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“ Barbara Ledeen and Peter Smith were among the people contacted by Flynn.

Clinton emails before Flynn’s request, as early as December 2015 .268 On December 3, 2015, she emailed Smith

Smith forwarded the email to two colleagues and 25“ Flynn 4/25/18 302, at 5-6; Flynn 5/1/18 302, at

7-8. 267 Flynn 11/29/17 302, at 7. “ 2“ Szobocsan 3/29/17 302, at 1. 269 12/3/15 Email, Ledeen to Smith

. 27° 12/3/15 Email, Ledeen to Smith (attachment). 62

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wrote, “we can discuss to whom it should be referred.”271 On December 16, 2015, Smith informed Ledeen

3 On August 28, 2016, Smith sent an email from an encrypted account with the subject “Sec.

to Szobocsan & Safron. 272 Szobocsan 3/29/18 302, at 1. 273 8/31/16 Email, Smith to Smith. 2"“ 8/28

/16 Email, Smith to Smith. 275 Incorporation papers of KLS Research LLC, 7/26/17— Szobocsan 3/29/ 18

302, at 2. 276 Szobocsan 3/29/18 302, at 3. 277 Financial Institution Record of Peter Smith and KLS

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Department of Justice and Kellyanne Conway.2280 The investigation established that Smith communicated

In September 2016, Smith and Ledeen got back in touch with each other about their respective efforts.

Clinton.” 28‘ Flynn 1 1/29/17 302, at 7-8; 10/15/16 Email, Smith to Flynn et al.; 8/28/16 Email, Smith

to Smith (bcc: Clovis et al.). 232 9/16/16 Email, Ledeen to Smith. 233 Prince 4/4/18 302, at 4-5.

See SM—2284941, serial 62. 285- 10/28/16 Email, Smith to Smith. 64

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Smith drafted multiple emails stating or intimating that he was in contact with Russian hackers.

For example, in one such email, Smith claimed that, in August 2016, KLS Research had organized meetings

Associates and security experts who worked with Smith on the initiative did not believe that Smith was

was in contact with Russian hackers or that Smith, Ledeen, or other individuals in touch with the Trump

Harm to Ongoing Matter 286 8/31/16 Email, Smith to Smith. 287 Safron 3/20/18 302, at 3 ; Szobocsan 3

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citizens.680 Veselnitskaya performed legal work for Denis Katsyvfsl the son of Russian businessman Peter

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(’28 Dearborn 6/20/18 302, at 3. 629 Dearborn 6/20/18 302, at 3-4. 63” Peter Baker et al., Excerpts

From The Times '3 Interview With Trump, New York Times (July 19, 2017). 631 Peter Baker et 31., Excerpts

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Special Counsel’s Office, at 18. 732 Remarks by President Trump in Press Gaggle (June 15, 2018). 734 Peter

Baker et al., Excerpts From The Times ’5 Interview With Trump, New York Times (July 19, 2017). 735 Peter

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, Hope Holt, Lester Hunt, Jody Ivanov, Igor Ivanov, Sergei Kasowitz, Marc Katsyv, Denis Katsyv, Peter

Son of Peter Katsyv; owner of Russian company Prevezon Holdings Ltd. and associate of Natalia Veselnitskaya

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Smith, Peter Spicer, Sean Stone, Roger Tillerson, Rex Timofeev, Ivan Trump, Donald Jr.

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Business established by an associate of and at the direction of Peter Smith to further Smith’s search