Case 1:18-cr-00850-WHP Document 15 Filed 12/07/18 Page 2 of 7
ended before the Iowa caucus and the first presidential primaries, in hopes of limiting the ongoing Russia investigations being conducted by Congress and the SCO.
In recent months, however, the defendant has taken significant steps to mitigate his criminal conduct. He chose to accept responsibility for his false statements and admit to his conduct in open court. He also has gone to significant lengths to assist the Special Counsel’s investigation. He has met with the SCO on seven occasions, voluntarily provided the SCO with information about his own conduct and that of others on core topics under investigation by the SCO, and committed to continuing to assist the SCO’s investigation. The information he has provided has been credible and consistent with other evidence obtained in the SCO’s ongoing investigation.
Offense Conduct
The defendant’s offense conduct is set forth in the Information and the Presentence Investigation Report (PSR). We underscore particular facts for purposes of sentencing.
The defendant’s lies to Congress were deliberate and premeditated. His false statements did not spring spontaneously from a line of examination or heated colloquy during a congressional hearing. They started in a written submission that he chose to provide to both houses of Congress ahead of his appearances. These circumstances show a deliberate effort to use his lies as a way to set the tone and shape the course of the hearings in an effort to stymie the inquiries.
The defendant amplified his false statements by releasing and repeating his lies to the public, including to other potential witnesses. The defendant was scheduled to appear before both intelligence committees in closed sessions. Prior to testifying, the defendant made a public appearance at the U.S. Capitol and released his prepared opening statement, which falsely claimed that the Moscow Project “was terminated in January of 2016[,] which occurred before the Iowa
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