1. Among other things, Neustar, Joffe and their associates, at the direction of Clinton, the Clinton Campaign and the DNC, exploited access to non-public and proprietary internet data, including without limitation, domain name system (DNS) internet traffic, of:

(i) a healthcare provider;

(ii) Trump Tower;

(iii) Donald Trump’s private apartment in Central Park West, and

(iv) the Executive Office of the President of the United States (EOP).38

k. In doing so, Joffe and Neustar intentionally accessed, without authorization or in excess of any authorization, the computers, servers, and/or other sensitive data sources at the above-stated facilities.

l. Furthermore, Joffe and Neustar stole trade secrets, in the form of proprietary, sensitive and confidential data, information, and knowledge, from the above-stated facilities.

[page 29]

1. Comey utilized the Steele Dossier as purported evidence to sign FISA documents to conduct surveillance on Carter Page, when he knew that the Dossier was discredited, and failed to advise the FISA court.

1. Comey failed to tell the FISA court that the Dossier was reportedly funded by the Clinton Campaign and the DNC and compiled by Fusion GPS.

1. Comey failed to tell the FISA court that the Dossier he relied upon to request a warrant to monitor Carter Page was a product of the Fusion GPS

1. Comey relied on the Dossier to monitor Carter Page, even though months later he called the information in the Dossier salacious and unverified.

1. Comey relied on the Dossier, even though the FBI determined the document was only minimally corroborated.

[page 37]

1. In March of 2019, shortly after the Muller Report determined there was no evidence of collusion, Reines went on Fox News and continued to accuse Donald J. Trump falsely.

1. Reines debated with Mollie Hemmingway who told Reines that the conspiracy was over and Reines responded: "You saying it on FOX doesn't make it so. He's under investigation be 17 other entities including the Southern District of New York."

1. Starting in or around 2019, two additional probes were launched to investigate the origins of the FBI's Crossfire Hurricane.

1. In a report dated December 9, 2019, the IG identified "at least 17 significant errors or omissions in the Carter Page FISA applications, and many additional errors in the Woods Procedure."

[page 53]

kek