Christopher Steele Testimony in Gubarev Lawsuit

Gubarev and others v Orbis Business Intelligence Ltd and another
Day 4
July 23, 2020
Opus 2 - Official Court Reporters
Phone: 0203 008 6619

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July 23, 2020 Gubarev and others v Orbis Bus [...] s Intelligence Ltd and another Day 4
1 Thursday, 23 July 2020 1 doubt?

2 (9.44 am) 2 A. Deputy Assistant Secretary of State for Europe and
3 Housekeeping 3 Central Eurasia , I believe .
4 MR JUSTICE WARBY: Yes, Mr Caldecott. 4 Q. Right. Now you had a colleague there , didn’ t you?
5 MR CALDECOTT: My Lord, I understand that, it may be more in 5 A. Yes.
6 the hope than in expectation , but the EPE is working at 6 Q. And is that Tatiana, who we see referred to in the
7 the moment. 7 notes?
8 MR JUSTICE WARBY: Yes, and is the link to court 72 working? 8 A. It is , yes .
9 MR CALDECOTT: I think it is working, but with the usual 9 Q. Did she take notes during the meeting?
10 concerns about it possibly being sporadic . 10 A. No, she didn’ t .
11 MR JUSTICE WARBY: Yes. Well, at the moment there’s only 11 Q. What was she there for?
12 one person in court 72, and that ’ s the young lady who 12 A. She was accompanying me on the trip.
13 has been attending throughout. 13 Q. But wouldn’t you want a note of a meeting of this
14 MR CALDECOTT: Yes. 14 importance?
15 MR JUSTICE WARBY: And it seems to me, and I have had it 15 A. We were not taking notes in America at all during that
16 confirmed by court staff , that there is room for one 16 visit .
17 person to come in, so I ’m going to vary the order on the 17 Q. Well? Let’ s just remind ourselves of what notes were
18 pre - trial review accordingly , and if more people turn up 18 being taken or the notes that we do have about this
19 with an interest in being here , then we may have to 19 meeting, because I think it ’ s only fair that one is
20 revisit it and there may be a balloon debate about who 20 careful about which are contemporaneous and which are
21 leaves in order to make space for someone else but, as 21 not.
22 I ’ve indicated , I don’t wish to take time on this . 22 Could we please have bundle E1 {E/37/117}. Yes,
23 MR CALDECOTT: No. My Lord, one other very small point, 23 I apologise , it ’ s 96, I ’ve got a reference to the
24 because of the sensitivities of where we are, if 24 internal numbering. It ’ s {E/37/96} we want.
25 your Lordship sees people using their mobile phones 25 Now, if you look , please , just below halfway ,
1 3
1 they ’ re only using it for hotspots to assist on the 1 there ’ s quite a slim paragraph before a row of bullet
2 document, but I thought I should mention it just so 2 points , and there ’ s a reference there to notes of the
3 your Lordship is aware. 3 meeting taken by State Department staff .
4 MR JUSTICE WARBY: Thank you. Right. Let’s just wait for 4 MR JUSTICE WARBY: I’m not sure we’re on the right page.
5 Ms Knight to be brought in . It shouldn’ t take too long . 5 MR CALDECOTT: Page 96. {E/37/96} bundle page 96, please.
6 MR CALDECOTT: Yes. 6 That’s it .
7 (Pause). 7 MR JUSTICE WARBY: It is the right one?
8 MR JUSTICE WARBY: It looks as though there are three or 8 MR CALDECOTT: It is the right one, yes. Just above the
9 four spaces at the back at the moment, unless your teams 9 bullet points :
10 are going to be enlarged during the day, that should be 10 "Notes of the meeting taken by State Department
11 enough. 11 staff reflect ..."
12 Yes, Mr Caldecott. 12 And we’ll see that those are plainly contemporaneous
13 MR CHRISTOPHER STEELE (continued) 13 manuscript notes .
14 Cross-examination by MR CALDECOTT (continued) 14 Now, there are also some notes taken by Kathleen
15 MR CALDECOTT: Just to pick up where we were, Mr Steele, 15 Kavalec?
16 meeting with the FBI, 3 October, we’ve dealt with that . 16 A. Can I just say , she was the only official in the meeting
17 A message from you offering yourself for a meeting on 17 so she must have taken all of the notes .
18 6 October with the State Department, and on 11 October, 18 Q. Thank you, that’ s very helpful , so she may have taken
19 this is where we had got to, the meeting takes place . 19 the manuscript notes as well .
20 First of all , as to who was there, Kathleen Kavalec 20 If we look at page 97, the next page. Sorry , just
21 was the senior State Department representative there . 21 to go to {E/37/98}, please, the first new paragraph:
22 Like a lot of these State Department people, she has 22 "In anticipation of an FBI interview , Kavalec said
23 a very long title , but we can see at {A/7/3} that she’s 23 she prepared a typewritten summary of the meeting within
24 an Assistant Secretary of State with a particular 24 1 to 2 weeks after talking with the liaison ."
25 interest or expertise in Russia , among other things, no 25 So that ’ s just to set out the different times when
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1 these notes were made. 1 Washington Post and the New York Times that day,
2 Now, can we please go to {E/35/1} in the same 2 I believe .
3 volume, that ’ s volume 1 if we’re looking at hard copies , 3 Q. What did you mean by the word "managing"?
4 tab 35, page 1. Thank you. Then can I just read the 4 A. I don’t think I said the word "managing", I think that ’ s
5 background at the top of that note: 5 her word.
6 "Orbis undertook the investigation into the 6 Q. Can we go back to page 5, please {E/35/5}, and I don’t
7 Russia/Trump connection at the behest of an institution 7 propose to go through this because we can trace it all
8 he declined to identify that had been hacked." 8 to various reports , you’ve been discussing some of the
9 Just pausing there , that ’ s right that you didn’ t in 9 allegations in the reports , and about a third of the way
10 fact identify the Democratic Party campaign team was 10 down on page 5, you will see the words:
11 your ultimate client , nor did you identify Perkins Coie? 11 "June - - reporting started ."
12 A. I think that ’ s right , yes . 12 And then you will see the words:
13 Q. "The institution approached them based on the 13 "NYT and WP have."
14 recommendation of Glenn Simpson and Peter Fritsch 14 Now, did you tell them that the New York Times and
15 ( specialists in economic crime, formerly of the [Wall 15 the Washington Post have your intelligence ?
16 Street Journal ])..." 16 A. Again, I don’t remember my exact words, but I might have
17 And then these words: 17 said that we had briefed them at an earlier stage .
18 "... and is keen to see this information come to 18 Q. It doesn’t suggest a mere briefing on generalities , does
19 light prior to November 8." 19 it ?
20 Now that was, indeed, was it not, the position of 20 A. I don’t know.
21 Fusion, that they did want your information to come to 21 (Pause).
22 light prior to November 8? 22 Q. Did you get the question?
23 A. I think that ’ s right , yes . 23 A. Yes, if the question - - I have no reason to believe that
24 Q. And that was a view I suggest you shared? 24 at that stage either the New York Times or the
25 A. Yes, but only through the government structure it ’ s come 25 Washington Post had any of my memoranda.
5 7
1 to light . 1 Q. No, that wasn’t quite the question I put to you. This
2 Q. Can we just test that a little bit , please , by just 2 doesn’t suggest that you had merely been briefing them
3 looking next at the manuscript notes . 3 on generalities , does it ?
4 They start on page 3 of the tab same, that ’ s 4 MR JUSTICE WARBY: Well, he answered that question. He said
5 {E/35/3}, and you will see in the top right -hand corner 5 "I don’t know".
6 in the American dating, 11 October 2016. Now, at one 6 MR CALDECOTT: Oh, did he? I’m sorry, I didn’t catch it .
7 point - - and Mr Winer was there as well , as we see from 7 Why did you raise the media with the State
8 the top of that page. 8 Department?
9 A. He was there for the beginning and the end of the 9 A. I ’m not sure whether I raised it or whether they raised
10 meeting but not for the majority of it . He left to do 10 it with me, I can’t remember.
11 other business . 11 Q. Now, I think it ’ s also on 11 October that you briefed
12 Q. May I first of all ask you a question or two about 12 three media institutions this time. Am I right that
13 {E/35/7}, where it looks as though you are talking about 13 they were the New York Times, the Washington Post and
14 four issues that you’re having to manage, and if you 14 Yahoo News?
15 look in the middle of that page it says : 15 A. Yes.
16 " Client needs". 16 Q. Now, you don’t mention Yahoo News in this briefing ; why
17 And that’s presumably a mix of Fusion and the 17 is that?
18 ultimate clients . 18 A. I don’t know whether I did or not.
19 "FBI." 19 Q. Now, there had been no reports published , no new
20 And then: 20 reports , between the briefing of 22 September and the
21 "[Washington Post/New York Times]" 21 briefing on 11 October.
22 And then "Source protection ". 22 I suggest you don’t have a second meeting with the
23 Now, did you raise those as matters you were having 23 same journalist from the same media organisations to
24 to deal with at that meeting? 24 discuss generalities . Do you accept that?
25 A. I don’t recall exactly , but we were due to meet the 25 A. There had been various events taking place on the
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1 ground. I don’t recall exactly what had intervened . 1 paragraph 39, please .
2 Q. What I suggest you were doing is you were briefing them 2 Now on this account you first hear from him out of
3 on details , on the detailed allegations . Yes? 3 the blue in August 2016 and you just see that in the
4 A. No, I don’t accept that . 4 third line in paragraph 39:
5 Q. And they must have come, I assume, with various queries 5 "In August 2016, Mr Talbott telephoned me at Orbis’ s
6 which you sought to answer? 6 office in London out of the blue and told me that he
7 A. Steven Lee Myers of the New York Times was a new person 7 understood, by clear implication , from senior contacts
8 we had been introduced to because he was an expert on 8 at the US State Department that we had been working on
9 Russia as opposed to the previous two, my Lord, who we 9 a project concerning Russian interference in the US
10 had met with earlier , who weren’t, Mr Sanger and 10 elections ."
11 Mr Lichtblau. 11 We then have three paragraphs about Mr Winer. And
12 Q. Now, you may not be able to help on this but I think 12 then at paragraph 43 {C/7/11}, you have a conversation
13 it ’ s right I should just mention it , {E/106/5}, please. 13 with Sir Andrew and you telephone Mr Talbott to request
14 Sorry , page 4. This is an article by a gentleman called 14 his advice . So is it right that there is no activity
15 Paul Wood at the BBC, you’ll see that on page 1. If you 15 from Mr Talbott in relation to these matters between his
16 kindly go to {E/106/4}: 16 call to you in August and your decision after
17 " Several sources have told me late last year Steele 17 consultation with Sir Andrew to contact him at the very
18 himself grew increasingly disillusioned with the FBI’s 18 beginning of November?
19 progress . 19 A. Yes, not that I know of. I don’t know what he was doing
20 "’He really thought that what he had would sway the 20 in Washington obviously, but as far as we were
21 election ’, said one. 21 concerned ...
22 "So in October, pages from his reports were seen by 22 Q. Could we have {E/63/1}, if anyone is on the hard copies ,
23 a few journalists , including me." 23 that ’ s volume 3, {E/63/5}. These are messages passing
24 Now, do you have any idea how the BBC came to see 24 to Mr Winer. Now, there are four green messages on the
25 written pages from your reports ? 25 right -hand side , and I should just pause to say that the
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1 A. No, I don’t . 1 conversation in November, on your account in

2 MR JUSTICE WARBY: What is the date of the article? 2 paragraph 43, is after the FBI had decided to cease
3 MR CALDECOTT: My Lord, I’m sorry. It’s 30 March 2017. 3 contact , and that takes place on 1 November when the
4 MR JUSTICE WARBY: So "late last year" is late in 2016. 4 Mother Jones article was published .
5 MR CALDECOTT: Correct. And my Lord, I ought to have just 5 On 31 October we have this message from you to
6 added, he is the Washington correspondent for the BBC. 6 Mr Winer:
7 Now, can we next move on, please, to 7 "... we’ve had some doubts about the wisdom of
8 Mr Strobe Talbott, and again, just let me find the 8 travelling to DC this week for reasons you will
9 reference to his CV, and we’ ll remind ourselves who he 9 understand."
10 is . {A/7/6}. And he had not been in government since 10 And then this :
11 2001; is that right ? I say government in a broad sense . 11 "However, Glenn and Strobe T have twisted our arms
12 A. Not in the executive , no. 12 and we are likely to leave on Wednesday and [will ] be
13 Q. And he didn’t at this time have any responsibility for 13 available for meetings over there Thurs/Fri if you want
14 national security , did he? 14 to pass that on to T."
15 A. Not formally , no. 15 Now, why was Mr Talbott twisting your arms to attend
16 Q. And he was a close friend of Hillary Clinton? 16 meetings - - this is about a week before the general
17 A. I ’m not sure he was a close friend of Hillary Clinton . 17 election , and this is before your conversation with
18 He had been at Oxford with Bill Clinton , I believe , 18 Sir Andrew, plainly . Can you help us about this
19 lived in the same house. 19 message?
20 Q. He was an advisor of Bill Clinton ’ s on Russia , wasn’t 20 A. I can’t . I mean, from what I recall , and Sir Andrew
21 he? 21 will answer this as well , Sir Andrew and I phoned
22 A. Yes, he was. He was the Deputy Secretary of State under 22 Strobe Talbott from his house at the beginning
23 Bill Clinton . 23 of November.
24 Q. Now, can we just remind ourselves as to how he comes 24 Q. But you see this is before the break with the FBI and we
25 into the story . Your witness statement at {C/7/10}, 25 have Strobe Talbott twisting your arms and wanting you
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1 to be available for meetings in Washington on the 1 officials of the State Department?

2 Thursday or Friday . That’s quite a specific suggestion 2 A. I think everything about this issue is not
3 about what Strobe Talbott was asking you to do. 3 straightforward , if I might say, in terms of handling
4 I ’m just rather surprised it has been forgotten and you 4 even with people like that .
5 can’t remember anything about it. 5 Q. "What you did with it ". But on your account, you know
6 A. I honestly don’t believe I had any contact - - direct 6 what he’s going to do with it . Why are you asking him
7 contact with Strobe Talbott before I spoke with him with 7 on 12 November what he did with it?
8 Sir Andrew. 8 A. I was trying to check what had happened at that meeting
9 Q. So you can’t remember why they wanted you to go to the 9 and what had happened subsequently.
10 United States on Wednesday, 2 November, with the 10 MR JUSTICE WARBY: Just to be clear, this is 12 November,
11 election due on the following Tuesday? 11 this is the English style ( inaudible ).
12 A. I think to meet Victoria Nuland. 12 MR CALDECOTT: My Lord, this is English style dates, yes.
13 Q. So you do now remember, do you? 13 MR JUSTICE WARBY: Okay.
14 A. I don’t remember Strobe Talbott being involved in that , 14 MR CALDECOTT: I’m sorry, I should have made that clear.
15 no, just Mr Winer. 15 MR JUSTICE WARBY: No, no, that’s what I thought
16 Q. By what means did Strobe Talbott contact you about this 16 ( inaudible ).
17 proposed trip to Washington, or do you say he didn’ t 17 MR CALDECOTT: Absolutely, and the same with timings as
18 contact you at all ? 18 well .
19 A. I don’t think he did , no. 19 "Perhaps you could give this some thought and get
20 Q. Now, the first message that we have between you and 20 back to me. All Best Wishes, Chris ."
21 Strobe Talbott is at {E/154/15}. You can just see it 21 Can you then, you see these have different cells ,
22 here , probably in another form elsewhere . And you say 22 Mr Steele, could you just go to the next cell , 7:
23 this : 23 "Thanks, let ’ s talk some time over the weekend."
24 "Dear Strobe, I know this is not straightforward but 24 And then this :
25 we need to discuss the package we delivered to you the 25 "There are clearly non-media angles to all this ."
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1 other week ..." 1 Now, that suggests that in your mind, there were
2 Now, pausing there , that ’ s a package of your 2 also media angles , doesn’t it ?
3 reports , isn ’ t it ? 3 A. Well, this was after a Mother Jones interview and things
4 A. Yes. 4 like that .
5 Q. "... and sooner the better . What you thought of it , 5 Q. Mr Steele, it ’ s also after the election , isn ’ t it ?
6 what you did with it , how we (both) should handle it and 6 A. Yes.
7 the issue it highlights going forward etc . Perhaps you 7 Q. What were the continuing media angles after the
8 could give this some thought and get back to me." 8 election ?
9 Now, what at the moment I am puzzled by is, if you 9 A. Well, the media continued to cover the issue .
10 look at paragraph 44 of your witness statement at 10 Q. Yes, but these are media angles from your perspective
11 {C/7/11}, this suggests that on or about 3 November: 11 and Mr Talbott’s perspective , aren ’ t they? This is the
12 "... Mr Talbott called me and stated that he wanted 12 gentleman you were messaging?
13 to discuss the pre - election memoranda with US Secretary 13 A. I think it refers to all angles of the media.
14 of State John Kerry and senior officials from the State 14 Q. "Also, did you see recent unguarded comments by DP and R
15 Department at a forthcoming private meeting ... he 15 from out east ..."
16 therefore requested a copy of the pre - election 16 Who is that?
17 memoranda." 17 A. They are two Russian officials , Dmitry Peskov, the
18 Now, if that is true , you know exactly why 18 (overspeaking) and deputy foreign minister Ryabkov.
19 Mr Talbott wants the memoranda, for a very specific and 19 Q. Can you just , please , look down to the cell 13,
20 identified purpose, and the natural enquiry to make is 20 21 November 2016, again from you:
21 how did the meeting go. 21 "Dear Strobe, we’re in a bit of a lull on the big
22 Can we go back and look at what you actually said : 22 issue right now but still working on it discreetly in
23 "Dear Strobe, I know this is not straightforward ." 23 the UK and have some contact now with senior
24 {E/154/15}. Now, what is not straightforward about 24 [Republicans ]."
25 a simple , private meeting with Mr John Kerry and senior 25 Now, what is "the big issue ", Mr Steele?
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1 A. Russian election interference . 1 Q. I ’m not absolutely sure . There’s a reference to it

2 Q. Well, isn ’ t the other big issue that Mr Trump is going 2 being leaked in the chronology, I think .
3 to be inaugurated on 20 January, and on the basis of 3 The Clinton campaign, perhaps understandably, were
4 your reports , if they are true , he is wholly unsuited to 4 outraged by this , and you were too.
5 be the President of the United States? 5 A. Yes.
6 A. I wouldn’t disagree with that . 6 Q. And before you spoke to Mr Corn, were you aware that on
7 Q. But wasn’t that the big issue ? 7 Sunday 30 October, the Democrat Senator Harry Reid, and
8 A. The big issue was in general Russian interference in the 8 I think he was the former Democrat Leader in the
9 election to try and help Mr Trump get elected. 9 House --
10 Q. But you see that reference there to "Some contact now 10 A. Minority leader of the Senate.
11 with senior Republicans ." So what I suggest was going 11 Q. ( inaudible ) Senate. That he had written an open letter
12 on is that you were hoping to get sufficient media 12 to Mr Comey, director of the FBI.
13 pressure and political pressure ; do you understand what 13 A. No, I wasn’t aware of that .
14 I ’m saying? 14 Q. It features in the article , doesn’t it ?
15 A. I do understand what you’re saying . 15 A. It may well do but - -
16 Q. Yes. To activate against Mr Trump pending investigation 16 Q. Well, we will see that it does. Did it come up in the
17 of these very serious charges? 17 call ?
18 A. I certainly wouldn’t go with media, I think we’d shared 18 A. Not that I recall , no.
19 with John McCain that we did want it to be seriously 19 Q. Can we hear, just in case it jogs your memory, file E2,
20 investigated . 20 {E/40/1}.
21 Q. That’s why I asked you about the phrase "non-media 21 In the third paragraph, this is his letter , second
22 channels ". 22 line :
23 In fact , I should have said , just for the sake of 23 " It has become clear that you possess explosive
24 completeness, that it ’ s right to say , isn ’ t it , that the 24 information about close ties and coordination between
25 trip that Mr Simpson and Mr Strobe Talbott were twisting 25 Donald Trump, his top advisors , and the Russian
17 19
1 your arms about in fact never took place? 1 government -- a foreign interest openly hostile to the
2 A. Correct . 2 United States , which Trump praises at every opportunity .
3 Q. Now, because of Mr Talbott’s straddling two dates , we 3 The public has a right to know this information .
4 haven’t dealt with the Mother Jones article , which comes 4 I wrote to you months ago calling for this information
5 in the middle of this , and I just want to ask you 5 to be released to the public ."
6 a little bit about that . 6 Now, just pausing there , that was the August letter
7 What time of day English time did you speak via 7 which we looked at , I think - -
8 Skype to David Corn of Mother Jones on Monday, 8 A. Yes.
9 31 October 2016? 9 Q. - - yesterday . So this is obviously a Democrat Party,
10 A. Early afternoon I had a business lunch , which 10 your ultimate clients . We’ve gone back in time, the
11 I remember, with a client , and I went back to the office 11 election still hasn’t taken place , this is October 30,
12 after that and had the conversation on Skype. 12 2016, this letter , and you can see why I’ve been trying
13 Q. That sounds about right because the article is timed at 13 to keep it chronological as it does get very confusing .
14 7.52 pm US time. 14 Do you now remember whether or not that letter was
15 Now, I think there ’ s a lot of non-contentious 15 discussed with Mr Corn?
16 material here so can I take it very shortly . On Friday 16 A. I don’t believe it was.
17 28 October, Mr Comey informed Congressional leaders that 17 Q. Because if we please look at {E/93/1}, this is E5 for
18 further emails had come to light relating to the closed 18 anyone using the hard copy, we see the article , and the
19 investigation , or then closed investigation , into 19 opening refers to what I might loosely call the
20 Hillary Clinton ’ s private server ; is that right ? 20 political blast which we’ve been discussing , and then
21 A. I believe so , yes . 21 about five lines in :
22 Q. And he said that the investigation had been reopened to 22 "On Sunday, Senate Minority Leader Harry Reid upped
23 consider them and, as happens in politics , it leaked , 23 the ante. He sent Comey a fiery letter saying the FBI
24 that letter to the Republican - - 24 chief may have broken the law [ that ’ s a reference to the
25 A. Was it not an open letter ? 25 Hatch Act, I think ] and pointed to a potentially greater
18 20
1 controversy ." 1 Would I be right that the words, it may not be

2 And then there’ s the quote I just read ending: 2 exactly the words, but the words "former senior
3 "’... the public has a right to know this 3 intelligence officer for a western country" was
4 information ." 4 a description you broadly agreed with, for these
5 Pausing there , leaving aside source material , did 5 purposes?
6 you agree with Mr Reid? 6 A. I do broadly agree with it . I can’t remember whether
7 A. That his point was that the government in the US should 7 I kind of agreed that with Mr Corn or whether Mr Simpson
8 have made the suspicions or whatever public ? 8 agreed it with Mr Corn.
9 Q. Yes. 9 Q. Did you record the call at all ?
10 A. I do believe that , yes . 10 A. No.
11 Q. Thank you. Then the top of the next page: 11 Q. Did you ever get a copy of the call ?
12 "Reid’ s missive set off a burst of speculation on 12 A. No.
13 Twitter and elsewhere ." 13 Q. He must have pressed you, presumably, for details of the
14 And obviously about what he was referring to . And 14 allegations ?
15 then there ’ s a reference back, you’ ll see , to the August 15 A. Yes.
16 letter . Were you aware of the August letter at the 16 Q. And I’m not suggesting you gave him source material , but
17 time? 17 you presumably gave him those details in the same way
18 A. At some point, yes , I was. I can’t remember exactly 18 you gave them to Mr Isikoff in September?
19 when. 19 A. No, I was very careful because we were on a Skype call ,
20 Q. Then if you look on page 2, about five lines in : 20 not face -to- face , so the line was not secure , therefore
21 "Last month Yahoo News reported that US... officials 21 I was pretty careful and reticent about what I said .
22 were probing the links between [Carter ] Page and senior 22 Q. Did you want Mr Corn to investigate as well as to
23 Russian officials ." 23 publish ?
24 And when you read this you no doubt realised that 24 A. I wanted him to investigate .
25 was the article published by Mr Isikoff ? 25 Q. Well, you’ve already told me that you appreciated he was
21 23
1 A. Yes. 1 likely to publish an article so you plainly wanted him

2 Q. "(Page has called accusations against him ’garbage ’). 2 to publish something, otherwise you wouldn’t have taken
3 On Monday, NBC News reported that the FBI has mounted 3 part in the call ?
4 a preliminary enquiry into the foreign business ties of 4 A. I wanted him to publish that the US Government was
5 Paul Manafort, Trump’s former campaign chief. But 5 investigating Trump.
6 Reid’ s recent note hinted at more than the Page or 6 Q. Now, again I don’t want to be selective about this . At
7 Manafort affairs ." 7 the top of page 3, perhaps unsurprisingly , the second - -
8 Then we get this : 8 in the top line , it ’ s right to say you declined to
9 "And a former senior intelligence officer for 9 identify the FBI contact.
10 a western country ..." 10 A. Yes.
11 Now, presumably you must have appreciated that with 11 Q. Now, we then get this sentence :
12 seven days to go to the presidential election , Mr Corn 12 "Mother Jones has reviewed that report and other
13 was likely to be publishing an article after your 13 memos [the] former spy wrote."
14 interview ? 14 Now, can we just remember that the allegation in
15 A. Yes. 15 here , there are - - if you just look on page 2 again ,
16 Q. And you also would have appreciated that he would have 16 please .
17 to say something about you, obviously not by name, but 17 "... Mother Jones ... in recent months he provided
18 he would have to say something about you? 18 the bureau with memos, based on his recent interactions
19 A. Yes. 19 with Russian sources , contending the Russian government
20 Q. And presumably you would be keen to control how he 20 has for years tried to co-opt and assist Trump -- and
21 described you? 21 that the FBI requested more information ..."
22 A. Yes. 22 MR JUSTICE WARBY: Sorry, where are you reading from?
23 Q. Because you wouldn’t want to give away too much, 23 MR CALDECOTT: I’m sorry, my Lord, I beg your pardon. It’s
24 because, for reasons we all understand, you didn’ t want 24 just towards the end of the first paragraph, so it ’ s the
25 to be revealed as the author. 25 top section , really .
22 24
1 Now, what is striking about this article in 1 point of this interaction with the FBI had been
2 particular is that it ’ s the first time, isn ’ t it , that 2 early October in Rome, and I think the second half
3 it appears in the open this very serious charge on 3 of October I had heard nothing much from the FBI about
4 page 3 in the first new paragraph, it says : 4 it . It seemed to have gone cold .
5 " It maintained that Trump ’and his inner circle have 5 Q. And then I want to ask you about what appears to be
6 accepted a regular flow of intelligence from the 6 a direct quote from you:
7 Kremlin, including on his democratic and other political 7 "’This is something of huge significance , way above
8 rivals ’." 8 party politics ,’ the former intelligence officer
9 And then this : 9 comments. ’I think [Trump’s] own party should be aware
10 " It claimed that Russian intelligence had 10 of this stuff as well ’."
11 ’compromised’ Trump during his visits to Moscow and 11 Now, that is not a reference to people concerned
12 could ’ blackmail him’." 12 with national security , it ’ s a wider political point
13 Now, you gave that information to Mr Corn knowing 13 that is being made, isn ’ t it ?
14 that it was likely to be published , didn’ t you? 14 A. It reads like that .
15 A. No, Mr Simpson must have done. 15 Q. Because, let ’ s just think about it , there are three
16 Q. Are you saying you didn’ t talk about report 80 at all ? 16 possible lines of action : law enforcement action , media
17 A. Only in broad terms. 17 action , and political action , and my suggestion is that
18 Q. The broad terms are exactly this , aren ’ t they , without 18 you were busy promoting all three of these to secure
19 going into detail ? We know there are some fairly sordid 19 your hoped-for objective of stopping Mr Trump.
20 details which we don’t need to mention, but this is 20 A. I don’t agree . I was certainly not promoting the media
21 exactly that , isn ’ t it : it ’ s a broad summary of this 21 side , and that was before we’d approached
22 allegation , but the sting is there , isn ’ t it ? 22 Senator McCain, but the reason we approached
23 A. Yes, this is quoting from the memo, not from the 23 Senator McCain was after I ’d had a conversation with
24 conversation . 24 Andrew Wood, my Lord, who had proposed him as somebody
25 Q. Then look at the next paragraph: 25 who was a statesman and who was an expert in this area .
25 27
1 "The former intelligence officer says the response 1 He was also a Republican and the reason we were keen for
2 from the FBI was shock and horror ." 2 it to go to a Republican was because the Democrats were
3 That’s quite strong words, and I suggest they link . 3 aware of it and therefore we thought there needed to be
4 You were discussing this particularly serious 4 balance .
5 allegation , and that ’ s what the shock and horror was 5 Q. I mean it’ s quite wide to say his own party should know
6 about. Then read on, just to see that that ’ s correct : 6 about it , isn ’ t it ?
7 "The FBI, after receiving the first memo..." 7 A. I think it ’ s true that they should have known.
8 That’s report 80, isn ’ t it ? 8 Q. Can we just quickly look , and this is much later after
9 A. Yes. 9 this publication by BuzzFeed, but it refers back to this
10 Q. "... did not immediately request additional 10 interview , E5 {E/103/1}, please, there ’ s only one page,
11 [ information ], according to the former intelligence 11 page 1. I ’m sorry , four paragraphs down, Mr Steele.
12 officer and his American associates . Yet in August, 12 A. I don’t have it , I ’m sorry .
13 they say , the FBI asked him for all information in his 13 Q. I beg your pardon, we’ve got a wrong reference , have we?
14 possession and for him to explain how the material had 14 {E/103/1}, please. That’s it , thank you very much. Do
15 been gathered and to identify his sources . The former 15 you see the block type :
16 spy forwarded to the bureau several memos -- some of 16 "’Someone like me stays in the shadows’, the former
17 which referred to members of Trump’s inner circle . 17 spy said ."
18 After that point , he continued to share information with 18 Do you see that?
19 the FBI." 19 A. I can see the block .
20 Then this slightly curious sentence : 20 Q. And if you go four paragraphs down from that, you’ ll see
21 "’ It ’ s ... clear there was or is a pretty substantial 21 a paragraph starting :
22 enquiry going on ’..." 22 "The former spy told me ..."
23 Are you suggesting you had any information to 23 Do you see that?
24 suggest the enquiry had stopped? 24 A. Yes, it ’ s very small .
25 A. Nothing definite , although I hadn’t - - the sort of high 25 Q. It is very small , I ’m sorry about that .
26 28
1 "The former spy told me that he was reluctant to be 1 A. I ’m not sure about that , my Lord. In fact , I believe if
2 talking with a reporter . He pointed out this was not 2 we look in the record , Mr Corn gave the impression at
3 his common practice. ’Someone like me stays in the 3 least , for a long time after this interview that this
4 shadows,’ he said . But he indicated that he believed 4 was an in -person interview with me, which obviously
5 this material was important and he was unsure how the 5 wasn’t true , so I had a reason to doubt his word.
6 FBI was handling it ." 6 Q. What do you mean it wasn’t true that it was an in -person
7 And then this : 7 interview with you? I appreciate Mr Simpson was there,
8 " Certainly , there had been no public signs that the 8 but you were the main interviewee , weren’t you?
9 FBI was investigating these allegations ." 9 A. He implied in interviews that he had met me personally
10 Now, you knew full well that the FBI was 10 and done the interview in person.
11 investigating these allegations because you had had the 11 Q. Well, perhaps in the short break if you can find
12 meeting in Rome on October 3 and attended by no less 12 anything where that is , it would be helpful .
13 than four FBI officials , including , I think , an expert 13 MR JUSTICE WARBY: Was it Skype? Was it audio only?
14 on Russia? 14 A. No it was video and audio Skype, three way with me and
15 A. That was the case in early October. But if I might say, 15 Mr Simpson and Mr Corn.
16 my Lord, there was also an article in the New York Times 16 MR CALDECOTT: But at the time that you read this article,
17 at the end of October in which FBI officers were quoted 17 which is actually the time I ’m interested in , there was
18 off the record as saying that there was nothing to see 18 no reason to doubt what he had said there , was there?
19 here and that this investigation wasn’t going anywhere 19 A. I didn’ t know whether Mr Simpson had read some of it to
20 and that the Russian Government wasn’t favouring 20 show it to him or whatever, but Mr Simpson denied that
21 President Trump, which suggested to me that the 21 he had ever given a memo to Mr Corn.
22 investigation had either been dropped or scaled back. 22 Q. Well, in that case you must have been extremely
23 Q. Now, you never contacted Mr Corn again after reading 23 concerned about how -- this is on your case - -
24 this article , did you? 24 A. Yes.
25 A. No, I didn’ t . Sorry , the first one or the second one, 25 Q. - - how Mr Corn had got hold of these reports if
29 31
1 either ? 1 Mr Simpson denied showing them to him.

2 Q. The first one. 2 A. I ’m not sure he got hold of the reports ; how he had been
3 A. No, never . 3 able to quote number 80, yes.
4 Q. Now, can we just look at paragraph 5 - - sorry , at 4 Q. Well, it ’ s not only number 80, he had reviewed that
5 paragraph 55 of your witness statement {C/7/14}. 5 report and other memos this former spy wrote?
6 A. I can’t see it . 6 A. So he claimed.
7 Q. Sorry , {C/7/14}, please. 7 Q. But you, I suggest , would have been very interested to
8 MR JUSTICE WARBY: (inaudible). 8 find out, if not obliged to find out, whether he had
9 MR CALDECOTT: Paragraph 55 at the bottom of page 14: 9 copies or not; yes?
10 "Neither I nor Orbis ever showed or provided copies 10 A. Yes, absolutely .
11 of any of the pre - election memoranda to any journalists 11 Q. Whether he had taken a verbatim record or not?
12 during those meetings ..." 12 A. Yes.
13 And this is plainly after you have dealt with the 13 Q. Whether he was showing them to other members of the
14 Mother Jones interview : 14 media or not?
15 "... or at any other time. Nor did we ever 15 A. Yes.
16 authorise , instruct or encourage Fusion or anyone else 16 Q. But you did nothing about it at all , did you?
17 to do this . On the contrary , I expressly forbade Fusion 17 A. No, I raised it with Mr Simpson.
18 to share any of the memoranda with journalists . Save 18 Q. You raised it with Mr Simpson, you said "I didn’ t do
19 that I now believe that Mr Simpson may have shown one or 19 it ", what other action did you take?
20 more of the pre - election memoranda to David Corn..." 20 A. That was it because Mr Simpson was the only other
21 Now, when David Corn writes "Mother Jones has 21 participant in the call and I wasn’t going to contact
22 reviewed that report and other memos this former spy 22 David Corn.
23 wrote", and when the article includes direct quotations 23 Q. But if there ’ s any risk that he has got unredacted
24 from report 80, you had no reason at all to suppose that 24 copies with dangerous material in it , I suggest you
25 Mr Corn was not telling the truth? 25 would plainly have taken action at the very least to
30 32
1 ensure that they were kept in the close and safe 1 Q. Well, that ’ s what it says here in the negative :
2 custody - - at the very least . 2 "... the Defendants were not aware that any of the
3 A. I raised it with Mr Simpson who said he did not have the 3 pre - election memoranda had been published to or within
4 memorandum. 4 media organisations ."
5 Q. You know, don’t you, that there ’ s - - and I don’t think 5 A. I say that as meaning that they had been shared with
6 I need to go to it , but you know that there ’ s evidence 6 them, given to them.
7 that in fact Mr Corn gave hard copies later to Mr Baker 7 Q. Well, there ’ s a difference between the word "given" and
8 of the FBI -- 8 the word "shared", isn ’ t there? If you allow someone to
9 A. Sure, but I didn’ t - - 9 review a document, you’re sharing it , aren ’ t you?
10 Q. - - not long after , a few days later ? 10 A. I don’t know in what way Mr Simpson shared, if you like ,
11 A. I didn’ t know about that until a year later or two years 11 that information with Mr Corn, whether he read it to
12 later . 12 him, Mr Corn took it down as shorthand, I just don’t
13 Q. You see the sentence we’re looking at , it ’ s wholly 13 know. It wasn’t done when I was on the line or present .
14 unclear as to whether he has or has not got copies 14 Q. Now another -- and this is a point I ’ve already made in
15 himself ; do you agree? 15 relation to Mr Isikoff - - again , it ’ s obvious , isn ’ t it ,
16 A. Yes. 16 that Mr Corn has not verified the serious allegation
17 Q. Now, if there had been redacted copies in circulation , 17 that Mr Trump was exposed to blackmail by reason of
18 which didn’ t have the source material in it , there would 18 unspecified conduct in Moscow. He has obviously not
19 have been no grounds for concern about Mr Corn possibly 19 verified that between 31 October and 1 November, has he?
20 having copies or having taken very detailed notes , would 20 A. It seems unlikely , although as you’ve just said ,
21 there? 21 Mr Caldecott, he was in touch with the chief counsel of
22 A. I disagree . I believe that the source identifiers even 22 the FBI, Mr Baker. Who was clearly a source of his , or
23 in the socalled redacted copy was still compromising. 23 a contact of his , and would have been aware of the whole
24 Q. Now I just want to, please , just want ask you very 24 investigation .
25 quickly about a paragraph in your defence . It ’ s 25 Q. But you’re not suggesting that the FBI had verified that
33 35
1 {A/13/1}, please. It ’ s {A/13/5}, paragraph 31. Thank 1 allegation by this time, are you?
2 you, Mr Steele, that ’ s helpful . 2 A. I don’t know.
3 {A/13/5}, please. This is - - I want to ask you in 3 Q. Or, indeed , any time, to be fair .
4 particular about the purple in that paragraph, which was 4 A. I don’t know, Mr Caldecott, I really don’t know.
5 added, I think , in March of this year . 5 Q. No.
6 "... the Defendants were not aware that any of the 6 A. It ’ s still not clear to me what they had and hadn’t
7 pre - election memoranda had been published to or within 7 verified because I ’m not in contact with them.
8 media organisations . They therefore had no knowledge as 8 Q. You see, can I just show you what you say later about
9 to how any such republication , if and to the extent that 9 the December memorandum at {C/7/22}, paragraph 79 of
10 it had occurred, had been secured." 10 your witness statement.
11 Now, is that true , Mr Steele? 11 A. Sorry , 79?
12 A. I think it ’ s true . Mr Simpson had denied that he had 12 Q. Yes.
13 shared the memoranda with Mr Corn. I have no reason to 13 "The contents of the December memorandum were
14 doubt him. 14 self - evidently sensitive and highly confidential . I did
15 Q. That doesn’t mean, does it , that Mr Corn might not have 15 not make any redactions to the December memorandum,
16 got it from somebody else? 16 since I expected that it would be handled
17 A. Well, not to my knowledge he didn’t. 17 sensitively ..."
18 Q. But you see , unless you’re calling Mr Corn a liar , you 18 Now, pausing there , the source identified in
19 did have reason to believe that the pre - election 19 the December memorandum is also identified in almost
20 memoranda had been published to Mother Jones, didn’t 20 identical language in several of the pre - election
21 you? 21 memoranda. I can go through this if I have to .
22 A. Can you define "published ", please ? 22 A. Yes, I don’t want to get too much into that , my Lord.
23 Q. Yes. That its contents had been conveyed to 23 Q. I ’m not asking you to name them, we know the
24 Mother Jones? 24 (Overspeaking), we discussed it yesterday .
25 A. That is ( inaudible ). 25 A. I would accept some, but certainly not all of them --
34 36
1 Q. Yes. 1 money that we were owed previously for work we had done
2 A. - - and in fact not that first one. 2 for them.
3 Q. Well, if I have to go to it , I mean obviously I ’m not 3 Q. Well, can we leave expenses to one side , and other work
4 going to ask you about the names of your sources or 4 to one side . The $15,000 for the work on the
5 anything like that . 5 intelligence - - this intelligence , you were not paid and
6 A. No, thank you. 6 you did not pursue, did you?
7 MR JUSTICE WARBY: Sorry, I don’t really understand the 7 A. After the Mother Jones call ?
8 answer: I would accept some but not that first one. 8 Q. Yes.
9 A. The first memoranda was the one that Mr Corn seems to 9 A. Or before?
10 have had access to , my Lord, and what I’m saying is that 10 Q. After .
11 the source of the December memorandum was not involved 11 A. Not after .
12 in the sourcing of the first memorandum. 12 Q. Thank you. Now you characterise this break with the FBI
13 MR CALDECOTT: No, no, I’m sorry, it’s my fault if that 13 because it was a break, wasn’t it , of sorts ?
14 wasn’t clear , I wasn’t suggesting it was so. All I 14 A. It seemed to be at the time, although obviously they
15 was saying was that the source of the December 15 re -engaged with us later so I ’m not sure it was a clean
16 memorandum which we saw redacted as published by 16 break. My Lord, the Mueller investigation and the FBI
17 BuzzFeed, that same description of the source appears in 17 officers that were involved in that re -engaged with me
18 other pre - election memoranda. 18 and my team in about March or April 2017.
19 A. Yes, correct . 19 Q. Yes. And, indeed, it would have been negligent of them
20 Q. So assuming that the source material is what makes this 20 not to .
21 highly sensitive , it ’ s equally true that there had been 21 Can we look at a paragraph in your witness
22 a serious breach of confidence in making this 22 statement, please , at {C/7/9}, the last sentence of
23 information available to Mr Corn. That’s the only point 23 paragraph 33:
24 I ’m making, and what I can’t understand is your inertia 24 "At this point , the FBI and I suspended our contact
25 in response to that? 25 by mutual agreement."
37 39
1 A. I wouldn’t say I was inert . I raised it with 1 Now, that’s a bit of a gloss , isn ’ t it , Mr Steele?
2 Mr Simpson, I said I was unhappy about it, and he 2 A. The agent, when he phoned me and I had a conversation
3 reassured me that he had not shared the memoranda with 3 with him said that things would change in the future and
4 Mr Corn, given him access to them. 4 that we should freeze contact for the time being. He
5 Q. Now, you were telephoned by handling agent 1 on 5 wasn’t categorical that we should break off . And then
6 1 November immediately, weren’t you, this came out about 6 I expressed my disappointment with the way that their
7 the Mother Jones article ? 7 director had apparently broken the Hatch Act the week
8 A. I think it was a day or two after , I can’t remember 8 before and we left it at that .
9 which. 9 But subsequently Mr Burrows, my business partner ,
10 Q. And it was obvious that the FBI and he too strongly 10 had a further conversation with the agent about,
11 disapproved of your giving the media quite detailed 11 I think , a month later , and, you know, he was happy to
12 information about your dealings with the FBI as well as 12 have a further conversation with my business partner .
13 the detailed information from report 80. 13 So I don’t believe it was a final break, and as I ’ve
14 A. They were cross about the fact that I ’d given the media 14 said , my Lord, when the Mueller investigation got up and
15 details of my relationship with them, and the other 15 running and Mr Ohr re-engaged with me and I offered our
16 issue was not really discussed on the telephone . 16 services to the Mueller investigation , they welcomed
17 Q. You were never paid the $15,000 which had been agreed in 17 that and came to London to interview me later that year ,
18 Rome for past work, were you? 18 and including one of the officers I met in Rome.
19 A. No, I wasn’t . 19 Q. I won’t do any more -- I want to ask one more question
20 Q. And you made no attempts to pursue that money, did you? 20 about this . It is obvious , wasn’t it , that the FBI were
21 A. I think I did , actually , yes . 21 very disappointed to have to break off relations . They
22 Q. Did you? 22 didn’ t want to do it ?
23 A. We were not paid our expenses for Rome either, my Lord, 23 A. I would argue they didn’ t actually completely break off
24 having gone to Rome at their request . We were never 24 relations : they suspended relations , really , I think .
25 paid the expenses, nor were we paid quite a large sum of 25 Q. And were you following the US media at this time,
38 40
1 obviously on these issues , not American football ? 1 the American Government.

2 A. Partly , yes . I mean, not like a hawk, because I had 2 Q. Now, I’m not going to run through each and every
3 other client work to do but of course we were monitoring 3 question I asked you about Mother Jones, because
4 it . 4 precisely the same points arise . I mean, is all you did
5 Q. And did Fusion keep you abreast with relevant publicity ? 5 was ring Mr Simpson and find out whether or not he had
6 Were you sent articles from time to time? 6 briefed Newsweek and is that the limit of what you did?
7 A. They would occasionally draw our attention to things if 7 A. Yes, I think that ’ s the limit of what we could do, given
8 they thought we had missed them or whatever, yes . 8 that we had broken contact with the FBI, or suspended
9 Q. And how did they do that? What communication method did 9 contact with the FBI.
10 they use? 10 Q. Now, do you still stand by that paragraph in your
11 A. Usually phone calls . Occasionally Skype, I think . 11 defence at {A/13/5}, paragraph 31 at the top of page 5:
12 Q. Did you talk to them by phone from time to time? 12 "The Defendants were not aware that any of the
13 A. Occasionally , yes . 13 pre - election memoranda had been published to or within
14 Q. Now can we please look at the Newsweek article of 14 media organisations ."
15 4 November 2016, which you clearly read the following 15 Do you accept that that is false ?
16 day. It ’ s at {E/159/1}, please. This is a version 16 A. On that definition it ’ s false , but not in terms of our
17 which, as you can see , we have done some marking up. 17 publication of it .
18 Now, I hope we can take a fairly short route through 18 Q. And again, I don’t mean to repeat this time and again,
19 this . Have you had time to look at the various 19 but we say either the unredacted versions were out there
20 footnotes? 20 and were dangerous and would have needed prompt and
21 A. Yes, I have looked at them. 21 serious action , or redacted versions were out there , in
22 Q. Are there any of them which you disagree with or which 22 which case , a casual approach was understandable.
23 you think are wrong or unfair ? 23 Now, can I just ask you, please , to look at {A/15/6}
24 A. I don’t think so , no. 24 for some further information? Request 14 on page 6, do
25 Q. You presumably read this article closely and with 25 we have that? Yes, we do:
41 43
1 interest ? 1 "Please state whether the December memorandum was

2 A. I certainly read it , yes . 2 provided to (a) the UK national security official ;
3 Q. And you’ve already told us that you never briefed 3 and/or (b) Fusion; and/or (c) Mr Kramer and
4 Newsweek? 4 Senator McCain with the source of the allegations
5 A. Correct . 5 against the Claimants redacted or not.
6 Q. And it would be pretty clear , reading the footnotes , 6 "Information pertaining to the status of the
7 that Newsweek had at the very least seen the three 7 source(s) of the intelligence contained within the
8 reports which feature , which are 80, 100 and 105? 8 December memorandum was not redacted when it was
9 A. I don’t know. That’s a reasonable assumption. 9 provided to either the UK national security official
10 Q. Now, what enquiries did you make about how this article 10 and/or Fusion and/or Mr Kramer and Senator McCain."
11 had come about? 11 And then this sentence :
12 A. I think I asked Mr Simpson whether he had briefed 12 "The information contained within the intelligence
13 Newsweek and he had said that he hadn’t. So the 13 reports pertaining to the status of the source(s) was
14 assumption we drew going forward was that an official in 14 consistent with the Defendants’ conscious efforts to
15 the American Government had briefed Newsweek, and indeed 15 protect the identity of the sources ."
16 the British Government, if you read the article . 16 Now, that seems to be saying that the danger had
17 Q. Well, the mere fact that other people are quoted in 17 been removed in the unredacted version ; do you
18 a very long article on other matters, it ’ s rather unfair 18 understand?
19 to conclude from that that they released the reports to 19 A. The danger is never removed. I think we covered this
20 Newsweek. The truth is it ’ s not at all clear at all 20 yesterday , my Lord, that when you draft an intelligence
21 from whom they got the report? 21 report there ’ s always a risk , you have to say something
22 A. That’s true . I don’t think it can be the British 22 about the source and the more you say about the source
23 Government unless the British Government had received 23 the more the risk , but there ’ s still very significant
24 the reporting from the Americans without our knowledge 24 risk when you’re dealing with a country like Russia and
25 before we briefed them, but it could certainly have been 25 its counterintelligence capabilities .
42 44
1 Q. You see, the slight problem I have is , if you look at 1 It says at paragraph 8 - - this is 3 April 2017, and
2 some of the source material , it actually is quite 2 it says this :
3 identifying by description , not to an individual , but if 3 "At all material times Fusion was subject to
4 you are a member of the FSB and you see it’s a close 4 an obligation not to disclose to third parties
5 associate of a named person, who knows about 5 confidential intelligence material provided to it by the
6 a particular meeting, you could be talking about only 6 Defendants in the course of that working relationship
7 three or four people. 7 without the agreement of the Defendants."
8 A. That may be rather too few, but certainly it ’ s 8 Now, Mr Steele, I suggest these two propositions are
9 a significant risk . 9 entirely contradictory ?
10 Q. Yes. 10 A. They’re in tension , I think , yes .
11 A. I mean, if there ’ s a government meeting in Russia and 11 Q. Well, which is right ?
12 a memo is circulated , I don’t know how many people would 12 A. I think this at 8 refers to the confidentiality
13 see it , but more than three or four , but yes , I accept 13 agreement with Mr Simpson, and the other refers to
14 the point . 14 a legal proposition that is designed by our - -
15 Q. You said yesterday that the pre - election memoranda were 15 determined by our US lawyers. So there ’ s definitely
16 Fusion’ s intellectual property ; do you remember that? 16 a tension between the two, yes .
17 A. Yes. 17 Q. But you see you adopted yesterday what the US lawyers
18 Q. And I take it that that is adopting the letter from your 18 were saying .
19 American attorneys, Bredhoff & Kaiser, which is at 19 A. In reality , whatever the legal status of this was, we
20 {E/144/2}. 20 had a firm agreement that Fusion couldn’ t disclose
21 A. E what, sorry ? 21 material without our permission , although they may have
22 Q. {E/144/2}. 22 formally owned the IP.
23 A. E1? 23 Q. You do accept, don’t you, that the inspector general of
24 Q. It ’ s in volume 6, E6. Sorry , it hasn’t come up yet. 24 the Horowitz inquiry , it was a very serious inquiry , and
25 Thank you. 25 that he would expect to be told the full truth about
45 47
1 A. 144. 1 this ?
2 Q. Tab 144 of E6. 2 A. Well, he was shown the confidentiality agreement and it
3 A. Yes. 3 was discussed with our lawyer who was at the meeting
4 Q. In fairness to you, I mean I understand the purpose of 4 with Horowitz what the status of the IP was, and we
5 this , it ’ s to take issue with a number of matters which 5 explained that there was clearly a tension between the
6 required correction , and if we look on page 2, 6 two.
7 paragraph 2: 7 Q. You see what your US attorneys appear to be doing is
8 "Orbis ’ s 2016 election reports ... owned the 8 distancing yourself from responsibility for any briefing
9 intellectual property and controlled what was done with 9 of the information in the reports because you say you
10 the information in the reports . Fusion consented to 10 were under the direction of Fusion and they controlled
11 Orbis voluntarily sharing the reports with the FBI, but 11 what was done.
12 the FBI had no control over what Fusion or Orbis did 12 A. We were certainly under the direction of Fusion but, as
13 with those reports . The FBI knew Fusion was Orbis’s 13 I said , the confidentiality agreement cuts across that
14 client from its very first meeting with Orbis about this 14 as well .
15 work in July 2016." 15 Q. Now, can we please just go back to Mr Strobe Talbott.
16 Now, the suggestion there , you appreciate , is that 16 MR JUSTICE WARBY: Is that a convenient moment for a
17 Fusion are free to do with the reports what they like . 17 mid-morning break?
18 They controlled what was done with the information in 18 MR CALDECOTT: Yes, my Lord, it is a very convenient moment,
19 the reports ; do you see that? 19 yes , thank you.
20 A. Yes. 20 MR JUSTICE WARBY: You are moving on, are you?
21 Q. Could you please look at {A/13/1}, which is your defence 21 MR CALDECOTT: Yes, to a completely new subject, yes.
22 {A/13/2}, paragraph 8, and just so we are clear , this 22 (11.09 am)
23 was the first version of the defence , which is fairly 23 (A short break)
24 close in time to the events we’re discussing . I ’ ll get 24 (11.20 am)
25 you a date in a minute, I ’m sorry , it ’ s not on my copy. 25 MR JUSTICE WARBY: Yes.
46 48
1 MR CALDECOTT: Mr Steele, I dealt with Mr Strobe’s messages 1 reference to it being shared with Congressional
2 when we went through the earlier part , you remember, so 2 colleagues , is there , and presumably your answer to that
3 we can move on to your discussion with Sir Andrew and 3 is : well , that arose after he had received them --
4 the idea of sending the report to the late 4 A. Correct .
5 Senator John McCain. 5 Q. - - from us.
6 Your witness statement deals with this at {C/7/16}. 6 A. Yes.
7 Can I just ask you about the first sentence of 7 Q. Now, can we just agree , I think there ’ s very little
8 paragraph 61. That’s {C/7/16}: 8 that ’ s contentious about this . The route whereby
9 " Sir Andrew Wood was aware that I had ceased our 9 Senator McCain obtained the reports is in the agreed
10 contact with the FBI in early November 2016 and he knew 10 chronology. Sir Andrew goes to the Halifax
11 the reasons for this ." 11 international security forum in Canada between 18 and
12 What reasons did you give to Sir Andrew for this 12 20 November. He meets Mr Kramer, whom he knows --
13 ending of contact with the FBI? 13 A. Mm-hm.
14 A. I can’t remember the exact conversation now but it was 14 Q. - - and then Senator McCain on 19 November?
15 along the lines that Mr Comey had made his announcement 15 A. Yes.
16 which made it almost impossible for us to - - excuse me, 16 Q. Mr Kramer then comes to England to discuss the dossier
17 my Lord -- continue working for two masters on this 17 with you, and then you send an encrypted copy to Fusion;
18 going forward and that a breach of the Hatch Act, and 18 is that right ?
19 therefore I had spoken to Mr Corn and that had resulted 19 A. That’s correct , yes .
20 in our suspending our relationship . 20 Q. Can I just ask this : why did you send an encrypted copy
21 Q. And you then say, just at the very bottom of that page: 21 to Fusion; I thought they already had the reports ?
22 "I therefore was keen that a senior Republican in 22 A. I was under the impression that they had destroyed them
23 Congress, with experience , expertise in Russia and 23 at the end of the contract , along with all the other
24 national security issues , and a reputation for 24 material .
25 discretion and bipartisanship , should be made aware of 25 Q. Had you been told that?
49 51
1 the existence and nature of our investigation and the 1 A. Yes.

2 intelligence we had received ." 2 Q. Now, it ’ s obvious , isn ’ t it , from the articles we’ve
3 And there’s something along similar lines in the 3 been looking at , that people in political circles would
4 last sentence of 62. 4 be aware that your reports had been seen by various
5 Now, what did you expect Senator McCain to do when 5 media organisations , or at least their gist had, let ’ s
6 he received these reports ? 6 be neutral about it for the moment?
7 A. I don’t know what I expected him to do, I expected him 7 A. Gist I accept.
8 to use his judgment as to how they should be treated , 8 Q. I ’ve been through this countryside at length . And that
9 and this was obviously after he had met with Sir Andrew, 9 it included some pretty serious charges .
10 and said that he believed that what had been described 10 A. Mm-hm.
11 posed a threat to national security , and that he wanted 11 Q. Now, could you please look at your further information ,
12 to follow up, my Lord. 12 which is in {A/15/3}, request 9 on page 3, and you were
13 Q. Now, can you just look , please , at paragraph 72 13 asked about the capacities in which Mr Kramer and the
14 {C/7/20}, which is about Mr Kramer contacting you, and 14 Senator received these reports , and at the top of page 4
15 you’ ll see how this is expressed . It ’ s : 15 you say :
16 "After Senator McCain had received the pre - election 16 "The Defendants believed that Senator McCain and
17 memoranda, Mr Kramer contacted me in early December and 17 Mr Kramer were acting only in their official capacities
18 informed me that Senator McCain had been requested to be 18 and were not informed of any other capacity or purpose
19 provided with any further intelligence . Mr Kramer 19 in which they were acting ."?
20 explained that Senator McCain took the intelligence in 20 A. Mm-hm.
21 the pre - election memoranda seriously and intended to 21 Q. "There were no grounds that led the Defendants to
22 share and discuss it with the director of the FBI, 22 suspect that Senator McCain and Mr Kramer were not
23 James Comey, and with trusted, close congressional 23 acting in their official capacities at any time up to
24 colleagues ." 24 and including the publication of the December memorandum
25 Now, in your defence in this case there is no 25 to Mr [McCain]."
50 52
1 A. Mr Kramer. 1 MR JUSTICE WARBY: Right. Well, we haven’t really dealt

2 Q. I ’m sorry , I beg your pardon, Mr Kramer. 2 with it .
3 Now, can we please look at {D/3/1}, I don’t think 3 MR CALDECOTT: Yes, I don’t think it’s going to take us very
4 we’ve had this file before , page 1. Sorry , is it not up 4 far .
5 yet? I beg your pardon. Could you go on to the next 5 A. There weren’t any.
6 page {D/3/2}. Thank you. Now, this was a statement 6 Q. "Mr Steele asked shortly after the US elections had been
7 submitted by Sir Andrew to the Senate Intelligence 7 completed to see me again. He told me that while at
8 Committee, and I don’t think we have a date. We have 8 least the basic elements of what has since become known
9 the date when obviously it was attached to Sir Andrew’s 9 as his ’ Dossier ’ were known by persons within the then
10 witness statement, but I can ask him about that. 10 existing Administration , he did not know that the same
11 All I want to ask you about for these purposes, 11 was true of senior Republicans. In justice , he believed
12 firstly , could you go, please , to - - we’ ll just see how 12 it might be right to tell a trustworthy senior
13 this comes about in - - the opening paragraph explains 13 Republican of its existence , on a confidential basis ,
14 how this statement comes about. 14 and to allow such a person if he/she wished to read the
15 A. Mm-hm. 15 document itself . The ’Dossier ’ was after all already in
16 Q. And then if we go over to the next page, please {D/3/3}. 16 the hands of the FBI".
17 the first new paragraph, this is talking about his 17 So there ’ s nothing you would disagree with there ,
18 discussions with you, Sir Andrew says this : 18 presumably?
19 "He [that ’ s you] referred to his links with the FBI 19 A. Not at the time, no, although subsequently of course is
20 as continuing to work in this vein , and apparent 20 this disagreement about whether they had all the memos
21 knowledge in other US government agencies of at least 21 before the package was delivered by Senator McCain to
22 the general outlines of what his (and I believed other) 22 Mr Comey.
23 enquiries had revealed ." 23 Q. Now, can you just look at the paragraph starting :
24 Now, I thought you said earlier this morning that 24 "I subsequently met Senator McCain..."
25 your relations with the FBI resumed in March? 25 This is obviously Sir Andrew speaking?
53 55
1 A. Contact with Bruce Ohr I think began or rebegan 1 A. Yes, which ...
2 in January 2017, and then he was discussing those 2 Q. And then he refers to you halfway through that
3 contacts with the FBI from that date. Direct contact 3 paragraph:
4 with the FBI then began later in the year through the 4 " All I could say was that I could vouch for the
5 Mueller process , which I think started in May, 5 personal honesty and professional integrity of the
6 I believe , 2017. 6 person who had gathered the material [ that ’ s you] and
7 Q. So did you know that your communications to Mr Ohr 7 that I agreed with that person that it was right to
8 in January were being forwarded by Mr Ohr to the FBI? 8 ensure that its existence was known of in responsible
9 A. He didn’t - - I ... I knew some of them were, yes. 9 Republican circles , not least given that it had been
10 Q. Well, can you help us a little bit more about that? 10 available to people in the current but outgoing
11 A. Sure. Can I explain that , my Lord. So there were two 11 Administration ."
12 reasons why I re - established contact with Mr Ohr 12 Now, was that the hope and expectation that
13 in January 2017, and to which he was responsive . One 13 Senator McCain would share at least the gist of the
14 was on a source protection issue in the United States , 14 reports with responsible Republican circles ?
15 which he was very concerned about, and he certainly took 15 A. I think possibly with his colleagues on the various
16 that to the FBI. And the second was an offer to engage 16 committees in the Senate, yes .
17 with the Mueller investigation , which then followed , and 17 Q. That’s not actually what it says , is it ? It says
18 he took that to the FBI, and then the FBI reached out to 18 " responsible Republican circles ", which is a rather
19 me themselves as a result of his intermediation . 19 wider concept than that?
20 MR JUSTICE WARBY: This is going off in a direction I didn’ t 20 A. Possibly , yes .
21 understand you to be going. I mean, I thought you were 21 Q. Now, just give me a minute to clear up the files .
22 putting to the witness that the first complete paragraph 22 Now, can we please have {E/62/4}. Now, I just want
23 on page {D/3/3} gives an account of this continuing 23 to ask you about the last message on this page:
24 links with the FBI in November 2016? 24 "A [ is obviously Sir Andrew], JM [is the late
25 MR CALDECOTT: Yes. 25 Senator McCain ]..."
54 56
1 A. Mm-hm. 1 giving it to the CIA, on your version ?

2 Q. "... appears to have bottled it ..." 2 A. Because Mr Kramer had been out discussing it with
3 Now, this is after he had given the report to the 3 Ms Wallander and Victoria Nuland and so on and so forth ,
4 FBI, and you knew he had given the report to the FBI? 4 and effectively , not necessarily vouching for it , but
5 A. Yes. 5 certainly being associated with it .
6 Q. Now, what had he not done which you expected him to do? 6 Q. Look at the next sentence :
7 A. I certainly thought he would take it to the CIA as well , 7 " Indications are that wealthy [Republican] donors
8 which he didn’ t appear to have done, and I ’m not sure 8 are buying off the critics ."
9 about other institutions like the NSA and so on, which 9 You see, I suggest that what you hoped would happen
10 would have been relevant to an investigation . 10 is that Senator McCain would activate a responsible , as
11 Q. But the phrase " bottled it " doesn’t really quite fit , 11 you would have seen it , a responsible wing of the
12 does it , not showing it to the CIA. Why would you 12 Republican party to take some form of public action
13 bottle not showing something to the CIA? It sounds like 13 about your intelligence . It ’ s nothing to do with him
14 a failure of nerve , doesn’t it ? 14 bottling giving it to the CIA. It ’ s a pretty insulting
15 A. I had the impression he had just passed on as a post box 15 thing to say of Senator McCain. He has given it to the
16 the reporting to the FBI only and given that Mr Comey 16 FBI, he has made it clear that he knows, he has a very
17 was part of the problem, as we saw it , I think 17 senior position in Homeland Security, and he is
18 Sir Andrew saw it, that didn’ t seem to be the sort of 18 effectively saying : I know, you know, so do your job
19 engagement we had expected, or the level of engagement 19 properly .
20 we had expected. 20 A. But he seems to have passed the responsibility back to
21 Q. You see there ’ s nothing in Sir Andrew’s statement about 21 Mr Comey, who seemed to be the problem, one of the
22 Senator McCain being expected to give it to the CIA, and 22 problems in the first place , and I would have expected
23 there ’ s nothing in your witness statement to suggest 23 Senator McCain to raise it in terms of his committees in
24 that you expected Senator McCain to give it to the CIA, 24 Congress, the Homeland Security Committee and the
25 and I suggest the phrase " bottled it " is wholly inapt 25 Intelligence Committee. He doesn’t seem to have done
57 59
1 for a decision by him not to give it to the CIA. It ’ s 1 that .

2 referring to something else , isn ’ t it ? 2 Q. Look at the next sentence :
3 A. No, I don’t think it is . I think it ’ s a reflection of 3 "But [John McCain] has the [ information ] and
4 the passivity which, having engaged very 4 therefore is compromised anyway."
5 enthusiastically and sent someone to London, an element 5 What does that mean?
6 of passivity in his response , my Lord, that initiative 6 A. It means he’s associated with it and would suffer
7 thereafter . 7 potentially a backlash for having been an intermediary
8 Q. "... and left DK exposed." 8 for it , which was, in fact , the case .
9 Now, on your pleaded case , Mr Kramer is merely 9 Q. Who was your source for this information about what was
10 a postman to Mr McCain. 10 going on in Washington in this respect?
11 A. Mm-hm. 11 A. I can’t remember whether it was Mr Kramer or Mr Simpson.
12 Q. Why is he exposed by Mr McCain not giving it to the CIA? 12 Q. Would you turn over to {E/62/5}, please, this is
13 A. Can I go back to the first point you made that he’s 13 Sir Andrew’s reply :
14 merely a postman: I think that ’ s unfair on Mr Kramer, 14 "Yes but not surprising . I thought the stratagem
15 he’s obviously a very clever , experienced official with 15 unlikely to succeed."
16 a lot of knowledge of Russia , and judgments with which 16 Now, you’re not seriously saying to me, are you,
17 he would share with Mr McCain. And, in fact , as you saw 17 that the stratagem was that Senator McCain would give it
18 elsewhere , he did actually go out, with Mr McCain’s 18 to the CIA?
19 encouragement, and engage with Celeste Wallander and the 19 A. I thought that Senator McCain would raise it with
20 White House and others, so I think Mr Kramer was far 20 colleagues on his committees in Congress and share it
21 more committed to this than just being a post box; 21 with the other agencies . The fact he’d only shared it
22 Mr Simpson was the post box. 22 with Mr Comey didn’t seem to get us anywhere given that
23 Q. Could you just answer my question why -- 23 Mr Comey had been part of the original problem, as we
24 A. The second one. 24 perceived it .
25 Q. - - was Mr Kramer left exposed by Mr McCain’s bottling 25 Q. Now, I want to be very clear about this . Are you saying
58 60
1 colleagues in Congress or are you saying fellow members 1 A. Mm-hm.

2 of his committee, or are you saying both? 2 Q. Now, who’s Catherine B?
3 A. I would -- my view was that it would be members of his 3 A. That was Catherine Belton, who was, I believe at the
4 committees who were also Congressional colleagues , such 4 time, at the Financial Times.
5 as Mr Rubio, for example. 5 Q. She writes for the Financial Times and the Guardian.
6 MR JUSTICE WARBY: Mr who? 6 A. She may have been freelance at that point , I can’t
7 A. Mr Rubio, a senior senator from Florida . 7 remember.
8 MR JUSTICE WARBY: Yes. I know who Mr Rubio is. 8 Q. Now, can we just go back, please , to {E/35/10}, E1 in
9 A. Mr Kramer did actually go to Paul Ryan’s chief of staff , 9 hard copy. These are the manuscript notes of the
10 who was the Leader of the House of Representatives . 10 meeting of 11 October with the State Department. And if
11 MR CALDECOTT: You see, you suggest in your witness 11 you look at the top there :
12 statement that the idea of Congressional colleagues 12 "Winer".
13 comes from Mr Kramer after the reports had been 13 And then the first point is rather badly written ,
14 delivered . I suggest that it was your hope and plan 14 but it looks like :
15 before the reports were delivered . 15 "Catherine Belton FT."
16 A. I would say expectation rather than hopes and plans . 16 And she is the Financial Times journalist we are
17 I mean, clearly it was up to Mr Kramer and certainly 17 talking about in this message.
18 Senator McCain to decide what they thought was 18 A. Mm-hm.
19 appropriate , and they came back to me with this request 19 Q. Now how did she crop up in the 11 October meeting before
20 to talk to Celeste Wallander in the White House but 20 we get to this message?
21 didn’ t give clearance or whatever to talk to Paul Ryan’s 21 A. I think she had, again , I don’t know exact dates,
22 chief of staff or , I think , Victoria Nuland. 22 my Lord, but I think she had written a profile of
23 Q. Can we please just look at a message from you to 23 somebody called Sergei Millian around that point at some
24 Mr Winer at tab 63, hard copy bundle E3 {E/63/1}. 24 time in the Financial Times, who was an ethnic
25 "... I would still be keen to meet Toria at some 25 Belarusian , I think , who was potentially associated or
61 63
1 point ." 1 claimed to be associated with the Trump campaign.

2 That is Victoria Nuland, again , one up from the 2 Q. Had you discussed your project with Catherine Belton at
3 bottom. 3 any time? She’s a friend of yours , isn ’ t she?
4 I ’m sorry , page 6, please . {E/63/6}. 4 A. A friend , yes , she’ s a friend . No, I hadn’t
5 MR JUSTICE WARBY: I was wondering why we were going back 5 discussed - - I hadn’t discussed this project with her .
6 to July of 2016. 6 Q. Now, can we please just look at the relationship between
7 MR CALDECOTT: Yes, quite. My fault, I didn’t give the page 7 the December memorandum and a couple of the earlier
8 {E/63/6}, do you see, 24 November, just under halfway , 8 memoranda. Can we first of all , please , look at
9 between the grey and the green. 9 {E/16/1}, that’s in E1, and page 1, please . This is
10 A. Toria , yes . 10 dated 19 October, and this is report 135; yes?
11 Q. "I would still be keen to meet Toria at some point. If 11 A. Yes. I can’t see the date because it ’ s on the next
12 she is over in London at all in the current job or 12 page.
13 thereafter , if she is interested . Some activity still 13 Q. The date is on the next page, and I ’m sorry , this is not
14 ongoing on the main project from here ." 14 a good copy:
15 What is "the main project "? 15 "Kremlin insider outlines important role played by
16 A. It ’ s loose talk , but obviously the investigation , if you 16 Trump’s lawyer Cohen in secret liaison with Russian
17 like , of Trump/Russia election interference . 17 leadership .
18 Q. Can I ask you were you exploring at this time any 18 "Cohen engaged with Russians in trying to cover up
19 possibility of alternative sponsors for your work in 19 scandal of Manafort and exposure of Page and meets
20 this respect? 20 Kremlin officials secretly in the EU in August in
21 A. No. 21 pursuit of this goal ."
22 Q. Could you just look at the one below that : 22 Right?
23 "... hope you’re bearing up with everything . Are 23 A. Mm-hm, yes.
24 you in DC next week and is Toria too? Our mutual friend 24 Q. Now, if you go over to page 2 {E/16/2}, there’s
25 Catherine B is thinking of visiting ." 25 a company comment, which says:
62 64
1 "The Kremlin insider was unsure of the identities of 1 Do you see that?
2 the PA officials ..." 2 A. Mm-hm.
3 Just you just help us about PA? 3 Q. That was also new, isn ’ t it ?
4 A. Presidential administration . 4 A. I think so , yes .
5 Q. Thank you: 5 MR JUSTICE WARBY: Where is that?
6 "... [ Presidential administration ] officials with 6 MR CALDECOTT: My Lord, I’m sorry, it’s a very bad copy,
7 whom Cohen met secretly in August, or the exact date/s 7 it ’ s above the block .
8 and locations of the meeting/s." 8 MR JUSTICE WARBY: Can I just -- I will make a note and then
9 So this report is lacking in detail about (a) 9 look at the document for the passage.
10 location and (b) dates of the meetings. Now, can we go 10 MR CALDECOTT: Do you have any idea who put that redaction
11 to {E/9/1}, please , and this is report 136, which is 11 in , Mr Steele?
12 dated 20 October, and we see a development in this 12 A. None at all . I ’d always assumed it was the ( inaudible )
13 story : 13 but ...
14 "Summary. 14 Q. Now, can we go back to your defence , please , at
15 "Kremlin insider reports Trump lawyer Cohen’s secret 15 {A/13/5}, and I just want to ask you about
16 meeting/s with Kremlin officials in August 2016..." 16 paragraph 32(d) and about seven lines in there is this
17 So we now have a month, and this: 17 sentence :
18 "... was/were held in Prague." 18 "The Second Defendant [that’s you] was unaware that
19 A. Mm-hm. 19 Mr Kramer had been contacted by any media outlets about
20 Q. And then, again , this is Mr Cohen’s alleged cover-up 20 the ’ dossier ’."
21 meeting in Prague, the very selfsame meeting which is 21 Now, do you say that ’ s true?
22 the subject of the December memorandum. 22 A. Before Mr Bensinger contacted me.
23 Now, the December memorandum is at tab 17, also E, 23 Q. That’s not what it says , is it ?
24 please , {E/17/1}, and we can see that it ’ s headed merely 24 A. It says :
25 as a continuation of this subject : 25 "Mr Kramer informed the Second Defendant that
65 67
1 "US/Russia further details of secret dialogue 1 Mr Bensinger had been repeatedly contacting him with
2 between Trump campaign team, Kremlin and associated 2 requests to speak."
3 hackers in Prague." 3 So other than that , I think it ’ s true .
4 Now, there are a number of new bits of information 4 Q. Now, I think this is most easily done, so we don’t bob
5 in here . First of all , that he was accompanied by three 5 around too much, by reference to the message log, which
6 colleagues , do you see that? 6 is at {E/154/1} and one advantage of this method is that
7 A. Mm-hm. 7 it has cell numbers, do you see? On the left -hand side
8 Q. That’s new, isn ’ t it ? 8 there are numbers, which is quite a convenient way of
9 A. Yes. 9 making sure we’re all looking at the same thing.
10 Q. "With Kremlin representatives and associated operators 10 {E/154/2}, please. Sorry . Thank you very much.
11 and hackers ." 11 Now, on the left -hand side , just so we get there
12 Just pausing there , I should have made the point, 12 quickly , do you see those numbers?
13 the date here has been widened from August 2016 in 13 A. Phone numbers?
14 report 135 - - sorry , in 136 - - to either August 14 Q. Cell numbers, I ’m going to call them, right at the
15 or September; do you see? So to anyone investigating , 15 left -hand side there ’ s a row of numbers attached to the
16 who had been concentrating on August, it would now be 16 messages?
17 relevant to know that it also might have taken place 17 A. Is there?
18 in September, and that if they ’ re looking for entries to 18 Q. Before you get to A, B, C and D, you see right at the
19 Prague, ( inaudible ) they ’ re looking whether Mr Cohen 19 left -hand side each message has a separate number?
20 went there , he had three colleagues with him. 20 A. What, just 1-45?
21 A. Mm-hm. 21 Q. On that page, yes , I ’m just going to use that as an easy
22 Q. Then if you look at the detail in paragraph 2 on page 1, 22 way of picking up. Can we first of all look at 9.
23 you’ ll see there : 23 Mr Kramer:
24 "One of their main Russian interlocutors was 24 "Just spoke with him, completely otr , gave him broad
25 Oleg Solodukhin." 25 picture . Stressed importance of verifying . Merry
66 68
1 Christmas!" 1 Q. Are you sure about this ?

2 Now, "him", in fact , is Mr Bensinger, isn ’ t it ? 2 A. I ’m not sure I was asking for telephone numbers.
3 A. I believe so , yes . 3 Q. Well, there ’ s obviously some communication missing, if
4 Q. And it ’ s clear to you from that message -- we’ ll have to 4 it simply starts , "Here are some possible numbers, in
5 come to this in much more detail later , but it ’ s clear 5 order of likelihood " without any introduction or
6 to you that Mr Kramer has given a broad picture of you 6 explanation of what the numbers are.
7 to Mr Bensinger at this stage on 24 December. 7 A. Mm, it’s a bit odd.
8 Can we now look at cell 12, please : 8 Q. So there must have been some earlier communication which
9 "Can we chat tomorrow or Monday? I’ve been asked 9 explained what this was about.
10 some [questions ] about PM. Thanks, David." 10 A. As you say , it ’ s very odd. I don’t know where it’ s come
11 "PM" is Paul Manafort, isn ’ t it ? 11 from.
12 A. I think so , yes . 12 Q. You say these are American numbers?
13 Q. And he is the subject of reports 135 and the December 13 A. The first three are . The fourth one is probably - -
14 memo; right? 14 I don’t - - yes , probably .
15 A. Yes. 15 OPUS 2 VIRTUAL HEARING MANAGER: My Lord, sorry, it’s
16 MR JUSTICE WARBY: Sorry, which -- the transcript seems to 16 Stephen from Opus 2 --
17 have stopped. 17 MR CALDECOTT: It could take a while. Now, what were you
18 MR CALDECOTT: I’m sorry, my Lord, it’s E6, bundle. 18 going to do with these telephone numbers, Mr Steele?
19 MR JUSTICE WARBY: Yes, I’m on the page, just which 19 A. Usually look them up in open source telephone databases,
20 reference - - 20 look at business cards , things like that .
21 MR CALDECOTT: Sorry, cell 12. 21 Q. But any competent newspaper could do that, couldn’ t
22 MR JUSTICE WARBY: 12? 22 they?
23 MR CALDECOTT: Yes, sorry, cell 12. 23 A. You would think so .
24 MR JUSTICE WARBY: When you get used to using the 24 Q. And why would that take a while .
25 simultaneous transcript it ’ s rather disconcerting when 25 A. It can take a while to see if you can get access to
69 71
1 it stops . 1 people’ s business cards , things like that .

2 MR CALDECOTT: Yes. Or etherised. 2 Q. Is there any question here of using intelligence
3 So that ’ s cell 12. Now look at cells 16 and 17. 3 contacts to do something with this material ?
4 There’s a quick chat you have with Mr Kramer: 4 A. No.
5 "Yes, of course , shortly if you like . C. 5 Q. You’re sure about that , are you?
6 " Perfect , thanks." 6 A. Mm-hm.
7 And then Mr Kramer comes back, this is rather out of 7 Q. And then this sentence at cell 18:
8 the blue : 8 "Also, what might your line be tomorrow if they ask
9 "Here are some possible numbers, in order of 9 you if your ’ trusted foreign source ’ is the same as
10 likelihood . Not much more from the Post." 10 David Corn’s?"
11 Now, "the Post" is the Washington Post, which is one 11 Now, can you help us about who "they" is here?
12 of the papers you said that you have been managing, 12 A. I ’m sorry , I just don’t recall .
13 according to the notes of 11 October? 13 Q. And it ’ s obvious , isn ’ t it , even from the ones we’ve
14 A. It ’ s one of the papers I briefed about the election . 14 looked at so far , and we’ ll see more, that Mr Kramer is
15 Q. Now, if you go in on your laptop to those telephone 15 talking to the media coming, back to you and then going
16 numbers, even today, three of the four are to do with 16 back to the media, isn ’ t he?
17 the name Cohen. You see we don’t know because there’s 17 A. Well, he’s been asked about Paul Manafort; I ’m not at
18 obviously some missing communication here, but I suggest 18 all clear that that has anything to do with our work.
19 these numbers are all numbers of Cohen’s. 19 Q. I ’m sorry?
20 A. I don’t recall . They may be. I don’t have any recall 20 A. He said he had been asked some questions about Paul
21 of that . 21 Manafort.
22 Q. Well, that ’ s what I suggest they were. 22 Q. But you agreed with me only a few minutes ago that Paul
23 Can you remember at all why you were asking for 23 Manafort is referred to both in 135 and the December
24 telephone numbers? 24 memorandum?
25 A. No. I ’m not sure I was -- 25 A. Sure, but he is a very highprofile figure and was being
70 72
1 investigated by all journalists in Washington at that 1 Q. And we’ll see , here you are freely engaging with the
2 time. 2 media about matters in the dossier .
3 Q. "Agree. I will say that all I ’m saying is he’s 3 A. No, David Kramer is, not us.
4 a foreign source , period ." 4 Q. Well, let ’ s continue .
5 So Mr Kramer is giving information to some group and 5 "I also have nothing to add."
6 it ’ s obviously not someone who already knows your 6 Well, you wouldn’t have anything to add to someone
7 identity , otherwise there would be no need for this 7 who had got the December memorandum, would you? But you
8 description , would there? 8 would have something to add if they hadn’t got
9 A. I don’t know. 9 the December memorandum.
10 Q. Well, just think about it . If it had been, for example, 10 A. It depends what you mean by "got the December
11 the Washington Post or the New York Times, they know 11 memorandum".
12 perfectly well that you are the author of the 12 Q. Were aware of its contents and allegations ?
13 intelligence reports , don’t they? 13 A. Some of its contents , I agree .
14 A. It depends if they ’ re talking about material in the 14 Q. Now, otherwise I will probably forget this , so I shall
15 intelligence reports . I ’m not sure they are . 15 deal with this one point now. You understand, don’t
16 Q. Well, why otherwise would they say "... is the same as 16 you, that the inspection process is the process whereby
17 David Corn’s"? That’s a reference to the Mother Jones 17 the other side looks at the documents which you have
18 article , which is primarily about your work, isn ’ t it ? 18 listed . You prepare copies of your documents so that
19 A. Sure, but I don’t know what the question that ’ s being 19 the other side can see them. So they obviously - - it ’ s
20 asked is . 20 no good to them just having a list ; they want to see the
21 Q. That’s part of the problem, there are obviously 21 documents?
22 communications going on between a number of these 22 A. Which documents are we talking about?
23 messages which we don’t have. 23 Q. Documents you have disclosed in your disclosure
24 A. I mean, further back, I think we have Mr Kramer saying 24 statement.
25 he had been asked some questions about Paul Manafort, 25 A. Okay.
73 75
1 but it ’ s not at all clear by whom or what questions or 1 Q. Now, you took screenshots on your phone, is that right ,
2 whether that refers to my work. 2 and you provided those screenshots to RPC for the
3 Q. Okay, well let ’ s look at one that without any doubt 3 purposes of our inspecting the documents, and then they
4 whatever is about your work. Look at cell 23: 4 were passed on to us; do you understand that , how
5 "WSJ Alan..." 5 inspection (overspeaking) works?
6 Now, that’s Alan Cullison , isn ’ t it ? 6 A. Yes, I can’t remember if I took the screenshots or my
7 A. I think so , yes . 7 technical guy took the screenshots , but yes , I think we
8 Q. "... is about to return to DC but asked me one more time 8 took screenshots .
9 about a meeting. He’s tried to run the Prague thing 9 Q. But presumably you checked the copies to make sure
10 down to no avail . I know you’d rather not but wanted to 10 everything was there , did you?
11 ask one more time. Thanks." 11 A. I think so , yes .
12 And you reply : 12 Q. Yes. Now can we please look at {E/155/3}, and if you
13 "Thanks. Disappointing they have not corroborated 13 look at this message -- we’ve looked at this message in
14 Prague, though perhaps not that surprising . My business 14 the log . You’ ll see that the reference to "I have
15 partner and wife remain opposed to me talking to media 15 nothing to add" has disappeared between page 3 and
16 on this subject for reasons you know." 16 page 4 as we were given this document on inspection.
17 Presumably you were concerned, particularly after 17 Now, can you help us at all as to how that happened,
18 Mother Jones and Newsweek, that the searchlight was 18 because the words "I have nothing to add" are quite
19 getting rather closer to you individually ; is that 19 significant .
20 right ? 20 MR JUSTICE WARBY: Sorry, I just need to understand exactly
21 A. And because we were no longer in the contract with 21 what you’re putting to the witness .
22 Fusion we had no reason to talk to the media. 22 MR CALDECOTT: Yes, my Lord.
23 Q. But I ’m sorry , the Fusion contract , as I understand it , 23 MR JUSTICE WARBY: Page 3.
24 ended with the election in November? 24 MR CALDECOTT: Page 3 ends "for reasons you know". It then
25 A. Correct . 25 picks up " his meeting in Nova Scotia with JM". What is
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1 missing , and you can see this particularly at E/154 -- 1 into it .

2 MR JUSTICE WARBY: Which volume are we in, because it is 2 "Got it . Will do. Thanks."
3 flicking between two pages and it is a very slow 3 So he is effectively your agent, he is passing on
4 process? 4 what you are saying to him on your behalf to the
5 MR CALDECOTT: I know, my Lord, this is one area in which 5 newspaper, isn ’ t it - - to the television company in this
6 physical bundles actually are easier . We are in E6, 6 case?
7 155, page 3, about how it was produced on inspection . 7 A. I ’m getting him to deflect the question . And I’ve no
8 {E/155/3-4}. 8 idea how they got hold of the question in the first
9 MR JUSTICE WARBY: So it’s two screenshots with text 9 place .
10 messages? 10 Q. Look at cell 41, please :
11 MR CALDECOTT: That’s right, my Lord, exactly. And you can 11 "Does the name Konstantin Kalimnik ring any bells ?
12 see the missing text conveniently , but because of the 12 "Not to me?"
13 importance of this , I thought it right to show the 13 Then this :
14 witness how it was actually produced to us, but if you 14 "What is the context and can I ask my main source?
15 look at E, bundle 6, 154, {E/154}, which is where we 15 C[ hris ].
16 were, you can see the excluded words in yellow . 16 "McClatchy reporter thinks he may be involved in
17 MR JUSTICE WARBY: Yes, I saw that, and there was a later 17 some way with Manafort.
18 disclosure which - - 18 "I know the answer but said I would ask anyway ..."
19 MR CALDECOTT: Yes, and we said we want to see all -- some 19 Says Mr Kramer. And so on.
20 of these text messages, we said , were incomplete, which 20 A. Mm-hm.
21 they were, and then we get this , and I was just asking 21 Q. Now, it ’ s clear there , isn ’ t it , that you are happy to
22 the witness whether he had any explanation . 22 go back to your main source, respond to the enquiries
23 A. I don’t . I ’m sorry if that happened. It had no 23 through Mr Kramer?
24 significance , my Lord, from our point of view. 24 A. This has got nothing to do with the memos in the
25 Q. Look at cell 35, from ABC -- 25 dossier , this issue of Konstantin Kalimnik, my Lord, is
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1 MR JUSTICE WARBY: We’re back on a different page now. 1 completely new, and nothing to do with my sources.
2 MR CALDECOTT: Sorry, my Lord, we’re back on {E/154/2}, hard 2 Q. Well, it may be nothing to do with your sources but
3 copy bundle E6. 3 Mr Manafort is very much to do with your reports , isn ’ t
4 A. Sorry , what was that again? 4 he?
5 Q. I ’m on cell 35 on page 2, please . ABC, you had briefed 5 A. Mr Manafort, yes, but Mr Manafort was a very
6 in September, had you not, 2016? 6 highprofile figure and was being investigated by every
7 A. Yes. 7 journalist in Washington by this stage .
8 Q. "Have you heard anything about an audio recording in 8 Q. Now, over the page, again , just lest I forget it , and
9 Russian that corroborates the Prague meeting?" 9 perhaps we don’t need to turn it up this time, because
10 So this is all about the Prague meeting. And then 10 it ’ s the same point {E/154/3}, if you look at the top of
11 you refer to it compromising your source. And then: 11 page 3, this is about possibly having meetings, and you
12 "How on earth did they get wind of this I wonder?" 12 say :
13 Then Mr Kramer says: 13 "So does Carl Bernstein , according to [Glenn’s ]
14 "No idea. Just passing along the [ question ] what 14 colleague Pete!"
15 should I tell them?" 15 Carl Bernstein is one of the people responsible for
16 Then there’s some redacted material . Do you know 16 the CNN article , isn ’ t he?
17 why that’s redacted? 17 A. Yes.
18 A. I can’t see it . 18 Q. Now, this text was also not apparent from the inspection
19 Q. It may be to do with your ... 19 initially given , although the rest of the message was.
20 MR JUSTICE WARBY: It looks like source identification . 20 Again, can you give us any help about that?
21 MR CALDECOTT: Yes, it may be something to do with this 21 A. I honestly can’t , no. Sorry .
22 tape. 22 MR JUSTICE WARBY: Can you give me a reference to...
23 A. I can’t remember, but ... 23 MR CALDECOTT: Yes, my Lord, to the original.
24 Q. Anyway, I’m not going to press that . 24 MR JUSTICE WARBY: Presumably it’s in the same area we were
25 "So perhaps you could simply say you are looking 25 looking at before .
78 80
1 MR CALDECOTT: Yes, it is. My Lord, I’ll give you a page. 1 and then it ’ s picked up, and we’ ll see again it ’ s the
2 It ’ s the same tab as the other one we have, but we just 2 same subject , from Mr Kramer:
3 need the page. I ’m asking my junior when I have his 3 "From Alan: I just talked to the Prague guy. He
4 file , it ’ s a familiar problem. 4 said the Israeli passport does not check out ..."
5 MR JUSTICE WARBY: Where are we in this? I always used to 5 And then he goes on:
6 carry three copies of everything when my leader wanted 6 "The Trump people seem to know everything, they will
7 it . 7 certainly be covering tracks everywhere if this is true
8 MR CALDECOTT: And can we just look, while we’re just 8 because so many people have been asking about it ."
9 getting that , at cell 49: 9 And then this very important sentence :
10 " Is Ignatiev ..." 10 "I was preparing to go to Cyprus next but I expect
11 I think is " Ignatius ", not " Ignatiev ", but it may be 11 they ’ re prepared there as well . And that really is
12 a misprint . 12 crawling into the lion ’ s den, more than Moscow even."
13 A. It is , yes , it ’ s David Ignatius . 13 Now, there is no reference to Cyprus anywhere other
14 Q. "... talking to dana and tom h?" 14 than in the December memorandum, is there?
15 Those are people who you briefed at the 15 A. Could you explain what you mean by that?
16 Washington Post previously . 16 Q. Well, there is no reference to Cyprus?
17 A. Yes. 17 A. In connection with Trump/Russia, or ...
18 Q. And you quite admire Mr Ignatius , you think he’s a good 18 Q. In relation to any of the reports I ’ve seen, and I ’ve
19 journalist , is that right ? 19 read them all very closely , there ’ s no reference to
20 A. I do, yes . 20 Cyprus save in relation to my clients ?
21 Q. "I think so , yes . Will double-check." 21 A. In the memos?
22 So again, Mr Kramer is going back to check something 22 Q. In the memos, yes?
23 that you are interested in . Then you say: 23 A. Yes. But there was a wider reference in terms of , for
24 "I dealt with Tom some during my time at State. 24 example, Mr Manafort who had banking arrangements there
25 Very good, smart guy." 25 which were being investigated .
81 83
1 A. Yes, I was interested to know whether Mr Ignatius - - 1 Q. But you appreciate that the Prague meeting is directly
2 whether Dana Priest and Tom were talking to him. 2 connected to my clients - -
3 Q. Look at cell 53. We’ve already had one cell which 3 A. It is - - it ’ s in - -
4 refers to ABC, which is cell 35: 4 Q. Because you said that - -
5 "Let’ s touch base tomorrow. Had a good chat with 5 A. Sorry , it ’ s in the same memo but I don’t think it ’ s
6 ABC tonight but they have a request : bifurcate what you 6 directly connected.
7 have from your source and what came from here that might 7 Q. Well, it is , because part of the purpose of the alleged
8 be less reliable . Thanks." 8 meeting in Prague was to cover up the cybercrime, wasn’t
9 Now that suggests, does it not, must have suggested 9 it , on your account?
10 to you that ABC must have a lot of detail from your 10 A. Yes, in Prague, the cybercrime in Prague and Eastern
11 reports to want you to divide what is from, if I can put 11 Europe.
12 it very loosely , your Russian source , and what is from 12 Q. And that the operators should be paid and so on?
13 sources here? 13 A. Yes, in that part of the world .
14 A. I ’m not entirely sure what they’re talking about here , 14 Q. What I want to ask you is this : why didn’t you disclose
15 but certainly I had briefed Matt Mosk of ABC back 15 this document first time round, Mr Steele?
16 in September and I had imagined in the interim that they 16 A. I honestly don’t know.
17 had been doing their own investigations , but I ’m not 17 Q. Because at the least it is suggested, isn ’ t it , that
18 sure what that refers to . 18 the December memorandum was out there with investigating
19 Q. And then, and this is quite a long , if we get to cell 19 media and not only with BuzzFeed, because Mr Cullison as
20 54, then there ’ s quite a bit here about what Michael 20 we know is from the Wall Street Journal?
21 Cohen told ABC, and Michael Cohen is the man who goes to 21 A. Well, certainly Mr Cullison does appear to be
22 the meeting in Prague, isn ’ t he, on your course - - well 22 investigating Mr Cohen, including Mr Cohen’s alleged
23 at least on your report , I should say? 23 visit to Prague.
24 A. That’s one of the things he does, yes . 24 Q. Now could you please just look at the last two lines of
25 Q. Yes. And then there are various references to Prague, 25 the cell we were looking at , the long cell , that long
82 84
1 "From Alan" section : 1 Steele :

2 "These are the things that could possibly move the 2 " Still en route home. Speak in an hour or so ."
3 matter forward . He’s anxious to do ... if there is 3 And then just over the page at cell 83 {E/154/4},
4 anything to give him." 4 Mr Kramer says:
5 A. Sorry , where is that? 5 "CNN reporting it now. Carl never got back."
6 Q. Just before cell 58, the very end of cell 57. Some of 6 And he’s reporting to you there that Mr Bernstein,
7 these cells go backwards but if you look at 57, it ’ s 7 who is , you may remember, in the yellow writing at the
8 just about in line with that : 8 top of the previous page, of CNN, never got back.
9 "These are the things that could possibly move the 9 Now, we suggest that Mr Kramer was working his socks
10 matter forward . He’s anxious to do ... if there is 10 off , collecting detailed enquiries from the media,
11 anything to give him. 11 referring them to you, and reporting back, and
12 "Can we chat soon?" 12 effectively he was acting as your agent for
13 Then you are happy to chat with him about this : 13 communicating with the media whom you did not personally
14 "Yes. In the next hour. C[ hris ]". 14 want to meet. Right or wrong?
15 I ’m emphasising when I say him, I ’m not suggesting 15 A. I disagree with that .
16 you were talking directly with Alan Cullison , but you 16 Q. You say nothing in your witness statement about this
17 were talking with Mr Kramer about these matters. 17 aspect of your dealings with Mr Kramer, do you?
18 "Great. Just buzz me when you’re free . Thanks." 18 A. That we were discussing the issues .
19 Then we get another bit of news about the 19 Q. With the media via him.
20 Washington Post enquiries : 20 A. That he was referring things that he was hearing from
21 "[Washington Post] had long chat with [Michael 21 media contacts back to me.
22 Cohen] today and he admitted that he was in Italy 22 Q. Well, it ’ s a bit more than that, but I ’m not going to go
23 late August but denied being in Prague. So he’s not 23 through it all again , Mr Steele.
24 far ." 24 A. No, I didn’ t mention that.
25 Then could we please just go down to cell 70. 25 Q. And just briefly , this goes on after the BuzzFeed
85 87
1 Kramer reports back to you, Mr Kramer: 1 publication , doesn’t it ? Look at cell 90:
2 "Don’t have the sense that the Post is on the verge . 2 "The Flynn calls story is picking up legs ."
3 Will check again tomorrow." 3 And then at cell 94, Mr Kramer says:
4 That’s on the verge of publication , isn ’ t it ? 4 "I think it ’ s time to get that other [Manafort]
5 A. I don’t know what that refers to . 5 story out there . Get some sleep. Best, D[avid ]."
6 Q. You must have had some understanding from what he was 6 "Thanks".
7 saying? 7 And these words from Mr Kramer:
8 A. At the time, probably , but I don’t know exactly what 8 "And Ignatius is the one I ’ ll feed it to .
9 that refers to , and the Post had been investigating 9 A. It ’ s a Michael Flynn story , isn ’ t it ?
10 these things for months by this stage . 10 Q. Michael Flynn, I beg your pardon?
11 Q. No doubt. 11 A. Yes, that ’ s important.
12 "Just tried again and not able to reach him. After 12 Q. "... and Ignatius is the one I ’ ll feed it to ."
13 telling me it was urgent to talk this morning, I can’t 13 A. There’s one reference to Michael Flynn in the whole
14 reach him." 14 dossier .
15 Then you say this : 15 Q. There’s one.
16 "Typical journo ! Please keep trying . C[ hris ]." 16 A. And it ’ s an open source issue which is that he had
17 So you are encouraged by this "on the verge ", you 17 dinner with Mr Putin, I think , in 2015. So any story
18 are responding proactively to it ; do you see what 18 here about Michael Flynn is completely independent of
19 I mean? 19 anything in the dossier .
20 A. Yes, but I don’t know what he’s talking about. 20 Q. Now we come to Mr Bensinger, and you obviously knew in
21 I obviously did at the time but ... 21 2016 and thereafter that he worked for BuzzFeed?
22 Q. This interest goes on: 22 A. Mm-hm.
23 "Spoke with him. I ’m free for next 10 minutes and 23 Q. And you told us earlier when I was asking you about
24 then again in an hour." 24 the September and October briefings , that these were
25 Says Mr Kramer. 25 journalists you didn’ t know previously .
86 88
1 A. Correct . 1 A. But I had refused to engage on it .

2 Q. But you did know Mr Bensinger. He’s in a rather 2 Q. Well, we’ ll see whether that ’ s right or not in a minute.
3 different category , isn ’ t he? 3 Now, you were deposed in the BuzzFeed proceedings on
4 A. I knew of him about another issue , yes . 4 18 June 2018, weren’t you?
5 Q. Yes. I don’t want to spend too much time on the FIFA 5 A. I was.
6 enquiry , but you spent quite a lot of time and gave him 6 Q. And again, I suggest , you would have carefully
7 quite a lot of help on the FIFA investigation , didn’ t 7 considered your communications with Mr Bensinger for
8 you? 8 that purpose, bearing in mind the very proceedings were
9 A. He was writing a book and said he had a film contract 9 against BuzzFeed.
10 potentially , and that this might be a lucrative project 10 A. I can’t recall . I ’m not sure that he came up in the
11 to do with my company, my Lord. 11 questions that were permitted by the judge. The
12 Q. Now, you have known, it’ s absolutely abundantly obvious , 12 High Court had narrowed considerably the questions that
13 that the claimants are suing on a publication by 13 were permitted to be asked.
14 BuzzFeed, aren’ t they? 14 Q. Can we look, please , at {F/14/1}, F1 if you are in hard
15 A. Yes. 15 copies . This is a disclosure statement which is signed
16 Q. And the moment you received the complaint, or shortly 16 by your solicitor on page {F/14/3}, and which you
17 thereafter , you must have carefully scrutinised your 17 presumably read carefully ?
18 dealings with BuzzFeed; yes? 18 A. I presume so, although it is a year ago.
19 A. With Mr Bensinger, because the project we were talking 19 MR JUSTICE WARBY: Is this the solicitor who is said to
20 to him about was nothing to do with BuzzFeed. It was 20 have - -
21 an independent thing he was working on. 21 A. It is .
22 Q. Are you saying that your messages with Mr Bensinger were 22 MR JUSTICE WARBY: -- performed suboptimally?
23 only about FIFA? 23 A. It is , my Lord. It was a big problem.
24 A. That was a business we were dealing with, yes . 24 MR CALDECOTT: My Lord, yes, there were a number of
25 The message he sent to me obviously on Christmas Eve 25 problems, but - -
89 91
1 or whatever referred to Trump/Russia, but that was out 1 MR JUSTICE WARBY: Yes, no, no, I’m just trying -- just for
2 of the blue , my Lord. We had been discussing FIFA for 2 the purposes of identification .
3 about six months. 3 MR CALDECOTT: Absolutely, my Lord, identification of the
4 Q. Maybe you had, but I don’t accept that answer for one 4 solicitor , quite correct .
5 moment. I suggest it ’ s absolutely clear that what 5 MR JUSTICE WARBY: Oh yes, she was.
6 Mr Bensinger wanted to talk to you about as a matter of 6 Well, full disclosure , she was a pupil in my
7 urgency was the dossier , and it ’ s clear from those 7 chambers.
8 messages that that ’ s what he wanted to talk to you 8 MR CALDECOTT: Yes.
9 about, and I ’ ll go to them shortly . 9 MR JUSTICE WARBY: I know who she is.
10 A. I don’t accept that and I think he wanted to talk to me 10 MR CALDECOTT: Her legal qualification is barrister .
11 about FIFA, he was planning to come to Europe, he was 11 MR JUSTICE WARBY: Yes, that’s how I know (inaudible).
12 going to go on to Rome to talk to the FBI agent, 12 MR CALDECOTT: I think she is a partner -- also a partner in
13 I believe , because the FBI agent would be involved in 13 the firm but that can be ( inaudible ) it may.
14 the FIFA investigation , and I think he used that as 14 You see "I ", the Defendants, and you are one of the
15 a sort of cover , if you like , to try and address the 15 defendants:
16 dossier issue with me when he arrived here . But 16 "... have carried out a reasonable and proportionate
17 ostensibly , I was meeting him to discuss the FIFA 17 search to locate all the documents which the Defendants
18 project . 18 were required to disclose under the order made by the
19 Q. Can we just be clear about this allegation you’re 19 court on [ the date ]."
20 making. You’re suggesting he used it as a cover when he 20 And that’s 18 June, and just while we’re on this ,
21 arrived here? 21 the order is at {B/10/2}, 7(a), the top of page 2,
22 A. I think he used it as a cover to engage with me at that 22 please . Thank you:
23 time about my possible involvement in the investigation . 23 "By 4 pm... the parties shall serve upon each other
24 Q. I suggest he was entirely open with you about wanting to 24 standard disclosure of documents, including electronic
25 talk about the Trump dossier before he came over? 25 documents by list and category by mutual exchange."
90 92
1 Now, Mr Mathieson, your present solicitor , in the 1 his own statement of the same date, which approved the
2 hard copy right at the back of F1, {F/28/9}. 2 contents of Mr Mathieson’s paragraph 20. Mr Mathieson
3 MR JUSTICE WARBY: I just missed the date of this. Is this 3 had said that he believed that the lawyer in question
4 the March 2020 statement? 4 had properly advised the defendants of their disclosure
5 MR CALDECOTT: Your Lordship is right, it would certainly be 5 obligations , so that was the point , that the evidence
6 that . It ’ s 25 March 2020. 6 confirmed, and then the question was:
7 MR JUSTICE WARBY: Yes. 7 "I assume from that you were told that standard
8 MR CALDECOTT: And if you look at paragraph 20 on page 9, 8 disclosure , the word ’standard ’ obviously suggests that
9 Mr Mathieson says: 9 it is the usual obligation on all litigants , is that you
10 "I believe , having reviewed ..." 10 had to disclose any documents which either might advance
11 And I don’t need to read the name: 11 our case or damage yours?"
12 "... privileged advice to the Defendants that [she] 12 That was the question . I assume you were told?
13 properly advised the Defendants of their disclosure 13 A. I ’m not sure I was, my Lord. I remember -- this is
14 obligations ..." 14 a developing situation as well , we’ve found out things
15 And then you, at the previous tab, {F/27/1}, this is 15 since March which are relevant , possibly , and all
16 your fourth witness statement. 16 I remember of the disclosure was that we were given time
17 A. What’s the date, please ? 17 periods and keyword searches and things like that which
18 Q. This is the witness statement of yours of 25 March. 18 we carried out to the best of our ability . And then the
19 A. Right. 19 time window was widened subsequently, and then we
20 Q. Then at paragraph 9.29, right at the end on {F/27/9}: 20 complied with that . That’s my memory of it. Obviously
21 "I have seen that statement [ that ’ s the one, 21 it ’ s the first time we had been through an exercise like
22 Mr Mathieson’s statement which we have just looked at ] 22 this .
23 in draft and understand and approve its contents ." 23 MR JUSTICE WARBY: I’m wondering, I mean, this is obviously
24 So, Mr Steele, I assume from that you were told that 24 a difficult topic .
25 standard disclosure , the word "standard" obviously 25 MR CALDECOTT: This is a difficult topic, my Lord.
93 95
1 suggests that it is the usual obligation on all 1 MR JUSTICE WARBY: If there’s another topic that you can
2 litigants , is that you had to disclose any documents 2 cover . I don’t know whether there’s any - - I don’t know
3 which either might advance our case or damage yours? 3 whether this is a surprise which calls for a request for
4 A. I don’t accept that , and this is a very difficult 4 advice to be given on whether privilege to be waived or
5 subject , my Lord. I think you know some of the 5 not, I just don’t have any idea , but I can see that if
6 background to it . 6 the drift of the witness ’ s answer is that something he
7 MR JUSTICE WARBY: Well, I don’t know anything that 7 has already said in a witness statement is not true , in
8 I haven’t been told in court in these proceedings . 8 the light of subsequent events or some improved
9 A. Mr Mathieson’s statement. 9 understanding, which seems to be where he’s going, then
10 MR JUSTICE WARBY: I know the lawyer concerned, as I’ve 10 we might get into quite a lot of privileged territory .
11 mentioned, I know her quite well , but I ’m not sure that 11 MR MILLAR: Yes, in relation to ...
12 matters. 12 MR JUSTICE WARBY: And difficulties about representation and
13 But if there ’ s a privilege issue , then I ’ ll leave it 13 all sorts of other consequences could follow , depending
14 to Mr Millar to raise it . The question that ’ s just been 14 on what he says .
15 asked, what did go into privileged advice , so you’re 15 MR MILLAR: Yes, in relation to the defence in real time.
16 entitled not to answer. 16 The problem is this has all been rehashed in March
17 MR MILLAR: Perhaps the question would be put again 17 and April for his witness statement in this case . So if
18 (overspeaking) privilege point . 18 he is being asked about advice and communications with
19 MR JUSTICE WARBY: Yes, perhaps you could just read it back 19 witnesses - -
20 off the transcript , I can do that . 20 MR JUSTICE WARBY: What he is being asked, I think, is
21 MR MILLAR: It was -- a long series of documents put to the 21 whether, as a result of what he was told , he understood
22 witness and then there was a question at the end of that 22 the obligations to be what we all know they are, and he
23 about his state of mind. 23 said he didn’ t .
24 MR JUSTICE WARBY: So he was shown paragraph 20 of 24 MR MILLAR: Yes.
25 Mr Mathieson’s statement of 26 March and paragraph 29 of 25 MR JUSTICE WARBY: Now, if he’s going to be challenged about
94 96
1 that , then we might get into some difficulties . 1 though that’ s right from your statement.
2 MR MILLAR: Exactly, then we might veer into the contents of 2 A. I think that ’ s right , but I don’t recall precisely .
3 communication between (inaudible). If it was simply 3 Q. Well, in fairness we’d better go back to your disclosure
4 what was the upshot of your state of mind for the 4 statement, just to see that , again , at {F/14/1}. The
5 purposes of (overspeaking) - - 5 bottom box on page 1:
6 MR JUSTICE WARBY: That’s not objectionable. 6 "Mailboxes and all director and employees of the
7 MR MILLAR: -- that he somehow culpably suppressed evidence 7 Defendant and electronic file storage , with any
8 himself , he is entitled to say at this stage what his 8 resulting documents provided to RPC."
9 understanding was. 9 Do you see that?
10 MR JUSTICE WARBY: Of course he is. But that was implicit 10 A. Sorry , which number 1 saying?
11 in the question and I think he - - 11 Q. At the very bottom there’s a box, of the first page at
12 MR MILLAR: Yes, that was the reason. 12 F/14. Sorry , we’re a bit high up on the electronic
13 MR JUSTICE WARBY: Yes. 13 document?
14 MR MILLAR: I’m grateful. 14 MR JUSTICE WARBY: We’re going to need to zoom out a bit.
15 MR CALDECOTT: My Lord, you understand from my perspective 15 MR CALDECOTT: Yes, at the very bottom box, if you look.
16 at the moment I have two witness statements, both of 16 Have you got file {F/14/1}, that might help you. We’ve
17 whom which appear to confirm that the proper advice was 17 got it now, needless to say . The very bottom box; do
18 given , the obligation is common knowledge, and I haven’t 18 you see?
19 gone beyond that. 19 A. Yes.
20 MR JUSTICE WARBY: No. 20 Q. Which rather suggests that you did the selection
21 MR CALDECOTT: But it is the answer which causes some 21 exercise with the help , I imagine, of your technical
22 difficulty . 22 man?
23 MR JUSTICE WARBY: Quite. That’s why I was suggesting it 23 A. And the office manager, I think .
24 might be wise to go on to another topic because you got 24 Q. And then the resulting documents were provided to RPC.
25 an answer that I don’t suppose you were expecting . 25 A. Mm-hm.
97 99
1 MR CALDECOTT: I was not expecting, no. 1 Q. Now, I assume -- what is the relevant device we’re
2 MR JUSTICE WARBY: And come back to it. 2 talking about here , is this a phone or a laptop , or
3 MR CALDECOTT: Yes. 3 phone?
4 MR JUSTICE WARBY: I’m not directing the way the 4 A. It ’ s a phone.
5 cross -examination goes - - 5 Q. It ’ s a phone?
6 MR CALDECOTT: No, no, no, my Lord, I wouldn’t -- 6 A. It ’ s an iPhone.
7 MR JUSTICE WARBY: -- but if this sort of line is going to 7 Q. And I imagine that the , for example, take WhatsApp, the
8 be pursued it ’ s got to be done very carefully , and what 8 WhatsApp messages are in folders under the individuals
9 you’re going to ask me to do has got to be quite clearly 9 with whom you were communicating?
10 specified . 10 A. Yes.
11 MR CALDECOTT: Yes. 11 Q. And would that be also true of the SMS files and the
12 Now, Mr Steele, you did know, did you not, at the 12 Signal files ?
13 stage when your first list was prepared and signed by 13 A. I think so , yes .
14 you, that the claimants had no idea that you had 14 Q. And obviously it ’ s a very simple task to scroll through
15 exchanged messages with Mr Bensinger of BuzzFeed or they 15 the individuals to see if there ’ s anyone relevant to
16 would obviously have mentioned it? 16 this story , and if you find such a person, to then go
17 A. I don’t recall that . 17 through the messages and to see if there ’ s anything
18 Q. There’s nothing in the messages that were disclosed to 18 relevant to this story .
19 suggest that you had ever met Mr Bensinger in January, 19 A. It ’ s not always entirely straightforward because
20 is there? 20 sometimes people are in under initials or whatever, or
21 A. If you say so . 21 another name. So it ’ s not always entirely clear , but
22 Q. My Lord, I am passing over some questions for the 22 yes , in general , once you’ve found the thread , you
23 reasons that have been indicated . 23 should be able to get it all out.
24 You did the selection exercise without your 24 Q. I mean, that’s precisely why, isn ’ t it , Mr Steele, it
25 solicitor present ; is that right ? I think that looks as 25 would be absurd to limit disclosure to electronic search
98 100
1 terms, because it ’ s pure happenstance as to whether the 1 Q. " Shortly before Christmas Day 2016, the Second Defendant
2 name happens to be in the particular key document or 2 spoke with Mr Kramer (the Second Defendant is unable to
3 whether there happens to be a message file with that 3 recall who initiated the conversation ). Mr Kramer
4 name. He might be called Donald Duck for all we know. 4 informed the Second Defendant that Mr Bensinger had been
5 A. Yes. 5 repeatedly contacting him with requests to speak. The
6 Q. Yes. 6 Second Defendant suggested that Mr Kramer should
7 A. Could I explain my memory, my Lord, of this issue , 7 therefore meet with Mr Bensinger with a view to finding
8 because ... 8 out what Mr Bensinger was investigating and what he
9 Q. Well, no. 9 wanted."
10 MR JUSTICE WARBY: I think it’s probably better just to 10 Right?
11 answer questions . 11 A. Yes.
12 A. Okay, my Lord. 12 Q. First of all , there ’ s no mention in that narrative of
13 MR JUSTICE WARBY: I think that’s right. 13 any message exchanges between you and Mr Bensinger or,
14 MR CALDECOTT: I am missing quite a lot of questions for 14 indeed , between you and Mr Kramer about Mr Bensinger, is
15 precisely the reason - - 15 there?
16 MR JUSTICE WARBY: Yes, well, there are a number of reasons 16 A. It says Mr Kramer informed me that Mr Bensinger had been
17 for that and I don’t need to go through them, but among 17 repeatedly contacting him. So that ’ s referring to our
18 them are the time we’ve got and it ’ s better for you to 18 contacting him.
19 leave it to your counsel to direct you to the right 19 Q. Are you saying that second sentence would tell us that
20 topics . 20 there were written communications between the two of
21 MR CALDECOTT: Now, on 19 February 2020, the claimants, with 21 them -- between you and Mr Kramer?
22 the advantage of depositions by Mr Kramer and 22 You see the first conversation was "spoke", and the
23 Mr Bensinger in the BuzzFeed proceedings, amended their 23 next one is merely "informed"?
24 case , and can I just show you the changes. At {A/12/3}, 24 A. Yes, it ’ s not clear .
25 please . 25 Q. And do you agree that the clear impression given by this
101 103
1 MR JUSTICE WARBY: We’re in the purple, aren’t we? 1 plea is that you did not know what subject matter
2 MR CALDECOTT: We’re in the purple, my Lord, absolutely 2 Mr Bensinger was interested in , and you asked Mr Kramer
3 right , and it ’ s 8.2.6: 3 to find out?
4 "On or about Christmas Day 2016 the Second Defendant 4 A. I don’t accept that , no. I think it ’ s clear that he was
5 contacted Mr Kramer, who by then had been contacted by 5 trying to speak to Mr Kramer, that indicated he wanted
6 media outlets about the Steele Dossier , and encouraged 6 to talk to him about the dossier .
7 him to meet Mr Bensinger of BuzzFeed as a matter of 7 Q. That’s not what it says at all , is it , Mr Steele? Just
8 urgency with a view to discussing the Steele Dossier , 8 read it .
9 including the December Memorandum. He did not advise 9 A. I have read it .
10 Mr Kramer against giving Mr Bensinger the December 10 Q. "... with a view to finding out what he was investigating
11 Memorandum. In all the circumstances pleaded here and 11 and what he wanted."
12 in the Amended Reply, Mr Kramer would have reasonably 12 There’s no reference to him wishing to talk about
13 believed that he had at least implied authority to give 13 the dossier , is there , in here?
14 Mr Bensinger a copy of the December Memorandum." 14 Now, just after this defence is served , we apply for
15 Now, that’s - - I ’m not asking you to comment on that 15 specific disclosure , and our witness statement in
16 case at this stage . Now, can we just see your response 16 support reveals a new discovery which we’ ll find at
17 to this plea at paragraph 32(d). 17 {F/24/1}. It ’ s Ms McIntyre’s witness statement, dated
18 Now, wholly leaving aside disclosure issues - - 18 11 March, and on {F/24/8}, she says this , at the end of
19 A. Sorry , paragraph? 19 paragraph 25:
20 Q. I beg your pardon, {A/13/5}, again, in the purple . 20 "As Mr Bensinger/BuzzFeed were the first publishers
21 Now, wholly leaving aside disclosure issues , you 21 of the December Memorandum, all of the Second
22 obviously had to look at the Bensinger messages to make 22 Defendant’s communications with Mr Bensinger (and
23 sure that your pleaded case on this new issue was 23 Mr Kramer on this issue ) are of crucial importance,
24 truthful ; yes? 24 however not one has been disclosed by the Defendants
25 A. I imagine so , yes . 25 either as being or having been under their control ."
102 104
1 Oh, I ’m sorry , we’ve lost it again . 1 MR JUSTICE WARBY: Right, I should make a note of the date
2 MR JUSTICE WARBY: Which paragraph are you reading from? 2 there .
3 MR CALDECOTT: F1, my Lord, tab 24, page 8, paragraph 25. 3 MR CALDECOTT: Yes, which is rather important.
4 {F/24/8}. And this is - - Mr Steele hopefully is not 4 MR JUSTICE WARBY: So 9 March.
5 confused, this is ( inaudible ). 5 MR CALDECOTT: It is 9 March.
6 MR JUSTICE WARBY: It’s on the screen now. 6 My Lord, there ’ s a procedural chronology in {A/6}.
7 A. 24, is that? 7 MR JUSTICE WARBY: Yes, I know I can look these things up,
8 MR JUSTICE WARBY: Yes. 8 it ’ s just I don’t think I got the date, I certainly
9 MR CALDECOTT: 25, and I just read the last sentence of 9 didn’ t write it down, when you were pursuing the
10 paragraph 25. Yes. I could read more but I think that 10 question , there ’ s a limit to how much extra looking up
11 will do for present purposes. 11 I can do.
12 Then could you please go to page 19 of the same 12 Right, 2 o’ clock , and the usual warning.
13 witness statement at (6) {F/24/19}, where again she says 13 (1.00 pm)
14 these communications are crucial , but then in the middle 14 (The short adjournment)
15 of that paragraph she says : 15 (2.01 pm)
16 "As detailed below in paragraph 53, it has also 16 MR JUSTICE WARBY: I’m just moving the procedural chronology
17 recently come to light , as a result of the publication 17 off my screen, just so that I have ... yes .
18 of a book by the founders of Fusion, that the Second 18 MR CALDECOTT: Mr Steele, just to remind you of the context,
19 Defendant and Mr Bensinger met in London on 19 I had been showing you the claimants ’ evidence in
20 3 January 2017, further to a text message exchange in 20 support of their application for the disclosure of
21 which Mr Bensinger is said to have stated that he wanted 21 specific documents in which they said that text
22 to discuss the Steele Dossier with the Second 22 messaging between you and Mr Bensinger was of crucial
23 Defendant." 23 importance, and they also provided some examples of
24 So she’ s making the point that this seems to be 24 specific text messages in , I think , the last reference
25 rather different , and obviously this discovery of these 25 that I gave at paragraph 53 of the witness statement of
105 107
1 text messages is relied on in support of the disclosure 1 Ms McIntyre.

2 application . 2 Now, could we please look at your witness statement
3 And lastly , on {F/24/21}, there is even more detail 3 in response . It ’ s your fourth witness statement, dated
4 given of these text messages in paragraphs 53 and 54. 4 25 March 2020, at {F/27/1}, hard copy file F1. And can
5 Perhaps you could just read that very quickly to 5 we please start at 9.9 on page 5. {F/27/5}
6 yourself , Mr Steele, please , 53 and 54 on page 21 of 6 Now, you say:
7 F/24, hard copy file F1. Thank you. Tab 24, page 21. 7 "So far as I can see , Ms McIntyre does not explain
8 A. Sorry , what was that again? 8 the basis on which this category of document is
9 Q. Page 21. It ’ s now up. 9 sought ..."
10 If you could just read quickly to yourself 10 And that is :
11 paragraphs 53 and 54, and we’ ll just see that a lot of 11 "... communication records ... used by me insofar as
12 detail has emerged about these text messages. 12 they relate to communications with any of the
13 Now, you served a witness statement in response , 13 individuals listed in Schedule A."
14 which it ’ s probably best if I come to after the 14 Those individuals included Mr Bensinger, didn’ t
15 adjournment. 15 they?
16 MR JUSTICE WARBY: Yes, that sounds like a convenient moment 16 A. If you say so . I can’t see in front of me.
17 to stop . 17 Q. Yes, well it ’ s fairly obvious from parenthesis in 9.9
18 Just on the chronology here , the amendment that we 18 that they do:
19 were looking at to the claimant ’ s case was 19 February, 19 "So far as I can see , Ms McIntyre does not explain
20 and the - - I ’ve lost count of how many re-amendments 20 the basis on which this category of document is sought
21 there are , but re - re - re -amended defence was 26 June, was 21 (save in relation to communications with Mr Bensinger
22 it ? That’s what I ’ve got. 22 which I deal with below)."
23 MR CALDECOTT: No, no, the amendment to the defence, the 23 Now, I will be corrected if I ’m wrong, but below
24 relevant amendment was paragraph 32(d), is two days 24 appears to be 9.22 on {F/27/8}, which we don’t yet have
25 before this witness statement is served . 25 up. Page 8, please . Thank you.
106 108
1 9.22 simply takes us round the houses back to 1 witness statement, the other side having said , and
2 9.1- 9.5. 9.1 is merely a general case that only you and 2 there ’ s no dispute about this , that they would be of
3 Orbis communicated with any of the individuals in 3 crucial importance?
4 schedule A? 4 A. I think we are going here , my Lord, into legal advice ,
5 MR JUSTICE WARBY: Which page are we on? 5 privileged legal communications, because I can’t - -
6 MR CALDECOTT: Page 3, it’s my fault. I should have said 6 could I seek guidance on this , what I should say and not
7 {F/27/3}, please, same tab. Thank you. 7 say .
8 9.2: 8 MR JUSTICE WARBY: Not from me. You have a right not to
9 "In our response ... to Request 18... the Defendants 9 disclose legal advice that you were given . Beyond that
10 have already given information ..." 10 I can’t assist .
11 Then over to {F/27/4}, please. Do you have file 1? 11 You have a right to waive that privilege , and
12 Just to your left , they ’ re on the bench. 12 I can’t tell whether that privilege prevents you from
13 A. That one. 13 giving an answer to the question .
14 Q. That one, yes , please . 14 MR MILLAR: At the moment I have no instructions.
15 MR JUSTICE WARBY: Which one is it? 15 MR JUSTICE WARBY: No.
16 MR CALDECOTT: Could you go to {F/27/4}. 16 MR MILLAR: If my lay client wishes to waive privilege - -
17 A. Yes. 17 MR JUSTICE WARBY: No.
18 Q. And you will see what you say at the bottom of page 3: 18 MR MILLAR: -- in any legal communication in relation to
19 "... the Defendants have already been given 19 disclosure . But obviously it ’ s his prerogative to do so
20 information about the extent of my contact with 20 if he wants to.
21 journalists in the late summer and early autumn of 21 MR JUSTICE WARBY: Yes.
22 2016." 22 MR MILLAR: But if he wants to do that, I would ask - -
23 And then you say this : 23 MR JUSTICE WARBY: For the opportunity to discuss.
24 "After that time, my contact with journalists was 24 MR MILLAR: -- for the opportunity to speak to him as
25 very limited ." 25 counsel .
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1 Well, I would suggest that through the agency of 1 MR JUSTICE WARBY: I think the first question, really , for
2 Mr Kramer, it was far from very limited . 2 Mr Steele, is whether he is able to answer the question
3 A. I don’t agree with that . 3 that he has just been asked without entering into
4 Q. All right . 4 details of legal advice that he was given . If he says
5 9.3 deals with emails , which we’re not presently 5 he isn ’ t , well then we’re into the next step , but he may
6 concerned with. 6 be able to .
7 9.4: 7 I mean, the point that ’ s been put to you, Mr Steele,
8 "I did not use SMS for any communications relating 8 is you were the person who sent and received the
9 to the preparation of the December... memorandum..." 9 messages. You, one would assume, knew what was being
10 And then: 10 said , that messages between you and Mr Bensinger were
11 "There are therefore no SMS communications in my or 11 crucial , and you didn’ t need any legal advice to work
12 Orbis ’ s control ..." 12 out whether they should be disclosed . At any rate , it
13 Then 9.5: 13 was open to you to say something about them. That’s the
14 "My WhatsApp, Signal and Skype accounts were not 14 point that ’ s been put. I have glossed it . So do you
15 synced with the cloud . I have already disclosed 15 want to give me -- what do you want to say in response
16 relevant messages from those accounts to the extent they 16 to that?
17 still exist and, as indicated above ..." 17 MR MILLAR: Perhaps the question could be put again from the
18 Right? 18 transcript - -
19 A. Mm-hm. 19 MR JUSTICE WARBY: Yes, probably better.
20 Q. Now, there is nothing in here which reveals the 20 MR MILLAR: -- the question about why something isn’t in the
21 existence of the Bensinger text messages, is there? 21 witness statement.
22 A. It doesn’t appear so , no. 22 MR JUSTICE WARBY: Yes.
23 Q. I ’m not asking you about your legal advice . You were 23 MR CALDECOTT: Well, I’m very content with the way his
24 the person who received and sent those messages to 24 Lordship very carefully put it , which should not refer
25 Mr Bensinger. Why did you not reveal them in this 25 in any way to legal advice . You were the person who
110 112
1 made this witness statement. You say that you read the 1 MR JUSTICE WARBY: I’ve got the document up here.
2 other side ’ s witness statement. It ’ s blindingly obvious 2 MR CALDECOTT: Right, F/33, it’s a letter that starts at
3 to a man of intelligence that these messages are 3 page 45 and we want page 46, please , and you’ ll see that
4 important and the other side are saying they’ re 4 this refers back to the very paragraphs we’ve been
5 crucially important. Why didn’t you, of your own 5 talking about, 9.5 and 9.6:
6 volition , mention the existence of those messages in 6 "We note that Mr Steele shall conduct searches for
7 this witness statement? 7 these communications using the New Keywords. We do not
8 A. I find it difficult to answer that , my Lord, on the face 8 consider that this alone constitutes a reasonable
9 of it . I do have something I would like to say , but 9 search . If Mr Steele is aware that he communicated with
10 I ’m not sure where that leaves me. 10 relevant persons within the short relevant timeframe - -
11 MR JUSTICE WARBY: Well, if you’ve got something you would 11 a matter of months -- it would be a very easy and
12 like to say that would involve or might involve waiving 12 entirely proportionate task to search these
13 legal privilege , then Mr Millar ’ s request to be given 13 communications without using keywords. The issue of
14 an opportunity to speak to you comes into play . 14 which journalists communicated with and when is of
15 A. Yes, I think so . 15 central importance to the issues in this action . There
16 MR MILLAR: I think he explained that it relates to the 16 are only 18 people in Schedule A; and 13 media
17 content - - the privilege relates to the content of legal 17 organisations in Schedule B ... he must in any event
18 advice . 18 surely remember to whom he spoke and roughly when and be
19 MR JUSTICE WARBY: Yes, I think it’s sufficiently clear from 19 able to check the relevant device (s )... please confirm
20 the answers he has given so far that that is what he is 20 that you agree ."
21 saying . 21 Then there is a letter from your solicitors which
22 MR CALDECOTT: My Lord -- 22 starts at {F/33/49} of 27 March, just to get the initial
23 MR JUSTICE WARBY: Well, it’s a question about timing and 23 frontispiece , then if we go to {F/33/50}, the second
24 the mechanics of this . We can either wait until the 24 page of that letter , you’ ll see those two paragraphs are
25 break that we’re going to have, if Mr Caldecott can move 25 picked up. Next page, please , that ’ s {F/33/50} of the
113 115
1 on to other topics , or deal with it straightaway . 1 bundle, just the next one after this one. Here we are.
2 MR CALDECOTT: My Lord, can I just say there is one more 2 Do you see in the middle of that page, these paragraphs
3 question , just one, which may raise some considerations , 3 are picked up:
4 and I think it ’ s best to ask that , because I don’t want 4 "Paragraphs 9.5 and 9.6."
5 Mr Millar to have to have two breaks with his client . 5 Then look at the second paragraph:
6 Are you saying , Mr Steele, that if you had been 6 "... we confirm that Mr Steele is also prepared to
7 asked: did you meet with Mr Bensinger face-to- face at 7 carry out a manual search for any WhatsApp, Signal and
8 this time, you would have happily said yes? 8 Skype communications with the Schedule A/B individuals ."
9 A. Absolutely . 9 Then please look at the last sentence of this
10 Q. Now, I want to show you a letter from your solicitors , 10 section :
11 please , at {F/33}, this is F2 in the hard copy. 11 " Finally , other than the face -to- face meetings that
12 It starts on {F/33/45} and it very shortly - - sorry , 12 have been admitted, we are informed that Mr Steele did
13 I beg your pardon. Page 45 is a letter from us, and 13 not conduct communications with the Schedule A/B
14 you’ ll see that at {F/33/46} there’s this - - 14 individuals by any other method."
15 MR JUSTICE WARBY: Sorry, I’m a little behind you because 15 Now, there are two things wrong with that sentence ,
16 I was logged out. 16 Mr Steele. Firstly , you did have a face -to- face meeting
17 MR CALDECOTT: Sorry, I did see your Lordship sort of wince 17 with Mr Bensinger that has not yet been admitted, and,
18 slightly and I wondered why. 18 secondly , you did have WhatsApp communications with
19 MR JUSTICE WARBY: I was wincing because I made three 19 Mr Bensinger. Now, how does that come about? To put it
20 attempts to log in and I knew that another failed 20 another way, does that reflect what you were -- did you
21 attempt would lead to a three -minute gap but, be that as 21 read this letter before it went?
22 it may, I was behind you on references , that ’ s the 22 A. I ’m not sure I did .
23 point . 23 Q. I just want to go back and see what ...
24 MR CALDECOTT: Is your Lordship on the hard copy one or the 24 MR JUSTICE WARBY: I’m just wondering about the
25 document one? 25 interpretation of this , whether your second point is
114 116
1 a good one or a bad one. 1 Q. "... did Steele have some expectation that this wouldn’t
2 MR CALDECOTT: That’s exactly what I was checking myself, 2 go public ?
3 I think it ’ s the first point that is the one I should 3 "No, no, I think he expected that it would come out
4 be - - 4 in one form or another. I don’t think he anticipated
5 MR JUSTICE WARBY: I don’t think it’s asserting -- 5 the exact way it did come out. But he was also hoping
6 MR CALDECOTT: The second one is not the same. 6 that his name would not be released . He was not
7 MR JUSTICE WARBY: "At the same time we’ll have a look for 7 interested in being the target of attention that way."
8 WhatsApp messages and there aren’t any." 8 Then I don’t think I need to read it , but you will
9 MR CALDECOTT: Yes, I think that’s right, I think that ’ s 9 see three lines to the same effect over the page.
10 a better point on the witness statement. 10 Now, can we please go to the Bensinger messages, and
11 Mr Steele, can I revise my question, I think my 11 I think it ’ s best to look at these in their original
12 second point is a bad one. The point I should be 12 form at {E/69/1}, and the hard copy, if you want to
13 confining myself to is : 13 refer to it , it ’ s E3.
14 " Finally , other than the face -to- face meetings that 14 A. 69?
15 have been admitted ..." 15 Q. {E/69/1}, and I want to take this quite slowly .
16 Because there had been no admission by you, having 16 The first message is from Mr Bensinger, top left :
17 looked at paragraph 32(d) of your purple defence , there 17 "Great. I ’d tentatively plan to be in London on
18 had been no admission by you of any meeting with 18 Monday Jan 24, and Tuesday the 25th. That sound good?"
19 Mr Bensinger up and until and, indeed , beyond, this 19 Right. I make it clear , I accept that ’ s
20 letter . That statement, do you agree , is false ? 20 an exploratory phone call about meeting about FIFA. And
21 A. Yes. 21 you say :
22 Q. It ’ s obviously information that , on the face of it , 22 "Yes, I ’ ll be around then and will look forward to
23 could only have come from you; that only you would know, 23 seeing you over here . Seasons best wishes to you as
24 wouldn’t you, who had met with the schedule A 24 well ."
25 individuals ? 25 That seems to show that you are on cordial terms
117 119
1 A. Well, I had discussed it with my solicitor . 1 with Mr Bensinger and he is not a journalist of whom you
2 Q. Before I pursue that , I think that had better be perhaps 2 are wary; right ?
3 on Mr Millar ’ s agenda sheet and I am going to move on 3 A. Mm-hm.
4 because I can’t - - 4 Q. And then on the left :
5 MR JUSTICE WARBY: Are you happy with that, Mr Millar? 5 " Excellent . Just thinking now it would be great to
6 MR MILLAR: Yes. 6 get on a Skype call with you ..."
7 MR CALDECOTT: Now, can we now -- and we’re close to the 7 MR JUSTICE WARBY: It’s a little early today!
8 end, subject to these points - - can we please just go to 8 (Pause).
9 the obviously important Bensinger messages themselves. 9 I ’ve had some identifying information but I ’m not
10 Can I just remind you before we do of one piece of 10 going to reveal it .
11 evidence from Mr Kramer, and I’ ll come back to some more 11 It might be an idea to shut the window, if we can do
12 as we go through to see what he says about this , but at 12 that , just for the moment, while we try and stop that
13 tab 49, of E2, that ’ s {E/49/1} this is Mr Kramer giving 13 because it is a distraction .
14 evidence to the Permanent Select Committee on 14 (Pause).
15 Intelligence . 15 So Mr Bensinger is saying :
16 A. Which page, sorry , Mr Caldecott? 16 "... would be great to get on a Skype call with ...
17 Q. Page 20, please {E/49/20}, hard copy file E2. 17 something that’ s come up..."
18 A. Page 20 in the bundle? 18 MR CALDECOTT: Then these important words:
19 Q. Page 20 of tab 49. And I’m just putting this to you to 19 "... come up at your earliest convenience."
20 point out what Mr Kramer says: 20 So something new has come up, I suggest , beyond the
21 "Okay. When you were talking to him in December, 21 first message which he is treating as urgent , and will
22 after he talked to Comey..." 22 see that you interpret it in precisely that way:
23 So after he talked to Comey, that "he" is 23 "Just going to bed here. What’s the thing which has
24 Senator McCain. 24 come up?"
25 A. Mr McCain. 25 So you know he is not talking about FIFA. There’s
118 120
1 something new that’s come up and he wants to talk to you 1 Q. Anyway, let ’ s return to the message that we were looking
2 about that at his earliest convenience. 2 a at 59.
3 Mr Bensinger: 3 MR JUSTICE WARBY: Just a moment. I’m picking up the
4 "Trump related. Tomorrow?" 4 reference to - -
5 It ’ s worth bearing in mind this is 23 December and 5 MR CALDECOTT: Sorry, {E/59/1}, hard copy E3, page 1.
6 very late at night and tomorrow is Christmas Eve. And 6 MR MILLAR: 69, I think.
7 you say : 7 MR CALDECOTT: No, 59 for this one, it is Mr Kramer’s.
8 "Probably. What’s the angle?" 8 MR MILLAR: Yes, that was the witness statement, F - - tab
9 And he says: 9 71, page 5, paragraph 9.10.
10 "People are telling me that Sen[ator ] McCain has 10 MR JUSTICE WARBY: Sorry, Mr Caldecott?
11 a dossier and it ’ s Russia related ." 11 MR CALDECOTT: E3, tab 59, page 1, this is Mr Kramer’s text
12 Now, at this juncture , this is 24 December, in the 12 message to you which comes exactly in the chronology
13 early hours of the morning, this message from 13 which I ’ve been following closely in Mr Bensinger’s
14 Mr Bensinger talking about the dossier and 14 messaging. I ’m just inserting it in the right place .
15 Senator McCain. 15 So it comes after Mr Bensinger says :
16 Now we need to go to tab 59 at page 1 {E/59/1}. 16 "People are selling me that Senator McCain has
17 MR JUSTICE WARBY: This is E/59, the same file? 17 a dossier and it ’ s Russia related . Can we discuss?"
18 MR CALDECOTT: Yes, E3, 59, page 1 from the hard copy file, 18 You agree that there is at least a phone call
19 Mr Steele. 19 between you and Mr Kramer, and then we have this message
20 I just remind you that you say : 20 from Mr Kramer:
21 "At or around the same time, Kramer told me during 21 "Just spoke with him, completely [ off the record ],
22 a Skype or phone call that Mr Bensinger was questioning 22 gave him [a] broad picture . Stressed importance of
23 him about the Trump/Russia issue and seeking to speak to 23 verifying . Merry Christmas!"
24 him." 24 And it ’ s obvious from the next message that you
25 This text was disclosed by you first time round, 25 weren’t very amused by being contacted on Christmas Eve
121 123
1 but, of course , unless you are in the know, one wouldn’t 1 by Mr Bensinger, which we can all understand.
2 know that "him" in the first and the second line was 2 Now, at this stage can I take you to some evidence
3 Mr Bensinger: 3 from Mr Kramer, again in the same file but at {E/75/15}.
4 "Just spoke with [Mr Bensinger], completely [ off the 4 I beg your pardon, eyesight , {E/78/15}, hard copy file
5 record ], gave him broad picture . Stressed [the] 5 E3. If you look at the quarter pages, the top
6 importance of verifying ." 6 right -hand page, Mr Fray-Witzer, this is the US
7 Now, just while we’re on this , you say that it was 7 Gubarev/BuzzFeed proceedings:
8 during a Skype or phone call . Is that - - I thought, if 8 "Question: I believe you told us that Mr Steele
9 you look back, and I ’m sorry to jump around but it ’ s 9 suggested that you speak with Ken Bensinger at BuzzFeed;
10 really impossible not to in this case to a degree, if we 10 is that correct ?
11 go back to {F/27/1} in hard copy file 1, to your fourth 11 "Answer: That is correct .
12 witness statement, at page 5, F1, tab 27, page 5, at 12 "Question: When did Mr Steele make this suggestion
13 9.10 on page 5 you say : 13 to you?
14 "In any case , there are no phone records because 14 "Answer: It was either Christmas Day -- excuse me,
15 I never used a landline or mobile carrier network in my 15 Christmas Day or right around there , right around that
16 limited communications with the schedule A individuals ." 16 holiday .
17 Are you sure that ’ s right ? 17 "Question: Was this in a telephone conversation ?
18 A. Pretty sure . I need to look at the list of individuals 18 "Answer: Yes.
19 again , but I ’m pretty sure that ’ s right . Skype ... 19 "Question: To the best of your recollection , what
20 Q. Well, the heading here - - 20 did Mr Steele say to you about contacting Ken Bensinger?
21 A. Sorry , Skype can be just a call , it ’ s not necessarily 21 "Answer: He indicated to me that Mr Bensinger had
22 a videolink . 22 been in touch with him, had heard about the existence of
23 Q. But you say here : 23 the document. And he vouched for Mr Bensinger saying
24 "... during a Skype or phone call ". 24 that he had worked with him and BuzzFeed in the FIFA
25 A. They’re sort of the same thing, I think , technically . 25 investigation which Mr Steele had been involved in ."
122 124
1 Now, just pausing there , Mr Kramer had no 1 Now, pausing there , Mr Steele, I ’m suggesting to you
2 involvement at all in the FIFA investigation , did he? 2 it ’ s abundantly clear that Mr Bensinger is coming all
3 A. No, but he was aware of it . 3 the way to London from the States to discuss dossier
4 "Answer: [And he] felt that Mr Bensinger was very 4 issues and not FIFA, from this run of messages.
5 trustworthy and professional but that he wasn’t in 5 A. I actually think he’s coming to discuss both.
6 a position from London to talk with him or meet with 6 MR JUSTICE WARBY: Well, are we talking about whether it’s
7 him. So he asked me if I would -- if he, Mr Steele, 7 clear now or whether it was clear then.
8 could give Mr Bensinger my phone number. 8 MR CALDECOTT: Clear then.
9 "Question: And what did you say to Mr Steele? 9 MR JUSTICE WARBY: Right.
10 "Answer: I said yes , that was fine . 10 A. I suspected, my Lord, that he might want to try and
11 "Question: Did Mr Steele ask you to provide 11 raise the Trump/Russia investigation with me and as
12 Mr Bensinger with a copy of The Memos? 12 I think I explained in my witness statement, I was keen
13 "Answer: He didn’t either way. 13 not to look shifty or whatever by cancelling a meeting
14 "Question: So just so that I understand, he didn’ t 14 which I wouldn’t normally have cancelled , effectively
15 ask you to give him a copy, he didn’ t ask you not to 15 with a commercial client .
16 give him a copy? 16 MR CALDECOTT: But just look at the context. He is
17 "Answer: Correct . 17 originally tentatively planning to come on 24 or
18 "Question: Did Mr Bensinger subsequently contact 18 25 January. Suddenly something comes up and he wants to
19 you? 19 come at your earliest convenience. You ask what. He
20 "Answer: Yes. 20 says it ’ s Trump-related, explains the Senator McCain
21 "Question: And presumably that was by telephone? 21 dossier point , and the next minute we have
22 "Answer: Yes. 22 a confirmation of when he’s going to arrive .
23 "Question: Do you remember what date that was? 23 Now, what brought him to London so quickly, we say,
24 "Answer: It may have been the next day, so possibly 24 was clearly the dossier . That’s what he’s coming to
25 the 26th or the 27th." 25 talk to you about. Of course he may have thrown in the
125 127
1 And just going back to pick this up, we’ve looked at 1 odd bit about FIFA, but we say it ’ s clear that he’s
2 Mr Kramer’s, and then do you see we get to 30 December: 2 coming to talk to you about the dossier , and, indeed ,
3 "Hello there . Just tried ringing you. Do you have 3 you knew that Mr Kramer had by this stage already given
4 a moment to chat? Travel- related question ." 4 him a broad overview off the record .
5 And then from Mr Bensinger: 5 Then he comes over and, just while we’re on this , at
6 "Confirming that Tuesday works for me -- let me know 6 this stage generally you were not meeting journalists ,
7 what time to come by. Thanks!" 7 you were communicating through the agency of Mr Kramer,
8 A. I don’t have the reference in front of me but ... it 8 and we went through all those messages this morning.
9 hasn’t come up. 9 We say you made an exception with Mr Bensinger
10 MR MILLAR: Can we get it up? 10 because you knew him quite well by this stage , and
11 MR CALDECOTT: I’m sorry, I beg your pardon, yes, {E/69/1}, 11 that ’ s why you were prepared to meet with him and
12 hard copy bundle E3. 12 discuss this subject ?
13 A. On E3 it’ s what, sorry ? 13 A. I don’t agree with that .
14 Q. Tab 69, page 1, this is the first sheet of messages. 14 Q. Then we see on page 2 of {E/69/2}, still , obviously ,
15 Now, it ’ s pretty obvious that we’re missing some 15 file E3, the meeting is on 3 January, and there ’ s
16 communications here because you’ ll see that we jump from 16 a message on that date:
17 the discussion about Senator McCain. I ’m not saying 17 "Good seeing you. Will be in touch."
18 they are missing messages of this type , but there 18 And then the first thing you get from him on
19 obviously are communications which we don’t have because 19 6 January is a, if I can put it loosely , a Trump-related
20 we jumped straight to : 20 article about his finances :
21 "Just tried ringing you. Do you have a moment to 21 "Would be interested in hearing your reaction ."
22 chat? Travel - related question ." 22 A. Sorry , which page are we on?
23 So we now know that he’s definitely coming: 23 Q. Page 2 of tab 69 of E3 {E/69/2}. And instead of
24 "Confirming that Tuesday works for me. Let me know 24 saying - - this is Trump territory , Russia territory ,
25 what time to come by. Thanks!" 25 I ’m not getting into this , you say :
126 128
1 "I ’ ll take a look at this over the weekend. Best 1 hiding ." {E/69/3}.
2 Chris ." 2 Now, pausing there , this is sent on the day that the
3 And then, good journalist that he is , he says : 3 Wall Street Journal revealed your identity as the
4 "Thanks. Should warn you it ’ s more innuendo than 4 author; is that right , 14 January?
5 proof of anything, but [ it ] seemed potentially 5 A. No, I think that was before .
6 interesting ." 6 Q. Was it?
7 And then, as we know, the BuzzFeed article - - 7 A. This was a couple of days - - I think that was the 11th
8 MR MILLAR: I’m sorry, was there a question on that? My 8 or the 12th. This was a couple of days later , I think .
9 learned friend read a number of messages out but he 9 MR JUSTICE WARBY: There’s the date of 14 January at the
10 didn’ t ask a question . It ’ s not cross -examination just 10 bottom of page 2.
11 to read messages, is it ? 11 A. Yes, the day when the Wall Street Journal revealed my
12 MR CALDECOTT: My Lord, it’s difficult, I’m trying to give 12 identity was before the 14th January.
13 a fair context . I was reading the message -- 13 MR JUSTICE WARBY: It was the 12th.
14 MR JUSTICE WARBY: I think the point you were making was 14 MR CALDECOTT: It was the 12th. Yes, my mistake.
15 that having been sent an article relating to Trump, he 15 A. So it ’ s two days later .
16 didn’ t say : get away, I ’m not dealing with Trump 16 Q. Now:
17 territory . 17 "I was very upset to hear you were forced to go into
18 MR CALDECOTT: Yes, that’s right. 18 hiding . For what it is worth, which I suspect is not
19 MR JUSTICE WARBY: But he hasn’t really had an opportunity 19 much, I have not told anyone we met and do not plan to."
20 to give a response or explanation for why he didn’t or 20 Now, pausing there , if your meeting was about FIFA,
21 whether he didn’ t . 21 this would be a completely irrelevant observation to
22 MR MILLAR: Yes. 22 make, wouldn’t it ?
23 A. Or, indeed , the content of the meeting with 23 A. I don’t agree . I think he’s trying to assuage his
24 Mr Bensinger. 24 conscience for what he’s done.
25 MR CALDECOTT: Well, I’m coming to that, but do answer the 25 Q. Do you mean he is telling a lie there , implicitly ?
129 131
1 question . 1 A. What sort of lie ?

2 A. I was basically trying to keep Mr Bensinger at arm’s 2 Q. Implying that you had spoken about the dossier when you
3 length , partly because I was afraid he was trying to 3 say you hadn’t?
4 investigate whether I had been involved in the 4 A. No, I don’t think he is saying that .
5 Trump/Russia investigation , and secondly , because 5 Q. Well, why would he want to keep secret the fact that you
6 I wanted to preserve the commercial opportunity that he 6 had met if it was only about FIFA?
7 presented to me when he came to London that he had 7 A. Presumably because precisely it implied something
8 a film deal on top of a book deal for this FIFA project , 8 different .
9 and I felt that if I just was completely rude and cut 9 Q. Mr Steele, what we say is this : that throughout this
10 him off , then he would take that deal elsewhere and 10 history , you were keen to get your detailed allegations
11 I would have no part of it . 11 out in the media, not necessarily including
12 Q. You understand that we say that these messages suggest 12 sourceidentifying material . If it meant assisting the
13 something quite else , and that you wouldn’t have brought 13 media to investigate to achieve that objective you did ;
14 Mr Bensinger all the way over from the United States at 14 right ? Do you agree with that?
15 his earliest convenience, asking to discuss the dossier 15 A. Before the election .
16 if all you were going to do when he arrived was say: no, 16 Q. Well, we’ve looked at a whole run of messages with
17 I ’m not discussing that subject . 17 Mr Kramer after the election , haven’t we?
18 A. He told me he was coming to discuss FIFA and that he was 18 A. Yes.
19 going on to Europe, my Lord, to meet other FIFA- related 19 Q. And just - - I ’m not going to go through them all again ,
20 contacts as part of that trip . 20 but you were assisting the media, we say, with a view to
21 Q. Well, I ’m not going to go back over the text messages. 21 getting your allegations out there , if that assistance
22 We disagree on their interpretation , plainly . 22 was necessary .
23 And then the last message on page 3: 23 A. I don’t fully accept that either , my Lord. A lot of the
24 "I am sorry this has been such a difficult week. 24 issues that were discussed at that time were not related
25 I was very upset to hear you were forced to go into 25 directly to the material that was in the dossier . The
130 132
1 Michael Flynn material , the Paul Manafort material , and 1 I ’m not asking for any advice , when did you first give
2 so on, Kalimnik; these were new issues that journalists 2 the Bensinger messages to your solicitors ?
3 were investigating at the time. 3 A. A long time ago, I believe . I can’t remember exactly
4 Q. What about the frequent references to Prague? 4 when, but a long time ago.
5 A. Yes, that may be an exception. 5 Q. Well, if there ’ s going to be an interval to discuss
6 Q. And also we say the history shows that you were quite 6 these matters, I would like an answer to that question ,
7 happy for your allegations to be published to the world 7 please .
8 at large when they had not been verified . 8 A. ( Inaudible ) is my recollection .
9 A. I disagree with that . 9 Q. And you were unable this morning, for example, to
10 Q. I thought you said that the Yahoo article in your view 10 explain why you didn’t disclose the message from
11 served the public interest ? 11 Mr Cullison which revealed that he had been briefed on
12 A. No, I said that the Yahoo article I understood had been 12 the allegations in the December memorandum, because he
13 either confirmed or verified by Mr Isikoff ’ s source in 13 said he was going to Cyprus; do you remember that? And
14 the DOJ. 14 I asked you could you explain why this was not
15 Q. Yes, and I cross -examined you about that and suggested 15 disclosed , and you said you don’t know, is what you
16 that the article said no such thing? 16 said , I think : I don’t know.
17 A. But what we were told was that that happened. 17 A. I think that was to be discussed with my counsel.
18 Q. That’s not what the article says , is it ? 18 Q. And the three , just look again , if we may, at
19 A. No. 19 Mr Kramer’s deposition at {E/78/1}, this is file E3, we
20 Q. You also agreed that the Mother Jones interview was with 20 want the hard copy:
21 a view to publication , so close to the election . That, 21 "... the copy of The Dossier you gave to those news
22 again , I suggest - - there was no way that Mr Corn was 22 organisations include the last two pages?"
23 going to be able to verify what you told him in that 23 That’s the December dossier. And he said:
24 interview before publication , was there? 24 "Not to Fred Hiatt at The Post, not to Peter Stone
25 A. I ’ve no idea what Mr Corn had or was doing otherwise, 25 and McClatchy.
133 135
1 and there was no indication that he was immediately 1 " It did to Alan Cullison ..."
2 going to publish anything. 2 The electronic reference , I ’m sorry . {E/78/28},
3 Q. You see, I suggest that you did , as you were doing 3 please :
4 throughout this period , you did brief Mr Bensinger about 4 "... it did to Ken Bensinger, it did to Carl
5 the details of your dossier in London on 3 January? 5 Bernstein ."
6 A. I deny that absolutely . 6 You see, all three of those players figure in our
7 Q. And I also suggest , I ’m not suggesting it in the form in 7 complaints about disclosure . Can we go back, please , to
8 which it happens, because as we all know it included the 8 your defence .
9 unredacted pre - election memoranda, but that you were 9 MR JUSTICE WARBY: Sorry, I’m a bit lost, {E/78/28} where?
10 also doing so as you were doing this throughout, with 10 MR CALDECOTT: My Lord, that’s what we’re looking at, E3 or
11 a view to publication ? 11 E/78, page 28, very top of the left -hand column.
12 A. I disagree with that as well . I thought it was the 12 A. Page 109.
13 business of the US Government to deal with this issue 13 MR CALDECOTT: Lines 5-6.
14 and to announce anything that was relevant to it . 14 MR JUSTICE WARBY: Right.
15 Q. What I don’t understand, Mr Steele, is this : if you had 15 MR CALDECOTT: And we have looked at this, and it’s
16 a meeting with Mr Bensinger on 3 January in which you 16 important. Can we please look at paragraph 32 at
17 positively told him that you were not prepared to 17 {A/13/5}.
18 discuss the Trump dossier, why was that not pleaded in 18 MR JUSTICE WARBY: Just remind me when Mr Kramer left
19 your defence at the very beginning or at any time 19 Mr Bensinger in a room with the documents?
20 thereafter ? 20 MR CALDECOTT: That is on 29 December, before the meeting on
21 A. I don’t know. 21 3 January.
22 Q. You don’t know. 22 MR JUSTICE WARBY: Yes.
23 A. It is pleaded in my witness statement, my most recent 23 MR CALDECOTT: Can we just look very carefully at 32(d),
24 witness statement. 24 because I will , indeed at the conclusion of this case ,
25 Q. Can I ask you this : when did you first , and again, 25 invite an adverse inference from this :
134 136
1 " Shortly before Christmas Day 2016, the Second 1 at least 10 minutes because this is a convenient moment
2 Defendant spoke with Mr Kramer (the Second Defendant is 2 for the break, but you may need longer.
3 unable to recall who initiated the conversation ). 3 MR MILLAR: I may need 15 minutes.
4 Mr Kramer informed the Second Defendant that 4 (2.58 pm)
5 Mr Bensinger had been repeatedly contacting him with 5 (A short break)
6 requests to speak. The Second Defendant suggested that 6 (3.21 pm)
7 Mr Kramer should therefore meet with Mr Bensinger with 7 MR CALDECOTT: Mr Steele, we have juniors to remind us of
8 a view to finding out what Mr Bensinger was 8 things we’ve forgotten and I have one thing I ought to
9 investigating and what he wanted." 9 put to you that is extremely short . This is another
10 Now, why does this narrative say nothing about the 10 short extract from Mr Kramer’s evidence at {E/78/1},
11 3 January meeting between you and Mr Bensinger? 11 bundle E3 in hard copy.
12 A. I don’t know. 12 A. 78.
13 Q. Well, that won’t really do, will it , because on your 13 Q. E/78 at page 54. {E/78/14}.
14 account, it positively assists your case , and the 14 A. Page 54 of the actual - - in the boxes?
15 inference I will invite the court to draw is that it ’ s 15 Q. Sorry , if you go to page 14, if you would, yes , it ’ s my
16 not there because, in fact , it ’ s damaging to your case 16 fault , {E/78/14} and 54 in the box.
17 when you truly know what happened at that meeting, 17 A. Yes.
18 otherwise it would be here ; do you understand what 18 Q. Then you will see at line 18:
19 I ’m saying? 19 "Then, the other two were BuzzFeed and
20 A. I do, but I don’t agree with you, Mr Caldecott. 20 Carl Bernstein ."
21 Q. Well, you are the only person who can give instructions 21 And then this :
22 about these matters. Did you read 32(d) carefully 22 Both of the meetings [ that ’ s those two meetings]
23 before it was served? 23 occurred at Mr Steele’ s request ."
24 A. I can’t remember. What I was taking issue with, 24 A. Mm-hm.
25 Mr Caldecott, was that you claimed that this was 25 Q. Now, is that right , first of all in relation to
137 139
1 detrimental to our case but, as you will see from my 1 Mr Bernstein?

2 witness statement later , I don’t think it is detrimental 2 A. Not as I recall it , no.
3 to our case . 3 Q. How certain are you about that?
4 Q. I ’m not interested in your witness statement at this 4 A. I ’m not certain .
5 stage , I ’m interested in this statement, which is 5 Q. And what about BuzzFeed and Mr Bensinger?
6 settled by leading and junior counsel , and has 6 A. Yes, I asked him to meet Mr Bensinger.
7 a statement of truth at the end of it . 7 Q. Thank you very much.
8 My Lord, that might be a convenient moment to have 8 Now, my understanding from my learned friend is that
9 this discussion , I think , between Mr Millar and -- 9 you are not waiving privilege and as a result of that ,
10 MR JUSTICE WARBY: Well, do I understand, then, that you 10 I ’m not going to ask you questions about your dealings
11 have concluded your cross -examination subject to 11 with your solicitors . I just want to ask you a few
12 anything that arises from that? 12 questions on the subjects which I explored with you.
13 MR CALDECOTT: Yes, I just want to check about one matter. 13 A. Yes.
14 MR JUSTICE WARBY: It’s probably a convenient moment. 14 Q. The first relates to your first list of documents, and
15 MR CALDECOTT: It might be a convenient moment anyway, 15 I think we are agreed that you did not include in that
16 my Lord. It ’ s been quite a ... 16 list any reference to the Bensinger messages; correct ?
17 MR JUSTICE WARBY: Well, it’s dense material. 17 A. Yes.
18 MR MILLAR: So is cross-examination concluded? 18 Q. Now, I just want to ask you, as an intelligent person
19 MR JUSTICE WARBY: As I understand it, it is. 19 with your kind of experience , did you not appreciate
20 MR CALDECOTT: Yes, subject to those behind me telling me 20 personally that to do justice in this case , it was right
21 I ’ve missed some vitally important point . 21 and proper that those messages should be revealed to the
22 MR JUSTICE WARBY: Yes, well take as much time as you need, 22 claimants?
23 bearing in mind the limits of the time available to us 23 A. Yes.
24 between now and the end of tomorrow, and you’ ll let me 24 Q. And I suspect you had read our particulars of claim when
25 know when you’re ready to resume. We’ll obviously take 25 they were served , and you would have noted that on at
138 140
1 least two occasions we say: 1 it .

2 "Pending disclosure , the claimants freely admit that 2 MR JUSTICE WARBY: Yes, I understand. I mean, unless
3 they do not know the precise identities ..." 3 Mr Millar wants to quarrel with that , I mean, I think
4 And so forth . Do you understand what I mean? That 4 you’ve got a basis for making some submissions to me.
5 disclosure was plainly being highlighted in our case as 5 MR CALDECOTT: Yes.
6 something which would shed light on what had actually 6 MR JUSTICE WARBY: Not including an adverse inference,
7 happen in detail , it ’ s obvious , from seeing the other 7 I think . Not including an adverse inference from
8 side ’ s documents. 8 asserting the privilege .
9 A. Yes. 9 MR MILLAR: Not including an adverse inference from
10 Q. I want to ask you the same question in relation to your 10 asserting privilege , yes .
11 witness statement. Simply as a layperson with your 11 Re-examination by MR MILLAR
12 experience of public life , did you not think that it was 12 MR MILLAR: Mr Steele, you were asked some questions about
13 wrong to say that you had disclosed all relevant 13 the Newsweek article ; do you remember that?
14 WhatsApp messages as a layman, just with your own 14 A. Yes.
15 conscience , leave aside any legal advice? 15 Q. And it was put to you - - this was this morning -- it ’ s
16 A. Yes. 16 at {E/159/1}, I think that ’ s the highlighted version .
17 Q. Did you read the solicitors ’ correspondence for the 17 A. E what, sorry ?
18 purposes of this trial ? 18 Q. {E/159/1} in the bundle, please . Here it is , it ’ s here .
19 A. I think so . I can’t remember exactly when I read what 19 It ’ s the highlighted version with the footnotes , do you
20 or whether I read everything , but I think I did . 20 remember you were asked?
21 Q. Did you read the passage which plainly appears to deny 21 A. Yes.
22 any face -to- face meetings with Mr Bensinger by 22 Q. And it was put to you that it must have been clear to
23 implication in the letter which I showed you? 23 you from the article when you read it that there were
24 A. I ’ve read that page, yes . 24 unredacted copies of your memos "out there" that needed
25 Q. And do you accept it ’ s wrong? 25 prompt action?
141 143
1 A. It ’ s wrong, yes . 1 A. Yes.

2 Q. Yes. Were you concerned when you saw that in the letter 2 Q. And in your answer you mentioned speaking to
3 as something that we had been told? 3 Glenn Simpson, you discussed your relationship with the
4 A. It didn’ t register , to be honest. 4 FBI. Did you consider doing anything else in terms of
5 Q. And lastly this , and I don’t think this is a privileged 5 action?
6 question : have you ascertained when you did provide the 6 A. I considered going to the FBI but we had sort of
7 Bensinger messages to your solicitors , first of all ? 7 suspended communications and contact, so that was not
8 A. Not with absolute clarity , my Lord, but certainly by, 8 feasible so in reality the only person I could really
9 I think , April this year . 9 contact was Mr Simpson, to check whether he knew
10 Q. I do want a bit of help about this . 10 anything about this , and he didn’ t .
11 A. Yes. I can’t - - I think they ’ve done some work on their 11 Q. You were asked some questions about what I would call
12 records but I can’t talk to the solicitor . 12 the , I don’t know if it ’ s the correct soubriquet , but
13 Q. I ’ ll accept April for the moment. 13 the "McCain bottled it " message at {E/62/4}. I think
14 When did you first disclose the existence of the 14 the relevant page is {E/62/5}.
15 Bensinger messages to your solicitors ? 15 A. It ’ s not come up yet.
16 A. I ’m not sure, but no later than April this year . 16 Q. {E/62}. It ’ s E3.
17 Q. And no earlier than April , but - - 17 A. E3.
18 A. I don’t know, to be honest. 18 Q. You are messaging Sir Andrew.
19 Q. Well, it should be a matter of record and I ’m quite 19 A. Mm-hm.
20 content to accept an answer after investigation , but 20 Q. And you mentioned in your answer when you were asked
21 I would like an answer to that question , I think it is a 21 about the words "compromised" that McCain might suffer
22 reasonable one to ask. 22 a backlash?
23 A. Mm-hm. 23 A. We haven’t actually got this on the screen , I don’t
24 MR CALDECOTT: My Lord, in the light of the maintenance of 24 think .
25 privilege , I think that ’ s as far as I can properly take 25 Q. I think it ’ s probably the next page, is it ?
142 144
1 A. I ’ve got the stratagem text . 1 Trump/Russia?

2 MR CALDECOTT: It’s the one behind that section, page 4. 2 A. I had no particular interest . I knew they were doing
3 You’ve got page 5 and we want page 4. 3 the investigations . I hoped those investigations
4 MR MILLAR: It’s {E/62/4}, I can guarantee if you go to the 4 obviously would be thorough and professional , but I had
5 hard bundle it will appear. 5 no interest in the investigations .
6 A. Which bundle is it ? 6 Q. You were taken to a document, if we can get it up on
7 Q. It is bundle 3. E3. It ’ s up, no, it ’ s not. 7 screen , that would be easier , thank you, you can put
8 A. I ’ve got E3 here. 8 that away now, at {F/14/1}. It ’ s a list of documents
9 Q. Yes, it is . You were asked about the word 9 for standard disclosure . You were taken to the bottom
10 "compromised"? 10 of page 1, "Mailboxes of all director and employees ..."
11 A. Yes. 11 et cetera ; do you remember that?
12 Q. And you said he would suffer a backlash? 12 A. Yes.
13 A. Yes. 13 Q. Then you were taken to page 3, I think , with the
14 Q. Do you want to expand on that, what you had in mind? 14 signature on it from Ms Cain, and it ’ s dated
15 A. A political backlash , if he had been discussing and 15 29 July 2019.
16 acting on this set of memos with senior law enforcement 16 A. Mm-hm.
17 or Congressional colleagues , then he would suffer 17 Q. Were you shown that disclosure statement?
18 a political backlash from Mr Trump. 18 A. I can’t remember.
19 Q. And you said you thought he did in the next part? 19 Q. Do you recall the circumstances in which you disclosed
20 A. I thought he might, and I think he certainly did . 20 in your witness statement at E7/25, {E/25/1} and in the
21 Q. What did that involve ? 21 disclosure in response to the consent order in April ,
22 A. I think we would have to go back and look at it , but it 22 the face -to- face meeting with Bensinger and the
23 involved things like the flag not being flown at half 23 messages?
24 mast when he died, and things like that . 24 A. Not precisely , but it was when we had two solicitors and
25 Q. You were asked at some length about your messaging with 25 two barristers working on the case and on the material .
145 147
1 Mr Kramer, at {E/154/1}. I think that ’ s when you were 1 Q. Do you recall the application for specific disclosure in
2 asked about it . It ’ s colour -coded -- 2 March?
3 A. Is there a reference on the bundle? 3 A. Yes.
4 Q. Yes, it ’ s the last bundle, E6. 4 Q. I think what’s being put to you is that it would be
5 A. Yes. Is that it here now on the screen? 5 appropriate to draw an adverse inference as to your
6 Q. Yes, that ’ s the colour -coded, 154. 6 honesty as a witness in this case from the fact that
7 A. Yes. 7 that is when those things were disclosed ; do you follow ?
8 Q. And you were taken to pages 3 and 4. 3, first , please . 8 A. Yes.
9 Do you want to get it up in the bundle ( inaudible ), turn 9 Q. Do you want to comment on that?
10 the page. 10 A. I would say it ’ s an oversight by us. There’s absolutely
11 A. What’s the bundle number, please? 11 no way I would ever try and conceal anything from this
12 Q. {E/154}, bundle 6, pages 3 and 4. 12 court , my Lord.
13 A. Yes. It ’ s up now. Yes. 13 MR JUSTICE WARBY: Well, Mr Steele, I’ve got no questions,
14 Q. Okay. It ’ s messaging with Mr Kramer in early January, 14 so we’ve come to the end of your evidence , thank you.
15 this is when it was put to you that you were 15 So it will be Sir Andrew next by videolink ; yes?
16 communicating with journalists through Mr Kramer using 16 Can you just remind me where he is giving his evidence
17 him as your agent. 17 from?
18 A. Yes. 18 MR MILLAR: Where?
19 Q. Having looked now at some length a number of times at 19 MR JUSTICE WARBY: Yes.
20 those pages, is there anything in there , you see there 20 MR MILLAR: The Channel Islands. He was shielding at the
21 that is Mr Kramer telling you he was talking to 21 time.
22 journalists about the dossier ? 22 MR JUSTICE WARBY: Yes, I remember authorising this, there’s
23 A. No. A reference to Prague, that ’ s all . 23 no question about the legitimacy of it , it ’ s just the
24 Q. What was your interest in whether journalists in 24 bare fact of where it was I couldn’ t remember.
25 Washington were doing their own investigations into 25 MR MILLAR: Five minutes to get him connected?
146 148
1 MR JUSTICE WARBY: Yes, I’ll rise for five minutes just to 1 Q. And the standard procedure is to put a black block
2 get the technicalities sorted out. 2 through any sensitive source material which the
3 (3.39 pm) 3 recipient shouldn’ t see in the service ?
4 (A short break) 4 A. I never had such documents to me when I was in the
5 (3.55 pm) 5 service .
6 SIR ANDREW WOOD (affirmed) 6 Q. Can I just ask you a question about Russia . It ’ s
7 Examination-in- chief by MR MILLAR 7 a dangerous place and it would be a dangerous place for
8 MR MILLAR: Sir Andrew, it’s Gavin Millar QC here, counsel 8 journalists to investigate sensitive political matters,
9 for the defendants, Orbis and Mr Steele. We have in our 9 would it not?
10 file of witness statements in this case a witness 10 A. Yes, certainly . But also their duty, I should add.
11 statement in your name, which runs to three pages and 11 Q. And just , you may not be able to answer this question ,
12 has a signature on the third page and is dated 12 but if you were dealing with allegations of a sensitive
13 15 April 2020. It ’ s in the bundle at {C/8/1}. 13 nature in Russia , the obvious investigators would be
14 Can you hear me? 14 people with access to intelligence , would it not?
15 A. I can hear you now, yes . 15 A. Yes, but I should add that I was not in the intelligence
16 Q. Do you have a copy of that witness statement? 16 service myself .
17 A. I do. 17 Q. No.
18 Q. Is that your signature on the third page? 18 A. I was the recipient of such documents.
19 A. It is . 19 Q. Now, did you understand in November 2016, which is when
20 Q. And are the contents of that witness statement true to 20 your brief role in this occurs , that Mr Steele’ s
21 the best of your knowledge and belief ? 21 relationship with the FBI was continuing?
22 A. They are. 22 A. That was my understanding, yes.
23 MR MILLAR: Thank you. Will you wait there, please . 23 Q. Thank you. Now, you helpfully prepared a document for
24 Cross-examination by MR CALDECOTT 24 the Senate Intelligence Committee, do you remember that?
25 MR CALDECOTT: Sir Andrew, I represent the claimants in this 25 A. I do.
149 151
1 matter and I hope you -- you may not have the pleasure 1 Q. And I think it ’ s dated March 2018, and I think you have
2 of seeing me, but I hope at least you can hear me? 2 a copy with you.
3 A. I can hear you, yes . 3 A. I do.
4 Q. A few short questions . Firstly , in the diplomatic and 4 Q. I just want to ask you about the paragraph which starts :
5 intelligence fields , it ’ s not uncommon to have reports 5 "Mr Steele asked shortly ..."
6 from sensitive sources . Is that - - a fairly obvious 6 And it ’ s the second new paragraph, but the third
7 statement, but I assume it ’ s right . 7 paragraph on the second page which in our bundle is
8 A. It is , correct . 8 {D/3/3}:
9 Q. And it ’ s also common to have reports with sensitive 9 "Mr Steele asked shortly after the US elections had
10 content, even though they may not mention sensitive 10 been completed to see me again. He told me that while
11 sources? 11 at least the basic elements of what has since become
12 A. Yes. 12 known as his ’ Dossier ’ were known to people within the
13 Q. And anyone of experience in Crown service would 13 then existing Administration , he did not know that the
14 appreciate the importance of protective markings for 14 same was true of senior Republicans ."
15 both these kinds of documents? 15 Just pausing there , did you know that Mr Steele had
16 A. Yes. 16 briefed the media about some of his intelligence
17 Q. And talking about source material , redaction is 17 in September of 2016?
18 a standard procedure depending, of course , on who the 18 A. He didn’t mention that at the time, no.
19 document is going to be shown to? 19 Q. Or in October 2016, just before this ?
20 A. Yes. 20 A. I should emphasise two things , if I may. First , that
21 Q. And it may be greater or less , depending on the 21 I have not read the dossier and do not know the details
22 recipients ? 22 of what is in it , and I did not know that at the time.
23 A. I ’m not sure about that . I don’t remember it being so 23 He gave me a general account of what was in it . He said
24 when I last saw such documents, which was in - - well , in 24 that he was in touch with the FBI. That is the first
25 the year 1999. 25 thing .
150 152
1 The second thing is that the - - he had had 1 understanding from what he said in response that
2 connections with, as I said , the FBI, and we spoke at 2 he would be expected or necessarily wish to show it to
3 that first meeting of his links with Mr Strobe Talbott, 3 others .
4 which is why I knew that the administration was aware of 4 Q. Can you please - - I think you do have these , I hope,
5 its contents . 5 Sir Andrew, which are your text messages with Mr Steele.
6 I was not aware of what other discussions he’d had. 6 A. Yes.
7 He referred to an American partner, or colleague , but 7 Q. We have them, and just so I can give everybody the
8 he did not mention his name and I didn’ t ask for it . 8 reference , it ’ s {E/62/4} and we want to look, if we may,
9 Q. As I understand it , in this discussion Mr Steele said 9 just at page 4 of those messages, E3 if anybody has the
10 that it might be right to tell a trustworthy senior 10 hard bundle, at tab 62. This is a message from
11 Republican of its existence on a confidential basis and 11 Mr Steele to you at the bottom of that page. Do you
12 to allow such a person to read the document, and after 12 have them green and grey; is that how they appear on
13 some discussion Senator McCain was thought to be 13 your page?
14 a suitable person. 14 A. Well, there ’ s green and grey.
15 A. That is correct . Senator McCain was, of course , not 15 Q. Yes, thank you. I think you’ ll see that green is
16 obliged to read it , and I was asked to ask him whether 16 Mr Steele, and on 19 December this, of course , is after
17 he wished to see it or not. 17 your visit to Halifax , after Mr Kramer has come to
18 Q. Can you just help me a little about, if you look at two 18 London, after he has collected - - had a conversation ,
19 complete paragraphs from the end, it starts : 19 then the reports go to the United States , then they find
20 "I subsequently met Senator McCain..." 20 their way to the late Senator McCain.
21 A. Yes. 21 I just want to ask you a little bit about this , as
22 Q. It ’ s the pre -penultimate paragraph, and halfway in you 22 to what you understood Mr Steele to be saying :
23 say : 23 "A [that ’ s you ], JM [that’s the late Senator McCain]
24 " All I could say was that I could vouch for the 24 appears to have bottled it ..."
25 personal honesty and professional integrity of the 25 What did you think he was referring to there?
153 155
1 person who had gathered the material ..." 1 A. I don’t honestly recall . I know he took the papers to
2 That’s Mr Steele. 2 the FBI himself . Whether he wished to pursue them
3 "... and that I agreed with that person that it was 3 further than that , I don’t know. I ’m not quite sure
4 right to ensure that its existence was known in 4 what "bottled it " meant.
5 responsible Republican circles ..." 5 Q. And what about:
6 Now, just pausing there , obviously Senator McCain 6 "... and left [David Kramer] exposed"?
7 was to be the recipient . Was the intention that 7 A. Yes, again , it was difficult for me to interpret at the
8 he should share it with like -minded Republicans, by 8 time. I suppose David Kramer had come across and taken
9 which I mean people who would be concerned about these 9 the documents and Senator McCain had simply taken them
10 matters in the proper way? 10 to the FBI, which already had them, something like that .
11 A. That wasn’t the intention of the discussion , but it was 11 Q. Can I just pause there for a moment? It was a wholly
12 not certainly ruled out by the discussion . The main 12 proper thing , wasn’t it , for Senator McCain to give it
13 purpose was to say such a report existed . I would add 13 to the FBI? Although they already had it ,
14 that there was plenty of other material in the run-up to 14 Senator McCain had such a position that for them to know
15 the election itself , which put a more generalised 15 that he knew that they had it had some value, surely ?
16 context about whether or not the candidate Trump had 16 A. I ’m trying to look into his mind but I suppose he did
17 particular links or interests with the Russians . 17 think that , yes . I have no personal knowledge at all of
18 As I think I just said , there was no obligation at 18 what the senator actually made of the document. All
19 all on Senator McCain to wish to send someone to look at 19 I remember is that when I spoke to him about it ,
20 these documents. My understanding from him was that 20 he thanked me in very flattering terms, and he made
21 when the person he did in the end decide to send had 21 a remark to the effect that he would be looking at the
22 looked at them, that person could judge whether or not 22 interests of his nation as his first criterion . That
23 they should be seen and read by him. What he did after 23 refers back to some fairly rude things that candidate
24 that was entirely up to him, his responsibility . There 24 Trump had said about the senator during the campaign
25 was not any suggestion on my part or any idea of my 25 itself , I suppose.
154 156
1 Q. Just reading the - - leaving the next two sentences , then 1 sure that they were so evaluating . I don’t know what
2 it says : 2 answer he gave to that , but that must have been part of
3 "But [John McCain] has the info and therefore is 3 his decision not to pursue it further in Congress.
4 compromised anyway." 4 Secondly, I think it fair to remember that the
5 Can you help us as to why he would be compromised by 5 senator himself was either becoming or already was
6 merely having the information? 6 seriously ill at that particular time. So I honestly
7 A. Well, that ’ s more of a comment, not made by me, but it’s 7 cannot look into his possible judgment. All I can say
8 a ( inaudible ) this . 8 is that I took the message of the existence of this
9 Q. No. Could you just turn over the page, please , to the 9 document to him because it’ s possible , of course , to
10 next page, and this is your reply {E/62/5}, and while 10 deny anybody -- to doubt anybody’s honour and
11 I find your second paragraph comforting , I only want to 11 truthfulness and so on, but I have never , myself , seen
12 ask you about the first paragraph. 12 any cause to do so in the person of Senator McCain, who
13 A. Sorry . 13 seemed to me, anyway, to be the very soul of
14 Q. "Yes but not surprising . I thought the stratagem 14 truthfulness , courage and honour.
15 unlikely to succeed." 15 Q. I don’t think anyone in this court has been critical of
16 Now, that’s your reply . Can I just ask you what the 16 Senator McCain so I can reassure you about that .
17 stratagem was? 17 Shall I just ask you a little bit about Mr Kramer?
18 A. I don’t remember discussing a stratagem, but my 18 How well did you know him in November 2016?
19 assumption had been that the senator would mention it to 19 A. I ’ve known David Kramer for many years, and the
20 other people in his committee in Congress, in the 20 positions he has held in Republican presidencies , his
21 Senate, something like that anyway. But we did not 21 leadership of various groups in the United States , and
22 discuss a stratagem. The stratagem, as far as I was 22 I have always had the highest respect for him.
23 concerned, was simply to satisfy the requirement that 23 Q. He is an honest man in your assessment and your
24 the Republicans at a senior level at least knew of the 24 experience of him as at November 2016?
25 existence of this document. 25 A. If he has ever told a lie to me or in my presence,
157 159
1 Q. Was there not some hope, I mean bearing in mind, 1 I can’t think why and I’ve never noticed .
2 I appreciate you had not read the dossier , but you were 2 Q. And he is also a man who is concerned about Russian
3 aware that some of the suggestions in it were serious ? 3 misconduct of this type?
4 A. From the description I had of it , which was only three 4 A. Certainly .
5 points , again , as reported to the Senate, the 5 Q. And indeed I think I ’m right in saying I think he has
6 implications of that were very serious indeed . 6 quite a close interest in Russian affairs ?
7 Q. Yes. And was there not a hope that those whom you might 7 A. Certainly . That’s one reason I know him quite well .
8 have regarded as a responsible Republican group in 8 Q. And it ’ s also quite right to say that you trusted him
9 disagreement with Mr Trump, if I can use that phrase , 9 but so did Senator McCain, didn’t he?
10 would take some action to ensure that it was 10 A. That is also correct .
11 investigated ? 11 MR CALDECOTT: Thank you very much, Sir Andrew. The
12 A. Well, yes . 12 defendants’ counsel may or may not have further
13 Q. Can I just ask you how long you’ve known -- sorry , I beg 13 questions , but thank you for your time.
14 your pardon, Sir Andrew, you’re trying to add something? 14 Re-examination by MR MILLAR
15 A. It ’ s my fault . 15 MR MILLAR: Did you express your views about Mr Kramer to
16 I think I should just repeat what the senator 16 Mr Steele?
17 himself said : that the criterion he was guided by was 17 A. Almost certainly . I mean --
18 not his feelings about President - elect Trump. It was 18 Q. Along the lines that you - -
19 about what was best for his country. I did not doubt at 19 A. He did not answer that particular question , but it would
20 the time that I spoke to him that he saw the 20 be an odd question to ask anyway.
21 implications of this as being very serious indeed if 21 Q. Yes, but it was a barrister ’ s question in a trial , so ...
22 true , and that he would wish to ensure that the reports 22 A. Sorry , I don’t mean to be foolish .
23 in that would be properly evaluated . 23 Q. No, no, that ’ s all right . Do you remember what you said
24 So I suppose that his prime aim in going to the FBI, 24 to him about Mr Kramer?
25 even though he knew they already had it , was to make 25 A. Probably no more than that I had plenty of dealings with
158 160
1 him in Russian affairs and discussing Russian business 1 we understand he has put in a bid for the whole day, so
2 with him; that I knew he was close to the senator and 2 he’s probably the most anxious.
3 that he would be an appropriate person for me to speak 3 MR JUSTICE WARBY: Do you want to bid for an earlier start
4 to to ask the senator whether he wished to see me on 4 than that?
5 these general matters. 5 MR CALDECOTT: My Lord, no.
6 Q. And we know that Mr Kramer ended up as an intermediary 6 MR JUSTICE WARBY: I didn’t think you would!
7 to Mr McCain, Senator McCain from Mr Steele. Did you 7 MR MILLAR: I think he will get the lion ’ s share of the day.
8 discuss that with Mr Steele? 8 MR JUSTICE WARBY: Right. Then 9.30 tomorrow.
9 A. I don’t recall him questioning me on the subject . 9 (4.19 pm)
10 I mean, I was hardly likely just to barge up to the 10 (The court adjourned until 9.30 am on
11 senator in the middle of a big conference and say: I ’ve 11 Friday , 23 July 2020)
12 got something to tell you. 12
13 Q. No, I mean later on, in relation to passing documents to 13
14 Senator McCain. 14
15 A. Well, it was Senator McCain’s suggestion that David 15
16 should come across to the UK to look at the documents 16
17 and, if necessary , take them back. 17
18 Q. And what did you think about that? 18
19 A. I couldn’ t think - - it didn’ t even occur to me that 19
20 he was anything other than a trustworthy and reliable 20
21 intermediary . 21
22 MR MILLAR: Thank you very much. 22
23 Does your Lordship have any questions ? 23
24 MR JUSTICE WARBY: I don’t have any questions. So, 24
25 Sir Andrew, thank you very much for being patient and 25
161 163
1 giving your evidence . That’s the end of it . 1 INDEX

2 Thank you, we’ ll terminate the link . 2 PAGE
3 A. Thank you. 3 Housekeeping .........................................1
4 MR JUSTICE WARBY: Now it’s time for your closing speech. 4 MR CHRISTOPHER STEELE (continued) ....................2
5 Sorry . 5 Cross-examination by MR CALDECOTT .............2
6 MR MILLAR: You needn’t say sorry: because of the way we had (continued)
7 discussed the timetabling I had prepared to make it this 6
8 afternoon . Re-examination by MR MILLAR .................143
9 MR JUSTICE WARBY: Well, so I understood, because I’ve got 7
10 the hard copy authorities . But I ’m not going to - - SIR ANDREW WOOD (affirmed) .........................149
11 I don’t think this is a good time to start . There seems 8
12 a risk that I might not be concentrating to the degree Examination-in- chief by MR MILLAR ...........149
13 I should . 9
14 MR MILLAR: I can assure you I had been hoping to make it Cross-examination by MR CALDECOTT ...........149
15 this afternoon but the timetable has slipped a bit . 10
16 MR JUSTICE WARBY: Yes, it has. The original proposal was Re-examination by MR MILLAR .................160
17 that we would be on to your closing or that of 11
18 Mr Caldecott today - - at the beginning of today, so 12
19 we’re a day behind. 13
20 Well, we must deal with it tomorrow, and since we’ve 14
21 got a ready and willing member of staff to start early , 15
22 and there ’ s no reason not to , we can start at 9.30 if 16
23 that suits you. 9.30? 17
24 MR MILLAR: Splendid. I shall discuss with Mr Caldecott 18
25 splitting the time, but I ’ve already indicated to him -- 19
20
162
21
22
23
24
25
164
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141:15 america (1) 3:15 arms (5) 12:11,15,25 18:1 43:12 49:9,25 52:4 75:12 belton (3) 63:3,15 64:2 8:2,16,20,21 9:2 48:8
A
advise (1) 102:9 american (8) 6:6 26:12 41:1 130:2 115:9 125:3 153:4,6 158:3 bench (1) 109:12 briefings (1) 88:24
a123 (1) 101:24 advised (2) 93:13 95:4 42:15 43:1 45:19 71:12 arose (1) 51:3 away (3) 22:23 129:16 147:8 bensinger (79) 67:22 68:1 briefly (1) 87:25
a131 (2) 34:1 46:21 advisor (1) 10:20 153:7 around (7) 63:23 68:5 119:22 69:2,7 88:20 89:2,19,22 british (3) 42:16,22,23
B
a132 (1) 46:22 advisors (1) 19:25 americans (1) 42:24 121:21 122:9 124:15,15 90:6 91:7 98:15,19 101:23 broad (9) 10:11 25:17,18,21
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102:20 136:17 affirmed (2) 149:6 164:7 amused (1) 123:25 arrive (1) 127:22 68:18 115:17 103:4,7,8,13,14,16 128:4
a153 (1) 52:12 afraid (1) 130:3 andor (4) 44:3,3,10,10 arrived (3) 90:16,21 130:16 b102 (1) 92:21 104:2,22 105:19,21 107:22 broadly (2) 23:4,6
a156 (1) 43:23 after (45) 4:24 11:16 12:2 andrew (27) 11:13,17 article (32) 9:14 10:2 12:4 back (47) 2:9 7:6 14:8,22 108:14,21 110:21,25 broken (3) 20:24 40:7 43:8
a6 (1) 107:6 16:3,5,7 18:12 22:13 12:18,20,21 13:8 27:24 18:4,13 19:14 20:18 21:25 15:20 18:11 20:10 21:15 112:10 114:7 116:17,19 brought (3) 2:5 127:23
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ab (2) 116:8,13 39:7,10,11 50:9,16 51:3 144:18 148:15 149:6,8,25 42:10,16,18 73:18 80:16 67:14 70:7 72:15,16 73:24 122:3,4 123:15 bullet (2) 4:1,9
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82:4,6,10,15,21 86:12 87:25 104:14 106:14 161:25 164:7 133:10,12,16,18 143:13,23 86:1 87:5,8,11,21 93:2 125:4,8,12,18 126:5 127:2 69:18 77:15 78:3 116:1
ability (1) 95:18 109:24 116:1 118:22,23 andrews (3) 53:9 57:21 articles (2) 41:6 52:2 94:19 98:2 99:3 109:1 128:9 129:24 130:2,14 118:18 126:12 139:11
able (9) 9:12 32:3 86:12 123:15 132:17 142:20 60:13 ascertained (1) 142:6 115:4 116:23 118:11 134:4,16 135:2 136:4,19 143:18 145:5,6,7
100:23 112:2,6 115:19 152:9 153:12 154:23 angle (1) 121:8 aside (4) 21:5 102:18,21 122:9,11 126:1 130:21 137:5,7,8,11 140:5,6,16 146:3,4,9,11,12 149:13
133:23 151:11 155:16,17,18 angles (5) 15:25 16:2,7,10,13 141:15 136:7 145:22 156:23 141:22 142:7,15 147:22 152:7 155:10
above (4) 4:8 27:7 67:7 afternoon (3) 18:10 162:8,15 announce (1) 134:14 ask (45) 6:12 18:5 27:5 161:17 bensingerbuzzfeed (1) bundles (1) 77:6
110:17 again (39) 7:16 10:8 16:20 announcement (1) 49:15 33:24 34:3 37:4 40:19 background (2) 5:5 94:6 104:20 bureau (2) 24:18 26:16
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absolute (1) 142:8 43:18,18 55:7 62:2 63:21 85:19 89:4 96:1 97:24 56:23 62:18 67:15 72:8 145:12,15,18 bernstein (6) 80:13,15 87:6 burst (1) 21:12
absolutely (10) 15:17 19:1 65:20 78:4 80:8,20 81:22 100:21 114:20 116:20 74:11 79:14,18 84:14 98:9 backwards (1) 85:7 136:5 139:20 140:1 business (11) 6:11 18:10
32:10 89:12 90:5 92:3 83:1 86:3,12,24 87:23 91:6 119:4 139:9 111:22 114:4 125:11,15,15 bad (3) 67:6 117:1,12 best (11) 15:20 88:5 95:18 22:4 40:9,12 71:20 72:1
102:2 114:9 134:6 148:10 94:17 99:4 102:20 answer (35) 9:6 12:21 37:8 127:19 129:10 134:25 badly (1) 63:13 106:14 114:4 119:11,23 74:14 89:24 134:13 161:1
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accept (17) 8:24 9:4 36:25 133:22 134:25 135:18 101:11 111:13 112:2 113:8 153:8,16 155:21 157:12,16 balloon (1) 1:20 better (7) 14:5 99:3 buzz (1) 85:18
37:8 43:15 45:13 47:23 152:10 156:7 158:5 124:11,14,18,21 158:13 159:17 160:20 banking (1) 83:24 101:10,18 112:19 117:10 buzzfeed (18) 28:9 37:17
52:7 90:4,10 94:4 104:4 against (5) 17:16 22:2 44:5 125:4,10,13,17,20,22,24 161:4 bare (1) 148:24 118:2 84:19 87:25 88:21
119:19 132:23 141:25 91:9 102:10 129:25 135:6 142:20,21 asked (32) 17:21 26:13 barge (1) 161:10 between (27) 8:20 11:15 89:14,18,20 91:3,9 98:15
142:13,20 agencies (2) 53:21 60:21 144:2,20 151:11 159:2 42:12 43:3 52:13 55:6 69:9 barrister (1) 92:10 13:20 19:24 21:22 35:7,19 101:23 102:7 124:9,24
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access (4) 37:10 38:4 71:25 agenda (1) 118:3 answered (1) 8:4 91:13 94:15 96:18,20 base (1) 82:5 66:2 73:22 76:15 77:3 97:3
C
151:14 agent (8) 38:5 40:2,10 79:3 answers (1) 113:20 104:2 112:3 114:7 125:7 based (2) 5:13 24:18 103:13,14,20,21 107:22
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151:10,15 154:13 158:14 alone (1) 115:8 57:2 108:24 141:21 155:24 assure (1) 162:14 behest (1) 5:7 97:16 127:5 139:22 150:15 121:18 123:5,7,10,11
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address (1) 90:15 already (17) 23:25 35:14 apply (1) 104:14 attempts (2) 38:20 114:20 being (29) 1:10,19 3:18 144:13 155:24 156:4 136:10,13,15,20,23
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adjournment (2) 106:15 96:7 109:10,19 110:15 84:1 140:19 150:14 158:2 attended (1) 29:12 54:8 57:22 58:21 59:5 bottom (11) 30:9 49:21 62:3 139:7 142:24 143:5 145:2
107:14 128:3 156:10,13 158:25 appreciated (3) 22:11,16 attending (1) 1:13 72:25 73:19 80:6 83:25 99:5,11,15,17 109:18 149:24,25 160:11
administration (6) 55:10 159:5 162:25 23:25 attention (2) 41:7 119:7 85:23 96:18,20 104:25 131:10 147:9 155:11 162:18,24 163:5 164:5,9
56:11 65:4,6 152:13 153:4 also (31) 4:14 8:11 16:2,5,14 approach (1) 43:22 attorneys (2) 45:19 48:7 112:9 119:7 123:25 141:5 box (8) 57:15 58:21,22 call (19) 11:16 19:17 20:19
admire (1) 81:18 22:16 28:1 29:16 36:19 approached (3) 5:13 audio (3) 31:13,14 78:8 145:23 148:4 150:23 99:5,11,15,17 139:16 23:9,11,19 24:3 32:21 39:7
admission (2) 117:16,18 61:4 65:23 66:17 67:3 72:8 27:21,22 august (14) 11:3,5,16 20:6 158:21 161:25 boxes (1) 139:14 68:14 119:20 120:6,16
admit (1) 141:2 75:5 80:18 92:12 100:11 appropriate (3) 61:19 148:5 21:15,16 26:12 64:20 belarusian (1) 63:25 breach (2) 37:22 49:18 121:22 122:8,21,24 123:18
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116:12,17 117:15 133:6,20 134:7,10 150:9 approve (1) 93:23 author (3) 22:25 73:12 131:4 believe (20) 3:3 7:2,23 10:18 39:12,13,16 40:5,13,21,23 called (5) 9:14 14:12 22:2
adopted (1) 47:17 151:10 160:2,8,10 approved (1) 95:1 authorise (1) 30:16 13:6 18:21 20:16 21:10 48:17,23 113:25 139:2,5 63:23 101:4
adopting (1) 45:18 alternative (1) 62:19 april (9) 39:18 47:1 96:17 authorising (1) 148:22 30:19 31:1 33:22 34:19 149:4 calling (2) 20:4 34:18
advance (2) 94:3 95:10 although (8) 26:25 35:20 142:9,13,16,17 147:21 authorities (1) 162:10 40:13 54:6 63:3 69:3 90:13 breaks (1) 114:5 calls (3) 41:11 88:2 96:3
advantage (2) 68:6 101:22 39:14 47:21 55:19 80:19 149:13 authority (1) 102:13 93:10 124:8 135:3 bredhoff (1) 45:19 came (8) 9:24 38:6 40:17
adverse (5) 136:25 143:6,7,9 91:18 156:13 area (3) 27:25 77:5 80:24 autumn (1) 109:21 believed (7) 29:4 50:10 brief (2) 134:4 151:20 61:19 82:7 90:25 91:10
148:5 always (6) 44:21 67:12 81:5 arent (6) 16:11 25:18 35:9 avail (1) 74:10 52:16 53:22 55:11 95:3 briefed (13) 7:17 8:11 130:7
advice (15) 11:14 93:12 100:19,21 159:22 89:14 102:1 117:8 available (5) 12:13 13:1 102:13 42:3,12,15,25 43:6 70:14 campaign (6) 5:10 19:3 22:5
94:15 96:4,18 97:17 amended (2) 101:23 102:12 argue (1) 40:23 37:23 56:10 138:23 bells (1) 79:11 78:5 81:15 82:15 135:11 64:1 66:2 156:24
110:23 111:4,9 amendment (3) arise (1) 43:4 aware (19) 2:3 19:6,13 21:16 below (5) 3:25 62:22 105:16 152:16 canada (1) 51:11
112:4,11,25 113:18 135:1 106:18,23,24 arises (1) 138:12 27:9 28:3 34:6 35:2,23 108:22,23 briefing (7) 7:18 cancelled (1) 127:14
cancelling (1) 127:13 clean (1) 39:15 communications (21) 54:7 contained (2) 44:7,12 70:5 82:22 97:10 122:1 121:5,12 126:2 135:12,23 directly (4) 84:1,6 85:16
candidate (2) 154:16 156:23 clear (33) 11:7 15:10,14 73:22 91:7 96:18 103:20 contemporaneous (2) 3:20 127:25 150:18 153:15 136:20 155:16 132:25
cannot (1) 159:7 19:23 26:21 36:6 37:14 104:22 105:14 108:12,21 4:12 155:16 159:9 decide (2) 61:18 154:21 director (5) 19:12 40:7 50:22
cant (31) 8:10 12:20 13:5,9 42:6,20 46:22 56:21 59:16 110:8,11 111:5 115:7,13 contending (1) 24:19 cover (7) 16:9 64:18 84:8 decided (1) 12:2 99:6 147:10
21:18 23:6 30:6 37:24 38:8 60:25 69:4,5 72:18 74:1 116:8,13,18 122:16 content (6) 112:23 90:15,20,22 96:2 decision (3) 11:16 58:1 159:3 disagree (8) 17:6 33:22
49:14 60:11 63:6 64:11 79:21 90:5,7,19 100:21 126:16,19 144:7 113:17,17 129:23 142:20 covered (1) 44:19 declined (2) 5:8 24:8 41:22 55:17 87:15 130:22
76:6 78:18,23 80:21 86:13 103:24,25 104:4 113:19 company (3) 64:25 79:5 150:10 covering (1) 83:7 defendant (14) 67:18,25 133:9 134:12
91:10 108:16 111:5,10,12 119:19 127:2,7,7,8 128:1 89:11 contentious (1) 51:8 coverup (1) 65:20 99:7 102:4 103:1,2,4,6 disagreement (2) 55:20
118:4 135:3 137:24 141:19 143:22 competent (1) 71:21 contents (9) 34:23 36:13 crawling (1) 83:12 105:19,23 137:2,2,4,6 158:9
142:11,12 147:18 160:1 clearance (1) 61:21 complaint (1) 89:16 75:12,13 93:23 95:2 97:2 crime (1) 5:15 defendants (20) 34:6 35:2 disappeared (1) 76:15
capabilities (1) 44:25 clearly (7) 15:25 35:22 41:15 complaints (1) 136:7 149:20 153:5 criterion (2) 156:22 158:17 43:12 44:14 47:6,7 disappointed (1) 40:21
capacities (3) 52:13,17,23 48:5 61:17 98:9 127:24 complete (2) 54:22 153:19 context (5) 79:14 107:18 critical (1) 159:15 52:16,21 92:14,15,17 disappointing (1) 74:13
capacity (1) 52:18 clever (1) 58:15 completed (2) 55:7 152:10 127:16 129:13 154:16 critics (1) 59:8 93:12,13 95:4 104:22,24 disappointment (1) 40:6
cards (2) 71:20 72:1 client (8) 5:11 6:16 18:11 completely (9) 40:23 48:21 continuation (1) 65:25 crop (1) 63:19 109:9,19 149:9 160:12 disapproved (1) 38:11
careful (3) 3:20 23:19,21 41:3 46:14 111:16 114:5 68:24 80:1 88:18 122:4 continue (2) 49:17 75:4 cross (1) 38:14 define (1) 34:22 disclose (9) 47:4,20 84:14
carefully (7) 89:17 91:6,17 127:15 123:21 130:9 131:21 continued (6) 2:13,14 16:9 crossexamination (8) 2:14 definite (1) 26:25 92:18 94:2 95:10 111:9
98:8 112:24 136:23 137:22 clients (4) 6:18 20:10 83:20 completeness (1) 17:24 26:18 164:4,5 98:5 129:10 138:11,18 definitely (2) 47:15 126:23 135:10 142:14
carl (5) 80:13,15 87:5 136:4 84:2 complied (1) 95:20 continuing (4) 16:7 53:20 149:24 164:5,9 definition (1) 43:16 disclosed (10) 75:23 98:18
139:20 clinton (5) 10:16,17,18,23 compromised (6) 25:11 60:4 54:23 151:21 crossexamined (1) 133:15 deflect (1) 79:7 104:24 110:15 112:12
carried (2) 92:16 95:18 19:3 144:21 145:10 157:4,5 contract (4) 51:23 74:21,23 crown (1) 150:13 degree (2) 122:10 162:12 121:25 135:15 141:13
carrier (1) 122:15 clintons (2) 10:20 18:20 compromising (2) 33:23 89:9 crucial (5) 104:23 105:14 delivered (4) 13:25 55:21 147:19 148:7
carry (2) 81:6 116:7 close (11) 10:16,17 19:24 78:11 contradictory (1) 47:9 107:22 111:3 112:11 61:14,15 disclosure (25) 75:23 77:18
carter (1) 21:22 33:1 45:4 46:24 50:23 conceal (1) 148:11 contrary (1) 30:17 crucially (1) 113:5 democrat (3) 19:7,8 20:9 91:15 92:6,24 93:13,25
casual (1) 43:22 118:7 133:21 160:6 161:2 concentrating (2) 66:16 control (4) 22:20 46:12 cullison (6) 74:6 84:19,21 democratic (2) 5:10 25:7 95:4,8,16 99:3 100:25
catch (1) 8:6 closed (2) 18:18,19 162:12 104:25 110:12 85:16 135:11 136:1 democrats (1) 28:2 102:18,21 104:15 106:1
categorical (1) 40:5 closely (3) 41:25 83:19 concept (1) 56:19 controlled (3) 46:9,18 48:10 culpably (1) 97:7 den (1) 83:12 107:20 111:19 136:7
category (4) 89:3 92:25 123:13 concern (1) 33:19 controversy (1) 21:1 curious (1) 26:20 denied (4) 31:20 32:1 34:12 141:2,5 147:9,17,21 148:1
108:8,20 closer (1) 74:19 concerned (11) 11:21 27:11 convenience (4) 120:19 current (2) 56:10 62:12 85:23 disconcerting (1) 69:25
catherine (5) 62:25 closing (2) 162:4,17 31:23 54:15 74:17 94:10 121:2 127:19 130:15 custody (1) 33:2 dense (1) 138:17 discovery (2) 104:16 105:25
63:2,3,15 64:2 cloud (1) 110:15 110:6 142:2 154:9 157:23 convenient (8) 48:16,18 68:8 cut (1) 130:9 deny (3) 134:6 141:21 discreetly (1) 16:22
cause (1) 159:12 cnn (3) 80:16 87:5,8 160:2 106:16 138:8,14,15 139:1 cuts (1) 48:13 159:10 discretion (1) 49:25
causes (1) 97:21 cohen (9) 64:16,18 65:7 concerning (1) 11:9 conveniently (1) 77:12 cv (1) 10:9 department (10) 2:18,21,22 discuss (19) 8:24 13:25
cease (1) 12:2 66:19 70:17 82:21,21 concerns (1) 1:10 conversation (15) 11:12 cybercrime (2) 84:8,10 4:3,10 8:8 11:8 14:15 15:1 14:13 50:22 51:16 90:17
ceased (1) 49:9 84:22 85:22 conclude (1) 42:19 12:1,17 18:12 25:24 27:23 cyprus (5) 83:10,13,16,20 63:10 105:22 111:23 123:17
celeste (2) 58:19 61:20 cohens (4) 65:15,20 70:19 concluded (2) 138:11,18 40:2,10,12 49:14 103:3,22 135:13 depending (3) 96:13 127:3,5 128:12 130:15,18
cell (26) 15:22 16:19 68:7,14 84:22 conclusion (1) 136:24 124:17 137:3 155:18 150:18,21 134:18 135:5 157:22 161:8
D
69:8,21,23 70:3 72:7 74:4 coie (1) 5:11 conduct (3) 35:18 115:6 conveyed (1) 34:23 depends (2) 73:14 75:10 162:24
77:25 78:5 79:10 81:9 cold (1) 27:4 116:13 coopt (1) 24:20 d (1) 68:18 deposed (1) 91:3 discussed (12) 20:15 36:24
82:3,3,4,19 84:25,25 colleague (3) 3:4 80:14 conference (1) 161:11 coordination (1) 19:24 d31 (1) 53:3 deposition (1) 135:19 38:16 48:3 64:2,5,5 118:1
85:6,6,25 87:3 88:1,3 153:7 confidence (1) 37:22 copies (14) 5:3 11:22 30:10 d32 (1) 53:6 depositions (1) 101:22 132:24 135:17 144:3 162:7
cells (3) 15:21 70:3 85:7 colleagues (10) 50:24 51:2 confidential (4) 36:14 47:5 32:9,24 33:7,14,17,20 d33 (3) 53:16 54:23 152:8 deputy (3) 3:2 10:22 16:18 discussing (13) 7:8 20:20
central (2) 3:3 115:15 56:15 60:20 61:1,4,12 55:13 153:11 75:18 76:9 81:6 91:15 damage (2) 94:3 95:11 described (2) 22:21 50:10 26:4 46:24 54:2 59:2 87:18
certain (2) 140:3,4 66:6,20 145:17 confidentiality (3) 47:12 143:24 damaging (1) 137:16 description (5) 23:4 37:17 90:2 102:8 130:17 145:15
cetera (1) 147:11 collected (1) 155:18 48:2,13 copy (34) 14:16 20:18 23:11 dana (2) 81:14 82:2 45:3 73:8 158:4 157:18 161:1
challenged (1) 96:25 collecting (1) 87:10 confining (1) 117:13 33:23 46:25 51:17,20 danger (2) 44:16,19 designed (1) 47:14 discussion (7) 49:3 126:17
chambers (1) 92:7 colourcoded (2) 146:2,6 confirm (3) 97:17 115:19 61:24 63:9 64:14 67:6 78:3 dangerous (4) 32:24 43:20 destroyed (1) 51:22 138:9 153:9,13 154:11,12
change (1) 40:3 column (1) 136:11 116:6 93:2 102:14 106:7 108:4 151:7,7 detail (8) 25:19 65:9 66:22 discussions (2) 53:18 153:6
changes (1) 101:24 come (36) 1:17 5:18,21,25 confirmation (1) 127:22 114:11,24 118:17 119:12 databases (1) 71:19 69:5 82:10 106:3,12 141:7 disillusioned (1) 9:18
channel (1) 148:20 9:5 18:18 19:16 42:11 confirmed (3) 1:16 95:6 121:18 122:11 123:5 124:4 date (17) 10:2 46:25 53:8,9 detailed (7) 9:3 33:20 dispute (1) 111:2
channels (1) 17:22 45:24 69:5 71:10 88:20 133:13 125:12,15,16 126:12 54:3 64:11,13 66:13 92:19 38:11,13 87:10 105:16 distancing (1) 48:8
characterise (1) 39:12 90:11 98:2 105:17 106:14 confirming (2) 126:6,24 135:20,21 139:11 149:16 93:3,17 95:1 107:1,8 132:10 distraction (1) 120:13
charge (1) 25:3 116:19 117:23 118:11 confused (1) 105:5 152:2 162:10 125:23 128:16 131:9 details (9) 9:3 23:13,17 divide (1) 82:11
charges (2) 17:17 52:9 119:3,5 120:17,19,20,24 confusing (1) 20:13 cordial (1) 119:25 dated (7) 64:10 65:12 104:17 25:20 38:15 66:1 112:4 dk (1) 58:8
chat (8) 69:9 70:4 82:5 121:1 126:7,9,25 congress (6) 49:23 59:24 corn (31) 18:8 19:6 20:15 108:3 147:14 149:12 152:1 134:5 152:21 dmitry (1) 16:17
85:12,13,21 126:4,22 127:17,19 144:15 148:14 60:20 61:1 157:20 159:3 22:12 23:7,8,22 25:13 dates (5) 15:12 18:3 63:21 determined (1) 47:15 document (20) 2:2 35:9
check (7) 15:8 81:22 83:4 155:17 156:8 161:16 congressional (6) 18:17 29:23 30:20,21,25 65:7,10 detrimental (2) 138:1,2 55:15 67:9 76:16 84:15
86:3 115:19 138:13 144:9 comes (12) 10:24 18:4 51:16 50:23 51:1 61:4,12 145:17 31:2,15,21,25 32:22 dating (1) 6:6 developing (1) 95:14 99:13 101:2 108:8,20
checked (1) 76:9 53:13,14 61:13 70:7 connected (3) 84:2,6 148:25 33:7,19 34:13,15,18 david (14) 18:8 30:20,21 development (1) 65:12 114:25 115:1 124:23 147:6
checking (1) 117:2 113:14 123:12,15 127:18 connection (2) 5:7 83:17 35:11,12,16 37:9,23 38:4 32:22 69:10 72:10 73:17 device (2) 100:1 115:19 150:19 151:23 153:12
chief (5) 20:24 22:5 35:21 128:5 connections (1) 153:2 49:19 133:22,25 75:3 81:13 88:5 156:6,8 dialogue (1) 66:1 156:18 157:25 159:9
61:9,22 comey (12) 18:17 19:12 conscience (2) 131:24 corner (1) 6:5 159:19 161:15 didnt (50) 3:4,10 5:9 8:6 documents (27)
chris (5) 15:20 79:15 85:14 20:23 49:15 50:23 55:22 141:15 corns (2) 72:10 73:17 day (16) 2:10 7:1 18:7 38:8 10:13 13:17 22:24 75:17,18,21,22,23 76:3
86:16 129:2 57:16 59:21 60:22,23 conscious (1) 44:14 correct (18) 10:5 18:2 26:6 41:16 102:4 103:1 25:14,16 29:25 31:19 92:17,24,25 94:2,21 95:10
christmas (10) 69:1 89:25 118:22,23 consent (1) 147:21 37:19 42:5 51:4,19 74:25 124:14,15 125:24 131:2,11 32:18 33:9,11,18 34:17,20 99:8,24 107:21 136:19
102:4 103:1 121:6 comforting (1) 157:11 consented (1) 46:10 89:1 92:4 124:10,11 137:1 162:19 163:1,7 40:22,23 54:9,20 57:8,18 140:14 141:8 147:8
123:23,25 124:14,15 137:1 coming (8) 72:15 126:23 consequences (1) 96:13 125:17 140:16 144:12 days (6) 22:12 33:10 106:24 60:22 61:21 62:7 84:14 150:15,24 151:4,18 154:20
christopher (2) 2:13 164:4 127:2,5,24 128:2 129:25 consider (3) 18:23 115:8 150:8 153:15 160:10 131:7,8,15 87:24 88:25 89:7 96:23 156:9 161:13,16
chronological (1) 20:13 130:18 144:4 corrected (1) 108:23 dc (3) 12:8 62:24 74:8 107:9 108:14 112:11 113:5 does (19) 7:18 8:3 19:16
chronology (6) 19:2 51:10 comment (4) 64:25 102:15 considerably (1) 91:12 correction (1) 46:6 deal (9) 6:24 75:15 108:22 125:13,14,15 20:13 34:15 57:12 60:5
106:18 107:6,16 123:12 148:9 157:7 considerations (1) 114:3 correspondence (1) 141:17 114:1 130:8,8,10 134:13 129:10,16,20,21 135:10 79:11 80:13 82:9,24 83:4
cia (10) 57:7,12,13,22,24 comments (2) 16:14 27:9 considered (2) 91:7 144:6 correspondent (1) 10:6 162:20 142:4 144:10 152:18 153:8 84:21 108:7,19 116:19,20
58:1,12 59:1,14 60:18 commercial (2) 127:15 130:6 consistent (1) 44:14 corroborated (1) 74:13 dealing (4) 44:24 89:24 160:9 161:19 163:6 137:10 161:23
circle (2) 25:5 26:17 committed (1) 58:21 constitutes (1) 115:8 corroborates (1) 78:9 129:16 151:12 died (1) 145:24 doesnt (10) 7:18 8:2 16:2
circles (5) 52:3 56:9,14,18 committee (7) 53:8 59:24,25 consultation (1) 11:17 couldnt (4) 47:20 71:21 dealings (5) 38:12 87:17 difference (1) 35:7 19:14 34:15 57:11,14
154:5 61:2 118:14 151:24 157:20 contact (26) 11:17 12:3 148:24 161:19 89:18 140:10 160:25 different (6) 4:25 15:21 78:1 59:25 88:1 110:22
circulated (1) 45:12 committees (4) 56:16 59:23 13:6,7,16,18 16:23 17:10 counsel (7) 35:21 101:19 deals (2) 49:6 110:5 89:3 105:25 132:8 doing (11) 9:2 11:19 48:7
circulation (1) 33:17 60:20 61:4 24:9 32:21 35:23 36:7 111:25 135:17 138:6 149:8 dealt (6) 2:16 18:4 30:13 difficult (7) 94:4 95:24,25 82:17 133:25 134:3,10,10
circumstances (2) 102:11 common (3) 29:3 97:18 39:24 40:4 43:8,9 49:10,13 160:12 49:1 55:1 81:24 113:8 129:12 130:24 156:7 144:4 146:25 147:2
147:19 150:9 54:1,3,12 109:20,24 count (1) 106:20 dear (3) 13:24 14:23 16:21 difficulties (2) 96:12 97:1 doj (1) 133:14
claimants (9) 44:5 89:13 communicated (3) 109:3 125:18 144:7,9 counterintelligence (1) 44:25 debate (1) 1:20 difficulty (1) 97:22 donald (2) 19:25 101:4
98:14 101:21 106:19 115:9,14 contacted (7) 29:23 50:17 country (4) 22:10 23:3 44:24 december (34) 36:9,13,15,19 dinner (1) 88:17 done (15) 25:15 31:10 35:13
107:19 140:22 141:2 communicating (4) 87:13 67:19,22 102:5,5 123:25 158:19 37:11,15 44:1,8 50:17 diplomatic (1) 150:4 39:1 41:17 46:9,18 48:11
149:25 100:9 128:7 146:16 contacting (7) 50:14 68:1 countryside (1) 52:8 52:24 64:7 65:22,23 direct (5) 13:6 27:6 30:23 57:6,8 59:25 68:4 98:8
claimed (4) 25:10 32:6 64:1 communication (7) 41:9 103:5,17,18 124:20 137:5 couple (3) 64:7 131:7,8 69:7,13 72:23 75:7,9,10 54:3 101:19 131:24 142:11
137:25 70:18 71:3,8 97:3 108:11 contacts (5) 11:7 54:3 72:3 courage (1) 159:14 83:14 84:18 102:9,10,14 directing (1) 98:4 donors (1) 59:7
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7:4,6,16,20 8:5,16,18,22 e401 (1) 19:20 enforcement (2) 27:16 expecting (2) 97:25 98:1 57:4,4,16 59:16 90:12,13 24:13 26:1,11,15 27:8 109:10,19 111:9 112:4
9:1,4 10:1 11:19 e491 (1) 118:13 145:16 expenses (3) 38:23,25 39:3 144:4,6 151:21 152:24 28:16,22 29:1 30:22 32:5 113:13,20 128:3
13:6,14,19 20:16 24:6 e4920 (1) 118:17 engage (4) 54:16 58:19 experience (5) 49:23 140:19 153:2 156:2,10,13 158:24 formerly (1) 5:15 gives (1) 54:23
25:20 27:20 28:12 33:5,5 e5 (2) 20:17 28:10 90:22 91:1 141:12 150:13 159:24 fbis (1) 9:18 forth (2) 59:3 141:4 giving (10) 38:11 58:12
35:10,12 36:2,4,4,22 37:7 e59 (1) 121:17 engaged (2) 58:4 64:18 experienced (1) 58:15 feasible (1) 144:8 forthcoming (1) 14:15 59:1,14 73:5 102:10
40:13 41:24 42:9,22 43:18 e591 (2) 121:16 123:5 engagement (2) 57:19,19 expert (3) 9:8 27:25 29:13 feature (1) 42:8 forum (1) 51:11 111:13 118:13 148:16
45:12 47:23 50:7 53:3,8 e6 (6) 45:24 46:2 69:18 77:6 engaging (1) 75:1 expertise (2) 2:25 49:23 features (1) 19:14 forward (6) 14:7 42:14 49:18 162:1
55:3 58:3 63:21 68:4 78:3 146:4 england (1) 51:16 explain (8) 26:14 54:11 february (2) 101:21 106:19 85:3,10 119:22 glenn (3) 5:14 12:11 144:3
70:17,20,20 71:10,14 e62 (1) 144:16 english (3) 15:11,12 18:7 83:15 101:7 108:7,19 feed (2) 88:8,12 forwarded (2) 26:16 54:8 glenns (1) 80:13
72:12 73:9,13,19,23 75:15 e624 (4) 56:22 144:13 145:4 enlarged (1) 2:10 135:10,14 feelings (1) 158:18 found (2) 95:14 100:22 gloss (1) 40:1
77:23 80:9 84:5,16 155:8 enough (1) 2:11 explained (5) 48:5 50:20 fellow (1) 61:1 founders (1) 105:18 glossed (1) 112:14
86:2,5,8,20 89:5 90:4,10 e625 (3) 60:12 144:14 enquiries (5) 42:10 53:23 71:9 113:16 127:12 felt (2) 125:4 130:9 four (9) 2:9 6:14 11:24 goal (1) 64:21
93:11 94:4,7 96:2,2,5 157:10 79:22 85:20 87:10 explains (2) 53:13 127:20 few (6) 9:23 33:10 45:8 28:11,20 29:13 45:7,13 goes (6) 51:10 82:21 83:5
97:25 98:17 99:2 101:17 e631 (2) 11:22 61:24 enquiry (5) 14:20 22:4 explanation (3) 71:6 77:22 72:22 140:11 150:4 70:16 86:22 87:25 98:5
104:4 107:8 108:24 110:3 e635 (1) 11:23 26:22,24 89:6 129:20 fields (1) 150:5 fourth (4) 71:13 93:16 108:3 going (53) 1:17 2:10 14:7
114:4 117:5 119:4,8 e636 (2) 62:4,8 ensure (5) 33:1 56:8 154:4 exploratory (1) 119:20 fiery (1) 20:23 122:11 15:6 17:2,11 25:19 26:22
126:8,19 128:13 131:23 e691 (3) 119:12,15 126:11 158:10,22 explored (1) 140:12 fifa (17) 89:5,7,23 fraywitzer (1) 124:6 29:19 32:21 37:4 42:14
132:4,23 134:15,21,22 e692 (2) 128:14,23 entering (1) 112:3 exploring (1) 62:18 90:2,11,14,17 119:20 fred (1) 135:24 43:2 49:18 54:20,21 55:3
135:15,16 137:12,20 138:2 e693 (1) 131:1 enthusiastically (1) 58:5 explosive (1) 19:23 120:25 124:24 125:2 127:4 free (3) 46:17 85:18 86:23 60:10 62:5 68:14,21 71:18
142:5,18 144:12,23 150:23 e725 (1) 147:20 entirely (7) 47:9 82:14 90:24 exposed (5) 35:17 128:1 130:8,18 131:20 freelance (1) 63:6 72:15 73:22 78:24 81:22
156:1,3 157:18 159:1,15 e7515 (1) 124:3 100:19,21 115:12 154:24 58:8,12,25 156:6 132:6 freely (2) 75:1 141:2 87:22 90:12 96:9,25 98:7,9
160:22 161:9,24 162:11 e78 (2) 136:11 139:13 entitled (2) 94:16 97:8 exposure (1) 64:19 fifarelated (1) 130:19 freeze (1) 40:4 99:14 111:4 113:25 118:3
dossier (34) 51:16 55:9,15 e781 (2) 135:19 139:10 entries (1) 66:18 express (1) 160:15 figure (3) 72:25 80:6 136:6 frequent (1) 133:4 120:10,23 126:1 127:22
67:20 75:2 79:25 88:14,19 e7814 (2) 139:13,16 epe (1) 1:6 expressed (2) 40:6 50:15 file (18) 19:19 53:4 81:4 friday (3) 13:2 18:16 163:11 130:16,19,21 132:19
90:7,16,25 102:6,8 e7815 (1) 124:4 equally (1) 37:21 expressly (1) 30:17 99:7,16 101:3 106:7 108:4 fritsch (1) 5:14 133:23 134:2 135:5,13
104:6,13 105:22 121:11,14 e7828 (2) 136:2,9 et (1) 147:11 extent (3) 34:9 109:20 109:11 118:17 121:17,18 front (2) 108:16 126:8 140:10 144:6 150:19
123:17 127:3,21,24 128:2 e91 (1) 65:11 etc (1) 14:7 110:16 122:11 124:3,4 128:15 frontispiece (1) 115:23 158:24 162:10
130:15 132:2,25 134:5,18 e931 (1) 20:17 etherised (1) 70:2 extra (1) 107:10 135:19 149:10 fsb (1) 45:4 gone (4) 20:10 27:4 38:24
135:21,23 146:22 earlier (9) 7:17 9:10 49:2 ethnic (1) 63:24 extract (1) 139:10 files (3) 56:21 100:11,12 ft (1) 63:15 97:19
152:12,21 158:2 53:24 64:7 71:8 88:23 eu (1) 64:20 extremely (2) 31:22 139:9 film (2) 89:9 130:8 full (3) 29:10 47:25 92:6 good (10) 64:14 75:20
doublecheck (1) 81:21 142:17 163:3 eurasia (1) 3:3 eyesight (1) 124:4 final (1) 40:13 fully (1) 132:23 81:18,25 82:5 117:1
doubt (9) 3:1 21:24 31:5,18 earliest (4) 120:19 121:2 europe (4) 3:2 84:11 90:11 finally (2) 116:11 117:14 further (12) 18:18 40:10,12 119:18 128:17 129:3
F
34:14 74:3 86:11 158:19 127:19 130:15 130:19 finances (1) 128:20 43:24 50:19 52:11 66:1 162:11
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doubts (1) 12:7 49:10 50:17 109:21 120:7 evaluating (1) 159:1 f1 (6) 91:14 93:2 105:3 find (11) 10:8 31:11 32:8,8 160:12 10:10,11 20:1 21:7 24:4,19
down (8) 7:10 16:19 121:13 146:14 162:21 eve (3) 89:25 121:6 123:25 106:7 108:4 122:12 43:5 100:16 104:3,16 fusion (20) 5:21 6:17 29:20 42:15,16,23,23 43:1
28:11,20 35:12 74:10 earth (1) 78:12 even (9) 15:4 33:22 70:16 f14 (1) 99:12 113:8 155:19 157:11 30:16,17 41:5 44:3,10 45:11 53:21 134:13
85:25 107:9 easier (2) 77:6 147:7 72:13 83:12 106:3 150:10 f141 (4) 91:14 99:4,16 147:8 finding (3) 103:7 104:10 46:10,12,13,17 47:3,20 grateful (1) 97:14
dp (1) 16:14 easily (1) 68:4 158:25 161:19 f143 (1) 91:16 137:8 48:10,12 51:17,21 great (4) 85:18 119:17
draft (2) 44:20 93:23 east (1) 16:15 event (1) 115:17 f2 (1) 114:11 fine (1) 125:10 74:22,23 105:18 120:5,16
draw (3) 41:7 137:15 148:5 eastern (1) 84:10 events (3) 8:25 46:24 96:8 f24 (1) 106:7 firm (2) 47:20 92:13 fusions (1) 45:16 greater (2) 20:25 150:21
drew (1) 42:14 easy (2) 68:21 115:11 ever (7) 23:11 30:10,15 f241 (1) 104:17 first (56) 2:20 4:21 6:12 11:2 future (1) 40:3 green (5) 11:24 62:9
drift (1) 96:6 economic (1) 5:15 31:21 98:19 148:11 159:25 f2419 (1) 105:13 13:20 24:24 25:2,4 26:7 155:12,14,15
dropped (1) 29:22 effect (2) 119:9 156:21 every (3) 20:2 43:2 80:6 f2421 (1) 106:3 29:25 30:2 37:2,8,9,12 G grew (1) 9:18
duck (1) 101:4 effectively (5) 59:4,18 79:3 everybody (1) 155:7 f248 (2) 104:18 105:4 46:14,23 49:7 53:17 54:22 grey (3) 62:9 155:12,14
due (2) 6:25 13:11 87:12 127:14 everything (6) 15:2 62:23 f271 (3) 93:15 108:4 122:11 58:13 59:22 63:13 64:8 gap (1) 114:21 ground (1) 9:1
during (10) 2:10 3:9,15 efforts (1) 44:14 76:10 81:6 83:6 141:20 f273 (1) 109:7 66:5 68:22 71:13 79:8 garbage (1) 22:2 grounds (2) 33:19 52:21
25:11 30:12 81:24 121:21 either (16) 7:24 29:22 30:1 everywhere (1) 83:7 f274 (2) 109:11,16 84:15 95:21 98:13 99:11 gathered (3) 26:15 56:6 group (2) 73:5 158:8
122:8,24 156:24 38:23 43:19 44:9 66:14 evidence (11) 33:6 95:5 97:7 f275 (1) 108:5 103:12,22 104:20 112:1 154:1 groups (1) 159:21
duty (1) 151:10 94:3 95:10 104:25 113:24 107:19 118:11,14 124:2 f278 (1) 108:24 117:3 119:16 120:21 gave (14) 23:16,17,18 25:13 guarantee (1) 145:4
124:14 125:13 132:23 139:10 148:14,16 162:1 f279 (1) 93:20 121:25 122:2 126:14 31:2 33:7 68:24 89:6 guardian (1) 63:5
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133:13 159:5 exact (5) 7:16 49:14 63:21 f289 (1) 93:2 128:18 134:25 135:1 107:25 122:5 123:22 gubarevbuzzfeed (1) 124:7
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143:17 election (17) 9:21 12:17 exactly (15) 6:25 9:1 14:18 f3345 (1) 114:12 146:8 152:20,24 153:3 gavin (1) 149:8 guided (1) 158:17
e1 (4) 3:22 45:23 63:8 64:9 13:11 16:5,8 17:1,9 20:11 21:18 23:2 25:18,21 76:20 f3346 (1) 114:14 156:22 157:12 general (8) 12:16 17:8 47:23 guy (3) 76:7 81:25 83:3
e1031 (2) 28:10,14 22:12 46:8 62:17 70:14 77:11 86:8 97:2 117:2 f3349 (1) 115:22 firstly (3) 53:12 116:16 150:4 53:22 100:22 109:2 152:23
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e1064 (1) 9:16 74:24 132:15,17 133:21 123:12 135:3 141:19 f3350 (2) 115:23,25 fit (1) 57:11 161:5
e1065 (1) 9:13 154:15 examinationinchief (2) 149:7 face (2) 113:8 117:22 five (4) 20:21 21:20 148:25 generalised (1) 154:15 h (1) 81:14
e1442 (2) 45:20,22 elections (3) 11:10 55:6 164:8 facetoface (7) 23:20 114:7 149:1 generalities (3) 7:18 8:3,24 hacked (1) 5:8
e154 (3) 77:1,15 146:12 152:9 example (5) 61:5 73:10 116:11,16 117:14 141:22 flag (1) 145:23 generally (1) 128:6 hackers (2) 66:3,11
e1541 (2) 68:6 146:1 electronic (5) 92:24 99:7,12 83:24 100:7 135:9 147:22 flattering (1) 156:20 gentleman (2) 9:14 16:12 hadnt (7) 26:25 36:6 42:13
e15415 (2) 13:21 14:24 100:25 136:2 examples (1) 107:23 failed (1) 114:20 flicking (1) 77:3 get (39) 7:22 14:8 15:19 64:4,5 75:8 132:3
e1542 (2) 68:10 78:2 element (1) 58:5 excellent (1) 120:5 failure (1) 57:14 florida (1) 61:7 17:9,12 20:13 22:8 23:11 half (2) 27:2 145:23
e1543 (1) 80:10 elements (2) 55:8 152:11 exception (2) 128:9 133:5 fair (4) 3:19 36:3 129:13 flow (1) 25:6 24:11 36:22 46:24 60:22 halfway (4) 3:25 56:2 62:8
e1544 (1) 87:3 else (6) 1:21 30:16 34:16 exchange (2) 92:25 105:20 159:4 flown (1) 145:23 63:20 68:11,18 69:24 153:22
e1553 (1) 76:12 58:2 130:13 144:4 exchanged (1) 98:15 fairly (6) 25:19 41:18 46:23 flynn (6) 88:2,9,10,13,18 71:25 77:21 78:12 82:19 halifax (2) 51:10 155:17
e15534 (1) 77:8 elsewhere (4) 13:22 21:13 exchanges (1) 103:13 108:17 150:6 156:23 133:1 85:19 88:4,5 96:10 97:1 handle (1) 14:6
e1591 (3) 41:16 143:16,18 58:18 130:10 excluded (1) 77:16 fairness (2) 46:4 99:3 folders (1) 100:8 100:23 115:22 120:6,16 handled (1) 36:16
e161 (1) 64:9 emails (2) 18:18 110:5 excuse (2) 49:16 124:14 false (3) 43:15,16 117:20 follow (3) 50:12 96:13 148:7 126:2,10 128:18 129:16 handling (3) 15:3 29:6 38:5
e162 (1) 64:24 emerged (1) 106:12 executive (1) 10:12 familiar (1) 81:4 followed (1) 54:17 132:10 146:9 147:6 148:25 hands (1) 55:16
e171 (1) 65:24 emphasise (1) 152:20 exercise (3) 95:21 98:24 far (11) 11:20 55:4 58:20 following (4) 13:11 40:25 149:2 163:7 happen (2) 59:9 141:7
e2 (3) 19:19 118:13,17 emphasising (1) 85:15 99:21 72:14 85:24 108:7,19 41:15 123:13 getting (5) 74:19 79:7 81:9 happened (6) 15:8,9 76:17
e251 (1) 147:20 employees (2) 99:6 147:10 exist (1) 110:17 110:2 113:20 142:25 foolish (1) 160:22 128:25 132:21 77:23 133:17 137:17
e3 (18) 61:24 119:13 121:18 en (1) 87:2 existed (1) 154:13 157:22 football (1) 41:1 gist (3) 52:5,7 56:13 happens (4) 18:23 101:2,3
123:5,11 124:5 126:12,13 encourage (1) 30:16 existence (11) 50:1 55:13 fault (5) 37:13 62:7 109:6 footnotes (3) 41:20 42:6 give (27) 14:8 15:19 22:23 134:8
128:15,23 135:19 136:10 encouraged (2) 86:17 102:6 56:8 110:21 113:6 124:22 139:16 158:15 143:19 49:12 56:21 57:22,24 58:1 happenstance (1) 101:1
139:11 144:16,17 145:7,8 encouragement (1) 58:19 142:14 153:11 154:4 favouring (1) 29:20 forbade (1) 30:17 60:17 61:21 62:7 80:20,22 happily (1) 114:8
155:9 encrypted (2) 51:17,20 157:25 159:8 fbi (63) 2:16 4:22 6:19 forced (2) 130:25 131:17 81:1 85:4,11 102:13 happy (5) 40:11 79:21 85:13
e351 (1) 5:2 end (15) 6:9 24:24 29:17 existing (2) 55:10 152:13 12:2,24 19:12 20:23 22:3 foreign (5) 16:18 20:1 22:4 112:15 125:8,15,16 118:5 133:7
e3510 (1) 63:8 51:23 85:6 93:20 94:22 expand (1) 145:14 24:9,21 26:2,7,13,19 72:9 73:4 129:12,20 135:1 137:21 hard (25) 5:3 11:22 20:18
e353 (1) 6:5 104:18 118:8 138:7,24 expect (3) 47:25 50:5 83:10 27:1,3 29:6,9,10,13,17 forget (2) 75:14 80:8 155:7 156:12 33:7 61:24 63:9 78:2 91:14
e355 (1) 7:6 148:14 153:19 154:21 expectation (4) 1:6 56:12 33:8 35:22,25 38:10,12 forgotten (2) 13:4 139:8 given (27) 31:21 35:6,7 93:2 106:7 108:4
e357 (1) 6:13 162:1 61:16 119:1 39:12,16,24 40:20 43:8,9 form (5) 13:22 59:12 38:4,14 43:7 56:9 114:11,24 118:17 119:12
e37117 (1) 3:22 ended (2) 74:24 161:6 expected (11) 36:16 50:7,7 46:11,12,13 49:10,13 119:4,12 134:7 57:3,4,16 59:15 60:22 69:6 121:18 122:11 123:5 124:4
e3796 (2) 3:24 4:5 ending (2) 21:2 49:13 57:6,19,20,22,24 59:22 50:22 53:19,25 formally (2) 10:15 47:22 76:16 80:19 95:16 96:4 126:12 135:20 139:11
e3798 (1) 4:21 ends (1) 76:24 119:3 155:2 54:3,4,8,16,18,18,24 55:16 former (14) 19:8 22:5,9 23:2 97:18 103:25 106:4 145:5 155:10 162:10
hardly (1) 161:10 58:20 61:10,20 included (3) 52:9 108:14 intermediary (3) 60:7 104:4,17 105:6 106:9,14 kindly (1) 9:16 layperson (1) 141:11
harry (2) 19:7 20:22 housekeeping (2) 1:3 164:3 134:8 161:6,21 107:8 108:3,17 109:6 kinds (1) 150:15 lead (1) 114:21
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97:18 132:17 144:23 I 143:6,7,9 interpretation (2) 116:25 126:13,15 127:2,6,20 158:25 161:2 leading (1) 138:6
having (16) 6:14,23 33:20,20 incomplete (1) 77:20 130:22 128:1 129:4,10,12 131:15 knight (1) 2:5 leaked (2) 18:23 19:2
38:24 58:4 60:7 75:20 id (4) 27:23 38:14 67:12 increasingly (1) 9:18 interval (1) 135:5 136:15 137:15,16 know (97) 7:20 8:5,18 learned (2) 129:9 140:8
80:11 93:10 104:25 111:1 119:17 independent (2) 88:18 89:21 intervened (1) 9:1 138:14,16,17 139:15 11:19,19 13:24 14:18,23 least (18) 31:3 32:25 33:2
117:16 129:15 146:19 idea (11) 9:24 49:4 61:12 index (1) 164:1 interview (12) 4:22 16:3 141:7,25 142:1 15:5 20:3 21:3 25:19 28:5 42:7 52:5 53:21 55:8
157:6 67:10 78:14 79:8 96:5 indicated (7) 1:22 29:4 22:14 28:10 30:14 143:15,18,19 31:19 33:5,6,11 35:10,13 56:9,13 82:23 84:17
hawk (1) 41:2 98:14 120:11 133:25 98:23 104:5 110:17 124:21 31:3,4,7,10 40:17 144:12,15,16,25 36:2,4,4,23 40:11 42:9 102:13 123:18 139:1 141:1
headed (1) 65:24 154:25 162:25 133:20,24 145:2,4,7,7 146:2,4,13,14 45:12 50:7 54:7 55:10 150:2 152:11 157:24
heading (1) 122:20 identical (1) 36:20 indication (1) 134:1 interviewee (1) 31:8 147:8,14 148:10,23 59:18,18 61:8 63:21 66:17 leave (5) 12:12 39:3 94:13
hear (8) 11:2 19:19 130:25 identification (3) 78:20 indications (1) 59:7 interviews (1) 31:9 149:8,13 150:5,7,9 151:6 70:17 71:10 73:9,11,19 101:19 141:15
131:17 149:14,15 150:2,3 92:2,3 individual (1) 45:3 into (22) 5:6 10:25 18:19 152:1,6 153:5,11,22 154:4 74:10,16 76:24 77:5 78:16 leaves (2) 1:21 113:10
heard (3) 27:3 78:8 124:22 identified (3) 14:20 36:18,19 individually (1) 74:19 22:4 25:19 36:22 79:1 155:8 157:7 158:15 159:9 79:18 82:1 83:6 84:16,20 leaving (4) 21:5 102:18,21
hearing (3) 71:15 87:20 identifiers (1) 33:22 individuals (10) 100:8,15 83:12 94:15 96:10 97:1,2 160:8 162:4 86:5,8,20 88:25 89:2 157:1
128:21 identify (5) 5:8,10,11 24:9 108:13,14 109:3 116:8,14 111:4 112:3,5 113:14 itself (3) 55:15 154:15 92:9,11 94:5,7,10,11 led (1) 52:21
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held (2) 65:18 159:20 identifying (2) 45:3 120:9 inert (1) 38:1 146:25 156:16 159:7 ive (27) 1:22 3:23 20:12 104:1 107:7 117:23 120:25 left (9) 6:10 40:8 58:8,25
hello (1) 126:3 identities (2) 65:1 141:3 inertia (1) 37:24 introduced (1) 9:8 35:14 40:13 52:8 69:9 79:7 122:1,2 126:6,23,24 129:7 109:12 119:16 120:4
help (14) 9:12 12:18 17:9 identity (4) 44:15 73:7 inference (6) 136:25 137:15 introduction (1) 71:5 83:18,18 94:10 106:20,22 134:8,21,22 135:15,16 136:18 156:6
54:10 65:3 72:11 76:17 131:3,12 143:6,7,9 148:5 investigate (5) 23:22,24 115:1 120:9 123:13 133:25 137:12,17 138:25 141:3 lefthand (5) 68:7,11,15,19
80:20 89:7 99:16,21 ignatiev (2) 81:10,11 info (1) 157:3 130:4 132:13 151:8 138:21 141:24 145:1,8 142:18 144:12 136:11
142:10 153:18 157:5 ignatius (6) 81:11,13,18 82:1 information (32) 5:18,21 investigated (5) 17:20 73:1 148:13 159:19 160:1 152:13,15,21,22 legal (14) 47:14,19 92:10
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90:9 94:13 118:11 119:22
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72:2,11 75:1 82:7,13,14,20 10:3,17 13:4 15:14 17:14 73:5 109:10,20 117:22 investigation (23) 5:6 17:16 156:17 length (4) 52:8 130:3 145:25
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88:18 90:16,21 100:2 19:1 23:16 24:23 120:9 157:6 18:19,19,22 29:19,22 known (10) 28:7 55:8,9 56:8 146:19
98:19 105:20 127:18
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145:8 146:5 149:8 69:18,19 70:25 71:2 initially (1) 80:19 investigations (5) 82:17 konstantin (2) 79:11,25 52:5 74:3 75:4 82:5 123:1
job (2) 59:18 62:12
hes (24) 15:6 58:13,15 60:6 72:12,17,19 73:3,15 74:23 initials (1) 100:20 146:25 147:3,3,5 kramer (86) 44:3,10 letter (20) 18:24,25 19:11,21
jogs (1) 19:19
72:17 73:3 74:9 81:18 77:23 78:5,24 79:7 81:3 initiated (2) 103:3 137:3 investigators (1) 151:13 50:14,17,19 51:12,16 20:6,12,14,23 21:16,16
john (6) 14:14,25 17:19 49:5
85:3,10,23 86:20 87:6 89:2 82:14,17 85:15,15 86:23 initiative (1) 58:6 invite (2) 136:25 137:15 52:13,17,22 53:1,2 45:18 114:10,13
60:3 157:3
96:9,25 126:23 87:22 91:10 92:1 94:11 inner (2) 25:5 26:17 involve (3) 113:12,12 145:21 58:9,14,20,25 59:2 60:11 115:2,21,24 116:21 117:20
jones (16) 12:4 16:3 18:4,8
127:5,22,24 128:1 95:13,23 97:14 98:4 innuendo (1) 129:4 involved (8) 13:14 37:11 61:9,13,17 67:19,25 68:23 141:23 142:2
24:12,17 30:14,21
131:23,24 163:2 102:15 105:1 107:16 inperson (2) 31:4,6 39:17 79:16 90:13 124:25 69:6 70:4,7 72:14 73:5,24 level (2) 57:19 157:24
34:20,24 38:7 39:7 43:3
heshe (1) 55:14 108:23 110:23 112:23 inquiry (2) 47:24,24 130:4 145:23 75:3 78:13 79:19,23 81:22 liaison (2) 4:24 64:16
73:17 74:18 133:20
hiatt (1) 135:24 113:10 114:15 116:22,24 inserting (1) 123:14 involvement (2) 90:23 125:2 83:2 85:17 86:1,1,25 liar (1) 34:18
journal (4) 5:16 84:20
hiding (2) 131:1,18 118:19 120:9 122:9,19 insider (3) 64:15 65:1,15 ip (2) 47:22 48:4 87:4,9,17 88:3,7 101:22 lichtblau (1) 9:11
131:3,11
high (3) 26:25 91:12 99:12 123:3,14 126:11,17 127:1 insofar (1) 108:11 iphone (1) 100:6 102:5,10,12 lie (3) 131:25 132:1 159:25
journalist (6) 8:23 63:16
highest (1) 159:22 128:25 129:8,12,16,25 inspecting (1) 76:3 irrelevant (1) 131:21 103:2,3,6,14,16,21 life (1) 141:12
80:7 81:19 120:1 129:3
highlighted (3) 141:5 130:17,21 132:19 134:7 inspection (5) 75:16 76:5,16 isikoff (3) 21:25 23:18 35:15 104:2,5,23 110:2 light (8) 5:19,22 6:1 18:18
journalists (14) 9:23
143:16,19 135:1 136:2,9 137:19 77:7 80:18 isikoffs (1) 133:13 118:11,13,20 121:21 96:8 105:17 141:6 142:24
30:11,18 73:1 88:25
highlights (1) 14:7 138:4,5 140:4,10 inspector (1) 47:23 islands (1) 148:20 123:19,20 124:3 125:1 like (31) 2:22 15:4 16:4
109:21,24 115:14 128:6
highly (2) 36:14 37:21 142:16,19 150:23 156:3,16 instead (1) 128:23 isnt (36) 14:3 16:5 17:2,24 128:3,7 132:17 136:18 27:14 28:16 29:3 35:10
133:2 146:16,22,24 151:8
highprofile (2) 72:25 80:6 160:5 162:10 institution (2) 5:7,13 25:2,21,22 26:8 27:13 28:6 137:2,4,7 146:1,14,16,21 37:5 41:2 44:24 46:17
journo (1) 86:16
hillary (3) 10:16,17 18:20 imagine (3) 99:21 100:7 institutions (2) 8:12 57:9 35:8,15 40:1 52:2 58:2 155:17 156:6,8 159:17,19 57:9,13 62:17 63:14 70:5
judge (2) 91:11 154:22
himself (6) 9:18 33:15 97:8 102:25 instruct (1) 30:16 64:3 66:8 67:3 69:2,11 160:15,24 161:6 71:20 72:1 78:20 90:15
judgment (2) 50:8 159:7
156:2 158:17 159:5 imagined (1) 82:16 instructions (2) 111:14 72:13,16 73:18 74:6 kramers (5) 123:7,11 126:2 95:17,21 106:16 113:9,12
judgments (1) 58:16
hinted (1) 22:6 immediately (3) 26:10 38:6 137:21 79:5,21 80:3,16 82:22 135:19 139:10 135:6 142:21 145:23,24
july (5) 1:1 46:15 62:6
history (2) 132:10 133:6 134:1 insulting (1) 59:14 84:17 86:4 88:9 89:3 kremlin (8) 25:7 64:15,20 156:10 157:21
147:15 163:11
hold (3) 31:25 32:2 79:8 implication (2) 11:7 141:23 integrity (2) 56:5 153:25 100:24 112:5,20 65:1,15,16 66:2,10 likelihood (2) 70:10 71:5
jump (2) 122:9 126:16
holiday (1) 124:16 implications (2) 158:6,21 intellectual (2) 45:16 46:9 israeli (1) 83:4 likely (5) 12:12 22:13 24:1
jumped (1) 126:20 L
home (1) 87:2 implicit (1) 97:10 intelligence (30) 7:15 22:9 issues (10) 6:14 41:1 49:24 25:14 161:10
juncture (1) 121:12
homeland (2) 59:17,24 implicitly (1) 131:25 23:3 25:6,10 26:1,11 27:8 87:18 102:18,21 115:15 lacking (1) 65:9 likeminded (1) 154:8
june (4) 7:11 91:4 92:20
honest (3) 142:4,18 159:23 implied (3) 31:9 102:13 39:5,5 44:7,12,20 47:5 127:4 132:24 133:2 lady (1) 1:12 limit (4) 43:6,7 100:25
106:21
honestly (5) 13:6 80:21 132:7 50:2,19,20 53:7 59:13,25 italy (1) 85:22 landline (1) 122:15 107:10
junior (2) 81:3 138:6
84:16 156:1 159:6 implying (1) 132:2 72:2 73:13,15 113:3 its (189) 3:19,23,24 5:25 language (1) 36:20 limited (3) 109:25 110:2
juniors (1) 139:7
honesty (3) 56:5 148:6 importance (10) 3:14 68:25 118:15 150:5 151:14,15,24 8:11 9:13 10:3 16:5 17:24 laptop (2) 70:15 100:2 122:16
153:25 77:13 104:23 107:23 111:3 152:16 24:8,23,24 25:2,21 26:21 large (2) 38:25 133:8 limits (1) 138:23
K
honour (2) 159:10,14 115:15 122:6 123:22 intelligent (1) 140:18 27:12 28:5,7,24 32:4 last (14) 9:17 10:4 21:21 line (10) 11:4 19:22 23:20
hope (10) 1:6 41:18 56:12 150:14 intended (1) 50:21 33:13,25 34:1,12,23 35:15 kaiser (1) 45:19 39:22 50:4 56:23 84:24 24:8 35:13 72:8 85:8 98:7
61:14 62:23 150:1,2 155:4 important (11) 29:5 64:15 intention (2) 154:7,11 36:6 37:13,21 41:16 kalimnik (3) 79:11,25 133:2 105:9 107:24 116:9 130:23 122:2 139:18
158:1,7 83:9 88:11 107:3 113:4,5 interaction (1) 27:1 42:18,20 43:16 44:25 kathleen (2) 2:20 4:14 135:22 146:4 150:24 lines (10) 20:21 21:20 27:16
hoped (2) 59:9 147:3 118:9 120:18 136:16 interactions (1) 24:18 45:4,8,24 46:5,14,25 50:15 kavalec (3) 2:20 4:15,22 lastly (2) 106:3 142:5 49:15 50:3 67:16 84:24
hopedfor (1) 27:19 138:21 interest (10) 1:19 2:25 20:1 52:2 55:3,13 56:8 58:1,3 keen (8) 5:18 22:20 28:1 late (10) 9:17 10:4,4 49:4 119:9 136:13 160:18
hopefully (1) 105:4 impossible (2) 49:16 122:10 42:1 86:22 133:11 146:24 59:13,14 62:16 64:11 49:22 61:25 62:11 127:12 56:24 85:23 109:21 121:6 link (3) 1:8 26:3 162:2
hopes (1) 61:16 impression (4) 31:2 51:22 147:2,5 160:6 65:24 67:6,7 68:3 132:10 155:20,23 links (5) 21:22 53:19 54:24
hoping (3) 17:12 119:5 57:15 103:25 interested (10) 31:17 32:7 69:4,5,18,25 70:14 keep (5) 20:13 41:5 86:16 later (17) 28:8 33:7,10,11,12 153:3 154:17
162:14 improved (1) 96:8 62:13 81:23 82:1 104:2 71:7,10,10,15 72:13 73:6 130:2 132:5 36:8 39:15 40:11,17 54:4 lions (2) 83:12 163:7
horowitz (2) 47:24 48:4 inapt (1) 57:25 119:7 128:21 138:4,5 74:1 75:12,13,19 77:9 ken (3) 124:9,20 136:4 69:5 77:17 131:8,15 138:2 list (7) 75:20 92:25 98:13
horror (2) 26:2,5 inaudible (14) 15:11,16 interesting (1) 129:6 79:21 80:10,24 81:2,4,13 kept (1) 33:1 142:16 161:13 122:18 140:14,16 147:8
hostile (1) 20:1 19:11 30:8 34:25 66:19 interests (2) 154:17 156:22 83:1,1 84:3,5,5 85:7 87:22 kerry (2) 14:14,25 lawyer (5) 48:3 64:16 65:15 listed (2) 75:18 108:13
hotspots (1) 2:1 67:12 92:11,13 97:3 105:5 interference (4) 11:9 17:1,8 88:4,9,16 89:12 90:5,7 key (1) 101:2 94:10 95:3 litigants (2) 94:2 95:9
hour (3) 85:14 86:24 87:2 135:8 146:9 157:8 62:17 93:6,23 95:21 98:8 keyword (1) 95:17 lawyers (2) 47:15,17 little (9) 6:2 18:6 51:7 54:10
hours (1) 121:13 inaugurated (1) 17:3 interim (1) 82:16 100:4,5,6,14,19,21 keywords (2) 115:7,13 lay (1) 111:16 114:15 120:7 153:18
house (6) 10:19 12:22 19:9 include (2) 135:22 140:15 interlocutors (1) 66:24 101:1,10,18 102:3 103:24 kind (2) 23:7 140:19 layman (1) 141:14 155:21 159:17
lived (1) 10:19 markings (1) 150:14 34:7,13,20 35:3 36:21 127:21 nbc (1) 22:3 obvious (13) 35:15 38:10 oversight (1) 148:10
locate (1) 92:17 mast (1) 145:24 37:9,18 38:3 43:13 45:15 minutes (6) 72:22 86:23 necessarily (4) 59:4 122:21 40:20 52:2 72:13 89:12 overspeaking (5) 16:18
location (1) 65:10 masters (1) 49:17 50:17,21 64:8 134:9 139:1,3 148:25 149:1 132:11 155:2 108:17 113:2 123:24 36:24 76:5 94:18 97:5
locations (1) 65:8 material (27) 18:16 21:5 memorandum (26) 33:4 misconduct (1) 160:3 necessary (2) 132:22 161:17 126:15 141:7 150:6 151:13 overview (1) 128:4
log (3) 68:5 76:14 114:20 23:16 26:14 29:5 32:24 36:9,13,15,19 37:11,12,16 misprint (1) 81:12 need (17) 13:25 25:20 33:6 obviously (39) 11:20 20:9 owed (1) 39:1
logged (1) 114:16 33:18 37:20 45:2 47:3,5,21 44:1,8 52:24 64:7 65:22,23 missed (3) 41:8 93:3 138:21 73:7 76:20 80:9 81:3 93:11 21:14 22:17 31:4 35:18 own (7) 27:9 28:5 82:17 95:1
london (12) 11:6 40:17 58:5 51:24 56:6 72:3 73:14 72:24 75:7,9,11 83:14 missing (7) 70:18 71:3 99:14 101:17 112:11 119:8 37:3 39:14 41:1 50:9 53:9 113:5 141:14 146:25
62:12 105:19 119:17 125:6 78:16 132:12,25 133:1,1 84:18 102:9,11,14 104:21 77:1,12 101:14 126:15,18 121:16 122:18 138:22 55:25 56:24 58:15 62:16 owned (2) 46:8 47:22
127:3,23 130:7 134:5 138:17 147:25 150:17 110:9 135:12 missive (1) 21:12 139:2,3 70:18 71:3 73:6,21 75:19 oxford (1) 10:18
155:18 151:2 154:1,14 memory (3) 19:19 95:20 mistake (1) 131:14 needed (3) 28:3 43:20 86:21 88:20 89:25 93:25
P
long (13) 2:5,23 31:3 33:10 mathieson (3) 93:1,9 95:2 101:7 mix (1) 6:17 143:24 95:8,20,23 98:16 100:14
42:18 82:19 84:25,25 mathiesons (4) 93:22 memos (12) 24:13,18 26:16 mm (1) 71:7 needless (1) 99:17 102:22 105:25 111:19 pa (2) 65:2,3
85:21 94:21 135:3,4 94:9,25 95:2 30:22 32:5 55:20 79:24 mmhm (23) 51:13 52:10,20 neednt (1) 162:6 117:22 118:9 126:19 package (3) 13:25 14:2
158:13 matt (1) 82:15 83:21,22 125:12 143:24 53:15 57:1 58:11 63:1,18 needs (1) 6:16 128:14 138:25 147:4 154:6 55:21
longer (2) 74:21 139:2 matter (9) 85:3,10 90:6 145:16 64:23 65:19 66:7,21 67:2 negative (1) 35:1 occasionally (3) 41:7,11,13 pages (9) 9:22,25 77:3 124:5
look (78) 3:25 4:20 6:15 102:7 104:1 115:11 138:13 mention (11) 2:2 8:16 9:13 72:6 79:20 88:22 99:25 negligent (1) 39:19 occasions (1) 141:1 135:22 146:8,12,20 149:11
14:10,22 16:19 20:17 142:19 150:1 25:20 87:24 103:12 113:6 110:19 120:3 139:24 neither (1) 30:10 occur (1) 161:19 paid (6) 38:17,23,25,25 39:5
21:20 24:15 25:25 28:8 matters (12) 6:23 11:15 150:10 152:18 153:8 142:23 144:19 147:16 nerve (1) 57:14 occurred (2) 34:10 139:23 84:12
30:4 31:2 39:21 41:14,19 42:18 46:5 75:2 85:17 157:19 mobile (2) 1:25 122:15 network (1) 122:15 occurs (1) 151:20 papers (3) 70:12,14 156:1
43:23 45:1 46:6,21 50:13 94:12 135:6 137:22 151:8 mentioned (4) 94:11 98:16 moment (22) 1:7,11 2:9 14:9 neutral (1) 52:6 oclock (1) 107:12 paragraph (60) 4:1,21
52:11 53:3 55:23 59:6 60:2 154:10 161:5 144:2,20 48:16,18 52:6 89:16 90:5 never (13) 18:1 29:23 30:3 october (25) 2:16,18,18 6:6 11:1,4,12 12:2 14:10 19:21
61:23 62:22 63:11 64:6,8 maybe (1) 90:4 mere (2) 7:18 42:17 97:16 106:16 111:14 38:17,24 42:3 44:19 87:5,8 8:11,21 9:22 12:5 18:9,17 24:24 25:4,25 28:21
66:22 67:9 68:22 69:8 70:3 mccain (57) 17:19 27:22,23 merely (7) 8:2 58:9,14 65:24 120:12 123:3 126:4,21 122:15 151:4 159:11 160:1 19:7 20:11 27:2,3 30:4,5,9 33:25 34:1,4 36:9
71:19,20 74:3,4 76:12,13 44:4,10 49:5 50:5,16,18,20 103:23 109:2 157:6 138:8,14,15 139:1 142:13 news (6) 8:14,16 21:21 22:3 29:12,15,17 35:19 39:21,23 43:10,11 46:7,22
77:15,25 79:10 80:10 81:8 51:9,14 52:16,22,25 merry (2) 68:25 123:23 156:11 85:19 135:21 63:10,19 64:10 65:12 47:1 49:8 50:13 53:13,17
82:3 84:24 85:7 88:1 91:14 55:21,24 56:13,25 message (32) 2:17 12:5,19 monday (4) 18:8 22:3 69:9 newspaper (2) 71:21 79:5 70:13 88:24 152:19 54:22 55:23 56:3 66:22
93:8 99:15 102:22 107:7 57:22,24 58:10,12,17 13:20 56:23 61:23 119:18 newsweek (9) 41:14 odd (4) 71:7,10 128:1 160:20 67:16 93:8,20 94:24,25
108:2 116:5,9 117:7 59:10,15,23 60:3,17,19 63:17,20 68:5,19 69:4 money (2) 38:20 39:1 42:4,7,13,15,20 43:6 74:18 offer (1) 54:16 95:2 102:17,19 104:19
119:11,22 122:9,18 124:5 61:18 118:24,25 121:10,15 76:13,13 80:19 89:25 monitoring (1) 41:3 143:13 offered (1) 40:15 105:2,3,10,15,16 106:24
127:13,16 129:1 135:18 123:16 126:17 127:20 101:3 103:13 105:20 month (3) 21:21 40:11 65:17 next (28) 4:20 6:3 10:7 offering (1) 2:17 107:25 116:5 117:17 123:9
136:16,23 145:22 153:18 144:13,21 153:13,15,20 119:16 120:21 121:13 months (5) 20:4 24:17 86:10 15:22 21:11 25:25 53:5,16 office (3) 11:6 18:11 99:23 136:16 152:4,6,7 153:22
154:19 155:8 156:16 159:7 154:6,19 155:20,23 123:1,12,19,24 128:16 90:3 115:11 59:6 60:2 62:24 64:11,13 officer (5) 22:9 23:3 26:1,12 157:11,12
161:16 156:9,12,14 157:3 129:13 130:23 135:10 more (27) 1:5,18 22:6 24:21 83:10 85:14 86:23 103:23 27:8 paragraphs (10) 11:11
looked (11) 20:7 41:21 72:14 159:12,16 160:9 144:13 155:10 159:8 30:20 40:19,19 44:22,23 112:5 115:25 116:1 123:24 officers (3) 29:17 39:17 28:11,20 106:4,11
76:13 93:22 117:17 126:1 161:7,7,14 messages (46) 11:23,24 49:1 45:13 54:10 58:21 69:5 125:24 127:21 144:25 40:18 115:4,24 116:2,4 153:19
132:16 136:15 146:19 mccains (3) 58:18,25 161:15 68:16 73:23 77:10,20 70:10 72:14 74:8,11 83:12 145:19 148:15 157:1,10 official (7) 4:16 42:14 44:2,9 pardon (10) 24:23 28:13
154:22 mcclatchy (2) 79:16 135:25 89:22 90:8 98:15,18 87:22 105:10 106:3 114:2 night (1) 121:6 52:17,23 58:15 53:2,5 88:10 102:20
looking (15) 5:3 6:3 33:13 mcintyre (3) 108:1,7,19 100:8,17 102:22 118:11 129:4 154:15 157:7 noncontentious (1) 18:15 officials (10) 14:14 15:1 114:13 124:4 126:11
52:3 66:18,19 68:9 78:25 mcintyres (1) 104:17 106:1,4,12 107:24 160:25 none (1) 67:12 16:17 21:21,23 29:13 158:14
80:25 84:25 106:19 107:10 mean (31) 7:3 12:20 28:5 110:16,21,24 112:9,10 morning (6) 53:24 86:13 nonmedia (2) 15:25 17:21 64:20 65:2,6,16 parenthesis (1) 108:17
123:1 136:10 156:21 31:6 34:15 37:3 41:2 113:3,6 117:8 118:9 121:13 128:8 135:9 143:15 nor (4) 5:11 30:10,15 38:25 oh (3) 8:6 92:5 105:1 part (12) 24:3 49:2 57:17
looks (6) 2:8 6:13 63:14 43:4,18 45:11 46:4 54:21 119:10 126:14,18 127:4 moscow (3) 25:11 35:18 normally (1) 127:14 ohr (5) 40:15 54:1,7,8,12 60:23 73:21 84:7,13
75:17 78:20 98:25 60:5 61:17 73:24 75:10 128:8 129:9,11 130:12,21 83:12 note (6) 3:13 5:5 22:6 67:8 okay (6) 15:13 74:3 75:25 130:11,20 145:19 154:25
loose (1) 62:16 83:15 86:19 95:23 100:24 132:16 135:2 140:16,21 mosk (1) 82:15 107:1 115:6 101:12 118:21 146:14 159:2
loosely (3) 20:19 82:12 112:7 131:25 141:4 141:14 142:7,15 147:23 most (3) 68:4 134:23 163:2 noted (1) 140:25 oleg (1) 66:25 participant (1) 32:21
128:19 143:2,3 154:9 158:1 155:5,9 mother (16) 12:4 16:3 notes (16) 3:7,9,15,17,18 once (1) 100:22 particular (9) 2:24 25:2 34:4
lordship (7) 1:25 2:3 93:5 160:17,22 161:10,13 messaging (6) 16:12 107:22 18:4,8 24:12,17 30:14,21 4:2,10,13,14,17,19 5:1 6:3 ones (1) 72:13 45:6 101:2 147:2 154:17
112:24 114:17,24 161:23 meaning (1) 35:5 123:14 144:18 145:25 34:20,24 38:7 39:7 43:3 33:20 63:9 70:13 ongoing (1) 62:14 159:6 160:19
lost (3) 105:1 106:20 136:9 means (2) 13:16 60:6 146:14 73:17 74:18 133:20 nothing (19) 26:25 27:3 open (7) 18:25 19:11 25:3 particularly (3) 26:4 74:17
lot (10) 2:22 18:15 58:16 meant (2) 132:12 156:4 met (12) 9:10 31:9 40:18 mounted (1) 22:3 29:18 32:16 55:17 71:19 88:16 90:24 112:13 77:1
82:10 89:6,7 96:10 101:14 mechanics (1) 113:24 50:9 55:24 65:7 98:19 move (6) 10:7 49:3 85:2,9 57:21,23 59:13 75:5 opening (2) 20:19 53:13 particulars (1) 140:24
106:11 132:23 media (37) 8:7,12,23 105:19 117:24 131:19 113:25 118:3 76:15,18 79:24 80:1,2 openly (1) 20:1 parties (2) 47:4 92:23
lucrative (1) 89:10 16:2,7,9,10,13 17:12,18 132:6 153:20 moving (2) 48:20 107:16 87:16 89:20 98:18 110:20 operators (2) 66:10 84:12 partly (2) 41:2 130:3
lull (1) 16:21 27:16,20 32:14 34:8 35:4 method (3) 41:9 68:6 116:14 ms (7) 2:5 59:3 104:17 137:10 opportunity (6) 20:2 partner (6) 40:9,12 74:15
lunch (1) 18:10 38:11,14 40:25 43:14 52:5 michael (8) 82:20,21 85:21 108:1,7,19 147:14 noticed (1) 160:1 111:23,24 113:14 129:19 92:12,12 153:7
67:19 72:15,16 74:15,22 88:9,10,13,18 133:1 much (18) 22:23 27:3 nova (1) 76:25 130:6 party (6) 5:10 20:9 27:8,9
M
75:2 84:19 87:10,13,19,21 middle (5) 6:15 18:5 105:14 28:8,14 36:22 68:5,10 69:5 november (23) 5:19,22 opposed (2) 9:9 74:15 28:5 59:12
mailboxes (2) 99:6 147:10 102:6 115:16 132:11,13,20 116:2 161:11 70:10 80:3 89:5 107:10 11:18 12:1,3,23 13:10 opus (2) 71:15,16 pass (1) 12:14
main (7) 31:8 62:14,15 66:24 152:16 midmorning (1) 48:17 131:19 138:22 140:7 14:11 15:7,10 16:20 35:19 orbis (7) 5:6 30:10 passage (2) 67:9 141:21
79:14,22 154:12 meet (13) 6:25 13:12 61:25 might (28) 7:16 15:3 20:19 160:11 161:22,25 38:6 41:15 49:10 51:12,14 46:11,12,14 109:3 149:9 passed (3) 57:15 59:20 76:4
maintained (1) 25:5 62:11 87:14 102:7 103:7 29:15 34:15 55:12 66:17 mueller (5) 39:16 40:14,16 54:24 62:8 74:24 151:19 orbiss (4) 11:5 46:8,13 passing (5) 11:23 78:14 79:3
maintenance (1) 142:24 114:7 125:6 128:11 130:19 72:8 82:7 89:10 94:3 95:10 54:5,17 159:18,24 110:12 98:22 161:13
majority (1) 6:10 137:7 140:6 96:10 97:1,2,24 99:16 must (15) 4:17 9:5 22:11 nsa (1) 57:9 order (7) 1:17,21 70:9 71:5 passivity (2) 58:4,6
makes (1) 37:20 meeting (48) 2:16,17,19 101:4 113:12 120:11 23:13 25:15 31:22 71:8 nuland (4) 13:12 59:3 61:22 92:18,21 147:21 passport (1) 83:4
making (7) 37:22,24 68:9 3:9,13,19 4:3,10,16,23 127:10 138:8,15 144:21 82:9,10 86:6 89:17 115:17 62:2 organisations (7) 8:23 34:8 past (1) 38:18
90:20 105:24 129:14 143:4 6:10,24 8:22 14:15,21,25 145:20 153:10 158:7 143:22 159:2 162:20 number (13) 32:3,4 46:5 35:4 43:14 52:5 115:17 patient (1) 161:25
man (5) 82:21 99:22 113:3 15:8 29:12 45:6,11 46:14 162:12 mutual (3) 39:25 62:24 66:4 68:19 73:22 91:24 135:22 paul (10) 9:15 22:5 61:9,21
159:23 160:2 48:3 63:10,19 65:21,21 millar (51) 94:14,17,21 92:25 99:10 101:16 125:8 129:9 original (4) 60:23 80:23 69:11 72:17,20,22 73:25
manafort (15) 22:5,7 64:19 74:9 76:25 78:9,10 82:22 96:11,15,24 97:2,7,12,14 myers (1) 9:7 146:11,19 119:11 162:16 133:1
69:11 72:17,21,23 73:25 84:1,8 90:17 116:16 111:14,16,18,22,24 myself (4) 117:2,13 151:16 numbering (1) 3:24 originally (1) 127:17 pause (6) 2:7 7:21 11:25
79:17 80:3,5,5 83:24 88:4 117:18 119:20 127:13 112:17,20 113:16 114:5 159:11 numbers (16) ostensibly (1) 90:17 120:8,14 156:11
133:1 128:6,15 129:23 131:20 118:5,6 123:6,8 126:10 68:7,8,12,13,14,15 others (2) 58:20 155:3 pausing (12) 5:9 14:2 20:6
N
manage (1) 6:14 134:16 136:20 137:11,17 129:8,22 138:9,18 139:3 70:9,16,19,19,24 otherwise (6) 24:2 73:7,16 21:5 36:18 66:12 125:1
manager (2) 71:15 99:23 147:22 153:3 143:3,9,11,12 145:4 name (11) 22:17 36:23 70:17 71:2,4,6,12,18 75:14 133:25 137:18 127:1 131:2,20 152:15
managing (3) 7:3,4 70:12 meetings (13) 12:13,16 13:1 148:18,20,25 149:7,8,8,23 79:11 93:11 100:21 nyt (1) 7:13 otr (1) 68:24 154:6
manual (1) 116:7 30:12 65:8,10,16 80:11 160:14,15 161:22 101:2,4 119:6 149:11 ought (2) 10:5 139:8 pending (2) 17:16 141:2
O
manuscript (4) 4:13,19 6:3 116:11 117:14 139:22,22 162:6,14,24 163:7 153:8 ourselves (3) 3:17 10:9,24 people (22) 1:18,25 2:22
63:9 141:22 164:6,8,10 named (1) 45:5 objectionable (1) 97:6 outgoing (1) 56:10 15:4 27:11 42:17 45:7,12
many (4) 45:12 83:8 106:20 meets (2) 51:12 64:19 millars (2) 113:13 118:3 names (1) 37:4 objective (2) 27:19 132:13 outlets (2) 67:19 102:6 52:3 56:10 80:15 81:15
159:19 member (2) 45:4 162:21 millian (1) 63:23 narrative (2) 103:12 137:10 obligation (5) 47:4 94:1 95:9 outlines (2) 53:22 64:15 83:6,8 100:20 115:16
march (17) 10:3 34:5 39:18 members (4) 26:17 32:13 mind (9) 16:1 91:8 94:23 narrowed (1) 91:12 97:18 154:18 outraged (1) 19:4 121:10 123:16 151:14
53:25 93:4,6,18 94:25 61:1,3 97:4 121:5 138:23 145:14 nation (1) 156:22 obligations (3) 93:14 95:5 over (19) 12:13 15:23 46:12 152:12 154:9 157:20
95:15 96:16 104:18 memo (6) 25:23 26:7 31:21 156:16 158:1 national (6) 10:14 27:12 96:22 53:16 60:12 62:12 64:24 peoples (1) 72:1
107:4,5 108:4 115:22 45:12 69:14 84:5 minister (1) 16:18 44:2,9 49:24 50:11 obliged (2) 32:8 153:16 80:8 87:3 90:25 98:22 perceived (1) 60:24
148:2 152:1 memoranda (21) 7:25 minority (2) 19:10 20:22 natural (1) 14:20 observation (1) 131:21 109:11 119:9,23 128:5 perfect (1) 70:6
marking (1) 41:17 14:13,17,19 30:11,18,20 minute (4) 46:25 56:21 91:2 nature (2) 50:1 151:13 obtained (1) 51:9 129:1 130:14,21 157:9 perfectly (1) 73:12
performed (1) 91:22 political (9) 17:13 20:20 75:14 86:8 101:10 106:14 23:9,11,13,16,22,25 148:23 151:6,11 recipients (1) 150:22 removed (2) 44:17,19
perhaps (13) 14:7 15:19 19:3 25:7 27:12,17 52:3 112:19 121:8 138:14 24:6,11 25:16,18,25 26:10 160:19,20,21 recollection (2) 124:19 135:8 reopened (1) 18:22
24:7 31:11 74:14 78:25 145:15,18 151:8 144:25 160:25 163:2 27:5,15 28:5,8,13,20,25 questioning (2) 121:22 161:9 recommendation (1) 5:14 repeat (2) 43:18 158:16
80:9 94:17,19 106:5 politics (2) 18:23 27:8 probing (1) 21:22 29:23 30:2,4,7 questions (18) 69:10 72:20 record (8) 23:9 29:18 31:2 repeatedly (4) 68:1 103:5,17
112:17 118:2 posed (1) 50:11 problem (8) 45:1 57:17 31:6,11,22,25 73:25 74:1 91:11,12 98:22 32:11 122:5 123:21 128:4 137:5
period (2) 73:4 134:4 position (4) 5:20 59:17 59:21 60:23 73:21 81:4 32:4,7,11,13,16,18,23 101:11,14 140:10,12 142:19 reply (5) 60:13 74:12 102:12
periods (1) 95:17 125:6 156:14 91:23 96:16 33:5,10,13,17,24 143:12 144:11 148:13 recording (1) 78:8 157:10,16
perkins (1) 5:11 positions (1) 159:20 problems (2) 59:22 91:25 34:15,18,23 35:1,7,14,25 150:4 160:13 161:23,24 records (3) 108:11 122:14 report (18) 24:12 25:16 26:8
permanent (1) 118:14 positively (2) 134:17 137:14 procedural (2) 107:6,16 36:3,5,8,12,23 37:1,3,20 quick (1) 70:4 142:12 30:22,24 32:5 38:13 42:21
permission (1) 47:21 possess (1) 19:23 procedure (2) 150:18 151:1 38:5,10,17,20,22 quickly (6) 28:8 33:25 68:12 redacted (8) 33:17,23 37:16 44:21 49:4 57:3,4 64:10
permitted (2) 91:11,13 possession (1) 26:14 proceedings (5) 91:3,8 94:8 39:3,8,10,12,19 40:19,25 106:5,10 127:23 43:21 44:5,8 78:16,17 65:9,11 66:14 82:23
person (23) 1:12,17 9:7 possibility (1) 62:19 101:23 124:7 41:5,9,12,14,22,25 quite (33) 4:1 8:1 13:2 26:3 redaction (2) 67:10 150:17 154:13
31:10 45:5 55:14 56:6,7 possible (6) 27:16 70:9 71:4 process (4) 54:5 75:16,16 42:3,6,10,17 43:2,10,18 28:5 38:11,25 45:2 57:11 redactions (1) 36:15 reported (3) 21:21 22:3
100:16 110:24 112:8,25 90:23 159:7,9 77:4 45:1,10,15,18,22,24 62:7 68:8 76:18 81:18 reengaged (3) 39:15,17 158:5
137:21 140:18 144:8 possibly (9) 1:10 33:19 produced (2) 77:7,14 46:2,4,21 47:11,17,23 82:19,20 89:6,7 92:4 94:11 40:15 reporter (2) 29:2 79:16
153:12,14 154:1,3,21,22 56:15,20 80:11 85:2,9 professional (4) 56:5 125:5 48:7,15 49:21 50:13 96:10 97:23 98:9 101:14 reestablished (1) 54:12 reporting (6) 7:11 42:24
159:12 161:3 95:15 125:24 147:4 153:25 51:5,7,14,16,20,25 119:15 128:10 130:13 reexamination (4) 143:11 57:16 87:5,6,11
personal (3) 56:5 153:25 post (17) 7:1,15,25 8:13 profile (1) 63:22 52:2,8,11,21 53:2,16 133:6 138:16 142:19 156:3 160:14 164:6,10 reports (40) 7:8,9 8:19,20
156:17 57:15 58:21,22 progress (1) 9:19 54:7,10 55:6,23 56:2,17,21 160:6,7,8 refer (3) 78:11 112:24 9:22,25 14:3 17:4 31:25
personally (3) 31:9 87:13 70:10,11,11 73:11 81:16 project (9) 11:9 62:14,15 57:2,6,11,21 58:8,12,23,25 quotations (1) 30:23 119:13 32:2 42:8,19 44:13
140:20 85:20,21 86:2,9 135:24 64:2,5 89:10,19 90:18 59:6 60:2,9,12,25 61:23 quote (3) 21:2 27:6 32:3 reference (29) 3:23 4:2 10:9 46:8,10,11,13,17,19 48:9
persons (2) 55:9 115:10 postman (2) 58:10,14 130:8 62:11,18,22 63:2,5,8,19 quoted (2) 29:17 42:17 17:10 19:1 20:24 21:15 50:6 51:9,21 52:4,14 56:14
perspective (3) 16:10,11 postnew (1) 6:21 promoting (2) 27:18,20 64:2,6,13,24 65:5,20 quoting (1) 25:23 27:11 28:13 51:1 68:5 61:13,15 65:15 69:13
97:15 potentially (5) 20:25 60:7 prompt (2) 43:20 143:25 66:8,10,22 67:3,14,23 69:20 73:17 76:14 80:22 73:13,15 80:3 82:11 83:18
R
pertaining (2) 44:6,13 63:25 89:10 129:5 proof (1) 129:5 68:4,14,18,21 69:4,13 83:13,16,19,23 88:13 86:1 150:5,9 155:19
peskov (1) 16:17 practice (1) 29:3 proper (4) 97:17 140:21 70:15,22 71:1,3,8,12,21,24 r (1) 16:14 104:12 107:24 123:4 126:8 158:22
pete (1) 80:14 prague (19) 65:18,21 66:3,19 154:10 156:12 72:2,5,7,13,19,22 raise (7) 6:23 8:7 59:23 136:2 140:16 146:3,23 represent (1) 149:25
peter (2) 5:14 135:24 74:9,14 78:9,10 82:22,25 properly (5) 59:19 93:13 73:3,10,16,21 74:3,8,23 60:19 94:14 114:3 127:11 155:8 representation (1) 96:12
phone (15) 41:11,12 68:13 83:3 84:1,8,10,10,23 85:23 95:4 142:25 158:23 75:1,4,12,14,23 76:1,9,12 raised (6) 8:9,9 32:17,18 references (3) 82:25 114:22 representative (1) 2:21
76:1 100:2,3,4,5 119:20 133:4 146:23 property (2) 45:16 46:9 77:25 78:5,8,19,24 33:3 38:1 133:4 representatives (2) 61:10
121:22 122:8,14,24 123:18 praises (1) 20:2 proportionate (2) 92:16 79:10,21 80:2,8,18 rate (1) 112:12 referred (6) 3:6 26:17 53:19 66:10
125:8 precise (1) 141:3 115:12 81:14,18,21 82:3,19,25 rather (14) 13:4 42:18 45:8 72:23 90:1 153:7 republican (14) 18:24 28:1,2
phoned (2) 12:21 40:2 precisely (7) 43:4 99:2 proposal (1) 162:16 83:16,18,22 56:18 61:16 63:13 69:25 referring (6) 21:14 58:2 49:22 55:13 56:9,14,18
phones (1) 1:25 100:24 101:15 120:22 propose (1) 7:7 84:1,4,7,12,14,17,24 85:6 70:7 74:10,19 89:2 99:20 87:11,20 103:17 155:25 59:7,12 153:11 154:5
phrase (4) 17:21 57:11,25 132:7 147:24 proposed (2) 13:17 27:24 86:6,11,22 87:16,19,22,25 105:25 107:3 refers (13) 16:13 20:19 28:9 158:8 159:20
158:9 preelection (14) 14:13,16 proposition (1) 47:14 88:10,12,15,20,23 reach (2) 86:12,14 47:12,13 56:2 74:2 82:4,18 republicans (6) 16:24 17:11
physical (1) 77:6 30:11,20 34:7,19 35:3 propositions (1) 47:8 89:2,5,12,16,22 90:4,19,24 reached (1) 54:18 86:5,9 115:4 156:23 55:11 152:14 154:8 157:24
pick (2) 2:15 126:1 36:20 37:18 43:13 45:15 protect (1) 44:15 91:2,6,14 93:18,20 reaction (1) 128:21 reflect (2) 4:11 116:20 republication (1) 34:9
picked (3) 83:1 115:25 116:3 50:16,21 134:9 protection (2) 6:22 54:14 98:18,22 99:3,11,20,24 read (40) 5:4 21:2,24 26:6 reflection (1) 58:3 reputation (1) 49:24
picking (3) 68:22 88:2 123:3 preliminary (1) 22:4 protective (1) 150:14 100:1,5,7,11,14,24 101:6,9 31:16,19 35:11 41:15,25 refused (1) 91:1 request (11) 11:13 26:10
picks (1) 76:25 preparation (1) 110:9 provide (2) 125:11 142:6 102:20 103:1,12,19,25 42:2,16 55:14 83:19 91:17 regarded (1) 158:8 38:24 43:24 52:12 61:19
picture (4) 68:25 69:6 122:5 prepare (1) 75:18 provided (10) 24:17 30:10 104:7,10 106:9 108:17 93:11 94:19 104:8,9 register (1) 142:4 82:6 96:3 109:9 113:13
123:22 prepared (8) 4:23 83:11 44:2,9 47:5 50:19 76:2 109:14,18 110:4,20,23 105:9,10 106:5,10 113:1 regular (1) 25:6 139:23
piece (1) 118:10 98:13 116:6 128:11 134:17 99:8,24 107:23 114:10 116:23 117:22 116:21 119:8 129:9,11 rehashed (1) 96:16 requested (3) 14:16 24:21
place (11) 2:19 8:25 12:3 151:23 162:7 public (9) 20:3,5 21:3,8 29:8 118:2,17,19 119:1,15 137:22 140:24 reid (3) 19:7 20:22 21:6 50:18
18:1 20:11 59:22 66:17 preparing (1) 83:10 59:12 119:2 133:11 141:12 120:4 122:20,23 123:1 141:17,19,20,21,24 143:23 reids (2) 21:12 22:6 requests (3) 68:2 103:5
79:9 123:14 151:7,7 prepenultimate (1) 153:22 publication (10) 28:9 43:17 126:14 128:14,23 152:21 153:12,16 154:23 relate (1) 108:12 137:6
plainly (8) 4:12 12:18 24:1 prerogative (1) 111:19 52:24 86:4 88:1 89:13 130:12,21 131:6,16,25 158:2 related (4) 121:4,11 123:17 required (2) 46:6 92:18
30:13 32:25 130:22 presence (1) 159:25 105:17 133:21,24 134:11 132:2,5,9,16,19 reading (6) 24:22 29:23 42:6 132:24 requirement (1) 157:23
141:5,21 present (4) 35:13 93:1 98:25 publicity (1) 41:5 133:4,6,10,15,18,20 105:2 129:13 157:1 relates (3) 113:16,17 140:14 rerereamended (1) 106:21
plan (3) 61:14 119:17 131:19 105:11 publish (5) 23:23 24:1,2,4 134:3,7,15,22,25 reads (1) 27:14 relating (3) 18:18 110:8 respect (3) 60:10 62:20
planning (2) 90:11 127:17 presented (1) 130:7 134:2 135:5,9,18 137:13,21 ready (2) 138:25 162:21 129:15 159:22
plans (1) 61:16 presently (1) 110:5 published (11) 8:19 12:4 138:4 139:13,15,18,25 real (1) 96:15 relation (11) 11:15 35:15 respond (1) 79:22
play (1) 113:14 preserve (1) 130:6 21:25 25:14 34:7,20,22 140:3,5,7,14,18,24 realised (1) 21:24 83:18,20 96:11,15 108:21 responding (1) 86:18
played (1) 64:15 presidencies (1) 159:20 35:3 37:16 43:13 133:7 141:10,17,21,25 reality (2) 47:19 144:8 111:18 139:25 141:10 response (11) 26:1 37:25
players (1) 136:6 president (2) 17:5 29:21 publishers (1) 104:20 142:2,5,10,13,17,19 really (14) 9:20 24:25 36:4 161:13 58:6 102:16 106:13 108:3
plea (2) 102:17 104:1 presidentelect (1) 158:18 publishing (1) 22:13 143:15,18,22 37:7 38:16 40:24 55:1 relations (4) 40:21,24,24 109:9 112:15 129:20
pleaded (5) 58:9 102:11,23 presidential (3) 22:12 65:4,6 pupil (1) 92:6 144:2,11,16,18,20,25 57:11 83:11 112:1 122:10 53:25 147:21 155:1
134:18,23 press (1) 78:24 pure (1) 101:1 145:7,9,12,14,19,21,25 129:19 137:13 144:8 relationship (6) 38:15 47:6 responsibility (4) 10:13 48:8
please (81) 3:22,25 4:5,21 pressed (1) 23:13 purple (5) 34:4 102:1,2,20 146:4,6,8,12,14,19,24 reamendments (1) 106:20 49:20 64:6 144:3 151:21 59:20 154:24
5:2 6:2 7:6 9:13 10:7 11:1 pressure (2) 17:13,13 117:17 147:6,13,17,19 148:1,4,9 reason (14) 7:23 27:22 28:1 released (3) 20:5 42:19 responsible (8) 56:8,14,18
16:19 20:17 24:16 presumably (14) 6:17 purpose (6) 14:20 46:4 52:18 149:16,18,20 30:24 31:5,18 34:13,19 119:6 59:10,11 80:15 154:5
28:10,14 30:7 33:24 22:11,20 23:13,17 41:25 84:7 91:8 154:13 150:4,9,13,17,21 35:17 74:22 97:12 101:15 relevant (15) 41:5 57:10 158:8
34:1,3,22 39:22 41:14,16 51:2 55:18 74:17 76:9 purposes (7) 23:5 53:11 76:3 151:1,6,11,17,19,23 160:7 162:22 66:17 95:15 100:1,15,18 responsive (1) 54:13
43:23 44:1 46:21 48:15 80:24 91:17 125:21 132:7 92:2 97:5 105:11 141:18 152:1,4,19 153:9,18,22 reasonable (4) 42:9 92:16 106:24 110:16 rest (1) 80:19
50:13 52:11 53:3,12,16 presume (1) 91:18 pursue (5) 38:20 39:6 118:2 155:4,7,15 156:5,11 115:8 142:22 115:10,10,19 134:14 result (4) 54:19 96:21
56:22 60:12 61:23 62:4 pretrial (1) 1:18 156:2 159:3 157:1,9,14 158:1,7,13 reasonably (1) 102:12 141:13 144:14 105:17 140:9
63:8 64:6,8,9 65:11,24 pretty (8) 23:21 26:21 42:6 pursued (1) 98:8 159:15,23 reasons (9) 12:8 22:24 reliable (2) 82:8 161:20 resulted (1) 49:19
67:14 68:10 69:8 76:12 52:9 59:14 122:18,19 pursuing (1) 107:9 160:2,5,8,18,21,23 49:11,12 54:12 74:16 relied (1) 106:1 resulting (2) 99:8,24
78:5 79:10 84:24 85:25 126:15 pursuit (1) 64:21 161:6,13,18 76:24 98:23 101:16 reluctant (1) 29:1 resume (1) 138:25
86:16 91:14 92:22 93:17 prevents (1) 111:12 putin (1) 88:17 qc (1) 149:8 reassure (1) 159:16 remain (1) 74:15 resumed (1) 53:25
101:25 105:12 106:6 previous (3) 9:9 87:8 93:15 putting (3) 54:22 76:21 qualification (1) 92:10 reassured (1) 38:3 remark (1) 156:21 reticent (1) 23:21
108:2,5,25 109:7,11,14 previously (3) 39:1 81:16 118:19 quarrel (1) 143:3 rebegan (1) 54:1 remember (41) 7:16 8:10 return (2) 74:8 123:1
114:11 115:3,19,25 116:9 88:25 puzzled (1) 14:9 quarter (1) 124:5 recall (17) 6:25 9:1 12:20 13:5,9,13,14 18:11 20:14 reveal (2) 110:25 120:10
118:8,17 119:10 135:7 priest (1) 82:2 queries (1) 9:5 19:18 70:20,20 72:12 21:18 23:6 24:14 38:8 revealed (6) 22:25 53:23
136:3,7,16 143:18 primarily (1) 73:18 Q question (54) 6:12 7:22,23 91:10 98:17 99:2 103:3 45:16 49:2,14 60:11 63:7 131:3,11 135:11 140:21
146:8,11 149:23 155:4 prime (1) 158:24 8:1,4 40:19 43:3 58:23 137:3 140:2 147:19 148:1 70:23 76:6 78:23 87:7 reveals (2) 104:16 110:20
157:9 prior (2) 5:19,22 q (458) 3:4,6,9,11,13,17 4:18 72:2 73:19 78:14 79:7,8 156:1 161:9 95:13,16 115:18 125:23 review (2) 1:18 35:9
pleasure (1) 150:1 private (3) 14:15,25 18:20 5:13,24 6:2,12 7:3,6,18,22 94:14,17,22 95:3,6,12 received (9) 42:23 50:2,6,16 135:3,13 137:24 141:19 reviewed (4) 24:12 30:22
plenty (2) 154:14 160:25 privilege (12) 94:13,18 96:4 8:1,11,16,19 9:2,5,12 97:11 107:10 111:13 51:3 52:14 89:16 110:24 143:13,20 147:11,18 32:4 93:10
pm (11) 18:14 69:10,11 111:11,12,16 113:13,17 10:13,16,20,24 11:22 112:1,2,17,20 113:23 112:8 148:22,24 150:23 151:24 revise (1) 117:11
92:23 107:13,15 139:4,6 140:9 142:25 143:8,10 12:24 13:9,13,16,20 14:5 114:3 117:11 receiving (1) 26:7 156:19 157:18 159:4 revisit (1) 1:20
149:3,5 163:9 privileged (5) 93:12 94:15 15:5 16:5,7,10,14,19 124:8,12,17,19 recent (5) 16:14 22:6 160:23 righthand (3) 6:5 11:25
pointed (2) 20:25 29:2 96:10 111:5 142:5 17:2,7,10,16,21 18:3,13,22 125:9,11,14,18,21,23 24:17,18 134:23 remind (9) 3:17 10:9,24 124:6
points (5) 4:2,9 43:4 118:8 proactively (1) 86:18 19:1,6,11,14,16,19 20:9,17 126:4,22 129:8,10 130:1 recently (1) 105:17 107:18 118:10 121:20 ring (2) 43:5 79:11
158:5 probably (13) 13:22 71:13,14 21:9,11,20 22:2,16,20,23 135:6 141:10 142:6,21 recipient (3) 151:3,18 154:7 136:18 139:7 148:16 ringing (2) 126:3,21
rise (1) 149:1 secondly (3) 116:18 130:5 sensitivities (1) 1:24 signs (1) 29:8 121:23 124:9 137:6 161:3 stops (1) 70:1 surprising (3) 60:14 74:14
risk (6) 32:23 44:21,23,24 159:4 sent (8) 20:23 41:6 58:5 similar (1) 50:3 speaking (2) 55:25 144:2 storage (1) 99:7 157:14
45:9 162:12 secret (4) 64:16 65:15 66:1 89:25 110:24 112:8 129:15 simple (2) 14:25 100:14 specialists (1) 5:15 story (8) 10:25 65:13 suspect (3) 52:22 131:18
rivals (1) 25:8 132:5 131:2 simpson (24) 5:14 17:25 23:7 specific (6) 13:2 14:19 88:2,5,9,17 100:16,18 140:24
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19:1 21:2,15 28:10 32:23 131:19 133:17,23 134:17 waive (2) 111:11,16 wholly (6) 17:4 33:13 57:25 159:18,24
124:1 125:14 130:12 yet (6) 26:12 45:24 53:5
33:5,6 35:7 44:21,23 45:11 142:3 152:10 159:25 waived (1) 96:4 102:18,21 156:11 2017 (7) 10:3 39:18 47:1
134:15 137:18 138:10,19 108:24 116:17 144:15
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141:4 143:2 151:19 153:9 york (8) 6:21 7:1,14,24 8:13
57:21,23 64:24 68:15 tomorrow (9) 69:9 72:8 82:5 wall (4) 5:15 84:20 131:3,11 74:1 87:13 97:17 100:9 2018 (2) 91:4 152:1
163:1 9:7 29:16 73:11
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understandably (1) 19:3 youll (12) 9:15 21:15 28:20
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97:9 140:8 151:22 154:20 115:3,24 126:16 138:24
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undertook (1) 5:6 35:9,25 44:24 60:16 62:23
66:18,19 73:14 82:14 topic (4) 95:24,25 96:1 97:24 31:13 37:7 48:16,20,25 wincing (1) 114:19 127:17
unfair (3) 41:23 42:18 58:14 72:5 76:21 85:18 90:19,20
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unhappy (1) 38:2 yours (4) 64:3 93:18 94:3
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54:14 130:14 155:19 yourself (4) 2:17 48:8
128:18 133:16 139:8 towards (1) 24:24 92:1,5,9,11 93:3,7 wing (1) 59:11 26 (2) 94:25 106:21
159:21 106:6,10
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thinking (2) 62:25 120:5 tracks (1) 83:7 96:1,12,20,25 wise (1) 97:24 27 (2) 115:22 122:12
122:1 143:2 42:3 100:22 113:11 143:4
thinks (1) 79:16 transcript (4) 69:16,25 94:20 97:6,10,13,20,23 98:2,4,7 wish (4) 1:22 154:19 155:2 27th (1) 125:25
unlikely (3) 35:20 60:15 145:3 158:13
third (7) 7:9 11:4 19:21 47:4 112:18 99:14 101:10,13,16 102:1 158:22 28 (2) 18:17 136:11
157:15
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unredacted (5) 32:23 43:19 Z
thorough (1) 147:4 travelrelated (2) 126:4,22 107:1,4,7,16 109:5,15 156:2 161:4
44:17 134:9 143:24 3
though (6) 2:8 6:13 74:14 treated (1) 50:8 111:8,15,17,21,23 wishes (3) 15:20 111:16
unspecified (1) 35:18 zoom (1) 99:14
99:1 150:10 158:25 treating (1) 120:21 112:1,19,22 113:11,19,23 119:23 3 (28) 2:16 6:4 11:23 14:11
unsuited (1) 17:4
thought (23) 2:2 9:20 14:5,8 trial (2) 141:18 160:21 114:15,19 115:1 116:24 wishing (1) 104:12 24:7 25:4 29:12 47:1 52:12
unsure (2) 29:5 65:1 1
15:15,19 28:3 41:8 51:21 tried (5) 24:20 74:9 86:12 117:5,7 118:5 120:7 witness (48) 10:25 14:10 76:15,23,24 77:7 80:11
unsurprisingly (1) 24:7
53:24 54:21 57:7 60:14,19 126:3,21 121:17 123:3,10 127:6,9 30:5 36:10 39:21 49:6 1 (23) 4:24 5:3,4 9:15 12:3 105:20 109:6,18 128:15
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urgent (2) 86:13 120:21
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Christopher Steele Testimony in Gubarev Lawsuit

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Christopher Steele Testimony in Gubarev Lawsuit

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Gubarev and others v Orbis Business Intelligence Ltd and another

July 23, 2020

Opus 2 - Oﬃcial Court Reporters

Phone: 0203 008 6619

1 Thursday, 23 July 2020 1 doubt?

1 A. No, I don’t . 1 conversation in November, on your account in

1 to be available for meetings in Washington on the 1 oﬃcials of the State Department?

1 A. Russian election interference . 1 Q. I ’m not absolutely sure . There’s a reference to it

1 controversy ." 1 Would I be right that the words, it may not be

1 A. Yes. 1 likely to publish an article so you plainly wanted him

1 either ? 1 Mr Simpson denied showing them to him.

1 obviously on these issues , not American football ? 1 the American Government.

1 interest ? 1 "Please state whether the December memorandum was

1 the existence and nature of our investigation and the 1 A. Yes.

1 A. Mr Kramer. 1 MR JUSTICE WARBY: Right. Well, we haven’t really dealt

1 A. Mm-hm. 1 giving it to the CIA, on your version ?

1 for a decision by him not to give it to the CIA. It ’ s 1 that .

1 colleagues in Congress or are you saying fellow members 1 A. Mm-hm.

1 point ." 1 claimed to be associated with the Trump campaign.

1 Christmas!" 1 Q. Are you sure about this ?

1 it stops . 1 people’ s business cards , things like that .

1 missing , and you can see this particularly at E/154 -- 1 into it .

1 "From Alan" section : 1 Steele :

1 A. Correct . 1 A. But I had refused to engage on it .

1 text messages is relied on in support of the disclosure 1 Ms McIntyre.

1 question . 1 A. What sort of lie ?

1 detrimental to our case but, as you will see from my 1 Mr Bernstein?

1 least two occasions we say: 1 it .

1 A. It ’ s wrong, yes . 1 A. Yes.

1 A. I ’ve got the stratagem text . 1 Trump/Russia?

1 giving your evidence . That’s the end of it . 1 INDEX

5 (10) 7:6,10 30:4 43:11

6 (8) 2:18 43:24 45:24 62:4

8 (7) 5:19,22 46:22 47:1,12

9 (5) 52:12 68:22 93:8

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