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Harm to Ongoing Matter Conduct involving Michael Cohen.

The President’s conduct towards Michael Cohen, a former Trump Organization executive, changed from praise

castigation of Cohen when he became a cooperating witness.

In 2017, Cohen provided false testimony to Congress about the project, including stating that he had

personal counsel, who, according to Cohen, said that Cohen should “stay on message” and not contradict

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Michael Cohen, 1:18-cr-850 (S.D.N.Y. Dec. 7, 2018), Doc. 14.

Michael Cohen, 1:18—‘cr-850 (S.D.N.Y.

at 1-4; Cohen 8/7/18 302, at 15. 9” Cohen 9/12/18 302, at :2, 4. 9'3 Cohen 9/12/18 302, at 4. g 9”

Expert Investment Company); Cohen 9/12/18 302, at 3; Written Responses of Donald J.

). 917 Cohen 9/12/18 302, at 5. 135

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). 9‘9 1/20/16 Email, Poliakova to Cohen; Call Records of Michael Cohen.

list. 1/20/16 Cohen Microsoft Outlook Entry (6:22 a.m.). 92" Cohen 11/20/18 302, at 5. 92' Cohen 11

/20/18 302, at 5—6; Cohen 11/12/18 302, at 4. 9” Cohen 11/20/18 302, at 5. 923 Cohen 9/12/18 302, at

Sater to Cohen (attachment). ”6 Cohen 1 1/20/18 302, at 5. 927 Cohen 9/ 12/ 1 8 302, at 6.

Transcripts, at 24) (testimony of Michael Cohen). 928 Cohen 9/ 12/ 1 8 302, at 6. 9” Cohen 9/18/18 302

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relayed that 969 P-SCO-00009478 (Statement of Michael D.

Cohen, Esq. (Aug. 28, 2017)). 97° P~SCO-00009478 (Statement of Michael D. Cohen, Esq.

Transcripts, at 24-25) (testimony by Michael Cohen).

P-SCO—0000003687 (8/16/17 Drafi Statement of Michael Cohen); Cohen 11/20/18 302, at 4. 9'73 Cohen 11

See P-SCO-0000009478 (Statement of Michael D. Cohen, Esq.

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to SSCI). 999 Cohen 11/12/18 302, at 2; Cohen 9/12/18 302, at 9. 1000 Cohen 9/12/18 302, at 9. 1001

Cohen 9/18/18 302, at 7; see, 8. g. , READ: Michael Cohen ’3 statement to the Senate intelligence committee

Call Records of Michael Cohen.

House of Representatives, Interview of Michael Cohen (Oct. 24, 2017), at 10-11, 117419. 1006 Call Records

of Michael Cohen.

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and describing Cohen as the President’s “fixer,” Cohen received a text message from the President’s personal

It’s an attack on what we all “’07 See, e.g., Michael Rothfeld & Joe Palazzolo, Trump Lawyer Arranged

Transcripts, at 147—148) (testimony of Michael Cohen).

Call Records of Michael Cohen. 10“ 2/ 19/ 1 8 Text Message, President’s personal counsel to Cohen; see

the New York field office of the Federal Bureau of Investigation . . . executed search warrants for Michael

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York Times and a third rate reporter . . . are going out of their way to destroy Michael Cohen and his

They use non- existent ‘sources’ and a drunk/drugged up loser who hates Michael, 31 fine person with a

Michael is a businessman for his own account/lawyer who I have always liked 8:: respected.

, at 11. ””9 Cohen 9/12/18 302,, at 11. mo Cohen 9/12/18 302, at 11. ”’2' Cohen 9/12/18 302, at 11.

"’24 See Maggie Haberman et al., Michael Cohen Has Said He Would Take a Bullet for Trump.

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April 24, 2018, the President responded to a reporter’s inquiry whether he would consider a pardon for Cohen

reported based on an “exclusive” interview with Cohen that Cohen “strongly signaled his willingness to

103” Remarks by President Trump in Press Gaggle, The White House (June 15, 2018). 1038 EXCLUSIVE: Michael

have my first loyalty.” ”39 See e.g., Darren Samuelsohn, Michael Cohen hires Clinton scandal veteran

Lanny Davis, Politico (July 5, 2018). 104° See, e. g, Matt Apuzzo et a1., Michael Cohen Secretly Taped

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05'3 The President also said that Cohen was “a weak person.

regarding the Trump Tower Moscow project: “So here’s the story: Go back and look at the paper that Michael

Cohen wrote before he testified in the House and/or Senate.

Michael Cohen, l:18-cr-850 (S.D.N.Y.

P-SCO-000009477 (Statement of Michael D. Cohen, Esq.

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On December 3, 2018, after Cohen had filed his sentencing memorandum, the President tweeted, “Michael

Cohen asks judge for no Prison Time.’

Cohen to break the law. . . .

As a lawyer, Michael has great liability to me!

W53 On December 16, 2018, the President tweeted, “Remember, Michael Cohen only became a ‘Rat’ after