Changes

On Tuesday January 10, 2017, [[CNN]] stated President-elect Trump was briefed on the ''[[Clinton-Steele dossier]]''.  An hour later Buzzfeed published the dossier and CNN linked to it.<ref><small>4. One of the seventeen reports in the Dossier—CIR 112—accused the Plaintiffs of criminal conduct and participation in an alleged [[Trump-Russia]] scheme to influence the [[2016 presidential election]]. Defendants knew that this Report was not verified, and that it defamed Plaintiffs on its face. Defendants could easily have removed that Report from the Dossier before they started peddling the Dossier to media and journalists in September and October 2016. They chose not to do so. Nor did they attempt to determine the veracity of that Report with the Plaintiffs themselves.

On Tuesday January 10, 2017, [[CNN]] stated President-elect Trump was briefed on the ''[[Clinton-Steele dossier]]''.  An hour later Buzzfeed published the dossier and CNN linked to it.<ref><small>4. One of the seventeen reports in the Dossier—CIR 112—accused the Plaintiffs of criminal conduct and participation in an alleged [[Trump-Russia]] scheme to influence the [[2016 presidential election]]. Defendants knew that this Report was not verified, and that it defamed Plaintiffs on its face. Defendants could easily have removed that Report from the Dossier before they started peddling the Dossier to media and journalists in September and October 2016. They chose not to do so. Nor did they attempt to determine the veracity of that Report with the Plaintiffs themselves.

5. At all times during the Defendants’ engagement of Orbis and [[Christopher Steele|Steele]], it was either intended or clearly foreseeable that the Dossier’s contents would be republished (in whole or in part) to third parties, either by the Defendants themselves or their clients. Indeed, that is the entire purpose of “oppo research” in politics. Those third parties included government officials, as well as news media and journalists who could make its content public.

5. At all times during the Defendants’ engagement of Orbis and [[Christopher Steele|Steele]], it was either intended or clearly foreseeable that the Dossier’s contents would be republished (in whole or in part) to third parties, either by the Defendants themselves or their clients. Indeed, that is the entire purpose of “oppo research” in politics. Those third parties included government officials, as well as news media and journalists who could make its content public.

6. On information and belief, Defendants arranged for Steele to brief selected members of the print and online media about the information he was compiling on candidate Trump. Consistent with the intended purpose of “oppo research” to publicly discredit its target, Steele’s briefings were designed to generate interest in the Dossier and secure its eventual public dissemination. Briefings were held for journalists from the New York Times, the Washington Post, CNN, Yahoo News, and others in September 2016. Shortly thereafter, Yahoo News published an article by Michael Isikoff that described some of the content of the Dossier (referred to there as “intelligence reports” and “reports”), which was still being compiled at that time.1

6. On information and belief, Defendants arranged for Steele to brief selected members of the print and online media about the information he was compiling on candidate Trump. Consistent with the intended purpose of “oppo research” to publicly discredit its target, Steele’s briefings were designed to generate interest in the Dossier and secure its eventual public dissemination. Briefings were held for journalists from the New York Times, the [[Washington Post]], CNN, [[Yahoo News]], and others in September 2016. Shortly thereafter, Yahoo News published an article by Michael Isikoff that described some of the content of the Dossier (referred to there as “intelligence reports” and “reports”), which was still being compiled at that time.1

Many other media articles reported speculative accounts of the Dossier’s existence and contents. In October 2016, Steele was interviewed by David Corn, a writer for Mother Jones, which on October 31, 2016 published an article headlined “A Veteran Spy Has Given The FBI Information Alleging a Russian Operation to Cultivate Donald Trump.”2

Many other media articles reported speculative accounts of the Dossier’s existence and contents. In October 2016, Steele was interviewed by [[David Corn]], a writer for [[Mother Jones]], which on October 31, 2016 published an article headlined “A Veteran Spy Has Given The FBI Information Alleging a Russian Operation to Cultivate Donald Trump.”2

The Corn article stated that it had “reviewed” the early reports in the Dossier, and then quoted from those reports as well as statements made by Steele in the interview. The public dissemination of the Dossier’s content had begun in earnest.

The Corn article stated that it had “reviewed” the early reports in the Dossier, and then quoted from those reports as well as statements made by Steele in the interview. The public dissemination of the Dossier’s content had begun in earnest.

7. In addition to cultivating media interest, the Defendants also organized or approved a meeting in Great Britain between Steele and David Kramer, a director of a private foundation led by U.S. Senator [[John McCain]]. The purpose of that meeting was to brief Kramer on behalf of Senator McCain, who at the time was an outspoken critic of Trump’s candidacy. Subsequently, in November 2016, Defendants provided a copy of the Dossier’s first sixteen reports, including the Report that falsely accused and defamed Plaintiffs, to Kramer for redelivery to Senator McCain.

7. In addition to cultivating media interest, the Defendants also organized or approved a meeting in Great Britain between Steele and David Kramer, a director of a private foundation led by U.S. Senator [[John McCain]]. The purpose of that meeting was to brief Kramer on behalf of Senator McCain, who at the time was an outspoken critic of Trump’s candidacy. Subsequently, in November 2016, Defendants provided a copy of the Dossier’s first sixteen reports, including the Report that falsely accused and defamed Plaintiffs, to Kramer for redelivery to Senator McCain.