Kirill Dmitriev's Transition-Era Outreach to the Incoming Administration

¶Aven 's description of his interactions with Putin is consistent with the behavior of Kirill Dmiti-iev, a Russian national who heads Russia's sovereign wealth fund an d is closely connected to Putin. Dmiti·iev unde1iook effo1is to meet members of the incoming Tnunp Administi·ation in the months after the election . Drniti·iev asked a close business associate who worked for the United Arab Einirates (UAE) royal comi , George Nader, to inti·oduce him to Trnmp ti-ansition officials, and Nader eventually an anged a meeting in th e Seychelles between Dmiti-iev an d Erik Prince, a Trnmp Campaign suppo1ier and an associate of Steve B annon.989 In addition, th e UAE national secm ity advisor inti·oduced Drniti·iev to a hedge fund manager and friend of Jared Kushner, Rick Gerson, in late November 2016. In December 2016 and Januaiy 2017, Dtniti·iev an d Gerson worked on a proposal for reconciliation between the United States and Russia, which Dtniti·iev implied he cleared through Putin. Gerson provided that proposal to Kushner before the inaugm ation, and Kushner later gave copies to B annon and Secretaiy of State Rex Tillerson .

Background

¶Drniti-iev is a Russian national who was appointed CEO of Russia's sovereign wealth fund, th e Russian Direct Investinent Fund (RDIF), when it was founded in 2011 .990 Drniti·iev repo1ied directly to Putin an d frequently refen ed to Putin as his "boss."⁹⁹¹⁹⁹¹ Gerson 6/15/ 18 302, at L See also, e.g. , 12/14/16 Text Message, Dmitriev to Gerson; 1/9/17 Text Message, Dmiti·iev to Gerson.

¶RDIF has co-invested in vai·ious projects with UAE sovereign wealth funds.⁹⁹²⁹⁹² [Redacted: (b) (3)] Dtniti·iev regulai·ly interacted with Nader, a senior advisor to UAE Crown Prince Mohainmed bin Zayed

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¶(Crown Prince Mohammed), in connection with RDIF 's dealings with the UAE.⁹⁹³⁹⁹³ Nader 1/22/ 18 302, at 1-2; Nader 1/23/ 18 302, at 2-3; 5/3/ 16 Email, Nader to Phares; - [Redacted: (b) (3)] Putin wanted Dmitriev to be in charge ofboth the financial and the political relationship between Russia and the Gulf states, in pa1t because Dmitriev had been educated in the West and spoke English fluently.⁹⁹⁴⁹⁹⁴ Nader 1/22/18 302, at 1-2. Nader considered Dmitriev to be Putin's interlocutor in the Gulf region, and would relay Dmitriev's views directly to Crown Prince Mohammed.⁹⁹⁵⁹⁹⁵ Nader 1/22/18 302, at 3.

¶Nader developed contacts with both U.S. presidential campaigns dming the 2016 election, and kept Dmitriev abreast of his effo1ts to do so.⁹⁹⁶⁹⁹⁶ Nader 1/22/18 302, at 3; [Redacted: (b) (3)] According to Nader, Dmitriev said that his and the government of Russia's preference was for candidate Tnnn to win and asked Nader to assist him in meetin members of the Trnm Cam ai n .997

¶Nader did not introduce Dmitriev to anyone associated with the Trnmp Campaign before the election.⁹⁹⁹⁹⁹⁹ Nader 1/22/18 302, at 3. 1000 [Redacted: (b) (3)] 1001 [Redacted: (b) (3)] 1002 [Redacted: (b) (3)] 1003 [Redacted: (b) (3)] 1004 [Redacted: (b) (3)]

¶Erik Prince is a businessman who had relationships with various individuals associated with the Trnmp Campaign, including Steve Bannon, Donald Trnmp Jr., and Roger Stone.¹⁰⁰⁵¹⁰⁰⁵ Prince 4/4/ 18 302, at 1-5; Bannon 2/ 14/ 18 302, at 21. Prince did not have a fonnal role in the Campaign, although he offered to host a fundraiser for

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¶Trnmp and sent unsolicited policy papers on issues such as foreign policy, trade, and Russian election interference to Bannon. 1006

¶After the election, Prince frequently visited transition offices at Trnmp Tower, primarily to meet with Bannon but on occasion to meet Michael Flynn and others.¹⁰⁰⁷¹⁰⁰⁷ Flynn 11/20/17 302, at 6; Flynn 1/11/18 302, at 5; Flynn 1/24/18 302, at 5-6; Flynn 5/1/18 302, at 11; P1ince 4/4/18 302, at 5, 8; Bannon 2/14/18 302, at 20-21; 11/12/16 Email, Prince to Corallo. Prince and Bannon would discuss, inter alia, foreign policy issues and Prince's recommendations regarding who should be appointed to fill key n a t i ~sitions. 1008 Although ~ affiliated with the transition, N a d e r - received a s s u r a n c e s - that the incoming Administration considered Prince a trusted associate.10

Kirill Dmitriev's Post-Election Contacts With the Incoming Administration

Soon after midnight on election night, Dmiti·iev messaged [Redacted: (b) (3), (b) (7)(E)] who was ti·avelin to New York to attend the 2016 World Chess Championship. Dmitiy Peskov, the ss Cham ionshi .1010 'J!llll'RTI~

¶At approximately 2:40 a.m. on November 9, 2016, news reports stated that can didate Clinton had called President-Elect Tnunp to concede. At approximate! 2:50 a.m., President-Elect Trnm ublicl stated that Clinton had called to con ·atulate ·

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¶Later th at morning, Dmitriev contacted Nader, who was in New York, to request a meeting with the "key people" in the incoming Administration as soon as possible in light of the " [g]reat results." 10 16 He asked Nader to convey to the incoming Administration that "we want to sta1t rebuilding the relationship in whatever is a comfo1table pace for them. We understand all of the sensitivities an d are not in a 111sh." 1017 Dmitriev and Nader had previously discussed Nader introducing him to the contacts Nader had made within the Tnnnp Campaign.1018 Dmitriev also told Nader that he would ask Putin for permission to travel to the United States, where he would be able to speak to media outlets about the positive impact of T111mp's election an d the need for reconciliation between the United States and Russia. 1019

¶Later th at day, Dmitriev flew to New York, where Peskov was separately traveling to attend the chess tournament. 1020 Dmitriev invited Nader to th e opening of th e tomnament and noted that, if there was "a chan ce to see anyone key from Tnnnp camp," he "would love to sta1t building for the foture." 1021 Dmitriev also asked Nader to invite Kushner to the event so that he (Dmitriev) could meet him.1022 Nader did not pass along Dmitriev's invitation to anyone connected with the incoming Administration.1023 Although one World Chess Federation official recalled hearing from an attendee that President-Elect T111mp had stopped by the tomnament, the investigation did not establish that Tnnnp or any Campaign or Transition Team official attended the event. 1024 And the President's written answers denied that he had.1025

¶Nader stated th at Dmitriev continued to press him to set up a meeting with transition officials, and was paiticularly focused on Kushner an d Trnmp Jr. 1026 Drnitriev told Nader that

¶[Redacted: (b) (3)]

¶~ .

¶11/9/ 16 Text Message, Dmitriev to Nader (9:34 a.m.); Nader 1/22/18 302, at 4.

¶11/9/ 16 Text Message, Dmitriev to Nader (11:58 p.m.).

¶Nader 1/22/18 302, at 3.

¶11/9/ 16 Text Messa e, Dmitriev to Nader 10:06 a.m.); 11/9/ 16 Text Message, Dmitii ev to Nader (10:10 a.m.);

¶11/9/ 16 Text Message, Dmitriev to Nader (10:08 a.m.); 11/9/ 16 Text Message, Dmitii ev to Nader (3:40 p.m.); Nader 1/22/ 18 302, at 5.

¶11/9/ 16 Text Message, Dmitriev to Nader (7:10 p.m.).

¶11/ 10/ 16 Text Message, Dmitriev to Nader (5:20 a.m.).

¶Nader 1/22/ 18 302, at 5-6.

¶Marinello 5/31/18 302, at 2-3; Nader 1/22/ 18 302, at 5-6.

¶W1itten Responses of Donald J. Tmmp (Nov. 20, 2018), at 17-18 (Response to Question V, Pait (a).

¶N ader 1/22/ 18 302, at 6; [Redacted: (b) (3)]

¶Nader 1/22/18 302, at 6; [Redacted: (b) (3)]

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¶According to Nader, Dmiti·iev was ve1y allXlous to connect wit t e mcommg A mmsti·at1on and told Nader that he would tiy other routes to do so besides Nader himself.¹⁰³⁰¹⁰³⁰ Nader 1/22/18 302, at 6. Nader did not ultimately inti·oduce Dmiu-iev to anyone associated with the incoming Adminisu-ation during Dmitriev's post-election u-ip to New York.¹⁰³¹¹⁰³¹ Nader 1/22/ 18 302, at 5-7.

¶In early December 2016, Dmiti·iev again broached the topic of meeting incoming Adminisu-ation officials with Nader in Januaiy or Febmaiy.¹⁰³²¹⁰³² 12/8/ 16 Text Messages, Dmitii ev to Nader (12:10:31 a.m.); Nader 1/22/ 18 302, at 11. Dmiu-iev sent Nader a list of publicly available quotes of Dmiu-iev speaking positively about Donald Tnnnp "in case they [were] helpful." 1033

Erik Prince and Kirill Dmitriev Meet in the Seychelles

George Nader and Erik Prince Arrange Seychelles Meeting with Dmitriev

¶Nader traveled to New York in eai·ly Januaiy 2017 and had lunchtime and dinner meetings with Erik Prince on Januaiy 3, 2017 .1034 Nader and Prince discussed Dmiu-iev.¹⁰³⁵¹⁰³⁵ Prince 5/3/ 18 302, at 3; [Redacted: (b) (3)] Nader info1med Prince that the Russians were looking to build a link with the incoming Tnnnp Adminisu-ation .1036 he told Prince that Dmiti·iev had been ushin Nader to inu-oduce him to someone from the incomin Administi·ation

¶. Nader suggested, in light of Prince' s relationship with Transition Team officials that Prince and Dmiti·iev meet to discuss issues of mutual concem .1038 Prince told Nader that he needed to think fuii her about it and to check with Transition Team officials. 1039

¶After his dinner with Prince, Nader sent Prince a link to a Wikipedia entiy about Dmiti·iev, and sent Dmiu-iev a message stating that he had j ust met "with some key people within the fainily and inner circle"- a reference to Prince-and that he had spoken at length and positively about

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¶Dmitriev.¹⁰⁴⁰¹⁰⁴⁰ 1/4/ 17 Text Message, Nader to Prince; 1/4/ 17 Text Messa es, Nader to Dmitriev (5:24 a.m. - (b)( )-l 3 5:26 a.m.); Nader 1/22/ 18 302, at 8-9; Nader told Dmitriev that the people he met had asked for Dmitriev's bio, and Dmitriev replied that he would update and send it.¹⁰⁴¹¹⁰⁴¹ 1/4/ 17 Text Messages, Nader & Dmitriev (7:24:27 a.m.). Nader later received from Dmiti·iev two files concerning Dmitriev: one was a two-page biography, and the other was a list of Dmitriev's positive quotes about Donald Tnnnp. 1042

¶The next morning, Nader fo1warded the message an d attachments Dmiti·iev had sent him to Prince.1043 Nader wrote to Prince that th ese documents were the versions "to be used with some additional details for them" (with "them" refeITing to members of the incoming Administration).1044 Prince opened the attachments at Tnnnp Tower within an hour of receiving them.¹⁰⁴⁵¹⁰⁴⁵ Prince 5/3/ 18 302, at 1-3. Prince stated that, while he was at Trnmp Tower that day, he spoke with Kellyanne Conway, Wilbur Ross, Steve Mnuchin, and others while waiting to see Bannon.¹⁰⁴⁶¹⁰⁴⁶ Prince 5/3/ 18 302, at 2-3. Cell-site location data for Prince's mobile phone indicates that Prince remained at Trnmp Tower for approximately three hours. 1047 Prince said that he could not recall whether, durin those three hours he met with Bannon and discussed Dmitriev with him.1048

¶Prince booked a ticket to the Seychelles on Januaiy 7, 2017.¹⁰⁵⁰¹⁰⁵⁰ 1/5/ 17 Email, Kasbo to Prince. The following day, Nader wrote to Dmitriev that he had a "pleasant smprise" for him, namely that he had aITanged for Dmitriev to meet "a Special Guest" from "the New Team," refeITing to Prince. 1051 Nader asked Dmitriev if he could come to the Seychelles for the meeting on Janua1y 12, 2017, an d Dmiti·iev agreed. 1052

¶The following day,~ surance from Nader that the Seychelles meeting would be woii hwhile.¹⁰⁵³¹⁰⁵³ 1/9/ 17 Text Message, Dmitriev to Nader.

¶~ Dmitriev was not enthusiastic about the idea of meeting with Prince, and that Nader assured him that Prince wielded influence with the incoming

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¶Administration .1054 Nader wrote to Dmitriev, "This guy [Prince] is designated by Steve [Bannon] to meet you! I know him and he is ve1y ve1y well connected and tm sted by the New Team. His sister is now a Minister of Education." 1055 According to Nader, Prince had led him to believe that Bannon was aware of Prince's upcoming meeting with Dmitriev, and Prince acknowledged that it was fair for Nader to think that Prince would pass info1mation on to the Transition Team.¹⁰⁵⁶¹⁰⁵⁶ Nader 1/ 19/ 18 302, at 13; [Redacted: (b) (3)] Prince 5/3/ 18 302, at 3. Bannon, however, told the Office that Prince did not tell him in advance about his meeting with Dmitriev.1057

The Seychelles Meetings

¶Dmitriev aiTived with his wife in the Seychelles on Januaiy 11, 2017, and checked into the Four Seasons Reso1i where Crown Prince Mohammed and Nader were staying.¹⁰⁵⁸¹⁰⁵⁸ 1/ 10/ 17 Text Messages, Dmitriev & Nader (2:05:54 - 3:30:25 p.m.); 1/ 11/ 17 Text Messages, Dmitriev & Nader (2 :1 6:16 - 5:17:59 p.m.). Prince aiTived that sam e day.1059 Prince and Dmitriev met for the first time that afternoon in Nader's villa, with Nader present.¹⁰⁶⁰¹⁰⁶⁰ 1/ 11/ 17 Text Messages, Nader & Dmitiiev (5 :1 8:24 - 5:37:14 p.m.); [Redacted: (b) (3)] The initial meeting lasted approximately 30-45 minutes. 1061

¶Prince described the eight years o t e O ama A 1strab on m negative tenns, an state that he was looking fo1ward to a new era of cooperation and conflict resolution .1063 According to Prince, he told Dmitriev that Bannon was effective if not conventional, and that Prince provided policy papers to Bannon .1064

[Redacted: (b) (3)] llill[Redacted: (b) (3)]

¶1054 [Redacted: (b) (3)] topic of Russian interference in the 2016 election did not come up.

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¶Prince added that he would info1m Bannon about his meeting with Dmitriev, and that ifthere was interest in continuin the discussion Bannon or someone else on the Transition Team would do

¶Afte1wards, Prince returned to his room, where he learned that a Russian aircraft caiTier had sailed to Libya, which led him to call Nader and ask him to set up another meeting with Dmitriev.¹⁰⁷³¹⁰⁷³ Prince 4/4/18 302, at 10; Prince 5/3/ 18 302, at 4; [Redacted: (b) (3)] According to Nader, Prince called and said he had checked with his associates back home and needed to convey to Dmitriev that Libya was "off the table." 1074 Nader wrote to Dmitriev that Prince had "received an urgent message that he needs to convey to you immediately," and aiTanged for himself, Dmitriev, and Prince to meet at a restaurant on the Four Seasons propei1y_101s

¶At the second meeting, Prince told Dmitriev that the United States could not acce t an Russian involvement in Lib a because it would make the situation there much worse. 1076

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[Redacted: (b) (3)] — 1077

¶After the brief second meeting concluded, Nader and Dmiti·iev discussed what had ti·anspired.¹⁰⁷⁸¹⁰⁷⁸ Nader 1/22/ 18 302, at 15; [Redacted: (b) (3)] -· Dmiti·iev told Nader that he was disappointed in his meetings with Prince for two reasons: first, he believed the Russians needed to be communicating with someone who had more authority within the incoming Adminisu-ation than Prince had.¹⁰⁷⁹¹⁰⁷⁹ Nader 1/22/ 18 302, at 9, 15; [Redacted: (b) (3)] Second, he had hoped to have a discussion of greater substance, such as outlinin a sti·ate ic roadmap for both counti·ies to follow.¹⁰⁸⁰¹⁰⁸⁰ Nader 1/22/18 302, at 15. 1081 [Redacted: (b) (3)] Nader 1/22/ 18 302, at 15. Dmiu-iev told Nader that Prince's comments

¶[Q>lij•

¶Hours after the second meeting, Prince sent two text messages to Bannon from the Seychelles.¹⁰⁸²¹⁰⁸² Call Records of Erik Prince [Redacted: (b) (3)] As described further below, investigators were unable to obtain the content of these or other messages between Prince and Bannon, and the investigation also did not identify evidence of any further communication between Prince and Dmiu-iev after their meetings in the Seychelles.

Erik Prince's Meeting with Steve Bannon after the Seychelles Trip

¶After the Seychelles meetings, Prince told Nader that he would infonn Bannon about his discussion with Dmiu-iev and would convey that someone within the Russian power stru cture was interested in seeking better relations with the incoming Administi·ation. 1083 On Januaiy 12, 2017, Prince contacted Bannon 's personal assistant to set up a meeting for the following week.¹⁰⁸⁴¹⁰⁸⁴ 1/ 12/ 17 Text Messages, Prince to Preate. Several days later, Prince messaged her again asking about Bannon 's schedule.¹⁰⁸⁵¹⁰⁸⁵ 1/ 15/ 17 Text Message, Prince to Pt·eate.

¶Prince said that he met Bannon at Bannon 's home after returning to the United States in mid-Januaiy and briefed him about several topics, including his meeting with Drniti·iev. 1086 Prince told the Office that he explained to Bannon that Dmiti·iev was the head of a Russian sovereign wealth fund and was interested in improving relations between the United States and Russia.¹⁰⁸⁷¹⁰⁸⁷ Pt·ince 4/4/ 18 302, at 11; Prince 5/3/ 18 302, at 5. Prince had on his cellphone a screenshot of Dmiu-iev' s Wikipedia page dated Janua1y 16, 2017, and Prince told the Office that he likely showed that image to Bannon.¹⁰⁸⁸¹⁰⁸⁸ Prince 5/3/18 302, at 5; 1/16/17 Image on Prince Phone (on file with the Office). Prince also believed he provided Bannon with Dmitriev's contact information.¹⁰⁸⁹¹⁰⁸⁹ Prince 5/3/18 302, at 5. According to Prince, Bannon instructed Prince not to follow up with Dmitriev, and Prince had the impression that the issue was not a priority for Bannon.¹⁰⁹⁰¹⁰⁹⁰ Prince 5/3/18 302, at 5. Prince related that Bannon did not appear angry, just relatively uninterested.¹⁰⁹¹¹⁰⁹¹ Prince 5/3/18 302, at 5.

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¶Bannon, by contrast, told the Office that he never discussed with Prince anything regarding Dmitriev, RDIF, or any meetings with Russian individuals or people associated with Putin.¹⁰⁹²¹⁰⁹² Bannon 10/26/18 302, at 10-11. Bannon also stated that had Prince mentioned such a meeting, Bannon would have remembered it, and Bannon would have objected to such a meeting having taken place.¹⁰⁹³¹⁰⁹³ Bannon 10/26/18 302, at 10-11.

¶The conflicting accounts provided by Bannon and Prince could not be independently clarified by reviewing their communications, because neither one was able to produce any of the messages they exchanged in the time period surrounding the Seychelles meeting. Prince's phone contained no text messages prior to March 2017, though provider records indicate that he and Bannon exchanged dozens of messages.¹⁰⁹⁴¹⁰⁹⁴ Call Records of Erik Prince [Redacted: (b) (3)] Prince denied deleting any messages but claimed he did not know why there were no messages on his device before March 2017.¹⁰⁹⁵¹⁰⁹⁵ Prince 4/4/18 302, at 6. Bannon's devices similarly contained no messages in the relevant time period, and Bannon also stated he did not know why messages did not appear on his device.¹⁰⁹⁶¹⁰⁹⁶ Bannon 10/26/18 302, at 11; Bannon 2/14/18 302, at 36. Bannon told the Office that, during both the months before and after the Seychelles meeting, he regularly used his personal Blackberry and personal email for work-related communications (including those with Prince), and he took no steps to preserve these work communications.¹⁰⁹⁷¹⁰⁹⁷ Bannon 10/26/18 302, at 11.

Kirill Dmitriev's Post-Election Contact with Rick Gerson Regarding U.S.-Russia Relations

¶Dmitriev's contacts during the transition period were not limited to those facilitated by Nader. In approximately late November 2016, the UAE national security advisor introduced Dmitriev to Rick Gerson, a friend of Jared Kushner who runs a hedge fund in New York.¹⁰⁹⁸¹⁰⁹⁸ Gerson 6/5/18 302, at 1, 3; 11/26/16 Text Message, Dmitriev to Gerson; 1/25/17 Text Message, Dmitriev to Nader. Gerson stated he had no formal role in the transition and had no involvement in the Trump Campaign other than occasional casual discussions about the Campaign with Kushner.¹⁰⁹⁹¹⁰⁹⁹ Gerson 6/5/18 302, at 1. After the election, Gerson assisted the transition by arranging meetings for transition officials with former UK prime minister Tony Blair and a UAE delegation led by Crown Prince Mohammed.¹¹⁰⁰¹¹⁰⁰ Gerson 6/5/18 302, at 1-2; Kushner 4/11/18 302, at 21.

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¶When Dmitriev and Gerson met, they principally discussed potential joint ventures between Gerson's hedge fund and RDIF.¹¹⁰¹¹¹⁰¹ Gerson 6/5/18 302, at 3-4; see, e.g., 12/2/16 Text Messages, Dmitriev & Gerson; 12/14/16 Text Messages, Dmitriev & Gerson; 1/3/17 Text Message, Gerson to Dmitriev; 12/2/16 Email, Tolokonnikov to Gerson. Dmitriev was interested in improved economic cooperation between the United States and Russia and asked Gerson who he should meet with in the incoming Administration who would be helpful towards this goal.¹¹⁰²¹¹⁰² Gerson 6/5/18 302, at 3; 12/14/16 Text Message, Dmitriev to Gerson. Gerson replied that he would try to figure out the best way to arrange appropriate introductions, but noted that confidentiality would be required because of the sensitivity of holding such meetings before the new Administration took power, and before Cabinet nominees had been confirmed by the Senate.¹¹⁰³¹¹⁰³ 12/14/16 Text Message, Gerson to Dmitriev. Gerson said he would ask Kushner and Michael Flynn who the "key person or people" were on the topics of reconciliation with Russia, joint security concerns, and economic matters.¹¹⁰⁴¹¹⁰⁴ 12/14/16 Text Message, Gerson to Dmitriev.

¶Dmitriev told Gerson that he had been tasked by Putin to develop and execute a reconciliation plan between the United States and Russia. He noted in a text message to Gerson that if Russia was "approached with respect and willingness to understand our position, we can have Major Breakthroughs quickly."¹¹⁰⁵¹¹⁰⁵ 12/14/16 Text Messages, Dmitriev & Gerson; Gerson 6/15/18 302, at 1. Gerson and Dmitriev exchanged ideas in December 2016 about what such a reconciliation plan would include.¹¹⁰⁶¹¹⁰⁶ 12/14/16 Text Messages, Dmitriev & Gerson. Gerson told the Office that the Transition Team had not asked him to engage in these discussions with Dmitriev, and that he did so on his own initiative and as a private citizen.¹¹⁰⁷¹¹⁰⁷ Gerson 6/15/18 302, at 1.

¶On January 9, 2017, the same day he asked Nader whether meeting Prince would be worthwhile, Dmitriev sent his biography to Gerson and asked him if he could "share it with Jared (or somebody else very senior in the team) – so that they know that we are focused from our side on improving the relationship and my boss asked me to play a key role in that."¹¹⁰⁸¹¹⁰⁸ 1/9/17 Text Messages, Dmitriev to Gerson; 1/9/17 Text Message, Dmitriev to Nader. Dmitriev also asked Gerson if he knew Prince, and if Prince was somebody important or worth spending time with.¹¹⁰⁹¹¹⁰⁹ Gerson 6/5/18 302, at 4. After his trip to the Seychelles, Dmitriev told Gerson that Bannon had asked Prince to meet with Dmitriev and that the two had had a positive meeting.¹¹¹⁰¹¹¹⁰ 1/18/17 Text Messages, Dmitriev & Gerson.

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¶On January 16, 2017, Dmitriev consolidated the ideas for U.S.-Russia reconciliation that he and Gerson had been discussing into a two-page document that listed five main points: (1) jointly fighting terrorism; (2) jointly engaging in anti-weapons of mass destruction efforts; (3) developing "win-win" economic and investment initiatives; (4) maintaining an honest, open, and continual dialogue regarding issues of disagreement; and (5) ensuring proper communication and trust by "key people" from each country.¹¹¹¹¹¹¹¹ 1/16/17 Text Messages, Dmitriev & Gerson. On January 18, 2017, Gerson gave a copy of the document to Kushner.¹¹¹²¹¹¹² Gerson 6/5/18 302, at 3; Gerson 6/15/18 302, at 2. Kushner had not heard of Dmitriev at that time.¹¹¹³¹¹¹³ Gerson 6/5/18 302, at 3. Gerson explained that Dmitriev was the head of RDIF, and Gerson may have alluded to Dmitriev's being well connected.¹¹¹⁴¹¹¹⁴ Gerson 6/5/18 302, at 3; Gerson 6/15/18 302, at 1-2; Kushner 4/11/18 302, at 22. Kushner placed the document in a file and said he would get it to the right people.¹¹¹⁵¹¹¹⁵ Gerson 6/5/18 302, at 3. Kushner ultimately gave one copy of the document to Bannon and another to Rex Tillerson; according to Kushner, neither of them followed up with Kushner about it.¹¹¹⁶¹¹¹⁶ Kushner 4/11/18 302, at 32. On January 19, 2017, Dmitriev sent Nader a copy of the two-page document, telling him that this was "a view from our side that I discussed in my meeting on the islands and with you and with our friends. Please share with them – we believe this is a good foundation to start from."¹¹¹⁷¹¹¹⁷ 1/19/17 Text Message, Dmitriev to Nader (11:11:56 a.m.).

¶Gerson informed Dmitriev that he had given the document to Kushner soon after delivering

¶1118 it. On January 26, 2017, Dmitriev wrote to Gerson that his "boss"—an apparent reference to Putin—was asking if there had been any feedback on the proposal.¹¹¹⁹¹¹¹⁹ 1/26/17 Text Message, Dmitriev to Gerson. Dmitriev said, "[w]e do not want to rush things and move at a comfortable speed. At the same time, my boss asked me to try to have the key US meetings in the next two weeks if possible."¹¹²⁰¹¹²⁰ 1/26/17 Text Message, Dmitriev to Gerson. He informed Gerson that Putin and President Trump would speak by phone that Saturday, and noted that that information was "very confidential."¹¹²¹¹¹²¹ 1/26/17 Text Message, Dmitriev to Gerson.

¶The same day, Dmitriev wrote to Nader that he had seen his "boss" again yesterday who had "emphasized that this is a great priority for us and that we need to build this communication channel to avoid bureaucracy."¹¹²²¹¹²² 1/26/17 Text Message, Dmitriev to Nader (10:04:41 p.m.). On January 28, 2017, Dmitriev texted Nader that he wanted "to see if I can confirm to my boss that your friends may use some of the ideas from the 2 pager I sent you in the telephone call that will happen at 12 EST,"¹¹²³¹¹²³ 1/28/17 Text Message, Dmitriev to Nader (11:05:39 a.m.). an apparent reference to the call scheduled between President Trump and Putin. Nader replied, "Definitely paper was so submitted to Team by Rick and me. They took it seriously!"¹¹²⁴¹¹²⁴ 1/28/17 Text Message, Nader to Dmitriev (11:11:33 a.m.). After the call between President Trump and Putin occurred, Dmitriev wrote to Nader that "the call went very well. My boss wants me to continue making some public statements that us [sic] Russia cooperation is good and important."¹¹²⁵¹¹²⁵ 1/29/17 Text Message, Dmitriev to Nader (11:06:35 a.m.). Gerson also wrote to Dmitriev to say that the call had gone well, and Dmitriev replied that the document they had drafted together "played an important role."¹¹²⁶¹¹²⁶ 1/28/17 Text Message, Gerson to Dmitriev; 1/29/17 Text Message, Dmitriev to Gerson.

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¶Gerson and Dmitriev appeared to stop communicating with one another in approximately March 2017, when the investment deal they had been working on together showed no signs of progressing.¹¹²⁷¹¹²⁷ Gerson 6/15/18 302, at 4; 3/21/17 Text Message, Gerson to Dmitriev.