types of devices used to access the account;

X. All activity logs for the account;

Y. All location information for the account, including all location data collected by any
plugins or widgets;

Z. The types of service utilized by the user;

-3-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 48 of 50

AA. All information about the account's use of Twitter' s link service, including all website links
embedded in, exporting data to, or importing data from, the account's website or blog;

BB. All full website links that were shortened by Twitter's link service, all resulting shortened
links, and all information about the number of times that a link posted by the account was
clicked;

CC. All information about connections between the account and third-party websites and
applications, including any Twitter, Facebook or other social networking accounts to which
posts from the account are sent;

DD. All data and information that has been deleted by the user;

EE. The length of service (including start date) and the means and source of any payments
associated with the service (including any credit card or bank account number);

FF. All privacy settings and other account settings, including email addresses or other accounts
that the account has blocked;

GG. Information regarding linked accounts, including accounts linked by cookie, IP address
(including registration IP address), advertising ID, User Client UUID, User Guest Cookie
ID, Known Device Token, Normalized Email Address, Android ID, IMEi, GUID, device
identifier, or any other account or device identifier;

HH. Information regarding accounts linked to accounts to which the Target Accounts are linked;

II. All records pertaining to communications between the Service Provider and any person
regarding the user or the user's account with the Service Provider, including contacts with
support services, records of actions taken, and investigative or user complaints concerning
the subscriber.

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access ofa protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June 1, 2015 to the present, including:

-4-
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 49 of 50

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, or any

individual associated with the Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

-5 -
Case 1:19-mc-00029-CRC Document 29-16 Filed 04/28/20 Page 50 of 50

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s );

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

I. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)--who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 1 of 33

AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched )
Case: 1: 18-sc-02670
or identify the person by name and address) ) Assigned To: Howell, Beryl A.
INFORMATION ASSOCIATED WITH ONE ACCOUNT ) Assign. Date : 8/20/2018
STORED AT PREMISES CONTROLLED BY 1&1 MAIL ) Description: Search & Seizure Warrant
& MEDIA, INC. )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Eastern District of Pennsylvania
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before September 3, 2018 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to 10:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Rudolph Contreras-, U.S. District Judge
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued: if_dJ!J(J.&18 3: l?t t'\L / Judge 's signature

City and state: Washington, DC Hon. Rudolph Contreras, U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 2 of 33

AO 93 (Rev. l l/13) Search and Seizure Warrant (Page 2)

Return
Case No. : Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of pe1jury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 3 of 33

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following l&I Mail account, whic;h

is stored at premises owned, maintained, controlled, or operated by 1&1 Mail & Media, Inc., a

company headquartered i~ Chesterbrook, Pennsylvania:

-1-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 4 of 33

ATTACHMENT B

I. Information to be disclosed by l&l Mail

To the extent that the infonnation described in Attachment A is within the possession,

custody, or control of 1& 1 Mail & Media, Inc. (the "Provider"), including any messages, records,

files, logs, or information that have been deleted but are still available to the Provider, or have

been preserved pursuant to a request made under 18 U.S.C. § 2703(£), the Provider is required to

disclose the following information to the government for each account listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date and time at which each

email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the ac.count, to

include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the

account, including address books, contact and buddy lists, calendar data, pictures,

and files;

-2-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 5 of 33

e. All records pertaining to communications between the Provider and any person

regarding the account, including contacts with support services and records of

actions taken;

f. All subscriber "change history" associated with the account;

g. All search history and web history associated with the account;

h. All location and maps information associated with the account;

1. All device information associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Number

("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), or

International Mobile Equipment Identities ("IMEI")); and

j. For any accounts linked to the accounts listed in Attachment A, including accounts

linked by cookie, SMS number, or recovery email address, and for accounts for

which the accounts described in Attachment A are the recovery email address,

provide all records or other information regarding the identification of the account,

to include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number).

-3-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 6 of 33

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1030 (unauthorized access of a protected computer); 18

U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud);

and 52 U.S.C. § 30121 (foreign contribution ban), including:

a. Evidence of unauthorized access to protected computers;

b. Evidence of the distribution or transfer of data obtained through unauthorized

access to protected computers;

c. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

d. Evidence indicating the account owner's state of mind as it relates to the crimes

under investigation;

e. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

f. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

g. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

-4-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 7 of 33

h. Communications, recorqs, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

i. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

J. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

-5-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 8 of 33
AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT


for the Clerk, U.S. District & Bankruptcy
District of Columbia Courts for the District of Columbia

In the Matter of the Search of


Case: 1:18-sc-02670

l
(Briefly describa the property to be searched
or identify the person by name and oddres!i) Ass!gned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH ONE ACCOUNT Assign. Date: 8/20/2018
STORED AT PREMISES CONTROLLED BY 1&1 MAIL &
MEDIA, INC.
Description: Search & Seizure Warrant
)

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement offi cer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A
located in the -------
Eastern District of Pennsylvania
----"--''--"-...c...r...;_..:....:.._;~- - -
, there is now concealed (identify the
person or describe the property to be seized):
See Attachment B

The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
M evidence of a crime;
Mcontraband, fruits of crime, or other items illegally possessed;
~ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
52 u.s.c. § 30121 Foreign Contribution Ban
18 u.s.c. §§ 1030, 371 Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts :
See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of _ _ days (give exact ending date if more than 30 days: _ _ __ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA:
!Kyle R. Freeny (ASC) Patrick J. Myers, Special Agent, FBI
Printed name and title

Sworn to before me and signed in my presence.

Date: er
City and state: Washington, D.C. Hon. Rudolph Contreras, U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 9 of 33

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA
AUG 2o20'8
Clerk. U.S. District & Bankruptcy
Courts for thil Oiatriat af r · a
IN THE MATTER OF THE SEARCH OF
INFORMATION ASSOCIATED WITH Case: 1 :18-sc-02670
ONE ACCOUNT STORED AT PREMISES Assigned To: Howell, Beryl A.
CONTROLLED BY l&l MAIL & MEDIA, Assign. Date: 8/20/2018
INC. Description: Search & Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Patrick J. Myers, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the account ("Target Account"), stored at

premises owned, maintained, controlled or operated by l&l Mail & Media, Inc. ("1&1 Mail"), a

company headquartered in Chesterbrook, Pennsylvania. The information to be disclosed by 1& 1

Mail and searched by the government is described in the following paragraphs and in Attachments

A and B.

2. I am a Special Agent with the Federal Bureau of Investigation ("FBI") assigned to

FBI Pittsburgh working directly with the Special Counsel's Office. I have been a Special Agent

with the FBI since 2017. I was previously employed as a network and software engineer for

approximately fifteen years, including for the FBI. As a Special Agent, I have conducted national

security investigations relating to foreign intelligence and cybersecurity.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

-1-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 10 of 33

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Account contain evidence, fruits, or

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 951 (acting as an unregistered foreign agent), 18 U.S.C. § 1030 (unauthorized access of

a protected computer), 18 U.S.C. § 1343 (wire fraud), and 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121(a)(l)(C) (foreign expenditure ban).

There also is probable cause to search the information described in Attachment A for evidence,

contraband, fruits, and/or instrumentalities of the Subject Offenses, further described in

Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competentjurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(l)(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

PROBABLE CAUSE

A. Russian Government-Backed Hacking Activity during the 2016 Presidential


Election

6. On June 14, 2016, the cybersecurity firm CrowdStrike, Inc. and its affiliates

("CrowdStrike") published a blog post entitled, "Bears in the Midst: Intrusion into the

-2-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 11 of 33

Democratic National Committee." 1 In the blog post, CrowdStrike described how the firm "was

called by the Democratic National Committee (DNC), the formal governing body for the US

Democratic Party, to respond to a suspected breach." According to CrowdStrike, the cyber actor

known as "Fancy Bear" breached the DNC network in 2016. CrowdStrike further assessed:

"Extensive targeting of defense ministries and other military victims [by FANCY BEAR] has

been observed, the profile of which closely mirrors the strategic interests of the Russian

government, and may indicate affiliation with f'nasttoe Pa:rne,ri:hrnaTeJihHoe Yrrpasnem1e (Main

Intelligence Department) or GRU, Russia's premier military intelligence service."

7. Starting in or around mid-2016, published reports also detailed attempts to

compromise both the work and personal email accounts of numerous individuals involved in the

2016 U.S. presidential campaign through "spearphishing" efforts. In this context, spear phishing

refers to the fraudulent practice of sending an email that purports to be from a known or trusted

sender in order to induce the targeted victim to respond in a desired manner, typically by clicking

a malicious link or URL. The perpetrators used Bitly, a link-shortening and management service,

to disguise the malicious URLs. Victims of these spearphishing efforts included John Podesta, the

chairman of the Clinton Campaign, who received a spearphishing email on or about March 19,

2016. The email contained a Bitly link created by the Bitly account john356gh, which the FBI has

linked to a known GRU officer.

8. On or about September 20, 2016, Crowd Strike also identified a new intrusion into

the DNC's virtual private cloud, hosted by Amazon Web Services (AWS). CrowdStrike advised

1
"Bears in the Midst: Intrusion into the Democratic National Committee," June 14, 2016,
available at https://www.crowdstrike.com/blog/bears-midst-intrusion-democratic-national-
committee.

-3-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 12 of 33

the FBI that the perpetrators obtained unauthorized access to the DNC's VPC system through the

theft of an administrator credential, which gave the perpetrators the ability to modify the network's

security rules. After gaining this access, the perpetrators modified the rules that limited the

universe of devices that could connect to the victim computers. Based on its forensic analysis,

CrowdStrike determined that the perpetrators copied snapshots of the DNC's cloud-based

computers onto at least three new AWS accounts created by the perpetrators.

9. Following the inception of the spear phishing and intrusion campaigns, a series of

overlapping actors began to be release documents stolen from the DNC, DCCC, and the personal

email accounts of campaign-affiliated individuals. Release of these stolen documents principally

occurred through three forums: (1) a series of accounts operated under the online persona

"Guccifer 2.0"; (2) a website and series of accounts operated under the online persona "DCLeaks";

and (3) the websites and public archives operated by the group "Wikileaks." The releases of stolen

documents included confidential memoranda written by Democratic employees; strategy

documents discussing various components of the 2016 federal elections; and confidential

correspondences of the DNC and DCCC, as well as individuals involved in the presidential

campaign of Hillary Clinton.

10. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." 2 In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith .in the US

2
"Assessing Russian Activities and Intentions in Recent US Elections," Jan. 6, 2017, available at
https://www.dni.gov/files/documents/ICA_20l 7_01.pdf.

-4-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 13 of 33

democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Government developed a clear preference for President-elect Trump.

11. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

12. With respect to hacking activity, the USIC assessed: "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." In addition, "In July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC further assessed that cyber

operations by Russian military intelligence (General Staff Main Intelligence Directorate or GRU)

"resulted in the compromise of the personal e-mail accounts of Democratic Party officials and

political figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

13. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to release

US victim data obtained in cyber operations publicly and in exclusives to media outlets."

14. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

presidential election, including conspiracy to commit authorized access to protected computers.

(Case No. 1:18-cr-00125).

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Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 14 of 33

B. Guccifer 2.0's Use of WikiLeaks to Further the Interference in the 2016 U.S.
Presidential Election

15. On June 15, 2016, the day after CrowdStrike publicly attributed the DNC hack to

Russian government actors, the persona Guccifer 2.0 published its first post on a WordPress

blog, publicly claiming responsibility for the hack. The post, titled "GUCCIFER 2.0 DNC'S

SERVERS HACKED BY A LONE HACKER," contained a number of documents that Guccifer

2.0 represented as "docs I downloaded from the Democrats network." Guccifer 2.0 also stated in

the same post that, with respect to the documents stolen from the DNC, "[t]he main part of the

papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

16. According to open source information, WikiLeaks is a self-described anti-secrecy

organization, which is responsible for releasing stolen documents from a number of government

and non-governmental entities. Julian Assange, an Australian citizen, founded WikiLeaks in or

around 2006, and he has stated in public interviews that he is deeply involved in running the

organization.

17. On or about June 20, 2016, Guccifer 2.0 registered the Twitter account

@GUCCIFER_ 2. Search warrant returns for that Twitter account show that Guccifer 2.0

communicated via direct message with WikiLeaks' Twitter account, @wikileaks, about the stolen

DNC documents, including about ways to maximize the impact of the documents on the 2016

U.S. presidential election. For example, on or about June 22, 2016, WikiLeaks sent a private

message to Guccifer 2.0, via Twitter, telling Guccifer 2.0 to "[s]end any new material [stolen

from the DNC] here for us to review and it will have a much higher impact than what you are

doing." On or about July 6, 2016, WikiLeaks stated, "if you have anything hillary related we

want it in the next tweo [sic] days prefable [sic] because the DNC [Democratic National

Convention] is approaching and she will solidify Bernie supporters behind her after." Guccifer

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Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 15 of 33

2.0 responded, "ok ... I see." WikiLeaks explained, "we think trump has only a 25% chance of

winning against Hillary ... so conflict between Bernie and Hillary is interesting."

18. According to information obtained through a court-authorized search of the

Target Account conducted in or around August 2016, I know that on or about July 14, 2016,

Guccifer 2.0 sent WikiLeaks an email with an attachment titled "wk dnc linkl .txt.gpg." Search

warrant returns for the Guccifer 2.0 Twitter account show that Guccifer 2.0 then sent a direct

message to WikiLeaks that appears to explain that the encrypted file contained instructions on

how to access an online archive of stolen DNC documents. On or about July 18, 2016,

WikiLeaks confirmed it had "the 1Ob or so archive" and would make a release of the stolen

documents "this week."

19. On or about July 22, 2016, WikiLeaks released over 20,000 emails and other

documents stolen from the DNC network. This release occurred approximately three days before

the start of the Democratic National Convention. WikiLeaks did not disclose Guccifer 2.0's role

in providing them.

20. On or about October 7, 2016, WikiLeaks released the first set of emails that had

been stolen from John Podesta, chairman of the Clinton Campaign. Between on or about

October 7, 2016 and November 7, 2016, WikiLeaks released approximately thirty-three tranches

of documents that had been stolen from Podesta. Based on an assessment of the WikiLeaks

releases, investigators believe that the total amount of stolen election-related data released by

WikiLeaks was substantially greater than the 1GB of stolen data apparently contained in the

online archive provided by Guccifer 2.0, as described above.

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Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 16 of 33

21. In an August 2017 interview, AS SANGE indicated that only a small number of

people, including himself, worked on the release of the DNC emails. 3 Based on public source

information, I know that AS SANGE made false and misleading statements about the origins of

the stolen documents, including statements that insinuated that WikiLeaks had received them

from a recently-deceased DNC employee.

22. Investigators have learned that WikiLeaks and/or ASSANGE communicated,

including via intermediaries, about the stolen documents with Roger J. Stone ("STONE"), who

advised the presidential campaign of Donald J. Trump in 2015 and who remained in contact with

individuals employed by the campaign through the 2016 election. For example, search warrant

returns for STONE's Hotmail account , show that on or about July 25,

2016, STONE directed one of his associates, Jerome CORSI, to "[g]et to Assange [a]t the

Ecuadorian Embassy in London and get the pending WikiLeaks emails ... ." On or about July

31, 2016, Stone reached out again to CORSI, suggesting that he should "see Assange." A few

days later, on or about August 2, 2016, CORSI emailed STONE, "Word is friend in embassy

plans 2 more dumps. One shortly after I'm back 2nd in Oct[ober]. Impact planned to be very

damaging .... " I believe that CORSl's reference to a "friend in [the] embassy" refers to

ASSANGE.

C. The Target Account

23. According to subscriber information obtained from WordPress in July 2016, the

Guccifer 2.0 WordPress account ) was created on June 15, 2016 using

the email addres and Target Account was listed as

3
See https://www.newyorker.com/magazine/2017/08/21/julian-assange-a-man-without-a-country

-8-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 17 of 33

another email address on the account. Subscriber records for the Target Account indicate that it

was created on July 23, 2016 in the name of "Guccifer Second."

24. The FBI searched the Target Account in approximately August 2016 pursuant to

a search warrant authorized by the Northern District of California. In approximately September

2017, the government obtained additional non-content information about the Target Account

pursuant to 18 U.S.C. § 2703(d), which included header information for the period of time

between approximately August 2016 and September 2017. The header information shows that

the Target Account continued to receive emails through at least approximately February 25,

2017, including emails from WordPress and the file sharing services DropBox and MediaFire,

which were not captured in the original court-authorized search conducted in August 2016.

25. Subscriber records obtained from l&l Mail in August 2018 show that the Target

Account is still active (that is, it has not been deleted). The last login is listed as October 18,

2016. Records from the Target Account will, among other things, assist investigators in

understanding Guccifer 2.0's use of file sharing services, which may in turn assist investigators

in identifying additional means by which Guccifer 2.0 shared stolen documents with WikiLeaks

and others.

BACKGROUND CONCERNING l&l MAIL

26. In my training and experience, I have learned that l&l Mail provides a variety of

on-line services, including electronic mail ("email") access, to the public. 1& 1 Mail allows

subscribers to obtain email accounts at several domain names, including mail.com, like the Target

Account. Subscribers obtain an account by registering with l&l Mail. During the registration

process, 1& 1 Mail asks subscribers to provide basic personal information. Therefore, the

computers of 1& 1 Mail are likely to contain stored electronic communications (including retrieved

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Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 18 of 33

and unretrieved email for l&l Mail subscribers and information concerning subscribers and their

use of 1& 1 Mail services, such as account access information, email transaction information, and

account application information. In my training and experience, such information may constitute

evidence of the crimes under investigation because the information can be used to identify the

account's user or users.

27. In my training and experience, email providers generally ask their subscribers to

provide certain personal identifying information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and other

identifiers, alternative email addresses, and, for paying subscribers, means and source of payment

(including any credit or bank account number). In my training and experience, such information

may constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users. Based on my training and my experience, I know that, even if

subscribers insert false information to conceal their identity, this information often provides clues

to their identity, location, or illicit activities.

28. In my training and experience, email providers typically retain certain transactional

information about the creation and use of each account on their systems. This information can

include the date on which the account was created, the length of service, records of log-in

(i.e., session) times and durations, the types of service utilized, the status of the account (including

whether the account is inactive or closed), the methods used to connect to the account (such as

logging into the account via the provider's website), and other log files that reflect usage of the

account. In addition, email providers often have records of the Internet Protocol address

("IP address") used to register the account and the IP addresses associated with particular logins

to the account. Because every device that connects to the Internet must use an IP address,

-10-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 19 of 33

IP address information can help to identify which computers or other devices were used to access

the email account.

29. In my training and experience, m some cases, email account users will

communicate directly with an email service provider about issues relating to the account, such as

technical problems, billing inquiries, or complaints from other users. Email providers typically

retain records about such communications, including records of contacts between the user and the

provider's support services, as well as records of any actions taken by the provider or user as a

result of the communications. In my training and experience, such information may constitute

evidence of the crimes under investigation because the information can be used to identify the

account's user or users.

30. This application seeks a warrant to search all responsive records and information

under the control of l&l Mail, a provider subject to the jurisdiction of this court, regardless of

where 1& 1 Mail has chosen to store such information. The government intends to require the

disclosure pursuant to the requested warrant of the contents of wire or electronic communications

and any records or other information pertaining to the customers or subscribers if such

communication, record, or other information is within l&l Mail's possession, custody, or control,

regardless of whether such communication, record, or other information is stored, held, or

maintained outside the United States.

31. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

-11-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 20 of 33

the account. This "user attribution" evidence is analogous to the search for "indicia of occupancy"

while executing a search warrant at a residence. For example, email communications, contacts

lists, and images sent (and the data associated with the foregoing, such as date and time) may

indicate who used or controlled the account at a relevant time. Further, information maintained by

the email provider can show how and when the account was accessed or used. For example, as

described below, email providers typically log the Internet Protocol (IP) addresses from which

users access the email account, along with the time and date of that access. By determining the

physical location associated with the logged IP addresses, investigators can understand the

chronological and geographic context of the email account access and use relating to the crime

under investigation. This geographic and timeline information may tend to either inculpate or

exculpate the account owner. Additionally, information stored at the user's account may further

indicate the geographic location of the account user at a particular time (e.g., location information

integrated into an image or video sent via email). Last, stored electronic data may provide relevant

insight into the email account owner's state of mind as it relates to the offense under investigation.

For example, information in the email account may indicate the owner's motive and intent to

commit a crime (e.g., communications relating to the crime), or consciousness of guilt

(e.g., deleting communications in an effort to conceal them from law enforcement).

32. Because there is probable cause to believe that the Target Account is an

operational account created to further criminal conduct, this application seeks authorization to

seize the information in Attachment B from the time of the creation of the account to the present.

FILTER REVIEW PROCEDURES

33. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

-12-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 21 of 33

with professional responsibility requirements concerning the maintenance of attorney-client and

other operative privileges. The procedures include use, if necessary, of a designated "filter team,"

separate and apart from the investigative team, in order to address potential privileges. The

government, however, does not at this time anticipate that any of the items described in

Attachment A will contain materials requiring review by a designated filter team.

CONCLUSION

34. Based on the forgoing, I request that the Court issue the proposed search warrant.

35. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

36. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

-Ei?~
Special Agent
Federal Bureau oflnvestigation

Subscribed and sworn to before me on this _df}_~ yof August, 2018.

__,
rable Rudolph Contreras
United States District Judge

-13-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 22 of 33

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following l&l Mail account, which

is stored at premises owned, maintained, controlled, or operated by l&I Mail & Media, Inc., a

company headquartered in Chesterbrook, Pennsylvania:

-1-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 23 of 33

ATTACHMENTB

I. Information to be disclosed by l&l Mail

To the extent that the information described in Attachment A is within the possession,

custody, or control of 1& 1 Mail & Media, Inc. (the "Provider"), including any messages, records,

files, logs, or information that have been deleted but are still available to the Provider, or have

been preserved pursuant to a request made under 18 U.S.C. § 2703(£), the Provider is required to

disclose the following information to the government for each account listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date and time at which each

email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the account, to

include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the

account, including address books, contact and buddy lists, calendar data, pictures,

and files;

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Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 24 of 33

e. All records pertaining to communications between the Provider and any person

regarding the account, including contacts with support services and records of

actions taken;

f. All subscriber "change history" associated with the account;

g. All search history and web history associated with the account;

h. All location and maps information associated with the account;

1. All device information associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Number

("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), or

International Mobile Equipment Identities ("IMEi")); and

J. For any accounts linked to the accounts listed in Attachment A, including accounts

linked by cookie, SMS number, or recovery email address, and for accounts for

which the accounts described in Attachment A are the recovery email address,

provide all records or other information regarding the identification of the account,

to include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number).

-3-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 25 of 33

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision ofa felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1030 (unauthorized access of a protected computer); 18

U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud);

and 52 U.S.C. § 30121 (foreign contribution ban), including:

a. Evidence of unauthorized access to protected computers;

b. Evidence of the distribution or transfer of data obtained through unauthorized

access to protected computers;

c. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

d. Evidence indicating the account owner's state of mind as it relates to the crimes

under investigation;

e. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

f. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

g. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

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Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 26 of 33

h. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

1. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

J. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

-5-
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 27 of 33

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF


Case: 1:18-sc-02670
INFORMATION AS SOCIA TED WITH ONE
Assigned To: Howell, Beryl A.
ACCOUNT STORED AT PREMISES
CONTROLLED BY l&l MAIL & MEDIA, Assign. Date : 8/20/2018
INC. Description: Search & Seizure Warrant

MOTION TO SEAL WARRANT AND RELATED DOCUMENTS AND


TO REQUIRE NO -DIS 'LOSURE UND "' R 18 U.S .C. § 2705(b)

The United States of America, moving by and through its undersigned counsel, respectfully

moves the Court for an Order placing the above-captioned warrant and the application and affidavit

in support thereof (collectively herein the "Warrant") under seal, and precluding the provider from

notifying any person of the Warrant pursuant to 18 U.S.C. § 2705(b). In regard to the non-

disclosure, the proposed Order would direct l&l Mail & Media, Inc. ("l&l Mail"), an electronic

communication and/or remote computing services provider headquartered in Chesterbrook,

Pennsylvania, not to notify any other person (except attorneys for l&l Mail for the purpose of

receiving legal advice) of the existence or content of the Warrant for a period of one year or until

further order of the Court.

1. The Court has the inherent power to seal court filings when appropriate,

including the Warrant. United States v. Hubbard, 650 F.2d 293, 315-16 (D.C. Cir. 1980) (citing

Nixon v. Warner Communications, Inc., 435 U.S. 589, 598 (1978)). The Court may also seal the

Warrant to prevent serious jeopardy to an ongoing criminal investigation when, as in the present

case, such jeopardy creates a compelling governmental interest in preserving the confidentiality of

the Warrant. See Washington Post v. Robinson, 935 F.2d 282, 287-89 (D.C. Cir. 1991).
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 28 of 33

2. In addition, this Court has jurisdiction to issue the requested order because it is "a

court of competent jurisdiction" as defined by 18 U.S.C. § 2711. Specifically, the Court is a

"district court of the United States ... that - has jurisdiction over the offense being investigated."

18 U.S.C. § 2711(3)(A)(i). Acts or omissions in furtherance of the offense under investigation

occurred within Washington, D.C. See 18 U.S.C. § 3237.

3. Further, the Court has authority to require non-disclosure of the Warrant under 18

U.S.C. § 2705(b). l&l Mail provides an "electronic communications service," as defined in 18

U.S.C. § 2510(15), and/or "remote computing service," as defined in 18 U.S.C. § 2711(2). The

Stored Communications Act ("SCA"), 18 U.S.C. §§ 2701-2712, governs how l&l Mail may be

compelled to supply communications and other records using a subpoena, court order, or search

warrant. Specifically, Section 2703(c)(2) authorizes the Government to obtain certain basic

"subscriber information" using a subpoena, Section 2703(d) allows the Government to obtain other

"non-content" information using a court order, and Section 2703(a)-(b)(1 )(A) allows the

Government to obtain contents of communications using a search warrant. See 18 U.S.C. § 2703.

4. The SCA does not set forth any obligation for providers to notify subscribers about

subpoenas, court orders, or search warrants under Section 2703. However, many have voluntarily

adopted policies of notifying subscribers about such legal requests. Accordingly, when necessary,

Section 2705(b) of the SCA enables the Government to obtain a court order to preclude such

notification. In relevant part, Section 2705(b) provides as follows: 1

(b) Preclusion of notice to subject of governmental access. - A governmental


entity acting under section 2703 ... may apply to a court for an order commanding
a provider of electronic communications service or remote computing service to
whom a warrant, subpoena, or court order is directed, for such period as the court

1
Section 2705(b) contains additional requirements for legal process obtained pursuant to 18 U.S.C.
§ 2703(b)(1 )(B), but the Government does not seek to use the proposed Order for any legal process
under that provision.

2
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 29 of 33

deems appropriate, not to notify any other person of the existence of the warrant,
subpoena, or court order. The court shall enter such an order if it determines that
there is reason to believe that notification of the existence of the warrant, subpoena,
or court order will result in-
(1) endangering the life or physical safety of an individual;
(2) flight from prosecution;
(3) destruction of or tampering with evidence;
(4) intimidation of potential witnesses; or
(5) otherwise seriously jeopardizing an investigation or unduly delaying a trial.

18 U.S.C. § 2705(b). The United States District Court for the District of Columbia has made clear

that a nondisclosure order under Section 2705(b) must be issued once the Government makes the

requisite showing about potential consequences of notification:

The explicit terms of section 2705(b) make clear that if a courts [sic] finds that there
is reason to believe that notifying the customer or subscriber of the court order or
subpoena may lead to one of the deleterious outcomes listed under § 2705(b ), the
court must enter an order commanding a service provider to delay notice to a
customer for a period of time that the court determines is appropriate. Once the
government makes the required showing under § 2705(b ), the court is required to
issue the non-disclosure order.

In re Application for Order of Nondisclosure Pursuant to 18 US.C. § 2705(b) for Grand Jury

Subpoena #GJ2014031422765, 41 F. Supp. 3d 1, 5 (D.D.C. 2014).

5. Accordingly, this motion to seal sets forth facts showing reasonable grounds to

command l&l Mail not to notify any other person (except attorneys for 1&1 Mail for the purpose

of receiving legal advice) of the existence of the Subpoena for a period of one year or until further

order of the Court.

FA N-DlSCLOSURE

6. The Federal Bureau oflnvestigation ("FBI") is investigating WikiLeaks and others

for violations of 18 U.S.C. § 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the fact), 18

U.S.C. § 4 (misprision of a felony), 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 951 (acting as an

unregistered foreign agent), 18 U.S.C. § 1030 (unauthorized access of a protected computer);

18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud),

3
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 30 of 33

and 22 U.S.C. § 611 et seq. (Foreign Agents Registration Act), and 52 U.S.C. § 30121 (foreign

contribution ban) (the "Subject Offenses"), in connection with efforts to compromise the networks

of the Democratic National Convention ("DNC"), the Democratic Congressional Campaign

Committee ("DCCC"), and the email accounts of U.S. persons involved in the 2016 presidential

election, followed by the public release of stolen materials through various outlets.

7. In this matter, the government requests that the Warrant be sealed until further order

of the Court and that l&l Mail and its employees be directed not to notify any other person of the

existence or content of the Warrant (except attorneys for 1& 1 Mail for the purpose of receiving

legal advice) for a period of one year or until further order of the Court. Such an order is

appropriate because the Warrant relates to an ongoing criminal investigation, the scope and nature

of which is neither public nor known to the targets of the investigation, and its disclosure may alert

these targets to the nature, scope, and focus of the ongoing investigation. Disclosure of the Warrant

and related papers may also alert the targets to the scope of information known to the FBI. Once

alerted to this information, potential targets would be immediately prompted to destroy or conceal

incriminating evidence, alter their operational tactics to avoid future detection, and otherwise take

steps to undermine the investigation and avoid future prosecution. In particular, given that they

are known to use electronic communication and remote computing services, the potential target

could quickly and easily destroy or encrypt digital evidence relating to their criminal activity.

8. Given the complex and sensitive nature of the criminal activity under investigation,

and also given that the criminal scheme may be ongoing, the Government anticipates that this

confidential investigation will continue for the next year or longer. However, should

circumstances change such that court-ordered nondisclosure under Section 2705(b) becomes no

longer needed, the Government will notify the Court and seek appropriate relief.

4
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 31 of 33

9. There is, therefore, reason to believe that notification of the existence of the

Warrant will seriously jeopardize the investigation, including by giving the targets an opportunity

to flee from prosecution, destroy or tamper with evidence, and intimidate witnesses. See 18 U.S .C.

§ 2705(b)(2)-(5). Because of such potential jeopardy to the investigation, there also exists a

compelling governmental interest in confidentiality to justify the government's sealing request.

See Robinson, 935 F.2d at 287-89.

10. Based on prior dealings with l&l Mail, the United States is aware that, absent a

court order under Section 2705(b) commanding l&l Mail not to notify anyone about a legal

request, 1& 1 Mail may, upon receipt of a warrant seeking the contents of electronically stored wire

or electronic communications for a certain account, notify the subscriber or customer of the

existence of the warrant prior to producing the material sought.

WHEREFORE, for all the foregoing reasons, the government respectfully requests that the

above-captioned warrant, the application and affidavit in support thereof, and all attachments

thereto and other related materials be placed under seal, and furthermore, that the Court command

1& 1 Mail not to notify any other person of the existence or contents of the above-captioned warrant

(except attorneys for 1& 1 Mail for the purpose of receiving legal advice) for a period of one year

or until further order of the Court.

Respectfully submitted,

ROBERTS. MUELLER, III


Special Counsel

Dated: 8 [2o/( 8 By:


Kyle
The ·a l Counsel's O · e
(202) 616-3812

5
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 32 of 33

AUG 2o2018
Clerk, U.S. District & Bankruptcy
IN THE UNITED STATES DISTRICT COURT Courts tor the District of Columbia
FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF


Case: 1: 18-sc-02670
INFORMATION AS SOCIA TED WITH ONE
Assigned To : Howell, Beryl A.
ACCOUNT STORED AT PREMISES
Assign. Date: 8/20/2018
CONTROLLED BY l&l MAIL & MEDIA,
Description: Search & Seizure Warrant
INC.

ORDER

The United States has filed a motion to seal the above-captioned warrant and related

documents, including the application and affidavit in support thereof (collectively the "Warrant"),

and to require l&l Mail & Media, Inc. ("1&1 Mail"), an electronic communication and/or remote

computing services provider headquartered in Chesterbrook, Pennsylvania, not to disclose the

existence or contents of the Warrant pursuant to 18 U.S.C. § 2705(b).

The Court finds that the United States has established that a compelling governmental

interest exists to justify the requested sealing, and that there is reason to believe that notification

of the existence of the Warrant will seriously jeopardize the investigation, including by giving the

targets an opportunity to flee from prosecution, destroy or tamper with evidence, and intimidate

witnesses. See 18 U.S.C. § 2705(b)(2)-(5).

IT IS THEREFORE ORDERED that the motion is hereby GRANTED, and that the

warrant, the application and affidavit in support thereof, all attachments thereto and other related

materials, the instant motion to seal, and this Order be SEALED until further order of the Court;

and
Case 1:19-mc-00029-CRC Document 29-17 Filed 04/28/20 Page 33 of 33

IT IS FURTHER ORDERED that, pursuant to 18 U.S.C . § 2705(b), l&l Mail and its

employees shall not disclose the existence or content of the Warrant to any other person (except

attorneys for I & I Mail for the purpose of receiving legal advice) for a period of one year or until

further order of the Court.

//L--
BLE RUDOLPH CONTRERAS
TES DISTRICT JUDGE

oG)oJdfl_c (

2
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 1 of 35

AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1: 18-sc-02671
or identify the person by name and address) ) Ass!gned To : Howell, Beryl A
INFORMATION ASSOCIATED WITH ) Assign. Date: 8/20/2018
ONE CELLULAR TELEPHONE NUMBER THAT IS ) Description: Search & Seizure Warrant
STORED AT PREMISES CONTROLLED BY AT&T )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of Florida
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before August 31, 2018 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to I 0:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell, Chief U.S. District Judge
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued:

City and state: Washington, DC Hon. Rudolph Contreras, U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 2 of 35

AO 93 (Rev. I l/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of :

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 3 of 35

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the cellular telephone assigned call

number ("the Account"), that is stores at premises controlled by AT&T ("the

Provider"), headquartered at 11760 US Highway 1, North Palm Beach, Florida.

-1-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 4 of 35

ATTACHMENT B

I. Information to be disclosed by Provider

To the extent that the information described in Attachment A is within the possession,

custody, or control of the Provider, including any information that has been deleted but is still

available to the Provider or that has been preserved pursuant to a request made under 18 U.S.C.

§ 2703(f), the Provider is required to disclose to the government the following information

pertaining to the Account listed in Attachment A for the time period June 14, 2016 through

November 15, 2016:

a. The following information about the customers or subscribers of the Account:

1. Names (including subscriber names, user names, and screen names);

ii. Addresses (including mailing addresses, residential addresses, business


addresses, and e-mail addresses);

m. Local and long distance telephone connection records;

1v. Records of session times and durations, and the temporarily assigned
network addresses (such as Internet Protocol ("IP") addresses) associated
with those sessions;

v. Length of service (including start date) and types of service utilized;

vi. Telephone or instrument numbers (including MAC addresses, Electronic


Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),
Mobile Equipment Identifier ("MEID"); Mobile Identification Number
("MIN"), Subscriber Identity Modules ("SIM"), Mobile Subscriber
Integrated Services Digital Network Number ("MS ISDN"); International
Mobile Subscriber Identity Identifiers ("IMSI"), or International Mobile
Equipment Identities ("IMEi");

vii. Other subscriber numbers or identities (including the registration Internet


Protocol ("IP") address); and

viii. Means and source of payment for such service (including any credit card
or bank account number) and billing records.

-2-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 5 of 35

b. All records and other information (not including the contents of communications)

relating to wire and electronic communications sent or received by the Account,

including:

1. the date and time of the communication, the method of the

communication, and the source and destination of the communication

(such as the source and destination telephone numbers (call detail

records), email addresses, and IP addresses); and

11. information regarding the cell tower and antenna face (also known as

"sectors") through which the communications were sent and received.

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A which

consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and abetting),

18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18 U.S.C. § 371

(conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a

protected computer); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to

commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the period from June

14, 2016 to November 15, 2016.

-3-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 6 of 35
AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT FI .


for the
AUG 2 O 2018
District of Columbia
GI erk, U,S. District & Bankruptcy
Courts for the District of Columbia
In the Matter of the Search of Case: 1:18-sc-02671
(Briefly describ • the p roperty to be searched
or ide111ify the p erson by name nnd address)
INFORMATION ASSOCIATED WITH
ONE CELLULAR TELEPHONE NUMBER STORED AT
l
)
)
Assigned To: Howell, Beryl A.
Assign. Date: 8/20/2018
Description: Search & Seizure Warrant
PREMISES CONTROLLED BY AT&T )

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location) :

See Attachment A
located in the - - - -- District of - - --
- --Southern Florida
- - - - - -- -
, there is now concealed (identify the
person or describe the property to be seized):
See Attachment B

The basis for the search under Fed. R. Crim. P. 41 (c) is (check one or more):
~ evidence of a crime;
0 contraband, fruits of crime, or other items illegally possessed;
0 property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
52 U.S.C. § 30121 Foreign Contribution Ban
18 U.S.C. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of days (give exact ending date if more than 30 days: - - - - - ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA:
c_A~,-
.c.-
1. ~ ,..--·-~~-
pp 1ca11 s signature

IKyle R. Freeny (ASC) Andrew Mitchell, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date: _ 8_µg!_)i}( (
/ Judge's signature

City and state: Washington, D.C. Hon. Rudolph Contreras, U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 7 of 35

~Il
AUG 2 o 2018
Clork, U.S. District & Baok1optcy
IN THE UNITED STATES DISTRICT COURT Courts for the blstrlct of Columbia
FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF Case: 1: 18-sc-02671


INFORMATION ASSOCIATED WITH Assigned To : Howell, Beryl A.
ONE CELLULAR TELEPHONE NUMBER Assign. Date : 8/20/2018
THAT IS STORED AT PREMISES Description: Search & Seizure Warrant
CONTROLLED BY AT&T

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Andrew Mitchell, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant under 18

U.S.C. § 2703(d) and Federal Rule of Criminal Procedure 41 for information associated with a

certain cellular telephone assigned call number ("Target Telephone"), which is

stored at premises owned, maintained, controlled or operated by AT&T, a wireless telephone

service provider headquartered in North Palm Beach, Florida. The information to be disclosed by

AT&T and searched by the government is described in the following paragraphs and in

Attachments A and B.

2. I am a Special Agent with the Federal Bureau oflnvestigation (FBI), and have been

since 2011. As a Special Agent of the FBI, I have received training and experience in investigating

criminal and national security matters.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested warrant and does

not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit; there

- 1-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 8 of 35

is probable cause to believe that violations of the following statutes have been committed or are

being committed: 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and abetting), 18 U.S.C.

§ 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18 U.S.C. § 1001 (false

statements), 18 U.S.C. § l 030 (unauthorized access of a protected computer), 18 U.S.C. § 1343

(wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud), and 52 U.S.C.

§ 3012l(a)(l)(C) (foreign expenditure ban). There also is probable cause to search the information

described in Attachment A for evidence of the Subject Offenses, further described in Attachment

B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(1 )(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

6. When the Government obtains records under § 2703 pursuant to a search warrant,

the Government is not required to notify the subscriber or any other person of the warrant, for such

a period as the Court deems appropriate, where there is reason to believe that such notification will

seriously jeopardize an investigation. 18 U.S.C. § 2705(b).

PROBABLE CAUSE

7. The Special Counsel's Office, with FBI's assistance, is investigating the Russian

government's efforts to interfere in the 2016 presidential election, as well as any links and/or

coordination between the Russian government and individuals associated with the campaign of

President Donald Trump ("Trump Campaign"). This includes investigating Roger Stone (STONE)

-2-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 9 of 35

and others known and unknown, in connection with the hacking of email accounts associated with

the Democratic National Committee (DNC), Democratic Congressional Campaign Committee

(DCCC), and individuals involved in the presidential campaign of Hillary Clinton, as well as the

subsequent dissemination of hacked materials via the persona Guccifer 2.0 and the organization

WikiLeaks, among others.

8. This application seeks cell-site location information for the Target Telephone,

used by STONE, between June 14, 2016 and November 15, 2016. As set forth below, this

corresponds to the time period during which there is evidence that STONE was engaged in, and

attempting to engage in, communications, directly or indirectly, with WikiLeaks and its founder

Julian ASSANGE about the content of stolen documents prior to their public release. During this

same time period, STONE was also in communications with members of the Trump Campaign.

A. Background on Relevant Individuals

1. Roger STONE

9. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official relationship

with the Campaign thereafter, STONE maintained his support for Trump and continued to make

media appearances in support of the Campaign. As described further below, STONE also

maintained contact with individuals employed by the Campaign, including then-campaign

chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

10. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According to

-3 -
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 10 of 35

publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter" for

the website "World Net Daily" a/k/a "WNO.com." CORSI has also written a number of books

regarding Democratic presidential candidates. As described further below, CORSI was in contact

with STONE during the summer and fall of 20 I 6 regarding forthcoming disclosures of hacked

information by WikiLeaks, and appears to have obtained information regarding upcoming

disclosures which he relayed to STONE.

B. Russian Government-Backed Hacking Activity During the 2016 Presidential Election

12. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

-4-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 11 of 35

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian Government
developed a clear preference for President-elect Trump.

13. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

14. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks and

maintained that access until at least June 2016." The USIC attributed these cyber activities to the

Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted in the

compromise of the personal e-mail accounts of Democratic Party officials and political figures. By

May, the GRU had exfiltrated large volumes of data from the DNC."

15. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to release

US victim data obtained in cyber operations publicly and in exclusives to media outlets."

16. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

17. The Special Counsel's Office has determined that individuals associated with the

-5-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 12 of 35

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

18. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals used

three new accounts with the same cloud computing service to move the "snapshots" to those

accounts.

19. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

20. On or about November 1, 2016, individuals associated with the GRU spearphished

over 100 accounts used by organizations and personnel involved in administering elections in

numerous Florida counties.

21. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

presidential election, including conspiracy to commit authorized access to protected computers.

See United States v. Viktor Borisovich Netyksho, et al. (Case No. 1:18-cr-00125).

C. Evidence of Google Searches Relating to the Conduct Under Investigation

22. During the course of its investigation, the FBI has identified a series of searches

that appear to relate to the persona Guccifer 2.0, which predate the public unveiling of that persona.

In pa1iicular, on or about June 15, 2016 (prior to the publication of the Guccifer 2.0 WordPress

blog), records from Google show that searches were conducted for the terms "guccifer" and

-6-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 13 of 35

"guccifer j une," from an IP address within the range 107. 77 .216.0/24. 1 This IP range is assigned

to AT&T Mobility LLC, and, according to Google, the searches were all conducted from Florida.

23. IP logs obtained from Twitter show that STONE used multiple IP addresses within

the range 107.77.216.0/24 to log into his Twitter account@RogerJStoneJr.

24. Pursuant to a search warrant issued by Chief Judge Beryl A. Howell on or about

June 13, 2018, the FBI obtained all searches conducted by the CookieIDs that conducted the

Guccifer-related searches described above. 2 Based on these results, the FBI has not yet been able

to attribute the searches to any particular user.

D. STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

25. On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated on

its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part of

the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon." In

that post, Guccifer 2.0 also began releasing hacked DNC documents.

26. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

27. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

1
Google does not retain full IP addresses for searches conducted more than one year ago. The
truncated IP addresses designated here as 107.77.216.0/24 and 17.56.26.0/24 each encompass a
range of up to 256 IP addresses.
2
Google assigns unique CookieIDs to searches conducted while a user is not logged into a Google
account. All searches conducted from the same device and browser during a 24-hour window are
associated with the same CookieID.

-7-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 14 of 35

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

28. · On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

aimed at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With regard

to the October surprise, what would be your forecast on that given what Julian Assange has

intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain to

the Clinton Foundation but there's no telling what the October surprise may be." A few days later,

STONE clarified that while he was not personally in touch with AS SANGE, he had a close friend

who served as an intermediary.

29. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

30. On August 13, 2016, STONE posted a tweet using @RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day, Guccifer

2.0's Twitter account was reinstated.

-8-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 15 of 35

31. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

32. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

33. On August 21, 2016, using @RogerJStoneJR, STONE tweeted: "Trust me, it will

soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same

day, STONE reiterated that because of the work of a '"mutual acquaintance' of both his and

[ASSANGE], the public [could] expect to see much more from the exiled whistleblower in the

form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I believe

that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the Clinton

aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

34. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

35. On Saturday, October 1, 2016, usmg @RogerJStoneJr, STONE tweeted,

"Wednesday@HillaryClinton is done. #WikiLeaks."

36. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement ASSANGE had scheduled for the next day from the balcony

-9-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 16 of 35

of the Ecuadoran Embassy in London. On the day of the AS SAN GE announcement- which was

part of WikiLeaks' 10-year anniversary celebration - STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used@RogerJStoneJr to

tweet: "Payload coming. #Lockthemup."

37. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

38. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"REI,,EASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link to

approximately 2,050 emails that had been hacked from John Podesta's personal email account.

39. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta - referring back to STONE's August 21,

2016 C-SP AN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do. I

do believe he has all of the e-mails that Ruma Abedin and Cheryl Mills, the Clinton aides, thought

were deleted. I hear that through my emissary."

40. On March 27, 2017, CNN reported that a representative ofWikiLeaks, writing from

-10-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 17 of 35

an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

E. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

41. On October 13, 2016, while WikiLeaks was in the midst of releasing the hacked

Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

account @wikileaks. 3 The latter account is the official Twitter account of WikiLeaks and has been

described as such by numerous news reports. The message read: "Sine~ I was all over national

TV, cable and print defending WikiLeaks and assange against the claim that you are Russian agents

and debunking the false charges of sexual assault as trumped up bs you may want to rexamine the

strategy of attacking me- cordially R."

42. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

43. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your operation

leaks like a sieve. You need to figure out who your friends are."

44. On or about November 9, 2016, one day after the presidential election, @wikileaks

3
On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the Twitter
account@RogerJStoneJr.
-11-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 18 of 35

sent a direct message to @RogerJStoneJr containing a single word: "Happy?" @wikileaks

immediately followed up with another message less than a minute later: "We are now more free

to communicate."

45. In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE, the

founder of WikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with ASSANGE in numerous public reports, stating: "Still

nonsense. As a journalist it doesn't matter where you get information only that it is accurate and

authentic. The New York Times printed the Pentagon Papers which were indisputably stolen from

the government and the courts ruled it was legal to do so and refused to issue an order restraining

the paper from publishing additional articles. If the US government moves on you I will bring

down the entire house of cards. With the trumped-up sexual assault charges dropped I don't know

of any crime you need to be pardoned for - best regards. R." That same day, @JulianAssange

responded: "Between CIA and DoJ they're doing quite a lot. On the DoJ side that's coming most

strongly from those obsessed with taking down Trump trying to squeeze us into a deal."

46. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest level

of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in this

forum as experience demonstrates it is monitored. Best regards R."

F. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks

4 7. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, On October 17,

2017, Chief Judge Howell issued a search warrant for one of STONE's addresses,

On or about December 19, 2017, Chief Judge Howell issued a search

-12-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 19 of 35

warrant for email account. On or about March 14, 2018, Chief Judge Howell issued

a search warrant for STONE's iCloud account. Information recovered pursuant to those search

warrants indicated the following:

48. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger Stone

so he knows your availability to meet Manafort and DT this coming week." CORSI appears to

have forwarded the message to STONE at who replied to CORSI that,

"May meet Manafort -guarantee nothing."

49. On or about May 18, 2016, CORSI emailed STONE a

with the title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

50. On July 25, 2016, STONE, using sent an email to CORSI

with the subject line, "Get to Assange." The body of the message read: "Get to Assange [a]t

Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

51. On or about July 31, 2016, STONE, using emailed

CORSI with the subject line, "Call me MON." The body of the email read: should see

Assange[.] should find Bernie [S]anders brother who called Bill a Rapist - tum him for

Trump[.] should find or more proof of Bill getting kicked out."

52. On or about August 2, 2016 (approximately 19 days before STONE publicly

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 20 of 35

tweeted about "Podesta's time m the barrel"), CORSI emailed STONE at

, "Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued, "Signs are Fox will

have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor, for now.

Post-DNC bump for HRC an artifact ofrigged polling. Won't last. I expect presidential campaign

to get serious starting Sept. Still in pre-season games. Time to let more than Podesta to be exposed

as in bed w enemy if they are not ready to drop HRC. That appears to be the game hackers are

now about. Would not hurt to start suggesting HRC old, memory bad, has stroke -- neither he nor

she well. I expect that much of next dump focus, setting stage for Foundation debacle."

Investigators believe that CORSI's reference to a "friend in embassy [who] plans 2 more dumps"

refers to ASSANGE, who resided in Ecuador's London Embassy in 2016.

53. On or about August 4, 2016, an associate of STONE's, emailed

STONE at The email contained a link to a poll indicating that Clinton

led Trnmp by 15 points. STONE responded on or about the same day, "enjoy it while u can[.] I

dined with my new pal Julian Assange last night." subsequently stated to investigators

that, around the same time, STONE told him he had gone to London to meet ASSANGE.

also stated that in 2018, told STONE he would be interviewed by the FBI

and would have to divulge the conversation about meeting ASSANGE. STONE told

he was joking and had not actually met AS SAN GE. 4

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 21 of 35

54. Through a search of STONE's iCloud account, the FBI has uncovered evidence

suggesting that STONE was in Los Angeles for one or more meetings at the time that he claimed,

in his email to to have "dined" with ASSANGE. For example, an associate of

STONE sent a text to STONE at approximately 3:38PM on August 2, asking "How did ur meeting

go in LA?" STONE responded. "It's this afternoon[.]" The following day, the associate asked,

"Any report from ur meeting?" On or about August 4, 2016, STONE texted the associate, "Will

call later - heading for airport now[.]" Additionally, investigators have identified a photograph in

STONE's iCloud that appears to have been taken on August 3, 2016 and had geo-Iocation

information indicating that it was taken in Los Angeles.

55. On or about August 15, 2016, CORSI emailed STONE at

"Give me a call today if you can. Despite MSM drumroll that HRC is already elected, it's not over

yet. More to come than anyone realizes. Won't really get started until after Labor Day. I'm in NYC

this week. Jerry."

56. On or about August 31, 2016, CORSI emailed STONE at

"Did you get the PODESTA writeup." STONE replied "[y]es."

57. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Yanukovych - Panama papers reveals Podesta hired by S [bJerbank,

Russia's largest financial institution-Podesta$$$ ties to Russia undermine Clinton false narrative

attempting to tie Trump to Putin."

58. On or about September 6, 2016, CORSI emailed STONE at

: "Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

59. On or about September 24, 2016, emailed CORSI, "I will have much

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 22 of 35

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have secure

back channel through Roger. I saw him again in NYC last Friday and spoke to him about it again

today." wrote back, "Awaiting secret file. Explosive ... Hope you are well. Can't wait

for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted about file[.]"

In a subsequent meeting with investigators, indicated this conversation concerned

possible derogatory information he was trying to obtain from Turkey.

60. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange - what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve BANNON,

who was CEO of the Campaign at the time, and wrote: "You should call Roger. See below. You

didn't get from me." BANNON wrote back, "I've got important stuff to worry about." The

associate responded, "Well clearly he knows what Assange has. I'd say that's important."

61. On or about October 4, 2016, AS SANGE gave a press conference at the Ecuadorian

Embassy. There had been speculation in the press leading up to that event that ASSANGE would

release information damaging to then-candidate Clinton, but WikiLeaks did not make any new

releases. Instead, ASSANGE promised more documents, including information "affecting three

powerful organizations in three different states, as well as, of course, information previously

referred to about the U.S. election process." ASSANGE also stated that WikiLeaks would publish

documents on various subjects every week for the next ten weeks, and vowed that the U.S.

election-related documents would all come out before Election Day.

62. On or about October 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 23 of 35

63. That same day, BANNON emailed STONE at "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't cut

deal w/ clintons???" STONE replied, "Don't think so BUT his lawyer is a big democrat."

64. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE was

about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking STONE

about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and BANNON

had been hoping for releases of damaging information that morning.

G. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released

65. According to a publicly available news article, 5 at approximately 11AM on Friday,

October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from a source

regarding a previously unaired video of candidate Trump. According to the same article,

"Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage from a 2005

segment on 'Access Hollywood,' the Washington Post reporter was on the phone, calling Trump's

campaign, 'Access Hollywood,' and NBC for reaction."

66. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

67. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

5
https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-Iev.:d-tape-of-donald-trump-
then-the-race-was-on/2016/10/07 /31d74 714-8ce5-11e6-875e-2c 1bfe943 b66_story.html

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 24 of 35

68. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

69. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

70. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

71. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails hacked

from John Podesta that focused primarily on materials related to the Clinton Foundation. On or

about August 2, 2016, CORSI emailed STONE using "I expect that

much of next dump focus, setting stage for Foundation debacle."

72. At approximately 6:27PM, an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks - The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using

forwarded message to CORSI without comment. STONE does

not appear to have forwarded the email to any other individual.

H. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

73. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed-have

to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty minutes

later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T attacking

Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job numbers."

74. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

using emailed Corsi asking him to "send me your best podesta links."

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 25 of 35

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on Podesta

is complicated. Two articles in length. I can give you in raw form the stuff I got in Russian

translated but to write it up so it's easy to understand will take weekend. Your choice?"

75. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3 :25PM EDT, CORSI

emailed STONE at both , with the subject line

"Podesta talking points." Attached to the email was a file labeled, "ROGER STONE podesta

talking points Oct 12 2016.docx." The "talking points" included the statement that "Podesta is at

the heart of a Russian-government money laundering operation that benefits financially Podesta

personally and the Clintons through the Clinton Foundation."

76. CORSI followed up several minutes later with another email titled, "Podesta talking

points," with the text "sent a second time just to be sure you got it." STONE emailed CORSI back

via the Hotmail Account, "Got them and used them."

77. On or about Thursday, October 13, 2016, CORSI emailed STONE at

"PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could post

under my by-line since I am the one under attack by Podesta and now Mook." CORSI wrote back

to STONE, "I'll give you one more - NOBODY YET HAS THIS[:] It looks to me like

skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once had

the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's Clinton

Fund account, there's no telling how much money he laundered, or where it ended up. Nothing in

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 26 of 35

Clinton Foundation audited financials or IRS Form 990s about $$$ received via Russia &

Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me SOMETHING to

post on Podesta since I have now promised it to a dozen MSM reporters[.]"

78. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own name."

That same day, STONE posted a blog post with the title, "Russian Mafia money laundering, the

Clinton Foundation and John Podesta." In that post, STONE wrote, "although I have had some

back-channel communications with Wikileaks I had no advance notice about the hacking of Mr.

Podesta nor I have I ever received documents or data from Wikileaks." The post then asked, "Just

how much money did a controversial Russian billionaire investor with ties to

the Vladimir Putin and the Russian government, launder through Metcombank, a Russian regional

bank owned 99.978 percent by with the money transferred via Deutsche Bank and

Trust Company Americas in New York City, with the money ending up in a private bank account

in the Bank of America that is operated by the Clinton Foundation?"

79. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's basically

a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

80. On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now - before 2pm[.]" STONE responded, "Missed u - just landed

JFK - on Infowars now." CORSI wrote back, "Call afterwards. Have some important intel to

share."

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 27 of 35

81. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd: ASSANGE ... URGENT ... " CORSI wrote,

"From a very trusted source," and forwarded an email with the header information stripped out,

showing only the body text. The email read, "Yes[.] I figured this. Assange is threatening Kerry,

Ecuador and U.K. He will drop the goods on them if they move to extradite him. My guess is that

he has a set of dead man files that include Hillary. It's what they used to call a 'Mexican stand

off[.]' Only hope is that if Trump speaks out to save him[.] Otherwise he's dead anyway, once he's

dropped what he has. If HRC wins, Assange can kiss his life away. Interesting gambit Assange

has to play out. He's called Podesta's bluff and raised him the election."

82. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

83. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice ofWikileaks' hacking of Podesta's e-mails." STONE

stated that, "I predicted that Podesta's business dealings would be exposed. I didn't hear it from

Wikileaks, although Julian Assange and I share a common friend. I reported the story on my

website." STONE linked to the story he had asked CORSI to write for him on October 13, 2016

discussed above.

84. On or about November 8, 2016, the United States presidential election took place.

85. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

86. On or about November 10, 2016, CORSI messaged STONE at his iCloud account,

"Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in London.

Have some interesting news for you."

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 28 of 35

I. The Target Telephone

87. Search warrant returns for STONE's Hotmail account,

show that on numerous occasions, including in 2016, STONE provided the Target Telephone

Number to individuals as his cellular telephone number and/or the way to reach him. On or about

August 17, 2017, AT&T, indicated that the "user" of the

Target Telephone Number is "Roger J. Stone." Publicly available databases indicate the Target

Telephone Number is currently assigned to AT&T wireless and registered to Drake Ventures, a

company investigators have linked to STONE.

88. There is evidence that STONE used the Target Phone in connection with the

conduct under investigation. For example, according to records

a) STONE called CORSI on or about July 25, 2016 from the Target Phone, and spoke

with him for approximately twenty-six minutes. Less than roughly two hours after that call,

STONE emailed CORSI, "Get to Assange [a]t the Ecuadorian Embassy in London and get the

pending wikileaks emails .... "

b) On or about July 30, 2016--one day before STONE instructed CORSI to have

contact ASSANGE-Manafort, who was then-Chairman of the Trump Campaign,

called STONE on the Target Phone Number. The two spoke for approximately sixty-seven

minutes.

c) On or about October 7, 2016, on the day of the Access Hollywood video disclosure,

STONE received a call from the Washington Post at the Target Phone Number, and shortly

thereafter, STONE had two conversations with CORSI from the Target Phone Number.

89. As set forth in Attachment B, this application seeks cell-site location information

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 29 of 35

for the Target Telephone between Ju ne 14. 201 6-the day before a Google search was conducted

for several Guccifer-related terms from a Florida IP address, followed by Guccifer 2.0's first public

appearance-and November 15, 2016- one week after the 2016 presidential election and less than

one week after CORSI messaged STONE about having "interesting news" for him. Given

STONE's repeated communications with and/or about the WikiLeaks releases during this time,

including discussions about the content of the documents prior to their release, there is probable

cause to believe that STONE's whereabouts during this time period will yield evidence of the

Subject Offenses under investigation. Location information for the Target Phone will assist

investigators in determining, among other things: whether STONE was in Florida at the time of

the Guccifer-related searches; whether STONE met with members of the Trump Campaign at or

around any of the events or communications discussed above; and where STONE was on the night

he claimed he "dined" with ASSANGE. 6 Location information will also assist investigators in

identifying meetings between STONE and any intermediaries to WikiLeaks and/or other potential

co-conspirators during this time period.

BACKGROUND CONCERNING AT&T

90. In my training and experience, I have learned that AT&T is a company that provides

cellular telephone access to the general public. I also know that providers of cellular telephone

service have technical capabilities that allow them to collect and generate information about the

locations of the cellular telephones to which they provide service, including cell-site data, also

6
As noted above, investigators believe that STONE was in Los Angeles at the time he claimed to
have met AS SANGE, but the FBI is investigating whether STONE may have met an intermediary
instead, or otherwise made contact with WikiLeaks. As explained below, the precision of cell-site
location information varies depending on the distance between towers (among other things).
Given the density of Los Angeles, I believe that cell-site location data for STONE's trip there
would assist investigators in determining, among other things, whether STONE was present at the
locations he has publicly claimed to have been.

-23-
Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 30 of 35

known as "tower/face information" or "cell tower/sector records." Cell-site data identifies the

"cell towers" (i.e., antenna towers covering specific geographic areas) that received a radio signal

from the cellular telephone and, in some cases, the "sector" (i.e., faces of the towers) to which the

telephone connected. These towers are often a half-mile or more apart, even in urban areas, and

can be 10 or more miles apart in rural areas. Furthennore, the tower closest to a wireless device

does not necessarily serve every call made to or from that device. Accordingly, cell-site data

provides an approximate location of the cellular telephone but is typically less precise than other

types of location information, such as E-911 Phase II data or Global Positioning Device ("GPS")

data.

91. Based on my training and experience, I know that AT&T can collect cell-site data

about the Target Telephone. Cell-site location data is typically generated only when the phone

is used to engage in communications. I also know that wireless providers such as AT&T typically

collect and retain cell-site data pertaining to cellular phones to which they provide service in their

normal course of business in order to use this information for various business-related purposes.

92. Based on my training and experience, I know that wireless providers such as

AT&T typically collect and retain information about their subscribers in their normal course of

business. This information can include basic personal information about the subscriber, such as

name and address, and the method(s) of payment (such as credit card account number) provided

by the subscriber to pay for wireless telephone service. I also know that wireless providers such

as AT&T typically collect and retain information about their subscribers' use of the wireless

service, such as records about calls or other communications sent or received by a particular

phone and other transactional records, in their normal course of business. In my training and

experience, this information may constitute evidence of the crimes under investigation because

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 31 of 35

the information can be used to identify the Target Telephone user or users and may assist in the

identification of co-conspirators and/or victims

FILTER REVIEW PROCEDURES

93. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

with professional responsibility requirements concerning the maintenance of attorney-client and

other operative privileges. The procedures include use, if necessary, of a designated "filter team,"

separate and apart from the investigative team, in order to address potential privileges. The

government, however, does not at this time anticipate that any of the items described in

Attachment A will contain materials requiring review by a designated filter team.

CONCLUSION

94. Based on the forgoing, I request that the Court issue the proposed search warrant.

95. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 32 of 35

REQUEST FOR SEALING

96. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

c:::::~
Andrew Mitchell
Special Agent
Federal Bureau of Investigation

Subscribed and sworn to before me on this .Jfl day of August, 2018.

The Honor ble Rudolph Contreras


United States District Judge

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 33 of 35

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the cellular telephone assigned call

number ("the Account"), that is stores at premises controlled by AT&T ("the

Provider"), headquartered at 11760 US Highway 1, North Palm Beach, Florida.

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 34 of 35

ATTACHMENT B

I. Information to be disclosed by Provider

To the extent that the information described in Attachment A is within the possession,

custody, or control of the Provider, including any information that has been deleted but is still

available to the Provider or that has been preserved pursuant to a request made under 18 U.S.C.

§ 2703(f), the Provider is required to disclose to the government the following information

pertaining to the Account listed in Attachment A for the time period June 14, 2016 through

November 15, 2016:

a. The following information about the customers or subscribers of the Account:

i. Names (including subscriber names, user names, and screen names);

11. Addresses (including mailing addresses, residential addresses, business


addresses, and e-mail addresses);

Ill. Local and long distance telephone connection records;

1v. Records of session times and durations, and the temporarily assigned
network addresses (such as Internet Protocol ("IP") addresses) associated
with those sessions;

v. Length of service (including start date) and types of service utilized;

vi. Telephone or instrument numbers (including MAC addresses, Electronic


Serial Numbers ("ESN"), Mobile Electronic Identity Numbers ("MEIN"),
Mobile Equipment Identifier ("MEID"); Mobile Identification Number
("MIN"), Subscriber Identity Modules ("SIM"), Mobile Subscriber
Integrated Services Digital Network Number ("MSISDN"); International
Mobile Subscriber Identity Identifiers ("IMSI"), or International Mobile
Equipment Identities ("IMEi");

vii. Other subscriber numbers or identities (including the registration Internet


Protocol ("IP") address); and

vu1. Means and source of payment for such service (including any credit card
or bank account number) and billing records.

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Case 1:19-mc-00029-CRC Document 29-18 Filed 04/28/20 Page 35 of 35

b. All records and other information (not including the contents of communications)

relating to wire and electronic communications sent or received by the Account,

including:

1. the date and time of the communication, the method of the

communication, and the source and destination of the communication

(such as the source and destination telephone numbers (call detail

records), email addresses, and IP addresses); and

11. information regarding the cell tower and antenna face (also known as

"sectors") through which the communications were sent and received.

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A which

consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and abetting),

18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18 U.S.C. § 371

(conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a

protected computer); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to

commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the period from June

14, 2016 to November 15, 2016.

-3-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 1 of 56
AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1: 18-sc-02727
or identify the person by name and address) ) Assigned To : Chief Judge Beryl A. Howell
INFORMATION ASSOCIATED WITH ONE ACCOUNT ) Assign. Date : 8/28/2018
STORED AT PREMISES ) Description: Search and Seizure Warrant
CONTROLLED BY FACEBOOK )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before September 11, 2018 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to 10:00 p.m. D at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. James E. Boasberg, U.S. District Judge
(United States Magistrate Judge)

D Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box).
D for days (not to exceed 30) D until, the facts justifying, the later specific date of

Date and time issued: r ~


f'-"''-',""'""'"--
_ _,'3'--'/'----'-v=-f~ft._Cj,c__---''3"---',

City and state: _W_a_s_hi_n_..g_to_n_:_,_D_C_ _ _ _ _ _ __ Hon. J . Boasberg, U.S. District Judge


Printed name and title
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 2 of 56
AO 93 (Rev. l l/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 3 of 56

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the Facebook accounts registered to

the following email addresses, stored at premises owned, maintained, controlled, or operated by

Facebook, Inc. ("Facebook"), a company headquartered in Menlo Park, California:

-1-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 4 of 56

ATTACHMENT B

I. Information to be disclosed by Facebook

To the extent that the information described in Attachment A is within the possession,

custody, or control of Facebook, Inc. ("Facebook"), including any messages, records, files, logs,

or information that have been deleted but are still available to Facebook, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(f), Facebook is required to disclose the

following information to the government for each account listed in Attachment A:

(a) All contact and personal identifying information, including full name, user

identification number, birth date, gender, contact e-mail addresses, physical address

(including city, state, and zip code), telephone numbers, screen names, websites,

and other personal identifiers.

(b) All activity logs for the account and all other documents showing the user's posts

and other Facebook activities;

(c) All photos and videos uploaded by that user ID and all photos and videos uploaded

by any user that have that user tagged in them, including Exchangeable Image File

("EXIF") data and any other metadata associated with those photos and videos;

(d) All profile information; News Feed information; status updates; videos,

photographs, rn:ticles, and other items; Notes; Wall postings; friend lists, including

the friends' Facebook user identification numbers; groups and networks of which

the user is a member, including the groups' Facebook group identification numbers;

future and past event postings; rejected "Friend" requests; comments; gifts; pokes;

tags; and information about the user's access and use ofFacebook applications;

-2-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 5 of 56

(e) All other records of communications and messages made or received by the user,

including all private messages, chat history, video calling history, and pending

"Friend" requests;

(f) All records relating to machine cookies;

(g) All "check ins" and other location information, including records of the user's

latitude and longitude;

(h) All IP logs, including all records of the IP addresses that logged into the account;

(i) All records of the account's usage of the "Like" feature, including all Facebook

posts and all non-Facebook webpages and content that the user has "liked";

(j) All information about the Facebook pages that the account is or was a "fan" of;

(k) All past and present lists of friends created by the account;

(1) All records ofFacebook searches performed by the account;

(m) All information about the user's access and use ofFacebook Marketplace;

(n) The types of service utilized by the user;

(o) The length of service (including start date) and the means and source of any

payments associated with the service (including any credit card or bank account

number);

(p) Group identification numbers; a list of users currently registered to the group; a list

of users who like the page; group or page contact information, including all contact

information for the creator and/or administrator of the group and a PDF of the

current status of the group profile page;

(q) All past and present Admins for the group;

(r) The "Creator" of the group;

-3-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 6 of 56

(s) All privacy settings and other account settings, including privacy settings for

individual Facebook posts and activities, and all records showing which Facebook

users have been blocked by the account;

(t) All records pertaining to connnunications between Facebook and any person

regarding the user or the user's Facebook account, including contacts with support

services and records of actions taken;

(u) All records related to advertisements and advertising conducted through the

accounts, including advertisements purchased, advertising parameters (search

terms, groups, geographic areas) selected and queried.

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to connnit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June 1, 2015 to the present, including:

a. All records, information, documents or tangible materials that relate in any way to

connnunications regarding hacking, release of hacked material, connnunications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or connnunications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

-4-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 7 of 56

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, or any

individual associated with the Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

-5-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 8 of 56

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

' 1. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 9 of 56

AUG 2 B 2018
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA Clerk, U.S. Disirict & Bankruptoy
Courts. tor the District of Ga!mnhia

IN THE MATTER OF THE SEARCH OF Case: 1:18-sc-02727


Assigned To : Chief Judge Beryl A. Howell
INFORMATION ASSOCIATED WITH ONE
ACCOUNT STORED AT PREMISES Assign. Date: 8/28/2018
Description: Search and Seizure Warrant
. CONTROLLED BY FACEBOOK

ORDER

The United States has filed a motion to seal the above-captioned warrant and related

documents, including the application and affidavit in support thereof (collectively the "Warrant"),

and to require Facebook, Inc. ("Facebook"), an electronic communication and/or remote

computing services provider headquartered in Menlo Park, California, not to disclose the existence

or contents of the Warrant pursuant to 18 U.S.C .. § 2705(b).

The Court finds that the United States has established that a compelling governmental

interest exists to justify the requested sealing, and that there is reason to believe that notification

of the existence of the Warrant will seriously jeopardize the investigation, including by giving the

targets an opportunity to flee from prosecution, destroy or tamper with evidence, and intimidate

witnesses. See 18 U.S.C. § 2705(b)(2)-(5).

IT IS THEREFORE ORDERED that the motion is hereby GRANTED, and that the

warrant, the application and affidavit in support thereof, all attachments thereto and other related

materials, the instant motion to seal, and this Order be SEALED until further order of the Court;

and
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 10 of 56

IT IS FURTHER ORDERED that, pursuant to 18 U.S.C. § 2705(b), Facebook and its

employees shall not disclose the existence or content of the Warrant to any other person (except

attorneys for Facebook for the purpose of receiving legal advice) for a period of one year or until

further order of the Court.

ES E. BOASBERG
ISTRICT JUDGE

1/k~~
Date

2
Case
AO 106 (Rev. 04/10) 1:19-mc-00029-CRC
Application for a Search Warrant Document 29-19 Filed 04/28/20 Page 11 of 56

UNITED STATES DISTRICT COURT


AUG 2 8 2018
for the
District of Columbia Clerk, U.S. Districi &, B~nkruptoy
Courts for the District ot Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched )
Case: 1:18-sc-02727
or identify the person by name and address) ) Assigned To : Chief Judge Beryl A. Howell
INFORMATION ASSOCIATED WITH Assign. Date: 8/28/2018
ONE ACCOUNT STORED AT PREMISES CONTROLLED )l Description: Search and Seizure Warrant
BYFACEBOOK

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A
located in the Northern District of ----~
California ----
, there is now concealed (identify the
person or describe the property to be seized):
See Attachment B

The basis for the search under Fed. R. Crim. P. 4I(c) is (check one or more}:
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
~ property designed for use, intended for use, or used in committing a crime;
D a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section Offense Description
52 U.S.C. § 30121 Foreign Contribution Ban
18 u.s.c. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

r/ Continued on the attached sheet.


D Delayed notice of days (give exact ending date if more than 30 days: ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA:
4~urA{,t!,,u.__ Applicant's signature

!Kyle R. Freeny (ASC) Curtis Heide, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date: 1/1--f/;t
City and state: Washington, D.C. Hon. J
Printed name and title
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 12 of 56

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF Case: 1: 18-sc-02727


INFORMATION ASSOCIATED WITH ONE Assigned To : Chief Judge Beryl A. Howell
ACCOUNT STORED AT PREMISES Assign. Date: 8/28/2018
CONTROLLED BY F ACEBOOK Description: Search and Seizure Warrant

MOTION TO SEAL WARRANT AND RELATED DOCUMENTS AND


TO REQUIRE NON-DISCLOSURE UNDER 18 U.S.C. § 2705(b)

The United States of America, moving by and through its undersigned counsel, respectfully

moves the Court for an Order placing the above-captioned warrant and the application and affidavit

in support thereof ( collectively herein the "Warrant") under seal, and precluding the provider from

notifying any person of the Warrant pursuant to 18 U.S.C. § 2705(b). In regard to the non-

disclosure, the proposed Order would direct Facebook, Inc. ("Facebook"), an electronic

communication and/or remote computing services provider headquartered in Menlo Park,

California, not to notify any other person (except attorneys for Facebook for the purpose of

receiving legal advice) of the existence or content of the Warrant for a period of one year or until

further order of the Court.

JURISDICTION AND LEGAL BACKGROUND

1. The Court has the inherent power to seal court filings when appropriate,

including the Warrant. United States v. Hubbard, 650 F.2d 293, 315-16 (D.C. Cir. 1980) (citing

Nixon v. Warner Communications, Inc., 435 U.S. 589, 598 (1978)). The Court may also seal the

Warrant to prevent serious jeopardy to an ongoing criminal investigation when, as in the present

case, such jeopardy creates a compelling governmental interest in preserving the confidentiality of

the Warrant. See Washington Postv. Robinson, 935 F.2d 282, 287-89 (D.C. Cir. 1991).

2. In addition, this Court has jurisdiction to issue the requested order because it is "a

court of competent jurisdiction" as defined by 18 U.S.C. § 2711. Specifically, the Court is a


Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 13 of 56

(1) endangering the life or physical safety of an individual;


(2) flight from prosecution;
(3) destruction of or tampering with evidence;
(4) intimidation of potential witnesses; or
(5) otherwise seriously jeopardizing an investigation or unduly delaying a trial.

18 U.S.C. § 2705(b). The United States District Court for the District of Columbia has made clear

that a nondisclosure order under Section 2705(b) must be issued once the Government makes the

requisite showing about potential consequences of notification:

The explicit terms of section 2705(b) make clear that if a courts [sic] finds that there
is reason to believe that notifying the customer or subscriber of the court order or
subpoena may lead to one of the deleterious outcomes listed under § 2705(b), the
court must enter an order commanding a service provider to delay notice to a
customer for a period of time that the court determines is appropriate. Once the
government makes the required showing under § 2705(b), the court is required to
issue the non-disclosure order.

In re Application for Order of Nondisclosure Pursuant to 18 U.S.C. § 2705(b) for Grand Jury

Subpoena #GJ2014031422765, 41 F. Supp. 3d 1, 5 (D.D.C. 2014).

5. Accordingly, this motion to seal sets forth facts showing reasonable grounds to

command Facebook not to notify any other person (except attorneys for Facebook for the purpose

of receiving legal advice) of the existence of the Subpoena for a period of one year or until further

order of the Court.

FACTS SUPPORTING SEALING AND NON-DISCLOSURE

6. The Federal Bureau oflnvestigation ("FBI") is investigating violations of 18 U.S.C.

§ 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a

felony), 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 951 (acting as an unregistered foreign agent),

18 U.S.C. § 1030 (unauthorized access of a protected computer); 18 U.S.C. § 1343 (wire fraud),

18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud), and 22 U.S.C. § 611 et seq.

(Foreign Agents Registration Act), and 52 U.S.C. § 30121 (foreign contribution ban) (the "Subject

Offenses"), in connection with efforts to compromise the networks of the Democratic National

3
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 14 of 56

to flee from prosecution, destroy or tamper with evidence, and intimidate witnesses. See 18 U.S. C.

§ 2705(b)(2)-(5). Because of such potential jeopardy to the investigation, there also exists a

compelling governmental interest in confidentiality to justify the government's sealing request.

See Robinson, 935 F.2d at 287-89.

10. Based on prior dealings with Facebook, the United States is aware that, absent a

court order under Section 2705(b) commanding Facebook not to notify anyone about a legal

request, Facebook may, upon receipt of a warrant seeking the contents of electronically stored wire

or electronic communications for a certain account, notify the subscriber or customer of the

existence of the warrant prior to producing the material sought.

WHEREFORE, for all the foregoing reasons, the government respectfully requests that the

above-captioned warrant, the application and affidavit in support thereof, and all attachments

thereto and other related materials be placed under seal, and furthermore, that the Court command

Facebook not to notify any other person of the existence or contents of the above-captioned warrant

(except attorneys for Facebook for the purpose of receiving legal advice) for a period of one year

or until further order of the Court.

Respectfully submitted,

ROBERT S. MUELLER, III


Special C o u n u

Dated: -~6c.,/~2==1?!~/~t---ef_,_2~ By:

5
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 15 of 56
FILED
AUG 2 8 2018
IN THE UNITED STATES DISTRICT COURT Clerk, U.S. District & Bankruptcy
FOR THE DISTRICT OF COLUMBIA Courts for the District of Columbia

IN THE MATTER OF THE SEARCH OF Case: 1:18-sc-02727


INFORMATION ASSOCIATED WITH Assigned To : Chief Judge Beryl A. Howell
ONE ACCOUNT STORED AT PREMISES Assign. Date : 8/28/2018
CONTROLLED BY FACEBOOK Description: Search and Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Curtis Heide, beingfirst duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the Facebook account registered to

("Target Account"), stored at premises owned, maintained, controlled or operated by Facebook,

Inc. ("Facebook"), a company headquartered in Menlo Park, California. The information to be

disclosed by Facebook and searched by the government is described in the following paragraphs

and in Attachments A and B.

2. I have been a Special Agent with the Federal Bureau of investigation for 12 years.

In the course of my duties, I have been responsible for investigating federal crimes and national

security matters involving both counterintelligence and issues related to cybersecurity.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Account contain evidence, fruits, or

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

-1-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 16 of 56

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision ofa felony), 18

U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a protected

computer), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud), 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C. § 1513 (witness

tampering), and 52 U.S.C. § 30121(a)(l)(C) (foreign expenditure ban). There also is probable

cause to search the information described in Attachment A for evidence, contraband, fruits,

and/or instrumentalities of the Subject Offenses, further described in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(1 )(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

PROBABLE CAUSE

A. Background on Relevant Individuals

i. Roger STONE

6. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

-2-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 17 of 56

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

7. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WNO.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

-3-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 18 of 56

B. Russian Government-Backed Hacking Activity During the 2016 Presidential


Election

9. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Government developed a clear preference for President-elect Trump.

10. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls.'"

11. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities

to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

-4-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 19 of 56

12. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

13. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

14. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

15. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

16. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

17. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

18. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

-5-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 20 of 56

presidential election, including conspiracy to connnit authorized access to protected computers.

See United States v. Viktor Borisovich Netyksho, et al. (Case No. 1:18-cr-00125).

C. STONE's ~.ublic Interactions with Guccifer 2.0 and WikiLeaks

19. On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

20. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.

21. On August 5, 2016, STONE published an article on Breitbart.com entftled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

22. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

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aimed at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With

regard to the October surprise, what would be your forecast on that given what Julian Assange

has intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain

to the Clinton Foundation but there's no telling what the October surprise may be." A few days

later, STONE clarified that while he was not personally in touch with AS SAN GE, he had a close

friend who served as an intermediary.

23. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

24. On August 13, 2016, STONE posted a tweet using@RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

25. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me ifl can help u anyhow. it would be a great pleasure to me."

26. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

27. On August 21, 2016, using @RogerJStoneJR, STONE tweeted: "Trust me, it will

soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same

day, STONE reiterated that because of the work of a "'mutual acquaintance' of both his and

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[ASSANGE], the public [could] expect to see much more from the exiled whistleblower in the

form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

28. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

29. On Saturday, October 1, 2016, using@RogerJStoneJr, STONE tweeted,

"Wednesday @ HillaryClinton is done. #WikiLeaks."

30. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement ASSANGE had scheduled for the next day from the balcony

of the Ecuadoran Embassy in London. On the day of the ASSANGE announcement-which was

part ofWikiLeaks' IO-year anniversary celebration - STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used@RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

31. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

32. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #imWithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

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33. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta- referring back to STONE's August 21,

2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

34. On March 27, 2017, CNN reported that a representative ofWikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

35. On October 13, 2016, while WikiLeaks was in the midst of releasing the hacked

Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

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account @wikileaks. l The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

to rexamine the strategy of attacking me- cordially R."

36. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

37. On or about October 15, 2016,@RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

38. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

39. In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE,

the founder ofWikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with ASSANGE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the govermnent and the courts ruled it was legal to do so and refused to

1On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
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issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

40. On Saturday, June 10, 2017,@RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks

41. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, On October

17, 2017, Chief Judge Howell issued a search warrant for one ofSTONE's addresses,

On or about December 19, 2017, Chief Judge Howell issued a search

warrant for mail account. On or about March 14, 2018, Chief Judge Howell

issued a search warrant for STONE's iCloud account. Information recovered pursuant to those

search warrants indicated the following:

42. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger

Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

appears to have forwarded the message to STONE at who replied to

CORSI that, "May meet Manafort -guarantee nothing."

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43. On or about May 18, 2016, CORSI emailed STONE at

with the title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

44. On July 25, 2016, STONE, using sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

45. On or about July 31, 2016, STONE, using emailed

CORSI with the subject line, "Call me MON." The body of the email read: " should see

Assange[.] should find Bernie [SJ anders brother who called Bill a Rapist~ turn him for

Trump[.] should find or more proof of Bill getting kicked out."

46. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at

"Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued, "Signs are Fox

will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HRC an artifact ofrigged polling. Won't last. I expect presidential

campaign to get serious starting Sept. Still in pre-season games. Time to let more than Podesta to

be exposed as in bed w enemy if they are not ready to drop HRC. That appears to be the game

hackers are now about. Would not hurt to start suggesting HRC old, memory bad, has stroke --

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neither he nor she well. I expect that much of next dump focus, setting stage for Foundation

debacle." Investigators believe that CORSI's reference to a "friend in embassy [who] plans 2

more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in 2016.

47. On or about August 5, 2016, an associate of STONE's, emailed

STONE at The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet ASSANGE. also stated

that in 2018, told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SAN GE. STONE told he was joking and

had not actually met ASSANGE. 2

48. Through a search of STONE's iCloud account, the FBI has uncovered evidence

suggesting that STONE was in Los Angeles for one or more meetings at the time that he claimed,

in his email to to have "dined" with ASSANGE. For example, an associate of

STONE sent a text to STONE at approximately 3:38PM on August 2, asking "How did ur meeting

go in LA?" STONE responded. "It's this afternoon[.]" The following day, the associate asked,

"Any report from ur meeting?" On or about August 4, 2016, STONE texted the associate, "Will

call later -heading for airport now[.]" Additionally, investigators have identified a photograph in

STONE's iCloud that appears to have been taken on August 3, 2016 and had geo-location

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information indicating that it was taken in Los Angeles.

49. On or about August 15, 2016, CORSI emailed STONE at

"Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

50. On or about August 31, 2016, CORSI emailed STONE at

"Did you get the PODESTA writeup." STONE replied "[y]es."

51. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Yanukovych - Panama papers reveals Podesta hired by

S [b]erbank, Russia's largest financial institution - Podesta $$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

52. On or about September 6, 2016, CORSI emailed STONE at

"Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

53. On or about September 24, 2016, emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have

secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today." wrote back, "Awaiting secret file. Explosive ... Hope you are well.

Can't wait for the debate. Channeling Reagan; I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators, indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

54. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange - what's he got? Hope it's good." STONE wrote

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back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON, who was CEO of the Campaign at the time, and wrote: "You should call Roger. See

below. You didn't get from me." BANNON wrote back, "I've got important stuff to worry

about." The associate responded, "Well clearly he knows what Assange has. I'd say that's

important."

55. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

AS SAN GE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

56. On or about October 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

57. That same day, BANNON emailed STONE at "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawyer is a big

democrat."

58. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

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was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to AS SAN GE, and

BANNON had been hoping for releases of damaging information that morning.

F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

59. According to a publicly available news article, 3 at approximately I !AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."

60. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

61. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

62. At approximately I :42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

63. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

64. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywoodtape.

3 https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07/31d74714-8ce5- l l e6-875e-2c 1bfe943b66_story.html

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65. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE using "I expect

that much of hext dump focus, setting stage for Foundation debacle."

66. At approximately 6:27PM, an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks - The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using

forwarded message to CORSI without comment. STONE

does not appear to have forwarded the email to any other individual.

G. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

67. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed-

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job

numbers."

68. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

using emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

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69. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at both with the subject

line "Podesta talking points." Attached to the email was a file labeled, "ROGER STONE

podesta talking points Oct 12 2016.docx." The "talking points" included the statement that

"Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation."

70. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Hotmail Account, "Got them and used them."

71. On or about Thursday, October 13, 2016, CORSI emailed STONE at

"PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I'll give you one more-NOBODY YET HAS THIS[:] It looks to me

like skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

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72. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

have had some back-channel communications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money did a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through

Metcombank, a Russian regional bank owned 99.978 percent by with the money

transferred via Deutsche Bankand Trust Company Americas in New York City, with the money

ending up in a private bank account in the Bank of America that is operated by the Clinton

Foundation?"

73. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

74. On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now - before 2pm[.]" STONE responded, "Missed u - just

landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

75. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

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AS SANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand off[.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. IfHRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election."

76. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

77. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice of Wikileaks' hacking of Podesta' s e-mails."

STONE stated that, "I predicted that Podesta's business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

78. On or about November 8, 2016, the United States presidential election took place.

79. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

80. On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in

London. Have some interesting news for you."

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I. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikileaks

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88. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCI). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic assertions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta' s email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such assertions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trust me, it will soon be the Podesta's
time in the barrel. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but
does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrutiny....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.
I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
Assange to independently confirm this report, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
information proved to be correct. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

89. In a document dated March 26, 2018 titled "Minority Views," Democratic

members ofHPSCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with Julian Assange?
MR. STONE: No.

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Q: So throughout the many months in which you represented you were either in
communication with Assange or communication through an intermediary with Assange,
you were only referring to a single fact that you had confirmed with the intermediary -
MR. STONE: That -
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is correct, even though it was repeated to me on numerous separate
occasions.

90. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an article on his website, stonecoldtruth.com, titled "ls it the Podesta's

Time in the Barrel Yet?" In that article, STONE stated: "[l]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of Jolm

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

J. STONE's Messaging to Randy CREDICO about STONE's "Back channel"

91. On or about November 19, 2017, Randy CREDICO (who, as described further

below, STONE publicly identified as his "intermediary" to ASSANGE), messaged STONE, "My

lawyer wants to see me today." STONE responded, "'Stonewall it. Plead the fifth. Anything to

save the plan' ........ Richard Nixon[.]" CREDICO responded, "Ha ha."

92. On or about November 21, 2017, CREDICO messaged STONE, "I was told that

the house committee lawyer told my lawyer that I will be getting a subpoena[.]" STONE wrote

back, "That was the point at which your lawyers should have told them you would assert your

5th Amendment rights if compelled to appear." They continued to message, and CREDICO

wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To do what? Nothing

happening in DC the day before Thanksgiving - why are u busting my chops?"

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93. On or about November 24, 2017, STONE, texted CREDICO, "Assange is a

journalist and a damn good one- meeting with him is perfectly legal and all you ever told me was

he had the goods [o]n Hillary and would publish them - which he himself said in public b4 u told

me. It's a fucking witchunt [sic]." CREDICO replied, "I told you to watch his tweets. That's

what I was basing it on. I told you to watch his Tweets in October not before that I knew nothing

about the DNC stuff[.] I just followed his tweets[.]" STONE responded, "U never said anything

about the DNC but it was August." CREDICO wrote back, "It was not August because I didn't

interview him or meet him until August 26th[.] That was my first communication with his

secretary in London, August 26th." STONE wrote back, "Not the way I remember it - oh well I

guess Schiff will try to get one ofus indicted for perjury[.]"

94. STONE and CREDICO continued to exchange messages and on November 24,

2017, CREDICO wrote to STONE, "Forensic evidence proves that there is no back Channel. So

now you can relax."

95. On or about November 28, 2017, CREDICO tweeted a copy of a subpoena he

received from HPSCI that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

96. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that "Credico merely[]

confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credi co never said he knew or had any information as to source or

content of the material."

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97. On or about December 1, 2017, CREDICO messaged STONE, "I don't know why

you had to lie and say you had a back Channel now I had to give all of my forensic evidence to

the FBI today what a headache(.] 4 You could have just told him the truth that you didn't have a

back Channel they now know that I was not in London until September of this year[.] You had

no back-channel and you could have just told the truth ... You want me to cover you for perjury

now[.]" STONE responded, "What the fuck is your problem? Neither ofus has done anything

wrong or illegal. You got the best press of your life and you can get away with asserting for 5th

Amendment rights ifu don't want talk about AND if you turned over anything to the FBI you're

a fool." CREDICO responded, "You open yourself up to six counts of perjury[.] But I'm sure,

that wasn't sworn testimony so you're probably clear[.] Council for the committee knows you

never had a back Channel and if you had just told the truth wouldn't have put me in this bad spot

... you should go back ... and amend your testimony and tell them the truth." CREDICO

repeated: "you need to amend your testimony before I testify on the 15th." STONE replied, "If

you testify you're a fool. Because of tromp [sic] I could never get away with a certain [sic] my

Fifth Amendment rights but you can. I guarantee you you [sic] are the one who gets indicted for

perjury if you're stupid enough to testify[.]"

98. STONE and CREDICO continued to message each other on or about December I,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fuck off good night." CREDICO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

4 Contrary to his statement, CREDICO has not provided any forensic evidence to the FBI.

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99. On or about December 13, 2017, according to public reporting, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

100. STONE and CREDICO continued to exchange text messages, and on or about

January 6, 2018, CREDICO indicated to STONE that he was having dinner with a reporter.

STONE responded, "Hope u don't fuck Up my efforts to get Assange a pardon[.]" CREDICO

messaged STONE, "I have the email from his chief of staff August 25th 2016 responding to an

email I sent to WikiLeaks website email address asking you would do my show[.] That was my

initial contact."

101. On or about January 8, 2018, CREDICO messaged STONE, stating: "Embassy

logs ... + 17 other pieces of information prove that I did not have any conversations with

Assange until September oflast year."

102. CREDICO and STONE continued to message each other, and on or about January

25, 2018, CREDICO wrote to STONE: "You lied to the house Intel committee ... But you'll get

off because you're friends with Trump so don't worry. I have all the forensic evidence[.] I was

not a ba[ck] Channel and I have all those emails from September of2016 to prove it[.]"

103. On or about April 13, 2018, news reports stated that CREDICO had shown

reporters copies of email messages he had received from STONE in the prior few days that

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

from you," referring to CREDICO's therapy dog. CREDICO stated that it was "cetiainly scary .

. . When you start bringing up my dog, you're crossing the line[.]" 5

5 https://www.yahoo.com/news/comedian-randy-credico-says-trurnp-adviser-roger-stone-
threatened-dog-135911370.html

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104. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

He was depressed about it. Or was he lying." The article noted that CREDI CO stated he did not

have prostate cancer and did not have any such discussion with STONE.

K Statements Regarding STONE's Use of Social Media

105. On or about Friday, May 18, 2018 was voluntarily interviewed

by investigators from the Special Counsel's Office. told investigators that he became

STONE's assistant in Florida in 2015, and that during the summer of 2016, he acted as STONE's

right-hand man. 7

106. According t STONE utilized the services of several individuals to

post social media content to Facebook and Twitter, and that he and STONE both

instructed these individuals about what to post. tated that he purchased a couple

hundred fake Facebook accounts as part of this work (including both new and existing accounts),

and that bloggers working for STONE would try to build what looked like real Facebook

accounts.

107. further stated that STONE wanted to push out WikiLeaks content

through his Facebook and Twitter accounts, and that content related to the stolen Podesta emails

was pushed out through STONE's Facebook and Twitter accounts.

6 https ://www.motherjones.com/politics/2018/0 5/roger-stone-to-associate-prepare-to-die/

7 told investigators that he would sometimes send emails from STONE's account.

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108. In or around August 2018, pursuant to a warrant issued by Chief Judge Howell,

the FBI searched several Facebook accounts associated with STONE, which (among other

things) were used to purchase Facebook advertisements. Search warrant returns for one of those

account show that STONE or one of his associates created an ad

campaign on or about August 26, 2016, that included the text, "The Democrats are right to fear

Assange's next email drops will be devastating to Hillary." The same account was also used to

create and run a Facebook ad campaign on or about March 28, 2017, that included the following

text: "ROGER STONE - NO consensus that Guccifer 2.0 is a 'Russian Asset' just because US

Intel says he is."

L. The Target Account

109. According to subscriber records, the email account

was created on August 17, 2015, in the name of"Falo Memo Tio." 8 STONE's Hotmail account

is listed as the recovery email for the account. In my training and

experience, when setting up a new email account, users typically provide an email account under

their control as the recovery account in order to ensure continued access to the new account, for

example, in the event a password is lost or compromised. Accordingly, there is probable cause

to believe that STONE controls (directly, or through an employee or associate) the email account

110. The goverrnnent obtained non-content information associated with the

pursuant to an order issued by Chief Judge Howell under 18 U.S.C.

8 Subscriber records list the "Language Code" for the email account as "pt_BR." I believe this
indicates that the subscriber selected Brazilian Portuguese as the primary language for the
account. Based on machine translation, the customer name "Falo Memo Tio" translates from
Portuguese to "I speak Memo Uncle."

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§ 2703(d). Although subscriber records indicate that the last login to the email account took

place on August 18, 2015, header information shows that the account continued to receive emails

until at least July 27, 2018, including from companies that offer advertisement placements.

111. Header information shows that the email account received multiple emails from

Facebook between approximately November 3, 2016 and November 7, 2016, shortly before the

U.S. presidential election. On or about October 5, 2016, the email account also received an

email from [email protected], an account that I believe is associated with Google

AdSense. According to open source information, Google AdSense is a program that matches ads

to websites based on their content and visitors, and it allows individuals to place targeted

advertising on its network of content sites.

112. Based on a query performed through Facebook's law enforcement portal, the FBI

has confirmed that the email account is registered to an active

Facebook account. As explained further below, in my training and experience, I know that, in

addition to posting content and purchasing advertisements, Facebook accounts can be used to

communicate privately and directly with other users through Facebook's messaging function.

This function is similar to the direct messaging function of Twitter, which STONE used to

communicate with WikiLeaks and ASSANGE in 2016 and 2017.

BACKGROUND CONCERNING FACEBOOK

113. Facebook owns and operates a free-access social networking website of the same

name that can be accessed at http://www.facebook.com. Facebook allows its users to establish

accounts with Facebook, and users can then use their accounts to share written news, photographs,

videos, and other information with other Facebook users, and sometimes with the general public.

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114. Facebook asks users to provide basic contact and personal identifying information

to Facebook, either during the registration process or thereafter. This information may include the

user's full name, birth date, gender, contact e-mail addresses, Facebook passwords, Facebook

security questions and answers (for password retrieval), physical address (including city, state, and

zip code), telephone numbers, screen names, websites, and other personal identifiers. Facebook

also assigns a user identification number to each account.

115. Facebook users may join one or more groups or networks to connect and interact

with other users who are members of the same group or network. Facebook assigns a group

identification number to each group. A Facebook user can also connect directly with individual

Facebook users by sending each user a "Friend Request." If the recipient of a "Friend Request"

accepts the request, then the two users will become "Friends" for purposes of Facebook and can

exchange communications or view information about each other. Each Facebook user's account

includes a list of that user's "Friends" and a "News Feed," which highlights information about the

user's "Friends," such as profile changes, upcoming events, and birthdays.

116. Facebook users can select different levels of privacy for the communications and

information associated with their Facebook accounts. By adjusting these privacy settings, a

Facebook user can make information available only to himself or herself, to particular Facebook

users, or to anyone with access to the Internet, including people who are not Facebook users. A

Facebook user can also create "lists" of Facebook friends to facilitate the application of these

privacy settings. Facebook accounts also include other account settings that users can adjust to

control, for example, the types of notifications they receive from Facebook.

117. Facebook users can create profiles that include photographs, lists of personal

interests, and other information. Facebook users can also post "status" updates about their

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whereabouts and actions, as well as links to videos, photographs, articles, and other items available

elsewhere on the Internet. Facebook users can also post information about upcoming "events,"

such as social occasions, by listing the event's time, location, host, and guest list. In addition,

Facebook users can "check in" to particular locations or add their geographic locations to their

Facebook posts, thereby revealing their geographic locations at particular dates and times. A

particular user's profile page also includes a "Wall," which is a space where the user and his or

her "Friends" can post messages, attachments, and links that will typically be visible to anyone

who can view the user's profile.

118. Facebook allows users to upload photos and videos, which may include any

metadata such as location that the user transmitted whens/he uploaded the photo or video. It also

provides users the ability to "tag" (i.e., label) other Facebook users in a photo or video. When a

user is tagged in a photo or video, he or she receives a notification of the tag and a link to see the

photo or video. For Facebook's purposes, the photos and videos associated with a user's account

will include all photos and videos uploaded by that user that have not been deleted, as well as all

photos and videos uploaded by any user that have that user tagged in them.

119. Facebook users can exchange private messages on Facebook with other users.

These messages, which are similar to e-mail messages, are sent to the recipient's "Inbox" on

Facebook, which also stores copies of messages sent by the recipient, as well as other information.

Facebook users can also post comments on the Facebook profiles of other users or on their own
'
profiles; such comments are typically associated with a specific posting or item on the profile. In

addition, Facebook has a Chat feature that allows users to send and receive instant messages

through Facebook. These chat communications are stored in the chat history for the account.

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Facebook also has a Video Calling feature, and although Facebook does not record the calls

themselves, it does keep records of the date of each call.

120. If a Facebook user does not want to interact with another user on Facebook, the

first user can "block" the second user from seeing his or her account.

121. Facebook has a "like" feature that allows users to give positive feedback or connect

to particular pages. Facebook users can "like" Facebook posts or updates, as well as webpages or

content on third-party (i.e., non-Facebook) websites. Facebook users can also become "fans" of

particular Facebook pages.

122. Facebook has a search function that enables its users to search Facebook for

keywords, usemames, or pages, among other things.

123. Each Facebook account has an activity log, which is a list of the user's posts and

other Facebook activities from the inception of the account to the present. The activity log includes

stories and photos that the user has been tagged in, as well as connections made through the

account, such as "liking" a Facebook page or adding someone as a friend. The activity log is

visible to the user but cannot be viewed by people who visit the user's Facebook page.

124. Facebook Notes is a blogging feature available to Facebook users, and it enables

users to write and post notes or personal web logs ("biogs"), or to import their biogs from other

services, such as Xanga, LiveJournal, and Blogger.

125. The Facebook Gifts feature allows users to send virtual "gifts" to their friends that

appear as icons on the recipient's profile page. Gifts cost money to purchase, and a personalized

message can be attached to each gift. Facebook users can also send each other "pokes," which are

free and simply result in a notification to the recipient that he or she has been "poked" by the

sender.

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126. Facebook also has a Marketplace feature, which allows users to post free classified

ads. Users can post items for sale, housing, jobs, and other items on the Marketplace.

127. In addition to the appJications described above, Facebook also provides its users

with access to thousands of other applications ("apps") on the Facebook platform. When a

Facebook user accesses or uses one of these applications, an update about that the user's access or

use of that application may appear on the user's profile page.

128. Some Facebook pages are affiliated with groups of users, rather than one individual

user. Membership in the group is monitored and regulated by the administrator or head of the

group, who can invite new members and reject or accept requests by users to enter. Facebook can

identify all users who are currently registered to a particular group and can identify the

administrator and/or creator of the group. Facebook uses the term "Group Contact Info" to

describe the contact information for the group's creator and/or administrator, as well as a PDF of

the current status of the group profile page.

129. Facebook uses the term "Neoprint" to describe an expanded view of a given user

profile. The "Neoprint" for a given user can include the following information from the user's

profile: profile contact information; News Feed information; status updates; links to videos,

photographs, articles, and other items; Notes; Wall postings; friend lists, including the friends'

Facebook user identification numbers; groups and networks of which the user is a member,

including the groups' Facebook group identification numbers; future and past event postings;

rejected "Friend" requests; comments; gifts; pokes; tags; and information about the user's access

and use of Facebook applications.

130. Facebook also retains Internet Protocol ("IP") logs for a given user ID or IP address.

These logs may contain information about the actions taken by the user ID or IP address on

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Facebook, including information about the type of action, the date and time of the action, and the

user ID and IP address associated with the action. For example, if a user views a Facebook profile,

that user's IP log would reflect the fact that the user viewed the profile, and would show when and

from what IP address the user did so.

131. Social networking providers like Facebook typically retain additional information

about their users' accounts, such as information about the length of service (including start date),

the types of service utilized, and the means and source of any payments associated with the service

(including any credit card or bank account number). In some cases, Facebook users may

communicate directly with Facebook about issues relating to their accounts, such as technical

problems, billing inquiries, or complaints from other users. Social networking providers like

Facebook typically retain records about such communications, including records of contacts

between the user and the provider's support services, as well as records of any actions taken by

the provider or user as a result of the communications.

132. As explained herein, information .stored in connection with a Facebook account

may provide crucial evidence of the "who, what, why, when, where, and how" of the criminal

conduct under investigation, thus enabling the United States to establish and prove each element

or alternatively, to exclude the innocent from further suspicion. In my training and experience, a

Facebook user's "Neoprint," IP log, stored electronic communications, and other data retained by

Facebook, can indicate who has used or controlled the Facebook account. This "user attribution"

evidence is analogous to the search for "indicia of occupancy" while executing a search warrant

at a residence. For example, profile contact information, private messaging logs, status updates,

and tagged photos (and the data associated with the foregoing, such as date and time) may be

evidence of who used or controlled the Facebook account at a relevant time. Further, Facebook

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account activity can show how and when the account was accessed or used. For example, as

described herein, Facebook logs the Internet Protocol (IP) addresses from which users access their

accounts along with the time and date. By determining the physical location associated with the

logged IP addresses, investigators can understandthe chronological and geographic context of the

account access and use relating to the crime under investigation. Such information allows

investigators to understand the geographic and chronological context ofFacebook access, use, and

events relating to the crime under investigation. Additionally, Facebook builds geo-location into

some of its services. Geo-location allows, for example, users to "tag" their location in posts and

Facebook "friends" to locate each other. This geographic and timeline information may tend to

either inculpate or exculpate the Facebook account owner. Last, Facebook account activity may

provide relevant insight into the Facebook account owner's state of mind as it relates to the offense

under investigation. For example, information on the Facebook account may indicate the owner's

motive and intent to commit a crime (e.g., information indicating a plan to commit a crime), or

consciousness of guilt (e.g., deleting account information in an effort to conceal evidence from

law enforcement).

133. Therefore, the computers of Facebook are likely to contain all the material

described above, including stored electronic communications and information concerning

subscribers and their use ofFacebook, such as account access information, transaction information,

and other account information.

FILTER REVIEW PROCEDURES

134. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

with professional responsibility requirements concerning the maintenance of attorney-client and

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other operative privileges. The procedures include use, if necessary, of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

CONCLUSION

135. Based on the forgoing, I request that the Court issue the proposed search warrant.

136. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

13 7. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

/;'-1,~ A~/~,b~
Curtis Heide
Special Agent
Federal Bureau ofinvestigation

Subscribed and sworn to before me on this J!f day of August, 2018.

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ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the Facebook accounts registered to

the following email addresses, stored at premises owned, maintained, controlled, or operated by

Facebook, Inc. ("Facebook"), a company headquartered in Menlo Park, California:

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ATTACHMENT B

I. Information to be disclosed by Facebook

To the extent that the information described in Attachment A is within the possession,

custody, or control of Facebook, Inc. ("Facebook"), including any messages, records, files, logs,

or information that have been deleted but are still available to Facebook, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(f), Facebook is required to disclose the

following information to the government for each account listed in Attachment A:

(a) All contact and personal identifying information, including full name, user

identification number, birth date, gender, contact e-mail addresses, physical address

(including city, state, and zip code), telephone numbers, screen names, websites,

and other personal identifiers.

(b) All activity logs for the account and all other documents showing the user's posts

and other Facebook activities;

( c) All photos and videos uploaded by that user ID and all photos and videos uploaded

by any user that have that user tagged in them, including Exchangeable Image File

("EXIF") data and any other metadata associated with those photos and videos;

(d) All profile information; News Feed information; status updates; videos,

photographs, articles, and other items; Notes; Wall postings; friend lists, including

the friends' Facebook user identification numbers; groups and networks of which

the user is a member, including the groups' Facebook group identification numbers;

future and past event postings; rejected "Friend" requests; comments; gifts; pokes;

tags; and information about the user's access and use ofFacebook applications;

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(e) All other records of communications and messages made or received by the user,

including all private messages, chat history, video calling history, and pending

"Friend" requests;

(f) All records relating to machine cookies;

(g) All "check ins" and other location information, including records of the user's

latitude and longitude;

(h) All IP logs, including all records of the IP addresses that logged into the account;

(i) All records of the account's usage of the "Like" feature, including all Facebook

posts and all non-Facebook webpages and content that the user has "liked";

G) All information about the Facebook pages that the account is or was a "fan" of;

(k) All past and present lists of friends created by the account;

(1) All records of Facebook searches performed by the account;

(m) All information about the user's access and use ofFacebook Marketplace;

(n) The types of service utilized by the user;

(o) The length of service (including start date) and the means and source of any

payments associated with the service (including any credit card or bank account

number);

(p) Group identification numbers; a list of users currently registered to the group; a list

of users who like the page; group or page contact information, including all contact

information for the creator and/or administrator of the group and a PDF of the

current status of the group profile page;

(q) All past and present Admins for the group;

(r) The "Creator" of the group;

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Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 55 of 56

(s) All privacy settings and other account settings, including privacy settings for

individual Facebook posts and activities, and all records showing which Facebook

users have been blocked by the account;

(t) All records pertaining to communications between Facebook and any person

regarding the user or the user's Facebook account, including contacts with support

services and records of actions taken;

(u) All records related to advertisements and advertising conducted through the

accounts, including advertisements purchased, advertising parameters (search

terms, groups, geographic areas) selected and queried.

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud); and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June 1, 2015 to the present, including:

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

-4-
Case 1:19-mc-00029-CRC Document 29-19 Filed 04/28/20 Page 56 of 56

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, or any

individual associated with the Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

.h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

i. The identity of the person( s) who created or used the account, including records

that help reveal the whereabouts of such person( s);

-5-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 1 of 49
AO 93 (Rev. 1 l/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1:18-sc-02728
or identify the person by name and address) ) Assigned To : Chief Judge Beryl A. Howell
INFORMATION ASSOCIATED WITH ONE ACCOUNT ) Assign. Date: 8/28/2018
STORED AT PREMISES ) Description: Search and Seizure Warrant
CONTROLLED BY GOOGLE )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before September 11, 2018 (not to exceed 14 days)
'iii in the daytime 6:00 a.m. to I 0:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. James E. Boasberg, U.S. District Judge
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued: -~=m-/-Jo,icf,)J.t,_/(._f>'-_-~,,,_._:)":1._,/'-'-""'--------

City and state: _W_as_h_in_.g,_t_on_.,c_D_C_ _ _ _ _ _ __ U.S. District Judge


Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 2 of 49
AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 3 of 49

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Google accounts, which

are stored at premises owned, maintained, controlled, or operated by Google, LLC ("Google"), a

company headquartered in Mountain View, California:

-1-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 4 of 49

ATTACHMENT B

I. Information to be disclosed by Google

To the extent that the information described in Attachment A is within the possession,

custody, or control of Google, LLC ("Google"), including any messages, records, files, logs, or

information that have been deleted but are still available to Google, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(f), Google is required to disclose the following

information to the government for each account listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date and time at which each

email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the account, to

include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the

account, including address books, contact and buddy lists, calendar data, pictures,

and files;

-2-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 5 of 49

e. All records pertaining to connnunications between the Provider and any person

regarding the account, including contacts with support services and records of

actions taken;

f. All subscriber "change history" associated with the account;

g. All search history and web history associated with the account;

h. All location and maps information associated with the account;

1. All Google Analytics information associated with the account (including all

properties and UA codes associated with the account, and, for each of these

proprieties and UA codes, all usemames and email accounts associated with them);

J. All Google Developers Console information associated with the account;

k. All Minutemaid information associated with the account;

I. All Android information associated with the account;

m. All Google Docs associated with the account;

n. All YouTube information associated with the account;

o. All Google Hangouts information associated with the account;

p. All Google Voice information associated with the account;

q. All Web & App Activity associated with the account;

r. All Google Drive information associated with the account;

s. All Google+ information associated with the account;

t. All device information associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

-3-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 6 of 49

Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Number

("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), or

International Mobile Equipment Identities ("IMEI")); and

u. For any accounts linked to the accounts listed in Attachment A, including accounts

linked by cookie, SMS number, or recovery email address, and for accounts for

which the accounts described in Attachment A are the recovery email address,

provide all records or other information regarding the identification of the account,

to include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number).

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June 1, 2015 to the present, including:

-4-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 7 of 49

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, or any

individual associated with the Trump Campaign;

c. Communications, records, documents, and ot4er files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

-5-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 8 of 49

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

I. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
AO 106 (Rev. 04/10} Application 'for a Search Warrant
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 9 of 49

UNITED STATES DISTRICT COURT


for the AUG 2 8 2018
District of Columbia Clerk, U.S. Districi & Bankruptuy
Courts for the District of Columllia
In the Matter of the Search of
(Briefly describe the property to be searched )~ Case: 1:18-sc-02728
or identify the person by name and address)
INFORMATION ASSOCIATED WITH
Assigned To : Chief Judge Beryl A. Howell
ONE ACCOUNT STORED AT PREMISES CONTROLLED )~ Assign. Date: 8/28/2018
BY GOOGLE Description: Search and Seizure Warrant

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location);

See Attachment A
located in the Northern District of _ _ _ __-C,:.:a:.:.lic.:fo::-r..n.,,ia,...__ _ _ , there is now concealed (identify the
person or describe the property to be seized):
See Attachment B

The basis for the search under Fed. R. Crim. P. 4l(c) is (check one or more):
Mevidence of a crime;
Mcontraband, fruits of crime, or other items illegally possessed;
ref property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
52 u.s.c. § 30121 Foreign Contribution Ban
18 U.S.C. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of _ _ days (give exact ending date if more than 30 days: ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

~ s, /I, ,,?ktA,,..___
Reviewed by AUSA/SAUSA: Applicant's signature

!Kyle R. Freeny (ASC) Curtis Heide, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date:

City and state: Washington, D.C.


Printed name and title
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 10 of 49
FILED
AUG 2 8 2018
IN THE UNITED STATES DISTRICT COURT Cieri(, U.S. District & Bankruptcy
Courts for the District of Columbia
FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF Case: 1: 18-sc-02728


INFORMATION ASSOCIATED WITH Assigned To : Chief Judge Beryl A. Howell
ONE ACCOUNT STORED AT PREMISES Assign. Date: 8/28/2018
CONTROLLED BY GOOGLE Description: Search and Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Curtis A. Heide, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the Google account ("Target Account"),

stored at premises owned, maintained, controlled or operated by Google, LLC ("Google"), a

company headquartered in Mountain View, California. The information to be disclosed by Google

and searched by the government is described in the following paragraphs and in Attachments A

andB.

2. I have been a Special Agent with the Federal Bureau of investigation for 12 years.

In the course of my duties, I have been responsible for investigating federal crimes and national

security matters involving both counterintelligence and issues related to cybersecurity.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Account contain evidence, fruits, or

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

-1-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 11 of 49

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a protected

computer), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud), 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C. § 1513 (witness

tampering), and 52 U.S.C. § 30121(a)(l)(C) (foreign expenditure ban). There also is probable

cause to search the information described in Attachment A for evidence, contraband, fruits,

and/or instrumentalities of the Subject Offenses, further described in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(l)(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

PROBABLE CAUSE

A. Background on Relevant Individuals

i. Roger STONE

6. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

-2-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 12 of 49

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

7. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WNO.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

.-3-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 13 of 49

B. Russian Government-Backed Hacking Activity During the 2016 Presidential


Election

9. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Government developed a clear preference for President-elect Trump.

10. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

11. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities

to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

-4-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 14 of 49

12. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

13. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

14. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

15. For example, inor around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

16. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

17. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

18. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

-5-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 15 of 49

presidential election, including conspiracy to commit authorized access to protected computers.

See United States v. Viktor Borisovich Netyksho, et al. (Case No. 1: 18-cr-00125).

C. STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

19. On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

20. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.

21. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

22. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

-6-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 16 of 49

aimed at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With

regard to the October surprise, what would be your forecast on that given what Julian Assange

has intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain

to the Clinton Foundation but there's no telling what the October surprise may be." A few days

later, STONE clarified that while he was not personally in touch with ASSANGE, he had a close

friend who served as an intermediary.

23. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thauks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

24. On August 13, 2016, STONE posted a tweet using@RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

25. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

26. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

27. On August 21, 2016, using @RogerJStoneJR; STONE tweeted: "Trust me, it will

soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same

day, STONE reiterated that because of the work of a '"mutual acquaintance' of both his and

-7-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 17 of 49

[AS SANGE], the public [could] expect to see much more from the exiled whistleblower in the

form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Ruma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

28. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

29. On Saturday, October!, 2016, using@RogerJStoneJr, STONE tweeted,

"Wednesday@ HillaryC!inton is done. #WikiLeaks."

30. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement ASSANGE had scheduled for the next day from the balcony

of the Ecuadoran Embassy in London. Onthe day o£the AS SANGE announcement - which was

part ofWikiLeaks' IO-year anniversary celebration- STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used@RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

31. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

32. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryC!inton #Podesta #imWithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

-8-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 18 of 49

33. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta-referring back to STONE's August 21,

2016 C-SPAN and Twitter references-argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

34. On March 27, 2017, CNN reported that a representative ofWikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture),and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true,''

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

35. On October 13, 2016, while WikiLeaks was in the midst of releasing the hacked

Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

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account @wikileaks. 1 The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

to rexamine the strategy of attacking me- cordially R."

36. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

37. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

38. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

39. In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE,

the founder ofWikiLeaks. For example, on June 4, 2017,@RogerJStoneJr directly messaged

@JulianAssange, an address associated with AS SANGE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

1
On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
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Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 20 of 49

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

40. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks

41. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, On October

17, 2017, Chief Judge Howell issued a search warrant for one of STONE's addresses,

On or about December 19, 2017, Chief Judge Howell issued a search

warrant for email account. On or about March 14, 2018, Chief Judge Howell

issued a search warrant for STONE's iCloud account. Information recovered pursuant to those

search warrants indicated the following:

42. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger

Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

appears to have forwarded the message to STONE at who replied to

CORSI that, "May meet Manafort -guarantee nothing."

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Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 21 of 49

.43. On or about May 18, 2016, CORSI emailed STONE at

with the title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

44. On July 25, 2016, STONE, using sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

45. On or about July 31, 2016, STONE, using emailed

CORSI with the subject line, "Call me MON." The body of the email read: should see

Assange[.] should find Bernie [S]anders brother who called Bill a Rapist -turn him for

Trump[.] should find or more proof of Bill getting kicked out."

46. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at

"Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued, "Signs are Fox

will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HRC an artifact of rigged polling. Won't last. I expect presidential

campaign to get serious starting Sept. Still in pre-season games. Time to let more than Podesta to

be exposed as in bed w enemy if they are not ready to drop HRC. That appears to be the game

hackers are now about. Would not hurt to start suggesting HRC old, memory bad, has stroke --

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neither he nor she well. I expect that much of next dump focus, setting stage for Foundation

debacle." Investigators believe that CORSI's reference to a "friend in embassy [who] plans 2

more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in 2016.

47. On or about August 5, 2016, an associate of STONE's, emailed

STONE at The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet AS SANGE. also stated

that in 2018, told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SAN GE. STONE told he was joking and

had not actually met ASSANGE. 2

48. Through a search of STONE's iCloud account, the FBI has uncovered evidence

suggesting that STONE was in Los Angeles for one or more meetings at the time that he claimed,

in his email to to have "dined" with ASSANGE. For example, an associate of

STONE sent a text to STONE at approximately 3:38PM on August 2, asking "How did ur meeting

go in LA?'' STONE responded. "It's this afternoon[.]" The following day, the associate asked,

"Any report from ur meeting?" On or about August 4, 2016, STONE texted the associate, "Will

call later - heading for airport now[.]" Additionally, investigators have identified a photograph in

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STONE's iCloud that appears to have been taken on August 3, 2016 and had geo-location

information indicating that it was taken in Los Angeles.

49. On or about August 15, 2016, CORSI emailed STONE at

"Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

50. On or about August 31, 2016, CORSI emailed STONE at

: "Did you get the PODESTA writeup." STONE replied "[y]es."

51. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Yanukovych - Panama papers reveals Podesta hired by

S[b]erbank, Russia's largest financial institution - Podesta $$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

52. On or about September 6, 2016, CORSI emailed STONE at

"Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

53. On or about September 24, 2016, emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have

secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today." wrote back, "Awaiting secret file. Explosive ... Hope you are well.

Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators, indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

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54. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange - what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON, who was CEO of the Campaign at the time, and wrote: "You should call Roger. See

below. You didn't get from me." BANNON wrote back, "I've got important stuff to worry

about." The associate responded, "Well clearly he knows what Assange has. I'd say that's

important."

55. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

AS SAN GE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, AS SAN GE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." AS SAN GE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

56. On or about October. 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

57. That same day, BANNON emailed STONE at "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawyer is a big

democrat."

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58. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

59. According to a publicly available news article, 3 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."

60. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

61. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

62. At approximately I :42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

63. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

3 https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07/31d74714-8ce5-11 e6-875e-2c 1bfe943b66_ story.html

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64. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

65. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE using "I expect

that much of next dump focus, setting stage for Foundation debacle."

66. At approximately 6:27PM, an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks - The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using

forwarded message to CORSI without comment. STONE

does not appear to have forwarded the email to any other individual.

G. STONE Asks CORSl for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

67. On or about October 8, 2016, STONE messaged CORSI, "Lunchpostponed-

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job

numbers."

68. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

using emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

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Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 27 of 49

Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

69. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at both with the subject

line "Podesta talking points." Attached to the email was a file labeled, "ROGER STONE

podesta talking points Oct 12 2016.docx." The "talking points" included the statement that

"Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation."

70. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Hotmail Account, "Got them and used them."

71. On or about Thursday, October 13, 2016, CORSI emailed STONE at

"PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I'll give you one more -NOBODY YET HAS THIS[:] It looks to me

like skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once

had the c)lannel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

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Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 28 of 49

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

72. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

have had some back-channel communications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money did a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through

Metcombank, a Russian regional bank owned 99.978 percent by with the money

transferred via Deutsche Bank and Trust Company Americas in New York City, with the money

ending up in a private bank account in the Bank of America that is operated by the Clinton

Foundation?"

73. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

74. On or about October 17,2016, CORSI messaged STONE at his iCloud account,

.. "On Assange, can you call me now- before 2pm[.)" STONE responded, "Missed u- just

landed JFK - on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

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75. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand off[.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. IfHRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election."

76. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

77. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice ofWikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta's business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

78. On or about November 8, 2016, the United States presidential election took place.

79. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

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80. On or about November 10, 2016, CORSI messaged STONE at his iC!oud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in

London. Have some interesting news for you."

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I. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikileaks

88. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCI). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic assertions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta' s email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such assertions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trust me, it will soon be the Podesta's
time in the barrel. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but
does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrutiny....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.
I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
Assange to independently confirm this report, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
information proved to be correct. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

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89. In a document dated March 26, 2018 titled "Minority Views," Democratic

members of HP SCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in
communication with Assange or communication through an intermediary with Assange,
you were only referring to a single fact that you had confirmed with the intermediary -
MR. STONE: That -
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is correct, even though it was repeated to me on numerous separate
occas10ns.

90. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an article on his website, stonecoldtruth.com, titled "Is it the Podesta's

Time in the Barrel Yet?" In that article, STONE stated: "[I]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

J, STONE's Messaging to Randy CREDICO about STONE's "Back channel"

91. On or about November 19, 2017, Randy CREDICO (who, as described further

below, STONE publicly identified as his "intermediary" to ASSANGE), messaged STONE, "My

lawyer wants to see me today." STONE responded, "'Stonewall it. Plead the fifth. Anything to

save the plan' ........ Richard Nixon[.]" CREDICO responded, "Ha ha."

92. On or about November 21, 2017, CREDICO messaged STONE, "I was told that

the house committee lawyer told my lawyer that I will be getting a subpoena[.]" STONE wrote

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back, "That was the point at which your lawyers should have told them you would assert your

5th Amendment rights if compelled to appear." They continued to message, and CREDI CO

wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To do what ? Nothing

happening in DC the day before Thanksgiving - why are u busting my chops?"

93. On or about November 24, 2017, STONE, texted CREDICO, "Assange is a

journalist and a damn good one- meeting with him is perfectly legal and all you ever told me was

he had the goods [o]n Hillary and would publish them - which he himself said in public b4 u told

me. It's a fucking witchunt [sic]." CREDICO replied, "I told you to watch his tweets. That's

what I was basing it on. I told you to watch his Tweets in October not before that I knew nothing

about the DNC stuff[.] I just followed his tweets[.]" STONE responded, "U never said anything

about the DNC but it was August." CREDICO wrote back, "It was not August because I didn't

interview him or meet him until August 26th[.] That was my first communication with his

secretary in London, August 26th." STONE wrote back, "Not the way I remember it - oh well I

guess Schiff will try to get one ofus indicted for perjury[.]"

94. STONE and CREDICO continued to exchange messages and on November 24,

2017, CREDICO wrote to STONE, "Forensic evidence proves that there is no back Channel. So

now you can relax."

95. On or about November 28, 2017, CREDICO tweeted a copy of a subpoena he

received from HPSCI that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

96. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post1 STONE further stated that "Credico merely[]

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confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credico never said he knew or had any inf01mation as to source or

content of the material."

97. On or about December 1, 2017, CREDICO messaged STONE, "I don't know why

you had to lie and say you had a back Channel now I had to give all of my forensic evidence to

the FBI today what a headache[.] 4 You could have just told him the truth that you didn't have a

back Channel they now know that I was not in London until September of this year[.] You had

no back-channel and you could have just told the truth ... You want me to cover you for perjury

now[.]" STONE responded, "What the fuck is your problem? Neither ofus has done anything

wrong or illegal. You got the best press of your life and you can get away with asserting for 5th

Amendment rights ifu don't want talk about AND if you turned over anything to the FBI you're

a fool." CREDICO responded, "You open yourself up to six counts of perjury[.] But I'm sure

that wasn't sworn testimony so you're probably clear[.] Council for the committee knows you

never had a back Charmel and if you had just told the truth wouldn't have put me in this bad spot

... you should go back ... and amend your testimony and tell them the truth." CREDICO

repeated: "you need to amend your testimony before I testify on the 15th." STONE replied, "If

you testify you're a fool. Because of tromp [sic] I could never get away with a certain [sic] my

Fifth Amendment rights but you can. I guarantee you you [sic] are the one who gets indicted for

perjury if you're stupid enough to testify[.]"

98. STONE and CREDICO continued to message each other on or about December 1,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

4 Contrary to his statement, CREDICO has not provided any forensic evidence to the FBI.

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STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fuck off good night." CREDICO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

99. On or about December 13, 2017, according to public reporting, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

100. STONE and CREDICO continued to exchange text messages, and on or about

January 6, 2018, CREDICO indicated to STONE that he was having dinner with a reporter.

STONE responded, "Hope u don't fuck Up my efforts to get Assange a pardon[.]" CREDICO

messaged STONE, "I have the email from his chief of staff August 25th 2016 responding to an

email I sent to WikiLeaks website email address asking you would do my show[.] That was my

initial contact."

101. On or about January 8, 2018, CREDICO messaged STONE, stating: "Embassy

logs ... + 17 other pieces of information prove that I did not have any conversations with

Assange until September oflast year."

102. CREDICO and STONE continued to message each other, and on or about January

25, 2018, CREDICO wrote to STONE: "You lied to the house Intel committee ... But you'll get

off because you're friends with Trump so don't w01Ty. I have all the forensic evidence[.] I was

not a ba[ck] Channel and I have all those emails from September of2016 to prove it[.]"

103. On or about April 13, 2018, news reports stated that CREDICO had shown

reporters copies of email messages he had received from STONE in the prior few days that

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

-27-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 37 of 49

from you," referring to CREDICO's therapy dog. CREDICO stated that it was "certainly scary .

. . When you start bringing up my dog, you're crossing the line[.)" 5

104. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

He was depressed about it. Or was he lying." The article noted that CREDICO stated he did not

have prostate cancer and did not have any such discussion with STONE.

K. Statements Regarding STONE's Use of Social Media

105. On or about Friday, May 18, 2018, was voluntarily interviewed

by investigators from the Special Counsel's Office. told investigators that he became

STONE's assistant in Florida in 2015, and that during the summer of 2016, he acted as STONE's

right-hand man.

106. According to STONE utilized the services of several individuals to

post social media content to Facebook and Twitter, and that he and STONE both

instructed these individuals about what to post. stated that he purchased a couple

hundred fake Facebook accounts as part of this work (including both new and existing accounts),

and that bloggers working for STONE would try to build what looked like real Facebook

accounts.

5 https://www.yahoo.com/news/comedian-randy-credico-says-trump-adviser-roger-stone-
threatened-dog-135911370.html
6 https://www.motherjones.com/po litics/2018/05/roger-stone-to-associate-prepare-to-die/

-28-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 38 of 49

107. further stated that STONE wanted to push out WikiLeaks content

through his Facebook and Twitter accounts, and that content related to the stolen Podesta emails

was pushed out through STONE's Facebook and Twitter accounts.

108. In or around August 2018, pursuant to a warrant issued by Chief Judge Howell,

the FBI searched several Facebook accounts associated with STONE, which (among other

things) were used to purchase Facebook advertisements. Search warrant returns for one of those

accounts show that STONE or one of his associates created an ad

campaign on or about August 26, 2016, that included the text, "The Democrats are right to fear

Assange's next email drops will be devastating to Hillary." The same account was also used to

create and run a Facebook ad campaign on or about March 28, 2017, that included the following

text: "ROGER STONE - NO consensus that Guccifer 2.0 is a 'Russian Asset' just because US

Intel says he is."

L. The Target Account

109. According to subscriber records, Target Account was

created on August 17, 2015, in the name of"Falo Memo Tio." 7 STONE's account

is listed as the recovery email for the Target Account. In my training and

experience, when setting up a new email account, users typically provide an email account under

their control as the recovery account in order to ensure continued access to the new account, for

example, in the event a password is lost or compromised.

7
Subscriber records list the "Language Code" for the Target Account as "pt_BR." I believe
this indicates that the subscriber selected Brazilian Portuguese as the primary language for the
account. Based on machine translation, the customer name "Falo Memo Tio" translates from
Portuguese to "I speak Memo Uncle."

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Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 39 of 49

110. The government obtained non-content information associated with the Target

Account pursuant to an order issued by Chief Judge Howell under 18 U.S.C. § 2703( d).

Although subscriber records indicate that the last login to the Target Account took place on

August 18, 2015, header information shows that the account continued to receive emails until at

least July 27, 2018, including from companies that offer advertisement placements.

111. Header information shows that the Target Account received multiple emails

from Facebook between approximately November 3, 2016 and November 7, 2016, shortly before

the U.S. presidential election. On or about October 5, 2016, the Target Account also received

an email from [email protected], an account that I believe is associated with Google

AdSense. According to open source information, Google AdSense is a program that matches ads

to websites based on their content and visitors, and it allows individuals to place targeted

advertising on its network of content sites.

BACKGROUND CONCERNING GOOGLE

112. In my training and experience, I have learned that Google provides a variety of on-

line services, including electronic mail ("email") access, to the public. Google allows subscribers

to obtain email accounts at the domain name gmail.com, like the Target Account. Subscribers

obtain an account by registering with Google. During the registration process, Google asks

subscribers to provide basic personal information. Therefore, the computers of Google are likely

to contain stored electronic communications (including retrieved and unretrieved email) for

Google Mail subscribers and information concerning subscribers and their use of Google Mail

services, such as account access information, email transaction information, and account

application information. In my training and experience, such information may constitute evidence

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Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 40 of 49

of the crimes under investigation because the information can be used to identify the account's

user or users.

113. In my training and experience, email providers generally ask their subscribers to

provide certain personal identifying information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and other

identifiers, alternative email addresses, and, for paying subscribers, means and source of payment

(including any credit or bank account number). In my training and experience, such information

may constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users. Based on my training and my experience, I know that, even if

subscribers insert false information to conceal their identity, this information often provides clues

to their identity, location, or illicit activities.

114. In my training and experience, email providers typically retain certain transactional

information about the creation and use of each account on their systems. This information can

include the date on which the account was created, the length of service, records of log-in

(i.e., session) times and durations, the types of service utilized, the status of the account (including

whether the account is inactive or closed), the methods used to connect to the account (such as

logging into the account via the provider's website), and other log files that reflect usage of the

account. In addition, email providers often have records of the IP address used to register the

account and the IP addresses associated with particular logins to the account. Because every device

that connects to the Internet must use an IP address, IP address information can help to identify

which computers or other devices were used to access the email account.

11 S. In my training and experience, in some cases, email account users will

communicate directly with an email service provider about issues relating to the account, such as

-31-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 41 of 49

technical problems, billing inquiries, or complaints from other users. Email providers typically

retain records about such communications, including records of contacts between the user and the

provider's support services, as well as records of any actions taken by the provider or user as a

result of the communications. In my training and experience, such information may constitute

evidence of the· crimes under investigation because the information can be used to identify the

account's user or users.

116. This application seeks a warrant to search all responsive records and information

under the control of Google, a provider subject to the jurisdiction of this court, regardless of where

Google has chosen to store such information. The government intends to require the disclosure

pursuant to the requested warrant of the contents of wire or electronic communications and any

records or other information pertaining to the customers or subscribers if such communication,

record, or other information is within Google's possession, custody, or control, regardless of

whether such communication, record, or other information is stored, held, or maintained outside

the United States.

117. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of occupancy"

while executing a search warrant at a residence. For example, email communications, contacts

lists, and images sent (and the data associated with the foregoing, such as date and time) may

indicate who used or controlled the account at a relevant time. Further, information maintained by

-32-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 42 of 49

the email provider can show how and when the account was accessed or used. For example, as

described below, email providers typically log the Internet Protocol (IP) addresses from which

users access the email account, along with the time and date of that access. By determining the

physical location associated with the Jogged IP addresses, investigators can understand the

chronological and geographic context of the email account access and use relating to the crime

under investigation. This geographic and timeline information may tend to either inculpate or

exculpate the account owner. Additionally, information stored at the user's account may further

indicate the geographic location of the account user at a particular time (e.g., location information

integrated into an image or video sent via email). Last, stored electronic data may provide relevant

insight into the email account owner's state of mind as it relates to the offense under investigation.

For example, information in the email account may indicate the owner's motive and intent to

commit a crime (e.g., communications relating to the crime), or consciousness of guilt

(e.g., deleting communications in an effort to conceal them from law enforcement).

FILTER REVIEW PROCEDURES

118. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent·

with professional responsibility requirements concerning the maintenance of attorney-client and

other operative privileges. The procedures include use, if necessary, of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

CONCLUSION

119. Based on the forgoing, I request that the Court issue the proposed search warrant.

120. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

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Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 43 of 49

REQUEST FOR SEALING

121. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

~,~A /LA~
· ide
Special Agent
Federal Bureau oflnvestigation

Subscribed and sworn to before me on this~ day of August, 2018.

-34-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 44 of 49

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Google accounts, which

are stored at premises owned, maintained, controlled, or operated by Google, LLC ("Google"), a

company headquartered in Mountain View, California:

-1-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 45 of 49

ATTACHMENT B

I. Information to be disclosed by Google

To the extent that the information described in Attachment A is within the possession,

custody, or control of Google, LLC ("Google"), including any messages, records, files, logs, or

information that have been deleted but are still available to Google, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(!), Google is required to disclose the following

information to the government for each account listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date and time at which each

email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the account, to

include full name, physical address, . telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the

account, including address books, contact and buddy lists, calendar data, pictures,

and files;

-2-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 46 of 49

e. All records pertaining to communications between the Provider and any person

regarding the account, including contacts with support services and records of

actions taken;

f. All subscriber "change history" associated with the account;

g. All search history and web history associated with the account;

h. All location and maps information associated with the account;

1. All Google Analytics information associated with the account (including all

properties and UA codes associated with the account, and, for each of these

proprieties and UA codes, all usemames and email accounts associated with them);

J. All Google Developers Console information associated with the account;

k. All Minutemaid information associated with the account;

I. All Android information associated with the account;

m. All Google Docs associated with the account;

n. All YouTube information associated with the account;

o. All Google Hangouts information associated with the account;

p. All Google Voice information associated with the account;

q. All Web & App Activity associated with the account;

r. All Google Drive information associated with the account;

s. All Google+ information associated with the account;

t. All device information associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

-3-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 47 of 49

Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Number

("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), or

International Mobile Equipment Identities ("!MEI")); and

u. For any accounts linked to the accounts listed in Attachment A, including accounts

linked by cookie, SMS number, or recovery email address, and for accounts for

which the accounts described in Attachment A are the recovery email address,

provide all records or other information regarding the identification of the account,

to include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number).

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June 1, 2015 to the present, including:

-4-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 48 of 49

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, or any

individual associated with the Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

-5-
Case 1:19-mc-00029-CRC Document 29-20 Filed 04/28/20 Page 49 of 49

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

1. The identity of any non-U.S. person(s}-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s}-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 1 of 48
AO 93 (Rev. l l/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1:18-sc-02729
or identify the person by name and address) ) Assigned To : Chief Judge Beryl A. Howell
INFORMATION ASSOCIATED WITH ONE ACCOUNT ) Assign. Date: 8/28/2018
STORED AT PREMISES ) Description: Search and Seizure Warrant
CONTROLLED BY 1&1 MAIL & MEDIA, INC. )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Eastern District of Pennsylvania
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before September 11, 2018 (not to exceed 14 days)
f1 in the daytime 6:00 a.m. to 10:00 p.m.
0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. James E. Boasberg, U.S. District Judge
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued:

City and state: Washington, DC E. Boasberg, U.S. District Judge


Printed name and title
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 2 of 48
AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 3 of 48

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following I & I Mail accounts,

which are stored at premises owned, maintained, controlled, or operated by I & I Mail & Media,

Inc. ("I &I Mail"), a company headquartered in Chesterbrook, Pennsylvania:

-1-
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 4 of 48

ATTACHMENT B

I. Information to be disclosed by l&l Mail

To the extent that the information described in Attachment A is within the possession,

custody, or control of l&l Mail & Media, Inc. ("1&1 Mail"), including any messages, records,

files, logs, or information that have been deleted but are still available to 1& 1 Mail, or have been

preserved pursuant to a request made under 18 U.S.C. § 2703(f), 1&1 Mail is required to disclose

the following information to the government for each account listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date and time at which each

email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the account, to

include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the

account, including address books, contact and buddy lists, calendar data, pictures,

and files;

-2-
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 5 of 48

e. All records pertaining to communications between the Provider and any person

regarding the account, including contacts with support services and records of

actions taken;

f. All subscriber "change history" associated with the account;

g. All search history and web history associated with the account;

h. All location and maps information associated with the account;

i. All device information associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Number

("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), or

International Mobile Equipment Identities ("IMEI")); and

j. For any accounts linked to the accounts listed in Attaclunent A, including accounts

linked by cookie, SMS number, or recovery email address, and for accounts for

which the accounts described in Attaclunent A are the recovery email address,

provide all records or other information regarding the identification of the account,

to include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided dming registration, methods of connecting, log files, and means and

somce of payment (including any credit or bank account number).

-3-
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 6 of 48

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June 1, 2015 to the present, including:

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, or any

individual associated with the Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

-4-
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 7 of 48

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

I. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

-5-
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 8 of 48

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
AO 106 (Rev. 04/10) Application for a Search Warrant
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 9 of 48

UNITED STATES DISTRICT COURT FILED


for the AUG 2 B 2018
District of Columbia Clerk, U.S. District & Bankruptcy
Courts tor th~ Oistrict of G0!uml1ta
In the Matter of the Search of
(Briefly describe the property to be searched
or identify the person by name and address)
~
)
Case: 1:18-sc-02729
Assigned To : Chief Judge Beryl A. Howell
INFORMATION ASSOCIATED WITH Assign. Date: 8/28/2018
ONE ACCOUNT STORED AT PREMISES CONTROLLED ~ Description: Search and Seizure Warrant
BY 1&1 MAIL & MEDIA, INC. )

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A
- - - - - District of
located in the - - -Eastern _,P,_e__,n...n..s,_,y_..lv"a.._n...ia~--- , there is now concealed (identify the
person or describe the property to be seized):
See Attachment B

The basis for the search under Fed. R. Crim. P. 4l(c) is (check one or more):
r.f evidence of a crime;
r.f contraband, fruits of crime, or other items illegally possessed;
fl property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
52 U.S.C. § 30121 Foreign Contribution Ban
18 U.S.C. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

r;/ Continued on the attached sheet.


0 Delayed notice of days (give exact ending date if more than 30 days: ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

~'llzA . . ? ~ ~
Reviewed by AUSA/SAUSA: Applicant's signature

IKyle R. Freeny (AS() Curtis Heide, Special Agent, FBI


Printed name and title

Sworn to before me and signed in my presence.

Date:

City and state: Washington, D.C. U.S. District Judge


Printed name and title
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 10 of 48

FILED
IN THE UNITED STATES DISTRICT COURT AUG 2 8 2018
FOR THE DISTRICT OF COLUMBIA Clerk, U.S. District & Bankruptcy
Courts for tfle District of Columbia

IN THE MATTER OF THE SEARCH OF


INFORMATION ASSOCIATED WITH case: 1:18-sc-02729
ONE ACCOUNT STORED AT PREMISES Assigned To : Chief Judge Beryl A. Howell
CONTROLLED BY l&l MAIL & MEDIA, Assign. Date: 8/28/2018 .
INC. Description: Search and Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Curtis Heide, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the 1& 1 Mail account ("Target Account"),

stored at premises owned, maintained, controlled or operated by l&l Mail & Media, Inc. ("l&l

Mail"), a company headquartered in Chesterbrook, Pennsylvania. The information to be disclosed

by l&l Mail and searched by the government is described in the following paragraphs and in

Attachments A and B.

2. I have been a Special Agent with the Federal Bureau of investigation for 12 years.

In the course of my duties, I have been responsible for investigating federal crimes and national

security matters involving both counterintelligence and issues related to cybersecurity.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Account contain evidence, fruits, or

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 11 of 48

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a protected

computer), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud), 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C. § 1513 (witness

tampering), and 52 U.S.C. § 30121(a)(l)(C) (foreign expenditure ban). There also is probable

cause to search the information described in Attachment A for evidence, contraband, fruits,

and/or instrumentalities of the Subject Offenses, further described in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(l)(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

PROBABLE CAUSE

A. Background on Relevant Individuals

i. Roger STONE

6. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 12 of 48

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

7. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WNO.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 13 of 48

B. Russian Government-Backed Hacking Activity During the 2016 Presidential


Election

9. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Goverrunent developed a clear preference for President-elect Trump.

10. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian goverrunent employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Goverrunent agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

11. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities

to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 14 of 48

12. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

13. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

14. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

15. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own\technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

16. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

17. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

18. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 15 of 48

presidential election, including conspiracy to commit authorized access to protected computers.

See United States v. Viktor Borisovich Netyksho, et al. (Case No. 1: l 8-cr-00125).

C. STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

19. On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian govermnent actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

20. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.

21. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

22. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 16 of 48

aimed at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With

regard to the October surprise, what would be your forecast on that given what Julian Assange .

has intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain

to the Clinton Foundation but there's no telling what the October surprise may be." A few days

later, STONE clarified that while he was not personally in touch with AS SANGE, he had a close

friend who served as an intermediary.

23. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

24. On August 13, 2016, STONE posted a tweet using@RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

25. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

26. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

27. On August 21, 2016, using@RogerJStoneJR, STONE tweeted: "Trust me, it will

soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same

day, STONE reiterated that because of the work of a '"mutual acquaintance' of both his and

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 17 of 48

[ASSANGE], the public [could] expect to see much more from the exiled whistleblower in the

form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

28. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

29. On Saturday, October 1, 2016, using @RogerJStoneJr, STONE tweeted,

"Wednesday@HillaryClinton is done. #WikiLeaks."

30. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement AS SAN GE had scheduled for the next day from the balcony

of the Ecuadoran Embassy in London. On the day of the ASSANGE announcement-which was

part ofWikiLeaks' 10-year anniversary celebration- STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used@RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

31. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series oflewd remarks.

32. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #imWithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 18 of 48

33. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta-referring back to STONE's August 21,

2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

34. On March 27, 2017, CNN reported that a representative ofWikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta' s email ( speculation and conjecture) and the timing

or scope of their subsequent disclosures. So l am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

35. On October 13, 2016, while WikiLeaks was in the midst of releasing the hacked

Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 19 of 48

account @wikileaks. 1 The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

to rexamine the strategy of attacking me- cordially R."

36. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

37. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

38. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

39. In addition, @RogerJStoneJr also exchanged direct messages with AS SANGE,

the founder ofWikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with AS SAN GE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

1On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 20 of 48

issue an order restraining the paper from publishing additional articles. If the US govermnent

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

40. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Govermnent. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks

41. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, On October

17, 2017, Chief Judge Howell issued a search warrant for one of STONE's addresses,

On or about December 19, 2017, Chief Judge Howell issued a search

warrant for email account. On or about March 14, 2018, Chief Judge Howell

issued a search warrant for STONE's iCloud account. Information recovered pursuant to those

search warrants indicated the following:

42. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger

Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

appears to have forwarded the message to STONE at who replied to

CORSI that, "May meet Manafort -guarantee nothing."

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 21 of 48

43. On or about May 18, 2016, CORSI emailed STONE at

with the title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

44. On July 25, 2016, STONE, using sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

45. On or about July 31, 2016, STONE, using emailed

CORSI with the subject line, "Call me MON." The body of the email read: should see

Assange[.] should find Bernie [S]anders brother who called Bill a Rapist-tum him for

Trump[.] hould find or more proof of Bill getting kicked out."

46. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at

, "Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued, "Signs are Fox

will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HRC an artifact of rigged polling. Won't last. I expect presidential

campaign to get serious starting Sept. Still in pre-season games. Time to let more than Podesta to

be exposed as in bed w enemy if they are not ready to drop HRC. That appears to be the game

hackers are now about. Would not hurt to start suggesting HRC old, memory bad, has stroke --

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 22 of 48

neither he nor she well. I expect that much of next dump focus, setting stage for Foundation

debacle." Investigators believe that CORSI's reference to a "friend in embassy [who] plans 2

more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in 2016.

47. On or about August 5, 2016, an associate of STONE's, emailed

STONE at The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet AS SANGE. also stated

that in 2018, told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SANGE. STONE told he was joking and

had not actually met ASSANGE. 2

48. Through a search of STONE's iCloud account, the FBI has uncovered evidence

suggesting that STONE was in Los Angeles for one or more meetings at the time that he claimed,

in his email to to have "dined" with ASSANGE. For example, an associate of

STONE sent a text to STONE at approximately 3 :3 8PM on August 2, asking "How did ur meeting

go in LA?" STONE responded. "It's this afternoon[.]" The following day, the associate asked,

"Any report from ur meeting?" On or about August 4, 2016, STONE texted the associate, "Will

call later - heading for airport now[.]" Additionally, investigators have identified a photograph in

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 23 of 48

STONE's iCloud that appears to have been taken on August 3, 2016 and had geo-location

information indicating that it was taken in Los Angeles.

49. On or about August 15, 2016, CORSI emailed STONE at

"Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

50. On or about August 31, 2016, CORSI emailed STONE at

"Did you get the PODESTA writeup." STONE replied "[y]es."

51. On or.about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Yanukovych - Panama papers reveals Podesta hired by

S[b]erbank, Russia's largest financial institution-Podesta$$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

52. On or about September 6, 2016, CORSI emailed STONE at

"Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

53. On or about September 24, 2016, emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have

secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today." wrote back, "Awaiting secret file. Explosive ... Hope you are well.

Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators, indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 24 of 48

54. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange - what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON, who was CEO of the Campaign at the time, and wrote: "You should call Roger. See

below. You didn't get from me." BANNON wrote back, "I've got important stuff to worry

about." The associate responded, "Well clearly he knows what Assange has. I'd say that's

important."

55. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

ASSANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

56. On or about October 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

57. That same day, BANNON emailed STONE at "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawyer is a big

democrat."

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 25 of 48

58. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

59. According to a publicly available news article, 3 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."

60. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

61. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

62. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

63. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

3 https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07/31d74 714-8ce5-l l e6-875e-2c 1bfe943b66_story .html

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 26 of 48
II
I

64. At approximately 4:00PM, the Washington Post published a story regarding the
l
Access Hollywood tape.

65. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE using "I expect

that much of next dump focus, setting stage for Foundation debacle."

66. At approximately 6:27PM, an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks - The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using

forwarded message to CORSI without comment. STONE

does not appear to have forwarded the email to any other individual.

G. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

67. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed-

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job

numbers."

68. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

using emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 27 of 48

Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

69. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at both with the subject

line "Podesta talking points." Attached to the email was a file labeled, "ROGER STONE

podesta talking points Oct 12 2016.docx." The "talking points" included the statement that

"Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation."

70. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Hotmail Account, "Got them and used them."

71. On or about Thursday, October 13, 2016, CORSI emailed STONE at

"PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I'll give you one more-NOBODY YET HAS THIS[:] It looks to me

like skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 28 of 48

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

72. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

have had some back-channel communications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money did a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through

Metcombank, a Russian regional bank owned 99.978 percent by with the money

transferred via Deutsche Bank and Trust Company Americas in New York City, with the money

ending up in a private bank account in the Bank of America that is operated by the Clinton

Foundation?"

73. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

74. On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now - before 2pm[.J" STONE responded, "Missed u-just ·

landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

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75. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand off[.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. IfHRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election."

76. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

77. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice ofWikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta' s business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

78. On or about November 8, 2016, the United States presidential election took place.

79. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

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80. On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in

London. Have some interesting news for you."

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I. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikileaks

88. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCI). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic assertions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta's email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such assertions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trust me, it will soon be the Podesta' s
time in the barrel. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but
does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrutiny ....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.
I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
Assange to independently confirm this report, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
information proved to be correct. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

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89. In a document dated March 26, 2018 titled "Minority Views," Democratic

members ofHPSCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in
communication with Assange or communication through an intermediary with Assange,
you were only referring to a single fact that you had confirmed with the intermediary -
MR. STONE: That -
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is correct, even though it was repeated to me on numerous separate
occasions.

90. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an article on his website, stonecoldtrnth.com, titled "Is it the Podesta's

Time in the Barrel Yet?" In that article, STONE stated: "[I]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

J. STONE's Messaging to Randy CREDICO about STONE's "Back channel"

91. On or about November 19, 2017, Randy CREDICO (who, as described further

below, STONE publicly identified as his "intermediary" to AS SAN GE), messaged STONE, "My

lawyer wants to see me today." STONE responded, "'Stonewall it. Plead the fifth. Anything to

save the plan' ........ Richard Nixon[.]" CREDICO responded, "Ha ha."

92. On or about November 21, 2017, CREDICO messaged STONE, "I was told that

the house committee lawyer told my lawyer that I will be getting a subpoena[.]" STONE wrote

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back, "That was the point at which your lawyers should have told them you would assert your

5th Amendment rights if compelled to appear." They continued to message, and CREDICO

wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To do what? Nothing

happening in DC the day before Thanksgiving - why are u busting my chops?"

93. On or about November 24, 2017, STONE, texted CREDICO, "Assange is a

journalist and a damn good one- meeting with him is perfectly legal and all you ever told me was

he had the goods [o]n Hillary and would publish them - which he himself said in public b4 u told

me. It's a fucking witchunt [sic]." CREDICO replied, "I told you to watch his tweets. That's

what I was basing it on. I told you to watch his Tweets in October not before that I knew nothing

about the DNC stuff[.] I just followed his tweets[.]" STONE responded, "U never said anything

about the DNC but it was August." CREDICO wrote back, "It was not August because I didn't

interview him or meet him until August 26th[.] That was my first communication with his

secretary in London, August 26th." STONE wrote back, "Not the way I remember it - oh well I

guess Schiff will try to get one ofus indicted for perjury[.]"

94. STONE and CREDICO continued to exchange messages and on November 24,

2017, CREDICO wrote to STONE, "Forensic evidence proves that there is no back Charmel. So

now you can relax."

95. On or about November 28, 2017, CREDICO tweeted a copy of a subpoena he

received from HPSCI that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

96. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that "Credico merely []

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 35 of 48

confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credico never said he knew or had any information as to source or

content of the material."

97. On or about December 1, 2017, CREDICO messaged STONE, "I don't know why

you had to lie and say you had a back Channel now I had to give all of my forensic evidence to

the FBI today what a headache[.] 4 You could have just told him the truth that you didn't have a

back Channel they now know that I was not in London until September of this year[.] You had

no back-channel and you could have just told the truth ... You want me to cover you for perjury

now[.]'' STONE responded, "What the fuck is your problem? Neither ofus has done anything

wrong or illegal. You got the best press of your life and you can get away with asserting for 5th

Amendment rights ifu don't want talk about AND if you turned over anything to the FBI you're

a fool." CREDICO responded, "You open yourself up to six counts of perjury[.] But I'm sure

that wasn't sworn testimony so you're probably clear[.] Council for the committee knows you

never had a back Channel and if you had just told the truth wouldn't have put me in this bad spot

... you should go back ... and amend your testimony and tell them the truth." CREDICO

repeated: "you need to amend your testimony before I testify on the 15th." STONE replied, "If

you testify you're a fool. Because of tromp [sic] I could never get away with a certain [sic] my

Fifth Amendment rights but you can. I guarantee you you [sic] are the one who gets indicted for

perjury if you're stupid enough to testify[.]"

98. STONE and CREDICO continued to message each other on or about December 1,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

4 Contrary to his statement, CREDICO has not provided any forensic evidence to the FBI.
'

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 36 of 48

STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fuck off good night." CREDICO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

99. On or about December 13, 2017, according to public reporting, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

100. STONE and CREDICO continued to exchange text messages, and on or about

January 6, 2018, CREDICO indicated to STONE that he was having dinner with a reporter.

STONE responded, "Hope u don't fuck Up my efforts to get Assange a pardon[.]" CREDICO

messaged STONE, "I have the email from his chief of staff August 25th 2016 responding to an

email I sent to WikiLeaks website email address asking you would do my show[.] That was my

initial contact."

101. On or about January 8, 2018, CREDICO messaged STONE, stating: "Embassy

logs ... + 17 other pieces of information prove that I did not have any conversations with

Assange until September oflast year."

102. CREDICO and STONE continued to message each other, and on or about January

25, 2018, CREDICO wrote to STONE: "You lied to the house Intel committee ... But you'll get

off because you're friends with Trump so don't worry. I have all the forensic evidence[.] I was

not a ba[ck] Channel and I have all those emails from September of 2016 to prove it[.]"

103. On or about April 13, 2018, news reports stated that CREDICO had shown

reporters copies of email messages he had received from STONE in the prior few days that

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 37 of 48

from you," referring to CREDICO's therapy dog. CREDICO stated that it was "certainly scary .

. . When you start bringing up my dog, you're crossing the line[.]" 5

104. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

He was depressed about it. Or was he lying." The article noted that CREDICO stated he did not

have prostate cancer and did not have any such discussion with STONE.

K. Stone's Use of the Target Account

105. According to subscriber records, Target Account was

created on November 4, 2015 in the name of Roger Stone, and the last login to the account was

May29,2018. 7

106. Based on communications identified through a court-authorized search of

STONE's .Gmail account , I have learned that STONE used Target

Account to send and receive communications about WikiLeaks and

Assange:

107. For example, on or about March 21, 2018, STONE used the Target Account to

send an email with the subject, "Randy [Credico] and Me: The Truth about WikiLeaks." The

5 https://www.yahoo.com/news/comedian-randy-credico-says-trump-adviser-roger-stone-
threatened-dog0135911370.html
6 https://www.motherjones.com/politics/2018/05/roger-stone-to-associate-prepare-to-die/

7 The customer date of birth listed in the subscriber records is not STONE's birthdate. In my
training and experience, providers such as l&l. Mail do not verify customer dates of birth.

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 38 of 48

email appears to be a media blast sent to a distribution list that included STONE's Gmail account

In the email, STONE claimed, in substance and in part, that in 2016 he

had asked Credico to confirm that Assange had credible information on Clinton, and that Credico

"never said from whom he gained [the] confirmation, or the source, or the content of whatever

was coming."

108. At least one reporter also emailed STONE at the Target Account about

WikiLeaks and Assange. In particular, on or about May 11, 2018, a reporter with the

Washington Post emailed STONE at both nd Target Account

[email protected] about "a story on the Mueller investigation." The reporter described "a

scene when says he was asked about an email he received

from [STONE] that made reference to an upcoming meeting with Julian Assange." After noting

, STONE's position that no meeting with Assange ever occurred, the reporter also asked STONE,

in substance and in part, if he had anything further to add to the story.

I 09. On or about the same day, STONE responded from his Google account

stating that the email concerning a meeting with Assange was "a joke

made while trying to get off the phone." STONE also wrote, "Now would be a good time

for the Washington Post to report that the accusation there was an email that proved that I knew

about the contents of the WikiLeaks disclosures in advance has never been seen by the

Washington Post and was then ascribed to a 'phone call."'

BACKGROUND CONCERNING l&l MAIL

110. In my training and experience, I have learned that !&I Mail provides a variety of

on-line services, including electronic mail ("email") access, to the public. l&l Mail allows

subscribers to obtain email accounts at several domain names, including mail.com, like the Target

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 39 of 48

Account. Subscribers obtain an account by registering with l&l Mail. During the registration

process, l&l Mail asks subscribers to provide basic personal information. Therefore, the

computers of 1&1 Mail are likely to contain stored electronic communications (including retrieved

and unretrieved email for 1&1 Mail subscribers and information concerning subscribers and their

use of l&l Mail services, such as account access information, email transaction information, and

account application information. In my training and experience, such information may constitute.

evidence of the crimes under investigation because the information can be used to identify the

account's user or users.

111. In my training and experience, email providers generally ask their subscribers to

provide certain personal identifying information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and other

identifiers, alternative email addresses, and, for paying subscribers, means and source of payment

(including any credit or bank account number). In my training and experience, such information

may constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users. Based on my training and my experience, I know that, even if

subscribers insert false information to conceal their identity, this information often provides clues

to their identity, location, or illicit activities.

112. In my training and experience, email providers typically retain certain transactional

information about the creation and use of each account on their systems. This information can

include the date on which the account was created, the length of service, records of log-in

(i.e., session) times and durations, the types of service utilized, the status of the account (including

whether the account is inactive or closed), the methods used to connect to the account (such as

logging into the account via the provider's website), and other log files that reflect usage of the

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 40 of 48

account. In addition, email providers often have records of the Internet Protocol address

("IP address") used to register the account and the IP addresses associated with particular logins

to the account. Because every device that connects to the Internet must use an IP address,

IP address information can help to identify which computers or other devices were used to access

the email account.

113. In my training and experience, m some cases, email account users will

communicate directly with an email service provider about issues relating to the account, such as

technical problems, billing inquiries, or complaints from other users. Email providers typically

retain records about such communications, including records of contacts between the user and the

provider's support services, as well as records of any actions taken by the provider or user as a

result of the communications. In my training and experience, such information may constitute

evidence of the crimes under investigation because the information can be used to identify the

account's user or users.

114. This application seeks a warrant to search all responsive records and information

under the control of 1& I Mail, a provider subject to the jurisdiction of this court, regardless of

where 1& 1 Mail has chosen to store such information. The government intends to require the

disclosure pursuant to the requested warrant of the contents of wire or electronic communications

and any records or other information pertaining to the customers or subscribers if such

communication, record, or other information is within l&l Mail's possession, custody, or control,

regardless of whether such communication, record, or other information is stored, held, or

maintained outside the United States.

115. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" ofthe criminal conduct

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 41 of 48

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of occupancy"

while executing a search warrant at a residence. For example, email communications, contacts

lists, and images sent. (and the data associated with the foregoing, such as date and time) may

indicate who used or controlled the account at a relevant time. Further, information maintained by

the email provider can show how and when the account was accessed or used. For example, as

described below, email providers typically log the Internet Protocol (IP) addresses from which

users access the email account, along with the time and date of that access. By determining the

physical location associated with the logged IP addresses, investigators can understand the

chronological and geographic context of the email account access and use relating to the crime

under investigation. This geographic and timeline information may tend to either inculpate or

exculpate the account owner. Additionally, information stored at the user's account may further

indicate the geographic location of the account user at a particular time (e.g., location information

integrated into an image or video sent via email). Last, stored electronic data may provide relevant

insight into the email account owner's state of mind as it relates to the offense under investigation.

For example, information in the email account may indicate the owner's motive and intent to

commit a crime (e.g., communications relating to the crime), or consciousness of guilt

(e.g., deleting communications in an effort to conceal them from law enforcement).

FILTER REVIEW PROCEDURES

116. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 42 of 48

with professional responsibility requirements concerning the maintenance of attorney-client and

other operative privileges. The procedures include use, if necessary, of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

CONCLUSION

117. Based on the forgoing, I request that the Court issue the proposed search warrant.

118. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

119. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,
'
/~ /-1 . .d-1; ~
~ d e '1'
Special Agent
Federal Bureau ofinvestigation

Subscribed and sworn to before me on this~ day of August, 2018.

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 43 of 48

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following l&l Mail accounts,

which are stored at premises owned, maintained, controlled, or operated by l&l Mail & Media,

Inc. ("l&l Mail"), a company headquartered in Chesterbrook, Pennsylvania:

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 44 of 48

ATTACHMENT B

I. Information to be disclosed by l&l Mail

To the extent that the information described in Attachment A is within the possession,

custody, or control of l&l Mail & Media, Inc. ("1&1 Mail"), including any messages, records,

files, logs, or information that have been deleted but are still available to 1& 1 Mail, or have been

preserved pursuant to a request made under 18 U.S.C. § 2703(f), l&l Mail is required to disclose

the following information to the government for each account listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date and time at which each

email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the account, to

include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the

account, including address books, contact and buddy lists, calendar data, pictures,

and files;

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Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 45 of 48

e. All records pertaining to communications between the Provider and any person

regarding the account, including contacts with support services and records of

actions taken;

f. All subscriber "change history" associated with the account;

g. All search history and web history associated with the account;

h. All location and maps information associated with the account;

i. All device information associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Number

("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), or

International Mobile Equipment Identities ("IMEI")); and

J. For any accounts linked to the accounts listed in Attachment A, including accounts

linked by cookie, SMS number, or recovery email address, and for accounts for

which the accounts described in Attachment A are the recovery email address,

provide all records or other information regarding the identification of the account,

to include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number).

-3-
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II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June I, 2015 to the present, including:

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

. b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange Randy Credico, or any

individual associated with the Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure;

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

-4-
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 47 of 48

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

I. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

-5-
Case 1:19-mc-00029-CRC Document 29-21 Filed 04/28/20 Page 48 of 48

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

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AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of


Case: 1: 18-sc-02905
(Briefly describe the property to be searched
or identify the person by name and address) Assigned To: Howell, Beryl A.
Assign. Date : 9/26/2018
INFORMATION ASSOCIATED WITH ONE ACCOUNT
STORED AT PREMISES Description: Search & Seizure Warrant
CONTROLLED BY TWITTER )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before October 9, 2018 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to 10:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell., Ch ief U.S. District Judge
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3 !03a(b ), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued: -tkl2P1J?g:/- f..:. (}o/;); Judge 's signature

City and state: Wash ington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
- - - - - - -- - - - --- Printed name and title
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 2 of 59

AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 3 of 59

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Twitter accounts, which

are stored at premises owned, maintained, controlled, or operated by Twitter, Inc. ("Twitter"), a

company headquartered in San Francisco, California:

-1-
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 4 of 59

ATTACHMENT B

I. Information to be disclosed by Twitter

To the extent that the information described in Attachment A is within the possession,

custody, or control of Twitter, Inc. ("Twitter"), including any messages, records, files, logs, or

information that have been deleted but are still available to Twitter, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(f), Twitter is required to disclose the following

information to the government for each account listed in Attachment A:

A. All "Tweets" and Direct Messages sent, received, "favorited," or retweeted by the account,
and all photographs or images included in those Tweets and Direct Messages;

B. The content of all communications (public or private) sent to or from, stored in draft form
in, or otherwise associated with the account, including the content of all messages,
attachments, and header information;

C. All data and information associated with the profile page, including photographs, "bios,"
and profile backgrounds and themes;

D. All other content associated with the account, including, but not limited to, posts,
documents, spreadsheets, photos, and videos;

E. All information from the "Connect" tab for the account, including all lists of Twitter users
who have favorited or retweeted Tweets posted by the account, as well as a list of all Tweets
that include the username associated with the account (i.e., "mentions" or "replies");

F. All photographs and images in the user gallery for the account;

G. All location data associated with the account, including all information collected by the
"Tweet With Location" service;

H. All information about the account's use of Twitter' s link service, including all longer
website links that were shortened by the service, all resulting shortened links, and all
information about the number of times that a link posted by the account was clicked;

I. All data and information that has been deleted by the user;

J. A list of all of the people that the user follows on Twitter and all people who are following
the user (i.e., the user's "following" list and "followers" list);

K. A list of all users that the account has "unfollowed" or blocked;

L. All "lists" created by the account;

-2-
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 5 of 59

M. All information on the "Who to Follow" list for the account;

N. All privacy and account settings;

0. All records of Twitter searches performed by the account, including all past searches saved
by the account;

P. All current and historical subscriber and payment information, including full name, e-mail
address (including any secondary or recovery email addresses), physical address (including
city, state, and zip code), date of birth, gender, hometown, occupation, telephone number,
websites, screen names, user identification numbers, security questions and answers,
registration IP address, payment history, and other personal identifiers;

Q. All email addresses and telephone numbers ever registered (whether successfully or not)
to the account, including dates of any changes and the IP addresses used for any changes;

R. All past and current usernames, account passwords, and names associated with the account,
including dates of any changes and the IP addresses used for any changes;

S. All data and information associated with the profile page, including photographs;

T. All advertising data relating to the account, including, but not limited to, information
regarding unique advertising IDs associated with the user, any devices used to access the
account, application IDs, UDIDs, payment information (including, but not limited to, full
credit card numbers and expiration dates and PayPal accounts), ads clicked, and ads
created;

U. The dates and times at which the account and profile were created, and the Internet Protocol
("IP") address at the time of sign-up;

V. All transactional records associated with the account, including any IP logs or other records
of session times and durations;

W. Any information identifying the device or devices used to access the account, including a
device serial number, a GUID or Global Unique Identifier, a phone number, serial numbers,
MAC addresses, Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers
("MEIN"), Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers
("MIN"), Subscriber Identity Modules ("SIM"), Mobile Subscriber Integrated Services
Digital Network Number ("MSISDN"), International Mobile Subscriber Identifiers
("IMSI"), or International Mobile Equipment Identities ("IMEi"), and any other
information regarding the types of devices used to access the account;

X. All activity logs for the account;

Y. All location information for the account, including all location data collected by any
plugins or widgets;

Z. The types of service utilized by the user;

-3-
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 6 of 59

AA. All information about the account's use ofTwitter's link service, including all website links
embedded in, exporting data to, or importing data from, the account's website or blog;

BB. All full website links that were shortened by Twitter's link service, all resulting shortened
links, and all information about the number of times that a link posted by the account was
clicked;

CC. All information about connections between the account and third-party websites and
applications, including any Twitter, Face book or other social networking accounts to which
posts from the account are sent;

DD. All data and information that has been deleted by the user;

EE. The length of service (including start date) and the means and source of any payments
associated with the service (including any credit card or bank account number);

FF. All privacy settings and other account settings, including email addresses or other accounts
that the account has blocked;

GG. Information regarding linked accounts, including accounts linked by cookie, IP address
(including registration IP address), advertising ID, User Client UUID, User Guest Cookie
ID, Known Device Token, Normalized Email Address, Android ID, IMEi, GUID, device
identifier, or any other account or device identifier;

HH. Information regarding accounts linked to accounts to which the Target Accounts are linked;

II. All records pertaining to communications between the Service Provider and any person
regarding the user or the user's account with the Service Provider, including contacts with
support services, records of actions taken, and investigative or user complaints concerning
the subscriber.

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from March 1, 2016 to the present, including:

-4-
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 7 of 59

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, , Randy Credico, any

individual associated with the Trump Campaign, or any witness in the

investigation;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f.. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

-5-
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 8 of 59

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s );

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

I. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 9 of 59

III. Review Protocols

Review of the items described in Attachment A and Attachment B shall be conducted

pursuant to established procedures designed to collect evidence in a manner consistent with

professional responsibility requirements concerning the maintenance of attorney-client and other

operative privileges. When appropriate, the procedures shall include use of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

-7-
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 10 of 59
AO 106 (Rev. 04/10) Application for a Search Warrant

UNITED STATES DISTRICT COURT


for the
F
District of Columbia SEP 2. 6 2018
fWk U.S. District & Bankrupt(;Y
In the Matter of the Search of )
r.~~~ts for tila 0\!Hict Di f,{llumbla
Case: 1: 18-sc-02905 1
(JJricjly describe ihe p roperty to be searched )
or ide mijj, 1/w person by name and address) Ass!gned To: Howell, Beryl A.
)
INFORMATION ASSOCIATED WITH )
ONE ACCOUNT STORED AT PREMISES CONTROLLED
Assign. Date : 9/26/2018
)
BY TWITTER ) Description: Search & Seizure Warrant

APPLICATION FOR A SEARCH WARRANT


I, a foderal Jaw enfo rcement officer or an attorney for the government, request a search wa1rnnt and state under
penalty of pe1jury that I have reason to beli.eve that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A
located in the - --
Northern
- - - --
District of California
_ __ ____c:....;......;.;__.- - - - " - - --
, there is now concealed (identify the
person or describe the property to be seized):
See Attachment B

The basis for the search under Fed. R. Crim. P. 41 ( c) is (check one or more):
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
~ p~operty designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
52 U.S.C. § 30121 Foreign Contribution Ban
18 U.S.C. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

b/ Continued on the attached sheet.


0 Delayed notice of _ _ days (give exact ending date if more than 30 days: _ _ __ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA: Applicant's signature

IKyle R. Freeny (ASC) Patrick J. Myers, Special Agent, FBI


Printed name a.nd title

Sworn to before me and signed in my presence.

Judge's signature

City and state: Washington, D.C. Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 11 of 59

SEP 2 6 2016
IN THE UNITED STATES DISTRICT COURT
Clsrk, U.S. Dlst(fct & Bankruptcy
FOR THE DISTRICT OF COLUMBIA Courts for the Dfstrlct of Columbia

IN THE MATTER OF THE SEARCH OF Case: 1:18-sc-02905


INFORMATION AS SOCIA TED WITH Assigned To : Howell, Beryl A.
ONE ACCOUNT STORED AT PREMISES Assign. Date : 9/26/2018
CONTROLLED BY TWITTER, INC.
Description: Search & Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Patrick J. Myers, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the Twitter account , which is

stored at premises owned, maintained, controlled or operated by Twitter, Inc. ("Twitter"), a

company headquartered in San Francisco, California.

Upon receipt of the information described in Attachment A, government-authorized persons will

review that information to locate the items described in Attachment B.

2. I am a Special Agent with the Federal Bureau of Investigation ("FBI") assigned to

FBI Pittsburgh working directly with the Special Counsel's Office. I have been a Special Agent

with the FBI since 2017. I was previously employed as a network and software engineer for

approximately fifteen years, including for the FBI. As a Special Agent, I have conducted national

security investigations relating to foreign intelligence and cybersecurity.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

-1-
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 12 of 59

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Account contains evidence, fruits, or

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a protected

computer), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud), 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C. § 1513 (witness

tampering), and 52 U.S.C. § 30121(a)(l)(C) (foreign expenditure ban). There also is probable

cause to search the information described in Attachment A for evidence, contraband, fruits,

and/or instrumentalities of the Subject Offenses, further described in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(l)(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

PROBABLE CAUSE

A. Background on Relevant Individuals

i. Roger STONE

6. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

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Donald J. Trump (the "Campaign") until August 2015 . Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

7. Jerome CORSI is a political commentator who, according to publicly available

information, currently serves as the "Washington Bureau Chief for Inforwars.com." According

to publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WND.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

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B. Russian Government-Backed Hacking Activity During the 2016 Presidential


Election

9. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Government developed a clear preference for President-elect Trump.

10. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

11. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities

to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

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in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

12. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

13. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

14. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

15. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

16. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

17. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

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18. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

presidential election, including conspiracy to commit authorized access to protected computers.

See United States v. Viktor Borisovich Netyksho, et al. (Case No. 1: 18-cr-OO 125).

C. STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

19. On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

20. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

the DNC.

21. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

22. On August 8, 2016, STONE addressed the Southwest Broward Republican

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Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

aimed at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With

regard to the October surprise, what would be your forecast on that given what Julian Assange

has intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain

to the Clinton Foundation but there's no telling what the October surprise may be." A few days

later, STONE clarified that while he was not personally in touch with ASSANGE, he had a close

friend who served as an intermediary.

23. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

24. On August 13, 2016, STONE posted a tweet using @RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

25. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me ifl can help u anyhow. it would be a great pleasure to me."

26. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

27. On August 21, 2016, using@RogerJStoneJr, STONE tweeted: "Trust me, it will

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soon the [sic] Podesta's time in the barrel. #CrookedHillary." In a C-SPAN interview that same

day, STONE reiterated that because of the work of a '"mutual acquaintance' of both his and

[ASSANGE], the public [could] expect to see much more from the exiled whistleblower in the

form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

28. On September 16., 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

29. On Saturday, October 1, 2016, using @RogerJStoneJr, STONE tweeted,

"Wednesday @ HillaryClinton is done. #WikiLeaks."

30. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement AS SANGE had scheduled for the next day from the balcony

of the Ecuadoran Embassy in London. On the day of the AS SAN GE announcement - which was

part of WikiLeaks' 10-year anniversary celebration - STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used @RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

31. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

32. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

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"RELEASE: The Podesta Emails #HillaryClinton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

33. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta-referring back to STONE's August 21,

2016 C-SP AN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

34. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

35. On October 13, 2016, while WikiLeaks was in the midst ofreleasing the hacked

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Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

account @wikileaks. 1 The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

to rexamine the strategy of attacking me- cordially R."

36. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

37. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

38. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

39. In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE,

the founder of WikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with ASSANGE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

1
On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
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indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

40. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks

41. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, On October

17, 2017, Chief Judge Howell issued a search warrant for one of STONE's addresses,

On or about December 19, 2017, Chief Judge Howell issued a search

warrant for email account. On or about March 14, 2018, Chief Judge Howell

issued a search warrant for STONE's iCloud account. Information recovered pursuant to those

search warrants indicated the following:

42. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger

Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

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appears to have forwarded the message to STONE a who replied to

CORSI that, "May meet Manafort -guarantee nothing."

43. On or about May 18, 2016, CORSI emailed STONE a

with the title, "Roger -- why don't you look this over before I send it to I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

44. On July 25, 2016, STONE, using sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

45. On or about July 31, 2016, STONE, using emailed

CORSI with the subject line, "Call me MON." The body of the email read: should see

Assange[.] should find Bernie [S]anders brother who called Bill a Rapist- turn him for

Trump[.] should find or more proof of Bill getting kicked out."

46. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at

"Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued, "Signs are Fox

will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HRC an artifact of rigged polling. Won't last. I expect presidential

campaign to get serious starting Sept. Still in pre-season games. Time to let more than Podesta to

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be exposed as in bed w enemy if they are not ready to drop HRC. That appears to be the game

hackers are now about. Would not hurt to start suggesting HRC old, memory bad, has stroke --

neither he nor she well. I expect that much of next dump focus, setting stage for Foundation

debacle." Investigators believe that CORSI's reference to a "friend in embassy [who] plans 2

more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in 2016.

47. On or about August 5, 2016, an associate of STONE's, emailed

STONE at The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet ASSANGE. also stated

that in 2018, told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SAN GE. STONE told he was joking and

had not actually met AS SAN GE. 2

48. Through a search of STONE's iCloud account, the FBI has uncovered evidence

suggesting that STONE was in Los Angeles for one or more meetings at the time that he claimed,

in his email to to have "dined" with ASSANGE. For example, an associate of

STONE sent a text to STONE at approximately 3:38PM on August 2, asking "How did ur meeting

go in LA?" STONE responded. "It's this afternoon[.]" The following day, the associate asked,

"Any report from ur meeting?" On or about August 4, 2016, STONE texted the associate, "Will

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call later - heading for airport now[.]" Additionally, investigators have identified a photograph in

STONE's iCloud that appears to have been taken on August 3, 2016 and had geo-location

information indicating that it was taken in Los Angeles.

49. On or about August 15, 2016, CORSI emailed STONE at

"Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

50. On or about August 31, 2016, CORSI emailed STONE at

Did you get the PODESTA writeup." STONE replied "[y]es."

51. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Yanukovych - Panama papers reveals Podesta hired by

S[b]erbank, Russia's largest financial institution- Podesta$$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

52. On or about September 6, 2016, CORSI emailed STONE at

Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

53. On or about September 24, 2016, emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have

secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today." wrote back, "Awaiting secret file. Explosive ... Hope you are well.

Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

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54. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange - what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON, who was CEO of the Campaign at the time, and wrote: "You should call Roger. See

below. You didn't get from me." BANNON wrote back, "I've got important stuff to worry

about." The associate responded, "Well clearly he knows what Assange has. I'd say that's

important."

55. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

AS SANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

56. On or about October 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

57. That same day, BANNON emailed STONE at "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawyer is a big

democrat."

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58. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

59. According to a publicly available news article, 3 at approximately 11 AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."

60. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

61. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

62. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

63. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

3
https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07 /31d74 714-8ce5-11e6-875 e-2cl bfe94 3b66_story.html

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64. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

65. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE usin "I expect

that much of next dump focus, setting stage for Foundation debacle."

66. At approximately 6:27PM an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks -The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using

forwarded message to CORSI without comment. STONE

does not appear to have forwarded the email to any other individual.

G. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

67. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed-

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job

numbers."

68. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

usin emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

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Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

69. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at both and with the subject

line "Podesta talking points." Attached to the email was a file labeled, "ROGER STONE

podesta talking points Oct 12 2016.docx." The "talking points" included the statement that

"Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation."

70. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Account, "Got them and used them."

71. On or about Thursday, October 13, 2016, CORSI emailed STONE at

"PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, ''Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I'll give you one more -NOBODY YET HAS THIS[:] It looks to me

like skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

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Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

72. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

have had some back-channel communications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money did , a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through

Metcombank, a Russian regional bank owned 99.978 percent by with the money

transferred via Deutsche Bank and Trust Company Americas in New York City, with the money

ending up in a private bank account in the Bank of America that is operated by the Clinton

Foundation?"

73. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

74. On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now- before 2pm[.]" STONE responded, "Missed u- just

landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

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75. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand off[.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. IfHRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election."

76. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

77. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no'advance notice ofWikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta's business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

78. On or about November 8, 2016, the United States presidential election took place.

79. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

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80. On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in

London. Have some interesting news for you."


Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 32 of 59
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 33 of 59

I. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikileaks

88. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCI). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic assertions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta's email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such asse1iions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trust me, it will soon be the Podesta's
time in the barrel. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but
does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrutiny ....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.
I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
Assange to independently confirm this report, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
information proved to be con-ect. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

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89. In a document dated March 26, 2018 titled "Minority Views," Democratic

members of HPSCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement heen in any type of contact with Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in
communication with Assange or communication through an intermediary with Assange,
you were only referring to a single fact that you had confirmed with the intermediary -
MR. STONE: That -
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is correct, even though it was repeated to me on numerous separate
occasions.

90. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an article on his website, stonecoldtruth.com, titled "Is it the Podesta's

Time in the Ban-el Yet?" In that aiiicle, STONE stated: "[l]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

J. STONE's Messaging to Randy CREDICO about STONE's "Back channel"

91. On or about November 19, 2017, Randy CREDICO (who, as described further

below, STONE publicly identified as his "intermediary" to ASSANGE), messaged STONE, "My

lawyer wants to see me today." STONE responded, "'Stonewall it. Plead the fifth. Anything to

save the plan' ........ Richard Nixon[.]" CREDI CO responded, "Ha ha."

92. On or about November 21, 2017, CREDICO messaged STONE, "I was told that

the house committee lawyer told my lawyer that I will be getting a subpoena[.]" STONE wrote

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back, "That was the point at which your lawyers should have told them you would assert your

5th Amendment rights if compelled to appear." They continued to message, and CREDI CO

wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To do what? Nothing

happening in DC the day before Thanksgiving - why are u busting my chops?"

93. On or about November 24, 2017, STONE, texted CREDICO, "Assange is a

journalist and a damn good one- meeting with him is perfectly legal and all you ever told me was

he had the goods [o]n Hillary and would publish them - which he himself said in public b4 u told

me. It's a fucking witchunt [sic]." CREDICO replied, "I told you to watch his tweets. That's

what I was basing it on. I told you to watch his Tweets in October not before that I knew nothing

about the DNC stuff[.] I just followed his tweets[.]" STONE responded, "U never said anything

about the DNC but it was August." CREDICO wrote back, "It was not August because I didn't

interview him or meet him until August 26th[.] That was my first communication with his

secretary in London, August 26th." STONE wrote back, "Not the way I remember it - oh well I

guess Schiff will try to get one of us indicted for perjury[.]"

94. STONE and CREDICO continued to exchange messages and on November 24,

2017, CREDICO wrote to STONE, "Forensic evidence proves that there is no back Channel. So

now you can relax."

95. On or about November 28, 2017, CREDICO tweeted a copy of a subpoena he

received from HP SCI that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

96. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that "Credico merely[]

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confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credico never said he knew or had any information as to source or

content of the material."

97. On or about December 1, 2017, CREDICO messaged STONE, "I don't know why

you had to lie and say you had a back Channel now I had to give all of my forensic evidence to

the FBI today what a headache[.] 4 You could have just told him the truth that you didn't have a

back Channel they now know that I was not in London until September of this year[.] You had

no back-channel and you could have just told the truth ... You want me to cover you for pe1jury

now[.]" STONE responded, "What the fuck is your problem? Neither of tis has done anything

wrong or illegal. You got the best press of your life and you can get away with asserting for 5th

Amendment rights ifu don't want talk about AND if you turned over anything to the FBI you're

a fool." CREDICO responded, "You open yourself up to six counts of perjury[.] But I'm sure

that wasn't sworn testimony so you're probably clear[.] Council for the committee knows you

never had a back Channel and if you had just told the truth wouldn't have put me in this bad spot

... you should go back ... and amend your testimony and tell them the truth." CREDICO

repeated: "you need to amend your testimony before I testify on the 15th." STONE replied, "If

you testify you' re a fool. Because of tromp [sic] I could never get away with a certain [sic] my

Fifth Amendment rights but you can. I guarantee you you [sic] are the one who gets indicted for

perjury if you' re stupid enough to testify[.]"

98. STONE and CREDICO continued to message each other on or about December 1,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

4
Contrary to his statement, CREDICO had not provided any forensic evidence to the FBI.

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Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 37 of 59

STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't kriow how to tell his guys to

fuck off good night." CREDICO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

99. On or about December 13, 2017, according to public reporting, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

100. STONE and CREDICO continued to exchange text messages, and on or about

January 6, 2018, CREDICO indicated to STONE that he was having dinner with a reporter.

STONE responded, "Hope u don't fuck Up my efforts to get Assange a pardon[.]" CREDICO

messaged STONE, "I have the email from his chief of staff August 25th 2016 responding to an

email I sent to WikiLeaks website email address asking you would do my show[.] That was my

initial contact."

101. On or about January 8, 2018, CREDICO messaged STONE, stating: "Embassy

logs ... + 17 other pieces of information prove that I did not have any conversations with

Assange until September of last year."

I 02. CREDI CO and STONE continued to message each other, and on or about January

25, 2018, CREDICO wrote to STONE: "You lied to the house Intel committee ... But you'll get

off because you're friends with Trump so don't worry. I have all the forensic evidence[.] I was

not a ba[ck] Channel and I have all those emails from September of2016 to prove it[.]"

103. On or about April 13, 2018, news repo1is stated that CREDICO had shown

reporters copies of email messages he had received from STONE in the prior few days that

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

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Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 38 of 59

from you," referring to CREDICO's therapy dog. CREDJCO stated that it was "ce11ainly scary .

. . When you start bringing up my dog, you're crossing the line[.]" 5

104. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

He was depressed about it. Or was he lying." The article noted that CREDICO stated he did not

have prostate cancer and did not have any such discussion with STONE.

K. The Target Account

5
https ://www.yahoo.com/news/comedian-randy-credico-says-trump-adviser-ro ger-stone-
threatened-dog-135911370 .html
6
https://www.motherjones.com/politics/2018/05/roger-stone-to-associate-prepare-to-die/

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Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 39 of 59

BACKGROUND CONCERNING TWITTER

110. Twitter owns and operates a free-access social-networking website of the same

name that can be accessed at http://www.twitter.com. Twitter allows its users to create their own

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profile pages, which can include a short biography, a photo of themselves, and location

information. Twitter also pennits users create and read 140-character messages called "Tweets,"

and to restrict their "Tweets" to individuals whom they approve. These features are described in

more detail below.

111. Upon creating a Twitter account, a Twitter user must create a unique Twitter

usemame and an account password, and the user may also select a different name of 20

characters or fewer to identify his or her Twitter account. The Twitter user may also change this

usemame, password, and name without having to open a new Twitter account.

112. Twitter asks users to provide basic identity and contact information, either during

the registration process or thereafter. This information may include the user's full name, e-mail

addresses, physical address (including city, state, and zip code), date of birth, gender, hometown,

occupation, and other personal identifiers. For each user, Twitter may retain information about

the date and time at which the user's profile was created, the date and time at which the account

was created, and the Internet Protocol ("IP") address at the time of sign-up. Because every

device that connects to the Internet must use an IP address, IP address information can help to

identify which computers or other devices were used to access a given Twitter account.

113. A Twitter user can post a personal photograph or image (also known as an

"avatar") to his or her profile, and can also change the profile background or theme for his or her

account page. In addition, Twitter users can post "bias" of 160 characters or fewer to their profile

pages.

114. Twitter also keeps IP logs for each user. These logs contain information about the

user's logins to Twitter including, for each access, the IP address assigned to the user and the

date stamp at the time the user accessed his or her profile.

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115. As discussed above, Twitter users can use their Twitter accounts to post "Tweets"

of 140 characters or fewer. Each Tweet includes a timestamp that displays when the Tweet was

posted to Twitter. Twitter users can also "favorite," "retweet," or reply to the Tweets of other

users. In addition, when a Tweet includes a Twitter username, often preceded by the @ sign,

Twitter designates that Tweet a "mention" of the identified user. In the "Connect" tab for each

account, Twitter provides the user with a list of other users who have "favorited" or "retweeted"

the user's own Tweets, as well as a list of all Tweets that include the user's username (i.e., a list

of all "mentions" and "replies" for that username ).

116. Twitter users can include photographs or images in their Tweets. Each Twitter

account also 'is provided a user gallery that includes images that the user has shared on Twitter,

including images uploaded by other services.

117. Twitter users can also opt to include location data in their Tweets, which will

reveal the users' locations at the time they post each Tweet. This "Tweet With Location"

function is off by default, so Twitter users must opt in to the service. In addition, Twitter users

may delete their past location data.

118. When Twitter users want to post a Tweet that includes a link to a website, they

can use Twitter's link service, which converts the longer website link into a shortened link that

begins with http://t.co. This link service measures how many times a link has been clicked.

119. A Twitter user can "follow" other Twitter users, which means subscribing to

those users' Tweets and site updates. Each user profile page includes a list of the people who are

following that user (i.e., the user's "followers" list) and a list of people whom that user follows

(i.e., the user's "following" list). Twitters users can "unfollow" users whom they previously

followed, and they can also adjust the privacy settings for their profile so that their Tweets are

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visible only to the people whom they approve, rather than to the public (which is the default

setting). A Twitter user can also group other Twitter users into "lists" that display on the right

side of the user's home page on Twitter. Twitter also provides users with a list of "Who to

Follow," which includes a few recommendations of Twitter accounts that the user may find

interesting, based on the types of accounts that the user is already following and who those

people follow.

120. In addition to posting Tweets, a Twitter user can also send Direct Messages

(DMs) to one of his or her followers. These messages are typically visible only to the sender and

the recipient, and both the sender and the recipient have the power to delete the message from the

inboxes of both users. As of January 2012, Twitter displayed only the last 100 DMs for a

particular user, but older DMs are stored on Twitter's database.

121. Twitter users can configure the settings for their Twitter accounts in numerous

ways. For example, a Twitter user can configure his or her Twitter account to send updates to the

user's mobile phone, and the user can also set up a "sleep time" during which Twitter updates

will not be sent to the user's phone.

122. Twitter includes a search function that enables its users to search all public

Tweets for keywords, usernames, or subject, among other things. A Twitter user may save up to

25 past searches.

123. Twitter users can connect their Twitter accounts to third-party websites and

applications, which may grant these websites and applications access to the users' public Twitter

profiles.

124. If a Twitter user does not want to interact with another user on Twitter, the first

user can "block" the second user from following his or her account.

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125. In some cases, Twitter users may communicate directly with Twitter about issues

relating to their account, such as technical problems or complaints. Social-networking providers

like Twitter typically retain records about such communications, including records of contacts

between the user and the provider's support services, as well as records of any actions taken by

the provider or user as a result of the communications. Twitter may also suspend a particular user

for breaching Twitter' s terms of service, during which time the Twitter user will be prevented

from using Twitter's services.

126. As explained herein, information stored in connection with a Twitter account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, a

Twitter user's account information, IP log, stored electronic communications, and other data

retained by Twitter, can indicate who has used or controlled the Twitter account. This "user

attribution" evidence is analogous to the search for "indicia of occupancy" while executing a

search warrant at a r~sidence. For example, profile contact information, communications,

"tweets" (status updates) and "tweeted" photos (and the data associated with the foregoing, such

as date and time) may be evidence of who used or controlled the Twitter account at a relevant

time. Further, Twitter account activity can show how and when the account was accessed or

used. For example, as described herein, Twitter logs the Internet Protocol (IP) addresses from

which users access their accounts along with the time and date. By determining the physical

location associated with the logged IP addresses, investigators can understand the chronological

and geographic context of the account access and use relating to the crime under investigation.

Such information allows investigators to understand the geographic and chronological context of

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Twitter access, use, and events relating to the crime under investigation. Additionally, Twitter

builds geo-location into some of its services. If enabled by the user, physical location is

automatically added to "tweeted" communications. This geographic and timeline information

may tend to either inculpate or exculpate the Twitter account owner. Last, Twitter account

activity may provide relevant insight into the Twitter account owner's state of mind as it relates

to the offense under investigation. For example, information on the Twitter account may

indicate the owner's motive and intent to commit a crime (e.g., information indicating a criminal

plan) or consciousness of guilt (e.g., deleting account information in an effort to conceal

evidence from law enforcement).

127. Therefore, the computers of Twitter are likely to contain all the material described

above, including stored electronic communications and information concerning subscribers and

their use of Twitter, such as account access information, transaction information, and other account

information.

FILTER REVIEW PROCEDURES

128. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

with professional responsibility requirements concerning the maintenance of attorney-client and

other operative privileges. The procedures include use, if necessary, of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

CONCLUSION

129. Based on the forgoing, I request that the Court issue the proposed search warrant.

130. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

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REQUEST FOR SEALING

131. I fmther request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until further order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

c~
Special Agent
Federal Bureau of Investigation

Subscribed and sworn to before me on this ~,1Zy of September, 2018.

~d/~
The Honorable Beryl A. Howell
Chief United States District Judge

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ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Twitter accoun~s, which

are stored at premises owned, maintained, controlled, or operated by Twitter, Inc. ("Twitter"), a

company headquartered in San Francisco, California:

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Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 47 of 59

ATTACHMENT B

I. Information to be disclosed by Twitter

To the extent that the info1mation described in Attachment A is within the possession,

custody, or control of Twitter, Inc. ("Twitter"), including any messages, records, files, logs, or

information that have been deleted but are still available to Twitter, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(f), Twitter is required to disclose the following

information to the government for each account listed in Attachment A:

A. All "Tweets" and Direct Messages sent, received, "favorited," or retweeted by the account,
and all photographs or images included in those Tweets and Direct Messages;

B. The content of all communications (public or private) sent to or from, stored in draft form
in, or otherwise associated with the account, including the content of all messages,
attachments, and header information;

C. All data and information associated with the profile page, including photographs, "bios,"
and profile backgrounds and themes;

D. All other content associated with the account, including, but not limited to, posts,
documents, spreadsheets, photos, and videos;

E. All information from the "Connect" tab for the account, including all lists of Twitter users
who have favorited or retweeted Tweets posted by the account, as well as a list of all Tweets
that include the username associated with the account (i.e., "mentions" or "replies");

F. All photographs and images in the user gallery for the account;

G. All location data associated with the account, including all information collected by the
"Tweet With Location" service;

H. All information about the account's use of Twitter's link service, including all longer
website links that were shortened by the service, all resulting shortened links, and all
information about the number of times that a link posted by the account was clicked;

I. All data and information that has been deleted by the user;

J. A list of all of the people that the user follows on Twitter and all people who are following
the user (i.e., the user's "following" list and "followers" list);

K. A list of all users that the account has "unfollowed" or blocked;

L. All "lists" created by the account;

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Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 48 of 59

M. All information on the "Who to Follow" list for the account;

N. All privacy and account settings;

0. All records of Twitter searches performed by the account, including all past searches saved
by the account;

P. All current and historical subscriber and payment information, including full name, e-mail
address (including any secondary or recovery email addresses), physical address (including
city, state, and zip code), date of birth, gender, hometown, occupation, telephone number,
websites, screen names, user identification numbers, security questions and answers,
registration IP address, payment history, and other personal identifiers;

Q. All email addresses and telephone numbers ever registered (whether successfully or not)
to the account, including dates of any changes and the IP addresses used for any changes;

R. All past and current usemames, account passwords, and names associated with the account,
including dates of any changes and the IP addresses used for any changes;

S. All data and information associated with the profile page, including photographs;

T. All advertising data relating to the account, including, but not limited to, information
regarding unique advertising IDs associated with the user, any devices used to access the
account, application IDs, UDIDs, payment information (including, but not limited to, full
credit card numbers and expiration dates and PayPal accounts), ads clicked, and ads
created;

U. The dates and times at which the account and profile were created, and the Internet Protocol
("IP") address at the time of sign-up;

V. All transactional records associated with the account, including any IP logs or other records
of session times and durations;

W. Any information identifying the device or devices used to access the account, including a
device serial number, a GUID or Global Unique Identifier, a phone number, serial numbers,
MAC addresses, Electronic Serial Numbers ("ESN"), Mobile Electronic Identity Numbers
("MEIN"), Mobile Equipment Identifiers ("MEID"), Mobile Identification Numbers
("MIN"), Subscriber Identity Modules ("SIM"), Mobile Subscriber Integrated Services
Digital Network Number ("MSISDN"), International Mobile Subscriber Identifiers
("IMSI"), or International Mobile Equipment Identities ("IMEI"), and any other
information regarding the types of devices used to access the account;

X. All activity logs for the account;

Y. All location information for the account, including all location data collected by any
plugins or widgets;

Z. The types of service utilized by the user;

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AA. All information about the account's use ofTwitter's link service, including all website links
embedded in, exporting data to, or importing data from, the account's website or blog;

BB. All full website links that were shortened by Twitter's link service, all resulting shortened
links, and all information about the number of times that a link posted by the account was
clicked;

CC. All information about connections between the account and third-party websites and
applications, including any Twitter, Facebook or other social networking accounts to which
posts from the account are sent;

DD. All data and information that has been deleted by the user;

EE. The length of service (including start date) and the means and source of any payments
associated with the service (including any credit card or bank account number);

FF. All privacy settings and other account settings, including email addresses or other accounts
that the account has blocked;

GG. Information regarding linked accounts, including accounts linked by cookie, IP address
(including registration IP address), advertising ID, User Client UUID, User Guest Cookie
ID, Known Device Token, Normalized Email Address, Android ID, IMEI, GUID, device
identifier, or any other account or device identifier;

HH. Information regarding accounts linked to accounts to which the Target Accounts are linked;

II. All records pertaining to communications between the Service Provider and any person
regarding the user or the user's account with the Service Provider, including contacts with
support services, records of actions taken, and investigative or user complaints concerning
the subscriber.

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from March 1, 2016 to the present, including:

-4-
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a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, any

individual associated with the Trump Campaign, or any witness in the

investigation;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

-5-
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g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

I. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
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III. Review Protocols

Review of the items described in Attachment A and Attachment B shall be conducted

pursuant to established procedures designed to collect ~vidence in a manner consistent with

professional responsibility requirements concerning the maintenance of attorney-client and other

operative privileges. When appropriate, the procedures shall include use of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

-7-
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IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF


INFORMATION AS SOCIA TED WITH ONE
ACCOUNT STORED AT PREMISES
CONTROLLED BY TWITTER

The United States of America, moving by and through its undersigned counsel, respectfully

moves the Court for an Order placing the above-captioned warrant and the application and affidavit

in support thereof (collectively herein the "Warrant") under seal, and precluding the provider from

notifying any person of the Warrant pursuant to 18 U.S.C. § 2705(b). In regard to the non-

disclosure, the proposed Order would direct TWITTER, LLC ("TWITTER"), an electronic

communication and/or remote computing services provider headquartered in San Francisco,

California, not to notify any other person (except attorneys for TWITTER for the purpose of

receiving legal advice) of the existence or content of the Warrant for a period of one year or until

further order of the Court.

JURISDICTION AND LEGAL BACKGROUND

1. The Court has the inherent power to seal court filings when appropriate,

including the Warrant. United States v. Hubbard, 650 F.2d 293, 315-16 (D.C. Cir. 1980) (citing

Nixon v. Warner Communications, Inc., 435 U.S. 589, 598 (1978)). The Court may also seal the

Warrant to prevent serious jeopardy to an ongoing criminal investigation when, as in the present

case, such jeopardy creates a compelling governmental interest in preserving the confidentiality of

the Warrant. See Washington Post v. Robinson, 935 F.2d 282, 287-89 (D.C. Cir. 1991).

2. In addition, this Court has jurisdiction to issue the requested order because it is "a

court of competent jurisdiction" as defined by 18 U.S.C. § 2711. Specifically, the Court is a


Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 54 of 59

"district court of the United States ... that - has jurisdiction over the offense being investigated."

18 U.S.C. § 2711 (3)(A)(i). Acts or omissions in furtherance of the offense under investigation

occurred within Washington, D.C. See 18 U.S.C. § 3237.

3. Further, the Court has authority to require non-disclosure of the Warrant under 18

U.S.C. § 2705(b). TWITTER provides an "electronic communications service," as defined in 18

U.S.C. § 2510(15), and/or "remote computing service," as defined in 18 U.S.C. § 2711(2). The

Stored Communications Act ("SCA"), 18 U.S.C. §§,2701-2712, governs how TWITTER may be

compelled to supply communications and other records using a subpoena, court order, or search

warrant. Specifically, Section 2703(c)(2) authorizes the Government to obtain certain basic

"subscriber information" using a subpoena, Section 2703(d) allows the Government to obtain other

"non-content" information using a court order, and Section 2703(a)-(b)(1 )(A) allows the

Government to obtain contents of communications using a search warrant. See 18 U.S.C. § 2703.

4. The SCA does not set forth any obligation for providers to notify subscribers about

subpoenas, court orders, or search warrants under Section 2703. However, many have voluntarily

adopted policies of notifying subscribers about such legal requests. Accordingly, when necessary,

Section 2705(b) of the SCA enables the Government to obtain a court order to preclude such

notification. In relevant paii, Section 2705(b) provides as follows: 1

(b) Preclusion of notice to subject of governmental access. - A governmental


entity acting under section 2703 ... may apply to a court for an order commanding
a provider of electronic communications service or remote computing service to
whom a warrant, subpoena, or court order is directed, for such period as the court
deems appropriate, not to notify any other person of the existence of the warrant,
subpoena, or court order. The court shall enter such an order if it determines that
there is reason to believe that notification of the existence of the warrant, subpoena,
or court order will result in-
(1) endangering the life or physical safety of an individual;

1
Section 270.S(b) contains additional requirements for legal process obtained pursuant to 18 U.S.C.
§ 2703(b)(l)(B), but the Government does not seek to use the proposed Order for any legal process
under that provision.
2
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(2) flight from prosecution;


(3) destruction of or tampering with evidence;
(4) intimidation of potential witnesses; or
(5) otherwise seriously jeopardizing an investigation or unduly delaying a trial.

18 U.S.C. § 2705(b). The United States District Court for the District of Columbia has made clear

that a nondisclosure order under Section 2705(h) must he issued once the Government makes the

requisite showing about potential consequences of notification:

The explicit terms of section 2705(b) make clear that if a courts [sic] finds that there
is reason to believe that notifying the customer or subscriber of the court order or
subpoena may lead to one of the deleterious outcomes listed under § 2705(b ), the
court must enter an order commanding a service provider to delay notice to a
customer for a period of time that the court determines is appropriate. Once the
government makes the required showing under § 2705(b), the court is required to
issue the non-disclosure order.

In re Application for Order of Nondisclosure Pursuant to 18 US.C. § 2705(b) for Grand Jury

Subpoena #GJ2014031422765, 41 F. Supp. 3d 1, 5 (D.D.C. 2014).

5. Accordingly, this motion to seal sets forth facts showing reasonable grounds to

command TWITTER not to notify any other person (except attorneys for TWITTER for the

purpose ofreceiving legal advice) of the existence of the Subpoena for a period of one year or until

further order of the Court.

FACTS SUPPORTING SEALING AND NON-DISCLOSURE

6. The Federal Bureau oflnvestigation ("FBI") is investigating violations of 18 U.S.C.

§ 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a

felony), 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 951 (acting as an unregistered foreign agent),

18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a protected

computer); 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud), 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), and 22 U.S.C. § 611 et seq.

(Foreign Agents Registration Act), and 52 U.S.C. § 30121 (foreign contribution ban) (the "Subject

3
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 56 of 59

· Offenses"), arising out of the conduct of Roger Stone and others. It does not appear that Stone is

currently aware of the full nature and scope of the ongoing FBI investigation. Disclosure of this

warrant to Stone could lead him to destroy evidence or notify others who may delete information

relevant to the investigation.

7. In this matter, the government requests that the Warrant be sealed until further order

of the Court and that TWITTER and its employees be directed not to notify any other person of

the existence or content of the Warrant (except attorneys for TWITTER for the purpose of

receiving legal advice) for a period of one year or until further order of the Court. Such an order

is appropriate because the Warrant relates to an ongoing criminal investigation, the scope and

nature of which is neither public nor known to the targets of the investigation, and its disclosure

may alert these targets to the nature, scope, and focus of the ongoing investigation. Disclosure of

the Warrant and related papers may also alert the targets to the scope of information known to the

FBI. Once alerted to this information, potential targets would be immediately prompted to destroy

or conceal incriminating evidence, alter their operational tactics to avoid future detection, and

otherwise take steps to undermine the investigation and avoid future prosecution. In particular,

given that they are known to use electronic communication and remote computing services, the

potential target could quickly and easily destroy or encrypt digital evidence relating to their

criminal activity.

8. Given the complex and sensitive nature of the criminal activity under investigation,

and also given that the criminal scheme may be ongoing, the Government anticipates that this

confidential investigation will continue for the next year or longer. However, should

circumstances change such that court-ordered nondisclosure under Section 2705(b) becomes no

longer needed, the Government will notify the Court and seek appropriate relief.

4
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9. There is, therefore, reason to believe that notification of the existence of the

Warrant will seriously jeopardize the investigation, including by giving the targets an opportunity

to flee from prosecution, destroy or tamper with evidence, and intimidate witnesses. See 18 U.S.C.

§ 2705(b )(2)-(5). Because of such potential jeopardy to the investigation, there also exists a

compelling governmental interest in confidentiality to justify the government's sealing request.

See Robinson, 935 F.2d at 287-89.

10. Based on prior dealings with TWITTER, the United States is aware that, absent a

court order under Section 2705(b) commanding TWITTER not to notify anyone about a legal

request, TWITTER may, upon receipt of a warrant seeking the contents of electronically stored

wire or electronic communications for a certain account, notify the subscriber or customer of the

existence of the warrant prior to producing the material sought.

WHEREFORE, for all the foregoing reasons, the government respectfully requests that the

above-captioned warrant, the application and affidavit in support thereof, and all attachments

thereto and other related materials be placed under seal, and furthermore, that the Court command

TWITTER not to notify any other person of the existence or contents of the above-captioned

warrant (except attorneys for TWITTER for the purpose of receiving legal advice) for a period of

one year or until further order of the Court.

Respectfully submitted,

ROBERTS. MUELLER, III


Special Counsel

Dated: :) /2 (o /l'3 By:


Kyl
The cial Counsel's Office
(202) 616-3812

5
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1L'
SEP 2 6 2018
IN THE UNITED STATES DISTRICT COURT
Clerk, U.S. District & Bankruptcy
FOR THE DISTRICT OF COLUMBIA Courts for the District of Golumb/a

IN THE MATTER OF THE SEARCH OF Case: 1:18-sc-02905


INFORMATION AS SOCIA TED WITH ONE Assigned To : Howell, Beryl A.
ACCOUNT STORED AT PREMISES Assign. Date : 9/26/2018
CONTROLLED BY TWITTER
Description: Search & Seizure Warrant

ORDER

The United States has filed a motion to seal the above-captioned warrant and related

documents, including the application and affidavit in support thereof (collectively the "Warrant"),

and to require TWITTER, INC. ("TWITTER"), an electronic communication and/or remote

computing services provider headquartered in San Francisco, California, not to disclose the

existence or contents of the Warrant pursuant to 18 U.S.C. § 2705(b).

The Court finds that the United States has established that a compelling governmental

interest exists to justify the requested sealing, and that there is reason to believe that notification

of the existence of the Warrant will seriously jeopardize the investigation, including by giving the

targets an opportunity to flee from prosecution, destroy or tamper with evidence, and intimidate

witnesses. See 18 U.S.C. § 2705(b)(2)-(5).

IT IS THEREFORE ORDERED that the motion is hereby GRANTED, and that the

warrant, the application and affidavit in support thereof, all attachments thereto and other related

materials, the instant motion to seal, and this Order be SEALED until further order of the Court;

and
Case 1:19-mc-00029-CRC Document 29-23 Filed 04/28/20 Page 59 of 59

IT IS FURTHER ORDERED that, pursuant to 18 U.S.C. § 2705(b), TWITTER and its

employees shall not disclose the existence or content of the Warrant to any other person (except

attorneys for TWITTER for the purpose of receiving legal advice) for a period of one year or until

further order of the Court.

TIIEHON&t~LL
CHIEF UNITED STATES DISTRICT JUDGE

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ATTACHMENT A

Property to be Searched

This wmrnnt applies to information associated with the Twitter accounts registered to the

following email addresses, which are stored at premises owned, maintained, controlled, or

operated by Twitter, Inc. ("Twitter"), a company headquartered in San Francisco, California

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ATTACHMENT A

Property to be Searched

This wanant applies to infonnation associated with the Facebook accounts registered to

the following email addresses ("Target Facebook Accounts"), stored at premises owned,

maintained, controlled, or operated by Facebook, Inc. ("Facebook"), a company headquartered in

Menlo Park, California:

This wanant also applies to information associated with the Instagram accounts registered

to the following email addresses ("Target Instagram Accounts"), stored at premises owned,

maintained, controlled, or operated by Facebook:

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 1 of 56
AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1: 18-sc-02920
or identify the person by name and address) ) Assigned To : Howell, Be /
INFORMATION ASSOCIATED WITH THREE ) Ass,g~. Date: 9/27/2018 ry A.
ACCOUNTS STORED AT PREMISES ) Descnpt,on: Search & S .
CONTROLLED BY MICROSOFT ) e1zure Warrant
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the govenunent requests the search
of the following person or property located in the Western District of Washington
(Mentify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (;dentify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before October 11, 2018 (not to exceed 14 days)
;/ in the daytime 6:00 a.m. to 10:00 p.m. D at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell, Chief U.S. District Judge
(United States Magistrate Judge)

D Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
D for days (not to e,ceed 30) D until, the facts justifying, the later specific date of

Date and time issued:

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
-----·
Printed name and title
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 2 of 56
AO 93 (Rev. I 1/13) Search and Seizure Warranl (Page 2)

Retum
Case No.: Date aud time warrant executed: Copy ofwanant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare nnder penalty of petjury that this inventory is correct and was returned along with the original wanant to the
designated judge.

Date:
Ei:ecuting officer's signature

-·---,.,,-- ...
Printed name and title
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 3 of 56

ATTACHMENT A

Property to be Searched

This wanant applies to information associated with the following Microsoft accounts,

stored at premises owned, maintained, controlled, or operated by Microsoft Corporation

("Microsoft"), a company headquartered in Redmond, Washington:

This wanant also applies to infmmation associated with the following Skype usernames

and/or email addresses, stored at premises owned, maintained, controlled, or operated by Microsoft

Corporation, an electronic communication and/or remote computing service provider with

headquarters in Redmond, Washington:

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 4 of 56

ATTACHMENTB

I. Information to be disclosed by Microsoft

To the extent that the infonnation described in Attachment A is within the possession,

custody, or control of the Microsoft Corporation (hereinafter "the Provider"), regardless of whether

such infmmation is stored, held or maintained inside or outside of the United States, and including

any emails, records, files, logs, or information that have been deleted but are still available to the

Provider, the Provider is required to disclose the following information to the government for each

account or identifier listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date and time at which each

email was sent, and the size and length of each email;

b. The contents of all Skype communications sent to or from the account, including

videos, instant messages, group messages, and attachments, as well as the complete

conversation history for the account;

c. All records or other information regarding the identification of the account, to

include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

d. The types of service utilized;

-2-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 5 of 56

e. All Windows Live and OneDrive data and content;

f. All Microsoft Developer information and content and any other information and

content relating to software development and testing;

g. All records or other information stored at any time by an individual using the

account, including address books, contact and buddy lists, calendar data, pictures,

and files;

h. All records pertaining to communications between the Provider and any person

regarding the account, including contacts with support services and records of

actions taken;

1. All Lyne content;

j. All subscriber "change history" associated with the account;

k. All search history and web history associated with the account (including Bing

history);

I. All location and maps info1mation associated with the account;


'
m. All device infonnation associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Number

("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), or

International Mobile Equipment Identities ("IMEI")); and

n. For any accounts linked to the accounts listed in Attachment A, including accounts

linked by cookie, SMS number, or recovery email address, and for accounts for

-3-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 6 of 56

which the accounts described in Attachment A are the recovery email address,

provide all records or other information regm·ding the identification of the account,

to include full nmne, physical addrnss, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number).

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U .S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from March 1, 2016 to the present, including:

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or connnunications regm·ding disinformation, denial, dissembling

or other obfuscation about lmowledge of, or access to, hacked material;

-4-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 7 of 56

b. All records, infonnation, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, any

individual associated with the Trump Campaign, any witness in the investigation;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

-5-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 8 of 56

J. Credit card and other financial information, inclnding but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

I. The identity of any 11011-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

III. Review Protocols

Review of the items described in Attachment A and Attachment B shall be conducted

pursuant to established procedures designed to collect evidence in a manner consistent with

professional responsibility requirements concerning the maintenance of attorney-client and other

operative privileges. When appropriate, the procedures shall include use of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

-6-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 9 of 56

\;t~: '!i'
tt{ ~
lL [i'c'. r~
\:J.;;.,: ,.,oS,; <,..'.:<

IN THE UNITED STATES DISTRJCT COURT Stf1 2 7 2t118


FOR THE DISTRICT OF COLUMBIA Clerk, U.S. lll8trlct e, ll~~lm,p!GY
Courts for the District of Columbia

IN THE MATTER OF THE SEARCH OF


INFORMATION ASSOCIATED WITH Case: 1:18-sc-02920
THREE ACCOUNTS STORED Assigned To : Howell, Beryl A.
AT PREMISES CONTROLLED BY Assign. Date: 9/27/2018
MICROSOFT CORPORATION Description: Search & Seizure Warrant

ORDER

The United States has filed a motion to seal the above-captioned warrant and related

documents, including the application and affidavit in suppo1i thereof (collectively the "Warrant"),

and to require Microsoft Corporation ("Microsoft"), an electronic communication and/or remote

computing services provider headquartered in Redmond, Washington, not to disclose the existence

or contents of the Warrant pursuant to 18 U.S.C. § 2705(b).

The Court finds that the United States has established that a compelling governmental

interest exists to justify the requested sealing, and that there is reason to believe that notification

of the existence of the Warrant will seriously jeopardize the investigation, including by giving the

targets an opportunity to flee from prosecution, destroy or tamper with evidence, and intimidate

witnesses. See 18 U.S.C. § 2705(b)(2)-(5).

IT IS THEREFORE ORDERED that the motion is hereby GRANTED, and that the

warrant, the application and affidavit in support thereof, all attachments thereto and other related

materials, the instant motion to seal, and this Order be SEALED until further order of the Corui;

and
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 10 of 56

IT IS FURTHER ORDERED that, pursuant to 18 U.S.C. § 2705(b), Microsoft and its

employees shall not disclose the existence or content of the Warrant to any other person (except

attorneys for Microsoft for the purpose of receiving legal advice) for a period of one year or until

further order of the Court.

THEHONO~t~~
CHIEF UNITED STATES DISTRICT JUDGE

2
Case
AO !06 (Rev. 04/10) 1:19-mc-00029-CRC
Application for a Search Warrant Document 29-27 Filed 04/28/20 Page 11 of 56

UNITED STATES DISTRICT COURT


for the
SEP 2 7 2018
District of Columbia
Clark, U.S. District & Bankruptcy
!111wt,1 lor 11m l.ll0lrlc1 u1 Gi;:rni,\tfffi
In the Matter of the Search of ) Case: 1: 18-sc-02920
(Briefly describe the property to be searched )
or identify the person by name and address) Assigned To : Howell, Beryl A.
)
INFORMATION ASSOCIATED WITH ) Assign. Date: 9/27/2018
THREE ACCOUNTS STORED AT PREMISES ) Description: Search & Seizure Warrant
CONTROLLED BY MICROSOFT )

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the goverument, request a search warrant and state under
penalty of perjury that I.have reason to believe that on the following person or property (identify the person or describe the
property lo be searched and give its location):

See Attachment A
located in the Western District of _ _ ___,W=a,,,sh...i..
n,,_gt"o""n'-~· , there is now concealed (identify the
person or describe the property to be seized):
See Attachment B

The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
~ evidence of a crime;
ref contraband, fruits of crime, or other items illegally possessed;
ref property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained .

.The search is related to a violation of:


Code Section Offense Description
52 U.S.C. § 30121 Foreign Contribution Ban
18 U.S.C. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

r;/ Continued on the attached sheet.


0 Delayed notice of days (give exact ending date if more than 30 days: _ _ _ _ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA:
~
~ c a n t ' s Signature

Fyle R. Free~y (ASC) Patrick J. Myers, Special Agent, FBI- - - -


Printed name and title

Sworn to before me and signed in my presence. ·

Judge's signature

City and state: Washington, D.C. Hon. Beryl A Howell, Chief U.S. District Judge
---
Printed name and title
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 12 of 56

SEP 2 ! 2018
IN THE UNITED STATES DISTRICT COURT
Clerk, U.S. DIHtrlct & Bankruptcy
FOR THE DISTRICT OF COLUMBIA Courts for tl10 District ot Columbia

IN THE MATTER OF THE SEARCH OF


Case: 1:18-sc-02920
INFORMATION ASSOCIATED WITH
Assigned To : Howell, Beryl A.
THREE ACCOUNTS STORED AT
Assign. Date: 9/27/2018
PREMISES CONTROLLED BY
Description: Search & Seizure Warrant
MICROSOFT

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH ARRANT ,v
I, Patrick J. Myers, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the Microsoft email account ( "Target

Accounts 1") and the Skype accounts registered to ("Target Account

2") and to ("Target Account 3"), stored at premises owned,

maintained, controlled or operated by Microsoft Corporation ("Microsoft"), a company

headquartered in Redmond, Washington.

Upon receipt of the information described in Attachment A, government-authorized persons will

. review that information to locate the items described in Attachment B.

2. I am a Special Agent with the Federal Bureau ofinvestigation ("FBI") assigned to

FBI Pittsburgh working directly with the Special Counsel's Office. I have been a Special Agent

with the FBI since 2017. I was previously employed as a network and software engineer for

approximately fifteen years, including for the FBI. As a Specia!Agent, I have conducted national

security investigations relating to foreign intelligence and cybersecurity.

-1-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 13 of 56

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set fmih in this affidavit,

there is probable cause to believe that the Target Accounts contains evidence, fruits, or

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a protected

computer), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud), 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C. § 1513 (witness

tampering), and 52 U.S.C. § 30121(a)(l)(C) (foreign expenditnre ban). There also is probable

cause to search the infonnation described in Attachment A for evidence, contraband, fruits,

and/or instrumentalities of the Subject Offenses, further described in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(l )(A). · Specifically, the Co111i is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

-2-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 14 of 56

PROBABLE CAUSE

A. Background on Relevant Individuals

i. Roger STONE

6. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

7. Jerome CORSI is a political commentator who, according to publicly available


'
information, served as the "Washington Bureau Chief for Inforwars.com." According to

publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WND.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the sunrmer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

-3-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 15 of 56

B. Russian Government-Backed Hacking Activity During the 2016 Presidential


Election

9. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and hmm her
electability and potential presidency. We further assess Putin and the Russian
Govermnent developed a clear preference for President-elect Trump.

10. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian gove1mnent employed during its interference. The USIC summarized the effo1is

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

11. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

-4-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 16 of 56

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities

to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

12. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guecifer 2.0 persona, DCLeaks.com, and WikiLealcs to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

13. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

14. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

15. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud~based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

16. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 17 of 56

emails were later post on DCLeaks.

17. On or about November 1, 2016, individuals associated with the GRU

. spearphishcd over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

18. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

presidential election, including conspiracy to commit authorized access to protected computers.

See United States v. Viktor Borisovich Netyksho, et al. (Case No. 1: l 8-cr-00125).

C. STONE's. Public Interactions with Guccifcr 2.0 and WikiLeaks

19. On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the doclL.rnents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

20. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.

21. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

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why he did the hack of the DNC." The article also stated: "Gliccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

22. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

aimed at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With

regard to the October surprise, what would be your forecast on that given what Julian Assange

has intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain

to the Clinton Foundation but there's no telling what the October surprise may be." A few days

later, STONE clarified that while he was not personally in touch with AS SAN GE, he had a close

friend who served as an intermediary.

23. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addrnsses from the files of the DCCC.

24. On August 13, 2016, STONE posted a tweet using@RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

25. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me ifI can help u anyhow. it would be a great pleasure to me."

26. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

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resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

27. On August 21, 2016, using @RogerJStoneJR, STONE tweeted: "Trust me, it will

soon the [sic] Podesta' s time in the barrel. #CrookedHillary." In a C-SPAN interview that same

day, STONE reiterated that because of the work of a '"mutual acquaintance' of both his and

[ASSANGE], the public [could] expect to see much more from the exiled whistleblower in the

fmm of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

28. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

29. On Saturday, October 1, 2016, using@RogerJStoneJr, STONE tweeted,

"Wednesday@HillatyClinton is done. #WildLeaks."

30. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regariling an announcement AS SANGE had scheduled for the next day from the balcony

of the Ecuadoran Embassy in London. On the day of the ASSANGE announcement -which was

part of WikiLeaks' 10-year anniversary celebration - STONE told Infowars that his inte1mediary

described this release as the "mother load." On October 5, 2016, STONE used@RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

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31. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an mticle containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

32. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryClinton #Podesta #imWithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

33. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta-refening back to STONE's August 21,

2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of connnunications. I'm not implying I have any

influence with him or that I have advanced knowledge ofthe specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

34. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Cmnpaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 21 of 56

or scope of their subsequent disclosures. S9 I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came tme."

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

35. On October 13, 2016, while WikiLeaks was in the midst of releasing the hacked

Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

account @wikileaks. 1 The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

to rexarnine the strategy of attacking me- cordially R."

36. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

37. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

38. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wildleaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

39. In addition,@RogerJStoneJr also exchanged direct messages with ASSANGE,

1 Onor about August 7, 2017, Chief Judge Beryl A Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
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the founder of WikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with AS SAN GE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from 1he government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

40. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks

41. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, On October 17,

2017, Chief Judge Howell issued a search warrant for one of STONE's addresses,

On or about December 19, 2017, Chief Judge Howell issued a search

warrant for email account. On or about March 14, 2018, Chief Judge Howell

issued a search warrant for STONE's iC!oud account. Information recovered pursuant to those

search warrants indicated the following:

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42. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger

Stone so he knows your availability to meet Manafmt and DT this coming week." CORSI

appears to have forwarded the message to STONE at who replied to

CORSI that, "May meet Manafort -guarantee nothing."

43. On or about May 18, 2016, CORSI emailed STONE at

with the title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

44. On July 25, 2016, STONE, using sent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get to Assange

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

45. On or about July 31, 2016, STONE, using emailed

CORSI with the subject line, "Call me MON." The body of the email read: should see

Assange[.J should find Bernie [SJ anders brother who called Bill a Rapist - turn him for

Trump[.] should find or more proof of Bill getting kicked out."

46. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at

Word is friend in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued, "Signs are Fox

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will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HRC an artifact of rigged polling. Won't last. I expect presidential

campaign to get serious staiiing Sept. Still in pre-season games. Time to let more than Podesta to

be exposed as in bed w enemy if they are not ready to drop HRC. That appears to be the game

hackers are now about. Would not hurt to start suggesting HRC old, memmy bad, has stroke --

neither he nor she well. I expect that much of next dump focus, setting stage for Foundation

debacle." Investigators believe that CORSI' s reference to a "friend in embassy [who] plans 2

more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in 2016.

47. On or about August 5, 2016, an associate ofSTONE's, emailed

STONE at The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet ASSANGE. also stated

that in 2018, told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting AS SANGE. STONE told he was joking and

had not actually met ASSANGE. 2

48. Through a search of STONE's iCloud account, the FBI has uncovered evidence

suggesting that STONE was in Los Angeles for one or more meetings at the time that he claimed,

in his email to to have "dined" with ASSANGE. For exainple, an associate of

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STONE sent a text to STONE at approximately 3:38PM on August 2, asking "How did ur meeting

go in LA?" STONE responded. "It's this afternoon[.]" The following day, the associate asked,

"Any report from ur meeting?" On or about August 4, 2016, STONE texted the associate, "Will

call later - heading for airport now[.]" Additionally, investigators have identified a photograph in

STUNE's iC!oud that appears to have been taken on August 3, 2016 and had gco-location

information indicating that it was taken in Los Angeles.

49. On or about August 15, 2016, CORSI emailed STONE at

Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

50. On or about August 31, 2016, CORSI emailed STONE at

"Did you get the PODESTA writeup." STONE replied "[y]es."

51. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One - was hired by Rosatom in Giustra sca.'1dal. Podesta now under FBI

investigation - tied to Ukraine Yanukovyeh - Panama papers reveals Podesta hired by

S [bJerbank, Russia's largest financial institution - Podesta $$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

52. On or about September 6, 2016, CORSI emailed STONE at

"Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

53. On or about September 24, 2016, emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have

secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today." wrote back, "Awaiting secret file. Explosive ... Hope you are well.

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 26 of 56

Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators, indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

54. On or about October 3, 2016, an associate of STONE emailed STONE at

sked: "Assange -what's he got?Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be ont in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON, who was CEO of the Campaign at the time, and wrote: "Yon should call Roger. See

below. You didn't get from me." BANNON wrote back, "I've got important stnffto worry

about." The associate responded, "Well clearly he knows what Assange has. I'd say that's

important."

55. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

AS SAN GE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, AS SANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." AS SAN GE also stated that

WikiLealcs would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

56. On or about October 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

57. That same day, BANNON emailed STONE at "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

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to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawyer is a big

democrat."

58. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to ASSANGE, and

BANNON had been hoping for releases of damaging information that morning.

F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
·Are Released.

59. According to a publicly available news article,3 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."

60. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

61. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

62. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

3 https://www.washingtonpost.com/lifestyle/style/the-caller-had-a0lewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07/3 ld74714-8ce5-l le6-875e-2cl
.
bfe943b66- story.html

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63. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

64. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

65. At approximately 4:30PM, WikiLeaks tweeted out its first release ofemails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE using "I expect

that much of next dump focus, setting stage for Foundation debacle."

66. At approximately 6:27PM, an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks - The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using

forwarded message to CORSI without comment. STONE

does not appear to have forwarded the email to any other individual.

G. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

67. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed-

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job

numbers."

68. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

usin emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 29 of 56

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

· Podesta is complicated. Two articles in length. I can give you in raw forni the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

69. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at both ith the subject

line "Podesta talking points." Attached to the email was a file labeled, "ROGER STONE

podesta talking points Oct 12 2016.docx." The "talking points" included the statement that

"Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation."

70. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Hotmail Account, "Got them and used them."

71. On or about Thursday, October 13, 2016, CORSI emailed STONE at

PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I'll give you one more - NOBODY YET HAS THIS[:] It looks to me

like skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once

had the channel open from Metcombm1k to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 30 of 56

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

72. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

have had some back-channel conununications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money did a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through

Metcombank, a Russian regional bank owned 99 .978 percent by with the money

transferred via Deutsche Bank and Trust Company Americas in New Yark City, with the money

ending up in a private bank account in the 'Bank of America that is operated by the Clinton

Foundation?"

73. On or about October 14, 2016, CORSI sent a message to STONE at his iC!oud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

74. On or about October 17, 2016, CORSI messaged STONE at his iC!oud account,

"On Assange, can you call me now - before 2pm[.]" STONE responded, "Missed u - just

landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

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75. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Keny, Ecuador and U .K. He will drop the goods on them ii

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand off{.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. IfHRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election." Based on review of the original email that CORSI forwarded, the

"trusted source" was a self-identified retired librarian who gathers information from public chat

rooms.

76. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

77. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice ofWikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta' s business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

78. On or about November 8, 2016, the United States presidential election took place.

79. On or about November 9, 2016, CORSI messaged STONE at his iC!oud account,

"Congratulations, Roger. He could not have done it without you."

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80. On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Arc you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in

London. Have some interesting news for you."

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I. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikiieaks

88. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCI). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic assertions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta's email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such assertions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trnst me, it will soon be the Podesta' s
time in the barrel. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but
does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrntiny ....

[L]et me address the charge· that I had advance knowledge of the timing, content and
source of the WikiLealcs disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.
I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
Assange to independently confirm this· report, and he subsequently did. This journalist
assured me that WikiLeaks would release this infotmation in October and continued to
assure me of this throughout the balance of August and all of September. This
information proved to be c01rect. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 35 of 56

89. In a document dated March 26, 2018 titled "Minority Views," Democratic

members ofHPSCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with.Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in
cmmnunication with Assange or communication through an intermediary with Assange,
you were only referring to a single fact that you had confirmed with the intennediary -
MR. STONE: That - .
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is correct, even though it was repeated to me on numerous separate
occasions.

90. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an article on his website, stonecoldtruth.com, titled "Is it the Podesta's

Time in the Barrel Yet?" In tl1at article, STONE stated: "[I]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

J. STONE's Messaging to Randy CREDICO about STONE's "Back channel"

91. On or about November 19, 2017, Randy CREDICO (who, as described further

below, STONE publicly identified as his "intermediary" to AS SAN GE), messaged STONE, "My

lawyer wants to see me today." STONE responded, "'Stonewall it. Plead the fifth. Anything to

save the plan' ........ Richard Nixon[.]" CREDICO responded, "Ha ha."

92. On or about November 21, 2017, CREDICO messaged STONE, "I was told that

the house committee lawyer told my lawyer that I will be getting a subpoena[.]" STONE wrote

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 36 of 56

back, "That was the point at which your lawyers should have told them you would asse1t your

5th Amendment rights if compelled to appear." They continued to message, and CREDI CO

wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To do what? Nothing

happening in DC the day before Thanksgiving- why are u busting my chops?"

93. On or about November 24, 2017, STONE, texted CREDlCO, "Assange is a

journalist and a damn good one- meeting with him is perfectly legal and all you ever told me was

he had the goods [o Jn Hillary and would publish them - which he himself said in public b4 u told

me. It's a fucking witchunt [sic]." CREDICO replied, "I told you to watch his tweets. That's

what I was basing it on. I told you to watch his Tweets in October not before that I knew nothing

about the DNC stuff[.] I just followed his tweets[.]" STONE responded, "U never said anything

about the DNC but it was August." CREDICO wrote back, "It was not August because I didn't

interview him or meet him until August 26th[.] That was my first communication with his

secretary in London, August 26th." STONE wrote back, "Not the way I remember it- oh well I

guess Schiff will try to get one ofus indicted for perjury[.]"

94. STONE and CREDICO continued to exchange messages and on November 24,

2017, CREDICO wrote to STONE, "Forensic evidence proves that there is no back Channel. So

now you can relax."

95. On or about November 28, 2017, CREDICO tweeted a copy of a subpoena he

received from HPSCI that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

96. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that "Credico merely[]

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 37 of 56

confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillaty Clinton which are

pending publication,' ... Credico never said he ]mew or had any information as to source or

content of the material."

97. On or about December 1, 2017, CREDlCO messaged STONE, "l don't know why

you had to lie and say you had a back Channel now I had to give all of my forensic evidence to

the FBI today what a headache[.] 4 You could have just told him the truth that you didn't have a

back Channel they now know that I was not in London until September ofthis year[.] You had

no back-channel and you could have just told the truth ... You want me to cover you for perjury

now[.]" STONE responded, "What the fuck is your problem? Neither ofus has done anything

wrong or illegal. You got the best press of your life and you can get away with assetiing for 5th

Amendment rights ifu don't want talk about AND if you turned over anything to the FBI you're

a fool." CREDICO responded, "You open yourself up to six counts ofpe1jury[.] But I'm sme

that wasn't sworn testimony so you're probably clear[.] Council for t_l-1e committee !mows you

never had a back Channel and if you had just told the trnth wouldn't have put me in this bad spot

... you should go back ... and amend yom testimony and tell them the truth." CREDICO

repeated: "you need to amend your testimony before I testify on the 15th." STONE replied, "If

you testify you're a fool. Because of tromp [sic] I could never get away with a certain [sic] my

Fifth Amendment rights but you can. I guarantee you you [sic] are the one who gets indicted for

perjmy if you're stupid enough to testify[.]"

4
Contrary to his statement, CREDICO had not at that time provided any forensic evidence to the
FBI.

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 38 of 56

98. STONE and CREDICO continued to message each other on or abont December 1,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fnck off good night." CREDICO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

99. On or about December 13, 2017, according to public repmiing, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

100. STONE and CREDI CO continued to exchange text messages, and on or about

January 6, 2018, CREDICO indicated to STONE that he was having dinner with a reporter,

STONE responded, "Hope u don't fuck Up my effmis to get Assange a pardon[.]" CREDICO

· messaged STONE, "I have the email from his chief of staff August 25th 2016 responding to an

email I sent to WikiLeaks website email address asking you would do my show[.] That was my

initial contact."

101. On or about January 8, 2018, CREDICO messaged STONE, stating: "Embassy

logs ... + 17 other pieces of info1mation prove that I did not have any conversations with

Assange until September of last year."

102. CREDICO and STONE continued to message each other, and on or about January
'
25, 2018, CREDICO wrote to STONE: "You lied to the house Intel committee ... But you'll get

off because you're friends with Trump so don't worry. I have all the forensic evidence[.] I was

not a ba[ck] Channel and I have all those emails from September of2016 to prove it[.]"

103. On or about April 13, 2018, news rep01is stated that CREDICO had shown

repmiers c~pies of email messages he had received from STONE in the prior few days that

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 39 of 56

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

from you," referring to CREDICO's therapy dog. CREDICO stated that it was "certainly scary .

. . When you start bringing up my dog, you're crossing the line[.]" 5

104. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

He was depressed about it. Or was he lying." The article noted that CREDICO stated he did not

have prostate cancer and did not have any such discussion with STONE.

K. The Target Accounts

5 https://www.yahoo.com/news/comedian-randy-credico-says-trump-adviser-roger-stone-

threatened-dog-135911370.html
6 https ://www.motherjones.com/politics/2018/0 5/roger-stone-to-associate-prepare-to-die/

-28-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 40 of 56

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 41 of 56
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 42 of 56

BACKGROUND CONCERNING MICROSOFT

115. In my training and experience, I have learned that Microsoft provides a variety of

online services, including electronic mail ("email") access, voice communications services such

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 43 of 56

as Skype, Windows Live services, cloud storage services such as OneDrive, and software

development kit accounts, to the public. Subscribers obtain any of these types of accounts by

registering with Microsoft. During the registration process, Microsoft asks subscribers to provide

basic personal information. Therefore, the computers of Microsoft are likely to contain stored

electronic connnunications (including retrieved and unretrieved email for email subscribers and

information concerning subscribers and their use of email services, such as account access

information, email transaction information, and account application information. In my training

and experience, such information may constitute evidence of the crimes under investigation

because the information can be used to identify the account's user or users.

116. In my training and experience, email providers generally ask their subscribers to

provide certain personal identifying information when registering for a services account. Such

information can include the subscriber's full name, physical address, telephone numbers and other

identifiers, alternative email addresses, and, for paying subscribers, means and source of payment

(including any credit or bank accou._'lt number). In my training and experience, such information

may constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users. Based on my training and my experience, I know that, even if

subscribers inseit false information to conceal their identity, this information often provides clues

to their identity, location, or illicit activities.

117. In my training and experience, email providers typically retain ce1tain transactional

information about the creation and use of each account on theit systems. This information can

include the date on which the account was created, the length of service, records of log-in

(i.e., session) times and durations, the types of service utilized, the status of the account (including

whether the account is inactive or closed), the methods used to connect to the account (such as

-32-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 44 of 56

logging into the account via the provider's website), and other log files that reflect usage of the

account. In addition, email providers often have records of the Internet Protocol address

("IP address") used to register the account and the IP addresses associated with paiiicular logins

to the account. Because every device that connects to the Internet must use. an IP address,

IP address information can help to identify which computers or other devices were used to access

the email account.

118. In my training and experience, in some cases, account users will communicate

directly with a service provider about issues relating to the account, such as technical problems,

billing inquiries, or complaints from other users. Providers typically retain records about such

communications, including records of contacts between the user mid the provider's supp01i

services, as well as records of any actions taken by fue provider or user as a .result of the

communications. In my training and experience, such information may constitute evidence of the

crimes under investigation because the information can be used to identify fue account's user or

users.

119. This application seeks a warrant to search all responsive records and information

under the control of Microsoft, a provider subject to tl1e jurisdiction of this court, regardless of

where Microsoft has chosen to store such information. The government intends to require the

disclosure pursuant to the requested warrant of the contents of wire or electronic communications

and any records or oilier infonnation pertaining to the customers or subscribers if such

communication, record, or otherinformation is within Microsoft's possession, custody, or control,

regardless of whether such communication, record, or other information is stored, held, or

maintained outside the United States. It is my understanding that Microsoft has access to email

accounts with the top level domain .au, which is associated with Australia.

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 45 of 56

120. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of

occupancy"'while executing a search warrant at a residence. For example, email

communications, contacts lists, and images sent (and the data associated with the foregoing, such

as date and time) may indicate who used or controlled the account at a relevant time. Further,

information maintained by the email provider can show how and when the account was accessed

or used. For example, as described below, email providers typically log the IP addresses from

which users access the email account, along with the time and date of that access. By

determining the physical location associated with the logged IP addresses, investigators can

understand the chronological and geographic context of the email account access and use relating

to the crime under investigation. This geographic and timeline information may tend to either

inculpate or exculpate the account owner. Additionally, information stored at the user's account

may further indicate the geographic location of the account user at a particular time (e,g.,

location infom1ation integrated into an image or video sent via email). Last, stored electronic

data may provide relevant insight into the email account owner's state of mind as it relates to the

· offense under investigation. For example, information in the email account may indicate the

owner's motive and intent to commit a crime (e.g., communications relating to the crime), or

consciousness of guilt (e.g., deleting communications in an effort to conceal them from law

enforcement).

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 46 of 56

FILTER REVIEW PROCEDURES

121. Review of the items described in Attaclnnent A and Attaclnnent B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

with professional responsibility requirements concerning the maintenance of attorney-client and

other operative privileges. The procedures include use, if necessary, of a designated ''filter

team," separate and apart from the investigative team, in order to address potential privileges.

CONCLUSION

122. Based on the forgoing, I request that the Comt issue the proposed search warrant.

123. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

124. I further request that the Court order that all papers in support of this application,

including the affidavit and search warrant, be sealed until fmiher order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

docmnents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

~~
~y-e-rs____________
Special Agent
Federal Bureau oflnvestigation

Subscribed and sworn to before me on this l~y of September, 2018.

~48
The Honorable Beryl A. Howell
Chief United States District Judge

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 47 of 56

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the following Microsoft accounts,

stored at premises owned, maintained, controlled, or operated by Microsoft Corporation

("MiLausufl''), a comprury headqurutered in Redmond, Washington:

This warrant also applies to information associated with the following Skype usernrunes

and/or email addresses, stored at premises owned, maintained, controlled, or operated by Microsoft

Corporation, an electronic communication and/or remote computing service provider with

headquarters in Redmond, Washington:

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 48 of 56

ATTACHMENT B

I. Information to be disclosed by Microsoft

To the extent that the information described in Attachment A is within the possession,

custody, or control of the Microsoft Corporation (hereinafter "the Provider"), regardless of whether

such information is stored, held or maintained inside or outside of the United States, and including

any emails, records, files, logs, or information that have been deleted but are still available to the

Provider, the Provider is required to disclose the following information to the government for each

account or identifier listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date arid time at which each

email was sent, and the size and length of each email;

b. The contents of all Skype communications sent to or from the account, including

videos, instant messages, group messages, and attachments, as well as the complete

conversation history for the account;

c. All records or other information regarding the identification of the account, to

include full name, physical address, _telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

t¥e length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

d. The types of service utilized;

-2-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 49 of 56

which 1he accounts described in Attachment A are the recovery email address,

provide all records or other information regarding the identification of the account,

to include full name, physical address, telephone numbers and oilier identifiers,

records of session times and durations, the date on which the account was created,

1he length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses
I
provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number).

II. Information to be Seized by the Government

Any and all records 1hat relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations ofl8 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after 1he fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unau1horized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from March 1, 2016 to the present, including:

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons ~r entities associated with WikiLealcs, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

-4-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 50 of 56

b. All records, information, documents or tangible materials that relate in any way to

connnnnications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, any

individual associated with the Trump Campaign, any witness in the investigation;

c. Connnnnications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering connnunication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials; foreign entities, foreign persons, or foreign

principals;

e. All images, messages, connnunications, calendar entries, search terms, "address


;
book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Connnunications, records, documents, and other files that reveal eff01ts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign govermnent, foreign officials, foreign entities, foreign persons, or

foreign principals;

g. Evidence indicating how and when the acconnt was accessed or used, to determine
(

the geographic and chronological context of account access, use, and events relating

to the crimes nnder investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

i. The identity of the person(s) who created or used the acconnt, including records

that help reveal the whereabouts of such person(s);

-5-
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 51 of 56

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

1. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts. of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign goverurnent, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access infonnl'ltion that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

III. Review Protocols

Review of the items described in Attachment A and Attachment B shall be conducted

pursuant to established procedures designed to collect evidence in a manner consistent with·

professional responsibility requirements concerning the maintenance of attorney-client and .other

operative privileges. When appropriate, the procedures shall include use of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

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Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 52 of 56

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF Case: 1: 18-sc-02920


INFORMATION ASSOCIATED WITH Assigned To : Howell, Beryl A.
THREE ACCOUNTS STORED Assign. Date: 9/27/2018
AT PREMISES CONTROLLED BY Description: Search & Seizure Warrant
MICROSOFT CORPORATION

MOTION TO SEAL WARRANT AND RELATED DOCUMENTS AND


TO REQUIRE NON-DISCLOSURE UNDER 18 U.S.C. § 2705(b)

The United States of America, moving by and through its undersigned counsel, respectfully

moves the Court for an Order placing the above-captioned warrant and the application and affidavit

in support thereof (collectively herein the "Wanant") under seal, and precluding the provider from

notifying any person of the WaiTant pursuant to 18 U.S.C. § 2705(b). In regard t9 the non-

disclosure, the proposed Order wonld direct Microsoft Corporation ("Microsoft"), an electronic

communication and/or remote computing services provider headquartered in Redmond,

Washington, not to notify any other person (except attorneys for Microsoft for the purpose of

receiving legal advice) of the existence or content of the Wanant for a period of one year or until

further order of the Court.

JURISDICTION AND LEGAL BACKGROUND

1. The Court has the inherent power to seal comt filings when appropriate,

including the Warrant. United States v. Hubbard, 650 F.2d 293, 315-16 (D.C. Cir. 1980) (citing

Nixon v. Warner Communications, Inc., 435 U.S. 589, 598 (1978)). The Court may also seal the

Wanant to prevent serious jeopardy to an ongoing criminal investigation when, as in the present

case, such jeopardy creates a compelling governmental interest in preserving the confidentiality of

the Warrant. See Washington Post v. Robinson, 935 F.2d 282, 287-89 (D.C. Cir. 1991).
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 53 of 56

2. In addition, this Court has jurisdiction to issue the requested order because it is "a

court of competent jurisdiction" as defined by 18 U.S.C. § 2711. Specifically, the Comt is a

"district court of the United Slates ... that - has jurisdiction over the offense being investigated."

18 U.S.C. § 2711(3)(A)(i). Acts or omissions in furtherance of the offense under investigation

occuned within Washington, D.C. See 18 U.S.C. § 3237.

3. Further, the Court has authority to require non-disclosure of the Warrant under 18

U.S.C. § 2705(b). Microsoft provides an "electronic communications service," as defined in 18

U.S.C. § 2510(15), and/or "remote computing service," as defined in 18 U.S.C. § 2711(2). The

Stored Communications Act ("SCA"), 18 U.S.C. §§ 2701-2712, governs how Microsoft may be

compelled to supply communications and other records using a subpoena, court order, or search

wanant. Specifically, Section 2703(c)(2) authorizes the Government to obtain ce1tain basic

. "subscriber information" using a subpoena, Section 2703( d) allows the Government to obtain other

"non-content" information using a court order, and Section 2703(a)-(b)(l)(A) allows the

Government to obtain contents of communications using a search wanant. See 18 U.S.C. § 2703.

4. The SCA does not set forth any obligation for providers to notify subscribers about

subpoenas, court orders, or search warrants under Section 2703. However, many have voluntarily

adopted policies of notifying subscribers about such legal requests. Accordingly, when necessary,

Section 2705(b) of the SCA enables the Government to obtain a court order to preclude such

notification. In relevant part, Section 2705(b) provides as follows: 1

(b) Preclusion of notice to subject of governmental access. - A governmental


entity acting under section 2703 ... may apply to a court for an order commanding
a provider of electronic communications service or remote computing service to
whom a warrant, subpoena, or court order is directed, for such period as the court

1 Section 2705(b) contains additional requirements


for legal process obtained pursuant to 18 U.S.C.
§ 2703(b)(l)(B), but the Government does not seek to use the proposed Order for any legal process
under that provision.

2
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 54 of 56

deems appropriate, not to notify any other person of the existence of the warrant,
subpoena, or court order. The court shall enter such an order if it determines that
there is reason to believe that notification of the existence of the warrant, subpoena,
or court order will result in-
(1) endangering the life or physical safety of an individual;
(2) flight from prosecution;
(3) destruction of or tampering with evidence;
(4) intimidation of potential witnesses; or
(5) otherwise seriously jeopardizing an investigation or unduly delaying a trial.

18 U.S.C. § 2705(h). The United States District Court for the District of Columbia has made clear

that a nondisclosnre order under Section 2705(b) must be issued once the Government makes the

requisite showing about potential consequences of notification:

The explicit terms of section 2705(b) make clear that if a courts [sic] finds that there
is reason to believe that notifying the customer or subscriber of the court order or
subpoena may lead to one of the deleterious outcomes listed under § 2705(b), the
court must enter an order commanding a service provider to delay notice to a
customer for a period of time that the court determines is appropriate. Once the
government makes the required showing under § 2705(b), the court is required to
issue the non-disclosure order.

In re Application for Order of Nondisclosure Pursuant to 18 USC § 2705(b) for Grand Jury

Subpoena #GJ2014031422765, 41 F. Supp. 3d I, 5 (D.D.C. 2014).

5. Accordingly, this motion to seal sets forth facts showing reasonable grounds to

command Microsoft not to notify any other person (except attorneys for Microsoft for the purpose

of receiving legal advice) of the existence of the Subpoena for a period of one year or until further

order of the Court.

FACTS SUPPORTING SEALING AND NON-DISCLOSURE

6. The Federal Bureau ofinvestigation ("FBI") is investigating violations of 18 U.S.C.

§ 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision ofa

felony), 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 951 (acting as an umegistered foreign agent),

18 U.S.C. § 1030 (unauthorized access of a protected computer); 18 U.S.C. § 1343 (wire fraud),

18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud), and 22 U.S.C. § 611 et seq.

3
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 55 of 56

(foreign Agents Registration Act), and 52 U.S.C. § 30121 (foreign contribution ban) (the "Subject

Offenses"), in connection with efforts to compromise the networks of the Democratic National

Convention ("DNC"), the Democratic Congressional Campaign Committee ("DCCC"), and the

email accounts of U.S. persons involved in the 2016 presidential election, followed by the public

release of stolen materials tln·ough various outlets.

7. In this matter, the government requests that the Warrant be sealed until further order

of the Court and that Microsoft and its employees be directed not to notify any other person of the

existence or content of the Warrant (except attorneys for Microsoft for the purpose of receiving

legal advice) for a period of one year or until further order of the Court. Such an. order is

appropriate because the Warrant relates to an ongoing criminal investigation, the scope and nature

of which is neither public nor known to the targets of the investigation, and its disclosure may alert

these targets to the nature, scope, and focus of the ongoing investigation. Disclosure of the Warrant.

and related papers may also ale1t the targets to the scope of information !mown to the FBI. Once

alerted to this information, potential targets would be immediately prompted to destroy or conceal

incriminating evidence, alter their operational tactics to avoid future detection, and otherwise take

steps to undermine the investigation and avoid future prosecution. In particular, given that they

are known to use electronic communication and remote computing services, the potential target

could quickly and easily destroy or encrypt digital evidence relating to their criminal activity.

8. Given the complex and sensitive nature of the criminal activity under investigation,

and also given that the criminal scheme may be ongoing, the Government anticipates that this

confidential investigation will continue for the next year or longer. However, should

circumstances change such that court-ordered nondisclosure under Section 2705(b) becomes no

longer needed, the Government will notify the Court and seek appropriate relief.

4
Case 1:19-mc-00029-CRC Document 29-27 Filed 04/28/20 Page 56 of 56

9. There is, therefore, reason to believe that notification of the existence of the

Warrant will seriously jeopardize the investigation, including by giving the targets an opportunity

to flee from prosecution, destroy or tamper with evidence, and intimidate witnesses. See 18 U.S.C.

§ 2705(b)(2)-(5). Because of such potential jeopardy to the investigation, there also exists a

compelling governmental interest in confidentiality to justify the government's sealing request.

See Robinson, 935 f.2d at 287-89.

10. Based on prior dealings with Microsoft, the United States is aware that, absent a

court order under Section 2705(b) commanding Microsoft not to notify anyone about a legal

request, Microsoft may, upon receipt of a warrant seeking the contents of electronically stored wire

or electronic communications for a certain account, notify the subscriber or customer of the

existence of the wan-ant prior to producing the material sought.

WHEREFORE, for all the foregoing reasons, the government respectfully requests that the

above-captioned warrant, the application and affidavit in support thereof, and all attachments

thereto and other related materials be placed under seal, and furthermore, that the Court command

Microsoft not to notify any other person of the existence oi: contents of the above-captioned

warrant (except attorneys for Microsoft for the purpose of receiving legal advice) for a period of

one year or until further order of the Court.

Respectfully submitted,

ROBERT S. MUELLER, III


Special Counsel

Dated: ':) IZ?: / \ Y2 By:

5
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 1 of 57
AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


Case: 1:18-sc-02921
(Briefly describe the property to be searched )
or identify the person by name and address) ) Assigned To: Howell, Beryl A.
Assign. Date: 9/27/2018
INFORMATION ASSOCIATED WITH TWO ACCOUNTS )
STORED AT PREMISES )
Description: Search & Seizure Warrant
CONTROLLED BY GOOGLE )

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I find that the affidavit(s), or any recorded testimony; establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before October 11, 2018 (not to exceed 14 days)
r;t in the daytime 6:00 a.m. to 10:00 p.m.
0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the prope1iy was taken, or leave the copy and receipt at the place where the
prope1iy was taken.
The officer executing this warrant, or an officer present during the execution of the wanant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell, Chief U.S. District ~llQilL ______ .
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the pe1:son who, or whose
property, will be searched or seized (check the appropriate box) I
' ·
0 for _ _ days (nottoexceed30) 0 until, the facts justifying, the later specific dat'(1bf - - - ~ - - - --~-----

Date and time issued: ~-~~


Judge 's signature

City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 2 of 57
AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date: -
Executing officer's signature

·--··
Printed name and title
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 3 of 57

ATTACHMENT A

Property to be Searched

This warrant applies to info1mation associated with the Google accounts registered to the

following email addresses, which are stored at premises owned, maintained, controlled, or

operated by Google, LLC ("Google"), a company headquartered in Mountain View, California:

-1-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 4 of 57

ATTACHMENT B

I. Information to be disclosed by Google

To the extent that the information described in Attachment A is within the possession,

custody, or control of Google, LLC ("Google"), including any messages, records, files, logs, or

information that have been deleted but are still available to Google, or have been preserved

pursuant to a request made under 18 U.S.C. § 2703(f), Google is required to disclose the following

infmmation to the government for each account listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved

copies of emails sent to and from the account, draft emails, the source and

destination addresses associated with each email, the date and time at which each

email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the account, to

include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses,

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the

account, including address books, contact and buddy lists, calendar data, pictures,

and files;

-2-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 5 of 57

e. All records pertaining to connnunications between the Provider and any person

regarding the account, including contacts with support services and records of

actions taken;

f. All subscriber "change history" associated with the account;

g. All search history and web history associated with the account;

h. All location and maps inf01mation associated with the account;

1. All Google Analytics information associated with the account (including all

properties and UA codes associated with the account, and, for each of these

proprieties and UA codes, all usernames and email accounts associated with them);

J. All Google Developers Console inf01mation associated with the account;

k. All Minutemaid information associated with the account;

1. All Android information associated with the account;

m. All Google Docs associated with the account;

n. All Y ouTube information associated with the account;

o. All Google Hangouts information associated with the account;

p. All Google Voice information associated with the account;

q. All Web & App Activity associated with the account;

r. All Google Drive inf01mation associated with the account;

s. All Google+ infmmation associated with the account;

t. All device information associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

-3-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 6 of 57

Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network Number

("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), or

International Mobile Equipment Identities ("IMEI")); and

u. For any accounts linked to the accounts listed in Attachment A, including accounts

linked by cookie, SMS number, or recovery email address, and for accounts for

which the accounts described in Attachment A are the recovery email address,

provide all records or other information regarding the identification of the account,

to include full name, physical address, telephone numbers and other identifiers,

records of session times and durations, the date on which the account was created,

the length of service, the IP address used to register the account, log-in IP addresses

associated with session times and dates, account status, alternative email addresses

provided during registration, methods of connecting, log files, and means and

source of payment (including any credit or bank account number).

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from March 1, 2016 to the present, including:

-4-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 7 of 57

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling


I

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, infonnation, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, any

individual associated with the Trump Campaign, any witness in the investigation;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electioneering communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

-5-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 8 of 57

g. Evidence indicating how and when the account was accessed or used, to detennine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial infonnation, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

L The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access info1mation that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

-6-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 9 of 57

III. Review Protocols

Review of the items described in Attachment A and Attachment B shall be conducted

pursuant to established procedures designed to collect evidence in a manner consistent with

professional responsibility requirements concerning the maintenance of attorney-client and other

operative privileges. When appropriate, the procedures shall include use of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

-7-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 10 of 57

,,r' 'J,r r1L, rt~


;"',\;;;l lf"\'i
\h, '""''

SEP 2 l wm
IN THE UNITED STATES DISTRICT COURT
Clerk U.S. rnstrlct & Bankru\ltcy
FOR THE DISTRICT OF COLUMBIA r.ourt; for \lie O\stric1 oi Columbia

IN THE MATTER OF THE SEARCH OF


Case: 1:18-sc-02921
INFORMATION ASSOCIATED WITH TWO
Assigned To: Howell, Beryl A
ACCOUNTS STORED AT PREMISES
Assign. Date: 9/27/2018
CONTROLLED BY GOOGLE
Description: Search & Seizure Warrant

ORDER

The United States has filed a motion to seal the above-captioned warrant and related

documents, including the application and affidavit in support thereof (collectively the "Warrant"),

and to require Google, an electronic communication and/or remote computing services provider

headquartered in Mountain View, California, not to disclose the existence or contents of the

Warrant pursuant to 18 U.S.C. § 2705(b).

The Court finds that the United States has established that a compelling governmental

interest exists to justify the requested sealing, and that there is reason to believe that notification

of the existence of the Warrant will seriously jeopardize the investigation, including by giving the

targets an opportunity to flee from prosecution, destroy or tamper with evidence, and intimidate

witnesses. See 18 U.S.C. § 270S(b)(2)-(5).

IT IS THEREFORE ORDERED that the motion is hereby GRANTED, and that the

warrant, the application and affidavit in support thereof, all attachments thereto and other related

materials, the instant motion to seal, and this Order be SEALED until further order of the Court;

and
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 11 of 57

IT IS FURTHER ORDERED that, pursuant to 18 U.S.C. § 2705(b), Google and its

employees shall not disclose the existence or content of the Wa.1Tant to any other person (except

attorneys for Google for the purpose of receiving legal advice) for a period of one year or until

further order of the Court.

THE HONORABLEBRYL A. HOWELL


CHIEF UNITED STATES DISTRICT JUDGE

Wi,r(;pr!
Date

2
Case
AO 106 (Rev. 04/lO) 1:19-mc-00029-CRC
Application for a Search Warrant Document 29-28 Filed 04/28/20 Page 12 of 57

UNITED STATES DISTRICT COURT tF: J! lL r;


for the
District of Columbia SEP 2 '/ 201t\
Clark, U.S. District & [)ankruptcy
In the Matter of the Search of
Cm:rt::1 J1Jr thg nil'ltfict of Cnhnn.bla
)
(Briefly describe the property to be searched ) Case: 1:18-sc-02921
or identify the person by name and address) )
INFORMATION ASSOCIATED WITH Assigned To : Howell, Beryl A.
)
TWO ACCOUNTS STORED AT PREMISES ) Assign. Date: 9/27/2018
CONTROLLED BY GOOGLE ) Description: Search & Seizure·Warrant

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property Jo be searched and give its location):

See Attachment A
Northern
located in the - - - -----
District of _ __-C-.-a..li...fo,,.r_..n...,ia.__ _ _ , there is now concealed (identify the
person or describe the property to be seized):
See Attachment B

The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
r'lf evidence of a cri1ne;
ref contraband, fruits of crime, or other items illegally possessed;
ref property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
52 U.S.C. § 30121 Foreign Contribution Ban
18 U.S.C. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit. ·

r./ Continued on tbe attached sheet.


0 Delayed notice of days (give exact ending date if more than 30 days: _ _ _ _ _ ) is reqnested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA: Applicant's signatui·e

!Kyle R. Fre~ny (ASC)


I Patrick J. Myers, Special Agent, FBI
Printed name and title

Sworn to before me and signed in my presence.

~--------,,,~d
7
~
Judge's signature

City and state: Washingto_n_,_D_.C_.________ Hon. Beryl A Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 13 of 57

er:1:i ·,·,. ·1 UI
;i;_ 1
,n1''G
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA C1~rk, U.S. lllotrlct & Hankruptcy
Courts tor tt10 District o1 Golumbla

IN THE MATTER OF THE SEARCH OF Case: 1:18~sc-02921


INFORMATION ASSOCIATED WITH Assigned To : Howell, Beryl A.
TWO ACCOUNTS STORED AT PREMISES Assign. Date: 9/27/2018
CONTROLLED BY GOOGLE Description: Search & Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Patrick J. Myers, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for

information associated with the Google accounts registered to and

(the "Target Accounts 1 & 2"), stored at premises owned, maintained,

controlled or operated by Google, LLC ("Google"), a company headquartered in Mountain View,

California. As set forth below, the Target Accounts

Upon receipt of the information

described in Attachment A, government-authorized persons will review that information to locate

the items described in Attachment B.

2. I am a Special Agent with the Federal Bureau oflnvestigation ("FBI") assigned to

FBI Pittsburgh working directly with the Special Counsel's Office. I have been a Special Agent

with the FBI since 2017. I was previously employed as a network and software engineer for

approximately fifteen years, including for the FBI. As a Special Agent, I have conducted national

security investigations relating to foreign intelligence and cybersecurity.

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

-1-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 14 of 57

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Accounts contains evidence, fruits, or

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C, § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a protected

computer), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud), 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C. § 1513 (witness

tampering), and 52 U.S.C. § 3012l(a)(l)(C) (foreign expenditure ban). There also is probable

cause to search the information described in Attachment A for evidence, contraband, fruits,

and/or instrumentalities of the Subject Offenses, further described in Attachment B.

JURISDICTION

5. This Court has jurisdiction to issue the requested warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)(l )(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18. U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

PROBABLE CAUSE

A. Background on Relevant Individuals

i. Roger STONE

6. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

-2-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 15 of 57

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

7. Jerome CORSI is a political commentator who, according to publicly available

inf01mation, served as the "Washington Bureau Chief for Inforwars.com." According to

publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WND.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of 2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

-3-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 16 of 57

B. Russian Government-Backed Hacking Activity During the 2016 Presidential


Election

9. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Government developed a clear preference for President-elect Trump.

10. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian govennnent employed during its interference. The USIC summarized the effmis

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Govennnent agencies, state-funded media, third-pmiy

intermediaries, and paid social media users or 'trolls."'

11. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

services conducted cyber operations against targets associated with the 2016 US presidential

election, including targets associated with both major US political parties." Further, "[i]n July

2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities

to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

-4-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 17 of 57

in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

12. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

13. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

14. The Special Connsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

15. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-compnting service. In or aronnd late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's ovm technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

16. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a fotmer White House advisor who was then advising the Clinton Campaign. These

emails were later post on DCLeaks.

17. On or about November 1, 2016, individuals associated with the GRU

spearphished over 100 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

-5-
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 18 of 57

18. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

presidential election, including conspiracy to commit authorized access to protected computers.

See United States v. Viktor Borisovich Netyksho, et al. (Case No. 1: 18-cr-OO 125).

C. STONE's Public Interactions with Guccifer 2.0 and WikiLcaks

19. On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian govermuent actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility fol' the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

20. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.

21. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Guccifer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

why he did the hack of the DNC." The atiicle also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

22. On August 8, 2016, STONE addressed the Southwest Broward Republican

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Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

aimed at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With

regard to the October surprise, what would be your forecast on that given what Julian Assange

has intimated he's going to do'/" STU NE responded: ''Well, it could be any number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain

to the Clinton Foundation but there's no telling what the October surprise may be." A few days

later, STONE clarified that while he was not personally in touch with AS SAN GE, he had a close

friend who served as an intermediary.

23. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoneJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

24. On August 13, 2016, STONE posted a tweet using@RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

25. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

26. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated

that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.

27. On August 21, 2016, using @RogerJStoneJR, STONE tweeted: "Trust me, it will

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soon the [sic] Podesta's time in the ba1Tel. #CrookcdHillary." In a C-SPAN interview that same

day, STONE reiterated that because of the work of a '"mutual acquaintance' of both his and

[ASSANGEJ, the public [could] expect to see much more from the exiled whistle blower in the

form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... I think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abedin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

28. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLeaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

29. On Saturday, October 1, 2016, using@RogerJStoneJr, STONE tweeted,

"Wednesday @HillaryClinton is done. #WildLeaks."

30. On Sunday, October 2, 2016, MSNBC _Moming Joe producer Jesse Rodriquez

tweeted regarding an announcement AS SAN GE had scheduled foi" the next day from the balcony

of the Ecuadoran Embassy in London. On the day of the ASSANGE am1ouncement -which was

part of WikiLeaks' 10-yeaT anniversary celebration - STONE told Infowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE nsed@RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

31. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an article containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

32. Approximately a half hour later, at 4:32 PM, WikiLeal(s sent a Tweet reading

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"RELEASE: The Podesta Emails #HillaryClinton #Podesta #imWithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

33. WikiLealcs continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta- refeITing back to STONE's August 21,

2016 C-SP AN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this infonnation on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying l have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that Huma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

34. On March 27, 2017, CNN reported that a representative of WikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

D. STONE's Private Twitter Direct Messages with WikiLeaks and ASSANGE

35. On October 13, 2016, while WikiLealcs was in the midst of releasing the hacked

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Podesta emails, the Twitter account @RogerJStoneJr sent a private direct message to the Twitter

account @wikilcaks. 1 The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

to rexamine the strategy of attacking me- cordially R."

36. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

37. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operationleaks like a sieve. You need to figure out who your friends are."

38. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

39. In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE,

the founder ofWikiLeaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with AS SAN GE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get infonnation only that it is

accurate and authentic. The New Y orlc Times printed the Pentagon Papers which were

1On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
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indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restrnining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

40. On Saturday, June 10, 2017, @RogerJStoneJr sent a direct message to

@JulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks

41. On September 11, 2017, Chief Judge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address On October 17,

2017, Chief Judge Howell issued a search warrant for one ofSTONE's addresses,

On or about December 19, 2017, Chief Judge Howell issued a search

warrant for email account. On or about March 14, 2018, Chief Judge Howell

issued a search warrant for STONE's iCloud account. Information recovered pursuant to those

search warrants indicated the following:

42. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger

Stone so he knows your availability to meet Manafort and DT this coming week." CORSI

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appears to have forwarded the message to STONE at who replied to

CORSI that, "May meet Manafo1t -guarantee nothing."

43. On or about May 18, 2016, CORSI emailed STONE at

with the title, "Roger -- why don't you look this over before I send it I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recogpized us immediately and

was very cordial. He would look for this memo from you this afternoon."

44. On July 25, 2016, STONE, using sent arr email to

CORSI with the subject line, "Get to Assarrge." The body of the message read: "Get to Assarrge

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."

45. On or about July 31, 2016, STONE, using emailed

CORSI with the subject line, "Call me MON." The body of the email read: " should see

Assarrge[.] should find Bernie [S]arrders brother who called Bill a Rapist-tmn him for

Trmnp[.] should find or more proof of Bill getting kicked out."

46. On or about August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the barrel"), CORSI emailed STONE at

"Word is frie11.d in embassy plans 2 more dumps. One shortly after I'm

back. 2nd in Oct. Impact planned to be very damaging." The email continued, "Signs are Fox

will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor,

for now. Post-DNC bump for HRC arr artifact of rigged polling. Won't last. I expect presidential

campaign to get serious starting Sept. Still in pre-season games. Time to let more than Podesta to

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be exposed as in bed w enemy if they are not ready to drop HRC. That appears to be the game

hackers are now about. Would not hurt to start suggesting HRC old, memory bad, has stroke --

neither he nor she well. I expect that much of next dump focus, setting stage for Foundation

debacle." Investigators believe that CORSI's reference to a "friend in embassy [who] plans 2

more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in 2016.

47. On or about August 5, 2016, an associate of STONE's, emailed

STONE at The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet AS SANGE. also stated

that in 2018, told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting ASSANGE. STONE told he was joking and

had not actually met ASSANGE. 2

48. Through a search of STONE's iCloud account, the FBI has uncovered evidence

suggesting that STONE was in Los Angeles for one or more meetings at the time that he claimed,

in his email to to have "dined" with ASSANGE. For example, an associate of

STONE sent a text to STONE at approximately 3 :38PM on August 2, asking "How did ur meeting

go in LA?" STONE responded. "It's this afternoon[.]" The following day, the associate asked,

"Any report from ur meeting?" On or about August 4, 2016, STONE texted the associate, "Will

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call later- heading for airport now[.]" Additionally, investigators have identified a photograph in

STONE's iCloud that appears to have been taken on August 3, 2016 and had geo-location

information indicating that it was taken in Los Angeles.

49. On or about August 15, 2016, CORSI emailed STONE at

"Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

50. On or about August 31, 2016, CORSI emailed STONE at

"Did you get the PODESTA writeup." STONE replied "[y]es."

51. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $180k to

invest in Uranium One -was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Yanukovych - Panama papers reveals Podesta hired by

S[b]erbank, Russia's largest financial institution-Podesta$$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

52. On or about September 6, 2016, CORSI emailed STONE at

"Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

53. On or about September 24, 2016, emailed CORSI, "I will have much

more on Turkey. Need a back chaunel highly sensitive stuff." CORSI responded, "We have

secure back chaunel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today." wrote back, "Awaiting secret file. Explosive... Hope you are well.

Can't wait for the debate. Chauneling Reagan, I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators, indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

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54. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange - what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON, who was CEO of the Campaign at the time, and wrote: "You should call Roger. See

below. You didn't get from me." BANNON wrote back, "I've got important stuff to worry

about." The associate responded, "Well clearly he knows whatAssange has. I'd say that's

important."

55. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

AS SANGE would release information damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

56. On or about October 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

57. That same day, BANNON emailed STONE a "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawyer is a big

democrat."
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 28 of 57

58. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018; he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON aclmowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to AS SAN GE, and

BANNON had been hoping for releases of damaging information that morning.

F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

59. According to a publicly available news article, 3 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."

60. According to phone records at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

61. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

62. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

63. At approximately 2:18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

3 https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07 /3 ld74 714-8ce5-11e6-875e-2c 1bfe943b66_ story.html

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64. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

65. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE using "I expect

that much of next dump focus, setting stage for Foundation debacle."

66. At approximately 6:27PM, an author who has written about the

Clinton Foundation, and who, according to emails and phone records, regularly communicates

with STONE, sent STONE an email titled, "WikiLeaks - The Podesta Emails," with a link to the

newly-released Podesta emails. Approximately ten minutes later, STONE, using

forwarded message to CORSI without comment. STONE

does not appear to have forwarded the email to any other individual.

G. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE Is
Accused of Advance Knowledge of the Leak

67. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed-

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacldng bad job

numbers."

68. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

using emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

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Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

69. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at both with the subject

line "Podesta talking points." Attached to the email was a file labeled, "ROGER STONE

podesta talking points Oct 12 2016.docx." The "talking points" included the statement that

"Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation."

70. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Account, "Got them and used them."

71. On or about Thursday, October 13, 2016, CORSI emailed STONE at

"PODESTA -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I'll give you one more-NOBODY YET HAS THIS[:] It looks to me

like skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] [web link] Once

had the channel open from Metcombank to Deutsche Bank America to Ban[k] of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

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Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

72. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email at with the subject, "ROGER STONE article

KUSS1AN MAJ:ilA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOrIN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

have had some back-channel communications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money did a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian government, launder through

Metcombank, a Russian regional bank owned 99 .978 percent by with the money

transferred via Deutsche Bank and Trust Company Americas in New York City, with the money

ending up in a private bank account in the Bank of America that is operated by the Clinton

Foundation?"

73. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

74. On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now- before 2prn[.]" STONE responded, "Missed u-just

landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

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75. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

AS SAN GE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand off[.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. IfHRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election." Based on review of the original email that CORSI forwarded, the

"trusted source" was a self-identified retired librarian who gathers information from public chat

rooms.

76. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

77. On or about October 19; 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice ofWikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta' s business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

78. On or about November 8, 2016, the United States presidential election took place.

79. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

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80. On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in

London. Have some interesting news for you."

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I. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikilcaks

88. On September 26, 2017, STONE testified before the House Pennanent Select

Committee on Intelligence (HPSCI). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In. them, STONE stated:

Members of this Committee have made three basic asse1tions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman Jolm Podesta's email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillm-y Clinton or
that, my now public exchange with a persona that our intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such assertions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trust me, it will soon be the Podesta's
time in the barrel. #CrookedHillary" must be exan1ined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regm·ding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but
does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranium deal, their bank deal, and their Gazprom deal,
would come under public scrutiny....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] armounced that he was in possession of Clinton DNC emails.
I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed
Assange to independently confirm this report, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
information proved to be correct. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

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89. In a document dated March 26, 2018 titled "Minority Views," Democratic

members ofHPSCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in
communication with Assange or communication through an intermediary with Assange,
you were only refe1Ting to a single fact that you had confirmed with the intermediary -
MR. STONE: That -
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is con-ect, even though it was repeated to me on numerous separate
occasions.

90. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an article on his website, stonecoldtruth.com, titled "Is it the Podesta' s

Time in the B=el Yet?" In that ariicle, STONE stated: "[I]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the ban-el' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet refe1Ted to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

J. STONE's Messaging to Randy CREDICO about STONE's "Back channel"

91. On or about November 19,.2017, Randy CREDICO (who, as described further

below, STONE publicly identified as his "intermediary" to ASSANGE), messaged STONE, "My

lawyer wants to see me today." STONE responded, "'Stonewall it. Plead the fifth. Anything to

save the plan' ........Richard Nixon[.]" CREDICO responded, "Ha ha."

92. On or about November 21, 2017, CREDICO messaged STONE, "I was told that

the house connnittee lawyer told my lawyer that I will be getting a subpoena[.]'' STONE wrote

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back, "That was the point at which your lawyers should have told them you would assert your

5th Amendment rights if compelled to appear." They continued to message, and CREDI CO

wrote, "My lawyer wants me to cut a deal." STONE wrote back, 'To do what? Nothing

happening in DC the day before Thanksgiving - why are u busting my chops?"

93. On or about November 24, 2017, STONE, texted CREDICO, "Assange is a

journalist and a damn good one- meeting with him is perfectly legal and all you ever told me was

he had the goods [oJn Hillary and would publish them - which he himself said in public b4 u told

me. It's a fucking witchunt [sic]." CREDICO replied, "I told you to watch his tweets. That's

what I was basing it on. I told you to watch his Tweets in October not before that I knew nothing

about the DNC stuffI.J I just followed his tweets[.]" STONE responded, "U never said anything

about the DNC but it was August." CREDICO wrote back, "It was not August because I didn't

interview him or meet him until August 26th[.] That was my :first communication with his

secretary in London, August 26th." STONE wrote back, "Not the way I remember it - oh well I

guess Schiff will try to get one ofus indicted for perjmy[.]"

94. STONE and CREDI CO continued to exchange messages and on November 24,

2017, CREDICO wrote to STONE, "Forensic evidence proves that there is no back Channel. So

now you can relax."

95. On or about November 28, 2017, CREDICO tweeted a copy of a subpoena he

received from HPSCI that was dated November 27, 2017. Toll records show that on November

27 and 28, 2017, CREDICO and STONE communicated via text message more than a dozen

times.

96. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that "Credico merely[]

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confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credico never said he knew or had any infmmation as to source or

content of the material."

97. On or about December 1, 2017, CREDICO messaged STONE, "I don't lmowwhy

you had to lie and say you had a back Channel now I had to give all of my forensic evidence to

the FBI today what a headache[.] 4 You could have just told him the truth that you didn't have a

back Channel they now lmowthat I was not in London tmtil September of this year[.] You had

no back-chatmel and you could have just told the truth ... You want me to cover you for pe1jury

now[.]" STONE responded, "What the fuck is your problem? Neither ofus has done anything

wrong or illegal. You got the best press of your life and you can get away with asse1iing for 5th

Amendment rights ifu don't want talk about AND if you turned over anything to the FBI you're

a fool." CREDICO resp~nded, "You open yourself up to six counts ofpe1jury[.] But I'm sure

that wasn't sworn testimony so you're probably clear[.] Council for the connnittee knows you

never had a back Channel and if you had just told the truth wouldn't have put me in this bad spot

... you should go back ... and am.end your testimony and tell them the truth." CREDICO

repeated: "you need to amend your testimony before I testify on the 15th." STONE replied, "If

· you testify you're a fool. Because of tromp [sic] I could never get away with a certain [sic] my

Fifth Amendment rights but you can. I guarantee you you [sic] are the one who gets indicted for

perjury if you're stupid enough to testify[.]"

4Contrary to his statement, CREDICO had not at that time provided any forensic evidence to the
FBI.

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98. STONE and CREDICO continued to message each other on or about December 1,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fuck off good night." CREDICO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

99. On or about December 13, 2017, according to public reporting, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

I 00. STONE and CREDICO continued to exchange text messages, and on or about

January 6, 2018, CREDICO indicated to STONE that he was having dinner with a rep01ter.

STONE responded, "Hope u don't fuck Up my effo1ts to get Assange a pardon[.]" CREDICO

messaged STONE, "I have the email from his chief of staff August 25th 2016 responding to an

email I sent to WikiLeaks website email address asking you would do my show[.] That was my

initial contact."

101. On or about January 8, 2018, CREDICO messaged STONE, stating: "Embassy

logs ... + 17 other pieces of information prove that I did not have any conversations with

Assange until September oflast yeai."

102. CREDICO and STONE continued to message each other, and on or about Januaty

25, 2018, CREDICO wrote to STONE: "You lied to the house Intel committee ... But you'll get

off because you're friends with Tnunp so don't worr):'. I have all the forensic evidence[.] I was

not a ba[ ck] Channel and I have all those emails from September of 2016 to prove it[.]"

103. On or about April 13, 2018, news rep01ts stated that CREDICO had shown

repo1ters copies of email messages he had received from STONE in the prior few days that

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Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 40 of 57

stated, "You arc a rat. You are a stoolie. You backstab your friends - run your mouth my

lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

from you," referring to CREDICO's therapy dog. CREDICO slated that it was "certainly scary .

. . When you start bringing up my dog, you're crossing the line[.]" 5

104. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

He was depressed about it. Or was he lying." The aiticle noted that CREDI CO stated he did not

have prostate cancer and did not have any such discussion with STONE.

K. The Target Accounts

5 https://www.yahoo.com/news/comedian-randy-credico-says-trump-adviscr-roger-stone-

threatened-dog-135911370.html
6 https ://www.mothcrj ones.com/politics/2018/05/ro gcr-stone-to-associate-prcpare-to-die/

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Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 42 of 57

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BACKGROUND CONCERNING GOOGLE

115. In my training and experience, I have learned that Google provides a variety of on-

line services, including electronic mail ("email") access, to the public. Google allows subscribers

to obtain email accounts at the domain name gmail.com, like the Target Accounts. Subscribers

obtain an account by registering with Google. During the registration process, Google asks

subscribers to provide basic personal information. Therefore, the computers of Google are likely

to contain stored electronic communications (inclnding retrieved and umetrieved email) for

Google Mail subscribers and information concerning subscribers and their use of Google Mail

services, such as account access information, email transaction information, and account

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application inforn1ation. In my training and experience, such information may constitute evidence

of the crimes under investigation because the information can be used to identify the account's

user or users.

116. In my training and experience, email providers generally ask their subscribers to

provide certain personal identifying inforn1ation when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and other

identifiers, alternative email addresses, and, for paying subscribers, means and source of payment

(including any credit or bank account number). In my training and experience, such information

may constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users. Based on my training and my experience, I know that, even if

subscribers insert false infonnation to conceal their identity, this information often provides clues

to their identity, location, or illicit activities.

117. In my training and experience, email providers typically retain certain transactional

info1mation about the creation and use of each account on their systems. This information can

include the date on which the account was created, the length of service, records of log-in

(i.e., session) times and durations, the types of service utilized, the status of the account (including

whether the account is inactive or closed), the methods used to connect to the account (such as

logging into the account via the provider's website), and other log files that reflect usage of the

account. In addition, email providers often have records of the IP address used to register the

account an.d the IP addresses associated with particular logins to the account. Because every device

that connects to the Internet must use an IP address, IP address information can help to identify

which computers or other devices were used to access the email account.

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118. In my training and cxpenence, m some cases, email account users will

communicate directly with an email service provider about issues relating to the account, such as

technical problems, billing inquiries, or complaints from other users. Email providers typically

retain records about such communications, including records of contacts between the user and the

provider's support services, as well as records of any actions taken by the provider or user as a

result of the communications. In my training and experience, such information may constitute

evidence of the crimes under investigation because the information can be used to identify the

account's user or users.

119. This application seeks a wanant to search all responsive records and information

under the control of Google, a provider subject to the jurisdiction of this court, regardless of where

Google has chosen to store such information. The government intends to require the disclosure

pursuant to the requested wanant of the contents of wire or electronic communications and any

records or other information pertaining to the customers or subscribers if such communication,

record, or other information is within Google's possession, custody, or control, regardless of

whether such communication, record, or other information is stored, held, or maintained outside

the United States.

120. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of occupancy"

while executing a search wanant at a residence. For example, email communications, contacts

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Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 46 of 57

lists, and images sent (and the data associated with the foregoing, such as date and time) may

indicate who used or controlled the account at a relevant time. Further, information maintained by

the email provider can show how and when the account was accessed or used. For example, as

described below, email providers typically log the Internet Protocol (IP) addresses from which

users access the email account, along with the time and date of that access. By determining the

physical location associated with the logged IP addresses, investigators can understand the

chronological and geographic context of the email account access and use relating to the crime

under investigation. This geographic and timeline information may tend to either inculpate or

exculpate the account owner. Additionally, information stored at the user's account may further

indicate the geographic location of the account user at a particular time (e.g., location information

integrated into an image or video sent via email). Last, stored electronic data may provide relevant

insight into the email account owner's state of mind as it relates to the offense under investigation.

For example, information in the email account may indicate the owner's motive and intent to

commit a crime (e.g., communications relating to the crime), or consciousness of guilt

(e.g., deleting communications in an effort to conceal them from law enforcement).

FILTER REVIEW PROCEDURES

121. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner c~nsistent

with professional responsibility requirements concerning the maintenance of attorney-client and

other operative privileges. The procedures include use, if necessary, of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

CONCLUSION

122. Based on.the forgoing, I request that the Court issue the proposed search wanant.

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123. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

REQUEST FOR SEALING

124. I further request that the Court order that all papers in supp01i of this application,

including the affidavit and search warrant, be sealed until frniher order of the Court. These

documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

Special Agent
Federal Bureau oflnvestigation

Subscribed and sworn to before me on this ~ a y of September, 2018.

The Honorable Beryl A. Howell


Chief United States District Judge

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Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 48 of 57

ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the Google accounts registered to the

following email addresses, which are stored at premises owned, maintained, controlled, or

operated by Google, LLC ("Google"), a company headquartered in Mountain View, California:

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Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 49 of 57

e. All records pe1taining to communications between the Provider and any person

regarding the account, including contacts with suppmt services and records of

actions taken;

f. All subscriber "change history" associated with the account;

g. All search hislory aml web hislory associated with the account;

h. All location and maps information associated with the account;

1. All Google Analytics information associated with the account (including all

properties and UA codes associated with the account, and, for each of these

proprieties and UA codes, all usemarnes and email accounts associated with them);

j. All Google Developers Console information associated with the account;

k. All Minutemaid information associated with the account;

I. All Android information associated with the account;

m. All Google Docs associated with the account;

n. All YouTube information associated with the account;

o. All Google Hangouts information associated with the account;

p. All Google Voice information associated with the account;

q. All Web & App Activity associated with the account;

r. All Google Drive information associated with the account;

s. All Google+ information associated with the account;

t. All device information associated with the account, including all instrument or

telephone numbers (including MAC addresses, Electronic Serial Numbers

("ESN"), Mobile Electronic Identity Numbers ("MEIN"), Mobile Equipment

Identifier ("MEID"), Mobile Identification Numbers ("MIN"), Subscriber Identity

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Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 50 of 57

a. All records, infoimation, documents or tangible materials that relate in any way to

commnnications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material; '

b. All records, infmmation, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico, any

individual associated with the Trump Campaign, any witness in the investigation;

c. Commnnications, records, documents, and other files related· to any expenditure,

independent expenditure, or disbursement for an electioneering commnnication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

govermnent, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, commnnications, calendar entries, seaTch terms, "address

book" entries and contacts, including any and all preparatory steps talcen in

furtherance of the above-listed offenses;

f. Commnnications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign govermnent, foreign officials, foreign entities, foreign persons, or

foreign principals;

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Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 51 of 57

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's state of mind as it relates to the crimes under

investigation;

1. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

1. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)-including records that help reveal the whereabouts

of the person(s}--who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

· principals.

n. . Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

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Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 52 of 57

III. Review Protocols

Review of the items described in Attaclnnent A and Attaclnnent B shall be conducted

pursuant to established procedures designed to collect evidence in a manner consistent with

professional responsibility requirements concerning the maintenance of attorney-client and other

operative privileges. When appropriate, the procedures shall include use of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

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Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 53 of 57

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE SEARCH OF Case: 1:18-sc-02921


INFORMATION ASSOCIATED WITH TWO Assigned To: Howell, Beryl A.
ACCOUNTS STORED AT PREMISES Assign. Date: 9/27/2018
CONTROLLED BY GOOGLE Description: Search & Seizure Warrant

MOTION TO SEAL WARRANT AND RELATED DOCUMENTS AND


TO REQUIRE NON-DISCLOSURE UNDER 18 U.S.C. § 2705(b)

The United States of America, moving by and through its undersigned counsel, respectfully

moves the Court for an Order placing the above-captioned warrant and the application and affidavit

in support thereof(collectively herein the "Wan-ant") under seal, and precluding the provider from

notifying any person of the Wan-ant pursuant to 18 U.S.C. § 2705(b). In regard to the non-

disclosure, the proposed Order would direct Google, an electronic communication and/or remote

computing services provider headquartered in Mountain View, California, not to notify any other

person (except attorneys for Google for the purpose of receiving legal advice) of the existence or

content of the Warrant for a period of one year or until fiuther order of the Comt.

WRISDICTION AND LEGAL BACKGROUND

1. The Court has the inherent power to seal court filings when appropriate,

including the Wan-ant. United States v. Hubbard, 650 F.2d 293, 315-16 (D.C. Cir. 1980) (citing

Nixon v. Warner Communications, Inc., 435 U.S. 589, 598 (1978)). The Court may also seal the

Wanant to prevent serious jeopardy to an ongoing criminal investigation when, as in the present

case, such jeopardy creates a compelling governmental interest in preserving the confidentiality of

the Wmrant. See Washington Post v. Robinson, 935 F.2d 282, 287-89 (D.C. Cir. 1991).

2. In addition, this Comt has jurisdiction.to issue the requested order because it is "a

court of competent jurisdiction" as defined by 18 U.S.C. § 2711. Specifically, the Court is a

"district court of the United States ... that - has jurisdiction over the offense being investigated."
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 54 of 57

18 U.S.C. § 2711(3)(A)(i). Acts or omissions in furtherance of the offense under investigation

occmred within Washington, D.C. See 18 U.S.C. § 3237.

3. Further, the Court has authority to require non-disclosure of the Warrant under 18

U.S.C. § 2705(b). Google provides an "electronic communications service," as defined in 18

U.S.C. § 2510(15), and/or "remote computing service," as defined in 18 U.S.C. § 2711(2). The

Stored Communications Act ("SCA"), 18 U.S.C. §§ 2701-2712, governs how Google may be

compelled to supply communications and other records using a subpoena, comt order, or search

warrant. Specifically, Section 2703(c)(2) authorizes the Government to obtain certain basic

"subscriber information" using a subpoena, Section 2703(d) allows the Government to obtain other

"non-content" infmmation using a comt order, and Section 2703(a)-(b)(l)(A) allows the

Government to obtain contents of communications using a search warrant. See 18 U.S.C. § 2703.

4. The SCA does not set forth any obligation for providers to notify subscribers about

subpoenas, court orders, or search wanants under Section 2703. However, many have voluntarily

adopted policies of notifying subscribers about such legal requests. Accordingly, when necessary,

Section 2705(b) of the SCA enables the Government to obtain a court order to preclude such

notification. In relevant part, Section 2705(b) provides as follows: 1

(b) Preclusion of notice to subject of governmental access. - A governmental


entity acting under section 2703 ... may apply to a court for an order commanding
a provider of electronic communications service or remote computing service to
whom a warrant, subpoena, or court order is directed, for such period as the court
deems appropriate, not to notify any other person of the existence of the warrant,
subpoena, or court order. The court shall enter such an order if it determines that
there is reason to believe that notification of the existence of the warrant, subpoena,
or court order will result in-
(1) endangering the life or physical safety of an individual;
(2) flight from prosecution;

1 Section 2705(b) contains additional requirements for legal process obtained pursuant to 18 U.S.C.
§ 2703(b)(l)(B), but the Government does not seek to use the proposed Order for any legal process
under that provision.

2
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 55 of 57

(3) destruction of or tampering with evidence;


(4) intimidation of potential witnesses; or
(5) otherwise seriously jeopardizing an investigation or unduly delaying a trial.

18 U.S.C. § 2705(b ). The United States District Court for the District of Columbia has made clear

that a nondisclosure order under Section 2705(b) must be issued once the Government makes the

requisite showing about potential consequences of notification:

The explicit terms of section 2705(b) make clear that if a courts [sic] finds that there
is reason to believe that notifying the customer or subscriber of the court order or
subpoena may lead to one of the deleterious outcomes listed under§ 2705(b), the
court must enter an order commanding a service provider to delay notice to a
customer for a period of time that the court determines is appropriate. Once the
government makes the required showing under § 2705(b), the court is required to
issue the non-disclosure order.

In re Application for Order of Nondisclosure Pursuant to 18 USC § 2705(b) for Grand Jury

Subpoena #GJ2014031422765, 41 F. Supp. 3d 1, 5 (D.D.C. 2014).

5. Accordingly, this motion to seal sets forth facts showing reasonable grounds to

command Google not to notify any other person (except attorneys for Google for the purpose of

receiving legal advice) of the existence of the Subpoena for a period of one year or until further

order of the Court.

FACTS SUPPORTING SEALING AND NON-DISCLOSURE

6. The Federal Bureau oflnvestigation ("FBI") is investigating violations ofl 8 U.S.C.

§ 2 (aiding and abetting); 18 U.S.C. § 3 (accessory after the fact); 18 U.S.C. § 4 (misprision of a

felony); 18 U.S.C. § 371 (conspiracy); 18 U.S.C. § 1030 (unauthorized access of a protected

computer); 18 U.S.C. § 1343 (wire fraud); 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud); and 52 U.S.C. § 30121 (foreign contribution ban) (the "Subject Offenses"), in

connection with efforts to compromise the networks of the Democratic National Convention

("DNC"}, the Democratic Congressional Campaign Committee ("DCCC"), and the email accounts

of U.S. persons, followed by the public release of stolen materials through various outlets.

3
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 56 of 57

7. In this matter, the government requests that the Warrant be sealed until further order

of the Court and that Google and its employees be directed not to notify any other person of the

existence or content of the Wmrnnt (except attorneys for Google for the purpose ofreceiving legal

advice) for a period of one year or until further order of the Court. Such an order is appropriate

because the Wanant relates to an ongoing criminal investigation, the scope and nature of which is

neither public nor known to the targets of the investigation, and its disclosure may alert these

targets to the nature, scope, and focus of the ongoing investigation. Disclosure of the Warrant and

related papers may also alert the targets to the scope of information known to the FBI. Once alerted

to this information, potential targets would be immediately prompted to destroy or conceal.

incriminating evidence, alter their operational tactics to avoid future detection, and otherwise take

steps to undermine the investigation and avoid future prosecution. In particular, given that they

are !mown to use electronic communication and remote computing services, the potential target

could quickly and easily destroy or encrypt digital evidence relating to their criminal activity.

8. Given the complex and sensitive nature of the criminal activity under investigation,

and also given that the criminal scheme may be ongoing, the Government anticipates that this

confidential investigation will continue for the next year or longer. However, should

circumstances change such that court-ordered nondisclosure under Section 2705(b) becomes no

longer needed, the Government will notify the Court and seek appropriate relief.

9. There is, therefore, reason to believe that notification of the existence of the

WmTant will seriously jeopardize the investigation, including by giving the targets an opportunity

to flee from prosecution, destroy or tamper with evidence, and intimidate witnesses. See 18 U.S. C.

§ 2705(b)(2)-(5). Because of such potential jeopardy to the investigation, there also exists a

4
Case 1:19-mc-00029-CRC Document 29-28 Filed 04/28/20 Page 57 of 57

compelling govermnental interest in confidentiality to justify the govermnent's sealing request.

See Robinson, 935 F.2d at 287-89.

10. Based on prior dealings with Google, the United States is aware that, absent a court

order under Section 2705(b) commanding Google not to notify anyone about a legal request,

Google may, upon receipt of a warrant seeking the contents of electronically stored wire or

electronic communications for a certain account, notify the subscriber or customer of the existence

of the warrant prior to producing the material sought.

WHEREFORE, for all the foregoing reasons, the government respectfully requests that the

above-captioned warrant, the application and affidavit in support thereof, and all attachments

thereto and other related materials be placed under seal, and furthermore, that the Court command

Google not to notify any other person of the existence or contents of the above-captioned warrant

(except attorneys for Google for the purpose of receiving legal advice) for a period ofone year or

until further order of the Court.

Respectfully submitted,

ROBERT S. MUELLER, III


Special Counsel

By: /
Kyle . eeny
The Special Counsel '.s Office
(202) 616-3812

5
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 1 of 57
..1 and Seizure Warrant

.I
UNITED STATES DISTRICT COURT
for the
District of Columbia

In the Matter of the Search of


(Briefly describe the property to be searched
Case: 1: 18-sc-02922
or identify the person by name and address) Assigned To: Howell, Beryl A.
INFORMATION ASSOCIATED WITH ONE ACCOUNT
Assign. Date: 9/27/2018
STORED AT PREMISES Description: Search & Seizure Warrant
CONTROLLED BY APPLE /

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the govermnent requests the search
of the following person or property located in the Northern District of California
(identify the person or describe the property to be searched and give its location):

See Attachment A

I fmd that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the pe1wn or describe the property to be seized):

See Attachment B

YOU ARE COMMANDED to execute this warrant on or before October 11, 2018 (not to exceed 14 days)
,;{ in the daytime 6:00 a.m. to 10:00 p.m. 0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
prope,ty was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to -·· Hon. Beryl A. Howell, Chief U.S. District Judge ___
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), Ifind that immediate notification may have an adverse result listed in 18 U.S.C. j
§ 2705 (except for delay of trial), and autl1orize the officer executing this warrant to delay notice to the person who, or whose
propetty, will be searched or seized (check the appropriate box) II

Ii
0 for days (not to exceed 30) 0 until, the facts justifying, the later specific date of
'

Date and time issued: __ 1/J--r/7p17 c/' f'ld/A ~ , , / . ~


, · Judge's signature
I
11
City and state: Washington, DC Hon. Beryl A. Howell, Chief U.S. District Judge
.___
I!
Printed name and title

I
,I
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 2 of 57

AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return

Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of pe1jury that this inventmy is correct and was returned along with the original warrant to the
designated judge.

Date: -
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 3 of 57

ATTACHMENT A

Property to be Searched

This warrant applies to info1mation associated with the following accounts, which are

stored at premises owned, maintained, controlled, or operated by Apple, Inc. ("Apple"), a company

headquartered in Cupertino, California:

-1-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 4 of 57

ATTACHMENT B

I. Information to be disclosed by Apple

To the extent that the infonnation described in Attaclnnent A is within the possession,

custody, or control of the Apple, Inc. (hereinafter "the Provider"), regardless of whether such

information is stored, held or maintained inside or outside of the United States, and including

any emails, records, files, logs, or information that have been deleted but are still available to the

Provider, or has been preserved pursuant to a request made under 18 U.S.C. § 2703(:1:), the

Provider is required to disclose the following information to the govennnent for each account or

identifier listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved
copies of emails sent to and from the account, draft emails, the source and
destination addresses associated with each email, the date and time at which each
email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the account, to


include full name, physical address, telephone numbers and other identifiers,
records of session times and durations, the date on which the account was created,
the length of service, the IP address used to register the account, log-in IP addresses
associated with session times and dates, account status, alternative email addresses
provided during registration, methods of connecting, log files, and means and
source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the
account, including address books, contact and buddy lists, calendar data, pictures,
and files;

e. All records pertaining to communications between the Provider and any person
regarding the account, including contacts with support services and records of
actions taken; and other identifiers, records of session times and durations, the date
on which the account was created, the length of service, the types of service utilized,
the IP address used to register the account, log-in IP addresses associated with
session times and dates, account status, alternative e-mail addresses provided
during registration, all other user names associated with the account, all account
names associated with the subscriber, methods of connecting;

-2-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 5 of 57

f. All search histo1y or web history;

g. All records indicating the services available to subscribers of the accounts;

h. All usernames associated with or sharing a login IP address or browser cookie with
the accounts;

i. All cookies, including third-party cooldes, associated with the user;

J. All records that are associated with the machine cookies associated with the user;
and

k. All telephone or instrument numbers associated with the Account (including MAC
addresses, Electronic · Serial Numbers ("ESN"), Mobile Electronic Identity
Numbers ("MEIN"), Mobile Equipment Identifier ("MEID"), Mobile Identification
Numbers ("MIN"), Subscriber Identity Modules ("SIM"), Mobile Subscriber
Integrated Services Digital Network Number ("MSISDN"), International Mobile
Subscriber Identifiers ("IMSI"), or International Mobile Equipment Identities
("IMEI").

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June 1, 2016, to December 31, 2017, including:

a. All records, infmmation, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

-3-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 6 of 57

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, inf01mation, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi , Julian

Assang , Randy Creclico, Charles

Orte!, or any individual associated with the Tmmp Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expencliture, or disbursement for an electioneering communication;

d. Records of any furids or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and aH preparatory steps taken in

furtherance of the above-listed offenses;

f. Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials, foreign entities, foreign persons, or

foreign principals;

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence inclicating the account user's state of mind as it relates to the crimes under

investigation;

-4-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 7 of 57

i. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

I. The identity of any non-U.S. person(s)-including records that help reveal the

whereabouts of the person(s)-who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. Th~ identity of any person(s)-including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access information that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

III. Review Protocols

Review of the items described in Attachment A and Attachment B shall be conducted

pursuant to established procedures designed to collect evidence in a manner consistent with

professional responsibility requirements concerning the maintenance of attorney-client and other

-5-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 8 of 57

operative privileges. When appropriate, the procedures shall include use of a designated "filter

team," separate and apaii from the investigative team, in order to address potential privileges.

-6-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 9 of 57

FILED
IN THE UNITED STATES DISTRICT COURT
SEP 2 7 2018
FOR THE DISTRICT OF COLUMBIA Clerk, U.S. District & Bankruptcy
Courts for the District of Col~mbla

IN THE MATTER OF THE SEARCH OF Case: 1:18-sc-02922


INFORMATION ASSOCIATED WITH ONE Assigned To : Howell, Beryl A.
ACCOUNT STORED AT PREMISES Assign. Date : 9/27/2018
CONTROLLED BY APPLE, INC. Description: Search & Seizure Warrant

ORDER

The United States has filed a motion to seal the above-captioned warrant and related

documents, including the application and affidavit in support thereof (collectively the "Warrant"),

and to require Apple, Inc., an electronic conununication and/or remote computing services

provider headquartered in Cupertino, California, not to disclose the existence or contents of the

Warrant pursuant to 18 U.S.C. § 2705(b).

The Cowt finds that the United States has established that a compelling governmental

interest exists to justify the requested sealing, and that there is reason to believe that notification

of the existence of the Warrant will seriously jeopardize the investigation, including by giving the

targets an opportunity to flee from prosecution, destroy or tamper with evidence, and intimidate

witnesses. See 18 U.S.C. § 2705(b)(2)-(5).

IT IS THEREFORE ORDERED that the motion is hereby GRANTED, and that the

warrant, the application and affidavit in support thereof, all attachments thereto and other related

materials, the instant motion to seal, and this Order be SEALED until further order of the Court;

and
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 10 of 57

IT IS .FURTHER ORDERED that, pursuant to 18 U.S.C. § 2705(b), Apple and its

employees shall not disclose the existence or content of the Warrant to any other person (except

attorneys for Apple for the purpose of receiving legal advice) for a period of one year or until

futther order of the Court.

THE HONORAJ3LEOR LA. HOWELL


CHIEF UNITED STATES DISTRICT JUDGE

2
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 11 of 57

AO 106 (Rev, 04/ IO) Application for a Search Warrant

UNITED STATES DISTRICT COURT


FILED
for the SEP 27 2018
District of Columbia Clark, U.S. District & Bankruptcy
Courts for the District of Columbia.
In the Malter of the Search of ) Case: 1:18-sc-02922
(Briefly describe the property to he searched )
or idenlijy the person by name and address) ) Assigned To : Howell, Beryl A.
INFORMATION ASSOCIATED WITH ) Assign. Date : 9/27/2018
ONE ACCOUNT STORED AT PREMISES CONTROLLED ) Description: Search & Seizure Warrant
BY APPLE )

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or prope1ty (identify the person or describe the
property to be searched and give its location):

See Attachment A
located in the Northern District of California , there is now concealed (identify the
--- ·--~===----
person or describe the property to be setzed):
See Attachment B

The basis for the search under Fed. R. Crim. P. 4 l(c) is (check one or mo,e):
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
d property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
52 u.s.c. § 30121 Foreign Contribution Ban
18 u.s.c. §§ 1001, 1030, 371 False Statements, Unauthorized Access of Protected Computer, Conspiracy
See Affidavit for add'I
The application is based on these facts:
See attached Affidavit.

r;( Continued on the attached sheet.


0 Delayed notice of days (give exact ending date if more than 30 days: _ _ _ _ ) is requested
under I 8 U.S.C. § 3 I 03a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA: Applicanr 's signawre

!Kyle R. Freeny (ASC) Patrick J. Myers, S_pecial Agent, FBI


Printed name and Jitle

Sworn to before me and signed in my presence.

Date: _ t/;, ?j}!/1 ~. f(~~


Judge's signature

City and state: Washington, _D_.c_._ _ _ _ __ --~H~on. Beryl A Howell, Chief U.S. District Judge
Printed name and tille
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 12 of 57

FILED
IN THE UNITED STATES DISTRICT COURT SEP 2 7 2018
FOR THE DISTRICT OF COLUMBIA
Clerk, U.S. District & Bankruptcy
Courts tor th& Dlstrlct o1 Golumbl,
IN THE MATTER OF THE SEARCH OF
Case: 1:18-sc-02922
INFORMATION ASSOCIATED WITH
Assigned To: Howell, Beryl A.
ONE ACCOUNT STORED AT PREMISES
Assign. Date : 9/27/2018
CONTROLLED BY APPLE
Description: Search & Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Patrick J. Myers, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support. of an application for a search warrant for

information associated with the Apple account "Target Account"), stored at

premises owned, maintained, controlled or operated by Apple, Inc. ("Apple"), a company

headquartered in Cupertino, California. As set forth below, the Target Account is believed to be

used by an associate of STONE who was in communication with STONE on the day that

WikiLeaks first released emails stolen from Clinton Campaign chair John Podesta and who appears

to have met with STONE in October 2016 on the same day that STONE publicly claimed to have

had dinner with his back-channel to WikiLeaks founder Julian Assange. Upon receipt of the

information described in Attachment A, government-authorized persons will review that

info1mation to locate the items described in Attachment B.

2. I am a Special Agent with the Federal Bureau of Investigation ("FBI") assigned to

FBI Pittsburgh working directly with the Special Counsel's Office. I have been a Special Agent

with the FBI since 2017. I was previously employed as a network and software engineer for

approximately fifteen years, including for the FBI. As a Special Agent, I have conducted national

security investigations relating to foreign intelligence and cybersecurity.

-1-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 13 of 57

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other FBI personnel and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested warrant and

does not set forth all of my knowledge about this matter.

4. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that the Target Account contains evidence, fruits, or

instrumentalities of violations of 18 U.S.C. § 371 (conspiracy), 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § I 001 (false statements), 18 U.S.C. § 1030 (unauthorized access of a protected

computer), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and conspiracy to commit

wire fraud), 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C. § 1513 (witness

tampering), and 52 U.S.C. § 30121(a)(l)(C) (foreign expenditure ban). There also is probable

cause to search the information described in Attachment A for evidence, contraband, fruits,

and/or instrumentalities of the Subject Offenses, further described in Attachment B.

,JURISDICTION

5. This Court has jurisdiction to issue the requesteq warrant because it is "a court of

competent jurisdiction" as defined by 18 U.S.C. § 2711. Id. §§ 2703(a), (b)(l)(A), &

(c)( 1)(A). Specifically, the Court is "a district court of the United States (including a magistrate

judge of such a court) ... that has jurisdiction over the offense being investigated." 18 U.S.C.

§ 2711(3)(A)(i). The offense conduct included activities in Washington, D.C., as detailed below.

-2-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 14 of 57
II
i!
!
PROBABLE CAUSE
I
A. Background on Relevant Individuals !
.1
i. Roger STONE
II
6. Roger STONE is a self-employed political strategist/consultant and has been

actively involved in U.S. politics for decades. STONE worked on the presidential campaign of

Donald J. Trump (the "Campaign") until August 2015. Although Stone had no official

relationship with the Campaign thereafter, STONE maintained his support for Trump and

continued to make media appearances in support of the Campaign. As described further below,

STONE also maintained contact with individuals employed by the Campaign, including then-

campaign chairman Paul MANAFORT and deputy chairman Rick GATES.

ii. Jerome CORSI

7. Jerome CORSI is a political commentator who, according to publicly available

information, served as the "Washington Bureau Chief for lnforwars.com." According to

publicly-available sources, from 2014 until January 2017, CORSI was a "senior staff reporter"

for the website "World Net Daily" a/k/a "WNO.com." CORSI has also written a number of

books regarding Democratic presidential candidates. As described further below, CORSI was in

contact with STONE during the summer and fall of2016 regarding forthcoming disclosures of

hacked information by WikiLeaks, and appears to have obtained information regarding

upcoming disclosures which he relayed to STONE.

-3-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 15 of 57

B. Russian Government-Backed Hacking Activity During the 2016 Presidential


Election

9. On January 6, 2017, the USIC released a declassified version of an intelligence

assessment of Russian activities and intentions during the 2016 presidential election entitled,

"Assessing Russian Activities and Intentions in Recent US Elections." In the report, the USIC

assessed the following:

[] Russian President Vladimir Putin ordered an influence campaign in 2016 aimed at the
US presidential election. Russia's goals were to undermine public faith in the US
democratic process, denigrate [former] Secretary [of State Hillary] Clinton, and harm her
electability and potential presidency. We further assess Putin and the Russian
Govermnent developed a clear preference for President-elect Trump.

10. In its assessment, the USIC also described, at a high level, some of the techniques

that the Russian government employed during its interference. The USIC summarized the efforts

as a "Russian messaging strategy that blends covert intelligence operations-such as cyber

activity-with overt efforts by Russian Government agencies, state-funded media, third-party

intermediaries, and paid social media users or 'trolls."'

11. With respect to "cyber activity," the USIC assessed that "Russia's intelligence

-4-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 16 of 57 I
I
I
I'
,,

services conducted cyber operations against targets associated with the 2016 US presidential I
I
election, including targets associated with both major US political parties." Fmiher, "[i]n July I
:1
I
2015, Russian intelligence gained access to Democratic National Committee (DNC) networks

and maintained that access until at least June 2016." The USIC attributed these cyber activities
I
r
'
to the Russian GRU, also known as the Main Intelligence Directorate: "GRU operations resulted

in the compromise of the personal e-mail accounts of Democratic Party officials and political

figures. By May, the GRU had exfiltrated large volumes of data from the DNC."

I 2. With respect to the release of stolen materials, the USIC assessed "with high

confidence that the GRU used the Guccifer 2.0 persona, DCLeaks.com, and WikiLeaks to

release US victim data obtained in cyber operations publicly and in exclusives to media outlets."

13. Guccifer 2.0, who claimed to be an independent Romanian hacker, made multiple

contradictory statements and false claims about his identity throughout the election.

14. The Special Counsel's Office has determined that individuals associated with the

GRU continued to engage in hacking activity related to the 2016 presidential election through at

least November 1, 2016.

15. For example, in or around September 2016, these individuals successfully gained

access to DNC computers housed on a third-party cloud-computing service. In or around late

September, these individuals stole data from these cloud-based computers by creating backups of

the DNC's cloud-based systems using the cloud provider's own technology. The individuals

used three new accounts with the same cloud computing service to move the "snapshots" to

those accounts.

16. On or about September 4, 2016, individuals associated with the GRU stole the

emails from a former White House advisor who was then advising the Clinton Campaign. These

-5-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 17 of 57

emails were later post on DCLeaks.

17. On or about November 1, 2016, individuals associated with the GRU

spearphished over I 00 accounts used by organizations and personnel involved in administering

elections in numerous Florida counties.

18. On July 13, 2018, a grand jury in the District of Columbia returned an indictment

against twelve Russia military officers for criminal offenses related to efforts to influence the 2016

presidential election, including conspiracy to commit authorized access to protected computers.

See United States v. Viktor Borisovich Netyksho, et al. (Case No. l:18-cr-00125).

C. STONE's Public Interactions with Guccifer 2.0 and WikiLeaks

19. On June 14, 2016, CrowdStrike, the forensic firm that sought to remediate an

unauthorized intrusion into the computer systems of the DNC, publicly attributed the hack to

Russian government actors and the media reported on the announcement. On June 15, 2016, the

persona Guccifer 2.0 appeared and publicly claimed responsibility for the DNC hack. It stated

on its WordPress blog that, with respect to the documents stolen from the DNC, "[t]he main part

of the papers, thousands of files and mails, I gave to Wikileaks. They will publish them soon."

In that post, Guccifer 2.0 also began releasing hacked DNC documents.

20. On July 22, 2016, WikiLeaks published approximately 20,000 emails stolen from

theDNC.

21. On August 5, 2016, STONE published an article on Breitbart.com entitled, "Dear

Hillary: DNC Hack Solved, So Now Stop Blaming Russia." The article stated: "It doesn't seem

to be the Russians that hacked the DNC, but instead a hacker who goes by the name of Gucci fer

2.0." The article contained embedded publicly available Tweets from Guccifer 2.0 in the article

and stated: "Here's Guccifer 2.0's website. Have a look and you'll see he explains who he is and

-6-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 18 of 57

why he did the hack of the DNC." The article also stated: "Guccifer 2.0 made a fateful and wise

decision. He went to WikiLeaks with the DNC files and the rest is history. Now the world would

see for themselves how the Democrats had rigged the game."

22. On August 8, 2016, STONE addressed the Southwest Broward Republican

Organization. During his speech, he was asked about a statement by WikiLeaks founder Julian

ASSANGE to Russia Today (RT) several days earlier about an upcoming "October Surprise"

aimed at the Hillary Clinton presidential campaign. Specifically, STONE was asked: "With

regard to the October surprise, what would be your forecast on that given what Julian Assangc

has intimated he's going to do?" STONE responded: "Well, it could be any number of things. I

actually have communicated with Assange. I believe the next tranche of his documents pertain

to the Clinton Foundation but there's no telling what the October surprise may be." A few days

later, STONE clarified that while he was not personally in touch with AS SAN GE, he had a close

friend who served as an intermediary.

23. On August 12, 2016, Guccifer 2.0 publicly tweeted: "@RogerJStoncJr thanks that

u believe in the real #Guccifer2." That same day, Guccifer 2.0 released the personal cellphone

numbers and email addresses from the files of the DCCC.

24. On August 13, 2016, STONE posted a tweet using@RogerJStoneJr calling

Guccifer 2.0 a "HERO" after Guccifer 2.0 had been banned from Twitter. The next day,

Guccifer 2.0's Twitter account was reinstated.

25. On August 17, 2016, Guccifer 2.0 publicly tweeted, "@RogerJStoneJr paying you

back." Guccifer also sent a private message to @RogerJStoneJr stating "i'm pleased to say u r

great man. please tell me if I can help u anyhow. it would be a great pleasure to me."

26. On August 18, 2016, Paul MANAFORT, STONE's longtime friend and associate,

-7-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 19 of 57 I
I
I,
,1

i~
I!
,,
resigned as Chairman of the Trump Campaign. Contemporary press reports at the time indicated
I
that MANAFORT had worked with a Washington D.C.-based lobbying firms to influence U.S.

policy toward Ukraine.


Ii
27. On August 21, 2016, using@RogerJStoneJR, STONE tweeted: "Trust me, it will

soon the [sic] Podesta's time in the batTel. #CrookedHillary." In a C-SPAN interview that same

day, STONE reiterated that because of the work of a "'mutual acquaintance' of both his and

[ASSANGE], the public (could] expect to see much more from the exiled whistleblower in the

form of strategically-dumped Clinton email batches." He added: "Well, first of all, I think Julian

Assange is a hero ... [ think he's taking on the deep state, both Republican and Democrat. I

believe that he is in possession of all of those emails that Huma Abcdin and Cheryl Mills, the

Clinton aides, believe they deleted. That and a lot more. These are like the Watergate tapes."

28. On September 16, 2016, STONE said in a radio interview with Boston Herald

Radio that he expected WikiLcaks to "drop a payload of new documents on Hillary on a weekly

basis fairly soon. And that of course will answer the question as to what exactly what was erased

on that email server."

29. On Saturday, October!, 2016, using@RogerJStoneJr, STONE tweeted,

"Wednesday@ HillaryClinton is done. #WikiLeaks."

30. On Sunday, October 2, 2016, MSNBC Morning Joe producer Jesse Rodriquez

tweeted regarding an announcement ASSANGE had scheduled for the next day from the balcony

of the Ecuadoran Embassy in London. On the day of the ASSANGE announcement - which was

part of WikiLeaks' I 0-year anniversary celebration - STONE told lnfowars that his intermediary

described this release as the "mother load." On October 5, 2016, STONE used @RogerJStoneJr

to tweet: "Payload coming. #Lockthemup."

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 20 of 57

31. On Friday, October 7, 2016, at approximately 4:03 PM, the Washington Post

published an mticle containing a recorded conversation from a 2005 Access Hollywood shoot in

which Mr. Trump had made a series of lewd remarks.

32. Approximately a half hour later, at 4:32 PM, WikiLeaks sent a Tweet reading

"RELEASE: The Podesta Emails #HillaryC!inton #Podesta #im WithHer" and containing a link

to approximately 2,050 emails that had been hacked from John Podesta's personal email account.

33. WikiLeaks continued to release John Podesta's hacked emails through Election

Day, November 8, 2016. On October 12, 2016, Podesta- referring back to STONE's August 21,

2016 C-SPAN and Twitter references - argued publicly that "[it is] a reasonable assumption to -

or at least a reasonable conclusion - that [STONE] had advanced warning [of the release of his

emails] and the Trump campaign had advanced warning about what Assange was going to do. I

think there's at least a reasonable belief that [Assange] may have passed this information on to

[STONE]." Commenting to the NBC News, STONE indicated that he had never met or spoken

with Assange, saying that "we have a mutual friend who's traveled to London several times, and

everything I know is through that channel of communications. I'm not implying I have any

influence with him or that I have advanced knowledge of the specifics of what he is going to do.

I do believe he has all of the e-mails that 1-Juma Abedin and Cheryl Mills, the Clinton aides,

thought were deleted. I hear that through my emissary."

34. On March 27, 2017, CNN reported that a representative ofWikiLeaks, writing

from an email address associated with WikiLeaks, denied that there was any backchannel

communication during the Campaign between STONE and WikiLeaks. The same article quoted

STONE as stating: "Since I never communicated with WikiLeaks, I guess I must be innocent of

charges I knew about the hacking of Podesta's email (speculation and conjecture) and the timing

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 21 of 57 I
I
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1:
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t

or scope of their subsequent disclosures. So I am clairvoyant or just a good guesser because the

limited things I did predict (Oct disclosures) all came true."

D. STONE's Private Twitter Direct Messages with.WikiLeaks and ASSANGE

35. On October 13, 2016, while WikiLcaks was in the midst of releasing the hacked

Podesta emails, the Twitter account @RogerJStoncJr sent a private direct message to the Twitter

account @wikileaks. 1 The latter account is the official Twitter account of WikiLeaks and has

been described as such by numerous news reports. The message read: "Since I was all over

national TV, cable and print defending WikiLeaks and assange against the claim that you are

Russian agents and debunking the false charges of sexual assault as trumped up bs you may want

to rexamine the strategy of attacking me- cordially R."

36. Less than an hour later, @wikileaks responded by direct message: "We appreciate

that. However, the false claims of association are being used by the democrats to undermine the

impact of our publications. Don't go there if you don't want us to correct you."

37. On or about October 15, 2016, @RogerJStoneJr sent a direct message to

@wikileaks: "Ha! The more you \"correct\" me the more people think you're lying. Your

operation leaks like a sieve. You need to figure out who your friends are."

38. On or about November 9, 2016, one day after the presidential election,

@wikileaks sent a direct message to @RogerJStoneJr containing a single word: "Happy?"

@wikileaks immediately followed up with another message less than a minute later: "We are

now more free to communicate."

39. In addition, @RogerJStoneJr also exchanged direct messages with ASSANGE,

1
On or about August 7, 2017, Chief Judge Beryl A. Howell issued a search warrant for the
Twitter account @RogerJStoneJr.
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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 22 of 57

the founder of WikiLcaks. For example, on June 4, 2017, @RogerJStoneJr directly messaged

@JulianAssange, an address associated with ASSANGE in numerous public reports, stating:

"Still nonsense. As a journalist it doesn't matter where you get information only that it is

accurate and authentic. The New York Times printed the Pentagon Papers which were

indisputably stolen from the government and the courts ruled it was legal to do so and refused to

issue an order restraining the paper from publishing additional articles. If the US government

moves on you I will bring down the entire house of cards. With the trumped-up sexual assault

charges dropped I don't know of any crime you need to be pardoned for - best regards .. R." That

same day, @JulianAssange responded: "Between CIA and DoJ they're doing quite a lot. On the

DoJ side that's coming most strongly from those obsessed with taking down Trump trying to

squeeze us into a deal."

40. On Saturday, June 10, 2017, @RogcrJStoneJr sent a direct message to

@J ulianAssange, reading: "I am doing everything possible to address the issues at the highest

level of Government. Fed treatment of you and WikiLeaks is an outrage. Must be circumspect in

this forum as experience demonstrates it is monitored. Best regards R."

E. CORSl's Communications with STONE, and Others Regarding


Forthcoming Leaks

41. On September 11, 2017, ChiefJudge Beryl A. Howell of the District of Columbia

issued a search warrant for STONE's address, On October 17,

. 2017, Chief Judge Howell issued a search warrant for one ofSTONE' addresses,

On or about December 19, 2017, Chief Judge Howell issued a search

warrant fo email account. On or about March 14, 2018, Chief Judge Howell

issued a search warrant for STONE's iCloud account. Information recovered pursuant to those

.search warrants indicated the following:

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 23 of 57

42. On or about May 15, 2016, emailed CORSI: "Here is my flight

schedule. Need to get something confirmed now .... " CORSI responded, "I copied Roger

Stone so he knows your ayailability to meet Manafort and DT this coming week." CORSI

appears to have forwarded the message to STONE at ho replied to

CORSI that, "May meet Manafort -guarantee nothing."

43. On or about May 18, 2016, CORSI emailed STONE at

with the title, "Roger -- why don't you look this over before I send it to I believe that

CORSI wrote,

and I did manage to see Mr. Trump for a few minutes today as we were

waiting in Trump Tower to say hello to Mike Cohen. Mr. Trump recognized us immediately and

was very cordial. He would look for this memo from you this afternoon."

44. On July 25, 2016, STONE, using ent an email to

CORSI with the subject line, "Get to Assange." The body of the message read: "Get.to Assange

[a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly." The text of this email from STONE to CORSI substantially mirrored the

text of ah email that STONE received from ~a freelance blogger who had been

conducting research into the Clintons during presidential campaign---on or about the same day.

45. On or aboutJuly 31, 2016, STONE, using emailed

CORSI with the subject line, "Call me MON." The body of the email read: " should see

Assangc[.J should find Bernie [S]anders brother who called Bill a Rapist - tum him for

Trump[.] should find or more proof of Bill getting kicked out."

46. On or ahout August 2, 2016 (approximately 19 days before STONE publicly

tweeted about "Podesta's time in the banel"), CORSI emailed STONE at

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 24 of 57

11
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i
"Word is friend in embassy plans 2 more dumps. One shortly after I'm j
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back. 2nd in Oct. Impact planned to be very damaging." The email continued, "Signs are Fox
I
,,
will have me on mid-Aug. more post Ailes shakeup underway. Expect Shine to surface victor, I
I•

for now. Post-DNC bump for HRC an artifact of rigged polling. Won't last. I expect presidential I
i
~
campaign to get serious starting Sept. Still in pre-season games. Time to let more than Podesta to

be exposed as in bed w enemy if they are not ready to drop HRC. That appears to be the game
i
hackers are now about. Would not hurt to start suggesting HRC old, memory bad, has stroke -- IIi

neither he nor she well. I expect that much of next dump focus, setting stage for Foundation .

debacle." Investigators believe that CORSI's reference to a "friend in embassy [who] plans 2
I
more dumps" refers to ASSANGE, who resided in Ecuador's London Embassy in 2016.
I
47. On or about August 5, 2016, an associate of STONE's, emailed
Ir

STONE at The email contained a link to a poll indicating that Clinton

led Trump by 15 points. STONE responded "enjoy it while u can[.] I dined with my new pal

Julian Assange last night." subsequently stated to investigators that, around the

same time, STONE told him he had gone to London to meet ASSANGE. also stated

that in 2018, told STONE he would be interviewed by the FBI and would have to

divulge the conversation about meeting ASSANGE. STONE told he was joking and

had not actually met AS SAN GE. 2

48. Tlu·ough a search of STONE's iCloud account, the FBI has uncovered evidence

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 25 of 57

j
ll.

I
[

suggesting that STONE was in Los Angeles for one or more meetings at the time that he claimed,
i

in his email t , to have "dined" with ASSANGE. For example, an associate of II


I'

STONE sent a text to STONE at approximately 3 :38PM on August 2, asking "How did ur meeting !
go in LA?" STONE responded. "It's this afternoon[.]" The following day, the associate asked,

"Any report from ur meeting?" On or about August 4, 2016, STONE texted the associate, "Will

call later- heading for airport now[.]" Additionally, investigators have identified a photograph in

STONE's iCloud that appears to have been taken on August 3, 2016 and had geo-location

information indicating that it was taken in Los Angeles.

49. On or about August 15, 2016, CORSI emailed STONE at

: "Give me a call today if you can. Despite MSM drumroll that HRC is

already elected, it's not over yet. More to come than anyone realizes. Won't really get started

until after Labor Day. I'm in NYC this week. Jerry."

50. On or about August 31, 2016, CORSI emailed STONE at

Did you get the PODESTA writeup." STONE replied "[y]es."

51. On or about August 31, 2016, CORSI messaged STONE, "Podesta paid $ l 80k to

invest in Uranium One - was hired by Rosatom in Giustra scandal. Podesta now under FBI

investigation - tied to Ukraine Y anukovych - Panama papers reveals Podesta hired by

S[b ]erbank, Russia's largest financial institution - Podesta$$$ ties to Russia undermine Clinton

false narrative attempting to tie Trump to Putin."

52. On or about September 6, 2016, CORSI emailed STONE at

Roger[,] Is NY Post going to use the Pedesta [sic] stuff?"

53. On or about September 24, 2016, emailed CORSI, "I will have much

more on Turkey. Need a back channel highly sensitive stuff." CORSI responded, "We have

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 26 of 57

secure back channel through Roger. I saw him again in NYC last Friday and spoke to him about

it again today." wrote back, "Awaiting secret file. Explosive ... Hope you are well.

Can't wait for the debate. Channeling Reagan, I hope!" CORSI responded, "Keep me posted

about file[.]" In a subsequent meeting with investigators indicated this

conversation concerned possible derogatory information he was trying to obtain from Turkey.

54. On or about October 3, 2016, an associate of STONE emailed STONE at

and asked: "Assange - what's he got? Hope it's good." STONE wrote

back, "It is. I'd tell Bannon but he doesn't call me back. My book on the TRUMP campaign will

be out in Jan. Many scores will be settled." The associate forwarded the email to Steve

BANNON, who was CEO of the Campaign at the time, and wrote: "Yon should call Roger. See

below. Yon didn't get from me." BANNON wrote back, "I've got important stuff to worry

about." The associate responded, "Well clearly he knows what Assange has. I'd say that's

important."

55. On or about October 4, 2016, ASSANGE gave a press conference at the

Ecuadorian Embassy. There had been speculation in the press leading up to that event that

ASSANGE would release infonnation damaging to then-candidate Clinton, but WikiLeaks did

not make any new releases. Instead, ASSANGE promised more documents, including

information "affecting three powerful organizations in three different states, as well as, of course,

information previously referred to about the U.S. election process." ASSANGE also stated that

WikiLeaks would publish documents on various subjects every week for the next ten weeks, and

vowed that the U.S. election-related documents would all come out before Election Day.

56. On or about October 4, 2016, CORSI messaged STONE at his iCloud account:

"Assange made a fool of himself. Has nothing or he would have released it. Total BS hype."

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57. That same day, BANNON emailed STONE "What was

that this morning???" STONE replied, "Fear. Serious security concern. He thinks they are going

to kill him and the London police are standing done [sic]." BANNON wrote back, "He didn't

cut deal w/ clintons???" STONE replied, "Don't think so BUT his lawyer is a big

democrat."

58. When BANNON spoke with investigators during a voluntary interview on

February 14, 2018, he initially denied knowing whether the October 4, 2016 email to STONE

was about WikiLeaks. Upon further questioning, BANNON acknowledged that he was asking

STONE about WikiLeaks, because he had heard that STONE had a channel to AS SAN GE, and

BANNON had been hoping for releases of damaging information that morning.

F. STONE and CORSI Communications on October 7, 2016, when the Podesta Emails
Are Released.

59. According to a publicly available news article, 3 at approximately 11AM on

Friday, October 7, 2016, Washington Post reporter David Fahrenthold received a phone call from

a source regarding a previously unaired video of candidate Trump. According to the same

article, "Fahrenthold didn't hesitate. Within a few moments of watching an outtake of footage

from a 2005 segment on 'Access Hollywood,' the Washington Post reporter was on the phone,

calling Trump's campaign, 'Access Hollywood,' and NBC for reaction."

60. According to phone record , at approximately

11 :27 AM, CORSI placed a call to STONE, which STONE did not answer.

61. At approximately 11 :53AM, STONE received a phone call from the Washington

Post. The call lasted approximately twenty minutes.

3
https://www.washingtonpost.com/lifestyle/style/the-caller-had-a-lewd-tape-of-donald-trump-
then-the-race-was-on/2016/10/07 /3 l d7 4 7 l 4-8ce5- l l e6-875e-2cl bfe943 b66_story.html

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62. At approximately 1:42PM, STONE called CORSI and the two spoke for

approximately seventeen minutes.

63. At approximately 2: 18PM, CORSI called STONE and the two spoke for

approximately twenty minutes.

64. At approximately 4:00PM, the Washington Post published a story regarding the

Access Hollywood tape.

65. At approximately 4:30PM, WikiLeaks tweeted out its first release of emails

hacked from John Podesta that focused primarily on materials related to the Clinton Foundation.

On or about August 2, 2016, CORSI emailed STONE using "I expect

that much of next dump focus, setting stage for Foundation debacle."

66. At approximately 6:27PM, -the person who originally suggested

"get[ting] to Assange," and who, according to emails and phone records, regularly

communicated with STONE-sent STONE an email titled, "WikiLeaks - The Podesta Emails,"

with a link to the newly-released Podesta emails. Approximately ten minutes later, STONE,

using forwarded message to CORSI without comment.

STONE does not appear to have forwarded the email to any other individual.

G. STONE Asks CORSI for "SOMETHING" to Post About Podesta After STONE ls
Accused of Advance Knowledge of the Leak

67. On or about October 8, 2016, STONE messaged CORSI, "Lunch postponed-

have to go see T." CORSI responded to STONE, "Ok. I understand." Approximately twenty

minutes later, CORSI texted, "Clintons know they will lose a week of Paula Jones media with T

attacking Foundation, using Wikileaks Goldman Sachs speech comments, attacking bad job

numbers."

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 29 of 57

68. On or about Wednesday, October 12, 2016, at approximately 8:17AM, STONE,

usin m, emailed Corsi asking him to "send me your best podesta links."

STONE emailed CORSI at approximately 8:44AM EDT, "need your BEST podesta pieces."

CORSI wrote back at approximately 8:54AM EDT, "Ok. Monday. The remaining stuff on

Podesta is complicated. Two articles in length. I can give you in raw form the stuff I got in

Russian translated but to write it up so it's easy to understand will take weekend. Your choice?"

69. On or about that same day, October 12, 2016, Podesta accused STONE of having

advance knowledge of the publication of his emails. At approximately 3:25PM EDT, CORSI

emailed STONE at bot , with the subject

line "Podesta talking points." Attached to the email was a file labeled, "ROGER STONE

podesta talking points Oct 12 2016.docx." The "talking points" included the statement that

"Podesta is at the heart of a Russian-government money laundering operation that benefits

financially Podesta personally and the Clintons through the Clinton Foundation."

70. CORSI followed up several minutes later with another email titled, "Podesta

talking points," with the text "sent a second time just to be sure you got it." STONE emailed

CORSI back via the Hotmail Account, "Got them and used them."

71. On or about Thursday, October 13, 2016, CORSI emailed STONE at

: "PO DEST A -- Joule & ties to RUSSIA MONEY LAUNDERING to

CLINTON FOUNDATION." STONE responded, "Nice but I was hoping for a piece I could

post under my by-line since I am the one under attack by Podesta and now Mook." CORSI

wrote back to STONE, "I'll give you one more- NOBODY YET HAS THIS[:] It looks to me

like skimmed maybe billions off Skolkovo - Skolkovo kept their money with

Metcombank[.] The Russians launched a criminal investigation[.] (web link] Once

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 30 of 57

had the channel open from Metcombank to Deutsche Bank America to Ban[k) of America's

Clinton Fund account, there's no telling how much money he laundered, or where it ended up.

Nothing in Clinton Foundation audited financials or IRS Form 990s about$$$ received via

Russia & Metcombank[.] I'm working on that angle now." STONE replied, "Ok Give me

SOMETHING to post on Podesta since I have now promised it to a dozen MSM reporters[.]"

72. On or about Thursday, October 13, 2016 at approximately 6:30PM EDT, CORSI

sent STONE an email a with the subject, "ROGER STONE article

RUSSIAN MAFIA STYLE MONEY-LAUNDERING, the CLINTON FOUNDATION, and

JOHN PODESTA." The text stated: "Roger[,] You are free to publish this under your own

name." That same day, STONE posted a blog post with the title, "Russian Mafia money

laundering, the Clinton Foundation and John Podesta." In that post, STONE wrote, "although I

have had some back-channel communications with Wikileaks I had no advance notice about the

hacking of Mr. Podesta nor I have I ever received documents or data from Wikileaks." The post

then asked, "Just how much money did , a controversial Russian billionaire

investor with ties to the Vladimir Putin and the Russian goverrnnent, launder through

Metcombank, a Russian regional bank owned 99.978 percent b with the money

transferred via Deutsche Bank and Trust Company Americas in New York City, with the money

ending up in a private bank account in the Bank of America that is operated by the Clinton

Foundation?"

73. On or about October 14, 2016, CORSI sent a message to STONE at his iCloud

account, "I'm in NYC. Thinking about writing piece attacking Leer and other women. It's

basically a rewrite of what's out there. Going through new Wikileaks drop on Podesta."

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 31 of 57

74. On or about October 17, 2016, CORSI messaged STONE at his iCloud account,

"On Assange, can you call me now - before 2pm[.]" STONE responded, "Missed u - just

landed JFK- on Infowars now." CORSI wrote back, "Call afterwards. Have some important

intel to share."

75. On or about October 17, 2016, CORSI emailed STONE at

with the subject, "Fwd:

ASSANGE ... URGENT ... " CORSI wrote, "From a very trusted source," and forwarded an email

with the header information stripped out, showing only the body text. The email read, "Yes[.] I

figured this. Assange is threatening Kerry, Ecuador and U.K. He will drop the goods on them if

they move to extradite him. My guess is that he has a set of dead man files that include Hillary.

It's what they used to call a 'Mexican stand offl.]' Only hope is that if Trump speaks out to save

him[.] Otherwise he's dead anyway, once he's dropped what he has. IfHRC wins, Assange can

kiss his life away. Interesting gambit Assange has to play out. He's called Podesta's bluff and

raised him the election." Based on review of the original email that CORSI forwarded, the

"trusted source" was a self-identified retired librarian who gathers information from public chat

rooms.

76. On or about October 18, 2016, CORSI messaged STONE at his iCloud account,

"Pis call. Important."

77. On or about October 19, 2016, STONE published an article on Breitbart.com in

which he claimed he had, "no advance notice ofWikileaks' hacking of Podesta's e-mails."

STONE stated that, "I predicted that Podesta's business dealings would be exposed. I didn't hear

it from Wikileaks, although Julian Assange and I share a common friend. I reported the story on

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 32 of 57

my website." STONE linked to the story he had asked CORSI to write for him on October 13,

2016 discussed above.

78. On or about November 8, 2016, the United States presidential election took place.

79. On or about November 9, 2016, CORSI messaged STONE at his iCloud account,

"Congratulations, Roger. He could not have done it without you."

80. On or about November 10, 2016, CORSI messaged STONE at his iCloud

account, "Are you available to talk on phone?" Several minutes later, CORSI messaged, "I'm in

London. Have some interesting news for you."

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I. STONE's Congressional Testimony and Public Statements About His Relationship


with Wikileaks

88. On September 26, 2017, STONE testified before the House Permanent Select

Committee on Intelligence (HPSCJ). Although the hearing was closed, STONE released to the

public what he said were his opening remarks to the committee. In them, STONE stated:

Members of this Committee have made three basic assertions against me which must be
rebutted here today. The charge that I knew in advance about, and predicted, the hacking
of Clinton campaign chairman John Podesta' s email, that I had advanced knowledge of
the source or actual content of the WikiLeaks disclosures regarding Hillary Clinton or
that, my now public exchange with a persona that oµr intelligence agencies claim, but
cannot prove, is a Russian asset, is anything but innocuous and are entirely false. Again,
such assertions are conjecture, supposition, projection, and allegations but none of them
are facts ....

My Tweet of August 21, 2016, in which I said, "Trust me, it will soon be the Podesta's
time in the barrel. #CrookedHillary" must be examined in context. I posted this at a time
that my boyhood friend and colleague, Paul Manafort, had just resigned from the Trump
campaign over allegations regarding his business activities in Ukraine. I thought it
manifestly unfair that John Podesta not be held to the same standard. Note, that my
Tweet of August 21, 2016, makes no mention, whatsoever, of Mr. Podesta's email, but
does accurately predict that the Podesta brothers' business activities in Russia with the
oligarchs around Putin, their uranitun deal, their bank deal, and their Gazprom deal,
would come under public scrutiny ....

[L]et me address the charge that I had advance knowledge of the timing, content and
source of the WikiLeaks disclosures from the DNC. On June 12, 2016, WikiLeaks'
publisher Julian Assange[] announced that he was in possession of Clinton DNC emails.
I learned this by reading it on Twitter. I asked a journalist who I knew had interviewed

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 35 of 57

Assange to independently confirm this report, and he subsequently did. This journalist
assured me that WikiLeaks would release this information in October and continued to
assure me of this throughout the balance of August and all of September. This
information proved to be correct. I have referred publicly to this journalist as an,
"intermediary", "go-between" and "mutual friend." All of these monikers are equally
true.

89. In a document dated March 26, 2018 titled "MinorityViews," Democratic

members of HPSCI published excerpts from Stone's September 2017 testimony before HPSCI.

Those excerpts include the following:

Q: Have any of your employees, associates, or individuals acting on your behest or


encouragement been in any type of contact with Julian Assange?
MR. STONE: No.

Q: So throughout the many months in which you represented you were either in
communication with Assange or communication through an intermediary with Assange,
you were only referring to a single fact that you had confirmed with the intermediary -
MR. STONE: That -
Q: -- was the length and the breadth of what you were referring to?
MR. STONE: That is correct, even though it was repeated to me on numerous separate
occasions.

90. In the month that followed his testimony before HPSCI, on or about October 24,

2017, STONE published an article on his website, stonecoldtruth.com, titled "Is it the Podesta's

Time in the Barrel Yet?" In that article, STONE stated: "[I]t was this inevitable scrutiny of the

Podestas' underhanded business dealings that my 'time in the barrel' referred to and not, as some

have quite falsely claimed, to the hacking and publication almost two months later of John

Podesta's emails .... [M]y tweet referred to Podesta's business dealings with Russia, and the

expectation that it would become a news story."

J, STONE's Messaging to Randy CREDICO about STONE's "Back channel"

91. On or about November 19, 2017, Randy CREDICO (who, as described further

below, STONE publicly identified as his "intermediary" to ASSANGE), messaged STONE, "My

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 36 of 57
II
!
t
lawyer wants to see me today." STONE responded, '"Stonewall it. Plead the fifth. Anything to
'
save the plan' ........ Richard Nixon[.]" CREDI CO responded, "Ha ha."

92. On or about November 21, 2017, CREDI CO messaged STONE, "I was told that

the house committee lawyer told my lawyer that I will be getting a subpoena[.]" STONE wrote

back, 'That was the point at which your lawyers should have told them you would assert your

5th Amendment rights if compelled to appear." They continued to message, and CREDICO

wrote, "My lawyer wants me to cut a deal." STONE wrote back, "To do what? Nothing

happening in DC the day before Thanksgiving - why are u busting my chops?"

93. On or about November 24, 2017, STONE, texted CREDICO, "Assange is a

journalist and a damn good one- meeting with him is perfectly legal and all you ever told me was

he had the goods [oJn Hillary and would publish them - which he himself said in public b4 u told

me. It's a fucking witchunt [sic]." CREDICO replied, "I told you to watch his tweets. That's

what I was basing it on. I told you to watch his Tweets in October not before that I knew nothing

about the DNC stuff[.] I just followed his tweets[.]" STONE responded, "U never said anything

about the DNC but it was August." CREDI CO wrote back, "It was not August because I didn't

interview him or meet him until August 26th[.] That was my first communication with his

secretary in London, August 26th." STONE wrote back, "Not the way I remember it - oh well I

guess Schiff will try to get one ofus indicted for perjury[.]"

94. STONE and CREDI CO continued to exchange messages and on November 24,

2017, CREDI CO wrote to STONE, "Forensic evidence proves that there is no back Channel. So

now you can relax."

95. On or about November 28, 2017, CREDI CO tweeted a copy of a subpoena he

received from HPSCI that was dated November 27, 2017. Toll records show that on November

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 37 of 57

27 and 28, 2017, CREDI CO and STONE communicated via text message more than a dozen

times.

96. On November 29, 2017, STONE publicly stated that CREDICO was his

"intermediary." In a public Facebook post, STONE further stated that "Credico merely[)

confirmed for Mr. Stone the accuracy of Julian Assange's interview of June 12, 2016 with the

British ITV network, where Assange said he had 'e-mails related to Hillary Clinton which are

pending publication,' ... Credico never said he knew or had any information as to source or

content of the material."

97. On or about December I, 2017, CREDICO messaged STONE, "I don't know why

you had to lie and say you had a back Channel now I had to give all ofmy forensic evidence to

the FBI today what a headache[.]' You could have just told him the truth that you didn't have a

back Channel they now know that I was not in London until September of this year[.] You had

no back-channel and you could have just told the truth ... You want me to cover you for perjury

now[.]" STONE responded, "What the fuck is your problem? Neither ofus has done anything

wrong or illegal. You got the best press of your life and you can get away with asserting for 5th

Amendment rights ifu don't want talk about AND if you tumed over anything to the FBI you're

a fool." CREDICO responded, "You open yourself up to six counts of perjury[.] But I'm sure

that wasn't swom testimony so you 're probably clear[.] Council for the committee knows you

never had a back Channel and if you had just told the truth wouldn't have put me in this bad spot

... you should go back ... and amend your testimony and tell them the truth." CREDICO

repeated: "you need to amend your testimony before I testify on the 15th." STONE replied, "If

4
Contrary to his statement, CREDI CO had not at the time provided any forensic evidence to the
FBI.

-26-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 38 of 57

!
l•I

you testify you're a fool. Because of tromp [sic] I could never get away with a certain [sic] my
I
Fifth Amendment rights but you can. I guarantee you you [sicJ are the one who gets indicted for
fl

perjury if you're stupid enough to testify[.]" '

98. STONE and CREDICO continued to message each other on or about December 1,

2017. In response to STONE's message about being "stupid enough to testify," CREDICO told

STONE: "Whatever you want to say I have solid forensic evidence." STONE responded: "Get

yourself a real lawyer instead of some liberal wimp who doesn't know how to tell his guys to

fuck off good night." CREDICO then wrote: "Just tell them the truth and swallow your ego you

never had a back Channel particularly on June 12th[.]" STONE responded: "You got nothing."

99. On or about December 13, 2017, according to public reporting, CREDICO

indicated that he would not testify before HPSCI and would invoke his Fifth Amendment rights.

100. STONE and CREDICO continued to exchange text messages, and on or about

January 6, 2018, CREDICO indicated to STONE that he was having dinner with a reporter.

STONE responded, "Hope u don't fuck Up my efforts to get Assange a pardon[.]" CREDICO

messaged STONE, "I have the email from his chief of staff August 25th 2016 responding to an

email I sent to WikiLeaks website email address asking you would do my show[.] That was my

initial contact."

101. On or about January 8, 2018, CREDICO messaged STONE, stating: "Embassy

logs ... + 17 other pieces of information prove that I did not have any conversations with

Assange until September oflast year."

102. CREDI CO and STONE continued to message each other, and on or about January

25, 2018, CREDICO wrote to STONE: "You lied to the house Intel committee ... But you'll get

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 39 of 57 I
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lf:
II

off because you're friends with Trump so don't worry. I have all the forensic evidence[.] I was '~
I
!I
not a ba[ ck] Channel and I have all those emails from September of 2016 to prove it[.]"
I
11

103. On or about April 13, 2018, news reports stated that CREDICO had shown 11

reporters copies of email messages he had received from STONE in the prior few days that

stated, "You are a rat. You are a stoolie. You backstab your friends - run your mouth my
I
Ii,1
lawyers are dying Rip you to shreds." Another message stated, "I'm going to take that dog away

from you," referring to CREDICO's therapy dog. CREDICO stated that it was "certainly scary .

. . When you start bringing up my dog, you're crossing the line[.]" 5

104. On or about May 25, 2018, CREDICO provided additional messages he stated

were from STONE to another news agency. 6 In these messages, STONE, on April 9, 2018,

stated: "I am so ready. Let's get it on. Prepare to die[.]" In the article, CREDICO stated that he

considered this email from STONE a threat. STONE stated in the article that CREDICO "told

me he had terminal prostate cancer ... It was sent in response to that. We talked about it too.

He was depressed about it. Or was he lying." The article noted that CREDI CO stated he did not

have prostate cancer and did not have any such discussion with STONE.

K. STONE's Communications with

105. As noted above, in late July 2016 emailed STONE to "get to Assange,"

which appears to have precipitated STONE's email to CORSI with the same instruction.

106. On or about August 17, 2016 sent an email to STONE's Gmail account

with the subject line, "Introduction." The email was also sent to the work account o

5
https://www.yahoo.com/news/comedian-randy-credico-says-trump-adviser-roger-stone-
threatened-dog-1359113 70.htrnl
6
https: //www. motherj ones.com/politics/2018/0 5/roger-stone-to-associate-prepare-to-die/
-28-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 40 of 57

listed both STONE' telephone numbers, and he advised them, "You should find

time to chat."

107. Toll records for STONE's cellphone show that between August 18, 2016 and

November 3, 2016 was in contact with STONE approximately 60 times. This

included several calls on October 7, 2016, the day that WikiLeaks began releasing Podesta's

emails. On that day called STONE at approximately 12:33PM, within an hour of

STONE's call with the Washington Post, which was about to publish information about the

"Access Hollywood" tape. The call lasted approximately seven minutes. appears to

be the first person, other than journalists, to talk to STONE after STONE's call with the

Washington Pos called STONE a second time at approximately 2:38PM on the same

day. That call lasted approximately one minute. STONE also had a missed FaccTime call from

at approximately 3:32PM the same day. WikiLeaks released the first tranche of stolen

Podesta emails approximately one hour later.

108. As noted above told investigators that in January 2017, CORSI told

him that he (CORSI) and STONE were involved in and were aware of the timing and content of

the WikiLeaks releases in advance, including the fact that the emails belonged to John Podesta,

and CORSI implied, in sum and substance, that STONE was involved in the release of the

Podesta emails by WikiLeaks.

109. According to open source information, on or about October 12, 2016, five days

after the first release of stolen Podesta emails, STONE told a local news outlet in Florida, "I do

have a back-channel communication with Assange, because we have a good mutual friend. That

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 41 of 57

i
!
I!
friend travels back and forth from the United States to London and we talk. I had dinner with II
ri
him last Monday." 7 "Ibe Monday prior to the date ofSTONE's statement was October 10, 2016. !
!I
!,
110. In the early hours of October 10, 2016, at approximately 3:26AM EDT

texted STONE: "H . If you are still in NY we MUST meet tomorrow. Major major
I
stuff." At approximately 8:26AM the same day (but, effectively, the next morning, given the I
I
hour o R's text), STONE replied, "Ok- can we meet UES?" UES appears to be a
iI
reference to the Upper East Side of New York City, where STONE maintained a residence.

texted STONE at approximately 9:02AM, "Sure. Lunch? Coffee? Time?" and again at I
10:55AM, "What time works." Investigators have not located a response from STONE, although

called STONE at approximately 4:45PM°'with a call duration of approximately 4

seconds.

111. Cell-site location data for STONE shows that he was in the Upper East Side on

the evening of October 10, 2016, when he claimed to have met with his contact to Assange,

Financial records for STONE show a

transaction on October 10, 2016, at a pizza parlor located in the Upper East Side, in the amount

of approximately $20.

112. Search warrant returns show that after WikiLeaks began to release Podesta's

emails in October 2016, emailed STONE several times from the account

("Target Account") with links to WikiLeaks' website and discussion about the

us Podesta emails that WikiLeaks had released. For example, on or about

October 25, 2016, sent an email from the Target Acconnt to STONE' account

7
https ://miami .cbslocal.com/2016/1 0/12/trump-all y-roger-stone-admits-back-channel-tie-to-
wikileaks/

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 42 of 57

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i
j

[
with a link to the portion ofWikiLeaks' website containing Podesta emails, with the comment, I
I

"Cheryl Mills & John Podesta panic to cover Obama's lies on Hillary emails." !
I'
113. Search warrant returns for CORSI k account show th was in j
communication with CORSI at least in 2017. During an email exchange in June 2017 that
I
I
appears to relate to financial policy-makers, CORSI tol that he was "concerned about

Mueller," following up shortly thereafter to clarify that had "meant Mnuchen," the Secretary of

Treasury. CORSI added, "Guess I have Special Counsel on mind these days."

114. For the foregoing reasons, there is probable cause to believe that the Target

Account contains evidence, contraband, fruits, and/or instrumentalities of the Subject Offenses.

BACKGROUND CONCERNING APPLE

115. In my training and experience, I have learned that Apple provides a variety of on-

line services, including electronic mail ("email") access, to the public. Apple allows subscribers

to obtain email accounts at the domain name me.com, like the Target Account. Subscribers obtain

an account by registering with Apple. During the registration process, Apple asks subscribers to

provide basic personal information. Therefore, the computers of Apple are likely to contain stored

electronic communications (including retrieved and unretrieved email for Apple subscribers and

information concerning subscribers and their use of Apple services, such as account access

information, email transaction information, and account application information. In my training

and experience, such information may constitute evidence of the crimes under investigation

because the information can be used to identify the account's user or users.

116. In my training and experience, email providers generally ask their subscribers to

provide certain personal identifying· information when registering for an email account. Such

information can include the subscriber's full name, physical address, telephone numbers and other

-31-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 43 of 57

identifiers, alternative email addresses, and, for paying subscribers, means and source of payment

(including any credit or bank account number). In my training and experience, such information

may constitute evidence of the crimes under investigation because the information can be used to

identify the account's user or users. Based on my training and my experience, I know that, even if

subscribers insert false information to conceal their identity, this information often provides clues

to their identity, location, or illicit activities.

117. In my training and experience, email providers typically retain certain transactional

information about the creation and use of each account on their systems. This information can

include the date on which the account was created, the length of service, records of log-in

(i.e., session) times and durations, the types of service utilized, the status of the account (including

whether the account is inactive or closed), the methods used to connect to the account (such as

logging into the account via the provider's website), and other log files that reflect usage of the

account. In addition, email providers often have records of the Internet Protocol address

("IP address") used to register the account and the IP addresses associated with particular logins

to the account. Because every device that connects to the Internet must use an IP address,

IP address information can help to identify which computers or other devices were.used to access

the email account.

118. In my training and experience, in some cases, email account users will

.
communicate directly with an email service provider about issues relating to the account, such as

technical problems, billing inquiries, or complaints from other users. Email providers typically

retain records about such communications, including records of contacts between the user and the

provider's support services, as well as records of any actions taken by the provider or user as a

result of the communications. In my training and experience, such information may constitute

-32-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 44 of 57

evidence of the crimes under investigation because the information can be used to identify the

account's user or users.

119. This application seeks a wanant to search all responsive records and information

under the control of Apple, a provider subject to the jurisdiction of this court, regardless of where

Apple has chosen to store such information. The government intends to require the disclosure

pursuant to the requested warrant of the contents of wire or electronic communications and any

records or other information pertaining to the customers or subscribers if such communication,

record, or other information is within Apple's possession, custody, or control, regardless of

whether such communication, record, or other information is stored, held, or maintained outside

the United States.

120. As explained herein, information stored in connection with an email account may

provide crucial evidence of the "who, what, why, when, where, and how" of the criminal conduct

under investigation, thus enabling the United States to establish and prove each element or

alternatively, to exclude the innocent from further suspicion. In my training and experience, the

information stored in connection with an email account can indicate who has used or controlled

the account. This "user attribution" evidence is analogous to the search for "indicia of occupancy"

while executing a search warrant at a residence. For example, email communications, contacts

lists, and images sent (and the data associated with the foregoing, such as date and time) may

indicate who used or controlled the account at a relevant time. Further, information maintained by

the email provider can show how and when the account was accessed or used. For example, as

described below, email providers typically log the Internet Protocol (IP) addresses from which

users access the email account, along with the time and date of that access. By determining the

physical location associated with the logged IP addresses, investigators can understand the

-33-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 45 of 57 I
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f
I

chronological and geographic context of the email account access and use relating to the crime
Ir1
I•
11

under investigation. This geographic and timeline information may tend to either inculpate or I
I·,I
ii
exculpate the account owner. Additionally, information stored at the user's account may further
II
indicate the geographic location of the account user at a particular time (e.g., location information

integrated into an image or video sent via email). Last, stored electronic data may provide relevant
I
insight into the email account owner's state of mind as it relates to the offense under investigation. I
II
For example, information in the email account may indicate the owner's motive and intent to

commit a crime (e.g., communications relating to the crime), or consciousness of guilt


I
(e.g., deleting communications in an effort to conceal them from law enforcement).

FILTER REVIEW PROCEDURES

121. Review of the items described in Attachment A and Attachment B will be

conducted pursuant to established procedures designed to collect evidence in a manner consistent

with professional responsibility requirements concerning the maintenance of attorney-client and

other operative privileges. The procedures include use, if necessary, of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

CONCLUSION

122. Based on the forgoing, I request that the Court issue the proposed search warrant.

123. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not

required for the service or execution of this warrant.

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 46 of 57
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II
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~
REQUEST FOR SEALING I
I
124. I further request that the Court order that all papers in supp01t of this application,
i
including the affidavit and search warrant, be scaled until further order of the Court. These 1
I
i
documents discuss an ongoing criminal investigation, the full nature and extent of which is not

known to all of the targets of the investigation. Accordingly, there is good cause to seal these

documents because their premature disclosure may seriously jeopardize that investigation.

Respectfully submitted,

~
atrickJ.Myers
Special Agent
Federal Bureau of Investigation

Subscribed and sworn to before me on this .,,2}_~ of September, 2018.


hf/~
The Honorable Beryl A. Howell
Chief United States District Judge

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Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 47 of 57
II
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ATTACHMENT A

Property to be Searched
I
1
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This warrant applies to information associated with the following acconnts, which are

stored at premises owned, maintained, controlled, or operated by Apple, Inc. ("Apple"), a company

headquartered in Cupe1tino, California:


I
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II
"

-1-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 48 of 57

ATTACHMENTB

I. Information to be disclosed by Apple

To the extent that the information described in Attachment A is within the possession,

custody, or control of the Apple, Inc. (hereinafter "the Provider"), regardless of whether such

infonnation is stored, held or maintained inside or outside of the United States, and including

any emails, records, files, logs, or information that have been deleted but are still available to the

Provider, or has been preserved pursuant to a request made under 18 U.S.C. § 2703(f), the

Provider is required to disclose the following information to the government for each account or

identifier listed in Attachment A:

a. The contents of all emails associated with the account, including stored or preserved
copies of emails sent to and from the account, draft emails, the source and
destination addresses associated with each email, the date and time at which each
email was sent, and the size and length of each email;

b. All records or other information regarding the identification of the account, to


include full name, physical address, telephone nnmbers and other identifiers,
records of session times and durations, the date on which the account was created,
the length of service, the IP address used to register the account, log-in IP addresses
associated with session times and dates, account status, alternative email addresses
provided during registration, methods of connecting, log files, and means and
source of payment (including any credit or bank account number);

c. The types of service utilized;

d. All records or other information stored at any time by an individual using the
account, including address books, contact and buddy lists, calendar data, pictures,
and files;

e. All records pertaining to communications between the Provider and any person
regarding the account, including contacts with support services and records of
actions taken; and other identifiers, records of session times and durations, the date
on which the account was created, the length of service, the types of service utilized,
the IP address used to register the account, log-in IP addresses associated with
session times and dates, account status, alternative e-mail addresses provided
during registration, all other user names associated with the account, all account
names associated with the subscriber, methods of connecting;

-2-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 49 of 57

f. All search history or web history;

g. All records indicating the services available to subscribers of the accounts;

h. All usernames associated with or sharing a login IP address or browser cookie with
the accounts;

1. All cookies, including third-party cookies, associated with the user;

j. All records that are associated with the machine cookies associated with the user;
and

k. All telephone or instrument numbers associated with the Account (including MAC
addresses, Electronic Serial Numbers ("ESN"), Mobile Electronic Identity
Numbers ("MEIN"), Mobile Equipment Identifier ("MEID"), Mobile Identification
Numbers ("MIN"), Subscriber Identity Modules ("SIM"), Mobile Subscriber
Integrated Services Digital Network Number ("MSISDN"), International Mobile
Subscriber Identifiers ("IMS!"), or International Mobile Equipment Identities
("IMEI").

II. Information to be Seized by the Government

Any and all records that relate in any way to the accounts described in Attachment A

which consists of evidence, fruits, or instrumentalities of violations of 18 U.S.C. § 2 (aiding and

abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a felony), 18

U.S.C. § 371 (conspiracy), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1030 (unauthorized

access of a protected computer); 18 U.S.C. §§ 1505 and 1512 (obstruction of justice), 18 U.S.C.

§ 1513 (witness tampering), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 1349 (attempt and

conspiracy to commit wire fraud), and 52 U.S.C. § 30121 (foreign contributions ban) for the

period from June I, 2016, to December 31, 2017, including:

a. All records, information, documents or tangible materials that relate in any way to

communications regarding hacking, release of hacked material, communications

with persons or entities associated with WikiLeaks, including but not limited to

-3-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 50 of 57

Julian Assange, or communications regarding disinformation, denial, dissembling

or other obfuscation about knowledge of, or access to, hacked material;

b. All records, information, documents or tangible materials that relate in any way to

communications or meetings involving Jerome Corsi, Julian

Assange, Randy Credico,

or any individual associated with the-Trump Campaign;

c. Communications, records, documents, and other files related to any expenditure,

independent expenditure, or disbursement for an electionee1ing communication;

d. Records of any funds or benefits disbursed by or offered on behalf of any foreign

government, foreign officials, foreign entities, foreign persons, or foreign

principals;

e. All images, messages, communications, calendar entries, search terms, "address

book" entries and contacts, including any and all preparatory steps taken in

furtherance of the above-listed offenses;

f Communications, records, documents, and other files that reveal efforts by any

person to conduct activities on behalf of, for the benefit of, or at the direction of

any foreign government, foreign officials~ foreign entities, foreign persons, or

foreign principals;

g. Evidence indicating how and when the account was accessed or used, to determine

the geographic and chronological context of account access, use, and events relating

to the crimes under investigation and to the account owner;

h. Evidence indicating the account user's slate of mind as it relates to the crimes under

investigation;

-4-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 51 of 57

i. The identity of the person(s) who created or used the account, including records

that help reveal the whereabouts of such person(s);

J. Credit card and other financial information, including but not limited to, bills and

payment records evidencing ownership of the subject account;

k. All images, messages and communications regarding wiping software, encryption

or other methods to avoid detection by law enforcement;

I. The identity of any non-U.S. person(s)--including records that help reveal the

whereabouts of the person(s)--who made any expenditure, independent

expenditure, or disbursement for an electioneering communication; and

m. The identity of any person(s)--including records that help reveal the whereabouts

of the person(s)-who communicated with the account about any matters relating

to activities conducted by on behalf of, for the benefit of, or at the direction of any

foreign government, foreign officials, foreign entities, foreign persons, or foreign

principals.

n. Passwords and encryption keys, and other access inf01mation that may be necessary

to access the account and other associated accounts;

o. All existing printouts from original storage which concern the categories identified

in subsection II.a.

III. Review Protocols

Review of the items described in Attachment A and Attachment B shall be conducted

pursuant to established procedures designed to collect evidence in a manner consistent with

professional responsibility requirements concerning the maintenance of attorney-client and other

-5-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 52 of 57

operative privileges. When appropriate, the procedures shall include use of a designated "filter

team," separate and apart from the investigative team, in order to address potential privileges.

-6-
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 53 of 57

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA I
11
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IN THE MATTER OF THE SEARCH OF


INFORMATION ASSOCIATED WITH ONE
Case: 1:18-sc-02922
I
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Assigned To : Howell, Beryl A.
ACCOUNT STORED AT PREMISES Assign. Date: 9/27/2018
CONTROLLED BY APPLE Description: Search & Seizure Warrant

MOTION TO SEAL WARRANT AND RELATED DOCUMENTS AND


TO REQUIRE NON-DISCLOSURE UNDER 18 U.S.C. § 2705{b)

The United States of America, moving by and through its undersigned counsel, respectfully

moves the Court for an Order placing the above-captioned warrant and the application and affidavit

in support thereof (collectively herein the "Warrant") under seal, and precluding the provider from

notifying any person of the Warrant pursuant to 18 U.S.C. § 2705(b). In regard to the non-

disclosure, the proposed Order would direct Apple, Inc. ("Apple"), an electronic communication
.'
and/or remote computing services provider headquartered in Cupertino, California, not to notify

any other person (except attorneys for Apple for the purpose of receiving legal advice) of the

existence or content of the Warrant for a period of one year or until further order of the Court.

JURISDICTION AND LEGAL BACKGROUND

1. The Court has the inherent power to seal court filings when .appropriate,

including the Warrant. United States v. Hubbard, 650 F.2d 293, 315-16 (D.C. Cir. 1980) (citing
'\
Nixon v. Warner Communications, Inc., 435 U.S. 589, 598 (1978)). The Court may also seal the

Warrant to prevent serious jeopardy to an ongoing criminal investigation when, as in the present
'
case, such jeopardy creates a compelling governmental interest in preserving the confidentiality of

the Warrant. See Washington Postv. Robinson, 935 F.2d 282, 287-89 (D.C. Cir. 1991).

2. In addition, this Court has jurisdiction to issue the requested order because it is "a

court of competent jurisdiction" as defined by 18 U.S.C. § 2711. Specifically, the Court is a

"district court of the United States .. , that - has jurisdiction over the offense being investigated."
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 54 of 57

18 U.S.C. § 2711(3)(A)(i). Acts or omissions in furtherance of the offense under investigation

,occurred within Washington, D.C. See 18 U.S.C. § 3237.

3. Further, the Court has authority to require non-disclosure of the W arraot under 18

U.S.C. § 2705(b). Apple provides an "electronic communications service," as defined in 18

U.S.C. § 2510(15), and/or "remote computing service," as defined in 18 U.S.C. § 2711(2). The

Stored Communications Act ("SCA"), 18 U.S.C. §§ 2701-2712, governs how Apple may be

compelled to supply communications aod other records using a subpoena, court order, or search

warrant. Specifically, Section 27~3(c)(2) authorizes the Government to obtain certain basic

"subscriber information" using a subpoena, Section 2703(d) allows the Government to obtain other

"no.n-content" information using a court order, and Section 2703(a)-(b)(l)(A) allows the
J

Government to obtain contents of communications using a search warraot. See 18 U.S.C. § 2703.

4. The SCA does not set forth aoy obligation for providers to notify subscribers about

subpoenas, court orders, or search warraots under Section 2703. However, many have voluntarily

adopted policies of notifying subscribers about such legal requests. Accordingly, when necessary,

Section 2705(b) of the SCA enables the Government to obtain a court order to preclude such ·

notification. In relevant part, Section 2705(b) provides as follows: 1

(b) Preclusion of notice to subject of governmental access. - A governmental


entity acting under section 2703 ... may apply to a court for ao order commaoding
a provider of electronic communications service or remote computing service to
whom a warrant, subpoena, or court order is directed, for such period· as the court
deems appropriate, not to notify aoy other person of the existence of the warraot,
subpoena, or court order. The court shall enter such ao order if it determines that
there is reason to believe that notification of the existence of the warrant, subpoena,
or court order will result in-
(1) endaogering the life or physical safety of ao individual;
(2) flight from prosecution;

1
Section 2705(b) contains additional requirements for legal process obtained pursuaotto 18 U.S.C.
§ 2703(b)(I)(B), but the Govenunent does not seek to use the proposed Order for aoy legal process
,under that provislon.

2
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 55 of 57

(3) destruction of or tampering with evidence;


(4) intimidation of potential witnesses; or
(5) otherwise seriously jeopardizing an investigation or unduly delaying a trial.

18 U .S.C. § 2705(b ). The United States District Court for the District of Cohunbia has made clear
'
that a nondisclosure order under Section 2705(b) must be issued once the Government makes the

requisite showing about potential consequences of notification:

The explicit terms of section 2705(b) make clear that if a courts [sic] finds that there
is reason to believe that notifying the customer or subscriber of the court order or
subpoena may lead to one of the deleterious outcomes listed under § 2705(b), the
court must enter an order commanding a service provider to delay notice to a
customer for a period of time that the court determines is appropriate. Once the
government makes the required showing under§ 2705(b), the court is required to
issue the non-disclosure order.

In re Application for Order of Nondisclosure Pursuant to 18 U.S.C. § 2705(b) for Grand Jury

Subpoena #GJ2014031422765, 41 F. Supp. 3d 1, 5 (D.D.C. 2014).

5. Accordingly, this motion to seal sets forth facts showing reasonable grounds to

command Apple not to notify any other person (except attorneys for Apple for the purpose of

receiving legal advice) of the existence of the Subpoena for a period of one year or until further

order of the Court.

FACTS SUPPORTING SEALING AND NON-DISCLOSURE

6. The Federal Bureau ofinvestigation ("FBI") is investigating violations of 18 U.S.C.

§ 2 (aiding and abetting), 18 U.S.C. § 3 (accessory after the fact), 18 U.S.C. § 4 (misprision of a

felony), 18 U.S.C. § 371 '(conspiracy), 18 U.S.C. § 951 (acting as an unregistered foreign agent),

18 U.S.C. § 1030 (unauthorized access of a protected computer); 18 U,S,C. § 1343 (wire fraud),

18 U.S.C. § 1349 (attempt and conspiracy to commit wire fraud), and 22 U.S,C. § 611 et seq.

(Foreign Agents Registration Act), and 52 U.S.C. § 30121 (foreign contribution ban) (the "Subject

Offenses"), in connection with efforts to compromise the networks of the Democratic National '

Convention ("DNC"), the Democratic Congressional Campaign Committee ("DCCC"), and the

3
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 56 of 57

email accounts of U.S. persons, followed by the public release of stolen materials through various

outlets.

7. In this matter, the government requests that the Warrant be sealed until further order ·

of the Court and that Apple and its employees be directed not to notify any other person of the ·

existence or content of the Warrant (except attorneys for Apple for the purpose of receiving legal

advice) for a period of one year or until further order of the Court. Such ar1 order is appropriate

because the Warrarit relates to an ongoing criminal investigation, the scope arid nature of which is

neither public nor known to the targets of the investigation, and its disclosure may alert these

targets to the nature, scope, and focus of the ongoing investigation. Disclosure of the Warrarit and

related papers may also alert the targets to the scope of information known to the FBI. Once alerted

to this information, potential targets would be immediately prompted to destroy or conceal

incriminating evidence, alter their operational tactics to avoid future detection, and otherwise take

steps to undermine the investigation and avoid future prosecution. In particular, given that they

are known to use electronic communication and remote computing services, the potential target

could quickly and easily destroy or encrypt digital evidence relating to their criminal activity.

8. Given the complex arid sensitive nature of the criminal activity under.investigation,

and \tlso given that the criminal scheme may be ongoing, the, Government anticipates that this

confidential investigation will continue for the next year or longer. However, should

circumstances change such that court-ordered nondisclosure under Section 2705(b) becomes no

longer needed, the Government will notify the Court and seek appropriate relief,

9. There is, therefore, reason to believe that notification of the existence of the

Warrant will seriously jeopardize the investigation, including by giving the targets fill opportunity

to flee from prosecution, destroy or tamper with evidence, arid intimidate witnesses. See 18 U.S.C.

4
Case 1:19-mc-00029-CRC Document 29-29 Filed 04/28/20 Page 57 of 57

§ 2705(b)(2)-(5). Because of such potential jeopardy to the investigation, there also exists a

compelling governmental interest in confidentiality to justify the governmenfs sealing request.

See Robinson, 935 F.2d at 287-89.

I 0. Based on prior dealings with Apple, the United States is aware that, absent a court

order under Section 2705(b) commanding Apple not to notify anyone about a legal request, Apple

may, upon receipt of a warrant seeking the contents of electronically stored wire or electronic

communications for a certain account, notify the subscriber or customer of the existence of the

warrant prior to producing the material sought.

WHEREFORE, for all the foregoing reasons, the governmentrespectfully requests that the

above-captioned watrant, the application and affidavit in support thereof, and all attachments

thereto'and other related materials be placed under seal, and furthermore, iliat the Court command

Apple not to notify any other person of the existence or contents of the above-captioned warrant

(except attorneys for Apple for the purpose of receiving legal advice) for a period of one year or

until further order of the Court.

Respectfully submitted,

ROBERT S. MUELLER, III


Special Counsel

Dated: 'J/2...7: /\ '(> By:'


Ky!
The. p al Counsel's Office
(202) 616-3812

5
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ATTACHMENT A

Property to be Searched

This warrant applies to information associated with the Google accounts registered to the

following email addresses, which are stored at premises owned, maintained, controlled, or

operated by Google, LLC ("Google"), a company headquartered in Mountain View, California:

-1-
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AO 93 (Rev. 11/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
District of Columbia

In the Matter of the Search of )


(Briefly describe the property to be searched ) Case: 1: 19-sw-00057
or identify the p erson by name and address) ) Assigned To : Chief Judge Howell, Beryl A.
VARIOUS ELECTRONIC DEVICES BELONGING TO ) Assign. Date: 2/13/2019
ROGER J. STONE, JR. ) Description : Search and Seizure Warrant
)

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the District of Columbia
(identify the person or describe the property to be searched and give its location):

See Attachment A.

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the p erson or describe the prop erty to be seized):

See Attachment B.

YOU ARE COMMANDED to execute this warrant on or before February 27, 2019 (not to exceed 14 days)
~ in the daytime 6:00 a.m. to 10:00 p.m.
0 at any time in the day or night because good cause has been established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to Hon. Beryl A. Howell
(United States Magistrate Judge)

0 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U .S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the approp riate box)
0 for _ _ days (not to exceed 30) 0 until, the facts justifying, the later specific date of

Date and time issued:

City and state: Washington, DC Hon. Beryl A. Kowell, Ghief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 2 of 48

AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of:

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.

Date:
Executing officer 's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 3 of 48

ATTACHMENT A

Property to be Searched

The following devices provided to the FBI by currently in the District of

Columbia:
Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 4 of 48

ATTACHMENT B

Items to be seized from the Subject Devices

1. The items to be seized are fruits, evidence, information relating to, contraband, or

instrumentalities of violations Title 18, United States Code, Section 1505 (obstruction of

proceeding); (ii) Title 18, United States Code, Section 1001 (false statements); and (iii) Title 18,

United States Code 1512(b){l) (witness tampering), those violations involving Roger Stone, for

the time period June 2015 to the present, including:

a. Documents and communications that discuss or are related to WikiLeaks, Julian

Assange, and/or Russian interference in the 2016 U.S. presidential election;

b. Documents reflecting communications between Stone and Jerome Corsi;

c. Documents reflecting communications between Stone and Randy Credico;

d. Documents reflecting communications between Stone and members of the Trump

Campaign or Trump Campaign associates, including Steve Bannon,

Paul Manafort, Richard Gates, and Donald J. Trump;

e. Documents related to or discussing the U.S. House of Representatives Permanent

Select Committee on Intelligence, the Senate Select Committee on Intelligence, or

the Federal Bureau of Investigation;

f. Records and information relating to the e-mail accoun

a ;

g. Records and information relating to the WhatsApp account associated with

telephone number

h. Records and information relating to the Signal account associated with telephone

number

Page 1 of 3
Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 5 of 48

1. Records and information relating to the Wicla account associated with telephone

number ;

j. Any computers, media storage devices, tablets/iPads, cellular telephones,

smartphones, personal data assistant devices, or other electronic devices used to

commit the violations described above or to store records or documents described

above;

k. Records of personal and business activities relating to the operation and ownership

of the computer systems, such as telephone records, notes, notebooks, diaries, and

reference materials, in whatever form;

l. Records pertaining to accounts held with Internet Service Providers or of Internet

use, in whatever form;

2. For any computer or storage medium whose seizure is otherwise authorized by this

warrant, and any computer or storage medium that contains or in which is stored records or

information that is otherwise called for by this warrant (hereinafter, "COMPUTER"):

a. evidence of who used, owned, or controlled the COMPUTER at the time the things

described in this warrant were created, edited, or deleted, such as logs, registry

entries, configuration files, saved usernames and passwords, documents, browsing

history, user profiles, email, email contacts, "chat," instant messaging logs,

photographs, and correspondence;

b. evidence of software that would allow others to control the COMPUTER, such as

viruses, Trojan horses, and other forms of malicious software, as well as evidence

of the presence or absence of security software designed to detect malicious

software;

Page 2 of 3
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c. evidence of the lack of such malicious software;

d. evidence indicating how and when the computer was accessed or used to determine

the chronological context of computer access, use, and events relating to crime

under investigation and to the computer user;

e. evidence indicating the computer user' s state of mind as it relates to the crime under

investigation;

f. evidence of the attachment to the COMPUTER of other storage devices or similar

containers for electronic evidence;

g. evidence of counter-forensic programs (and associated data) that are designed to

eliminate data from the COMPUTER;

h. evidence of the times the COMPUTER was used;

1. passwords, encryption keys, and other access devices that may be necessary to

access the COMPUTER;

J. documentation and manuals that may be necessary to access the COMPUTER or

to conduct a forensic examination of the COMPUTER;

k. records of or information about Internet Protocol addresses used by the

COMPUTER;

l. records of or information about the COMPUTER's Internet activity, including

firewall logs, caches, browser history and cookies, "bookmarked" or "favorite"

web pages, search terms that the user entered into any Internet search engine, and

records of user-typed web addresses;

m. contextual information necessary to understand the evidence described in this

attachment.

Page 3 of3
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AO 106 ( Rev. 04/1 0) Applicat ion for a Search Warrant

UNITED STATES DISTRICT COURT ;:r_-~


for the
District of Columbia
fEB 13 Wt9
r.:eri<, tJ.~ ._ Distnct u uar,r<!'ll!)!Ci
Cnurts t{'(I' m-e District of"Cn! w ~
In the Matter of the Search of ) Case: 1 :19-sw-00057
(Briefly describe the property to be searched )
or identify the person by name and address) ) Assigned To : Chief Judge Howell, Beryl A .
VARIOUS ELECTRONIC DEVICES BELONGING TO ) Assign. Date : 2/13/2019
ROGER J. STONE , JR. ) Description: Search and Seizure Warrant
)

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

See Attachment A
located in the - -- - -- - -
District of _ __ __
Columbia
_ ;.c...;...;.- '--- ---
, there is now concealed (identify the
person or describe the property to be seized) :
See Attachment 8

The basis for the search under Fed. R. Crim. P. 4 l(c) is (check one or more):
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed;
rJ property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section Offense Description
18 U.S.C. § 1505 Obstruction of Proceeding
18 U.S.C. § 1512 Witness Tampering
18 U.S.C. § 1001 False Statements
The application is based on these facts :

See attached Affidavit.

~ Continued on the attached sheet.


0 Delayed notice of _ _ days (give exact ending date if more than 30 days: _ _ _ _ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

Reviewed by AUSA/SAUSA:
& ., A~ Applicant's signature

Curtis Heide, Special Agent, FBI


Faron Zelinsky (ASC)
Printed name and title

Sworn to before me and signed in my presence.

Date: 02/13/2019

City and state: Washington, D.C. Hon . Beryl A. Howell, Chief U.S. District Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 8 of 48

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

=~===:~~~~~~~~- ~~~- :;===1== ~ = --~~-=-·· a,• .•• • ·.a . .• •. · - · ·• • . .. • · ·- - - - ·· -

IN THE MATTER OF THE SEARCH OF Case: 1: 19-sw-00057


VARIOUS ELECTRONIC DEVICES Assigned To : Chief Judge Howell, Beryl A.
BELONGING TO ROGER J. STONE, JR. Assign. Date : 2/13/2019
Description: Search and Seizure Warrant

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT

I, Curtis A. Heide, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for the

following devices (the "Subject Devices") associated with Roger J. Stone, Jr. ("Roger Stone"),

described below and further in Attachment A, currently located in the District of Columbia:

a.

b.

c.

2. I am a Special Agent (SA) of the Federal Bureau of Investigation (FBI) and have

been since 2006. In the course of my duties, I have been responsible for investigating federal

crimes and national security matters involving both counterintelligence and issues related to

cybersecurity.

3. I am currently involved in the investigation into Roger J. Stone, Jr., ("Roger Stone")

and others known and unknown to the government, for the commission of unlawful activities in

the District of Columbia, and elsewhere, including, but not limited to: (i) obstruction of

proceeding, in violation of Title 18, United States Code, Section 1505; (ii) false statements, in

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violation of Title 18, United States Code, Section l 001 and (iii) witness tampering, in violation of

Title 18, United States Code l 512(b)(1) (collectively the "Specified Federal Offenses").

4. On January 24, 2019, a Grand Jury in the District of Columbia indicted Roger Stone

on seven counts: (i) obstruction of proceeding, in violation of Title 18, United States Code, Section

1505 (Count 1); (ii) false statements, in violation of Title 18, United States Code, Section 1001

(Counts 2-6) and; (iii) witness tampering, in violation of Title 18, United States Code 1512(b)(l)

(Count 7). See United States v. Roger Jason Stone, Jr., 19-cr-18-ABJ, Dkt. 1. On January 29,

2019, Roger Stone pied not guilty to the charges before Magistrate Judge Deborah A. Robinson.

5. I have personally participated in this investigation and am aware of the facts

contained herein based on my own investigation, as well as my review of documents, records, and

information provided to me by other law enforcement officers and technical experts.

6. This affidavit is intended to show merely that there is sufficient probable cause for

the requested warrant and does not set forth all of my knowledge about this matter. Unless

specifically indicated, all conversations and statements in this affidavit are related in substance

and part. Where I assert that an event took place on a particular date, I am asserting that it took

place on or about the date specified.

7. For the reasons set forth in this Affidavit, there is probable cause to believe that one

or more of the Specified Federal Offenses have been committed by Roger Stone and others known

and unknown to the government. Further, there is probable cause to believe that each of the Subject

Devices have been used to facilitate the commission of one or more of the Specified Federal

Offenses. Moreover, there is probable cause to believe that evidence, contraband, fruits, and

instrumentalities of violations of the Specified Federal Offense may be present in each of the

Subject Devices, as described further in Attachment B.

Page 2 of 41
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PROBABLE CAUSE

A. Background on Relevant Individuals

8. Roger Stone is a political consultant who has worked for decades in U.S . politics

and on U.S. political campaigns. Stone was an official on the U.S. presidential campaign of

Donald J. Trump ("Trump Campaign") until in or around August 2015, and subsequently

maintained regular contact with and publicly supported the Trump Campaign through the 2016

election.

9. Julian Assange is the founder and director of WikiLeaks, which is publicly

described as a non-profit organization that disseminates non-public information and classified

media provided by anonymized sources. WikiLeaks has posted numerous documents stolen from

the U.S. government. At all relevant times, Assange was located at the Ecuadorian Embassy in

London, United Kingdom.

10. Jerome Corsi is a political commentator who worked with an online media

publication during the 2016 U.S. presidential campaign. As set forth below, Corsi spoke regularly

with Stone throughout the campaign, including about the release of stolen documents by

WikiLeaks.

12. Based on the investigation to date, Randy Credico was a radio host who has known

Stone for more than a decade. In testimony before the U.S. House of Representatives Permanent

Selection Committee on Intelligence ("HP SCI") on or about September 26, 2017, Stone described

Credico (without naming him) as an " intermediary," "go-between," and "mutual friend" to

Assange. In a follow-up letter to HPSCI dated October 13, 2017, Stone identified Credico by

Page 3 of 41
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name and claimed Credico was the "gentleman who confirmed for Mr. Stone" that Assange, had

'"[e]mails related to Hillary Clinton which are pending publication." '

13. Richard Gates is a U.S. citizen who served for years as a political consultant and

lobbyist along with Paul Manafort. From in or around June 2016 until November 2016, Gates

served as the deputy campaign chairman of the Trump Campaign. On February 23, 2018, Gates

pled guilty to one count of conspiracy against the United States and one count of making false

statements to federal law enforcement officers. United States v. Gates, 1:l 7-cr-201 (D.D.C.).

14. Steve Bannon is a U.S. citizen who serves as a political consultant. Beginning in

or around August 2016 and through the 2016 U.S. presidential election, Bannon served as the chief

executive officer of the Trump Campaign.

B. Hacking Activity During the 2016 Presidential Election

16. John Podesta is a U.S. citizen who served for years as a political consultant. During

the 2016 U.S. presidential campaign, Podesta served as the campaign chairman of the Hillary

Clinton presidential campaign ("Clinton Campaign"). On or about March 24, 2016, Podesta

received a spearphishing 1 email designed to appear as a security notification (a partial copy of the

email was recovered by the FBI from a subsequent release of stolen emails, described below).

During an interview with the FBI in or around May 2018, Podesta indicated that after receiving

1
In my training and experience, spearphishing in this context refers to the fraudulent practice of
sending an email that purports to be from a known or trusted sender in order to induce the
targeted victim to respond in a desired manner, typically by clicking a malicious link or URL.

Page 4 of 41
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the email, his assistant (who also had access to the account) clicked on a link within the email and

entered the account password when prompted (believing this prompt to be part of a security

protocol). Based on my training and experience, this activity appears to have been a successful

spearphishing operation, through which an actor would have gained access to Podesta's email

account, allowing the actor to steal emails and documents from that account.

17. The Democratic National Committee ("DNC") and Democratic Congressional

Campaign Committee ("DCCC") are U.S. political committees focusing on U.S. federal elections.

Both the DNC and DCCC were involved in the 2016 U.S. federal elections, including the 2016

U.S. presidential election. According to DNC and DCCC individuals interviewed by the Special

Counsel's Office, in or around the spring of 2016, the DNC and DCCC became aware that their

computer systems had been compromised by unauthorized intrusions and hired the cybersecurity

company CrowdStrike to investigate the intrusions and remediate.

18. On or about June 14, 2016, CrowdStrike issued a public press release announcing

that the DNC's computer network had been compromised. In the public statement, CrowdStrike

indicated that it had identified "two sophisticated adversaries on the network," which it referred to

by the monikers COZY BEAR and FANCY BEAR. CrowdStrike stated that it had previously

seen these actors target other customers and that, based on their experience, "[b]oth adversaries

engage in extensive political and economic espionage for the benefit of the government of the

Russian Federation and are believed to be closely linked to the Russian government's powerful

and highly capable intelligence services."

19. On or about July 13, 2018, a federal grand jury sitting in the District of Columbia

returned an indictment against eleven Russian nationals, charging them with partaking in a

conspiracy to hack into, among other things, the email account of John Podesta, as well as the

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DNC and DCCC computer networks. United States v. Viktor Borisovich Netyksho, 1: l 8-cr-215

(D.D.C.). The indictment alleges that all of these individuals were military officers serving in the

Main Intelligence Directorate of the General Staff ("GRU"), the Russian Federation's military

intelligence agency.

C. WikiLeaks' Release of Stolen Documents During the 2016 Presidential Campaign

20. As alleged in the Netyksho indictment, after successfully hacking the DNC and

DCCC networks, as well as Podesta's email account, GRU officers transmitted some of the stolen

documents to WikiLeaks. GRU officers communicated with WikiLeaks members about the

transfers using online personas created by the GRU, including "Guccifer 2.0" and "DCLeaks."

(GRU officers separately used these personas to release some of the stolen documents).

21. On or about July 22, 2016, WikiLeaks released tens of thousands of documents

stolen from the DNC network. These stolen documents included communications by senior DNC

officials about campaign strategy, financial and fundraising data, and other documents related to

the 2016 U.S. federal elections, including the 2016 U.S. presidential election.

22. Beginning in or around October 2016, WikiLeaks began to release tens of

thousands of emails and documents stolen from Podesta's email account. Between on or about

October 7, 2016 and November 7, 2016, WikiLeaks released approximately 33 tranches of

documents that had been stolen from John Podesta, releasing a total of over 50,000 documents.

D. Stone's Communications About WikiLeaks During the Campaign

23. In April 2018 interviews with the Special Counsel's Office, Richard Gates stated

that starting in or around May 2016, when Gates was a senior official on the Trump campaign,

Stone informed members of the Trump Campaign that WikiLeaks had emails from then-candidate

Hillary Clinton. According to Gates, after the July 22, 2016 release of stolen DNC emails by

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WikiLeaks, Gates observed a conversation between Manafort and Stone in which they discussed

WikiLeaks and Stone's prediction of the release .

24. According to Gates, Manafort directed Gates to contact Stone about any additional

releases and what other information WikiLeaks had regarding the Clinton Campaign. Gates

contacted Stone, who made statements claiming that there would be potential future releases of

damaging material by WikiLeaks. In a separate interview with the Special Counsel' s Office in or

around October 2018, Gates recalled that at one point during the campaign he was with then-

candidate Trump in a car when the candidate had a telephone call with Stone; shortly after finishing

the call with Stone, Gates recalled then-candidate Trump said more leaks were coming.

25. Emails recovered through a court-authorized search of Stone's email account

show that shortly after the July 22, 2016 release of stolen DNC emails

by WikiLeaks, Stone corresponded with other associates about contacting WikiLeaks in order to

obtain other emails damaging to the Clinton Campaign:

a. On or about July 25, 2016, Stone sent an email to Jerome Corsi with the subject

line, "Get to Assange." The body of the message read, "Get to Assange [a]t

Ecuadorian Embassy in London and get the pending WikiLeaks emails .. . they

deal with Foundation, allegedly." On or about the same day, Corsi forwarded

2
A search of was authorized on or about September 11, 2017 by the U.S.
District Court for the District of Columbia. Case No. l:17-mj-661 (D.D.C. Sept. 11, 2017). A
second search of was authorized on or about August 3, 2018 by the U.S.
District Court for the District of Columbia. Case No. 1:18-sc-2582 (D.D.C. Aug. 3, 2018). On or
about September 26, 2018, the government obtained and executed an order pursuant to 18 U.S.C.
§ 2703(d) for records connected to Case No. I: 18-sc-2911 (D.D.C. Sept.
26, 2018). Records provided in response by Microsoft Corporation confirmed that the account
was still active and that the relevant emails described in this affidavit were not deleted from the
account.

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Stone' s email to who lived in the United Kingdom and who was a

supporter of the Trump Campaign.

b. On or about July 31, 2016, Stone emailed Corsi with the subject line, "Call me

MON." The body of the email read in part that "should see Assange."

c. On or about August 2, 2016, Corsi responded to Stone by email and wrote that he

was currently in Europe and planned to return in mid-August. Corsi stated, "Word

is friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct.

Impact planned to be very damaging." In a law enforcement interview, Corsi stated

that the phrase "friend in embassy" referred to Assange. Corsi added in the same

email, "Time to let more than Podesta to be exposed as in bed w enemy if they are

not ready to drop HRC. That appears to be the game hackers are now about. Would

not hurt to start suggesting HRC old, memory bad, has stroke - neither he nor she

well. I expect that much of next dump focus, setting stage for Foundation debacle."

26. According to recorded public statements recovered by the FBI, starting in early

August 2016, after receiving this August 2, 2016 email from Corsi, Stone made repeated

statements about information he claimed to have learned from Assange:

a. According to a public video posted to YouTube, on or about August 8, 2016, Stone

attended a public event in Broward County, Florida. During the event, Stone stated,

"I actually have communicated with Assange. I believe the next tranche of his

documents pertain to the Clinton Foundation, but there's no telling what the

October surprise may be."

b. According to a public video posted to YouTube, on or about August 12, 2016, Stone

was interviewed for a video segment on the show Info Wars, hosted by Alex Jones.

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During the interview, Stone stated that he was "in communication with Assange"

but was "not at liberty to discuss what I have."

c. According to a public video posted to YouTube, on or about August 16, 2016, Stone

stated during another interview with Alex Jones that "it became known on this

program that I have had some back-channel communications with WikiLeaks and

Assange." In a second interview on or about the same day with Dana Loesch of

the TheBlaze TV, Stone stated that he "communicated with Mr. Assange" and that

they had a "mutual acquaintance who is a fine gentleman."

d. According to a video posted to the public website of the TV station C-SPAN, during

a C-SPAN television interview on or about August 18, 2016, Stone stated that he

had communicated with Assange through an "intermediary, somebody who is a

mutual friend."

e. In or around late 2018, Credico voluntarily produced to the FBI a copy of a radio

interview he did with Stone on or about August 23, 2016 during which the two

discussed Stone's prior claims to be in contact with Assange. At one point during

the interview, Credico asked Stone, "You've been in touch indirectly with Assange.

Can you give us any kind of insight? Is there an October surprise happening?"

Stone responded, "Well, first of all, I don't want to intimate in any way that I control

or have influence with Assange because I do not. . . . We have a mutual friend,

somebody we both trust and therefore I am a recipient of pretty good information."

27. In or around November 2018, , Stone

produced a series of text messages between Stone and Credico during the 2016 presidential

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campaign. 3 These text messages show that, beginning on or about August 19, 2016, Stone

exchanged written communications with Credico about what WikiLeaks and Assange planned to

do. Emails recovered through a court-authorized search of Stone's email account

show additional written communications between Stone and Credico

about WikiLeaks in or around September 2016.

a. On or about August 19, 2016, Credi co sent a text message to Stone that read in part,

"I'm going to have Julian Assange on my show next Thursday." On or about

August 21 , 2016, Credi co sent another text message to Stone, writing in part, "I

have Julian Assange on Thursday so I' m completely tied up on that day."

b. On or about August 25, 20 16, Assange was a guest on Credico's radio show for the

first time. On or about August 26, 2016, Credico sent a text message to Stone that

stated, "Assange talk[ed] about you last night." Stone replied and asked what

Assange said, to which Credico responded, "He didn't say anything bad we were

talking about how the Press is trying to make it look like you and he are in cahoots."

c. On or about August 27, 2016, Credico sent text messages to Stone that said, "We

are working on a Julian Assange radio show," and that he (Credico) was " in charge"

of the project. In a text message sent later that day, Credico added, "Julian Assange

has kryptonite on Hillary."

d. On or about September 18, 2016, Stone sent a text message to Credico that said, "I

am e-mailing u a request to pass on to assange." Credico responded "Ok," and

3
As discussed below, Stone had previously released some of these text messages to members of
the media, who had written about them and published them in part.

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added in a later text message, "Just remember do not name me as your connection

to Assange you had one before that you referred to."

e. Later on or about September 18, 2016, Stone emailed Credi co an article with

allegations against then-candidate Clinton related to her service as Secretary of

State. Stone stated, "Please ask Assange for any State or HRC e-mail from August

10 to August 30 -- particularly on August 20, 2011 that mention [the subject of the

article] or confirm this narrative."

f. On or about September 19, 2016, Stone texted Credico again, writing, "Pass my

message ... to Assange." Credico responded, "I did." On or about September 20,

2016, Credico forwarded the request to a close friend who was an attorney with the

ability to contact the Assange. Credico blind-copied Stone on the forwarded email.

g. On or about September 30, 2016, Credico sent Stone via text message a photograph

of Credico standing outside the Ecuadorian Embassy in London where Assange

was located.

h. On or about October l, 2016, which was a Saturday, Credico sent Stone text

messages that stated, "big news Wednesday . . . now pretend u don't know me ...

Hillary's campaign will die this week." In the days preceding these messages, the

press had reported that Assange planned to make a public announcement on or

about Tuesday, October 4, 2016, which was reported to be the 10-year anniversary

of the founding of WikiLeaks.

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1. On or about October 2, 2016, Stone emailed Credico, with the subject line "WTF?"

and a link to an article at the website http://heatst.com/politics/october-surprise-

thwarted-wikileaks-cancels-highly-anticipated-tuesday-announcement-due-to-

security-concerns. Credico responded to Stone, "head fake."

J. On or about Monday, October 3, 2016, Stone wrote Credico and asked, "Did

Assange back off." Credico initially responded, "I can't tal[k] about it." After

further exchanges with Stone, Credico responded, "I think it[']s on for tomorrow."

Credico added, "Off the Record Hillary and her people are doing a full-court press

they [sic] keep Assange from making the next dump ... That's all I can tell you on

this line ... Please leave my name out of it."

28. Emails and text messages recovered by the FBI show that, in or around October

2016, Stone made statements about Assange' s future releases that were similar to prior statements

made by Credico to him. For example:

a. In a court-authorized search of Stone's email account the

FBI recovered an email from Stone to sent on or about October 3, 2016,

which stated in part, "Spoke to my friend in London last night. The payload is still

coming."

b. In a court-authorized search of the FBI also recovered an

email exchange from on or about October 3, 2016 between Stone and a reporter

who had connections to Bannon. In the exchange, the reporter asked, "Assange -

4
A search of was authorized on or about October 17, 2017 by the U.S.
District Court for the District of Columbia. Case No. l:17-mj-760 (D.D.C. Oct. 17, 2017). A
second search of was authorized on or about August 3, 2018 by the U.S.
District Court for the District of Columbia. Case No. 1: 18-sc-2583 (D.D.C. Aug. 3, 2018).

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what' s he got? Hope it's good." Stone responded, " It is. I'd tell Bannon but he

doesn't call me back."

c. On or about October 4, 2016, Assange held a press conference but did not release

any new materials pertaining to the Clinton Campaign. In a court-authorized search

o , the FBI recovered an email exchange between Stone and

Steve Bannon on or about October 4, 2016 that occurred after the press conference.

In the exchange, Bannon asked, " What was that this morning???", referring to

Assange's press conference. Stone responded, "Fear. Serious security concern. He

thinks they are going to kill him and the London police are standing do[wn].

However - a load every week going forward."

d. In a court-authorized search of Stone's iCloud account, 5 the FBI recovered text

messages between Stone an from on or about October 4, 2016. In one text

message asked Stone if he had "hear[d] anymore from London." Stone

replied, " Yes - want to talk on a secure line - got Whatsapp." In an interview with

the Special Counsel ' s Office in or around May 2018 confirmed that he and

Stone spoke and that Stone had told him WikiLeaks had more material to release,

and that the material was related to senior people associated with Clinton.

29. On or about October 7, 2016, WikiLeaks released the first set of emails stolen from

Podesta. According to text messages recovered from Stone's iCloud account, shortly after the

release, an associate of Bannon sent a text message to Stone that read "well done." Similarly,

5
A search of Stone's iCloud account was authorized on or about March 14, 2018 by the U.S.
District Court for the District of Columbia. Case No. l: 18-sc-662 (D.D.C. Mar. 14, 2018). The
records for Stone's iCloud account contained some, but not all, of Stone's communications from
the campaign period.

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during an April 2018 interview, Gates recalled that after the October 7, 2016 WikiLeaks release,

Stone said, "I told you this was coming."

E. Stone's Communications with the House Permanent Select Committee on Intelligence

30. On or about January 25, 2017, HPSCI publicly disclosed that it was investigating

allegations of Russian interference in the 2016 presidential election and possible links to

individuals associated with political campaigns. 6 During a public HPSCI hearing on or about

March 20, 2017, multiple HPSCI committee members indicated that Stone' s prior public

statements about having communications with Assange (particularly those from August 2016)

were of interest to the committee.

31. In or around May 2017, HP SCI sent a letter requesting that Stone voluntarily appear

before the committee and produce relevant documents to HPSCI (a copy of the HPSCI letter was

recovered by the FBI from a court-authorized search of Stone' s email account

[email protected]). The letter requested Stone produce:

Any documents, records, electronically stored information


including e-mail, communication, recordings, data and tangible
things (including, but not limited to, graphs, charts, photographs,
images and other documents) regardless of form, other than those
widely available (e.g., newspaper articles) that reasonably could
lead to the discovery of any facts within the investigation's publicly-
announced parameters.

32. On or about May 22, 2017, counsel for Stone responded to HPSCI in writing and

stated that "Mr. Stone has no documents, records, or electronically stored information, regardless

of form, other than those widely available that reasonably could lead to the discovery of any facts

6
On or about January 13, 2017, the chairman and vice chairman of the Senate Select Committee
on Intelligence ("SSCI") announced the committee would conduct an inquiry that would
investigate, among other things, any intelligence regarding links between Russia and individuals
associated with political campaigns, as well as Russian cyber activity and other "active measures"
directed against the United States in connection with the 2016 election.

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within the investigation's publicly-announced parameters." (A copy of the letter was recovered

from a court-authorized search of Stone' s email account .

F. Stone's Testimony Before HPSCI

33. On or about September 26, 2017, Stone provided HPSCI with an "opening

statement" that his counsel requested be included as part of the record of proceedings before

HPSCI. In his opening statement, which HPSCI provided to the Department of Justice,7 Stone

stated, "These hearings are largely based on a yet unproven allegation that the Russian state is

responsible for the hacking of the DNC and John Podesta and the transfer of that information to

WikiLeaks."

34. Also on or about September 26, 2017, Stone provided testimony in a closed session

before HPSCI, at the U.S. Capitol in Washington, D.C. Stone's testimony was transcribed, and a

copy of the transcript was obtained by the Special Counsel' s Office from HPSCI in or around

December 2018. Stone appeared before HP SCI under oath and affirmed for the record that he

would tell the truth. At the beginning of the hearing, Stone was admonished that "it is unlawful to

deliberately provide false information to Members of Congress or staff' and that "providing false

information to this committee or concealing material information from this committee is a crime

punishable by law."

Stone 's Testimony About Documents He Possessed Related to WikiLeaks

35. During his HPSCI testimony, Stone was asked about HPSCI's May 2017 document

7
On or about December 14, 2018, the U.S. Department of Justice requested the transcript of
Stone's interview with HPSCI, as well as any written submissions and/or correspondence from
Stone and/or his counsel before or after the interview. On or about December 20, 2018, HPSCI
provided the U.S. Department of Justice a copy of the transcript of the September 26, 2017
interview of Roger Stone, a copy of Stone' s written opening statement, and various
correspondence from Stone' s counsel to members ofHPSCI.

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request and whether Stone had any documents or written communications that discussed Julian

Assange, Russian interference, or other relevant documents:

Q: The committee wrote to you on May 9th requesting no later


than May 22 any documents, records, electronically stored
information, including email communication, recordings,
data, and other tangible things relevant to our investigation.
You wrote back through counsel that you had no documents,
records, or electronically stored information regardless of
form responsive to our requests. Was that a false statement?

A: That is not a false statement. That's what -- I believe that to


be true.

[ ...]

Q: So you have no emails to anyone concerning the allegations


of hacked documents or your conversations with the
Guccifer 2[.0] or any discussions you have had with third
parties about Julian Assange? You have no emails, no texts,
no documents whatsoever, any kind of that nature?

A: That is correct. Not to my knowledge. I think we met, again,


the precise criteria of your request, and we complied. Again,
if you have a more specific request, I'm happy to go back and
look. ...

Q: I just want to ask you under oath -

A: We did an extensive search consistent with the direction of


my attorneys, and we found nothing that met the criteria that
you asked for.

Q: I just want to be certain because you are under oath, where


your letter was not under oath, that you have no documents,
no emails, no texts, no tweets that refer to Julian Assange or
Guccifer 2[.0] or Paul Manafort or the allegations
concerning Russian connections with the campaign. You
have had no discussions in any written form. You've written
no documents yourself.

A: In connection with Russian collusion, consistent with your


exact and precise request, yes.

36. In fact, and as described above, Stone had sent and received numerous emails and

text messages during the 2016 campaign in which he discussed WikiLeaks, Assange, and

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WikiLeaks possession of hacked emails. Court-authorized searches of Stone's email accounts

(including ) and his iCloud account show that,

at the time of his testimony, Stone was still in possession of many of these emails and text messages

at the time he testified on or about September 22, 2017.8 These written communications included

(a) Stone's email to Corsi on or about July 25, 2016 that read in part, "Get to Assange [a]t

Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly."; (b) Stone's email to Corsi on or about July 31, 2016 that "should

see Assange"; (c) Corsi's email to Stone on or about August 2, 2016 that stated in part, "Word is

friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct. Impact planned

to be very damaging."; (d) dozens of text messages and emails between Stone and Credico,

beginning on or about August 19, 2016 and continuing through duration of the election, in which

they discussed WikiLeaks and Assange; (e) Stone's email to on or about October 3, 2016

that read in part "Spoke to my friend in London last night. The payload is still coming."; and (f)

Stone's email to Bannon on or about October 4, 2016 that claimed WikiLeaks would release "a

load every week going forward."

Stone's Testimony About His Early August 2016 Statements

37. During his HPSCI testimony on or about September 26, 2017, Stone was asked to

explain his statements in early August 2016 about being in contact with Assange. Stone was

specifically asked about his statement on or about August 8, 2016 that "I've actually

8
The warrant for Stone's email account was obtained on or about
September 11, 2017 and executed shortly thereafter. Records provided in or around September
2018 in response to a court order issued pursuant to 18 U.S.C. § 2703(d) confirmed that the account
was active and the emails in question were not deleted from the account. The warrant for Stone's
email account was obtained on or about October 17, 2017 and executed
shortly thereafter. The warrant for Stone's iCloud account (which contained the text messages
described above) was obtained on or about March 14, 2018 and executed shortly thereafter.

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communicated with Assange," as well as his statement on or about August 12, 2016 that he was

"in communication with Assange" but was "not at liberty to discuss what I have."

38. Stone testified that these public references to having a means of contacting

WikiLeaks referred exclusively to his contact with a journalist, who Stone described as a "go-

between, as an intermediary, as a mutual friend" of Assange. Stone declined to tell HPSCI the

name of this "intermediary," but he provided a description in his testimony that was largely

consistent with Credico. (On or about October 13, 2017, Stone caused a letter to be submitted to

HPSCI that identified Credico by name as the "gentleman who confirmed for Mr. Stone" that

Assange had "'[e]mails related to Hillary Clinton which are pending publication."').

39. In fact, documents recovered during the investigation (including those obtained via

search warrant returns show that Stone did not begin communicating

with Credico about Assange or WikiLeaks until on or about August 19, 2016 9- approximately

eleven days after Stone first claimed on or about August 8, 2016 to "actually have communicated

with Assange" and a week after his August 12, 2016 statements of being " in communication with

Assange" and "not at liberty to discuss what I have."

40. When interviewed by the FBI, Credico stated that the first time he ever spoke with

°
Assange was on or about August 25, 2016, when Credico interviewed Assange. 1 Credico also

provided the FBI with partially redacted emails that he claimed were between him and another

9
As described above, on or about August 19, 2016, Credi co informed Stone by text message that
Credi co intended to interview Assange the following week. On or about August 25, 2016, Credi co
interviewed Julian Assange for the first time, and on or about August 27, 2016, Credico texted
Stone that "Assange has kryptonite on Hillary."
1
°Credico was first interviewed by the FBI in or around August 2018. He has subsequently
participated in multiple voluntary interviews

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member of WikiLeaks from on or about August 25, 2016, in which the two discuss the technical

logistics for the interview later that day. During the exchange, Credico offered biographical

information about himself, apparently as a means of introduction.

41. The FBI has not identified any communications between Stone and Credico from

August 2016 in which Stone directs Credico to contact Assange or WikiLeaks. When interviewed

by the FBI, Credico claimed he was never directed by Stone in August 2016 to contact WikiLeaks.

42. In contrast, and as described above, the FBI has identified written communications

prior to August 8, 2016 in which Stone directed Corsi-not Credico--to contact Assange. On or

about July 25, 2016, for example, Stone wrote to Corsi, "Get to Assange [a]t Ecuadorian Embassy

in London and get the pending WikiLeaks emails .. . they deal with Foundation, allegedly."

Similarly, on or about August 2, 2016, Corsi-not Credico--sent an email to Stone in which Corsi

wrote that " [w]ord is friend in embassy plans 2 more dumps," including one in October. These

communications occurred days before Stone's first public statement on or about August 8, 2016

claiming to be in communication with Assange. However, at no time did Stone identify Corsi to

HPSCI as another individual Stone contacted to serve as a "go-between," "intermediary," or other

source for information from WikiLeaks. Similarly, Stone also never disclosed his written

communications with Corsi to HPSCI when answering HPSCI' s questioning about the August 8,

2016 and August 12, 2016 statements about being in communication with Assange.

Stone 's Testimony About Communications to Assange

43. During his HPSCI testimony, Stone was asked, "Did you ask [the intermediary] to

communicate anything else to Assange?" Stone responded, "I did not." Stone was then asked,

"Did you ask [the intermediary] to do anything on your own behalf?" Stone responded, "I did

not."

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44. In fact, starting on or about September 18, 2016, Stone directed Credi co to pass on

a request to Assange for documents that Stone believed would be damaging to the Clinton

Campaign.

a. According to text messages obtained on or about

September 18, 2016, Stone sent a text message to Credico that said, "I am e-mailing

u a request to pass on to Assange." On or about the same day, Stone emailed

Credico an article with allegations against then-candidate Clinton related to her

service as Secretary of State. Stone added, "Please ask Assange for any State or

HRC e-mail from August IO to August 30 - particularly on August 20, 2011 that

mention [the subject of the article] or confirm this narrative." (A copy of this email

was obtained through a search of Stone's email account .

b. According to text messages obtained on or about

September 19, 2016, Stone texted Credico again, writing " Pass my message . .. to

Assange." Credico responded, "I did." An email obtained from the account

shows that on or about September 20, 2016, Credico

forwarded the request to an attorney who had the ability to contact Assange;

Credico blind copied Stone on the same email.

Stone's Testimony About Written Communications with Credico

45. During his HPSCI testimony, Stone was asked repeatedly about his

communications with the person he identified as his intermediary. Stone stated that he had never

communicated with his intermediary in writing in any way. During one exchange, Stone claimed

only to have spoken with the intermediary telephonically:

Q: [H]ow did you communicate the intermediary?

A: Over the phone.

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Q: And did you have any other means of communicating with


the intermediary?

A: No.

Q: No text messages, no - none of the list, right?

A: No.

Later during his testimony, Stone again denied ever communicating with his intermediary in

writing:

Q: So you never communicated with your intermediary in


writing in any way?

A: No.

Q: Never emailed him or texted him?

A: He's not an email guy.

Q: So all your conversations with him were in person or over


the phone.

A: Correct.

46. As described above, Stone and Credico (whom Stone identified as his intermediary)

engaged in frequent written communication by email and text message. Beginning on or about

August 19, 2016, and continuing through the 2016 U.S. presidential election, Stone and Credico

engaged in dozens of communications by email or text message in which they discussed

WikiLeaks and the possible release of stolen documents that would be damaging to the Clinton

Campaign.

47. Written communications between Stone and Credico continued up until Stone's

HPSCI testimony and afterwards. For example, on or about September 26, 2017- the day that

Stone testified before HPSCI and denied having ever sent or received emails or text messages from

his identified intermediary-Stone and Credico exchanged over thirty text messages.

48. Certain of the electronic messages between Stone and Credico (which Stone denied

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ever taking place or possessing) would have been material to HPSCI, including Stone's messages

in or around September 2016 directing Credico to pass a request for documents to Assange, and

other relevant written communications with Credico. For example, on or about January 6, 2017,

Credico sent Stone an email, which Stone had in his possession at the time of his HPSCI testimony,

that had the subject line "Back channel bs." In the email, Credico wrote, "Well I have put together

timelines[] and you [] said you have a back-channel way back a month before I had Assange on

my show ... I have never had a conversation with Julian Assange other than my radio show ... I

have pieced it all together .. . so you may as well tell the truth that you had no back-channel or

there's the guy you were talking about early August." (A copy of this emai l was obtained through

a search of Stone's email accoun ).

Stone 's Testimony About Communications with the Trump Campaign

49. During his HPSCI testimony, Stone was asked, "[d]id you discuss your

conversations with the intermediary with anyone involved in the Trump campaign?" Stone

answered, "I did not." As described above, Stone spoke to multiple individuals involved in the

Trump campaign about what he claimed to have learned from his intermediary to Assange,

including the following:

a. As described above, Gates confirmed to investigators that Stone spoke with senior

Trump Campaign officials by telephone to inform them about materials possessed

by Assange and the timing of future releases.

b. According to text messages , on or about October

3, 2016, Stone wrote to , " Spoke to my friend in London last night. The

payload is still coming."

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c. As described above, on or about October 4, 2016, after receiving information from

Credico about the delay in WikiLeaks's release of stolen materials, Stone emailed

Bannon that Assange had a " [s]erious security concern" but would release "a load

every week going forward."

G. Stone's Attempts to Influence Credico Regarding HPSCI and the FBI

50. According to an email recovered through a court-authorized search of Stone' s email

accoun on or about October 19, 2017, Stone sent Credico an excerpt of

his October 13, 2017 letter to HPSCI in which Stone claimed Credico was his " intermediary" to

Assange. As described below, Credico repeatedly told Stone that his letter was false and said he

should correct his statement to HPSCI, but Stone did not do so. Stone then engaged in a prolonged

effort to prevent Credico from contradicting Stone's false statements to HPSCI.

51. In or around November 2017, Credico received a request from HP SCI to testify

voluntarily before the committee. After being contacted by HPSCI, Credico spoke and texted

repeatedly with Stone.

a. On or about November 19, 2017, Credico texted Stone that his lawyer wanted to

see him. Stone responded, " ' Stonewall it. Plead the fifth . Anything to save the

plan' . .. Richard Nixon." (A copy of these text messages was recovered through

a court-authorized search of Stone's iCloud account). On or about November 20,

2017, Credico informed HPSCI that he declined HPSCI's request for a voluntary

interview.

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b. On or about November 21, 2017, Credico texted Stone, "I was told that the house

committee lawyer told my lawyer that I will be getting a subpoena." Stone

responded, "That was the point at which your lawyers should have told them you

would assert your 5th Amendment rights if compelled to appear." (A copy of these

text messages was recovered through a court-authorized search of Stone's iCloud

account).

c. On or about November 28, 2017, Credico received a subpoena compelling his

testimony before HPSCL Credico informed Stone of the subpoena.

d. According to emails recovered from Stone' s email account

on or about November 30, 2017, Stone asked Corsi to write publicly about Credico.

Corsi responded, "Are you sure you want to make something out of this now? Why

not wait to see what [Credico] does? You may be defending yourself too much -

raising new questions that will fuel new inquiries. This may be a time to say less,

not more." Stone responded by telling Corsi that Credico "will take the 5th-but

let's hold a day."

e. According to text messages recovered from Stone's iCloud account, on multiple

occasions, starting on or about November 17, 2017, Stone and Credico discussed

Frank Pentangeli. Frank Pentangeli is a character in the film The Godfather: Part

II, who falsely claims not to know critical information before a congressional

committee that he does in fact know. On or about December 1, 2017, Stone told

Credico in a text message to "Start practicing your Pentagele." When interviewed

by the FBI, Credico confirmed that he understood Stone's references to Frank

Pentangeli to be Stone's way of suggesting Credico withhold relevant information

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Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 32 of 48

from investigators.

f. On or about December 1, 2017, Stone texted Credico, "And if you turned over

anything to the FBI you're a fool. " Later that day, Credico texted Stone, " You need

to amend your testimony before I testify on the 15th." Stone responded, "If you

testify you' re a fool. Because of tromp I could never get away with a certain [sic]

my Fifth Amendment rights but you can. I guarantee you you are the one who gets

indicted for perjury if you' re stupid enough to testify." (A copy of these text

messages was recovered through a court-authorized search of Stone's iCloud

account).

52. On or about December 12, 2017, Credico informed HP SCI that he intended to assert

his Fifth Amendment privilege against self-incrimination if required to appear by subpoena.

According to Credico, he invoked his Fifth Amendment privilege in part to avoid providing

evidence that would show Stone's previous testimony to Congress was false.

53. Following Credico's invocation of his Fifth Amendment privilege not to testify

before HPSCI, Stone and Credico continued to have discussions about the various investigations

into Russian interference in the 2016 election and what information Credico would provide to

investigators. During these conversations, Stone repeatedly made aggressive statements intended

to prevent Credico from cooperating with the investigations. For example:

a. On or about December 24, 2017, Credico texted Stone, "I met assange for f[i]rst

time this yea[r] sept 7 .. . docs prove that ... You should be honest w fbi . . . there

was no back channel ... be honest." Stone replied approximately two minutes

later, "I'm not talking to the FBI and if your smart you won't either." (A copy of

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these text messages was recovered through a court-authorized search of Stone's

iCloud account).

b. On or about April 9, 2018, Stone wrote in an email to Credico, "You are a rat. You

are a stoolie. You backstab your friends- run your mouth my lawyers are dying

Rip you to shreds." Stone also said he would "take that dog away from you,"

referring to Credico's dog. On or about the same day, Stone wrote to Credico, "I

am so ready. Let's get it on. Prepare to die [expletive]." (A copy of this email

exchange was recovered through a court-authorized search of Stone's email

accoun ).

c. On or about May 21, 2018, Credico wrote in an email to Stone, "You should have

just been honest with the house Intel committee . . . you've opened yourself up to

perjury charges like an idiot." Stone responded, " You are so full of [expletive].

You got nothing. Keep running your mouth and I'll file a bar complaint against

your friend [the attorney who had the ability to contact the head of Assange]." (A

copy of this email exchange was recovered through a court-authorized search of

Stone's email accou ). Credico believed Stone knew that

Credico was sensitive to having this friend 's name publicly disclosed.

H. Missing Electronic Communications and Stone's Use of Encrypted Communications

54. As described above, the government has recovered the content of many of Stone's

electronic communications from summer and fall of 2016 (during the period of the U.S.

presidential election) and afterward (during the period of pending congressional investigations into

Russian interference in the U.S. election). However, the government is aware of the existence of

Page 26 of 41
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numerous other relevant electronic communications, the content of which it has not yet been able

to recover.

55. As described above, during his HPSCI testimony, Stone falsely denied having

emailed or exchanged text messages with his " intermediary" (later identified by Stone as Randy

Credico). In fact, emails and text messages recovered in this investigation show the two

communicated frequently by email and text messages; court-authorized searches of Stone's email

and iCloud accounts confirm that Stone still had those communications at the time he testified in

or around September 2017. In numerous communications, Stone and Credico discussed Julian

Assange and WikiLeaks, as well as Stone's suggestion that Credico was his intermediary to

Assange. These communications appear relevant and responsive to HPSCI' s inquiry, but Stone

never disclosed them.

56. In addition to these emails and text messages in the FBI's possession, the FBI has

reviewed telephone billing records for Stone's cellular telephone for the years 2016 and 2017, and

they show text message communications whose content that the government to date has not been

able to obtain. For example, these records indicate that Stone and Credico alone exchanged

thousands of text messages (including over 1,500 text messages between the period November

2016 and December 2017) the substance of which the government to date has not recovered or

reviewed. The government has only recently obtained text messages between Stone and Credico

during some period of the campaign in 2016 from Stone's subpoena production, issued after media

reports in November 2018 stated that Stone's attorneys were able to extract text messages between

Stone and Credico from a phone Stone stopped using in 2016. But the government does not have,

for the same time period, many of Stone's other text messages. The government seeks these text

messages believing they may show additional evidence of (1) the falsity of Stone's HPSCI

Page 27 of 41
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testimony concerning his communications with his "intermediary" and (2) efforts to corruptly

persuade Credico not to cooperate with pending investigations. As discussed further below, the

government has reason to believe that these messages may be located on the Subject Devices.

57. Additionally, the FBI has interviewed multiple associates of Stone, who confirmed

that Stone has used encrypted applications to communicate with others. Similarly, records

obtained in this investigation indicate Stone uses multiple applications designed for encrypted

communication, including (a) WhatsApp, 11 (b) Signal, 12 (c) Wickr, 13 and (d) ProtonMail. 14 To

date, the FBI has not obtained any of Stone's communications conducted through these

applications.

11
According to open sources, WhatsApp is an application that allows the user to send text
messages, make voice calls, and transmit documents. WhatsApp uses end-to-end encryption and
stores its messages separately from those text messages used on a mobile device' s default message
application.
12
According to open sources, Signal is an encrypted communications application allowing the user
to send one-to-one and group messages, which can include files, voice notes, images and videos,
and make one-to-one voice and video calls. Signal uses standard cellular mobile numbers as
identifiers, and uses end-to-end encryption to secure all communications to other Signal users.
Signal also allows users to set timers to messages, after which the messages will be deleted from
both the sender' s and the receivers' devices.
13
According to open sources, Wickr is an instant messaging application that allows users to
exchange end-to-end encrypted and content-expiring messages, including photos, videos, and file
attachments and place end-to-end encrypted video conference calls. Like Signal, Wickr allows
users to set an expiration time for their encrypted communications. In addition to encrypting user
data and conversations, Wickr claims that its application strips metadata from all content
transmitted through the network.
14
According to open sources, ProtonMail is an end-to-end encrypted email service that uses client-
side encryption to protect email contents and user data before they are sent to ProtonMail servers.
According to its website, ProtonMail is run by Proton Technologies AG, a company based in the
Canton of Geneva, and its servers are located at two locations in Switzerland, outside of US and
EU jurisdiction.

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a. According to records from Stone' s iCloud account, a copy of the WhatsApp

application was downloaded to an iPhone registered to Stone on or about October

5, 2016. As described above, on or about October 4, 2016, Stone suggested in an

email to that they "talk on a secure line" and proposed using WhatsApp.

b. According to records from Stone's iCloud account, a copy of the Signal application

was downloaded to an iPhone registered to Stone on or about August 18, 2016.

Additionally, text messages recovered from Stone' s iCloud account revealed that

on or about November 15, 2016, Stone sent an attorney with the ability to contact

Julian Assange a link to download the Signal application. 15 Approximately fifteen

minutes after sending the link, Stone texted the attorney, "I'm on signal just dial

my number." The attorney responded, "I'll call you."

c. According to records from Stone's iCloud account, a copy of the ProtonMail

application was downloaded to an iPad registered to Stone on or about August 18,

2016.

d. According to records from Stone's iCloud account, a copy of the Wickr application

was downloaded to an iPhone registered to Stone on or about August 5, 2017.

58. Based on my training and experience, electronic communications using encrypted

applications such as WhatsApp, Signal, ProtonMail, and Wickr are sometimes maintained on the

device used to send and receive those communications. Communications from those applications

can be obtained by law enforcement by searching the device either manually or via a data

extraction device (such as Cellebrite). Searches of the physical device can reveal messages,

15
This attorney was a close friend of Credico's and was the same friend Credico emailed on or
about September 20, 2016 to pass along Stone's request to Assange for emails connected to the
allegations against then-candidate Clinton related to her service as Secretary of State.

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including text messages and messages exchanged over WhatsApp, Signal, ProtonMail, and Wicla,

that have not been backed up to cloud accounts (such as an iCloud account). Additionally, review

of the device and the downloaded application can reveal other evidence of encrypted

communications, such as call logs and contact lists.

59. The FBI continues to seek evidence of Stone's communications and contacts during

the period of the 2016 U.S. presidential election and through the present. The FBI believes these

communications may contain evidence of additional communications concerning Assange,

WikiLeaks, and the release of stolen documents damaging to the Clinton Campaign. Such

communications could constitute additional evidence of Stone's efforts to obstruct HPSCI's

investigation by showing additional contacts and communications about Assange and WikiLeaks

that Stone failed to disclose.

I. The Subject Devices

60. In or around November 2018, media reports began to publish excerpts of text

messages between Stone and Randy Credico that occurred during the 2016 U.S. election (copies

of these text messages subsequently were obtained from Stone ). 16

According to these news articles, Stone released these messages to the media outlets, which Stone

claimed were extracted by his lawyers from "a cell phone he stopped using in 2016." Based on

these statements and described further below, your affiant believes the cell phone referenced in the

article to be the iPhone Ss. 17

16
See, e.g., "Bombshell Text Messages Support Roger Stone's Claims About WikiLeaks
Backchannel," Daily Caller, Nov. 14, 2018, available at https://dailycaller.com/2018/11/14/roger-
stone-wikileaks-randy-credico-mueller.

a, Stone produced some text messages between Credico and


him; the latest-in-time text message produced by Stone occurred on or about November 14, 2016.

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61. On or about February 11, 2019, investigators, with the consent of Roger Stone's

attorneys, spoke with , a certified forensic examiner who stated he had been retained

by Roger Stone's attorneys. had been authorized by Stone's attorneys to provide the

Subject Devices to the FBI, although in providing the devices, Stone did not consent to their search.

Stillman gave the Agents three devices: the iPhone 5s, the iPhone 7, and the external hard drive.

62. produced documentation to investigators indicating that the iPhone 5s was

associated with the phone number ending in Stone's cellular number as discussed above.

The documentation also indicated that had imaged the iPhone 5s on or about November

10, 2018, several days before the article discussed above where Stone claimed to have released

newly-uncovered messages with Credico. Toll records produced by AT&T pursuant to subpoena

indicate that Stone used an iPhone 5s from at least on or about January 1, 20 15 through on or about

November 14, 2016. Therefore, it appears that the iPhone 5s was the device Stone was using

through November 14, 2016 to communicate with individuals including Credico and Corsi.

63. also produced documentation to investigators that the iPhone 7 he

provided to investigators was associated with the same Stone phone number ending in . As

discussed above, toll records produced by AT&T pursuant to subpoena indicate that Stone used an

iPhone 7 from at least on or about November 14, 2016 through on or about February 25, 2018. As

described above, Stone communicated extensively with Credico during this time. Toll records

also indicate Stone continued to communicate with Corsi during this time period using the x3034

number.

The government believes copies of later-in-time text messages from late 2016 and early 2017 could
be located on another device, such as the iPhone 7, or on backup storage media.

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64. further told investigators that the external hard drive contained forensic

images of Stone' s computers. stated that the hard drive contained backups created by a

separate company in September 2017 from Stone' s computers in both Florida and New York.

According to the backups were created as "clone copies," which are copies of Stone' s

computer systems. also indicated that the drive contained a separate image

created in March 2018 of Stone' s computer in Florida, as well as backup images of the iPhones

discussed above. As explained further herein, there is reason to believe that these images contain

communications made by Stone with Credico, Corsi, and others made during the relevant time

period, even if such communications had previously been deleted.

COMPUTERS, ELECTRONIC STORAGE, AND FORENSIC ANALYSIS

65. As described herein and in Attachment B, this application seeks permission to

search the Subject Devices. One form in which the records might be found is data stored on a

device 's hard drive. Thus, the warrants applied for would authorize the search of electronic storage

media.

66. Probable cause. I submit that there is probable cause to believe those records will

be stored on the Subject Devices (the term "computer" below refers to Subject Devices), for at

least the following reasons:

a. Based on my knowledge, training, and experience, I know that computer files or

remnants of such files can be recovered months or even years after they have been

downloaded onto a storage medium, deleted, or viewed via the Internet. Electronic

files downloaded to a storage medium can be stored for years at little or no cost.

Even when files have been deleted, they can be recovered months or years later

using forensic tools. This is so because when a person "deletes" a file on a

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computer, the data contained in the file does not actually disappear; rather, that data

remains on the storage medium until it is overwritten by new data.

b. Therefore, deleted files, or remnants of deleted files, may reside in free space or

slack space-that is, in space on the storage medium that is not currently being used

by an active file-for long periods of time before they are overwritten. In addition,

a computer' s operating system may also keep a record of deleted data in a "swap"

or "recovery" file.

c. Wholly apart from user-generated files, computer storage media- in particular,

computers' internal hard drives--contain electronic evidence of how a computer

has been used, what it has been used for, and who has used it. To give a few

examples, this forensic evidence can take the form of operating system

configurations, artifacts from operating system or application operation, file system

data structures, and virtual memory "swap" or paging files. Computer users

typically do not erase or delete this evidence, because special software is typically

required for that task. However, it is technically possible to delete this information.

d. Similarly, files that have been viewed via the Internet are sometimes automatically

downloaded into a temporary Internet directory or "cache."

67. Forensic evidence. As further described in Attachment B, this application seeks

permission to locate not only computer files that might serve as direct evidence of the crimes

described on the warrant, but also for forensic electronic evidence that establishes how computers

were used, the purpose of their use, who used them, and when. There is probable cause to believe

that this forensic electronic evidence will be on the Subject Devices because:

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a. Data on the storage medium can provide evidence of a file that was once on the

storage medium but has since been deleted or edited, or of a deleted portion of a

file (such as a paragraph that has been deleted from a word processing file) . Virtual

memory paging systems can leave traces of information on the storage medium that

show what tasks and processes were recently active. Web browsers, e-mail

programs, and chat programs store configuration information on the storage

medium that can reveal information such as online nicknames and passwords.

Operating systems can record additional information, such as the attachment of

peripherals, the attachment of USB flash storage devices or other external storage

media, and the times the computer was in use. Computer file systems can record

information about the dates files were created and the sequence in which they were

created, although this information can later be falsified.

b. As explained herein, information stored within a computer and other electronic

storage media may provide crucial evidence of the "who, what, why, when, where,

and how" of the criminal conduct under investigation, thus enabling the United

States to establish and prove each element or alternatively, to exclude the innocent ·

from further suspicion. In my training and experience, information stored within a

computer or storage media (e.g., registry information, communications, images and

movies, transactional information, records of session times and durations, internet

history, and anti-virus, spyware, and malware detection programs) can indicate who

has used or controlled the computer or storage media. This "user attribution"

evidence is analogous to the search for " indicia of occupancy" while executing a

search warrant at a residence. The existence or absence of anti-virus, spyware, and

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Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 42 of 48

malware detection programs may indicate whether the computer was remotely

accessed, thus inculpating or exculpating the computer owner. Further, computer

and storage media activity can indicate how and when the computer or storage

media was accessed or used. For example, as described herein, computers typically

contains information that log: computer user account session times and durations,

computer activity associated with user accounts, electronic storage media that

connected with the computer, and the IP addresses through which the computer

accessed networks and the internet. Such information allows investigators to

understand the chronological context of computer or electronic storage media

access, use, and events relating to the crime under investigation. Additionally,

some information stored within a computer or electronic storage media may provide

crucial evidence relating to the physical location of other evidence and the suspect.

For example, images stored on a computer may both show a particular location and

have geolocation information incorporated into its file data. Such file data typically

also contains information indicating when the file or image was created. The

existence of such image files, along with external device connection logs, may also

indicate the presence of additional electronic storage media ( e.g., a thumb drive).

The geographic and timeline information described herein may either inculpate or

exculpate the computer user. Last, information stored within a computer may

provide relevant insight into the computer user's state of mind as it relates to the

offense under investigation. For example, information within the computer may

indicate the owner's motive and intent to commit a crime (e.g., internet searches

indicating criminal planning), or consciousness of guilt (e.g., running a "wiping"

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Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 43 of 48

program to destroy evidence on the computer or password protecting/encrypting

such evidence in an effort to conceal it from law enforcement).

c. A person with appropriate familiarity with how a computer works can, after

examining this forensic evidence in its proper context, draw conclusions about how

computers were used, the purpose of their use, who used them, and when.

d. The process of identifying the exact files, blocks, registry entries, logs, or other

forms of forensic evidence on a storage medium that are necessary to draw an

accurate conclusion is a dynamic process. While it is possible to specify in advance

the records to be sought, computer evidence is not always data that can be merely

reviewed by a review team and passed along to investigators. Whether data stored

on a computer is evidence may depend on other information stored on the computer

and the application of knowledge about how a computer behaves. Therefore,

contextual information necessary to understand other evidence also falls within the

scope of the warrant.

e. Further, in finding evidence of how a computer was used, the purpose of its use,

who used it, and when, sometimes it is necessary to establish that a particular thing

is not present on a storage medium. For example, the presence or absence of

counter-forensic programs or anti-virus programs (and associated data) may be

relevant to establishing the user's intent.

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FILTER REVIEW PROCEDURES

Review of the items described in Attachment B will be conducted pursuant to established

procedures designed to collect evidence in a manner consistent with professional responsibility

requirements concerning the maintenance of attorney-client and other operative privileges. The

procedures include use of a designated "filter team," separate and apart from the investigative

team, in order to address potential privileges.

CONCLUSION

68. Based on the foregoing, your affiant respectfully requests that this Court issue a

search warrant for the Subject Devices, more particularly described in Attachment A authorizing

the seizure of the items described in Attachment B.

Respectfully submitted,

~ ~ d e, 4 . / ~
Special Agent
Federal Bureau of Investigation

Sworn and subscribed before me on this / J ~ ay of February, 2019.

The Honorable Beryl A. Howell


Chief United States District Judge

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Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 45 of 48

ATIACHMENTA

Property to be Searched

The following devices provided to the FBI by , currently in the District of

Columbia:

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Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 46 of 48

ATTACHMENT B

Items to be seized from the Subject Devices

1. The items to be seized are fruits, evidence, information relating to, contraband, or

instrumentalities of violations Title 18, United States Code, Section 1505 (obstruction of

proceeding); (ii) Title 18, United States Code, Section I 00 I (false statements); and (iii) Title 18,

United States Code 1512(b)(l) (witness tampering), those violations involving Roger Stone, for

the time period June 2015 to the present, including:

a. Documents and communications that discuss or are related to WikiLeaks, Julian

Assange, and/or Russian interference in the 2016 U.S . presidential election;

b. Documents reflecting communications between Stone and Jerome Corsi;

c. Documents reflecting communications between Stone and Randy Credico;

d. Documents reflecting communications between Stone and members of the Trump

Campaign or Trump Campaign associates, including Steve Bannon,

Paul Manafort, Richard Gates, and Donald J. Trump;

e. Documents related to or discussing the U.S. House of Representatives Permanent

Select Committee on Intelligence, the Senate Select Committee on Intelligence, or

the Federal Bureau of Investigation;

f. Records and information relating to the e-mail accounts

and p

g. Records and information relating to the WhatsApp account associated with

telephone number ;

Page 39 of 41
Case 1:19-mc-00029-CRC Document 29-31 Filed 04/28/20 Page 47 of 48

h. Records and information relating to the Signal account associated with telephone

numbe

1. Records and information relating to the Wickr account associated with telephone

numbe

J. Any computers, media storage devices, tablets/iPads, cellular telephones,

smartphones, personal data assistant devices, or other electronic devices used to

commit the violations described above or to store records or documents described

above;

k. Records of personal and business activities relating to the operation and ownership

of the computer systems, such as telephone records, notes, notebooks, diaries, and

reference materials, in whatever form ;

I. Records pertaining to accounts held with Internet Service Providers or of Internet

use, in whatever form ;

2. For all of the devices listed in Attachment A (hereinafter, "COMPUTER"):

a. evidence of who used, owned, or controlled the COMPUTER at the time the things

described in this warrant were created, edited, or deleted, such as logs, registry

entries, configuration files, saved usernames and passwords, documents, browsing

history, user profiles, email, email contacts, "chat," instant messaging logs,

photographs, and correspondence;

b. evidence of software that would allow others to control the COMPUTER, such as

viruses, Trojan horses, and other forms of malicious software, as well as evidence

of the presence or absence of security software designed to detect malicious

software;

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c. evidence of the lack of such malicious software;

d. evidence indicating how and when the computer was accessed or used to determine

the chronological context of computer access, use, and events relating to crime

under investigation and to the computer user;

e. evidence indicating the computer user's state of mind as it relates to the crime under

investigation;

f. evidence of the attachment to the COMPUTER of other storage devices or similar

containers for electronic evidence;

g. evidence of counter-forensic programs (and associated data) that are designed to

eliminate data from the COMPUTER;

h. evidence of the times the COMPUTER was used;

1. passwords, encryption keys, and other access devices that may be necessary to

access the COMPUTER;

J. documentation and manuals that may be necessary to access the COMPUTER or

to conduct a forensic examination of the COMPUTER;

k. records of or information about Internet Protocol addresses used by the

COMPUTER;

l. records of or information about the COMPUTER's Internet activity, including

firewall logs, caches, browser history and cookies, "bookmarked" or "favorite"

web pages, search terms that the user entered into any Internet search engine, and

records of user-typed web addresses;

m. contextual information necessary to understand the evidence described in this

attachment.

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Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 1 of 56

AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the
Southern District of New York

In the Matter of the Search of


(Briefly describe the property to be searched
)
)
].~MAG847
or identify theperson by name and address) ) Case No.
)
the Premises Known and Described as
)
)

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer

An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of New York
(identify the person or describe the property to be searched and give its location):

See Attachment A

The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):

See Attachment A

The search and seizure are related to violation(s) of (insert statuto,y citations):

18 U.S.C. §§ 1001, 1505, 1512(b)(1)


I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property. ·
YOU ARE COMMANDED to execute this warrant on or before February 6, 2019
(not to exceed 14 days)
~ in the daytime 6:00 a.m. to 10 p.m. 0 at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the wmrnnt and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or l ei3-VC tpfcopy.a~d receipt at the
1

place where the property was taken. . . : , , · . 1 • '. . . • , · •


. . .
The officer executing this warrant, or an officer present during the exeeu.tion.o(the warrant, rfmst prepare an
invento;y as required by law and promptly return this warrant and inventory t.ci..· the .Cf~rk ofth~ Cou.rt. _A,1
./'Upon its return, this warrant and inventory sho11ld be filed under seal by the ;Clerk of the Court~'~ ...,_/·_::._-_-_-_:-_:--
&SM.f Initials

0 I find that immediate notification may have an adverse result listed in 18,HS·'.C. § 2705 (except :for delay
of trial), and authorize the officer executing this warrant to delay notice to the p'ers9ri \\'.hO,: or whose prop(;)rty, will be
searched or seized (check the appropriate box) Ofor days (not to exceed 30). · ' ' , ·
· I J I \

Ountil, the facts justifying, the later specific. •dat,e: of, ·, -------

Date and time issued: / -l-+l//Jo~·


'--1-"IIJ-' I '-1- - 19~L~·:
0/.~ /LA
~- a,1>-J,_ _ _ __~_-
__-_
- _
--
/ 7 Judge 's signature

City and state: New York, NY Hon. Robert W. Lehrburger


-----------
Printed name and title
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 2 of 56

AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of :

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 3 of 56

ATTACHMENT A

I. Premises to be Searched - Subject Premises

The premises to be searched (the "Subject Premises") are described as follows, and

include all locked and closed containers found therein:

The Subject Premises are particularly described as

II. Items to Be Seized

A. Evidence, Fruits, and Instrumentalities of the Subject Offenses

The items to be seized from the Subject Premises include the following evidence, fruits,

and instrumentalities of violations of (i) Title 18, United States Code, Section 1505 (obstruction

of proceedings before departments, agencies, and committees); (ii) Title 18, United States Code,

Section 1001 (false statements); and (iii) Title 18, United States Code, Section 1512(b)(l) (witness

tampering); (collectively the "Subject Offenses"), for the period June 2015 to the present,

described as follows:

a. Evidence concerning who occupies or owns the Subject Premises, including

without limitation, utility and telephone bills, mail envelopes, addressed

correspondence, diaries, statements, identification documents, address books,,

telephone directories, and keys;

b. Documents and communications that discuss or are related to WildLeaks, Julian

Assange, and/or Russian interference in the 2016 U.S. presidential election;

1
. '
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 4 of 56

c. Documents that reflect communications between Roger Stone and Jerome Corsi

that concern the Subject Offenses;

d. Documents reflecting communications between Roger Stone and Randy Credico

that concern the Subject Offenses;

e. Documents reflecting communications between Roger Stone and members of the

Trump Campaign or Trump Campaign associates, including Stephen K. Bannon,

Paul Manafort, Richard Gates, and Donald J. Trump, that concern the

Subject Offenses;

f. Documents related to or discussing investigations into Russian interference in the

2016 U.S. presidential election and related matters by the U.S. House of

Representatives Permanent Select Committee on Intelligence; the U.S. Senate

Select Committee on Intelligence; and/or the Federal Bureau oflnvestigation;

g. Records and information relating to the use, ownership, or control of e-mail

accounts ;

h. Records and information demonstrating who uses, owns, or controls the WhatsApp

account associated with telephone numbe ;

1. Records and information demonstrating who uses, owns, or controls the Signal

account associated with telephone number ;

J. Records and information demonstrating who uses, owns, or controls the Wickr

account associated with telephone numbe ;

k. Records pertaining to accounts held with Internet Service Providers providing

service at or to the Subject Premises;

2
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 5 of 56

1. Computers and media storage devices, including tablets/iPads, and records or

documents demonstrating who operates, owns, or controls such devices, such as

telephone records, notes, notebooks, diaries, and reference materials, in whatever

form; and

m. Cellular telephones, smartphones, or personal data assistant devices, and records or

documents demonstrating who operates, owns, or controls such devices, such as

telephone records, notes, notebooks, _diaries, and reference materials, in whatever

form.

B. Search and Seizure of Electronically Stored Information

The items to be seized from the Subject Premises also include any computer devices and
storage media that may contain any electronically stored information falling within the categories
set forth in Section II.A.a-le of this Attachment above, including, but not limited to, desktop and
laptop computers, disk drives, modems, thumb drives, personal digital assistants, smart phones,
digital cameras, and scanners. In lieu of seizing an such computer devices or storage media, this
warrant also authorizes the copying of such devices or media for later review.
The items to be seized from the Subject Premises also include:
1. Any items or records needed to access the data stored on any seized or copied
computer devices or storage media, including but not limited to any physical keys, encryption
devices, or records oflogin credentials, passwords, private encryption keys, or similar information.

2. Any items or records that may facilitate a forensic examination of the computer
devices or storage media, including any hardware or software manuals or other information
concerning the configuration of the seized or copied computer devices or storage media.

3. Any evidence concerning the identities or locations of those persons with access to,
control over, or ownership of the seized or copied computer devices or storage media.

C. Review of ESI

Following seizure of any computer devices and storage media and/or the creation of
forensic image copies, law enforcement personnel (who may include, in addition to law
enforcement officers and agents, attorneys for the government, attorney support staff, agency
personnel assisting the government in this investigation, and outside technical experts under
government control) are authorized to review the ESI contained therein for information
responsive to the warrant.

3
I P \. 'I
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 6 of 56

In conducting this review, law enforcement personnel may use various techniques to
locate information responsive to the warrant, including, for example:
• surveying various file "directories" and the individual files they contain (analogous to
looldng at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);

• opening or cursorily reading the first few "pages" of such files in order to determine
their precise contents;

• scanning storage areas to discover and possibly recover recently deleted files or
.deliberately hidden files;

• performing key word searches through all electronic storage areas to determine whether
occuITences oflanguage contained in such storage areas exist that are intimately related
to the subject matter of the investigation; and

• reviewing metadata, system inf01mation, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.

Law enforcement personnel will make reasonable effo1is to search only for files,
documents, or other electronically stored information within the categories identified in Sections
II.A.a-k and II.B of this Attachment. However, law enforcement personnel are authorized to
conduct a complete review of all the ESI from seized devices or storage media if necessary to
evaluate its contents and to locate all data responsive to the warrant.

4
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 7 of 56

AO 106 (SDNY Rev. 01/17) Application for a Search Warrant

UNITED STATES DISTRICT COURT


for the
Southern District of New York

In the Matter of the Search of


(Briefly describe the property to be searched
or identify the person by name and address)
)
)
) CaseNl 9 7
See Attachment A )
)
)

APPLICATION FOR A SEARCH AND SEIZURE WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):

the Premises Known and Described as


located in the --------
Southern District of New York
------------
, there is now concealed (identify the
person or describe the property to be seized):

See Attached Affidavit and its Attachment A

The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
~vidence of a crime;
0 contraband, fruits of crime, or other items illegally possessed;
~roperty designed for use, intended for use, or used in committing a crime;
0 a person to be· arrested or a person who is unlawfully restrained.

The search is related to a violation of:


Code Section(s) Offense Description(s)
18 U.S.C. §§ 1001, 1505, .False statements, witness tampering, obstruction of proceedings
1512(b)(1) before departments, agencies, and committees
The application is based on these facts:
See Attached Affidavit and its Attachment A

i'lf Continued on the attached sheet.


0 Delayed notice of
under I 8 U.S.C. § 3103a, the basis of which is set forth EZ.
days (give exact ending date if more than 30 days: ) is requested

~ C / } 1 f . 's., s/gl1ati~re
) '. ,( / '\ i 11:' '· ( '11 ''}

., '$A rylic~ei_
-------,,--.,, ) ! ,, .
J, 'Robi1?Js0h ~ - - - - - -
-\......--.---,

0
'· f JI!
Prinzed ,iame
'
and titleI J
,
' \ ' ' '
Sworn to before me and signed in my presence. , ;."'J
• I./;; I I '
. I' '

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*'~/\LY< /I ·,, ' ~ , )
Date: - - - - - ~ - ~ - ' , , ·~--.-;..,--'+'~ ·-'------
I .
' .. ' J~dge 's sig,!atuta '
.I I I ) j ' ·,\ '

City and state: New York, NY


-------------
_______H_o_·n~.·'1-~obert
+- yy. 'p&_h.,..,tb_8_r~g_er_ _~ - - -
Prihted,11'nne al,dtitle
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 8 of 56

IN THE UNITED STATES DISTRICT COURT


FOR THE SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------------------,
''
In the Matter of the Application of the United TO BE FILED UNDER SEAL
States Of America for a Search and Seizure
Warrant for the Premises Known and Described Agent Affidavit in Support of
a Application for Search and Seizure
Warrant

-----------J'

SOUTHERN DISTRICT OF NEW YORK:

Mickey J. Robinson, being duly sworn, deposes says:

I. Introduction

A. Affiant

1. I am a Special Agent (SA) of the Federal Bureau of Investigation (FBI) and have

been since September 2012. I successfully completed New Agent Training at Quantico, Virginia,

where I received extensive instruction on criminal investigations.

2. I make this affidavit in support of an application pursuant to Rule 41 of the Federal

Rules of Criminal Procedure for a warrant to search the premises specified below (the "Subject

Premises") for, and to seize, the items and informatiQn described in Attachment A. This affidavit

is based upon my personal knowledge; my review of documents and other evidence; my

conversations with other law enforcement personnel; and my training, experience and advice

received concerning the use of computers in criminal activity and the forensic analysis of

electronically stored information ("ESI"). Because this affidavit is being submitted for the limited

purpose of establishing probable cause, it does not include all the facts that I have learned during

the course of my investigation. Where the contents of documents and the actions, statements, and

conversations of others are reported herein, they are reported in substance and in part, except where

otherwise indicated.

1
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 9 of 56

B. The Subject Premises

3. The Subject Premises are particularly described as

C. The Subject Offenses

4. For the reasons detailed below, I believe that there is probable cause to believe that

the Subject Premises contain evidence, fmits, and instrumentalities of violations of (i) Title 18,

United States Code, Section 1505 (obstruction of proceedings before departments, agencies, and

committees); (ii) Title 18, United States Code, Section 1001 (false statements); and (iii) Title 18,

United States Code, Section l 512(b)(1) (witness tampering); (collectively the "Subject Offenses").

II. Probable Cause

A. Probable Cause Regarding Commission of the Subject Offenses

5. I have personally participated in this investigation and am aware of the facts

contained herein based on my own investigation, as well as my review of documents, records, and

information provided to me by other law enforcement officers and technical experts.

6. This affidavit is intended to show merely that there is sufficient probable cause for

the requested warrant and does not set forth all of my knowledge about this matter. Unless

specifically indicated, all conversations and statements in this affidavit are related in substance

and part. Where I asse1i that an event took place on a particular date, I am asserting that it took

place on or about the date specified.

2
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 10 of 56

7. For the reasons set forth in this Affidavit, there is probable cause to believe that one

or more of the Subject Offenses have been committed by Roger Jason Stone, Jr., ("Roger Stone")

and others known and unknown to the government. Further, there is probable cause to believe the

Subject Premises have been used to facilitate the commission of one or more of the Subject

Offenses. Moreover, there is probable cause to believe that evidence, contraband, fruits, and

instrumentalities of violations of the Subject Offenses may be present in the Subject Premises.

Background on Relevant Individuals

8. Based on publicly available information and information obtained m the

investigation, I know the following:

a. Roger Stone is a political consultant who has worked for decades in U.S. politics

and on U.S. political campaigns. Stone was an official on the U.S. presidential

campaign of Donald J. Trump ("Trump Campaign") until in or around August

2015, and subsequently maintained regular contact with and publicly supported the

Trump Campaign through the 2016 election.

b. Julian Assange is the founder and director of 'YikiLeaks, which is publicly

described as a non-profit organization that disseminates non-public information and

classified media provided by anonymized sources. WikiLeaks has posted numerous

documents stolen from the U.S. government. At all relevant times, Assange was

located at the Ecuadorian Embassy in London, United Kingdom.

c. Jerome Corsi is a political commentator who worked with an online media

publication during the 2016 U.S. presidential campaign. As set forth below, Corsi

spoke regularly with Stone throughout the campaign, including about the release of

stolen documents by WikiLeaks.

3
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 11 of 56

e. ,Randy Credico was a radio host who has lmown Stone for more than a decade. In

testimony before U.S. House of Representatives Permanent Select Committee on

Intelligence ("HPSCI") on or about September 26, 2017, Stone described Credico

(without naming him) as an "intermediary," "go-between," and "mutual friend" to

Assange. In a follow-up letter to HPSCI dated October 13, 2017, Stone identified

Credico by name and claimed Credico was the "gentleman who confirmed for Mr.

Stone" that Assange, had "' [e] mails related to Hillary Clinton which are pending

publication.'"

f. Richard Gates is a U.S. citizen who served for years as a political consultant and

lobbyist along with Paul Manafort. From in or around June 2016 until November

2016, Gates served as the deputy campaign chairman of the Trump Campaign. On

February 23, 2018, Gates pled guilty to one count of conspiracy against the United

States and one count of making false statements to federal law enforcement officers.

United States v. Gates, l: 17-cr-201 (D.D.C.).

g. Stephen K. Bannon is a U.S. citizen who serves as a political consultant. Beginning

in or around August 2016 and through the 2016 U.S. presidential election, Bannon

served as the chief executive officer of the Trump Campaign.

4
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 12 of 56

Hacking Activity During the 2016 Presidential Election

9. John Podesta is a U.S. citizen who served for years as a political consultant. During

the 2016 U.S. presidential campaign, Podesta served as the campaign chairman of the Hillary

Clinton presidential campaign ("Clinton Campaign"). On or about March 24, 2016, Podesta

received a spearphishing 1 email designed to appear as a security notification (a partial copy of the

email was recovered by the FBI from a subsequent release of stolen emails, described below).

During an interview with the FBI in or around May 2018, Podesta indicated that after receiving

the email, his assistant (who also had access to the account) clicked on a link within the email and

entered the account password when prompted (believing this prompt to be part of a security

protocol). Based on my training and experience, this activity appears to have been a successful

spearphishing operation through which an actor would have gained access to Podesta' s email

account allowing the actor to steal emails and documents from that account.

10. The Democratic National Committee ("DNC") and Democratic Congressional

Campaign Committee ("DCCC") are U.S. political committees focusing on U.S. federal elections.

Both the DNC and DCCC were involved in the 2016 U.S. federal elections, including the 2016

U.S. presidential election. According to DNC and DCCC individuals interviewed by the Special

Counsel's Office, in or around the spring of 2016, the DNC and DCCC became aware that their

computer systems had been compromised by unauthorized intrusions and hired the cybersecurity ·

company CrowdStrike to investigate the intrusions and remediate.

1
In my training and experience, spearphishing in this context refers to the fraudulent practice of
sending an email that purports to be from a known ot trusted sender in order to induce the
targeted victim to respond in a desired manner, typically by clicldng a malicious link or URL.

5
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 13 of 56

11. On or about June 14, 2016, CrowdStrike issued a public press release announcing

that the DNC's computer network had been compromised. In the public statement, CrowdStrike

indicated that it had identified "two sophisticated adversaries on the network," which it referred to

by the monikers COZY BEAR and FANCY BEAR. CrowdStrike stated that it had previously

seen these actors target other customers and that, based on their experience, "[bJoth adversaries

engage in extensive political and economic espionage for the benefit of the government of the

Russian Federation and are believed to be closely linked to the Russian government's powerful

and highly capable intelligence services."

12. On or about July 13, 2018, a federal grand jury sitting in the District of Columbia

returned an indictment against eleven Russian nationals, charging them with partaking in a

conspiracy to hack into, among other things, the email account of John Podesta, as well as the

DNC and DCCC computer networks. United States v. Viktor Borisovich Netyksho, l:18-cr-215

(D.D.C.). The indictment alleges that all of these individuals were military officers serving in the

Main Intelligence Directorate of the General Staff ("GRU"), the Russian Federation's military

intelligence agency.

WikiLeaks' Release of Stolen Documents During the 2016 Presidential Campaign

13. As alleged in the Netyksho indictment, after successfully hacking the DNC and

DCCC networks, as well as Podesta' s email account, GRU officers transmitted some of the stolen

documents to WikiLeaks. GRU officers communicated with WikiLeaks members about the

transfers using online personas created by the GRU, including "Guccifer 2.0" and "DCLeaks."

(GRU officers separately used these personas to release some of the stolen documents).

14. On or about July 22, 2016, WildLeaks released tens of thousands of documents

stolen from the DNC network. These stolen documents included communications by senior DNC

6
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 14 of 56

officials about campaign strategy, financial and fundraising data, and other documents related to

the 2016 U.S. federal elections, including the 2016 U.S. presidential election.

15. Beginning in or around October 2016, WikiLeaks began to release tens of

thousands of emails and documents stolen from Podesta's email account. Between on or about

October 7, 2016 and November 7, 2016, WikiLeaks released approximately 33 tranches of

documents that had been stolen from. John Podesta, releasing a total of over 50,000 stolen

documents.

Stone's Communications About WikiLeaks During the Campaign


f

16. In April 2018 interviews with the Special Counsel's Office, Gates stated that

starting in or around May 2016, when Gates was a senior official on the Trump campaign, Stone

informed members of the Trump Campaign that WikiLeaks had emails from then-candidate

Hillary Clinton. According to Gates, after the July 22, 2016 release of stolen DNC emails by

WildLeaks, Gates observed a conversation between Manafort and Stone, in which they discussed

WikiLeaks and Stone's prediction of the release.

17. According to Gates, Manafort directed Gates to contact Stone about any additional

releases and what other information WikiLeaks had regarding the Clinton Campaign. Gates

contacted Stone, who made statements claiming that there would be potential future releases of

damaging material by WikiLeaks. In a separate interview with the Special Counsel's Office in or

around October 2018, Gates recalled that at one point during the campaign he was with then-

candidate Trump in a car when the candidate had a telephone call with Stone; shortly after finishing

the call with Stone, Gates recalled then-candidate Trump said more leaks were coming.

7
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 15 of 56

18. Emails recovered through a court-authorized search of Stone's email account

2
show that shortly after the July 22, 2016 releas~ of stolen DNC emails

by WikiLeak:s, Stone coffesponded with other associates about contacting WikiLeaks in order to

obtain other emails damaging to the Clinton Campaign:

a. On or about July 25, 20~6, Stone sent an email to Jerome Corsi with the subject

line, "Get to Assange." The body of the message read, "Get to Assange [a]t

Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they

deal with Foundation, allegedly." On or about the same day, Corsi forwarded

Stone's email to who lived in the United Kingdom and was a supporter of

the Trump Campaign.

b. On or about July 31, 2016, Stone emailed Corsi with the subject line, "Call me

MON." The body of the email read in part that "should see Assange."

c. On or about August 2, 2016, Corsi emailed Stone and wrote that he was cuffently

in Europe and planned to retum in mid-August. Corsi stated, "Word is friend in

embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct. Impact

planned to be very damaging." In a law enforcement interview, Corsi stated that

the phrase "friend in embassy" refeffed to Assange. Corsi added in the same email,

"Time to let more than Podesta to be exposed as in bed w enemy if they are not

2
A search of was authorized on or about September 11, 2017 by the U.S.
District Cour umbia. Case No. 1:l 7-mj-661 (D.D.C. Sept. 11, 2017). A
second search o was authorized on or about August 3, 2018 by the U.S.
District Court fo a. Case No. 1:18-sc-2582 (D.D.C. Aug. 3, 2018). On or
about September 26, 2018, the government obtained and executed an order pursuant to 18 U.S.C.
§ 27 03 (d) for records connected to Case No. 1:18-sc-2911 (D .D. C. Sept.
26, 2018). Records provided in r rporation confirmed that the account
was still active and that the relevant emails described in this affidavit were not deleted from the
account.

8
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 16 of 56

ready to drop HRC. That appears to be the game hackers are now about. Would

not hurt to start suggesting HRC old, memory bad, has stroke - neither he nor she

well. I expect that much of next dump focus, setting stage for Foundation debacle."

19. According to recorded public statements recovered by the FBI, starting in early

August 2016, after receiving this August 2, 2016 email from Corsi, Stone made repeated

statements about information he claimed to have learned from Assange:

a. According to a public video posted to YouTube, on or about August 8, 2016, Stone

attended a public event in Broward County, Florida. During the event, Stone stated,

"I actually have communicated with Assange. I believe the next tranche of his

documents pertain to the Clinton Foundation, but there's no telling what the

October surprise may be."

b. According to a public video posted to YouTube, on or about August 12, 2016, Stone

was interviewed for a video segment on the show Info Wars, hosted by Alex Jones.

During the interview, Stone stated that he was "in communication with Assange"

but was "not at liberty to discuss what I have."

c. According to a public video posted to YouTube, on or about August 16, 2016, Stone

stated during another interview with Alex Jones that "it became known on this

program that I have had some back-channel communication with WikiLeaks and

Assange." In a second interview on or about the same day with Dana Loesch of

the TheBlaze TV, Stone stated that he "communicated with Mr. Assange" and that

they had a "mutual acquaintance who is a fine gentleman."

d. According to a video posted to the public website of the TV station C-SPAN, during

a C-SPAN teleyision interview on or about August 18, 2016, Stone stated that he

9
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 17 of 56

had communicated with Assange through an "intermediary, somebody who is a

mutual friend."

e. In or around late 2018, Credico voluntarily produced to the FBI a copy of a radio

interview he did with Stone on or about August 23, 2016 during which the two

discussed Stone's prior claims to be in contact with Assange. At one point during

the interview, Credico asked Stone, "You've been in touch indirectly with Assange.

Can you give us any kind of insight? Is there an October surprise happening?"

Stone responded, "Well, first of all, I don't want to intimate in any way that I control

or have influence with Assange because I do not. . . . We have a mutual friend,

somebody we both trust and therefore I am a recipient of pretty good information."

20. In or around November 2018 , Stone

produced a series of text messages between Stone and Credico during the 2016 presidential

campaign. 3 These text messages show that beginning on or about August 19, 2016, Stone

exchanged written communications with Credico about what WikiLeak~ and Assange planned to

do. Emails recovered through a court-authorized search of Stone's email account

show additional written communications between Stone and Credico

about WikiLeaks in or around September 2016.

a. On or about August 19, 2016, Credico sent a text message to Stone that read in part,

"I'm going to have Julian Assange on my show next Thursday." On or about

August 21, 2016, Credico sent another text message to Stone, writing in part, "I

have Julian Assange on Thursday so I'm completely tied up on that day."

3
As discussed below, Stone had previously released some of these text messages to members of
the media, who had written about them and published them in part.

10
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 18 of 56

b. On or about August 25, 2016, Assange was a guest on Credico's radio show for the

first time. On or about August 26, 2016, Credico sent a text message to Stone that

stated, "Julian Assange talk[ed] about you last night." Stone replied and asked what

Assange said, to which Credico responded, "He didn't say anything bad we were

talking about how the Press is trying to make it look like you and he are in cahoots."

c. On or about August 27, 2016, Credico sent text messages to Stone that said, "We

are working on a Julian Assange radio show," and that he (Credico) was "in charge"

of the project. In a text message sent later that day, Credico added, "Julian Assange

has kryptonite on Hillary."

d. On or about September 18, 2016, Stone sent a text message to Credico that said, "I

am e-mailing u a request to pass on to assange." Credico responded "Ok," and

added in a later text message, "Just remember do not name me as your connection

to Assange you had one before that you referred to."

e. Later on or about September 18, 2016, Stone emailed Credico an article with

allegations against then-candidate Clinton related to her service as Secretary of

State. Stone stated, "Please ask Assange for any State or HRC e-mail from August

10 to August 30 -- particularly on August 20, 2011 that mention [the subject of the

article] or confinn this narrative."

f. On or about September 19, 2016, Stone texted Credico again, writing, "Pass my

message ... to Assange." Credico responded, "I did." On or about September 20,

2016, Credico forwarded the request to a close friend who was an attorney with the

ability to contact the Assange. Credico blind-copied Stone on the forwarded email.

11
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 19 of 56

g. On or about September 30, 2016, Credico sent Stone via text message a photograph

of Credico standing outside the Ecuadorian Embassy in London where Assange

was located.

h. On or about October 1, 2016, which was a Saturday, Credico sent Stone text

messages that stated, "big news Wednesday ... now pretend u don't know me ...

Hillary's campaign will die this week." In the days preceding these messages, the

press had reported that Assange planned to make a public announcement on or

about Tuesday, October 4, 2016, which was rep01ied to be the 10-year anniversary

of the founding ofWikiLeaks.

1. On or about October 2, 2016, Stone emailed Credico, with the subject line "WTF?"

and a link to an article at the website http://heatst.com/politics/october-surprise-

thwarted-wikileaks-cancels-highly-anticipated-tuesday-announcement-due-to-

security-concerns. Credico responded to Stone, "head fake."

J. On or about Monday, October 3, 2016, Stone wrote Credico and asked, "Did

Assange back off." Credico initially responded, "I can't tal[k] about it." After

further exchanges with Stone, Credico responded, "I think it['Js on for tomorrow."

Credico added, "Off the Record Hillary and her people are doing a full-court press

they [sic] keep Assange from making the next dump ... That's all I can tell you on

this line ... Please leave my name out of it."

21. Emails and text messages recovered by the FBI show that, in or around October

2016, Stone made statements about Assange's future releases, including statements that were

similar to statement that Credico made to him. For example:

12
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 20 of 56

a. In a court-authorized search of Stone's email accoun the

FBI recovered an email from Stone t sent on or about October 3, 2016,

which stated in part, "Spoke to my friend in London last night. The payload is still

coming."

b. In a comi-authorized search o , the FBI also recovered an

email exchange from on or about October 3, 2016 between Stone and a reporter

who had connections to Steve Bannon. In the exchange, the reporter asked,

"Assange - what's he got? Hope it's good." Stone responded, "It is. I'd tell

Bannon but he doesn't call me back."

c. On or about October 4, 2016, Assange held a press conference but did not release

any new materials pertaining to the Clinton Campaign. In a court-authorized search

o the FBI recovered an email exchange between Stone and

Bannon on or about October 4, 2016 that occurred after the press conference. In

the exchange, Bannon asked, "What was that this morning???," referring to

Assange's press conference. Stone responded, "Fear. Serious security concern. He

thinks they are going to kill him and the London police are standing do[wn].

However - a load every week going forward."

d. In a court-authorized search of Stone's iCloud account, 5 the FBI recovered text

messages between Stone and from on or about October 4, 2016. In one text

4
A search of was authorized on or about October 17, 2017 by the U.S.
District Court umbia. Case No. l:17-mj-760 (D.D.C. Oct. 17, 2017). A
second search of was authorized on or about August 3, 2018 by the U.S.
District Court for the District of Columbia. Case No. 1:18-sc-2583 (D.D.C. Aug. 3, 2018).
5
A search of Stone's iCloud account was authorized on or about March 14, 2018 by the U.S.
District Comi for the District of Columbia. Case No. l:18-sc-662 (D.D.C. Mar. 14, 2018). · The

13
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 21 of 56

message, asked Stone if he had "hear[d] anymore from London." Stone

replied, "Yes -want to talk on a secure line- got Whatsapp." In an interview with

the Special Counsel's Office in or around May 2018, confirmed that he and

Stone spoke and that Stone had told him WikiLeaks had more material to release,

and that the material was related to senior people associated with Clinton.

22. On or about October 7, 2016, WikiLeaks released the first set of emails stolen from

Podesta. According to text messages recovered from Stone's iCloud account, shortly after the

release, an associate of Bannon sent a text message to Stone that read, "well done." Similarly,

during an April 2018 interview, Gates recalled that after the October 7, 2016 WikiLeaks release,

Stone said, "I told you this was coming."

Stone's Communications with the House Permanent Select Committee on Intelligence

23. On or about January 25, 2017, HPSCI publicly disclosed that it was investigating

allegations of Russian interference in the 2016 presidential election and possible links to

individuals associated with political campaigns. 6 During a public HP SCI hearing on or about

March 20, 2017, multiple HPSCI committee members indicated that Stone's prior public

statements about having communications with Assange (paiiicularly those from August 2016)

were of interest to the committee.

records for Stone's iCloud account contained some, but not all, of Stone's communications from
the campaign period.
6
On or about January 13, 2017, the chairman and vice chairman of the Senate Select Committee
on Intelligence ("SSCI") announced the committee would conduct an inquiry that would
investigate, among other things, any intelligence regarding links between Russia and individuals
associated with political campaigns, as well as Russian cyber activity and other "active
measures" directed against the United States in connection with the 2016 election.

14
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 22 of 56

24. In or around May 2017, HP SCI ~ent a letter requesting that Stone voluntarily appear

before the committee and produce relevant documents to HP SCI (a copy of the HPSCI letter was

recovered by the FBI from a court-authorized search of Stone's email account

). The letter requested Stone produce:

Any documents, records, electronically stored information


including e-mail, communication, recordings, data and tangible
things (including, but not limited to, graphs, charts, photographs,
images and other documents) regardless of form, other than those
widely available (e.g., newspaper articles) that reasonably could
lead to the discovery of any facts within the investigation's publicly-
announced parameters.

25. On or about May 22, 2017, counsel for Stone responded to HPSCI in writing and .

stated that "Mr. Stone has no documents, records, or electronically stored information, regardless

of form, other than those widely available that reasonably could lead to the discovery of any facts

within the investigation's publicly-announced parameters." (A copy of the letter was recovered

from a court-authorized search of Stone's email accoun ).

Stone's Testimony Before HPSCI

26. On or about September 26, 2017, Stone provided HPSCI with an "opening

statement" that his counsel requested be included as part of the record of proceedings before

HPSCI. In his opening statement, which HPSCI provided to the Department of Justice, 7 Stone

stated, "These hearings are largely based on a yet unproven allegation that the Russian state is

7
On or about December 14, 2018, the U.S. Depaiiment of Justice requested the transcript of
Stone's interview with HPSCI, as well as any written submissions and/or correspondence from
Stone and/or his counsel before or after the interview. On or about December 20, 2018, HPSCI
provided the U.S. Depaiiment of Justice a copy of the transcript of the September 26, 2017
interview of Roger Stone, a copy of Stone's written opening statement, and various
correspondence from Stone's counsel to members ofHPSCI.

15
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 23 of 56

responsible for the hacking of the DNC and John Podesta and the transfer of that information to

WikiLeaks."

27. Also on or about September 26, 2017, Stone provided testimony in a closed session

before HPSCI, at the U.S. Capitol in Washington, D.C. Stone's testimony was transcribed, and a

copy of the transcript was obtained by the Department of Justice from HPSCI in or around

December 2018. Stone appeared before HPSCI under oath and affirmed for the record that he

would tell the truth. At the beginning of the hearin~, Stone was admonished that "it is unlawful to

deliberately provide false information to Members of Congress or staff' and that "providing false

information to this committee or concealing material information from this committee is a crime

punishable by law."

Stone's Testimony About Documents He Possessed Related to WikiLeaks

28. During his HPSCI testimony, Stone was asked about HPSCI's May 2017 document

request and whether Stone had any documents or written communications that discussed Julian

Assange, Russian interference,_ or other relevant documents:

Q: The committee wrote to you on May 9th requesting no later


than May 22 any documents, records, electronically stored
information, including email communication, recordings,
data, and other tangible things relevant to our investigation.
You wrote back through counsel that you had no documents,
records, or electronically stored information regardless of
form responsive to our requests. Was that a false statement?

A: That is not a false statement. That's what -- I believe that to


be true.

[...]

Q: So you have no emails to anyone concerning the allegations


of hacked documents or your conversations with the
Guccifer 2[.0J or any discussions you have had with third
parties about Julian Assange? You have no emails, no texts,
no documents whatsoever, any kind of that nature?

16
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 24 of 56

A: That is correct. Not· to my knowledge. I think we met, again,


the precise criteria of your request, and we complied. Again,
if you have a more specific request, I'm happy to go back and
look. ...

Q: I just want to ask you under oath -

A: We did an extensive search consistent with the direction of


my attorneys, and we found nothing that met the criteria that
you asked for.

Q: I just want to be certain because you are under oath, where


your letter was not under oath, that you have no documents,
no emails, no texts, no tweets that refer to Julian Assange or
Guccifer 2[.0] or Paul Manafort or the allegations
concerning Russian connections with the campaign. You
have had no discussions in any written form. You've written
no documents yourself.

A: In connection with Russian collusion, consistent with your


exact and precise request, yes.

29. In fact, and as described above, Stone had sent and received numerous emails and

text messages during the 2016 campaign in which he discussed WildLeaks, Assange, and

WildLeaks possession of hacked emails. Court-authorized searches of Stone's email accounts

(including ) and his iCloud account show that,

at the time of his testimony, Stone was still in possession of many of these emails and text messages

at the time he testified on or about September 22, 2017. 8 These written communications included

(a) Stone's email to Corsi on or about July 25, 2016, that read in part, "Get to Assange [a]t

Ecuadorian Embassy in London and get the pending WildLeaks emails . . . they deal with

8
The warrant for Stone's email account was obtained on or about
September 11, 2017 and executed shortly thereafter. Records provided in or around September
2018 in response to acourtorderissued pursuant to 18 U.S.C. § 2703(d) confrrmed that the account
was active and the emails in question were not deleted from the account. The warrant for Stone's
email account was obtained on or about October 17, 2017 and executed
shortly thereaf tone's iCloud account (which contained the text messages
described above) was obtained on or about March 14, 2018 and executed shortly thereafter.

17
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 25 of 56

Foundation, allegedly."; (b) Stone's email to Corsi on or about July 31, 2016 that "should

see Assange"; (c) Corsi' s email to Stone on or about August 2, 2016 that stated in part, "Word is

friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct. Impact planned

to be very damaging."; (d) dozens of text messages and emails between Stone and Credico,

beginning on or about August 19, 2016 and continuing through duration of the election, in which

they discussed WikiLeaks and Assange; (e) Stone's email to on or about October 3, 2016

that read in part "Spoke to my friend in London last night. The payload is still coming."; and (f)

Stone's email to Bannon on or about October 4, 2016 that claimed WikiLeaks would release "a

load every week going forward."

Stone's TestimonyAbout His Early August 2016 Statements

30. During his HPSCI testimony on or about September 26, 2017, Stone was asked to

explain his statements in early August 2016 about being in contact with Assange. Stone was

specifically asked about his statement on or about August 8, 2016 that "I've actually

communicated with Assange," as well as his statement on or about August 12, 2016 that he was

"in communication with Assange" but was "not at libe1iy to discuss what I have."

31. Stone testified that these public references to having a means of contacting

WikiLeaks referred exclusively to his contact with a journalist, who Stone described as a "go-

between, as an intermediary, as a mutual friend" of Assange. Stone declined to tell HPSCI the

name of this "intermediary," but he provided a description in his testimony that was largely

consistent with Credico. (On or about October 13, 2017, Stone caused a letter to be submitted to

HPSCI that identified Credico by name as the "gentlem:an who confirmed for Mr. Stone" that

Assange had "'[e]mails related to Hillary Clinton which are pending publication."').

32. In fact, documents recovered during the investigation

18
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 26 of 56

a) show that Stone did not begin communicating

with Credico about Assange or WikiLeaks until on or about August 19, 2016 9-approximately

eleven days after Stone first claimed on or about August 8, 2016 to "actually have communicated

with Assange" and a week after to his August 12, 2016 statements of being "in communication

with Assange" and "not at liberty to discuss what I have."

33. When interviewed by the FBI, Credico stated that the first time he ever spoke with

°
Assange was on or about August 25, 2016, when ~redico interviewed Assange. 1 Credico also

provided the FBI with partially redacted emails that he claimed were between lie and another

member of WildLeaks from on or about August 25, 2016, in which the two discuss the technical

logistics for the interview later that day. During the exchange, Credico offered biographical

info1mation about himself, apparently as a means of introduction.

34. The FBI has not identified any communications between Stone and Credico from

August 2016 in which Stone directs Credico to contact Assange or WikiLeaks. When interviewed

by the FBI, Credico claimed he was never directed by Stone in August 2016 to contact WikiLeaks.

35. In contrast, and as described above, the FBI has identified written communications

prior to August 8, 2016 in which Stone directed Corsi-not Credico-to contact Assange. On or

about July 25, 2016, for example, Stone wrote to Corsi, "Get to Assange [a]t Ecuadorian Embassy

in London and get the pending WildLeaks emails ... they deal with Foundation, allegedly."

Similarly, on or about August 2, 2016, Corsi-not Credico-sent an email to Stone in which Corsi

9
As described above, on or about August 19, 2016, Credico informed Stone by text message that
Credico intended to interview Assange the following week. On or about August 25, 2016, Credico
interviewed Julian Assange for the first time, and on or about August 27, 2016, Credico texted
Stone that "Assange has kryptonite on Hillary."
°
1
Credico was first interviewed by the FBI in or around August 2018. He has subsequently
paiiicipated in multiple voluntary interviews.

19
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 27 of 56

wrote that "[w]ord is friend in embassy plans 2 more dumps," including one in October. These

communications occurred days before Stone's first public statement on or about August 8, 2016

claiming to be in communication with Assange. However, at no time did Stone identify Corsi to

HPSCI as another individual Stone contacted to serve as a "go-between," "intermediary," or other

source for information from WikiLeaks. Stone also.never disclosed his written communications

with Corsi to HPSCI when answering HPSCI's questioning about the August 8, 2016_ and August

12, 2016 statements about being in communication with Assange.

Stone 's Testimony About Communications to Assange

36. During his HPSCI testimony, Stone was asked, "Did you ask [the intermediary] to

communicate anything else to Assange?" Stone responded, "I did not." Stone was then asked,

"Did you ask [the intermediary] to do anything on your own behalf?" Stone responded, "I did

not."

37. In fact, starting on or.about September 18, 2016, Stone directed Credico to pass on

a request to Assange for documents that Stone believed would be damaging to the Clinton

Campaign.

a. According to text messages , on or about

September 18, 2016, Stone sent a text message to Credico that said, "I am e-mailing

u a request to pass on to Assange." On or about the same day, Stone emailed

Credico an article with allegations against then-candidate Clinton related to her

service as Secretary of State. Stone added, "Please ask Assange for any State or

HRC e-mail from August 10 to August 30 - particularly on August 20, 2011 that

mention [the subject of the article] or confirm this narrative." (A copy of this email

was obtained through a search of Stone's email account ).

20
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 28 of 56

b. According to text messages , on or about

September 19, 2016, Stone texted Credico again, writing "Pass my message ... to

Assange." Credico responded, "I did." An email obtained from the account

shows that on or about September 20, 2016, Credico

forwarded the request to an attorney who had the ability to contact Assange;

Credico blind copied Stone on the same email.

Stone's Testimony About Written Communications with Credico

38. During his HPSCI testimony, Stone was asked repeatedly about· his

communications with the person he identified as his intermediary. Stone stated that he had never

communicated with his intermediary in writing in any way. During one exchange, Stone claimed

only to have spoken with the intermediary telephonically:

Q: [H]ow did you communicate the intermediary?

A: Over the phone.

Q: And did you have any other means of communicating with


the intermediary?

A: No.

Q: No text messages, no-none of the list, right?

A: No.

Later during his testimony, Stone again denied ever communicating with his intermediary in

writing:

Q: So you never communicated with your intermediary in


writing in any way?

A: No.

Q: Never emailed him or texted him?

A: He's not an email guy.

21
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 29 of 56

Q: So all your conversations with him were in person or over


the phone.

A: Correct.

39. As described above, Stone and Credico (who Stone identified as his intermediary)

engaged in :frequent written communication by email and text message. Beginning on or about

August 19, 2016, and continuing through the 2016 U.S. presidential election, Stone and Credico

engaged in dozens of communications by email or text message in which they discussed

WikiLeaks and the possible release of stolen documents that would be damaging to the Clinton

Campaign.

40. Written communications between Stone and Credico continued up until Stone's

HPSCI testimony and afterwards. For example, on or about September 26, 2017-the day that

Stone testified before HP SCI and denied having ever sent or received emails or text messages :from

his identified intermediary, Stone and Credico exchanged over thirty text messages.

41. Certain of the electronic messages between Stone and Credico (which Stone denied

ever taking place or possessing) would have been material to HPSCI, including Stone's messages

in or a!ound September 2016 directing Credico to pass a request for documents to Assange, and

other relevant written communications with Credico. For example, on or about January 6, 2017,

Credico sent Stone an email, which Stone had in his possession at the time of his HP SCI testimony,

that had the subject line "Back channel bs." In the email, Credico wrote, "Well I have put together

timelines[] and you[] said you have a back-channel way back a month before I had Assange on

my show . . . I have never had a conversation with Julian Assange other than my radio show ... I

have pieced it all together ... so you may as well tell the truth that you had no back-channel or

there's the guy you were talking about early August." (A copy of this email was obtained through.

a search of Stone's email account .

22
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 30 of 56

Stone 's Testimony About Communications with the Trump Campaign

42. During his HPSCI testimony, Stone was asked, "[d]id you discuss your

conversations with the inteimediary with anyone involved in the Trump campaign?" Stone

answered, "I did not." As described above, Stone spoke to multiple individuals involved in the

Trump campaign about what he claimed to have learned from his intermediary to Assange,

including the following:

a. As described above, Gates confirmed to investigators that Stone spoke with senior

Trump Campaign officials to infmm them about materials possessed by Assange

and the timing of future releases.

b. , on or about October

3, 2016, Stone wrote to , "Spoke to my friend in London last night. The

payload is still coming."

c. As described above, on or about October 4, 2016, after receiving information from

Credi co about the delay in WikiLeaks' s release of stolen materials, Stone emailed

Bannon that Assange had a "[sJerious security concern" but would release "a load

every week going forward."

Stone's Attempts to Influence Credico RegardingHPSCI and the FBI

4 3. According to an email recovered through a court-authorized search of Stone's email

account on or about October 19, 2017, Stone sent Credico an excerpt of

his October 13, 2017 letter to HPSCI in which Stone claimed Credico was his "intermediary" to

Assange. As described below, Credico repeatedly told Stone that his letter was false and said he

should correct his statement to HP SCI, but Stone did not do so. Stone then engaged in a prolonged

effort to prevent Credico from contradicting Stone's false statements to HPSCI.

23
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 31 of 56

44. In or around November 2017, Credico received a request from HPSCI to testify

voluntarily before the committee. After being contacted by HPSCI, Credico spoke and texted

repeatedly with Stone.

a. On or about November 19, 2017, Credico texted Stone that his lawyer wanted to

see him. Stone responded, "' Stonewall it. Plead the fifth. Anything to save the

plan' ... Richard Nixon." (A copy of these text messages was recovered through

a court-authorized search of Stone's iCloud account). On or about November 20,

2017, Credico informed HPSCI that he declined HPSCI's request for a voluntary

interview.

b. On or about November 21, 2017, Credico texted Stone, "I was told that the house

committee lawyer told my lawyer that I will be getting a subpoena." Stone

responded, "That was the point at which your lawyers should have told them you

would assert your 5th Amendment rights if compelled to appear." (A copy of these

text messages was recovered through a court-authorized search of Stone's iCloud

account).

c. On or about November 28, 2017, ,Credico received a subpoena compelling his

testimony before HPSCI. Credico informed Stone of the subpoena.

d. According to emails recovered from Stone's email accoun

on or about November 30, 2017, Stone asked Corsi to write publicly about Credico.

Corsi responded, ''Are you sure you want to make something out of this now? Why

24
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 32 of 56

not wait to see what [Credico] does? You may be defending yourself too much-

raising new questions that will fuel new inquiries. This may be a time to say less,

not more." Stone responded by telling Corsi that Credico "will take the 5th-but

let's hold a day."

e. According to text messages recovered from Stone's iCloud account, on multiple

occasions, starting on or about November 17, 2017, Stone and Credico discussed

Frank Pentangeli. Frank Pentangeli is a character in the film The Godfather: Part

11, who falsely claims not to lmow critical information before a congressional

committee that he does in fact lmow. On or about December 1, 2017, Stone told

Credico in a text message to "Start practicing your Pentagele." When interviewed

by the FBI, Credico confirmed that he understood Stone's references to Frank

Pentangeli to be Stone's way of suggesting Credico withhold relevant information

from investigators.

f. On or about December 1, 2017, Stone texted Credico, "And if you turned over

anything to the FBI you're a fool." Later that day, Credico texted Stone, "You need

to amend your testimony before I testify on the 15th." Stone responded, "If you

testify you're a fool. Because of tromp I could never get away with a ce1iain [sic]

my Fifth Amendment rights but you can. I guarantee you you are the one who gets

indicted for perjury if you're stupid enough to testify." (A copy of these text

messages was recovered through a court-authorized search of Stone's iCloud

account).

45. On or about December 12, 2017, Credico informed HPS CI that he intended to assert

his Fifth Amendment privilege against self-incrimination if required to appear by subpoena.

25
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 33 of 56

According to Credico, he invoked his Fifth Amendment privilege in part to avoid providing

evidence that would show Stone's previous testimony to Congress was false.

46. Following Credico's invocation of his Fifth Amendment privilege not to testify

before HPSCI, Stone and Credico continued to have discussions about the various investigations

into Russian interference in the 2016 election and what information Credico would provide to

investigators. During these conversations, Stone repeatedly made statements intended to prevent

Credico from cooperating with the investigations. For example:

a. On or about December 24, 2017, Credico texted Stone, "I met assange for f[i]rst

time this yea[r] sept 7 ... docs prove that ... You should be honest w fbi . . .

there was no back channel ... be honest." Stone replied approximately two

minutes later, "I'm not talking to the FBI and if your smart you won't either." (A

copy of these text messages was recovered through a court-authorized search of


I

Stone's iCloud account).

b. On or about April 9, 2018, Stone wrote in an email to Credico, "You are a rat. A

stoolie. You backstab your friends-run your mouth my lawyers are dying Rip you

to shreds." Stone also said he would "take that dog away from you," referring to

Credico's dog. On or about the same day, Stone wrote to Credico, "I am so ready.

Let's get it on. Prepare to die [expletive]." (A copy ofthis email exchange was

recovered through a court-authorized search of Stone's email account

).

c. On or about May 21, 2018, Credico wrote in an email to Stone, "You should have

just been honest with the house Intel committee ... you've opened yourself up to

pe1jury charges like an idiot." Stone responded, "You are so full of [expletive].

26
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 34 of 56

You got nothing. Keep running your mouth and I'll file a bar complaint against

your friend [the attorney who had the ability to contact Assange]." (A copy of this

email exchange was recovered through a court-authorized search of Stone's email

accoun ). Credico believed Stone knew that Credico was

sensitive to having this friend's name publicly disclosed.

Missing Electronic Communications and Stone's Use of Encrypted Communications

47. As described above, the government has recovered the content of many of Stone's

electronic communications from summer and fall of 2016 (during the period of the U.S.

presidential election) and afterward (during the period of pending congressional investigations into

Russian interference in the U.S. election). However, the government is aware of the existence of

numerous other relevant electronic communications that it has not yet been able to recover the

content.

48. As described above, during his HPSCI testimony, Stone falsely denied having

emailed or exchanged text messages with his "intermediary" (later identified by Stone as Randy

Credico). In fact, emails and text messages recovered in this investigation show the two

communicated :frequently by email and text messages; court-authorized searches of Stone's email

and iCloud accounts confirm that Stone still had those communications at the time he testified in

or around September 2017. In numerous communications, Stone and Credico discussed Julian

Assange and WikiLeaks, as well as Stone's suggestion that Credico was his intermediary to

Assange. These communications appear relevant and responsive to HPSCI's inquiry, but Stone

never disclosed them.

49. In addition to these emails and text messages in the FBI's possession, the FBI has

reviewed telephone billing records for Stone's cellular telephone for the years 2016 and 2017 and

27
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 35 of 56

they show text message communications whose content that the government to date has not been

able to obtain. For example, these records indicate that Stone and Credico alone exchanged

thousands of text messages (including over 1,500 text messages between the period November

2016 and December 2017) the substance of which the government to date has not recovered or

reviewed. The government has only recently obtained text messages between Stone and Credico

during some period of the campaign in 2016 from Stone's subpoena production, issued after media

reports in November 2018 stated that Stone's attorneys were able to extract text messages between

Stone and Credico from a phone Stone stopped using in 2016. But the government does not have,
;

for the same time period, many of Stone's other text messages. The government seeks these text

messages believing they may show additional evidence of (1) the falsity of Stone's HPSCI

testimony concerning his communications with his "intermediary" and (2) efforts to corruptly

persuade Credico not to cooperate with pending investigations.

50. Additionally, the FBI has interviewed multiple associates of Stone, who confirmed

that Stone has used encrypted applications to communicate with others. Similarly, records

obtained in this investigation indicate Stone uses multiple applications designed for encrypted

28
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 36 of 56

communic~tion, including (a) WhatsApp, 11 (b) Signal, 12 ( c) Wickr, 13 and (d) ProtonMail. 14 To

date, the FBI has not obtained any of Stone's communications conducted through these

applications.

a. According to records from Stone's iCloud account, a copy of the WhatsApp

application was downloaded to an iPhone registered to Stone on or about October

5, 2016. As described above, on or about October 4, 2016, Stone suggested in an

email to that they "talk on a secure line" and proposed using WhatsApp.

b. According to records from Stone's iCloud account, a copy of the Signal application

was downloaded to an iPhone registered to Stone on or about August 18, 2016.

Additionally, text messages recovered from Stone's iCloud account revealed that

on or about November 15, 2016, Stone sent an attorney with the ability to contact

11
According to open sources, WhatsApp is an application that allows the user to send text
messages, make voice calls, and transmit documents. WhatsApp uses end-to-end encryption and
stores its messages separately from those text messages used on a mobile device's default message
application.
12
According to open sources, Signal is an encrypted communications application allowing the user
to send one-to-one and group messages, which can include files, voice notes, images and videos,
and make one-to-one voice and video calls. Signal uses standard cellular mobile numbers as
identifiers, and uses end-to-end encryption to secure all communications to other Signal users.
Signal also allows users to set timers to messages, after which the messages will be deleted from
both the sender's and the receivers' devices.
13
According to open sources, Wicla is an instant messaging application that allows users to
exchange end-to-end encrypted and content-expiring messages, including photos, videos, and file
attachments and place end-to-end encrypted video conference calls. Like Signal, Wickr allows
users to set an expiration time for their encrypted communications. In addition to encrypting user
data and conversations, Wickr claims that its application strips metadata from all content
transmi_tted through the network.
14
According to open sources, ProtonMail is an end-to-end encrypted email service that uses client-
side encryption to protect email contents and user data before they are sent to ProtonMail servers.
According to its website, ProtonMail is run by Proton Technologies AG, a company based in the
Canton of Geneva, and its servers are located at two locations in Switzerland, outside of US and
EU jurisdiction.

29
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 37 of 56

Julian Assange a link to download the Signal application. 15 Approximately fifteen

minutes after sending the link, Stone texted the attorney, "I'm on signal just dial

my number." The attorney responded, "I'll call you."

c. According to records from Stone's iCloud account, a copy of the ProtonMail

application was downloaded to an iPad registered to Stone on or about August 18,

2016.

d. According to records from Stone's iCloud account, a copy of the Wickr application

was downloaded to an iPhone registered to Stone on or about August 5, 2017.

51. Based on my training and experience, electronic communications using encrypted

applications such as WhatsApp, Signal, ProtonMail, and Wicla are sometimes maintained on the

device used to send and receive those communications. Communications from those applications

can be obtained by law enforcement by searching the device either manually or via a data

extraction device (such as Cellebrite). Searches of the physical device can reveal messages,

including text messages and messages exchanged over WhatsApp, Signal, ProtonMail, and Wicla,

that have not been backed up to cloud accounts (such as an iCloud account). Additionally, review

of the device and the downloaded application can reveal other evidence of encrypted

communications, such as call logs and contact lists.

52. The FBI continues to seek evidence of Stone's communications and contacts dming

the period of the 2016 U.S. presidential election and through the present. The FBI believes these

communications may contain evidence of additional communications concerning Assange,

WikiLeaks, and the release of stolen documents damaging to the Clinton Campaign. Such

15
This attorney was a close friend of Credico' s and was the same friend Credico emailed on or
about September 20, 2016 to pass along Stone's request to Assange for emails connected to the
allegations against then-candidate Clinton related to her service as Secretary of State.

·30
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 38 of 56

communications could constitute additional evidence of Stone's efforts to obstruct HPSCI's

investigation by showing additional contacts and communications about Assange and WikiLeaks

that Stone failed to disclose.

Other Relevant Communications

53. On May 8, 2018, a law enforcement interview o was

conducted. was an employee of Stone's from approximately June 2016 through

approximately December 2016 and resided in Stone's previous New York apartment for a period

of time. provided information technology support for Stone, but was not f01mally trained to

do so. was aware that Stone communicated with Trump during the 2016 presidential

campaign, and afterward, both in person and by telephone. provided information about c\.

meeting at Trump Tower between Trump and Stone during the time worked for him, to which

Sterne carried a "file booklet" with him. Stone tol the file booklet was important and that

no one should touch it. also said Stone maintained the file booklet in his closet.

54. On December 3, 2018, law enforcement conducted an interview of an individual

("Person 1") who previously had a professional relationship with a reporter who provided Person

1 with info1mation about Stone. The reporter relayed to Person 1 that in or around January and

February 2016, Stone and Trump were in constant communication and that Stone kept

contemporaneous notes of the conversations. Stone's purpose in keeping notes was to later provide

a "post mortem of what went wrong."

31
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 39 of 56

B. Probable Cause Justifying Search of the Subject Premises

55. Your affiant is aware through the investigation that Stone maintains the Subject

Premises as his secondary residence. 16 Associates of Stone's have confirmed that Stone maintains

the Subject Premises as his residence when he visits New York, New York. 17

56. Billing records provided by Charter Com.munications

determined that the subscriber of services at the Subject Premises i

In a law enforcement interview, stated he worked as Stone's assistant. The interview of

in addition to a review of public source records, determined lives in Florida.

Your affiant believes established the Charter Com.munications account at the Subject

Premises on behalf of Stone.

58. Stone participated in an on camera interview that was aired on or about November

2018 at the Subject Prem.ises 18 . Your affiant observed an Apple MacBook Pro computer and an

iMac in the Subject Premises in the interview. In the interview, Stone was observed departing the

apartment building that houses the Subject Premises.

16
Stone's primary residence is
17
Public real estate listing indicates the Subject Premises has been listed since December 5, 2018
and will become available for rent on February 1, 2019. A broker for the Subject Premises listing
stated it was not available for viewing until February 1, 2019 because it was still occupied by the
tenant.
18
https://www.washingtonpost.com./p~litics/2018/11/08/roger-stone-has-rule-deny-everything-
he-does/?utm. term=.5ab41ac5df22

32
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 40 of 56

59. A review of records produced by Uber Technologies, Inc.,

determined that on or about December 2018, the user of the account associated with

Stone's telephone number and email address used Uber services at addresses at or close to the

Subject Premises. Your affiant is aware that users of Uber's services do not always use their

precise address when arranging for transportation, and believes the addresses close to the Subject

Premises are consistent with an individual whose destination is the Subject Premises.

60. Based on law enforcement interviews, your affiant is aware that Stone has used and

uses cellular telephones, desktop, and laptop computers to conduct electronic communications.

Stone also configures his computers to create regulars backups of his computers and maintains one

of these devices at the Subject Premises, which preserves documents and communications.

61. In or around May 2018, the FBI interviewed an individual ("Person 2") who

provided information technology services to Stone. According to Person 2, Stone maintains at

least one Apple computer in each of his residences and also had an Apple MacBook Pro laptop

computer at one point in time. Person 2 revealed billing receipts

and invoices issued to Nydia Bertran-Stone for information technology ("IT") services dated

January 2015 through May 2018. The records also show that Nydia Bertran-Stone was billed for

IT services in connection with three different Apple computers. Specifically, the billing receipts

show services for (1) an Apple iMac (serial number D25SY03RGQ17) configured with the name

"Stone-Roger-iMac-FL"; (2) a second Apple iMac (serial number D25TC077GQ17) configured

with the name "Stone-Roger-iMac-NYC"; and (3) an Apple MacBookPro 10 (serial number

C02KL05EFFT4) configured with the name "Stone-Nydia-MBPR." According to publicly

available information, the iMac is one of Apple's desktop models (i.e., a computer designed to be

stationary). The naming convention of the computer "Stone-Roger-iMac-NYC" therefore

33
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 41 of 56

suggests it is a stationary computer used by Stone and located at the Subject Premises. 19 According

to the billing records, Person 2 was requested to perfo1m remote support services on or about

March 21, 2018 on the computer named "Stone-Roger-iMac-NYC."

62. In the aforementioned Washington Post interview of Stone, at least two electronic

devices are visible to the view, specifically an Apple iMac computer and a MacBook Pro laptop

computer.

63. Person 2 also told law enforcement that Stone used the Apple Time Machine

("Time Machine") application to facilitate backups of his computers and that he believed Stone

used Time Machine on computers in his residences. According to publicly available information,

Time Machine is the built-in backup feature of Apple computers and can create copies of files on

a computer, including applications, music, photos, email, documents, and system files. A Time

Machine backup allows users to restore files from a specific point in time if the original files are

ever deleted, or if the hard drive is erased or replaced. In order to create backups with Time

Machine, a user connects an external storage device to the computer and selects that external

storage device as the backup disk. 20

64. Records produced by AT&T show that, since

2016, Stone has had multiple Apple iPhone devices registered to his personal cellular telephone

number (ending in According to AT&T, as of January 1, 2015 through approximately

November 14, 2016, Stone's telephone number was registered to an Apple iPhone model 5s

19
According to multiple associates of Stone interviewed by the FBI, Stone maintains an office in
the Subject Residence and conducts most of his work from the office when he is in Florida.
20
When the external is plugged in, 'the Time Machine will automatically make hourly backups for
the past 24 hours, daily backups for the past month, and weekly backups for all previous months.
The oldest backups are deleted when the external storage device selected as the backup disk is full.
The external device can be as small as a USB thumb drive.

34
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 42 of 56

("iPhone 5s") (IMSI 310410657061814). On or about November 14, 2016, Stone's cellular

telephone number was transferred to an Apple iPhone model 7 ("iPhone T') (IMSI

310410930460769). On or about September 28, 2018, Stone's cellular telephone number was

transferred to an Apple iPhone model XS ("iPhone XS") (IMSI 310410155529814).

65. Records produced by Uber Technologies, Inc.,

show that the account associated with Stone's telephone number and email address has the Uber

~pplic_~ti(?ll on multiple d~vic~s~ including a_device ide1!-tified as iPha.nel 1/, UDID - 668EDC?6-

29BF-4AD2-8BCA-D974C7906597. Publicly available information indicates that the identifier

"iPhonell,2" con-elates to an Apple iPhone model XS. Additionally, the subpoena returns

identified a device identified as iPhone9,4, UDID - 716JCF59-6Fl0-41C8-984B-

DE08401EDA74. Publicly available information indicates that the identifier iPhone9,4 correlates

to an Apple iPhone model iPhone 7 Plus.

35
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 43 of 56

67. Statements attributed to Stone in recent media articles also indicate that Stone

retains computer devices that he no longer uses and keeps relevant electronic communications on

those devices. In or around November 2018, media repo1is began to publish excerpts of text

messages between Stone and Randy Credico that occuned during the 2016 U.S. election (copies
23
o_f these tex_t 11?-~s.s~ges su~sequ~11tly ~~re obtained from Sto!_l~ ).

According to these news articles, Stone released these messages to the media outlets, which Stone

claimed were extracted by his lawyers from "a cell phone he stopped using in 2016." Based on

these statements, your affiant believes the cellular telephone referenced in the article to be the

iPhone 5s documented in the aforementioned AT&T records (which records indicate he stopped

using on or about November 14, 2016).24 Further, your affiant believes Stone maintains other

devices he is no longer actively using.

C. Probable Cause Justifying Search of ESI


68. I submit that if a computer or storage medium is found on the Subject Premises,

there is probable cause to believe those records will be stored on that computer or storage medium,

for at least the following reasons:

23 See, e.g., "Bombshell Text Messages Support Roger Stone's Claims About WikiLeaks
Backchannel," Daily Caller, Nov. 14, 2018, available at https://dailycaller.com/2018/11/14/roger-
stone-wildleaks-randy-credico-mueller.
24 Stone produced some text messages between he and
Credico; the latest-in-time text message produced by Stone occuned on or about November 14,
201 6. The government believes copies of later-in-time text messages from late 2016 and early
2017 could be located on another device, such as the iPhone 7 described above, or on backup
storage media.

36
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 44 of 56

a. Based on my knowledge, training, and experience, I know that computer files or

remnants of such files can be recovered months or even years after they have been

downloaded onto a storage medium, deleted, or viewed via the Internet. Electronic

files downloaded to a storage medium can be stored for years at little or no cost.

Even when files have been deleted, they can be recovered months or years later

using forensic tools. This is so because when a person "deletes" a file on a

computer, the data contained in the file does not actually disappear; rather, that data

remains on the storage medium until it is overwritten by new data.

b. Therefore, deleted files, or remnants of deleted files, may reside in free space or

slack space-that is, in space on the storage medium that is not currently being used

by an active file-for long periods of time before they are overwritten. In addition,

a computer's operating system may also keep a record of deleted data in a "swap"

or "recovery" file.

c. Wholly apart from user-generated files, computer storage media-in particular,

computers' internal hard drives-contain electronic evidence of how a computer

has been used, what it has been used for, and who has used it. To give a few

examples, this forensic evidence can take the form of operating system

configurations, artifacts from operating system or application operation, file system

data structures, and viliual memory "swap" or paging files. Computer users

typically do not erase or delete this evidence, because special software is typically

required for that task. However, it is technically possible to delete this information.

d. Similarly, files that have been viewed via the Internet are sometimes automatically

downloaded into a temporary Internet directory or "cache."

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Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 45 of 56

69. As further described in Attachment A, this application seeks permission to locate

not only computer files that might serve as direct evidence of the crimes described on the warrant,

but also for forensic electronic evidence that establishes how computers were used, the purpose of

their use, who used them, and when. There is probable cause to believe that this forensic electronic

evidence will be on any storage medium in the Subject Premises because:

a. Data on the storage medium can provide evidence of a file that was once on the

storage medium but has since been deleted or edited, or. of a deleted portion of a

file (such as a paragraph that has been deleted from a word processing file). Virtual

memory paging systems can leave traces of information on the storage medium that

show what tasks and processes were recently active. Web browsers, e-mail

programs, and chat programs store configuration information on the storage

medium that can reveal inf01mation such as online nicknames and passwords.

Operating systems can record additional info1mation, such as the attachment of

peripherals, the attachment of USB flash storage devices or other external storage

media, and the times the computer was in use. Computer file systems can record

information about the dates files were created and the sequence in which they were

created, although this information can later be falsified.

b. As explained herein, info1mation stored within a computer and other electronic

storage media may provide crucial evidence of the "who, what, why, when, where,

and how" of the crilninal conduct under investigation, thus enabling the United

States to establish and prove each element or alternatively, to exclude the innocent

from further suspicion. In my training and experience, information stored within a

computer or storage media (e.g., registry information, communications, images and

38
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 46 of 56

movies, transactional information, records of session times and durations, internet

history, and anti-virus, spyware, and malware detection programs) can indicate who

has used or controlled the computer or storage media. This "user attribution"

evidence is analogous to the search for "indicia of occupancy" while executing a

search wanant at a residence. The existence or absence of anti-virus, spyware, and

malware detection programs may indicate whether the computer was remotely

accessed, thus inculpating or exculpating the computer owner. Further, computer

and storage media activity can indicate how and when the computer or storage

media was accessed or used. For example, as described herein, computers typically

contains infmmation that log: computer user account session times and durations,

computer activity associated with user accounts, electronic storage media that

connected with the computer, and the IP addresses through which the computer

accessed networks and the internet. Such information allows investigators to

understand the chronological context of computer or electronic storage media

access, use, and events relating to the crime under investigation. Additionally,

some information stored within a computer or electronic storage media may provide

crucial evidence relating to the physical location of other evidence and the suspect.

For example, images stored on a computer may both show a particular location and

have geolocation information incorporated into its file data. Such file data typically

also contains information indicating when the file or image was created. The

existence of such image files, along with external device connection logs, may also

indicate the presence of additional electronic storage media (e.g., a digital camera

or cellular phone with an incorporated camera). The geographic and timeline

39
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 47 of 56

information described herein may either inculpate or exculpate the computer user.

Last, information stored within a computer may provide relevant insight into the

computer user's state of mind as it relates to the offense under investigation. For

example, information within the computer may indicate the owner's motive and

intent to commit a crime (e.g., internet searches indicating criminal planning), or

consciousness of guilt (e.g., running a "wiping" program to destroy evidence on the

computer or password protecting/encrypting such evidence in an effort to conceal

it from law enforcement).

c. A person with appropriate familiarity with how a computer works can, after

examining this forensic evidence in its proper context, draw conclusions about how

computers were used, the purpose of their use, who used them, and when.

d. The process of identifying the exact files, blocks, registry entries, logs, or other

forms of forensic evidence on a storage medium that are necessary to draw an

accurate conclusion is a dynamic process. While it is possible to specify in advance

the records to be sought, computer evidence is not always data that can be merely

reviewed by a review team and passed along to investigators. Whether data stored

on a computer is evidence may depend on other inf01mation stored on the computer

and the application of knowledge about how a computer behaves. Therefore,

contextual information necessary to understand other evidence also falls within the

scope of the warrant.

e. Further, in finding evidence of how a computer was used, the purpose of its use,

who used it, and when, sometimes it is necessary to establish that a paiiicular thing·

is not present on a storage medium. For example, the presence or absence of

40
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 48 of 56

counter-forensic programs or anti-virus programs (and associated data) may be

relevant to establishing the user's intent.

III. Procedures for Searching ESI

A. Execution of Warrant for ESI

70. Federal Rule of Criminal Procedure 41(e)(2)(B) provides that a warrant to search

for and seize property "may authorize the seizure of electronic storage media or the seizure or

copying of electronically stored information ... for later review." Consistent with Rule 41, this

application requests authorization to seize any computer devices and storage media and transport

them to an appropriate law enforcement facility for review. This is typically necessary for a number

of reasons:

• First, the volume of data on computer devices and storage media is often impractical
for law enforcement personnel to review in its entirety at the search location.

• Second, because computer data is particularly vulnerable to inadvertent or intentional


modification or destruction, computer devices are ideally examined in a controlled
environment, such as a law enforcement laboratory, where trained personnel, using
specialized software, can make a forensic copy of the storage media that can be
subsequently reviewed in a manner that does not change the underlying data.

• Third, there are so many types of computer hardware and software in use today that it
can be impossible to bring to the search site all of the necessary technical manuals and
specialized personnel and equipment potentially required to safely access the
underlying computer data.

• Fourth, many factors can complicate and prolong recovery of data from a computer
device, including the increasingly common use of passwords, encryption, or other
features.or configurations designed to protect or conceal data on the computer, which
often take considerable time and resources for forensic personnel to detect and resolve.

71. In most cases, a thorough search of a premises for information that might be stored

on storage media often requires the seizure of the physical storage media and later off-site review

consistent with the warrant. In lieu of removing storage media from the premises, it is sometimes

possible to make an image copy of storage media. Generally speaking, imaging is the taking of a

41
'
(
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 49 of 56

complete electronic picture of the computer's data, including all hidden sectors and deleted files.

Either seizure or imaging is often necessary to ensure the accuracy and completeness of data

recorded on the storage media, and to prevent the loss of the data either from accidental or

intentional destruction. This is true because of the following:

a. The time required for an examination. As noted above, not all evidence takes the

form of documents and files that can be easily viewed on site. Analyzing evidence

of how a computer has been used, what it has been used for, and who has used it

requires considerable time, and taking that much time on premises could be

unreasonable. As explained above, because the warrant calls for forensic electronic

evidence, it is exceedingly likely that it will be necessary to thoroughly examine

storage media to obtain evidence. Storage media can store a large volume of

information. Reviewing that information for things described in the warrant can

take weeks or months, depending on the volume of data stored, and would be

impractical and invasive to attempt on-site.

b. Technical requirements. Computers can be configured in several different ways,

featuring a variety of different operating systems, application software, and

configurations. Therefore, searching them sometimes requires tools or knowledge

that might not be present on the search site. The vast array of computer hardware

and software available makes it difficult to know before a search what tools or

knowledge will be required to analyze the system and its data on the Premises.

However, taking the storage media off-site and reviewing it in a controlled

environment will allow its examination with the proper tools and lmowledge.

42
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Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 50 of 56

c. Variety of forms of electronic media. Records sought under this warrant could be

stored in a variety of storage media formats that may require off-site reviewing with

specialized forensic tools.

72. Because multiple people share the Subject Premises as a residence, it is possible

that the Subject Premises will contain storage media that are predominantly used, and perhaps

owned, by persons who are not suspected of a crime. If it is nonetheless determined that that it is

possible that the things described in this warrant could be found on any of those computers or

storage media, the warrant applied for would permit the seizure and review of those items as well.

· B. Review of ESI

73. Following seizure of any computer devices and storage media and/or the creation

of forensic image copies, law enforcement personnel (who may include, in addition to law

enforcement officers and agents, attorneys for the government, attorney support staff, agency

personnel assisting the government in this investigation, and outside technical experts under

government control) will review the ESI contained therein for information responsive to the

warrant.

74. In conducting this review, law enforcement personnel may use various techniques

to determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such

techniques may include, for example:

• surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);

• conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to detennine its relevance);

• "scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and

43
I '
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 51 of 56

• performing electronic keyword searches through all electronic storage areas to


determine the existence and location of data potentially related to the subject matter of
the investigation25 ; and

• reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, wl).en, and by whom the computer was used.

75. Law enforcement personnel will make reasonable efforts to restrict their search to

data falling within the cate~ories of evidence specified in the warrant. Depending on the

circumstances, however, law enforcement personnel may need to conduct a complete review of all

the ESI from seized devices or storage media to evaluate its contents and to locate all data

responsive to the warrant.

76. Review of the items described in Attachment A will be conducted pursuant to

established procedures designed to collect evidence in a manner consistent with professional

responsibility requirements concerning the maintenance of attorney-client and ot.p.er operative

privileges. The procedures include use of a designated "filter team," separate and apart from the

investigative team, in order to address potential privileges.

C. Return of ESI

77. If the Government determines that the electronic devices are no longer necessary

to retrieve and preserve the data, and the devices themselves are not subject to seizure pursuant to

Federal Rule of Criminal Procedure 41(c), the Government will return these items, upon request.

Computer data that is encrypted or unreadable will not be returned unless law enforcement

personnel have determined that the data is not (i) an instrumentality of the offense, (ii) a fruit of

25
Keyword searches alone are typically inadequate to detect all relevant data. For one thing, keyword searches work
only for text data, yet many types of files, such as images and videos, do not store data as searchable text. Moreover,
even as to text data, there may be information properly subject to seizure but that is not captured by a keyword
search because the information does not contain the keywords being searched.

44
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 52 of 56

the ·criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed, or (v) evidence of the

Subject Offenses.

IV. Conclusion and Ancillary Provisions

78. Based on the foregoing, I respectfully request the court to issue a warrant to seize

the items and information specified in Attachment A to this affidavit and to the Search and Seizure

Warrant.

79. In light of the confidential nature of the continuing investigation, I respectfully

request that this affidavit and all papers submitted herewith be maintained under seal until the

Court orders otherwise. Sealing is necessary because items and information to be seized are

relevant to an ongoing investigation, and premature disclosure of the contents of this affidavit and

related documents may have a negative impact on this continuing investigation and may jeopardize

its effectiveness.

Respectfully submitted,

Special Agent
Federal Bureau of Investigation
i) I \ I \ , ,.1/

Subscribed and sworn to before me q1\ tbis~Y'fl.:day,;f faJ?-uary, 2019.


) ) ,.
I \

1' , ' ~

'
iYU_;f~· '
I
J
,, . /
/ ' - -..............
• . . . ; . _ , . . . . ._ _ __

' 1.' \II - ' - - - -

THE HONORABI.:E, ;R.OBERT W. LEHRBURGER


! '••I • •
United States Magistrate Judge

45
I '
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 53 of 56

ATTACHMENT A

I. Premises to be Searched - Subject Premises

The premises to be searched (the "Subject Premises") are described as follows, and

include all locked and closed containers found therein:

The Subject Premises are particularly described a

II. Items to Be Seized

A. Evidence, Fruits, and Instrumentalities of the Subject Offenses

The items to be seized from the Subject Premises include the following evidence, fruits,

and instrumentalities of violations of (i) Title 18, United States Code, Section 1505 (obstruction

of proceedings before departments, agencies, and committees); (ii) Title 18, United States Code,

Section 1001 (false statements); and (iii) Title 18, United States Code, Section 1512(b)(l) (witness

tampering); (collectively the "Subject Offenses"), for the period June 2015 to the present,

described as follows:

a. Evidence concerning who occupies or owns the Subject Premises, including

without limitation, utility and telephone bills, mail envelopes, addressed

correspondence, diaries, statements, identification documents, address books,

telephone directories, and keys;

b. Documents and communications that discuss or are related to WikiLeaks, Julian

Assange, and/or Russian interference in the 2016 U.S. presidential election;

1
/ '
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 54 of 56

c. Documents that reflect communications between Roger Stone and Jerome Corsi

that concern the Subject Offenses;

d. Documents reflecting communications between Roger Stone and Randy Credico

that concern the Subject Offenses;

e. Documents reflecting communications between Roger Stone and members of the

Trump Campaign or Trump Campaign associates, including Stephen K. Bannon,

, Paul Manafort, Richard Gates, and Donald J. Trump, that concern the

Subject Offenses;

f. Documents related to or discussing investigations into Russian interference in the

2016 U.S. presidential election and related matters by the U.S. House of

Representatives Permanent Select Committee on Intelligence; the U.S. Senate

Select Committee on Intelligence; and/or the Federal Bureau oflnvestigation;

g. Records and information relating to the use, ownership, or control of e-mail

accounts ;

h. Records and information demonstrating who uses, owns, or controls the WhatsApp

account associated with telephone numbe ;

i. Records and information demonstrating who uses, owns, or controls the Signal

account associated with telephone numbe ;

J. Records and information demonstrating who uses, owns, or controls the Wickr

account associated with telephone numbe ;

k. Records pertaining to accounts held with Internet Service Providers providing

service at or to the Subject Premises;

2
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 55 of 56

1. Computers and media storage devices, including tablets/iPads, and records or

documents demonstrating who operates, owns, or controls such devices, such as

telephone records, notes, notebooks, diaries, and reference materials, in whatever

form; and

m. Cellular telephones, smartphones, or personal data assistant devices, and records or

documents demonstrating who operates, owns, or controls such devices, such as

telephone records, notes, notebooks, diaries, and reference materials, in whatever

form.

B. Search and Seizure of Electronically Stored Information

The items to be seized from the Subject Premises also include any computer devices and
storage media that may contain any electronically stored information falling within the categories
set forth in Section II.A.a-le of this Attachment above, including, but not limited to, desktop and
laptop computers, disk drives, modems, thumb drives, personal digital assistants, smart phones·,
digital cameras, and scanners. In lieu of seizing an such computer devices or storage media, this
warrant also authorizes the copying of such devices or media for later review.
The items to be seized from the Subject Premises also include:
1. Any items or records needed to access the data stored on any seized or copied
computer devices or storage media, including but not limited to any physical keys, encryption
devices, or records oflogin credentials, passwords, private encryption keys, or similar information.

2. Any items or records that may facilitate a forensic examination of the computer
devices or storage media, including any hardware or software manuals or other information
concerning the configuration of the seized or copied computer devices or storage media.

3. Any evidence concerning the identities or locations of those persons with access to,
control over, or ownership of the seized or copied computer devices or storage media.

C. Review of ESI

Following seizure of any computer devices and storage media and/or the creation of
forensic image copies, law enforcement personnel (who may include, in addition to law
enforcement officers and agents, attorneys for the government, attorney support staff, agency
personnel assisting the government in this investigation, and outside technical experts under
government control) are authorized to review the ESI contained therein for information
responsive to the warrant.

3
Case 1:19-mc-00029-CRC Document 29-32 Filed 04/28/20 Page 56 of 56

In conducting this review, law enforcement personnel may use various techniques to
locate information responsive to the warrant, including, for example:
• surveying various file "directories" and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);

• op-ening or cursorily reading the first few "pages" of such files in order to determine
their precise contents; ·

• scanning storage areas to discover and possibly recover recently deleted files or
deliberately hidden files;

• performing key word searches through all electronic storage areas to determine whether
occunences oflanguage contained in such storage areas exist that are intimately related
to the subject matter of the investigation; and

• reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.

Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Sections
II.A.a-k and II.B of this Attachment. However, law enforcement personnel are authorized to
conduct a complete review of all the ESI from seized devices or storage media if necessary to
evaluate its contents and to locate all data responsive to the warrant.

4
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 1 of 53
... , .- .

AO 93 (Rev 12/09) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the

Southern District of Florida

In the Matter of the Search of )


(Briefly describe the property to be searched )
or identify the person by name and address) ) Case No. 19-6033-SNOW
)
, Fort Lauderdale, Florida (further
described in Attachment "A") )
)

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer

An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of Florida
(identify the person or describe the property to be searched and give its location):
Fort Lauderdale, Florida (further described in Allachmenl nAn)

The person or property to be searched, described above, is believed to conceal (identify the person or describe the
property to be seized):

See Attachment "8."

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.

YOU ARE COMMANDED to execute this warrant on or before F~ . l ~f1


(nottJ exceed f 4 days)
~ in the daytime 6:00 a.m. to 10 p.m. o at any time in the day or night as I find reasonable cause has been
established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken .
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to United States Magistrate Judge
Lurana S. Snow
(name)

o I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warran~ to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box) 0 for days (not to exceed 30).
J,.SS 0 until, the facts justifying, the later specific date of

Date and time issued: j,jf}.yl fCj 1~· d.6


Ph ~
~.JJ ~ Judge's signatllre

City and state: Fort Lauderdale, Florida Lurana S . Snow, United States Magistrate Judge
Printed name and title
. .
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 2 of 53

ATTACHMENT A

The address of the , Fort Lauderdale, Florida

Two photographs of the exterior of the Subject Premises are attached below.

Page 1 of1
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 3 of 53
.'

ATTACHMENT B

Property to be seized from the Subject Premises

1. The items to be seized are fruits, evidence, information relating to, contraband, or

instrumentalities of violations Title 18, United States Code, Section 1505 (obstruction of

proceeding); (ii) Title 18, United States Code, Section 1001 (false statements); and (iii) Title 18,

United States Code 1512(b)(1) (witness tampering), those violations involving Roger Stone, for

the time period June 2015 to the present, including:

a. Documents and communications that discuss or are related to WikiLeaks, Julian

Assange, and/or Russian interference in the 2016 U.S. presidential election;

b. Documents reflecting communications between Stone and Jerome Corsi;

c. Documents reflecting communications between Stone and Randy Credico;

d. Documents reflecting communications between Stone and members of the Trump

Campaign or Trump Campaign associates, including Steve Bannon, ,

Paul Manafort, Richard Gates, and Donald J. Trump;

e. Documents related to or discussing the U.S. House of Representatives Permanent

Select Committee on Intelligence, the Senate Select Committee on Intelligence, or

the Federal Bureau ofInvestigation;

f. Records and information relating to the e-mail accounts

and

g. Records and information relating to the WhatsApp account associated with

telephone number ;

h. Records and information relating to the Signal account associated with telephone

number ;

Page 1 of3
. . ...
, Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 4 of 53

1. Records and infonnation relating to the Wic1er account associated with telephone

number ;

J. Any computers, media storage devices, tablets/iPads, cellular telephones,

smartphones, personal data assistant devices, or other electronic devices used to

commit the violations described above or to store records or documents described

above;

k. Records of personal and business activities relating to the operation and

ownership of the computer systems, such as telephone records, notes, notebooks,

diaries, and reference materials, in whatever fonn;

1. Records pertaining to accounts held with Internet Service Providers or of Internet

use, in whatever fonn;

2. For any computer or storage medium whose seizure is otherwise authorized by

this warrant, and any computer or storage medium that contains or in which is stored records or

infonnation that is otherwise called for by this warrant (hereinafter, "COMPUTER"):

a. evidence of who used, owned, or controlled the COMPUTER at the time the

things described in this warrant were created, edited, or deleted, such as logs,

registry entries, configuration files, saved usernames and passwords, documents,

browsing history, user profiles, email, email contacts, "chat," instant messaging

logs, photographs, and correspondence;

b. evidence of software that would allow others to control the COMPUTER, such as

viruses, Trojan horses, and other fonns of malicious software, as well as evidence

of the presence or absence of security software designed to detect malicious

software;

Page 2 of3
.. . . Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 5 of 53

c. evidence of the lack of such malicious software;

d. evidence indicating how and when the computer was accessed or used to

determine the chronological context of computer access, use, and events relating

to crime under investigation and to the computer user;

e. evidence indicating the computer user's state of mind as it relates to the crime

under investigation;

f. evidence of the attachment to the COMPUTER of other storage devices or similar

containers for electronic evidence;

g. evidence of counter-forensic programs (and associated data) that are designed to

eliminate data from the COMPUTER;

h. evidence of the times the COMPUTER was used;

1. passwords, encryption keys, and other access devices that may be necessary to

access the COMPUTER;

J. documentation and manuals that may be necessary to access the COMPUTER or

to conduct a forensic examination of the COMPUTER;

k. records of or information about Internet Protocol addresses used by the

COMPUTER;

l. records of or information about the COMPUTER's Internet activity, including

firewall logs, caches, browser history and cookies, "bookmarked" or "favorite"

web pages, search terms that the user entered into any Internet search engine, and

records of user-typed web addresses;

m. contextual information necessary to understand the evidence described in this

attachment.

Page 3 of3
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 6 of 53
· "

AO 93 (Rev. 12/ 09) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy ofwarrant and inventory left with:
19-6033-SNOW
InventOlY made in the presence of:

Inventory ofthe property taken and name ofany person(s) seized:

Certification

I declare under penalty ofperjury that this inventory is correct and was returned along with the original
warrant to the designated judge.

Date:
Executing officer 's signature

Printed name and title


... Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 7 of 53
AD 106 (R ev 04 / 10) Application for a Search Warrant

UNITED STATES DISTRICT COURT


for the
Southern District of Florida

In the Matter of the Search of )


(Briefly describe the property to be searched )
or identify the person by name and address) Case No. 19-6033-SNOW
)
. , Fort Lauderdale, Florida (further described in )

Attachment nAn) )

APPLICATlON FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under

penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the

property to be searched and give its location):

Fort Lauderdale, Florida (further described in Attachment nAn)

Southern
located in the --------------- District of Florida , there is now concealed (identify the

- -----------------------
person or describe the property to be seized):

See Attachment "B."

The basis for the search under Fed . R. Crim. P. 41 (c) is (check one or more):
~ evidence of a crime;
~ contraband, fruits of crime, or other items illegally possessed ;
f'i property designed for use, intended for use, or used in committing a crime;
o a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section Offense Description
18U.S.C.1505 Obstruction of Proceeding
18 U.S.C. 1001 False Statements
18 U.S.C. 1512(b)(1) Witness Tampering
The application is based on these facts :
see attached affidavit.

Ii Continued on the attached sheet.


o Delayed notice of days (give exact ending date if more than 30 days : ) is requested
under 18 U.S.c. § 3103a, the basis of which is set forth on the attached sheet.

&, ~p:fL ,;;::!:'~


Curtis A. Heide, Special Agent, FBI
Printed name and title

Sworn to before me and signed in my presence.

Date I ji9-'1}/j ~.~.A. ~ Judge 's signature

City and state: Fort Lauderdale, Florida Lurana S. Snow, United States Magistrate Judge
Printed name and title
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 8 of 53

ATTACHMENT A

The address of the Subject Premises is Fort Lauderdale, Florida

Two photographs of the exterior of the Subject Premises are attached below.

Page 1 of 1
t '>t' Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 9 of 53

ATTACHMENT B

Property to be seized from the Subject Premises

1. The items to be seized are fruits, evidence, information relating to, contraband, or

instrumentalities of violations Title 18, United States Code, Section 1505 (obstruction of

proceeding); (ii) Title 18, United States Code, Section 1001 (false statements); and (iii) Title 18,

United States Code 1512(b)(1) (witness tampering), those violations involving Roger Stone, for

the time period June 2015 to the present, including:

a. Documents and communications that discuss or are related to WikiLeaks, Julian

Assange, and/or Russian interference in the 2016 U.S. presidential election;

b. Documents reflecting communications between Stone and Jerome Corsi;

c. Documents reflecting communications between Stone and Randy Credico;

d. Documents reflecting communications between Stone and members of the Trump

Campaign or Trump Campaign associates, including Steve Bannon, ,

Paul Manafort, Richard Gates, and Donald J. Trump;

e. Documents related to or discussing the U.S. House of Representatives Permanent

Select Committee on Intelligence, the Senate Select Committee on Intelligence, or

the Federal Bureau of Investigation;

f. Records and information relating to the e~mail accounts

and ;

g. Records and information relating to the WhatsApp account associated with

telephone number ;

h. Records and information relating to the Signal account associated with telephone

number ;

Page 1 of3
f .. I
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 10 of 53

1. Records and information relating to the Wickr account associated with telephone

number ;

J. Any computers, media storage devices, tablets/iPads, cellular telephones,

smartphones, personal data assistant devices, or other electronic devices used to

commit the violations described above or to store records or documents described

above;

k. Records of personal and business activities relating to the operation and

ownership of the computer systems, such as telephone records, notes, notebooks,

diaries, and reference materials, in whatever form;

1. Records pertaining to accounts held with Internet Service Providers or of Internet

use, in whatever form;

2. For any computer or storage medium whose seizure is otherwise authorized by

this warrant, and any computer or storage medium that contains or in which is stored records or

information that is otherwise called for by this warrant (hereinafter, "COMPUTER"):

a. evidence of who used, owned, or controlled the COMPUTER at the time the

things described in this wan'ant were created, edited, or deleted, such as logs,

registry entries, configuration files, saved usernames and passwords, documents,

browsing history, user profiles, email, email contacts, "chat," instant messaging

logs, photographs, and correspondence;

b. evidence of software that would allow others to control the COMPUTER, such as

viruses, Trojan horses, and other forms of malicious software, as well as evidence

of the presence or absence of security software designed to detect malicious

software;

Page 2 of3
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 11 of 53

c. evidence of the lack of such malicious software;

d. evidence indicating how and when the computer was accessed or used to

determine the chronological context of computer access, use, and events relating

to crime under investigation and to the computer user;

e. evidence indicating the computer user's state of mind as it relates to the crime

under investigation;

f. evidence of the attachment to the COMPUTER of other storage devices or similar

containers for electronic evidence;

g. evidence of counter-forensic programs (and associated data) that are designed to

eliminate data from the COMPUTER;

h. evidence of the times the COMPUTER was used;

I. passwords, encryption keys, and other access devices that may be necessary to

access the COMPUTER;

J. documentation and manuals that may be necessary to access the COMPUTER or

to conduct a forensic examination of the COMPUTER;

k. records of or information about Internet Protocol addresses used by the

COMPUTER;

1. records of or information about the COMPUTER's Internet activity, including

firewall logs, caches, browser history and cookies, "bookmarked" or "favorite"

web pages, search terms that the user entered into any Internet search engine, and

records of user-typed web addresses;

m. contextual information necessary to understand the evidence described in this

attachment.

Page 3 of3
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 12 of 53

AFFIDAVIT IN SUPPORT OF

AN APPLICATION FOR A SEARCH WARRANT

I, Curtis A. Heide, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for the

premises known and described as Fort Lauderdale, Florida, described in

the following paragraphs and further in Attachment A.

2. I am a Special Agent (SA) of the Federal Bureau of Investigation (FBI) and have

been since 2006. In the course of my duties, I have been responsible for investigating federal

crimes and national security matters involving both counterintelligence and issues related to

cybersecurity.

3. I am currently involved in the investigation into Roger Jason Stone, Jr., ("Roger

Stone") and others known and unknown to the government, for the commission of unlawful

activities in the Southern District of Florida, and elsewhere, including, but not limited to: (i)

obstruction of proceeding, in violation of Title 18, United States Code, Section 1505; (ii) false

statements, in violation of Title 18, United States Code, Section 1001 and (iii) witness tampering,

in violation of Title 18, United States Code 1512(b)(1 ) (collectively the "Specified Federal

Offenses") .

4. I have personally participated in this investigation and am aware of the facts

contained herein based on my own investigation, as well as my review of documents, records,

and information provided to me by other law enforcement officers and technical experts.

5. This affidavit is intended to show merely that there is sufficient probable cause

for the requested warrant and does not set forth all of my knowledge about this matter. Unless

specifically indicated, all conversations and statements in this affidavit are related in substance

Page 1 of 42
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 13 of 53

and part. Where I assert that an event took place on a particular date, I am asserting it took place

on or about the date specified.

6. I make this affidavit In support of an application for a warrant to search the

premises located at , Fort Lauderdale, FL (the "Subject Premises," as is more

particularly described in Attachment A), in connection with the Specified Federal Offenses, for

the items enumerated in Attachment B, which constitute evidence, contraband, fruits, and

instrumentalities of the Specified Federal Offenses.

7. For the reasons set forth in this Affidavit, there is probable cause to believe that

one or more of the Specified Federal Offenses have been committed by Roger Stone and others

known and unknown to the government. Further, there is probable cause to believe the Subject

Premises have been used to facilitate the commission of one or more of the Specified Federal

Offenses. Moreover, there is probable cause to believe that evidence, contraband, fruits, and

instrumentalities of violations of the Specified Federal Offense may be present in the Subject

Premises.

PROBABLE CAUSE

A. Background on Relevant Individuals

8. Roger Stone is a political consultant who has worked for decades in U.S. politics

and on U.S. political campaigns. Stone was an official on the U.S. presidential campaign of

Donald 1. Trump ("Trump Campaign") until in or around August 2015, and subsequently

maintained regular contact with and publicly supported the Trump Campaign through the 2016

election.

9. Julian Assange is the founder and director of WikiLeaks, which is publicly

described as a non-profit organization that disseminates non-pUblic information and classified

Page 2 of42
,. , Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 14 of 53

media provided by anonymized sources. WikiLeaks has posted numerous documents stolen from

the U.S. government. At all relevant times, Assange was located at the Ecuadorian Embassy in

London, United Kingdom.

10. Jerome Corsi is a political commentator who worked with an online media

publication during the 2016 U.S. presidential campaign. As set forth below, Corsi spoke

regularly with Stone throughout the campaign, including about the release of stolen documents

by WikiLeaks.

12. Based on the investigation to date, Randy Credico was a radio host who has

known Stone for more than a decade. In testimony before the U.S. House of Representatives

Permanent Selection Committee on Intelligence (" HPSCI") on or about September 26, 2017,

Stone described Credico (without naming him) as an "intermediary," "go-between," and "mutual

friend" to Assange. In a follow-up letter to HPSCI dated October 13, 2017, Stone identified

Credico by name and claimed Credico was the "gentleman who confirmed for Mr. Stone" that

Assange, had '" [e ]mails related to Hillary Clinton which are pending publication. '"

13 . Richard Gates is a U.S. citizen who served for years as a political consultant and

lobbyist along with Paul Manafort. From in or around June 2016 until November 2016, Gates

served as the deputy campaign chairman of the Trump Campaign. On February 23, 2018, Gates

pled guilty to one count of conspiracy against the United States and one count of making false

statements to federal law enforcement officers. United States v. Gales, 1: 17-cr-20 1 (D .D.C.).

Page 3 of42

Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 15 of 53

14. Steve Bannon is a U.S. citizen who serves as a political consultant. Beginning in

or around August 2016 and through the 2016 U.S. presidential election, Bannon served as the

chief executive officer of the Trump Campaign.

B. Hacking Activity During the 2016 Presidential Election

16. John Podesta is a U.S. citizen who served for years as a political consultant.

During the 2016 U.S. presidential campaign, Podesta served as the campaign chairman of the

Hillary Clinton presidential campaign ("Clinton Campaign"). On or about March 24, 2016,

Podesta received a spearphishingl email designed to appear as a security notification (a partial

copy of the email was recovered by the FBI from a subsequent release of stolen emails,

described below). During an interview with the FBI in or around May 2018, Podesta indicated

that after receiving the email, his assistant (who also had access to the account) clicked on a link

within the email and entered the account password when prompted (believing this prompt to be

part of a security protocol). Based on my training and experience, this activity appears to have

been a successful spearphishing operation through which an actor would have gained access to

Podesta's email account allowing the actor to steal emails and documents from that account.

17. The Democratic National Committee ("DNC") and Democratic Congressional

Campaign Committee ("DCCC") are U.S. political committees focusing on U.S. federal

I In my training and experience, spearphishing in this context refers to the fraudulent practice of
sending an email that purports to be from a known or trusted sender in order to induce the
targeted victim to respond in a desired manner, typically by clicking a malicious link or URL.

Page 4 of 42
,
< Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 16 of 53

elections. Both the DNC and DCCC were involved in the 2016 U.S. federal elections, including

the 2016 U.S. presidential election. According to DNC and DCCC individuals interviewed by

the Special Counsel's Office, in or around the spring of 2016, the DNC and DCCC became

aware that their computer systems had been compromised by unauthorized intrusions and hired

the cybersecurity company CrowdS trike to investigate the intrusions and remediate.

IS. On or about June 14,2016, CrowdStrike issued a public press release announcing

that the DNC's computer network had been compromised. In the public statement, CrowdStrike

indicated that it had identified "two sophisticated adversaries on the network," which it referred

to by the monikers COZY BEAR and FANCY BEAR. CrowdStrike stated that it had previously

seen these actors target other customers and that, based on their experience, "[bloth adversaries

engage in extensive political and economic espionage for the benefit of the government of the

Russian Federation and are believed to be closely linked to the Russian government's powerful

and highly capable intelligence services."

19. On or about July 13, 20 IS, a federal grand jury sitting in the District of Columbia

returned an indictment against eleven Russian nationals, charging them with partaking in a

conspiracy to hack into, among other things, the email account of Jolm Podesta, as well as the

DNC and DCCC computer networks. United States v. Viktor Borisovich Netyksho, 1: IS-cr-215

(D.D.C.). The indictment alleges that all of these individuals were military officers serving in

the Main Intelligence Directorate of the General Staff ("GRU"), the Russian Federation's

military intelligence agency.

C. WikiLeaks' Release of Stolen Documents During the 2016 Presidential Campaign

20. As alleged in the Netyksho indictment, after successfully hacking the DNC and

DCCC networks, as well as Podesta's email account, GRU officers transmitted some of the

Page 5 of 42
f. . Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 17 of 53

stolen documents to WikiLeaks. GRU officers communicated with WikiLeaks members about

the transfers using online personas created by the GRU, including "Guccifer 2.0" and

"DCLeaks." CGRU officers separately used these personas to release some of the stolen

documents).

21. On or about July 22, 2016, WikiLeaks released tens of thousands of documents

stolen from the DNC network. These stolen documents included communications by senior

DNC officials about campaign strategy, financial and fundraising data, and other documents

related to the 2016 U.S. federal elections, including the 2016 U.S. presidential election.

22. Beginning in or around October 2016, WikiLeaks began to release tens of

thousands of emails and documents stolen from Podesta's email account. Between on or about

October 7, 2016 and November 7, 2016, WikiLeaks released approximately 33 tranches of

documents that had been stolen from John Podesta, releasing a total of over 50,000 documents.

D. Stone's Communications About WikiLeaks During the Campaign

23. In April 2018 interviews with the Special Counsel's Office, Gates stated that

starting in or around May 2016, when Gates was a senior official on the Trump campaign, Stone

informed members of the Trump Campaign that WikiLeaks had emails from then-candidate

Hillary Clinton. According to Gates, after the July 22, 2016 release of stolen DNC emails by

WikiLeaks, Gates observed a conversation between Manafort and Stone in which they discussed

WikiLeaks and Stone's prediction of the release.

24. According to Gates, Manafort directed Gates to contact Stone about any

additional releases and what other information WikiLeaks had regarding the Clinton Campaign.

Gates contacted Stone, who made statements claiming that there would be potential future

releases of damaging material by WikiLeaks. In a separate interview with the Special Counsel's

Page 6 of42
., ~
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 18 of 53

Office in or around October 2018, Gates recalled that at one point during the campaign he was

with then-candidate Trump in a car when the candidate had a telephone call with Stone; shortly

after finishing the call with Stone, Gates recalled then-candidate Trump said more leaks were

coming.

25. Emails recovered through a court-authorized search of Stone's email account

show that shortly after the July 22, 2016 release of stolen DNC emails

by WikiLeaks, Stone corresponded with other associates about contacting WikiLeaks in order to

obtain other emails damaging to the Clinton Campaign:

a. On or about July 25, 2016, Stone sent an email to Jerome Corsi with the subject

line, "Get to Assange." The body of the message read: "Get to Assange [a]t

Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they

deal with Foundation, allegedly." On or about the same day, Corsi forwarded

Stone's email to , who lived in the United Kingdom and was a supporter

of the Trump Campaign.

b. On or about July 31, 2016, Stone emailed Corsi with the subject line, "Call me

MON." The body of the email read in part that " should see Assange."

c. On or about August 2, 2016, Corsi responded to Stone by email and wrote that he

was currently in Europe and planned to return in mid-August. Corsi stated, "Word

2 A search of was authorized on or about September 11, 2017 by the


U.s. District Court for the District of Columbia. Case No.1 :17-mj-661 (D.D.C. Sept. 11,2017).
A second search of was authorized on or about August 3, 2018 by the
U.S. District Court for the District of Columbia. Case No.1: 18-sc-2582 (D.D.C . Aug. 3,2018).
On or about September 26, 2018, the government obtained and executed an order pursuant to 18
U.S .c. § 2703(d) for records connected to . Case No.1 : 18-sc-2911
(D.D.C. Sept. 26, 2018). Records provided in response by Microsoft Corporation confirmed that
the account was still active and that the relevant emails described in this affidavit were not
deleted from the account.

Page 7 of 42
• Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 19 of 53

is friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct.

Impact planned to be very damaging." In a law enforcement interview, Corsi

stated that the phrase "friend in embassy" referred to Assange. Corsi added in the

same email, "Time to let more than Podesta to be exposed as in bed w enemy if

they are not ready to drop HRC. That appears to be the game hackers are now

about. Would not hurt to start suggesting HRC old, memory bad, has stroke ­

neither he nor she well. I expect that much of next dump focus, setting stage for

Foundation debacle."

26. According to recorded public statements recovered by the FBI, starting in early

August 2016, after receiving this August 2, 2016 email from Corsi, Stone made repeated

statements about information he claimed to have learned from Assange:

a. According to a public video posted to YouTube, on or about August 8, 2016,

Stone attended a public event in Broward County, Florida. During the event,

Stone stated, "I actually have communicated with Assange. I believe the next

tranche of his documents pertain to the Clinton Foundation, but there's no telling

what the October surprise may be."

b. According to a public video posted to YouTube, on or about August 12, 2016,

Stone was interviewed for a video segment on the show Info Wars, hosted by Alex

Jones. During the interview, Stone stated that he was "in communication with

Assange" but was "not at liberty to discuss what I have."

c. According to a public video posted to YouTube, on or about August 16, 2016,

Stone stated during another interview with Alex Jones that "it became known on

this program that I have had some back-channel communication with WikiLeaks

Page 8 of 42
., Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 20 of 53

and Assange." In a second interview on or about the same day with Dana Loesch

of the TheBlaze TV, Stone stated that he "communicated with Mr. Assange" and

that they had a "mutual acquaintance who is a fine gentleman."

d. According to a video posted to the public website of the TV station C-SPAN,

during a C-SP AN television interview on or about August 18, 2016, Stone stated

that he had communicated with Assange through an "intermediary, somebody

who is a mutual friend ."

e. In or around late 2018, Credico voluntarily produced to the FBI a copy of a radio

interview he did with Stone on or about August 23, 2016 during which the two

discussed Stone's prior claims to be in contact with Assange. At one point during

the interview, Credico asked Stone, "You ' ve been in touch indirectly with

Assange. Can you give us any kind of insight? Is there an October surprise

happening?" Stone responded, "Well, first of all, I don't want to intimate in any

way that I control or have influence with Assange because I do not. ... We have

a mutual friend , somebody we both trust and therefore I am a recipient of pretty

good information."

27. In or around November 2018, , Stone

produced a series of text messages between Stone and Credico during the 2016 presidential

campaign. 3 These text messages show that beginning on or about August 19, 2016, Stone

exchanged written communications with Credico about what WikiLeaks and Assange planned to

do. Emails recovered through a court-authorized search of Stone' s email account

3 As discussed below, Stone had previously released some of these text messages to members of
the media, who had written about them and published them in part.

Page 9 of 42
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show additional written communications between Stone and Credico

about WikiLeaks in or around September 2016,

a. On or about August 19, 2016, Credico sent a text message to Stone that read in

part, "I'm going to have Julian Assange on my show next Thursday." On or

about August 21, 2016, Credico sent another text message to Stone, writing in

part, "I have Julian Assange on Thursday so I'm completely tied up on that day."

b. On or about August 25, 2016, Assange was a guest on Credico's radio show for

the first time. On or about August 26,2016, Credico sent a text message to Stone

that stated, "Assange talk[ed] about you last night." Stone replied and asked what

Assange said, to which Credico responded, "He didn't say anything bad we were

talking about how the Press is trying to make it look like you and he are in

cahoots."

c. On or about August 27,2016, Credico sent text messages to Stone that said, "We

are working on a Julian Assange radio show," and that he (Credico) was "in

charge" of the project. In a text message sent later that day, Credico added,

"Julian Assange has kryptonite on Hillary."

d. On or about September 18, 2016, Stone sent a text message to Credico that said,

"I am e-mailing u a request to pass on to assange." Credico responded "Ok," and

added in a later text message, "Just remember do not name me as your connection

to Assange you had one before that you referred to."

e. Later on or about September 18, 2016, Stone emailed Credico an article with

allegations against then-candidate Clinton related to her service as Secretary of

State. Stone stated, "Please ask Assange for any State or HRC e-mail from

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August 10 to August 30 -- particularly on August 20, 2011 that mention

subject of the article] or this "

f. On or about September 19, 2016, texted Credico my

" responded, "1 did." or about

20,2016,
forwarded request to a close who was an attorney

with the ability to contact Stone on the

forwarded email.

g. On or about 30, 201 Credico sent Stone via text a

photograph of Credico standing outside the Embassy In London

where Assange was located.

h. On or October 1, 2016, which was a Credico sent text

messages stated, "big news Wednesday ... now pretend u don't know me ...

will die this " In the preceding these the

had reported that Assange planned to a public announcement on or

about October 4, 16, which was reported to be the 1

anniversary of the of WikiLeaks.

1. On or about October 2, 16, Stone emailed Credico, with the subject line

and a link to an article at the website http://heatst.com/politics/october­

surprise-thwarted-wikileaks-cancels-highly-anticipated-tuesday-announcement­

due-to-security-concerns. responded to Stone, "head fake."

J. On or about Monday, October 2016, wrote Credico and ac""""u, "Did

Assange back off." Credico initially responded, "I can't tal[k] about it." After

further exchanges with Stone, Credico responded, think on

II 42

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tomorrow." Credico added, "Off the Record Hillary and her people are doing a

full-court press they [sic] keep Assange from making the next dump ... That's all

I can tell you on this line ... Please leave my name out of it."

28. Emails and text messages recovered by the FBI show that, in or around October

2016, Stone made statements about Assange's future releases that were similar to prior

statements Credico made to him. For example:

a. In a court-authorized search of Stone's email account the

FBI recovered an email from Stone to sent on or about October 3, 2016,

which stated in part, "Spoke to my friend in London last night. The payload is

still coming."

b. In a court-authorized search of , the FBI also recovered an

email exchange from on or about October 3, 2016 between Stone and a reporter

who had connections to Bannon. In the exchange, the reporter asked, "Assange ­

what's he got? Hope it's good." Stone responded, "It is. I'd tell Bannon but he

doesn't call me back."

c. On or about October 4, 2016, Assange held a press conference but did not release

any new materials pertaining to the Clinton Campaign. In a court-authorized

search of , the FBI recovered an email exchange between

Stone and Steve Bannon on or about October 4, 2016 that occurred after the press

conference. In the exchange, Bannon asked, "What was that this morning???,"

referring to Assange's press conference. Stone responded, "Fear. Serious security

4 A search of was authorized on or about October 17, 2017 by the U.S.


District Court for the District of Columbia. Case No. 1:17-mj-760 (D.D.C. Oct. 17,2017). A
second search of was authorized on or about August 3, 2018 by the U.S.
District Court for the District of Columbia. Case No. 1:18-sc-2583 (D.D.C. Aug. 3,2018).

Page 12 of 42
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concern. He thinks they are going to kill him and the London police are standing

do[wn]. However - a load every week going forward."

d. In a court-authorized search of Stone's iCloud account,S the FBI recovered text

messages between Stone and from on or about October 4, 2016. In one

text message, asked Stone if he had "hear[d] anymore from London."

Stone replied, "Yes - want to talk on a secure line - got Whatsapp." In an

interview with the Special Counsel's Office in or around May 2018,

confirmed that he and Stone spoke and that Stone had told him WikiLeaks had

more material to release, and that the material was related to senior people

associated with Clinton.

29. On or about October 7, 2016, WikiLeaks released the first set of emails stolen

from Podesta. According to text messages recovered from Stone's iCloud account, shortly after

the release, an associate of Bannon sent a text message to Stone that read, "well done."

Similarly, during an April 2018 interview, Gates recalled that after the October 7, 2016

WikiLeaks release, Stone said, "I told you this was coming."

E. Stone's Communications with the House Permanent Select Committee on


Intelligence

30. On or about January 25, 2017, HPSCI publicly disclosed that it was investigating

allegations of Russian interference in the 2016 presidential election and possible links to

individuals associated with political campaigns. 6 During a public HPSCI hearing on or about

S A search of Stone's iCloud account was authorized on or about March 14, 2018 by the U.S.
District Court for the District of Columbia. Case No.1: 18-sc-662 (D.D.C. Mar. 14, 2018). The
records for Stone's iCloud account contained some, but not all, of Stone's communications from
the campaign period.

6On or about January 13,2017, the chairman and vice chairman of the Senate Select Committee
on Intelligence ("SSCI") announced the committee would conduct an inquiry that would

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March 20, 2017, multiple HPSCI committee members indicated that Stone's pnor public

statements about having communications with Assange (particularly those from August 2016)

were of interest to the committee.

31. In or around May 2017, HPSCI sent a letter requesting that Stone voluntarily

appear before the committee and produce relevant documents to HPSCI (a copy of the HPSCI

letter was recovered by the FBI from a court-authorized search of Stone's email account

). The letter requested Stone produce:

Any documents, records, electronically stored information


including e-mail, communication, recordings, data and tangible
things (including, but not limited to, graphs, charts, photographs,
images and other documents) regardless of form, other than those
widely available (e.g., newspaper articles) that reasonably could
lead to the discovery of any facts within the investigation's
publicly-announced parameters.

32. On or about May 22, 2017, counsel for Stone responded to HPSCI in writing and

stated, "Mr. Stone has no documents, records, or electronically stored information, regardless of

form, other than those widely available that reasonably could lead to the discovery of any facts

within the investigation'S publicly-announced parameters." (A copy of the letter was recovered

from a court-authorized search of Stone's email accountp ).

F. Stone's Testimony Before HPSCI

33. On or about September 26, 2017, Stone provided HPSCI with an "opening

statement" that his counsel requested be included as part of the record of proceedings before

HPSCI. In his opening statement, which HPSCI provided to the Department of Justice,7 Stone

investigate, among other things, any intelligence regarding links between Russia and individuals
associated with political campaigns, as well as Russian cyber activity and other "active
measures" directed against the United States in connection wi ththe 2016 election.
7 On or about December 14, 2018, the U.S. Department of Justice requested the transcript of
Stone's interview with HPSCI, as well as any written submissions and/or correspondence from

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stated, "These hearings are largely based on a yet unproven allegation that the Russian state is

responsible for the hacking of the DNC and John Podesta and the transfer of that information to

WikiLeaks."

34. Also on or about September 26, 2017, Stone provided testimony In a closed

session before HPSCI, at the U.S. Capitol in Washington, D.C. Stone's testimony was

transcribed, and a copy of the transcript was obtained by the Department of Justice from HPSCI

in or around December 2018. Stone appeared before HPSCI under oath and affirmed for the

record that he would tell the truth. At the beginning of the hearing, Stone was admonished that

"it is unlawful to deliberately provide false information to Members of Congress or staff' and

that "providing false information to this committee or concealing material information from this

committee is a crime punishable by law."

Stone's Testimony About Documents He Possessed Related to WikiLeaks

35. During his HPSCI testimony, Stone was asked about HPSCI's May 2017

document request and whether Stone had any documents or written communications that

discussed Julian Assange, Russian interference, or other relevant documents:

Q: The committee wrote to you on May 9th requesting no later


than May 22 any documents, records, electronically stored
information, including email communication, recordings,
data, and other tangible things relevant to our investigation.
You wrote back through counsel that you had no
documents, records, or electronically stored information
regardless of form responsive to our requests. Was that a
false statement?

A: That is not a false statement. That's what -- I believe that


to be true.

Stone and/or his counsel before or after the interview. On or about December 20, 2018, HPSCI
provided the U.S. Department of Justice a copy of the transcript of the September 26, 2017
interview of Roger Stone, a copy of Stone's written opening statement, and various
correspondence from Stone's counsel to members of HPSCI.

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[... ]

Q: So you no to anyone the


hacked documents or your conversations with the
Guccifer 2[.0] or any discussions you have with third
about Julian You no emails.no
no documents whatsoever, any kind of that nature?

A: That is correct. Not to my knowledge. I think we met,


again, the precise criteria of your request, and we complied.
if you have a more specific I'm happy to
back and look ....

Q: I just want to ask you under oath-

A: We did an with direction of


my attorneys, nothing that met criteria
that you asked for.

Q: I just want to be because you are under oath, where


your letter was not under that you have no
no no texts, no tweets that to Julian
or Guccifer 2[.0] or Paul Manafort or the allegations
concerning Russian connections with the campaign. You
have had no discussions in any written form. You've
written no documents yourself.

In connection with Russian collusion, consistent with your


exact and precise request,

36. In fact, as described sent and numerous and

text messages during the 2016 campaign In he WikiLeaks, Assange, and

possession of 11"',,,,,,,,, emails. Court-authorized of email accounts

(including ) and his iCloud account show

that, at the time of his testimony, Stone was still in vv,",,,,,-,,, many these and text

at the he on or about September 2017. 8 These written

8
warrant for Stone's email account was obtained on or about
September 11, 17 and executed shortly Records provided in or around September
18 in response to a court order issued pursuant to 18 § 2703(d) confinned that the
account was and emails question were not from account. The warrant

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communications included (a) Stone's email to Corsi on or about July 25, 2016, that read in part,

"Get to Assange [a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails ...

they deal with Foundation, allegedly."; (b) Stone's email to Corsi on or about July 31, 2016 that

Malloch "should see Assange"; (c) Corsi's email to Stone on or about August 2, 2016 that stated

in part: "Word is friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in

Oct. Impact planned to be very damaging."; (d) dozens of text messages and emails between

Stone and Credico, beginning on or about August 19, 2016 and continuing through duration of

the election, in which they discussed WikiLeaks and Assange; (e) Stone's email to on or

about October 3, 2016 that read in part "Spoke to my friend in London last night. The payload is

still coming."; and (f) Stone's email to Bannon on or about October 4, 2016 that claimed

WikiLeaks would release "a load every week going forward."

Stone's Testimony About His Early August 2016 Statements

37. During his HPSCI testimony on or about September 26, 2017, Stone was asked to

explain his statements in early August 2016 about being in contact with Assange. Stone was

specifically asked about his statement on or about August 8, 2016 that "I've actually

communicated with Assange," as well as his statement on or about August 12, 2016 that he was

"in communication with Assange" but was "not at liberty to discuss what I have."

38. Stone testified that these public references to having a means of contacting

WikiLeaks referred exclusively to his contact with a journalist, who Stone described as a "go-

between, as an intermediary, as a mutual friend" of Assange. Stone declined to tell HPSCI the

name of this "intermediary," but he provided a description in his testimony that was largely

for Stone's email account was obtained on or about October 17,2017 and
executed shortly thereafter. The warrant for Stone's iCloud account (which contained the text
messages described above) was obtained on or about March 14, 2018 and executed shortly
thereafter.

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consistent with Credico. (On or about October I 2017, Stone caused a letter to be to

HPSCI that identified Credico by name as the "gentleman who confirmed for Mr. that

had '" [e] mails to Hillary Clinton which are pending publication. ''').

39. In fact, documents recovered during the investigation (including those obtained

via search warrant returns show that Stone did not

communicating with Credico about .~~.~u ..,~ or WikiLeaks until on or about August 19, 2016 9

approximately days Stone first claimed on or about August 8, 2016 to "actually have

communicated with a week after his 6 statements of "in

communication Assange" and "not at liberty to discuss what I "

40. When interviewed by the FBI, Credico stated that the time he ever spoke

with Assange was on or about 2016, when interviewed 10 Credico

also provided the FBI with partially redacted emails that were between he

another member WikiLeaks from on or about August 25, which the two discuss the

technical for the that day. During Credico

biographical information about himself, apparently as a means

41. The FBI not identified Credico

2016 in which Stone to contact or WikiLeaks. When

interviewed by the Credico claimed he was never Stone in August 16 to

contact WikiLeaks.

9
described on or about August 19, Stone by text message that
Credico intended to interview Assange the or about August 25, 2016,
Credico interviewed Julian the first time, on or about 1
"Assange has kryptonite on Hillary."

10 Credico was first interviewed by in or around August 18. He has subsequently


participated in multiple voluntary interviews.

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42. In and as described above, the identified written

communications prior to 8, 2016 which Stone Corsi-not Credico--to contact

Assange. On or about July Stone wrote to Corsi, to Assange

Ecuadorian In London the WikiLeaks with

Foundation, allegedly." Similarly, on or about August 2, 2016, co--sem an

email to in which wrote that "[w lord is friend in embassy plans 2 more dumps,"

including one in October. communications days before first public

statement on or about August 2016 claiming to in communication with However,

at no time did identify to HPSCI as another individual Stone contacted to serve as a

"go-between," "intermediary," or other source for information WikiLeaks. Similarly,

Stone also never disclosed written communications with Corsi to when answering

HPSCI's about the August 2016 and August 12, 2016 statements about

communication with

43. During his HPSCI testimony, Stone was asked, "Did you ask [the intennediaryJ to

communicate anything to Stone did not." Stone was then asked,

"Did you [the intermediary] to do on your own behalf?" Stone responded, did

not."

44. In fact, on or about 18, 201 Stone directed Credico to

on a to .~~,~.. ,.,~ for documents that believed would be to Clinton

a. According to text , on or about

September 18, 2016, Stone sent a text v"''''''''~v to Credico said, "I am e-

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mailing u a request to pass on to Assange." On or about the same day, Stone

emailed Credico an article with allegations against then-candidate Clinton related

to her service as Secretary of State. Stone added, "Please ask Assange for any

State or HRC e-mail from August 10 to August 30 - particularly on August 20,

2011 that mention [the subject of the article] or confinn this narrative." (A copy

of this email was obtained through a search of Stone's email account

).

b. According to text messages , on or about

September 19,2016, Stone texted Credico again, writing "Pass my message ... to

Assange." Credico responded, "I did." An email obtained from the account

shows that on or about September 20, 2016, Credico

forwarded the request to an attorney who had the ability to contact Assange;

Credico blind copied Stone on the same email.

Stone's Testimonv About Written Communications with Credico

45. During his HPSCI testimony, Stone was asked repeatedly about his

communications with the person he identified as his intennediary. Stone stated that he had never

communicated with his intennediary in writing in any way. During one exchange, Stone claimed

only to have spoken with the intennediary telephonically:

Q: [H]ow did you communicate the intennediary?

A: Over the phone.

Q: And did you have any other means of communicating with


the intennediary?

A: No.

Q: No text messages, no - none of the list, right?

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Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 32 of 53

A: No.

Later during his testimony, Stone again denied ever communicating with his intermediary in

writing:

Q: So you never communicated with your intermediary In


writing in any way?

A: No.

Q: Never emailed him or texted him?

A: He's not an email guy.

Q: So all your conversations with him were in person or over


the phone.

A: Correct.

46. As described above, Stone and Credico (whom Stone identified as his

intermediary) engaged in frequent written communication by email and text message. Beginning

on or about August 19,2016, and continuing through the 2016 U.S. presidential election, Stone

and Credico engaged in dozens of communications by email or text message in which they

discussed WikiLeaks and the possible release of stolen documents that would be damaging to the

Clinton Campaign.

47. Written communications between Stone and Credico continued up until Stone's

HPSCI testimony and afterwards. For example, on or about September 26, 2017-the day that

Stone testified before HPSCI and denied having ever sent or received emails or text messages

from his identified intermediary, Stone and Credico exchanged over thirty text messages.

48. Certain of the electronic messages between Stone and Credico (which Stone

denied ever taking place or possessing) would have been material to HPSCI, including Stone's

messages in or around September 2016 directing Credico to pass a request for documents to

Assange, and other relevant written communications with Credico. For example, on or about

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January 6, 2017, Credico sent Stone an email, which Stone had in his possession at the time of

his HPSCI testimony, that had the subject line "Back channel bs." In the email, Credico wrote,

"Well I have put together timelines[] and you [] said you have a back-channel way back a month

before I had Assange on my show ... I have never had a conversation with Julian Assange other

than my radio show ... I have pieced it all together ... so you may as well tell the truth that you

had no back-channel or there's the guy you were talking about early August." (A copy of this

email was obtained through a search of Stone's email account ).

Stone's Testimony About Communications with the Trump Campaign

49. During his HPSCI testimony, Stone was asked, "[d]id you discuss your

conversations with the intermediary with anyone involved in the Trump campaign?" Stone

answered, "I did not." As described above, Stone spoke to multiple individuals involved in the

Trump campaign about what he claimed to have learned from his intermediary to Assange,

including the following:

a. As described above, Gates confirmed to investigators that Stone spoke with senior

Trump Campaign officials to inform them about materials possessed by Assange

and the timing of future releases.

b. According to text messages , on or about

October 3,2016, Stone wrote to "Spoke to my friend in London last night.

The payload is still coming."

c. As described above, on or about October 4, 2016, after receiving information

from Credico about the delay in WikiLeaks's release of stolen materials, Stone

emailed Bannon that Assange had a "[s]erious security concern" but would

release "a load every week going forward."

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G. Stone's Attempts to Influence Credico Regarding HPSCI and the FBI

50. According to an email recovered through a court-authorized search of Stone's

email accountp . on or about October 19, 2017, Stone sent Credico an

excerpt of his October 13, 2017 letter to HPSCI in which Stone claimed Credico was his

"intermediary" to Assange. As described below, Credico repeatedly told Stone that his letter was

false and said he should correct his statement to HPSCI, but Stone did not do so. Stone then

engaged in a prolonged effort to prevent Credico from contradicting Stone's false statements to

HPSCI.

51. In or around November 2017, Credico received a request from HPSCI to testify

voluntarily before the committee. After being contacted by HPSCI, Credico spoke and texted

repeatedly with Stone.

a. On or about November 19, 2017, Credico texted Stone that his lawyer wanted to

see him. Stone responded, '''Stonewall it. Plead the fifth. Anything to save the

plan' ... Richard Nixon." (A copy of these text messages was recovered through

a court-authorized search of Stone's iCloud account). On or about November 20,

2017, Credico informed HPSCI that he declined HPSCI's request for a voluntary

interview.

b. On or about November 21, 2017, Credico texted Stone, "I was told that the house

committee lawyer told my lawyer that I will be getting a subpoena." Stone

responded, "That was the point at which your lawyers should have told them you

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would assert your 5th Amendment rights if compelled to appear." (A copy of

these text messages was recovered through a court-authorized search of Stone's

iCloud account).

c. On or about November 28, 2017, Credico received a subpoena compelling his

testimony before HPSCI. Credico informed Stone of the subpoena.

d. According to emails recovered from Stone's email account

, on or about November 30, 2017, Stone asked Corsi to

write publicly about Credico. Corsi responded, "Are you sure you want to make

something out of this now? Why not wait to see what [Credico] does? You may

be defending yourself too much - raising new questions that will fuel new

inquiries. This may be a time to say less, not more." Stone responded by telling

Corsi that Credico "will take the 5th-but let's hold a day."

e. According to text messages recovered from Stone' s iCloud account, on multiple

occasions, starting on or about November 17, 2017, Stone and Credico discussed

Frank Pentangeli. Frank Pentangeli is a character in the film The Godfather: Part

II, who falsely claims not to know critical information before a congressional

committee that he does in fact know. On or about December 1,2017, Stone told

Credico in a text message to "Start practicing your Pentagele." When interviewed

by the FBI, Credico confirmed that he understood Stone's references to Frank

Pentangeli to be Stone's way of suggesting Credico withhold relevant information

from investigators.

f On or about December 1, 2017, Stone texted Credico, "And if you turned over

anything to the FBI you're a fool." Later that day, Credico texted Stone, "You

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need to amend your testimony before I testify on the 15th." Stone responded, "If

you testify you're a fool. Because of tromp I could never get away with a certain

[sic] my Fifth Amendment rights but you can. I guarantee you you are the one

who gets indicted for perjury if you're stupid enough to testify." (A copy of these

text messages was recovered through a court-authorized search of Stone's iCloud

account).

52. On or about December 12, 2017, Credico informed HPSCI that he intended to

assert his Fifth Amendment privilege against self-incrimination if required to appear by

subpoena. According to Credico, he invoked his Fifth Amendment privilege in part to avoid

providing evidence that would show Stone's previous testimony to Congress was false.

53. Following Credico's invocation of his Fifth Amendment privilege not to testify

before HPSCI, Stone and Credico continued to have discussions about the various investigations

into Russian interference in the 2016 election and what information Credico would provide to

investigators. During these conversations, Stone repeatedly made aggressive statements intended

to prevent Credico from cooperating with the investigations. For example:

a. On or about December 24, 2017, Credico texted Stone, "I met assange for f[i]rst

time this yea[ r] sept 7 ... docs prove that ... You should be honest w fbi ...

there was no back channel ... be honest." Stone replied approximately two

minutes later, "I'm not talking to the FBI and if your smart you won't either." (A

copy of these text messages was recovered through a court-authorized search of

Stone's iCloud account).

b. On or about April 9, 2018, Stone wrote in an email to Credico, "You are a rat. A

stoolie. You backstab your friends-run your mouth my lawyers are dying Rip

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you to shreds." Stone also said he would "take that dog away from you,"

referring to Credico's dog. On or about the same day, Stone wrote to Credico, "I

am so ready. Let's get it on. Prepare to die [expletive]." (A copy of this email

exchange was recovered through a court-authorized search of Stone's email

account ).

c. On or about May 21, 2018, Credico wrote in an email to Stone, "You should have

just been honest with the house Intel committee ... you've opened yourself up to

perjury charges like an idiot." Stone responded, "You are so full of [expletive].

You got nothing. Keep running your mouth and I'll file a bar complaint against

your friend [the attorney who had the ability to contact Assange]." (A copy of

this email exchange was recovered through a court-authorized search of Stone's

email accountp ). Credico believed Stone knew that Credico

was sensitive to having this friend's name publicly disclosed.

H. Missing Electronic Communications and Stone's Use of Encrypted Communications

54. As described above, the government has recovered the content of many of Stone's

electronic communications from summer and fall of 2016 (during the period of the U.S.

presidential election) and afterward (during the period of pending congressional investigations

into Russian interference in the U.S. election). However, the government is aware of the

existence of numerous other relevant electronic communications, the content of which it has not

yet been able to recover.

55. As described above, during his HPSCI testimony, Stone falsely denied having

emailed or exchanged text messages with his "intermediary" (later identified by Stone as Randy

Credico). In fact, emails and text messages recovered in this investigation show the two

Page 26 of 42
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Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 38 of 53

communicated frequently by email and text messages; court-authorized searches of Stone's

email and iCloud accounts confirm that Stone still had those communications at the time he

testified in or around September 2017. In numerous communications, Stone and Credico

discussed Julian Assange and WikiLeaks, as well as Stone's suggestion that Credico was his

intermediary to Assange. These communications appear relevant and responsive to HPSCI's

inquiry, but Stone never disclosed them.

56. In addition to these emails and text messages in the FBI's possession, the FBI has

reviewed telephone billing records for Stone's cellular telephone for the years 2016 and 2017,

and they show text message communications whose content that the government to date has not

been able to obtain. For example, these records indicate that Stone and Credico alone exchanged

thousands of text messages (including over 1,500 text messages between the period November

2016 and December 2017) the substance of which the government to date has not recovered or

reviewed. The government has only recently obtained text messages between Stone and Credico

during some period of the campaign in 2016 from Stone's subpoena production, issued after

media reports in November 2018 stated that Stone's attorneys were able to extract text messages

between Stone and Credico from a phone Stone stopped using in 2016. But the government does

not have, for the same time period, many of Stone's other text messages. The government seeks

these text messages believing they may show additional evidence of (1) the falsity of Stone's

HPSCI testimony concerning his communications with his "intermediary" and (2) efforts to

corruptly persuade Credico not to cooperate with pending investigations.

57. Additionally, the FBI has interviewed multiple associates of Stone, who

confirmed that Stone has used encrypted applications to communicate with others. Similarly,

records obtained in this investigation indicate Stone uses mUltiple applications designed for

Page 27 of 42
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 39 of 53

encrypted communication, including (a) WhatsApp, II (b) Signal,12 (c) Wickr,13 and (d)
14
ProtonMail. To date, the FBI has not obtained any of Stone's communications conducted

through these applications.

a. According to records from Stone's iCloud account, a copy of the WhatsApp

application was downloaded to an iPhone registered to Stone on or about October

5,2016. As described above, on or about October 4,2016, Stone suggested in an

email to that they "talk on a secure line" and proposed using

WhatsApp.

b. According to records from Stone's iCloud account, a copy of the Signal

application was downloaded to an iPhone registered to Stone on or about August

18, 2016. Additionally, text messages recovered from Stone's iCloud account

II According to open sources, WhatsApp is an application that allows the user to send text
messages, make voice calls, and transmit documents. WhatsApp uses end-to-end encryption and
stores its messages separately from those text messages used on a mobile device's default
message application.

12 According to open sources, Signal is an encrypted communications application allowing the


user to send one-to-one and group messages, which can include files, voice notes, images and
videos, and make one-to-one voice and video calls. Signal uses standard cellular mobile
numbers as identifiers, and uses end-to-end encryption to secure all communications to other
Signal users. Signal also allows users to set timers to messages, after which the messages will be
deleted from both the sender's and the receivers' devices.

13 According to open sources, Wickr is an instant messaging application that allows users to
exchange end-to-end encrypted and content-expiring messages, including photos, videos, and file
attachments and place end-to-end encrypted video conference calls. Like Signal, Wickr allows
users to set an expiration time for their encrypted communications. In addition to encrypting
user data and conversations, Wickr claims that its application strips metadata from all content
transmitted through the network.

14 According to open sources, ProtonMail is an end-to-end encrypted email service that uses
client-side encryption to protect email contents and user data before they are sent to ProtonMail
servers. According to its website, ProtonMail is run by Proton Technologies AG, a company
based in the Canton of Geneva, and its servers are located at two locations in Switzerland,
outside of US and EU jurisdiction.

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revealed that on or about November 15, 2016, Stone sent an attorney with the

ability to contact Julian Assange a link to download the Signal application. ls

Approximately fifteen minutes sending the link, Stone texted the attorney,

"I'm on signal just dial my number." attorney responded, "I'll call you."

c. According to records Stone's iCloud account, a of the ProtonMail

application was downloaded to an iPad registered to Stone on or about August 18,

2016.

d. According to from iCloud account, a copy the Wickr

application was downloaded to an iPhone registered to Stone on or about August

5, 17.

58. Based on my training and electronic communications encrypted

applications such as WhatsApp, Signal, ProtonMail, and Wickr are sometimes maintained on the

device used to and receive communications. Communications from those

applications can be obtained by law enforcement by the manually or a

data extraction device (such as Cellebrite). of the physical device can reveal messages,

including text and messages exchanged over WhatsApp, Signal, ProtonMail, and

Wickr, that have not backed to cloud accounts (such as an iCloud account).

Additionally, review of the device and the downloaded application can reveal other evidence

encrypted communications, such as call logs and contact lists.

continues to seek evidence of Stone's communications and contacts

during period of the 2016 U.S. presidential election through The

15
attorney was a close friend of Credico's and was the same friend Credico emailed on or
about September 2016 to Stone's request to emails connected to the
against then-candidate Clinton to of

Page 29 of 42
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 41 of 53

believes communications may contain evidence of additional communications concerning

WikiLeaks, and the of stolen documents damaging to the Clinton

Such communications could constitute additional evidence Stone's to obstruct

HPSCI's by showing additional contacts and about and

that Stone failed to

I. Other Relevant

60. On or about May 8, 2018, a law enforcement interview

was conducted. was an employee Stone's approximately June 2016

through approximately .lJ"-"v'-'H 2016 resided in Stone's previous York apartment for

a of time. provided information technology support for Stone but was not formally

trained to so. was aware that Stone communicated Trump the 2016

presidential campaign, and afterward, both in person by telephone. provided

information about a at Tower UI..,'VVI..,,,,, Trump Stone time

worked for to which carried a "file booklet" with him. told the file

booklet was important and that no one should it. said maintained file

booklet in closet.

61. or about 2018, law conducted an interview an

individual ("Person who had a relationship with a reporter who

provided IJ""'<'A~ 2 with information about Stone. reporter to Person 2 that in or

around January and February 2016, Stone and Trump were constant communication that

Stone notes of conversations. Stone's m notes was to

later provide a mortem of what went "

300f42
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 42 of 53

J. The Subject Premises

62. Your affiant is aware through the investigation that Stone maintains the Subject

Premises as his primary residence. 16 During physical surveillance of the Subject Premises on or

about January 14, 2019, the FBI observed Stone at the residence.

63. Records produced by Comcast on August 23, 2018

show that the subscriber of high-speed internet service and digital voice services at the

Subject Premises was Nydia Stone. According to public reporting and law enforcement

interviews, Nydia Stone is the spouse of Stone.

64. According to emails obtained through a court-authorized search of Stone's email

account , Stone sent an email on or about January 2, 2018 requesting the

recipient "update your files with my new address"; Stone identified the Subject Premises as his

new address. Additionally, in an email dated on or about August 2, 2018, Stone provided the

Subject Premises as his shipping address.

K. Computer Devices at the Subject Residence

65. Based on law enforcement interviews, your affiant is aware that Stone has used

and uses cellular telephones, desktop, and laptop computers to conduct electronic

communications. Stone also configures his computers to create regulars backups of his

computers and maintains one of these devices at the Subject Premises, which preserves

documents and communications.

16Stone also maintains a residence at New York, New


York.

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66. In or around May 2018, the FBI interviewed an individual ("Person 2") who

provided infonnation technology services to Stone. According to Person 2, Stone maintains at

least one Apple computer in each of his residences and also had an Apple MacBook Pro laptop

computer at one point in time. Person 2 revealed billing

receipts and invoices issued to Nydia Bertran-Stone for infonnation technology ("IT") services

dated January 2015 through May 2018. The records also show that Nydia Bertran-Stone was

billed for IT services in connection with three different Apple computers. Specifically, the

billing receipts show services for (1) an Apple iMac (serial number D25SY03RGQ 17)

configured with the name "Stone-Roger-iMac-FL"; (2) a second Apple iMac (serial number

D25TC077GQ 17) configured with the name "Stone-Roger-iMac-NYC"; and (3) an Apple

MacBookPro 10 (serial number C02KL05EFFT4) configured with the name "Stone-Nydia-

MBPR." According to publicly available infonnation, the iMac is one of Apple's desktop

models (i.e., a computer designed to be stationary). The naming convention of the computer

"Stone-Roger-iMac-FL" therefore suggests it is a stationary computer used by Stone and located

at the Subject Premises. I7 According to the billing records, the computer was serviced on or

about May 26,2018.

67. Person 2 also told law enforcement that Stone used the Apple Time Machine

("Time Machine") application to facilitate backups of his computers and that he believed Stone

used Time Machine on computers in his residences. According to publicly available

information, Time Machine is the built-in backup feature of Apple computers and can create

copies of files on a computer, including applications, music, photos, email, documents, and

system files. A Time Machine backup allows users to restore files from a specific point in time

17 According to multiple associates of Stone interviewed by the FBI, Stone maintains an office in
the Subject Residence and conducts most of his work from the office when he is in Florida.

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if the original files are ever deleted, or if the hard drive is erased or replaced. In order to create

backups with Time Machine, a user connects an external storage device to the computer and

selects that external storage device as the backup disk.18

68. Records produced by AT&T show that,

since 2016, Stone has had multiple Apple iPhone devices registered to his personal cellular

telephone number (ending in ). According to AT&T, between approximately January 1,

2015 and November 14, 2016, Stone's telephone number was registered to an Apple iPhone

model 5s ("iPhone 5s") (IMSI 310410657061814). On or about November 14,2016, Stone's

cellular telephone number was transferred to an Apple iPhone model 7 ("iPhone 7") (IMSI

310410930460769). On or about September 28, 2018, Stone's cellular telephone number was

transferred to an Apple iPhone model XS ("iPhone XS") (IMSI 310410155529814).

69. Records produced by Uber Teclmologies, Inc.,

show that the account associated with Stone's telephone number and email address has the Uber

application on multiple devices, including a device identified as iPhonell ,2, UDID - 668EDC66­

29BF-4AD2-8BCA-D974C7906597. Publicly available information indicates that the identifier

"iPhone 11,2" correlates to an Apple iPhone model XS. Additionally, the subpoena returns

identified a device identified as iPhone9,4, UDID 7161 CF59-6Fl 0-41 C8-984B­

DE0840 1EOA 74. Publicly available information indicates that the identifier iPhone9,4

correlates to an Apple iPhone model iPhone 7 Plus.

70. Records obtained from a court-authorized pen register/trap & trace ("PRTT")

monitoring of Stone's personal cellular telephone number 19 shows recent activity

18 When the external is plugged in, the Time Machine will automatically make hourly backups
for the past 24 hours, daily backups for the past month, and weekly backups for all previous
months. The oldest backups are deleted when the external storage device selected as the backup
disk is full. The external device can be as small as a USB thumb drive.

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indicating Stone continues to use the number and its associated device. For example, these

records show that between January 1, 2019 and January 10, 2019, telephone number was

used to make or receive over 150 telephone calls and send or receive over 750 text messages.

Likewise, a court-authorized PRTT of Stone's WhatsApp account (which is registered to Stone's

telephone number 20 showed the WhatsApp account was used to send or receive

approximately 13 WhatsApp messages and two WhatsApp voice calls between on or about

January 1,2019 and January 10,2019.

71. Statements attributed to Stone in recent media articles also indicate that Stone

retains computer devices that he no longer uses and keeps relevant electronic communications on

those devices. In or around November 2018, media reports began to publish excerpts of text

messages between Stone and Randy Credico that occurred during the 2016 U.S. election (copies

of these text messages subsequently were obtained from Stone 21

According to these news articles, Stone released these messages to the media outlets, which

Stone claimed were extracted by his lawyers from "a cell phone he stopped using in 2016."

Based on these statements, your affiant believes the cellular telephone referenced in the article to

be the iPhone 5s documented in the aforementioned AT&T records (which records indicate he

19 Installation and use of PRTT devices for was authorized by the U.S. District Court for
the District of Columbia on or about November 28, 2018. Case No.1: 18-pr-l72 (D.D.C. Nov.
28,2018).

20 Installation and use of PRTT devices for Stone's WhatsApp account was authorized by the
U.S. District Court for the District of Columbia on or about December 11, 2018. Case No.1: 18­
pr-250 (D.D.C. Dec. 11,2018).

21 See, e.g., "Bombshell Text Messages Support Roger Stone's Claims About WikiLeaks
Backchannel," Daily Caller, Nov. 14, 2018, available at
https:lldailycaller.coml20 18/11 I 14/roger-stone-wikileaks-randy-credico-mueller.

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Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 46 of 53

stopped using on or about November 14, 2016)?2 Further, your affiant believes Stone maintains

other devices he is no longer actively using.

COMPUTERS, ELECTRONIC STORAGE, AND FORENSIC ANALYSIS

72. As described above and in Attachment B, this application seeks permission to

search for records that might be found in the Subject Premises, in whatever form they are found.

One form in which the records might be found is data stored on a computer device's hard drive

or other storage media. Thus, the warrant applied for would authorize the seizure of electronic

storage media or, potentially, the copying of electronically stored information, all under Rule

41 (e )(2)(B).

73. Probable cause. I submit that if a computer or storage medium is found on the

Subject Premises, there is probable cause to believe those records will be stored on that computer

or storage medium, for at least the following reasons:

a. Based on my knowledge, training, and experience, I know that computer files or

remnants of such files can be recovered months or even years after they have been

downloaded onto a storage medium, deleted, or viewed via the Internet.

Electronic files downloaded to a storage medium can be stored for years at little

or no cost. Even when files have been deleted, they can be recovered months or

years later using forensic tools. This is so because when a person "deletes" a file

on a computer, the data contained in the file does not actually disappear; rather,

that data remains on the storage medium until it is overwritten by new data.

22 Stone produced some text messages between he and


Credico; the latest-in-time text message produced by Stone occurred on or about November 14,
2016. The govenunent believes copies of later-in-time text messages from late 2016 and early
2017 could be located on another device, such as the iPhone 7 described above, or on backup
storage media.

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b. Therefore, deleted files, or remnants of deleted files, may reside in free space or

slack space-that is, in space on the storage medium that is not currently being

used by an active file-for long periods of time before they are overwritten. In

addition, a computer's operating system may also keep a record of deleted data in

a "swap" or "recovery" file.

c. Wholly apart from user-generated files, computer storage media-in particular,

computers' internal hard drives-contain electronic evidence of how a computer

has been used, what it has been used for, and who has used it. To give a few

examples, this forensic evidence can take the form of operating system

configurations, artifacts from operating system or application operation, file

system data structures, and virtual memory "swap" or paging files. Computer

users typically do not erase or delete this evidence, because special software is

typically required for that task. However, it is technically possible to delete this

information.

d. Similarly, files that have been viewed via the Internet are sometimes

automatically downloaded into a temporary Internet directory or "cache."

74. Forensic evidence. As further described in Attaclunent B, this application seeks

permission to locate not only computer files that might serve as direct evidence of the crimes

described on the warrant, but also for forensic electronic evidence that establishes how

computers were used, the purpose of their use, who used them, and when. There is probable

cause to believe that this forensic electronic evidence will be on any storage medium in the

Subject Premises because:

Page 36 of 42
.

,
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 48 of 53

a. Data on the storage medium can provide evidence of a file that was once on the

storage medium but has since been deleted or edited, or of a deleted portion of a

file (such as a paragraph that has been deleted from a word processing file).

Virtual memory paging systems can leave traces of information on the storage

medium that show what tasks and processes were recently active. Web browsers,

e-mail programs, and chat programs store configuration information on the

storage mediwn that can reveal information such as online nicknames and

passwords. Operating systems can record additional information, such as the

attaclunent of peripherals, the attachment of USB flash storage devices or other

external storage media, and the times the computer was in use. Computer file

systems can record information about the dates files were created and the

sequence in which they were created, although this information can later be

falsified.

b. As explained herein, information stored within a computer and other electronic

storage media may provide crucial evidence of the "who, what, why, when,

where, and how" of the criminal conduct under investigation, thus enabling the

United States to establish and prove each element or alternatively, to exclude the

innocent from further suspicion. In my training and experience, information

stored within a computer or storage media (e.g., registry information,

communications, images and movies, transactional information, records of

session times and durations, internet history, and anti-virus, spyware, and

malware detection programs) can indicate who has used or controlled the

computer or storage media. This "user attribution" evidence is analogous to the

Page 37 of 42
I
\

Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 49 of 53

search for "indicia of occupancy" while executing a search warrant at a residence.

The existence or absence of anti-virus, spyware, and mal ware detection programs

may indicate whether the computer was remotely accessed, thus inculpating or

exculpating the computer owner. Further, computer and storage media activity

can indicate how and when the computer or storage media was accessed or used.

For example, as described herein, computers typically contains information that

log: computer user account session times and durations, computer activity

associated with user accounts, electronic storage media that connected with the

computer, and the IP addresses through which the computer accessed networks

and the internet. Such information allows investigators to understand the

chronological context of computer or electronic storage media access, use, and

events relating to the crime under investigation. Additionally, some information

stored within a computer or electronic storage media may provide crucial

evidence relating to the physical location of other evidence and the suspect. For

example, images stored on a computer may both show a particular location and

have geolocation information incorporated into its file data. Such file data

typically also contains information indicating when the file or image was created.

The existence of such image files, along with external device connection logs,

may also indicate the presence of additional electronic storage media (e.g., a

digital camera or cellular phone with an incorporated camera). The geographic

and timeline information described herein may either inculpate or exculpate the

computer user. Last, information stored within a computer may provide relevant

insight into the computer user's state of mind as it relates to the offense under

Page 38 of 42
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r' Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 50 of 53

investigation. For example, infonnation within the computer may indicate the

owner's motive and intent to commit a crime (e.g., internet searches indicating

criminal plaIll1ing), or consciousness of guilt (e.g., ruIll1ing a "wiping" program to

destroy evidence on the computer or password protecting/encrypting such

evidence in an effort to conceal it from law enforcement).

c. A person with appropriate familiarity with how a computer works can, after

examining this forensic evidence in its proper context, draw conclusions about

how computers were used, the purpose of their use, who used them, and when.

d. The process of identifying the exact files, blocks, registry entries, logs, or other

fonns of forensic evidence on a storage medium that are necessary to draw an

accurate conclusion is a dynamic process. While it is possible to specify in

advance the records to be sought, computer evidence is not always data that can

be merely reviewed by a review team and passed along to investigators. Whether

data stored on a computer is evidence may depend on other infonnation stored on

the computer and the application of knowledge about how a computer behaves.

Therefore, contextual infonnation necessary to understand other evidence also

falls within the scope of the warrant.

e. Further, in finding evidence of how a computer was used, the purpose of its use,

who used it, and when, sometimes it is necessary to establish that a particular

thing is not present on a storage medium. For example, the presence or absence

of counter-forensic programs or anti-virus programs (and associated data) may be

relevant to establishing the user's intent.

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• r
• ,
I' Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 51 of 53

75. Necessity ofseizing or copying entire computers or storage media. In most cases,

a thorough search of a premises for information that might be stored on storage media often

requires the seizure of the physical storage media and later off-site review consistent with the

warrant. In lieu of removing storage media from the premises, it is sometimes possible to make

an image copy of storage media. Generally speaking, imaging is the taking of a complete

electronic picture of the computer's data, including all hidden sectors and deleted files. Either

seizure or imaging is often necessary to ensure the accuracy and completeness of data recorded

on the storage media, and to prevent the loss of the data either from accidental or intentional

destruction. This is true because of the following:

a. The time required for an examination. As noted above, not all evidence takes the

form of documents and files that can be easily viewed on site. Analyzing

evidence of how a computer has been used, what it has been used for, and who

has used it requires considerable time, and taking that much time on premises

could be unreasonable. As explained above, because the warrant calls for forensic

electronic evidence, it is exceedingly likely that it will be necessary to thoroughly

examine storage media to obtain evidence. Storage media can store a large

volume of information. Reviewing that information for things described in the

warrant can take weeks or months, depending on the volume of data stored, and

would be impractical and invasive to attempt on-site.

b. Technical requirements. Computers can be configured in several different ways,

featuring a variety of different operating systems, application software, and

configurations. Therefore, searching them sometimes requires tools or knowledge

that might not be present on the search site. The vast array of computer hardware

Page 40 of 42
Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 52 of 53

and software available makes it difficult to know before a search what tools or

knowledge will be required to analyze the system and its data on the Premises.

However, taking the storage media off-site and reviewing it in a controlled

environment will allow its examination with the proper tools and knowledge.

c. Variety of forms of electronic media. Records sought under this warrant could be

stored in a variety of storage media formats that may require off-site reviewing

with specialized forensic tools.

76. Nature of examination. Based on the foregoing, and consistent with Rule

41 (e)(2)(B), the warrant I am applying for would permit seizing, imaging, or otherwise copying

storage media that reasonably appear to contain some or all of the evidence described in the

warrant, and would authorize a later review of the media or information consistent with the

warrant. The later review may require techniques, including but not limited to computer-assisted

scans of the entire medium, that might expose many parts of a hard drive to human inspection in

order to determine whether it is evidence described by the warrant.

77. Because multiple people share the Subject Premises as a residence, it is possible

that the Subject Premises will contain storage media that are predominantly used, and perhaps

owned, by persons who are not suspected of a crime. If it is nonetheless determined that that it is

possible that the things described in this warrant could be found on any of those computers or

storage media, the warrant applied for would permit the seizure and review of those items as

well.

FILTER REVIEW PROCEDURES

Review of the items described in Attachment B will be conducted pursuant to established

procedures designed to collect evidence in a manner consistent with professional responsibility

Page 41 of 42
.. .. Case 1:19-mc-00029-CRC Document 29-33 Filed 04/28/20 Page 53 of 53

requirements concerning the maintenance of attorney-client and other operative privileges. The

procedures include use of a designated "filter team," separate and apart from the investigative

team, in order to address potential privileges.

SEALING ORDER REQUESTED

78. It is further respectfully requested that this Court issue an Order sealing, until

further order of this Court, all papers submitted in support of this application, including the

application, affidavit, and search warrant, and the requisite inventory notice. Sealing is necessary

because items and information to be seized are relevant to an ongoing investigation, and

premature disclosure of the contents of this affidavit and related documents may have a negative

impact on this continuing investigation and may jeopardize its effectiveness.

CONCLUSION

79. Based on the foregoing, your affiant respectfully requests that this Court issue a

search warrant for the Subject Premises, more particularly described in Attachment A,

authorizing the seizure of the items described in Attachment B.

Respectfl By submitted,

v/I~ ') . ~~
Curtis A. Heide
pecial Agent
Federal Bureau of Investigation

Sworn to and subscribed before me on this ;Zy day of January, 2019.

1~~A-J_~~~_ J. ~
~
UNITED STATES MAGISTRATE JUDGE

Page 42 of 42
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 1 of 57

AO 93 (Rev. 12/09) Search and Seizure Warrant

UNITED STATES DISTRICT COURT


for the

Southern District of Florida

In the Matter of the Search of )

(Briefly describe the property to be searched )

or identifY the person by name and address) ) Case No. 19-6034-SNOW

)
Oakland Park, Florida
(further described in Attachment "A") )
)

SEARCH AND SEIZURE WARRANT


To: Any authorized law enforcement officer

An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of Florida
(identifY the person or describe the property to be searched and give its location):
Oakland Park, Florida (further described in Attachment "A")

The person or property to be searched, described above, is believed to conceal (identifY the person or describe the
property to be seized):

See Attachment "8"

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.

YOU ARE COMMANDED to execute this warrant on or before

(not to exceed 14 days)

~ in the daytime 6:00 a.m. to 10 p.m. o at any time in the day or night as I find reasonable cause has been

established.

Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to United States Magistrate Judge
Lurana S. Snow
(name)

o I find that immediate notification may have an adverse result listed in 18 U.S.c. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box) 0 for days (not to exceed 30).
o until, the facts justifying, the later specific date of
Date and time issued: I : :;).6

City and state: Fort Lauderdale, Florida Lurana S. Snow, United States Magistrate Jud~
Printed name and title
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 2 of 57

ATTACHMENT A

Oakland Park, Florida 33334.

The Subject Premises is a commercial space with a glass front door and glass windows covered

with a black fabric; a green awning bearing the letters "JVR" is above the door. A photograph of

the exterior of the Subject Premises is attached below.

Page 1 of1
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 3 of 57
- .,

ATTACHMENT B

Property to be seized from the Subject Premises

I. The items to be seized are fruits, evidence, information relating to, contraband, or

instrumentalities of violations Title 18, United States Code, Section 1505 (obstruction of

proceeding); (ii) Title 18, United States Code, Section 1001 (false statements); and (iii) Title 18,

United States Code l512(b)(I) (witness tampering), those violations involving Roger Stone, for

the time period June 2015 to the present, including:

a. Documents and communications that discuss or are related to WikiLeaks, Julian

Assange, and/or Russian interference in the 2016 U.S. presidential election;

b. Documents reflecting communications between Stone and Jerome Corsi;

c. Documents reflecting communications between Stone and Randy Credico;

d. Documents reflecting communications between Stone and members of the Trump

Campaign or Trump Campaign associates, including Steve Bannon, ,

Paul Manafort, Richard Gates, and Donald J. Trump;

e. Documents related to or discussing the U.S . House of Representatives Permanent

Select Committee on Intelligence, the Senate Select Committee on Intelligence, or

the Federal Bureau of Investigation;

f. Records and information relating to the e-mail accounts

and ;

g. Records and information relating to the WhatsApp account associated with

telephone number ;

h. Records and information relating to the Signal account associated with telephone

number ;

Page 1 of3
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 4 of 57

1. Records and infonnation relating to the Wickr account associated with telephone

number ;

J. Any computers, media storage devices, tablets/iPads, cellular telephones,

smruiphones, personal data assistant devices, or other electronic devices used to

commit the violations described above or to store records or documents described

above;

k. Records of personal and business activities relating to the operation and

ownership of the computer systems, such as telephone records, notes, notebooks,

diaries, and reference materials, in whatever fonn;

I. Records pertaining to accounts held with Internet Service Providers or of Internet

use, in whatever fonn;

2. For any computer or storage medium whose seizure is otherwise authorized by

this warrant, and any computer or storage medium that contains or in which is stored records or

information that is otherwise called for by this warrant (hereinafter, "COMPUTER"):

a. evidence of who used, owned, or controlled the COMPUTER at the time the

things described in this warrant were created, edited, or deleted, such as logs,

registry entries, configuration files, saved usernames and passwords, documents,

browsing history, user profiles, email, email contacts, "chat," instant messaging

logs, photographs, and correspondence;

b. evidence of software that would allow others to control the COMPUTER, such as

viruses, Trojan horses, and other fonns of malicious software, as well as evidence

of the presence or absence of security software designed to detect malicious

software;

Page 2 of3
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 5 of 57

c. evidence of the lack of such malicious software;

d. evidence indicating how and when the computer was accessed or used to

determine the chronological context of computer access, use, and events relating

to crime under investigation and to the computer user;

e. evidence indicating the computer user's state of mind as it relates to the crime

under investigation;

f. evidence of the attachment to the COMPUTER of other storage devices or similar

containers for electronic evidence;

g. evidence of counter-forensic programs (and associated data) that are designed to

eliminate data from the COMPUTER;

h. evidence of the times the COMPUTER was used;

1. passwords, encryption keys, and other access devices that may be necessary to

access the COMPUTER;

J. documentation and manuals that may be necessary to access the COMPUTER or

to conduct a forensic examination of the COMPUTER;

k. records of or information about Internet Protocol addresses used by the

COMPUTER;

I. records of or information about the COMPUTER's Internet activity, including

firewall logs, caches, browser history and cookies, "bookrnarked" or "favorite"

web pages, search terms that the user entered into any Internet search engine, and

records of user-typed web addresses;

m. contextual information necessary to understand the evidence described in this

attachment.

Page 3 of3
, . . Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 6 of 57

AO 93 (ReI'. /2/09) Search and Seizure Warrant (Page 2)

Return
Case No.: Date and time warrant executed: Copy ofwarrant and inventory left with:
19-6034-SNOW
Inventory made in the presence of:

Inventory ofthe property taken and name ofany person(s) seized:

Certification

I declare under penalty ofperjury that this inventory is correct and was returned along with the original
warrant to the designatedjudge.

Date:
Executing officer's signature

Printed name and title


Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 7 of 57
AO 106 (Rev 04110) Application for a Search Warrant

UNITED STATES DISTRICT COURT


for the
Southern District of Florida

Jn the Matter of the Search of


)
(Briefly describe the property to be searched )
or identify the person by name and address) Case No. 19-6034-SNOW
)
Oakland Park. Florida (further described )

in Attachment "A") )

APPLICATION FOR A SEARCH WARRANT


J, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that J have reason to bel ieve that on the following person or property (identify the person or describe the
property to be searched and give its location):
Oakland Park. Florida (further described in Attachment "A")

located in the Southern District of Florida , there is now concealed (identify the
------------------------
person or describe the property /0 be seized):

See Attachment "B"

The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):

~ evidence of a crime;

~ contraband, fruits of crime, or other items illegally possessed;

~ property designed for use, intended for use, or used in committing a crime;
o a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section Offense Description
18 U.S.C. 1505 Obstruction of Proceeding

18U.S.C.1001 False Statements

18 U.S.C. 1512(b)(1) Witness Tampering

The application is based on these facts:


See attached Affidavit.

ri C ontinued on the attached sheet.


o Delayed notice of _ _ days (give exact ending date if more than 30 days: _ _ _ _ _ ) is requested
under 18 U.S.c. § 31 03a, the basis of which is set forth on the a ached sheet.

Curtis A. Heide, Special Agent, FBI


Printed name and ti/le

Sworn to before me and signed in my presence.

Date rt it1'-I
City and state: Fort Lauderdale, Florida Lurana S. Snow, United States Magistrate Judge
Printed name and /itle
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 8 of 57

ATTACHMENT A

Oakland Park, Florida .

Page 1 of1
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 9 of 57

ATTACHMENT B

Property to be seized from the Subject Premises

1. The items to be seized are fruits, evidence, information relating to, contraband, or

instrumentalities of violations Title 18, United States Code, Section 1505 (obstruction of

proceeding); (ii) Title 18, United States Code, Section 1001 (false statements); and (iii) Title 18,

United States Code 1512(b)(1) (witness tampering), those violations involving Roger Stone, for

the time period June 2015 to the present, including:

a. Documents and communications that discuss or are related to WikiLeaks, Julian

Assange, and/or Russian interference in the 2016 U.S. presidential election;

b. Documents reflecting communications between Stone and Jerome Corsi;

c. Documents reflecting communications between Stone and Randy Credico;

d. Documents reflecting communications between Stone and members of the Trump

Campaign or Trump Campaign associates, including Steve Bannon,

Paul Manafort, Richard Gates, and Donald J. Trump;

e. Documents related to or discussing the U.S. House of Representatives Permanent

Select Committee on Intelligence, the Senate Select Committee on Intelligence, or

the Federal Bureau of Investigation;

f. Records and information relating to the e-mail accounts

and

g. Records and information relating to the WhatsApp account associated with

telephone number ;

h. Records and information relating to the Signal account associated with telephone

number ;

Page 1 of3
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 10 of 57

I. Records and information relating to the Wickr account associated with telephone

number ;

J. Any computers, media storage devices, tabletsliPads, cellular telephones,

smartphones, personal data assistant devices, or other electronic devices used to

commit the violations described above or to store records or documents described

above;

k. Records of personal and business activities relating to the operation and

ownership of the computer systems, such as telephone records, notes, notebooks,

diaries, and reference materials, in whatever form;

1. Records pertaining to accounts held with Internet Service Providers or of Internet

use, in whatever form;

2. For any computer or storage medium whose seizure is otherwise authorized by

this warrant, and any computer or storage medium that contains or in which is stored records or

information that is otherwise called for by this warrant (hereinafter, "COMPUTER"):

a. evidence of who used, owned, or controlled the COMPUTER at the time the

things described in this warrant were created, edited, or deleted, such as logs,

registry entries, configuration files, saved usernames and passwords, documents,

browsing history, user profiles, email, email contacts, "chat," instant messaging

logs, photographs, and correspondence;

b. evidence of software that would allow others to control the COMPUTER, such as

viruses, Trojan horses, and other forms of malicious software, as well as evidence

of the presence or absence of security software designed to detect malicious

software;

Page 2 of3
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 11 of 57

c. evidence of the lack of such malicious software;

d. evidence indicating how and when the computer was accessed or used to

determine the chronological context of computer access, use, and events relating

to crime under investigation and to the computer user;

e. evidence indicating the computer user's state of mind as it relates to the crime

under investigation;

f. evidence of the attachment to the COMPUTER of other storage devices or similar

containers for electronic evidence;

g. evidence of counter-forensic programs (and associated data) that are designed to

eliminate data from the COMPUTER;

h. evidence of the times the COMPUTER was used;

I. passwords, encryption keys, and other access devices that may be necessary to

access the COMPUTER;

J. documentation and manuals that may be necessary to access the COMPUTER or

to conduct a forensic examination of the COMPUTER;

k. records of or information about Internet Protocol addresses used by the

COMPUTER;

I. records of or information about the COMPUTER's Internet activity, including

firewall logs, caches, browser history and cookies, "bookmarked" or "favorite"

web pages, search terms that the user entered into any Internet search engine, and

records of user-typed web addresses;

m. contextual information necessary to understand the evidence described in this

attachment.

Page 3 of3
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 12 of 57

AFFIDAVIT IN SUPPORT OF

AN APPLICATION FOR A SEARCH WARRANT

I, Curtis A. Heide, being first duly sworn, hereby depose and state as follows:

fNTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a search warrant for the

premises known and described as Oakland Park, Florida described

in the following paragraphs and further in Attachment A.

2. I am a Special Agent (SA) of the Federal Bureau of Investigation (FBI) and have

been since 2006. In the course of my duties, I have been responsible for investigating federal

crimes and national security matters involving both counterintelligence and issues related to

cy bersecuri ty.

3. I am currently involved in the investigation into Roger Jason Stone, Jr., ("Roger

Stone") and others known and unknown to the government, for the commission of unlawful

activities in the Southern District of Florida, and elsewhere, including, but not limited to: (i)

obstruction of proceeding, in violation of Title 18, United States Code, Section 1505; (ii) false

statements, in violation of Title 18, United States Code, Section 1001 and (iii) witness tampering,

in violation of Title 18, United States Code 1512(b)(l) (collectively the "Specified Federal

Offenses").

4. I have personally participated in this investigation and am aware of the facts

contained herein based on my own investigation, as well as my review of documents, records,

and information provided to me by other law enforcement officers and technical experts.

5. This affidavit is intended to show merely that there is sufficient probable cause

for the requested warrant and does not set forth all of my knowledge about this matter. Unless

specifically indicated, all conversations and statements in this affidavit are related in substance

Page 1 of 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 13 of 57

and part. Where I assert that an event took place on a particular date, I am asserting that it took

place on or about the date specified.

6. I make this affidavit in support of an application for a warrant to search the

premises located at , Oakland Park, Florida (the "Subject Premises,"

as is more particularly described in Attachment A), in connection with the Specified Federal

Offenses, for the items enumerated in Attachment B, which constitute evidence, contraband,

fruits, and instrumentalities of the Specified Federal Offenses.

7. For the reasons set forth in this Affidavit, there is probable cause to believe that

one or more of the Specified Federal Offenses have been committed by Roger Stone and others

known and unknown to the government. Further, there is probable cause to believe the Subject

Premises have been used to facilitate the commission of one or more of the Specified Federal

Offenses. Moreover, there is probable cause to believe that evidence, contraband, fruits, and

instrumentalities of violations of the Specified Federal Offense may be present in the Subject

Premises.

PROBABLE CAUSE

A. Background on Relevant Individuals

8. Roger Stone is a political consultant who has worked for decades in U.S . politics

and on U.S. political campaigns. Stone was an official on the U.S. presidential campaign of

Donald 1. Trump ("Trump Campaign") until in or around August 2015, and subsequently

maintained regular contact with and publicly supported the Trump Campaign through the 2016

election.

Page 2 of 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 14 of 57

9. Julian is the founder and director of WikiLeaks, which is publicly

as a non-profit organization that disseminates non-public and classified

provided by sources. posted numerous

government. At relevant times, was located at the Embassy in

London, United Kingdom.

10. Jerome is a political commentator who worked with an online media

publication during 2016 presidential As set forth Corsi spoke

with Stone throughout the campaign, including about the stolen documents

by WikiLeaks.

Based on investigation to Randy Credico was a radio host who has

known Stone for more than a decade. In testimony before the U.S. Representatives

Selection on Intelligence on or about 26, 201

Credico naming him) as an "intennediary," " and "mutual

to Assange. In a follow-up letter to HPSCI dated October 13, 201 identified

name and was the who confirmed for Stone" that

.~_ ....,...,_, had '" [e]mails to Hillary Clinton which are pending publication.'"

13. Richard citizen as a political and

along with Paul From in or around June 2016 until November 16, Gates

as the deputy campaign chainnan of the Trump Campaign. On February 2018, Gates

Page 3 of 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 15 of 57

guilty to one count conspiracy against States and one count making false

statements to federal law officers. States v. Gates, 1: 1 1 (D.D.C.).

14. Steve is a U.S. citizen who serves as a political consultant. Beginning in

or around August the 2016 presidential election, served as the

chief executive officer Campaign.

B. Hacking During the 2016 Election

16. John is a U.S. citizen served for years as a political consultant.

the 2016 presidential campaign, served as the chairman of the

Hillary Clinton campaign ("Clinton Campaign"). On or about March 24, 2016,

t'O(leS'ra received a C',",,,.<>rr,h email to appear as a (a partial

copy of the email was recovered by the a subsequent stolen emails,

described below). an interview with in or around May Podesta indicated

that receiving his assistant (who had access to the account) clicked on a link

within the email andpMl.pr~.r1 account when prompted prompt to be

a security Based on my this aotJears to

been a successful spearphishing operation, which an actor would gained access to

Podesta's email account, allowing the actor to emails and documents that account.

spearphishing context refers to


to be from a or trusted sender in
in a desired manner, typically by clicking a

4 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 16 of 57

17. The Democratic National Committee ("DNC") and Democratic Congressional

Campaign Committee ("DCCC") are U.S. political committees focusing on U.S. federal

elections. Both the DNC and DCCC were involved in the 2016 U.S. federal elections, including

the 2016 U.S. presidential election. According to DNC and DCCC individuals interviewed by

the Special Counsel's Office, in or around the spring of 2016, the DNC and DCCC became

aware that their computer systems had been compromised by unauthorized intrusions and hired

the cybersecurity company CrowdStrike to investigate the intrusions and remediate.

IS. On or about June 14, 2016, CrowdStrike issued a public press release announcing

that the DNC's computer network had been compromised. In the public statement, CrowdS trike

indicated that it had identified "two sophisticated adversaries on the network," which it referred

to by the monikers COZY BEAR and FANCY BEAR. CrowdStrike stated that it had previously

seen these actors target other customers and that, based on their experience, "[b]oth adversaries

engage in extensive political and economic espionage for the benefit of the government of the

Russian Federation and are believed to be closely linked to the Russian government's powerful

and highly capable intelligence services."

19. On or about July 13, 201S, a federal grand jury sitting in the District of Columbia

returned an indictment against eleven Russian nationals, charging them with partaking in a

conspiracy to hack into, among other things, the email account of John Podesta, as well as the

DNC and DCCC computer networks. United States v. Viktor Borisovich Netyksho, I: lS-cr-21S

(D.D.C.). The indictment alleges that all of these individuals were military officers serving in

the Main Intelligence Directorate of the General Staff ("GRU"), the Russian Federation's

military intelligence agency.

Page 5 of46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 17 of 57

C. WikiLeaks' Release of Stolen Documents During the 2016 Presidential Campaign

20. As alleged in the Netyksho indictment, after successfully hacking the DNC and

DCCC networks, as well as Podesta's email account, GRU officers transmitted some of the

stolen documents to WikiLeaks. GRU officers communicated with WikiLeaks members about

the transfers using online personas created by the GRU, including "Guccifer 2.0" and

"DCLeaks." (GRU officers separately used these personas to release some of the stolen

documents).

21. On or about July 22, 2016, WikiLeaks released tens of thousands of documents

stolen from the DNC network. These stolen documents included communications by senior

DNC officials about campaign strategy, financial and fundraising data, and other documents

related to the 2016 U.S. federal elections, including the 2016 U.S. presidential election.

22. Beginning in or around October 2016, WikiLeaks began to release tens of

thousands of emails and documents stolen from Podesta's email account. Between on or about

October 7, 2016 and November 7, 2016, WikiLeaks released approximately 33 tranches of

documents that had been stolen from John Podesta, releasing a total of over 50,000 documents.

D. Stone's Communications About WikiLeaks During the Campaign

23. In April 2018 interviews with the Special Counsel's Office, Richard Gates stated

that starting in or around May 2016, when Gates was a senior official on the Trump campaign,

Stone informed members of the Trump Campaign that WikiLeaks had emails from then­

candidate Hillary Clinton. According to Gates, after the July 22, 2016 release of stolen DNC

emails by WikiLeaks, Gates observed a conversation between Manafort and Stone in which they

discussed WikiLeaks and Stone's prediction of the release.

Page 6 of 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 18 of 57

24. According to Gates, Manafort directed Gates to contact Stone about any

additional releases and what other information WikiLeaks had regarding the Clinton Campaign.

Gates contacted Stone, who made statements claiming that there would be potential future

releases of damaging material by WikiLeaks. In a separate interview with the Special Counsel's

Office in or around October 2018, Gates recalled that at one point during the campaign he was

with then-candidate Trump in a car when the candidate had a telephone call with Stone; shortly

after finishing the call with Stone, Gates recalled then-candidate Trump said more leaks were

coming.

25. Emails recovered through a court-authorized search of Stone's email account

show that shortly after the July 22, 2016 release of stolen DNC emails

by WikiLeaks, Stone corresponded with other associates about contacting WikiLeaks in order to

obtain other emails damaging to the Clinton Campaign:

a. On or about July 25, 2016, Stone sent an email to Jerome Corsi with the subject

line, "Get to Assange." The body of the message read, "Get to Assange [a]t

Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they

deal with Foundation, allegedly." On or about the same day, Corsi forwarded

Stone's email to , who lived in the United Kingdom and who was a

supporter of the Trump Campaign.

2 A search of was authorized on or about September II, 2017 by the


U.S. District Court for the District of Columbia. Case No.1 :17-mj-661 CD.D.C. Sept. 11,2017).
A second search of was authorized on or about August 3, 2018 by the
U.S. District Court for the District of Columbia. Case No. 1:18-sc-2582 CD.D.C. Aug. 3, 2018).
On or about September 26, 2018, the government obtained and executed an order pursuant to 18
U.S.c. § 2703Cd) for records connected to . Case No. 1:18-sc-2911
CD.D.C. Sept. 26, 2018). Records provided in response by Microsoft Corporation confirmed that
the account was still active and that the relevant emails described in this affidavit were not
deleted from the account.

Page 7 of 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 19 of 57

b. On or about July 31, 2016, Stone emailed Corsi with the subject line, "Call me

MON." The body of the email read in part that "should see Assange."

c. On or about August 2, 2016, Corsi responded to Stone by email and wrote that he

was currently in Europe and planned to return in mid-August. Corsi stated, "Word

is friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in Oct.

Impact planned to be very damaging." In a law enforcement interview, Corsi

stated that the phrase "friend in embassy" referred to Assange. Corsi added in the

same email, "Time to let more than Podesta to be exposed as in bed w enemy if

they are not ready to drop HRC. That appears to be the game hackers are now

about. Would not hurt to start suggesting HRC old, memory bad, has stroke ­

neither he nor she well. I expect that much of next dump focus, setting stage for

Foundation debacle."

26. According to recorded public statements recovered by the FBI, starting in early

August 2016, after receiving this August 2, 2016 email from Corsi, Stone made repeated

statements about information he claimed to have learned from Assange:

a. According to a public video posted to YouTube, on or about August 8, 2016,

Stone attended a public event in Broward County, Florida. During the event,

Stone stated, "I actually have communicated with Assange. I believe the next

tranche of his documents pertain to the Clinton Foundation, but there's no telling

what the October surprise may be."

b. According to a public video posted to YouTube, on or about August 12, 2016,

Stone was interviewed for a video segment on the show InfoWars, hosted by Alex

Page 8 of46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 20 of 57

Jones. During the interview, Stone stated that he was "in communication with

Assange" but was "not at liberty to discuss what I have."

c. According to a public video posted to YouTube, on or about August 16, 2016,

Stone stated during another interview with Alex Jones that "it became known on

this program that I have had some back-chatmel communications with WikiLeaks

and Assange." In a second interview on or about the same day with Dana Loesch

of the TheBlaze TV, Stone stated that he "communicated with Mr. Assange" and

that they had a "mutual acquaintance who is a fine gentleman."

d. According to a video posted to the public website of the TV station C-SPAN,

during a C-SP AN television interview on or about August 18, 2016, Stone stated

that he had communicated with Assange through an "intermediary, somebody

who is a mutual friend."

e. In or around late 2018, Credico voluntarily produced to the FBI a copy of a radio

interview he did with Stone on or about August 23, 2016 during which the two

discussed Stone's prior claims to be in contact with Assange. At one point during

the interview, Credico asked Stone, "You've been in touch indirectly with

Assange. Can you give us any kind of insight? Is there an October surprise

happening?" Stone responded, "Well, first of all, I don't want to intimate in any

way that I control or have influence with Assange because I do not. ... We have

a mutual friend, somebody we both trust and therefore I am a recipient of pretty

good information."

27. In or around November 2018, , Stone

produced a series of text messages between Stone and Credico during the 2016 presidential

Page 9 of 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 21 of 57

campaign. 3 text on or about 19, 6, Stone

WikiLeaks planned to

do. recovered through a court-authorized search of Stone's email account

show written communications between and Credico

about WikiLeaks in or around 2016.

a. or about Credico sent a text message to that read in

part, "I'm going to have Julian on my show next Thursday." On or

about August 21, 16, Credico sent text message to writing in

part, "I have Julian on Thursday so completely on that day."

b. On or about 2016, Assange was a on radio show for

the first time. On or about August 26, 2016, Credico sent a text

that stated, 'UU~.",",_ talk[ed] about you " Stone replied and asked what

Assange said, to which Credico responded, didn't say we were

about how is trying to it look like you and he are in

cahoots."

c. On or about August 2016, Credico sent text messages to that said, "We

are working on a Assange " and that he was "in

of the In a text sent later that Credico added,

"Julian Assange has kryptonite on Hillary."

d. On or about 18, 2016, Stone sent a text message to that said,

"I am e-mailing u a to pass on to " Credico "Ok," and

3 As below, Stone had previously released some these text "''''''''''F>'''''' to members of
the media, who had written about and published them in part.

10 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 22 of 57

added in a later text message, "Just remember do not name me as your connection

to Assange you had one before that you referred to."

e. Later on or about September 18, 2016, Stone emailed Credico an article with

allegations against then-candidate Clinton related to her service as Secretary of

State. Stone stated, "Please ask Assange for any State or HRC e-mail from

August 10 to August 30 -- particularly on August 20, 2011 that mention [the

subject of the article] or confirm this narrative."

f. On or about September 19, 2016, Stone texted Credico again, writing, "Pass my

message ... to Assange." Credico responded, "I did." On or about September

20, 2016, Credico forwarded the request to a close friend who was an attorney

with the ability to contact the Assange. Credico blind-copied Stone on the

forwarded email.

g. On or about September 30, 2016, Credico sent Stone via text message a

photograph of Credico standing outside the Ecuadorian Embassy in London

where Assange was located.

h. On or about October 1, 2016, which was a Saturday, Credico sent Stone text

messages that stated, "big news Wednesday ... now pretend u don't know me ...

Hillary's campaign will die this week." In the days preceding these messages, the

press had reported that Assange planned to make a public announcement on or

about Tuesday, October 4, 2016, which was reported to be the lO-year

anniversary of the founding of WikiLeaks.

Page 11 of 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 23 of 57

1. On or about October 2, 2016, Stone emailed Credico, with the subject line

"WTF?" and a link to an article at the website http://heatst.com/politics/october­

surprise-thwarted-wikileaks-cancels-highly-anticipated-tuesday-announcement­

due-to-security-concerns. Credico responded to Stone, "head fake."

J. On or about Monday, October 3, 2016, Stone wrote Credico and asked, "Did

Assange back off." Credico initially responded, "I can't tal[k] about it." After

further exchanges with Stone, Credico responded, "I think it[']s on for

tomorrow." Credico added, "Off the Record Hillary and her people are doing a

full-court press they [sic] keep Assange from making the next dump ... That's all

I can tell you on this line ... Please leave my name out of it."

28. Emails and text messages recovered by the FBI show that, in or around October

2016, Stone made statements about Assange's future releases that were similar to prior

statements made by Credico to him. For example:

a. In a court-authorized search of Stone's email accountp the

FBI recovered an email from Stone to sent on or about October 3, 2016,

which stated in part, "Spoke to my friend in London last night. The payload is

still coming."

b. In a court-authorized search of , the FBI also recovered an

email exchange from on or about October 3, 2016 between Stone and a reporter

who had connections to Bannon. In the exchange, the reporter asked, "Assange ­

4 A search of was authorized on or about October 17, 2017 by the U.S.


District Court for the District of Columbia. Case No. 1:17-mj-760 (D.D.C. Oct. 17,2017). A
second search of was authorized on or about August 3, 2018 by the U.S.
District Court for the District of Columbia. Case No.1: 18-sc-2583 (D.D.C. Aug. 3,2018).

Page 12 of 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 24 of 57

what's he got? it's good," responded, I'd tell Bannon but he

doesn't call me back."

c. On or about 4,2016, held a conference but not release

new materials pertaining to the Clinton Campaign. In a court-authorized

search , the FBI an email

and Steve JJUl'HV on or about October 4,2016 that occurred press

In Bannon "What was that this morning???"

referring to .~~~...~_ s press conference. responded, Serious security

concern. He thinks are going to London police are standing

do[wn]. However - a load week forward."

d. In a court-authorized search of Stone's iCloud account,S the recovered text

and on or about October 4, 201 In one

text asked if he had "hear[d] anymore from London."

replied, - want to talk on a secure line Whatsapp." In an

interview with the Counsel's in or around May 2018,

confirmed that and Stone and that told him WikiLeaks had

more material to and material was related to people

associated with Clinton.

29. or about 7, 201 WikiLeaks 1..""""";)""\..1 the first set stolen

Podesta. According to text messages recovered Stone's iCloud account, shortly after

the an associate Bannon sent a text message to that read done." Similarly,

iCloud account was authorized on or about March 14, 2018 by the U.S.
District Columbia. Case 1: 18-sc-662 Mar. 1 18). The
r"'''ArC1<' for Stone's iCloud account contained some, but not all, of Stone's communications
the period.

Page 13 46
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during an April 2018 interview, Gates recalled that after the October 7, 2016 WikiLeaks release,

Stone said, "I told you this was coming."

E. Stone's Communications with the House Permanent Select Committee on


Intelligence

30. On or about January 25, 2017, HPSCI publicly disclosed that it was investigating

allegations of Russian interference in the 2016 presidential election and possible links to

individuals associated with political campaigns. 6 During a public HPSCI hearing on or about

March 20, 2017, multiple HPSCI committee members indicated that Stone's prior public

statements about having communications with Assange (particularly those from August 2016)

were of interest to the committee.

31. In or around May 2017, HPSCI sent a letter requesting that Stone voluntarily

appear before the committee and produce relevant documents to HPSCI (a copy of the HPSCI

letter was recovered by the FBI from a court-authorized search of Stone's email account

). The letter requested Stone produce:

Any documents, records, electronically stored information


including e-mail, communication, recordings, data and tangible
things (including, but not limited to, graphs, charts, photographs,
images and other documents) regardless of form, other than those
widely available (e.g., newspaper articles) that reasonably could
lead to the discovery of any facts within the investigation's
publicly-announced parameters.

32. On or about May 22, 2017, counsel for Stone responded to HPSCI in writing and

stated that "Mr. Stone has no documents, records, or electronically stored information, regardless

of form, other than those widely available that reasonably could lead to the discovery of any

6 On or about January 13,2017, the chairman and vice chairman of the Senate Select Committee
on Intelligence ("SSCI") announced the committee would conduct an inquiry that would
investigate, among other things, any intelligence regarding links between Russia and individuals
associated with political campaigns, as well as Russian cyber activity and other "active
measures" directed against the United States in connection with the 2016 election.

Page 14 of 46
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facts within the investigation's publicly-arulOunced parameters." (A copy of the letter was

recovered from a court-authorized search of Stone's email account ).

F. Stone's Testimony Before HPSCI

33. On or about September 26, 2017, Stone provided HPSCI with an "opening

statement" that his counsel requested be included as part of the record of proceedings before

HPSCI. In his opening statement, which HPSCI provided to the Department of Justice,7 Stone

stated, "These hearings are largely based on a yet unproven allegation that the Russian state is

responsible for the hacking of the DNC and John Podesta and the transfer of that information to

WikiLeaks."

34. Also on or about September 26, 2017, Stone provided testimony in a closed

session before HPSCI, at the U.S. Capitol in Washington, D.C. Stone's testimony was

transcribed, and a copy of the transcript was obtained by the Special Counsel ' s Office from

HPSCI in or around December 2018. Stone appeared before HPSCI under oath and affirmed for

the record that he would tell the truth. At the beginning of the hearing, Stone was admonished

that "it is unlawful to deliberately provide false information to Members of Congress or staff'

and that "providing false information to this committee or concealing material information from

this committee is a crime punishable by law."

Stone's Testimony About Documents He Possessed Related to WikiLeaks

35. During his HPSCI testimony, Stone was asked about HPSCI's May 2017

document request and whether Stone had any documents or written communications that

7 On or about December 14, 2018, the U.S. Department of Justice requested the transcript of
Stone's interview with HPSCI, as well as any written submissions and/or correspondence from
Stone and/or his counsel before or after the interview. On or about December 20, 2018, HPSCI
provided the U.S. Department of Justice a copy of the transcript of the September 26, 2017
interview of Roger Stone, a copy of Stone's written opening statement, and various
correspondence from Stone's counsel to members of HPSCI.

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discussed Julian Assange, Russian interference, or other relevant documents:

Q: The committee wrote to you on May 9th requesting no later


than May 22 any documents, records, electronically stored
information, including email communication, recordings,
data, and other tangible things relevant to our investigation.
You wrote back through counsel that you had no
documents, records, or electronically stored information
regardless of form responsive to our requests. Was that a
false statement?

A: That is not a false statement. That's what -- I believe that


to be true.

[ ... ]

Q: So you have no emails to anyone concerning the allegations


of hacked documents or your conversations with the
Guccifer 2[.0] or any discussions you have had with third
parties about Julian Assange? You have no emails, no texts,
no documents whatsoever, any kind of that nature?

A: That is correct. Not to my knowledge. I think we met,


again, the precise criteria of your request, and we complied.
Again, if you have a more specific request, I'm happy to go
back and look ....

Q: I just want to ask you under oath-

A: We did an extensive search consistent with the direction of


my attorneys, and we found nothing that met the criteria
that you asked for.

Q: I just want to be certain because you are under oath, where


your letter was not under oath, that you have no documents,
no emails, no texts, no tweets that refer to Julian Assange
or Guccifer 2[.0] or Paul Manafort or the allegations
concerning Russian connections with the campaign. You
have had no discussions in any written form. You've
written no documents yourself.

A: In connection with Russian collusion, consistent with your


exact and precise request, yes.

36. In fact, and as described above, Stone had sent and received numerous emails and

text messages during the 2016 campaign in which he discussed WikiLeaks, Assange, and

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WikiLeaks possession of hacked emails. Court-authorized searches of Stone's email accounts

and his iCloud account show

that, at the time of his testimony, Stone was still in possession of many of these emails and text

messages at the time he testified on or about September 22, 2017. 8 These written

communications included (a) Stone's email to Corsi on or about July 25, 2016 that read in part,

"Get to Assange [a]t Ecuadorian Embassy in London and get the pending WikiLeaks emails . ..

they deal with Foundation, allegedly."; (b) Stone's email to Corsi on or about July 31, 2016 that

"should see Assange"; (c) Corsi's email to Stone on or about August 2, 2016 that stated

in part, "Word is friend in embassy plans 2 more dumps. One shortly after I'm back. 2nd in

Oct. Impact planned to be very damaging."; (d) dozens of text messages and emails between

Stone and Credico, beginning on or about August 19, 2016 and continuing through duration of

the election, in which they discussed WikiLeaks and Assange; (e) Stone's email to on or

about October 3, 2016 that read in part "Spoke to my friend in London last night. The payload is

still coming."; and (f) Stone's email to Bannon on or about October 4, 2016 that claimed

WikiLeaks would release "a load every week going forward."

Stone's Testimony About His Early August 2016 Statements

37. During his HPSCI testimony on or about September 26,2017, Stone was asked to

explain his statements in early August 2016 about being in contact with Assange. Stone was

specifically asked about his statement on or about August 8, 2016 that "I've actually

8 The warrant for Stone's email account was obtained on or about


September 11, 2017 and executed shortly thereafter. Records provided in or around September
2018 in response to a court order issued pursuant to 18 U.S.C. § 2703(d) confirmed that the
account was active and the emails in question were not deleted from the account. The warrant
for Stone's email account was obtained on or about October 17,2017 and
executed shortly thereafter. The warrant for Stone's iCloud account (which contained the text
messages described above) was obtained on or about March 14, 2018 and executed shortly
thereafter.

Page 17 of 46
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communicated with Assange," as well as his statement on or about August 12, 2016 that he was

"in communication with Assange" but was "not at liberty to discuss what I have."

38. Stone testified that these public references to having a means of contacting

WikiLeaks referred exclusively to his contact with a journalist, who Stone described as a "go-

between, as an intermediary, as a mutual friend" of Assange. Stone declined to tell HPSCI the

name of this "intermediary," but he provided a description in his testimony that was largely

consistent with Credico. (On or about October 13,2017, Stone caused a letter to be submitted to

HPSCI that identified Credico by name as the "gentleman who confirmed for Mr. Stone" that

Assange had '" [e]mails related to Hillary Clinton which are pending pUblication. "').

39. In fact, documents recovered during the investigation (including those obtained

via search warrant returns ) show that Stone did not begin

communicating with Credico about Assange or WikiLeaks until on or about August 19,2016 9­

approximately eleven days after Stone first claimed on or about August 8, 2016 to "actually have

communicated with Assange" and a week after his August 12, 2016 statements of being "in

communication with Assange" and "not at liberty to discuss what I have."

40. When interviewed by the FBI, Credico stated that the first time he ever spoke

with Assange was on or about August 25, 2016, when Credico interviewed Assange. 10 Credico

also provided the FBI with partially redacted emails that he claimed were between he and

another member of WikiLeaks from on or about August 25, 2016, in which the two discuss the

9 As described above, on or about August 19, 2016, Credico informed Stone by text message that
Credico intended to interview Assange the following week. On or about August 25, 2016,
Credico interviewed Julian Assange for the first time, and on or about August 27, 2016, Credico
texted Stone that "Assange has kryptonite on Hillary."

10Credico was first interviewed by the FBI in or around August 2018. He has subsequently
participated in multiple voluntary interviews.

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technical logistics for the interview later that day. During the exchange, Credico offered

biographical information about himself, apparently as a means of introduction.

41. The FBI has not identified any communications between Stone and Credico from

August 2016 in which Stone directs Credico to contact Assange or WikiLeaks. When

interviewed by the FBI, Credico claimed he was never directed by Stone in August 2016 to

contact WikiLeaks.

42. In contrast, and as described above, the FBI has identified written

communications prior to August 8, 2016 in which Stone directed Corsi-not Credico-to contact

Assange. On or about July 25, 2016, for example, Stone wrote to Corsi, "Get to Assange [aJt

Ecuadorian Embassy in London and get the pending WikiLeaks emails ... they deal with

Foundation, allegedly." Similarly, on or about August 2, 2016, Corsi-not Credico-sent an

email to Stone in which Corsi wrote that "[w Jord is friend in embassy plans 2 more dumps,"

including one in October. These communications occurred days before Stone's first public

statement on or about August 8, 2016 claiming to be in communication with Assange. However,

at no time did Stone identify Corsi to HPSCI as another individual Stone contacted to serve as a

"go-between," "intermediary," or other source for information from WikiLeaks. Similarly,

Stone also never disclosed his written communications with Corsi to HPSCI when answering

HPSCI's questioning about the August 8, 2016 and August 12, 2016 statements about being in

communication with Assange.

Stone's Testimony About Communications to Assange

43. During his HPSCI testimony, Stone was asked, "Did you ask [the intermediary J to

communicate anything else to Assange?" Stone responded, "I did not." Stone was then asked,

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"Did you ask [the intermediary] to do anything on your own behalf?" Stone responded, "I did

not."

44. In fact, starting on or about September 18, 2016, Stone directed Credico to pass

on a request to Assange for documents that Stone believed would be damaging to the Clinton

Campaign.

a. According to text messages , on or about

September 18, 2016, Stone sent a text message to Credico that said, "I am e­

mailing u a request to pass on to Assange." On or about the same day, Stone

emailed Credico an article with allegations against then-candidate Clinton related

to her service as Secretary of State. Stone added, "Please ask Assange for any

State or HRC e-mail from August 10 to August 30 - particularly on August 20,

2011 that mention [the subject of the article] or confirm this narrative." (A copy

of this email was obtained through a search of Stone's email account

).

b. According to text messages , on or about

September 19, 2016, Stone texted Credico again, writing "Pass my message ... to

Assange." Credico responded, "I did." An email obtained from the account

shows that on or about September 20, 2016, Credico

forwarded the request to an attorney who had the ability to contact Assange;

Credico blind copied Stone on the same email.

Stone's Testimony About Written Communications with Credico

45. During his HPSCI testimony, Stone was asked repeatedly about his

communications with the person he identified as his intermediary. Stone stated that he had never

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communicated with his intermediary in writing in any way. During one exchange, Stone claimed

only to have spoken with the intermediary telephonically:

Q: [H]ow did you communicate the intermediary?

A: Over the phone.

Q: And did you have any other means of communicating with


the intermediary?

A: No.

Q: No text messages, no - none of the list, right?

A: No.

Later during his testimony, Stone again denied ever communicating with his intermediary in

writing:

Q: So you never communicated with your intermediary In


writing in any way?

A: No.

Q: Never emailed him or texted him?

A: He's not an email guy.

Q: So all your conversations with him were in person or over


the phone.

A: Correct.

46. As described above, Stone and Credico (whom Stone identified as his

intermediary) engaged in frequent written communication by email and text message. Beginning

on or about August 19, 2016, and continuing through the 2016 U.S. presidential election, Stone

and Credico engaged in dozens of communications by email or text message in which they

discussed WikiLeaks and the possible release of stolen documents that would be damaging to the

Clinton Campaign.

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47. Written communications between Stone and Credico continued up until Stone's

HPSCI testimony and afterwards. For example, on or about September 26, 2017-the day that

Stone testified before HPSCI and denied having ever sent or received emails or text messages

from his identified intermediary-Stone and Credico exchanged over thirty text messages.

48. Certain of the electronic messages between Stone and Credico (which Stone

denied ever taking place or possessing) would have been material to HPSCI, including Stone's

messages in or around September 2016 directing Credico to pass a request for documents to

Assange, and other relevant written communications with Credico. For example, on or about

January 6, 2017, Credico sent Stone an email, which Stone had in his possession at the time of

his HPSCI testimony, that had the subject line "Back channel bs." In the email, Credico wrote,

"Well I have put together timelines[] and you [] said you have a back-channel way back a month

before I had Assange on my show ... I have never had a conversation with Julian Assange other

than my radio show ... I have pieced it all together ... so you may as well tell the truth that you

had no back-channel or there's the guy you were talking about early August." (A copy of this

email was obtained through a search of Stone's email account ).

Stone's Testimonv About Communications with the Trump Campaign

49. During his HPSCI testimony, Stone was asked, "[d]id you discuss your

conversations with the intermediary with anyone involved in the Trump campaign?" Stone

answered, "I did not." As described above, Stone spoke to multiple individuals involved in the

Trump campaign about what he claimed to have learned from his intermediary to Assange,

including the following:

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a. As described above, Gates confirmed to investigators that Stone spoke with senior

Trump Campaign officials by telephone to inform them about materials possessed

by Assange and the timing of future releases.

b. According to text messages , on or about

October 3, 2016, Stone wrote to , "Spoke to my friend in London last night.

The payload is still coming."

c. As described above, on or about October 4, 2016, after receiving information

from Credico about the delay in WikiLeaks's release of stolen materials, Stone

emailed Bannon that Assange had a "[s]erious security concern" but would

release "a load every week going forward."

G. Stone's Attempts to Influence Credico Regarding HPSCI and the FBI

50. According to an email recovered through a court-authorized search of Stone's

email accountp . on or about October 19, 2017, Stone sent Credico an

excerpt of his October 13, 2017 letter to HPSCI in which Stone claimed Credico was his

"intermediary" to Assange. As described below, Credico repeatedly told Stone that his letter was

false and said he should correct his statement to HPSCI, but Stone did not do so. Stone then

engaged in a prolonged effort to prevent Credico from contradicting Stone's false statements to

HPSCI.

51. In or around November 2017, Credico received a request from HPSCI to testify

voluntarily before the committee. After being contacted by HPSCI, Credico spoke and texted

repeatedly with Stone.

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a. On or about November 19, 2017, Credico texted Stone that his lawyer wanted to

see him. Stone responded, '''Stonewall it. Plead the fifth. Anything to save the

plan' .. . Richard Nixon." (A copy of these text messages was recovered through

a court-authorized search of Stone's iCloud account). On or about November 20,

2017, Credico informed HPSCI that he declined HPSCl's request for a voluntary

interview.

b. On or about November 21, 2017, Credico texted Stone, "1 was told that the house

committee lawyer told my lawyer that I will be getting a subpoena." Stone

responded, "That was the point at which your lawyers should have told them you

would assert your 5th Amendment rights if compelled to appear." (A copy of

these text messages was recovered through a court-authorized search of Stone's

iCloud account).

c. On or about November 28, 2017, Credico received a subpoena compelling his

testimony before HPSCI. Credico informed Stone of the subpoena.

d. According to emails recovered from Stone's email account

, on or about November 30, 2017, Stone asked Corsi to

write publicly about Credico. Corsi responded, "Are you sure you want to make

something out of this now? Why not wait to see what [Credico] does? You may

be defending yourself too much - raising new questions that will fuel new

inquiries. This may be a time to say less, not more." Stone responded by telling

Corsi that Credico "will take the 5th-but let's hold a day."

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e. According to text messages recovered from Stone's iCloud account, on multiple

occasions, starting on or about November 17, 2017, Stone and Credico discussed

Frank Pentangeli. Frank Pentangeli is a character in the film The Godfather: Part

II, who falsely claims not to know critical information before a congressional

committee that he does in fact know. On or about December 1, 2017, Stone told

Credico in a text message to "Start practicing your Pentagele." When interviewed

by the FBI, Credico confirmed that he understood Stone's references to Frank

Pentangeli to be Stone's way of suggesting Credico withhold relevant information

from investigators.

f. On or about December 1, 2017, Stone texted Credico, "And if you turned over

anything to the FBI you're a fool." Later that day, Credico texted Stone, "You

need to amend your testimony before I testify on the 15th." Stone responded, "If

you testify you're a fool. Because of tromp I could never get away with a certain

[sic] my Fifth Amendment rights but you can. I guarantee you you are the one

who gets indicted for perjury if you're stupid enough to testify." (A copy of these

text messages was recovered through a court-authorized search of Stone's iCloud

account).

52. On or about December 12, 2017, Credico informed HPSCI that he intended to

assert his Fifth Amendment privilege against self-incrimination if required to appear by

sUbpoena. According to Credico, he invoked his Fifth Amendment privilege in part to avoid

providing evidence that would show Stone's previous testimony to Congress was false.

53. Following Credico's invocation of his Fifth Amendment privilege not to testify

before HPSCI, Stone and Credico continued to have discussions about the various investigations

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into Russian interference in the 2016 election and what infonnation Credico would provide to

investigators. During these conversations, Stone repeatedly made aggressive statements intended

to prevent Credico from cooperating with the investigations. For example:

a. On or about December 24, 2017, Credico texted Stone, "I met assange for f[i]rst

time this yea[r] sept 7 ... docs prove that ... You should be honest w fbi ...

there was no back channel ... be honest." Stone replied approximately two

minutes later, "I'm not talking to the FBI and if your smart you won't either." (A

copy of these text messages was recovered through a court-authorized search of

Stone's iCloud account).

b. On or about April 9,2018, Stone wrote in an email to Credico, "You are a rat.

You are a stoolie. You backstab your friends-run your mouth my lawyers are

dying Rip you to shreds." Stone also said he would "take that dog away from

you," referring to Credico's dog. On or about the same day, Stone wrote to

Credico, "I am so ready. Let's get it on. Prepare to die [expletive]." (A copy of

this email exchange was recovered through a court-authorized search of Stone's

email account ).

c. On or about May 21, 2018, Credico wrote in an email to Stone, "You should have

just been honest with the house Intel committee ... you've opened yourself up to

perjury charges like an idiot." Stone responded, "You are so full of [expletive].

You got nothing. Keep running your mouth and I'll file a bar complaint against

your friend [the attorney who had the ability to contact the head of Assange]."

(A copy of this email exchange was recovered through a court-authorized search

of Stone's email account ). Credico believed Stone knew

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that Credico was sensitive to having this friend's name publicly disclosed.

H. Missing Electronic Communications and Stone's Use of Encrypted Communications

54. As described above, the government has recovered the content of many of Stone's

electronic communications from summer and fall of 2016 (during the period of the U.S.

presidential election) and afterward (during the period of pending congressional investigations

into Russian interference in the U.S. election). However, the government is aware of the

existence of numerous other relevant electronic communications, the content of which it has not

yet been able to recover.

55. As described above, during his HPSCI testimony, Stone falsely denied having

emailed or exchanged text messages with his "intermediary" (later identified by Stone as Randy

Credico). In fact, emails and text messages recovered in this investigation show the two

communicated frequently by email and text messages; court-authorized searches of Stone's

email and iCloud accounts confirm that Stone still had those communications at the time he

testified in or around September 2017. In numerous communications, Stone and Credico

discussed Julian Assange and WikiLeaks, as well as Stone's suggestion that Credico was his

intermediary to Assange. These communications appear relevant and responsive to HPSCI's

inquiry, but Stone never disclosed them.

56. In addition to these emails and text messages in the FBI's possession, the FBI has

reviewed telephone billing records for Stone's cellular telephone for the years 2016 and 2017,

and they show text message communications whose content that the government to date has not

been able to obtain. For example, these records indicate that Stone and Credico alone exchanged

thousands of text messages (including over 1,500 text messages between the period November

2016 and December 2017) the substance of which the government to date has not recovered or

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reviewed. The government has only recently obtained text messages between Stone and Credico

during some period of the campaign in 2016 from Stone's subpoena production, issued after

media reports in November 2018 stated that Stone's attorneys were able to extract text messages

between Stone and Credico from a phone Stone stopped using in 2016. But the government does

not have, for the same time period, many of Stone's other text messages. The government seeks

these text messages believing they may show additional evidence of (1) the falsity of Stone's

HPSCI testimony concerning his communications with his "intermediary" and (2) efforts to

corruptly persuade Credico not to cooperate with pending investigations.

57. Additionally, the FBI has interviewed mUltiple associates of Stone, who

confirmed that Stone has used encrypted applications to communicate with others. Similarly,

records obtained in this investigation indicate Stone uses multiple applications designed for

encrypted communication, including (a) WhatsApp, II (b) Signal,12 (c) Wickr,13 and (d)

II According to open sources, WhatsApp is an application that allows the user to send text
messages, make voice calls, and transmit documents. WhatsApp uses end-to-end encryption and
stores its messages separately from those text messages used on a mobile device's default
message application.

12 According to open sources, Signal is an encrypted communications application allowing the


user to send one-to-one and group messages, which can include files, voice notes, images and
videos, and make one-to-one voice and video calls. Signal uses standard cellular mobile
numbers as identifiers, and uses end-to-end encryption to secure all communications to other
Signal users. Signal also allows users to set timers to messages, after which the messages will be
deleted from both the sender's and the receivers' devices.

13 According to open sources, Wickr is an instant messaging application that allows users to
exchange end-to-end encrypted and content-expiring messages, including photos, videos, and file
attachments and place end-to-end encrypted video conference calls. Like Signal, Wickr allows
users to set an expiration time for their encrypted communications. In addition to encrypting
user data and conversations, Wickr claims that its application strips metadata from all content
transmitted through the network.

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14
ProtonMail. To date, the FBI has not obtained any of Stone's communications conducted

through these applications.

a. According to records from Stone's iCloud account, a copy of the WhatsApp

application was downloaded to an iPhone registered to Stone on or about October

5,2016. As described above, on or about October 4,2016, Stone suggested in an

email to that they "talk on a secure line" and proposed using

WhatsApp.

b. According to records from Stone's iCloud account, a copy of the Signal

application was downloaded to an iPhone registered to Stone on or about August

18,2016. Additionally, text messages recovered from Stone's iCloud account

revealed that on or about November 15, 2016, Stone sent an attorney with the

ability to contact Julian Assange a link to download the Signal application. IS

Approximately fifteen minutes after sending the link, Stone texted the attorney,

"I'm on signal just dial my number." The attorney responded, "I'll call you."

c. According to records from Stone's iCloud account, a copy of the ProtonMail

application was downloaded to an iPad registered to Stone on or about August 18,

2016.

14 According to open sources, ProtonMail is an end-to-end encrypted email service that uses
client-side encryption to protect email contents and user data before they are sent to ProtonMail
servers. According to its website, ProtonMail is run by Proton Technologies AG, a company
based in the Canton of Geneva, and its servers are located at two locations in Switzerland,
outside of US and EU jurisdiction.

IS This attorney was a close friend of Credico's and was the same friend Credico em ailed on or
about September 20, 2016 to pass along Stone's request to Assange for emails connected to the
allegations against then-candidate Clinton related to her service as Secretary of State.

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d. According to records from Stone's iCloud account, a copy of the Wickr

application was downloaded to an iPhone to Stone on or about August

201

58. Based on training electronic using encrypted

applications such as WhatsApp, ProtonMail, and Wickr are sometimes maintained on the

used to send and receive communications. Communications from

applications can be obtained by law enforcement by searching the device either manually or via a

data extraction device (such as Cellebrite). of physical device can messages,

including text messages messages exchanged over WhatsApp, Signal, ProtonMail,

Wickr, that have not been up to cloud accounts (such as an iCloud account).

Additionally, of the downloaded application can reveal evidence

encrypted communications, such as logs and contact lists.

The to seek 1...,.""1",, of communications and contacts

during the period of the 2016 U.S. presidential and through the The

believes communications may contain evidence of additional communications concerning

"",,,,11""''-', WikiLeaks, and the of documents damaging to the Clinton Campaign.

Such communications could constitute additional evidence of Stone's to obstruct

HPSCI's investigation showing additional contacts and communications and

WikiLeaks that Stone failed to disclose.

I. Other Relevant Records

60. On or about May 8, 2018, a law interview of

was conducted. was an employee of Stone's from approximately June 2016

through approximately December 16 and resided Stone's New York apartment for

30

Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 42 of 57

a period of time. provided infonnation technology support for Stone but was not fonnally

trained to do so. was aware that Stone communicated with Trump during the 2016

presidential campaign, and afterward, both in person and by telephone. provided

infonnation about a meeting at Trump Tower between Trump and Stone during the time

worked for him, to which Stone carried a "file booklet" with him. Stone told the file

booklet was important and that no one should touch it. also said Stone maintained the file

booklet in his closet.

61. On or about December 3,2018, law enforcement conducted an interview of an

individual ("Person 2") who previously had a professional relationship with a reporter who

provided Person 2 with information about Stone. The reporter relayed to Person 2 that in or

around January and February 2016, Stone and Trump were in constant communication and that

Stone kept contemporaneous notes of the conversations. Stone's purpose in keeping notes was to

later provide a "post mortem of what went wrong."

J. The Subject Premises

62. Your affiant is aware through the investigation that Stone maintains the Subject

Premises as his personal office and has done so since at least the 2016 Campaign. Public

reporting indicates that Stone occupied SUbject Premises as his office during the 2016

Campaign. 16 An April 17,2017 news article also described Stone's "personal office" at a

location matching the description of the Subject Premises. 17

16 See Roger Stone.' Inside The World Of A Political Hitman, CBS Miami, April 17, 2016,
available at https:llmiami.cbslocal.comJ20 16/04117lroger-stone-inside-the-world-of-a-political­
hitmanl ("CBS4's Jim DeFede has known Stone for years and visited him recently at his office in
a nondescript building in an industrial section of Oakland Park that houses his collection of
Nixon memorabilia.").

17 See Roger Stone Helped Donald Trump Get Elected President - Now He's Helping Himself,
Washington Post, April 19, 2017, available at https:llwww.washingtonpost.comJlifestyle/style/

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Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 43 of 57

63. to recovered court-authorized search

iCloud above), on or about 31, 2014 with the

lease for your signature," address of Subject

(The recovered contained no further content). On or about November 27, 2017, Stone

sent another individual address of the Subject Premises while arranging a meeting.

64. text show that has repeatedly identified the

Premises as office.

a. On or March 30, 201 Stone directed another individual to send a reporter

"to office." When the other individual asked , Stone ..",<,,,,,,,,,,1'1,:.1'1

in "Oakland " which corresponds to the address of the

Premises.

b. On or about April 8,2017, Stone exchanged with an individual who

identified as " a freelance photographer Washington

In the exchange, the photographer wrote he "would like to photograph you

first thing morning ... April 11 if that is convenient." Stone responded,

"Yes - let me figure out " The photographer then wrote that "[t]he

your that would a good location me." replied,

which is ofthe Subject Premises.

roger-stone-a-master-of-dark-political-arts-is-playing-the-russia-scandal-for-all-its-worth ("The
next part of the directions to his personal and broadcast studio calls for locating a "door
marked ' " which helpful, the crucial that there is no
discreetly "A" at the new next to a supplies There is,
a blacked-out door with no markings, and the man who emerges behind it, shorts,
loafers with no socks, a loosened tie and an untucked dress shirt, is unmistakably
").

Page 46
Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 44 of 57

In text from Stone's refers to the Subject

Premises as a "warehouse." or about July 25, 15, wrote another individual,

"Warehouse has very high cable if u want to use ' office. '" On or about

November 10,2017, Stone wrote an individual, "U don't need an speed [inter] net at

our warehouse avail "

66. On or about May 18, 2018, investigators interviewed an individual ("Person 1")

described himself as m summer 1 stated that

as of May 2018, he worked at hours a week for Stone. Communications recovered

from Stone's account communicated with duration of the

Campaign and afterwards through May 18. Those communications included matters related to

the 2016 Campaign and media presence.

67. Person 1 told that as of May 2018, he out of Stone's

home in Florida or at Fort Lauderdale (the ....p ..,"£'on 1 further

that Stone in the Subject

68. During of the Subject on or about January 17,

2019, the FBI observed enter the Subject Premises. Stone was accompanied by two

individuals believed to host a The following photographs (wearing a light

button-down shirt and tie) Subject Premises was taken on

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Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 45 of 57

K. Computer Devices at the Subject Premises

69. Based on law enforcement interviews, your affiant is aware that Stone has used

and uses cellular telephones, desktop, and laptop computers to conduct electronic

communications. Stone also configures his computers to create regulars backups.

70. As described above, in text messages recovered from Stone's iCloud account,

Stone indicated the Subject Premises has high-speed internet service (referred to as having "very

high speed cable" and "high speed net").

71. As described above, on or about April 8, 2017, Stone and a photographer hired by

the Washington Post agreed to meet at the Subject Premises on or about April 11, 2017 in order

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Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 46 of 57

for the photographer to photograph Stone. On or about April 19, 2017, the Washington Post

published a lengthy article about Stone that featured the following two photographs 18:

18"Roger Stone Helped Donald Trump Get Elected President - Now He's Helping Himself,"
Washington Post, Apr. 19, 2017, available at https://www.washingtonpost.comllifestyle/style/
roger-stone-a-master-of-dark-political-arts-is-playing-the-russia-scandal-for-all-its-worthl2017/
041l81l518184e-236f-lle7-b503-9d616bd5a305 _story.html?utm_term=. 7576648d5cel.

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Both photographs were credited to the photographer with the first name " ," and the

caption of the latter photograph read in part, "Stone in his memorabilia-overrun office." The

photographs depict, among other things, multiple computer accessories, including a monitor,

microphone, and printer.

72. In addition, messages recovered from the court-authorized search of Stone's

iCloud account show that since January 1, 2017, Stone has granted interviews over Skype from

his office, further indicating he likely has a computer present there. 19 For example, on or about

December 13, 2017, Stone coordinated an upcoming interview with another individual by text

message. Stone confirmed the interview, writing that he would participate via "Skype from our

Florida studio with green screen."

73. In or around May 2018, as discussed above, the FBI interviewed Person 1, who

worked for Stone. Person 1 told the FBI that Stone maintained a computer at the Subject

Premises.

74. In or around May 2018, the FBI interviewed an individual (Person 2) who

provided information technology services to Stone. Person 2 stated that Stone used the Apple

Time Machine ("Time Machine") application to facilitate backups of his computers. According

to publicly available information, Time Machine is the built-in backup feature of Apple

computers and can create copies of files on a computer, including applications, music, photos,

email,documents, and system files. A Time Machine backup allows users to restore files from a

specific point in time if the original files are ever deleted, or if the hard drive is erased or

19 According to publicly available information, Skype is a telecommunications application


software that specializes in providing video chat and voice calls between computers, tablets,
mobile devices, and similar devices via the internet.

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replaced. In order to create backups with Time Machine, a user connects an external storage

device to the computer and selects that external storage device as the backup disk,zo

75. Records produced by AT&T show that,

since 2016, Stone has had multiple Apple iPhone devices registered to his personal cellular

telephone number (ending in . According to AT&T, between approximately January 1,

2015 and November 14, 2016, Stone's telephone number was registered to an Apple iPhone

model 5s ("iPhone 5s") (IMSI 310410657061814). On or about November 14,2016, Stone's

cellular telephone number was transferred to an Apple iPhone model 7 ("iPhone 7") (IMSI

310410930460769). On or about September 28, 2018, Stone's cellular telephone number was

transferred to an Apple iPhone model XS ("iPhone XS") (IMSI 310410155529814).

76. Records produced by Uber Technologies, Inc.,

show that the account associated with Stone's telephone number and email address has the Uber

application on multiple devices, including a device identified as iPhone11,2, UDID - 668EDC66­

29BF-4AD2-8BCA-D974C7906597. Publicly available information indicates that the identifier

"iPhonel1,2" correlates to an Apple iPhone model XS. Additionally, the subpoena returns

identified a device identified as iPhone9,4, UDID - 7161 CF59-6Fl 0-41 C8-984B­

DE08401 EDA 74. Publicly available information indicates that the identifier iPhone9,4

correlates to an Apple iPhone model iPhone 7 Plus.

77. Records obtained from a court-authorized pen register/trap & trace ("PRTT")

monitoring of Stone's personal cellular telephone number 21 shows recent activity

20 When the external is plugged in, the Time Machine will automatically make hourly backups
for the past 24 hours, daily backups for the past month, and weekly backups for all previous
months. The oldest backups are deleted when the external storage device selected as the backup
disk is full. The external device can be as small as a USB thumb drive.

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indicating Stone continues to use the number and its associated device. For

records show that between January 1, 19 January 10, 2019, telephone number was

to make or receive over 150 calls and send or receive over text

Likewise, a court-authorized WhatsApp account (which is to

number 2 WhatsApp account was or

13 WhatsApp two WhatsApp voice calls on or

January 1,2019 and January 10,2019.

78. Statements attributed to in recent media articles also indicate that

retains computer devices that he no longer uses and keeps relevant electronic communications on

those devices. In or around November 18, media reports began to publish excerpts text

messages between Stone and Randy that occurred during the 2016 U.S.
23
text messages subsequently were from Stone

According to these news messages to the

were "a cell phone he stopped using in 16."

on these statements, your the cellular telephone referenced in to

the iPhone 5s documented AT &T records (which records indicate

21 Installation and use of PRTT was authorized by the U.S. District Court
District of Columbia on or about 18. Case No.1: 18-pr-l
2018).

22 Installation and use of PRTT devices WhatsApp account was authorized


District Court for the District on or about December 11, 2018.
(D.D.C. Dec. 11,2018).
23
e.g., "Bombshell Stone's Claims About
Backchannel," Daily 14, 2018, available at
https:lldailycaller.coml20 18/11 114/roger-stone-wikileaks-randy-credico-mueller.

38

Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 50 of 57

stopped using on or about November 14, 2016).24 Further, your affiant believes Stone maintains

other devices he is no longer actively using.

COMPUTERS, ELECTRONIC STORAGE, AND FORENSIC ANALYSIS

79. As described above and in Attachment B, this application seeks permission to

search for records that might be found in the Subject Premises, in whatever form they are found.

One form in which the records might be found is data stored on a computer device's hard drive

or other storage media. Thus, the warrant applied for would authorize the seizure of electronic

storage media or, potentially, the copying of electronically stored information, all under Rule

41 (e)(2)(B).

80. Probable cause. I submit that if a computer or storage medium is found on the

Subject Premises, there is probable cause to believe those records will be stored on that computer

or storage medium, for at least the following reasons:

a. Based on my knowledge, training, and experience, I know that computer files or

remnants of such files can be recovered months or even years after they have been

downloaded onto a storage medium, deleted, or viewed via the Internet.

Electronic files downloaded to a storage mediwn can be stored for years at little

or no cost. Even when files have been deleted, they can be recovered months or

years later using forensic tools. This is so because when a person "deletes" a file

on a computer, the data contained in the file does not actually disappear; rather,

that data remains on the storage medium until it is overwritten by new data.

24 , Stone produced some text messages between he and


Credico; the latest-in-time text message produced by Stone occurred on or about November 14,
2016. The government believes copies of later-in-time text messages from late 2016 and early
2017 could be located on another device, such as the iPhone 7 described above, or on backup
storage media.

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b. Therefore, deleted files, or remnants of deleted files, may reside in free space or

slack space-that is, in space on the storage medium that is not currently being

used by an active file-for long periods of time before they are overwritten. In

addition, a computer's operating system may also keep a record of deleted data in

a "swap" or "recovery" file.

c. Wholly apart from user-generated files, computer storage media-in particular,

computers' internal hard drives-contain electronic evidence of how a computer

has been used, what it has been used for, and who has used it. To give a few

examples, this forensic evidence can take the form of operating system

configurations, artifacts from operating system or application operation, file

system data structures, and virtual memory "swap" or paging files. Computer

users typically do not erase or delete this evidence, because special software is

typically required for that task. However, it is technically possible to delete this

information.

d. Similarly, files that have been viewed via the Internet are sometimes

automatically downloaded into a temporary Internet directory or "cache."

81. Forensic evidence. As further described in Attaclunent B, this application seeks

permission to locate not only computer files that might serve as direct evidence of the crimes

described on the warrant, but also for forensic electronic evidence that establishes how

computers were used, the purpose of their use, who used them, and when. There is probable

cause to believe that this forensic electronic evidence will be on any storage medium in the

Subject Premises because:

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a. Data on the storage medium can provide evidence of a file that was once on the

storage medium but has since been deleted or edited, or of a deleted portion of a

file (such as a paragraph that has been deleted from a word processing file).

Virtual memory paging systems can leave traces of information on the storage

medium that show what tasks and processes were recently active. Web browsers,

e-mail programs, and chat programs store configuration information on the

storage medium that can reveal information such as online nicknames and

passwords. Operating systems can record additional information, such as the

attachment of peripherals, the attachment of USB flash storage devices or other

external storage media, and the times the computer was in use. Computer file

systems can record information about the dates files were created and the

sequence in which they were created, although this information can later be

falsified.

b. As explained herein, information stored within a computer and other electronic

storage media may provide crucial evidence of the "who, what, why, when,

where, and how" of the criminal conduct under investigation, thus enabling the

United States to establish and prove each element or alternatively, to exclude the

innocent from further suspicion. In my training and experience, information

stored within a computer or storage media (e.g., registry information,

communications, images and movies, transactional information, records of

session times and durations, internet history, and anti-virus, spyware, and

malware detection programs) can indicate who has used or controlled the

computer or storage media. This "user attribution" evidence is analogous to the

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Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 53 of 57

search for "indicia of occupancy" while executing a search warrant at a residence.

The existence or absence of anti-virus, spyware, and malware detection programs

may indicate whether the computer was remotely accessed, thus inculpating or

exculpating the computer owner. Further, computer and storage media activity

can indicate how and when the computer or storage media was accessed or used.

For example, as described herein, computers typically contains information that

log: computer user account session times and durations, computer activity

associated with user accounts, electronic storage media that connected with the

computer, and the IP addresses through which the computer accessed networks

and the internet. Such information allows investigators to understand the

chronological context of computer or electronic storage media access, use, and

events relating to the crime under investigation. Additionally, some information

stored within a computer or electronic storage media may provide crucial

evidence relating to the physical location of other evidence and the suspect. For

example, images stored on a computer may both show a particular location and

have geolocation information incorporated into its file data. Such file data

typically also contains information indicating when the file or image was created.

The existence of such image files, along with external device connection logs,

may also indicate the presence of additional electronic storage media (e.g., a

digital camera or cellular phone with an incorporated camera). The geographic

and timeline information described herein may either inculpate or exculpate the

computer user. Last, information stored within a computer may provide relevant

insight into the computer user's state of mind as it relates to the offense under

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investigation. For example, information within the computer may indicate the

owner's motive and intent to commit a crime (e.g., internet searches indicating

criminal planning), or consciousness of guilt (e.g., running a "wiping" program to

destroy evidence on the computer or password protecting/encrypting such

evidence in an effort to conceal it from law enforcement).

c. A person with appropriate familiarity with how a computer works can, after

examining this forensic evidence in its proper context, draw conclusions about

how computers were used, the purpose of their use, who used them, and when.

d. The process of identifying the exact files, blocks, registry entries, logs, or other

forms of forensic evidence on a storage medium that are necessary to draw an

accurate conclusion is a dynamic process. While it is possible to specify in

advance the records to be sought, computer evidence is not always data that can

be merely reviewed by a review team and passed along to investigators. Whether

data stored on a computer is evidence may depend on other information stored on

the computer and the application of knowledge about how a computer behaves.

Therefore, contextual information necessary to understand other evidence also

falls within the scope of the warrant.

e. Further, in finding evidence of how a computer was used, the purpose of its use,

who used it, and when, sometimes it is necessary to establish that a particular

thing is not present on a storage medium. For example, the presence or absence

of counter-forensic programs or anti-virus programs (and associated data) may be

relevant to establishing the user's intent.

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82. Necessity ofseizing or copying entire computers or storage media. In most cases,

a thorough search of a premises for information that might be stored on storage media often

requires the seizure of the physical storage media and later off-site review consistent with the

warrant. In lieu of removing storage media from the premises, it is sometimes possible to make

an image copy of storage media. Generally speaking, imaging is the taking of a complete

electronic picture of the computer's data, including all hidden sectors and deleted files. Either

seizure or imaging is often necessary to ensure the accuracy and completeness of data recorded

on the storage media, and to prevent the loss of the data either from accidental or intentional

destruction. This is true because of the following:

a. The time required for an examination. As noted above, not all evidence takes the

form of documents and files that can be easily viewed on site. Analyzing

evidence of how a computer has been used, what it has been used for, and who

has used it requires considerable time, and taking that much time on premises

could be unreasonable. As explained above, because the warrant calls for forensic

electronic evidence, it is exceedingly likely that it will be necessary to thoroughly

examine storage media to obtain evidence. Storage media can store a large

volume of information. Reviewing that information for things described in the

warrant can take weeks or months, depending on the volume of data stored, and

would be impractical and invasive to attempt on-site.

b. Technical requirements. Computers can be configured in several different ways,

featuring a variety of different operating systems, application software, and

configurations. Therefore, searching them sometimes requires tools or knowledge

that might not be present on the search site. The vast array of computer hardware

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9 I' Case 1:19-mc-00029-CRC Document 29-34 Filed 04/28/20 Page 56 of 57

and software available makes it difficult to know before a search what tools or

knowledge will be required to analyze the system and its data on the Premises.

However, taking the storage media off-site and reviewing it in a controlled

environment will allow its examination with the proper tools and knowledge.

c. Variety of forms of electronic media. Records sought under this warrant could be

stored in a variety of storage media formats that may require off-site reviewing

with specialized forensic tools.

83. Nature of examination. Based on the foregoing, and consistent with Rule

41(e)(2)(B), the warrant I am applying for would permit seizing, imaging, or otherwise copying

storage media that reasonably appear to contain some or all of the evidence described in the

warrant, and would authorize a later review of the media or information consistent with the

warrant. The later review may require techniques, including but not limited to computer-assisted

scans of the entire medium, that might expose many parts of a hard drive to human inspection in

order to determine whether it is evidence described by the warrant.

84. Because multiple people share the Subject Premises as a residence, it is possible

that the Subject Premises will contain storage media that are predominantly used, and perhaps

owned, by persons who are not suspected of a crime. If it is nonetheless determined that that it is

possible that the things described in this warrant could be found on any of those computers or

storage media, the warrant applied for would permit the seizure and review of those items as

well.

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FILTER REVIEW PROCEDURES

85. Review of the items described in Attachment B will be conducted pursuant to

established procedures designed to collect evidence in a manner consistent with professional

responsibility requirements concerning the maintenance of attorney-client and other operative

privileges. The procedures include use of a designated "filter team," separate and apart from the

investigative team, in order to address potential privileges.

CONCLUSION

86. Based on the foregoing, your affiant respectfully requests that this Court issue a

search warrant for the Subject Premises, more particularly described in Attachment A,

authorizing the seizure of the items described in Attachment B.

Respectfully submitted,

. A. Heide
Special Agent
Federal Bureau of Investigation

Sworn and subscribed before me on thisJ.-Y day of January, 2019.

)f~J, ~
L.4tfRANA S. SNOW
UNITED STATES MAGISTRATE JUDGE

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