President Trump has entered into a lawsuit against….well….everybody involved in the Russian collusion hoax under the RICO Act. They include:
Hillary R. Clinton, HFACC, Inc., the Democratic National Committee, DNC Services Corporation, Perkins Coie, LLC, Michael Sussmann, Marc Elias, Debbie
Wasserman Schultz, Charles Halliday Dolan, Jr., Jake Sullivan, John Podesta, Robert E. Mook, Phillipe Reines, Fusion GPS, Glenn Simpson, Peter Fritsch, Nellie Ohr, Bruce Ohr, Orbis BusinessIntelligence, Ltd., Christopher Steele, Igor Danchenko, Neustar, Inc., Rodney Joffe, James Comey,
Peter Strzok, Lisa Page, Kevin Clinesmith, Andrew McCabe, John Does 1 through 10 (said names
being fictitious and unknown persons), and ABC Corporations 1 through 10.
1. In the run-up to the 2016 Presidential Election, Hillary Clinton and her cohorts
orchestrated an unthinkable plot – one that shocks the conscience and is an affront to this nation’s
democracy. Acting in concert, the Defendants maliciously conspired to weave a false narrative
that their Republican opponent, Donald J. Trump, was colluding with a hostile foreign sovereignty.
The actions taken in furtherance of their scheme—falsifying evidence, deceiving law enforcement,
and exploiting access to highly-sensitive data sources – are so outrageous, subversive and
incendiary that even the events of Watergate pale in comparison.
2. Under the guise of ‘opposition research,’ ‘data analytics,’ and other political
stratagems, the Defendants nefariously sought to sway the public’s trust. They worked together
with a single, self-serving purpose: to vilify Donald J. Trump. Indeed, their far-reaching
conspiracy was designed to cripple Trump’s bid for presidency by fabricating a scandal that would
be used to trigger an unfounded federal investigation and ignite a media frenzy.
3. The scheme was conceived, coordinated and carried out by top-level officials at the
Clinton Campaign and the DNC—including ‘the candidate’ herself—who attempted to shield her
involvement behind a wall of third parties.1 To start, the Clinton Campaign and the DNC enlisted
the assistance of their shared counsel, Perkins Coie, a law firm with deep Democrat ties, in the hopes of obscuring their actions under the veil of attorney-client privilege. Perkins Coie was
tasked with spearheading the scheme to find—or fabricate—proof of a sinister link between
Donald J. Trump and Russia. To do so, Perkins Coie launched parallel operations: on one front,
Perkins Coie partner Marc Elias led an effort to produce spurious ‘opposition research’ claiming
to reveal illicit ties between the Trump Campaign and Russian operatives; on a separate front,
Perkins Coie partner Michael Sussmann headed a campaign to develop misleading evidence of a
bogus ‘back channel’ connection between e-mail servers at Trump Tower and a Russian-owned
4. Marc Elias, in his mission to obtain derogatory anti-Trump ‘opposition research,’
commissioned Fusion GPS, an investigative firm, and its co-founders, Peter Fritsch and Glenn
Simpson, and directed them to dredge up evidence—actual or otherwise—of collusion between
Trump and Russia. Fritsch and Simpson, in turn, enlisted the assistance of Orbis Ltd. and its
owner, Christopher Steele, to produce a series of reports purporting to contain proof of the
supposed collusion. Of course, the now fully debunked collection of reports, known as the “Steele
Dossier,” was riddled with misstatements, misrepresentations and, most of all, flat out lies. In
truth, the Steele Dossier was largely based upon information provided to Steele by his primary
sub-source, Igor Danchenko, who was subsequently indicted for falsifying his claims. Even more damning, Danchenko had close ties to senior Clinton Campaign official, Charles Halliday Dolan,
Jr., who knowingly provided false information to Danchenko, who relayed it to Steele, who
reported it in the Steele Dossier and eagerly fed the deceptions to both the media and the FBI. This
duplicitous arrangement existed for a singular self-serving purpose – to discredit Donald J. Trump
and his campaign.
5. At the same time, Michael Sussmann, in his hunt for damaging intel against the
Trump Campaign, turned to Neustar, Inc., an information technology company, and one of its top
executives, Rodney Joffe, a fervent anti-Trumper who had recently been promised a high-ranking
position with the Clinton Administration, to exploit their access to non-public data in search of a
secret “back channel” connection between Trump Tower and Alfa Bank. When it was discovered
that no such channel existed, the Defendants resorted to truly subversive measures – hacking
servers at Trump Tower, Trump’s private apartment, and, most alarmingly, the White House. This
ill-gotten data was then manipulated to create a misleading “inference” and submitted to law
enforcement in an effort to falsely implicate Donald J. Trump and his campaign.2 All of these acts
were carried out in coordination with the Clinton Campaign and the DNC, at the behest of certain
6. While their multi-pronged attack was underway, the Defendants seized on the
opportunity to publicly malign Donald J. Trump by instigating a full-blown media frenzy. Indeed,
the Clinton Campaign and DNC—admittedly on a “mission” to “raise the alarm” about their
contrived Trump-Russia link4—repeatedly fed disinformation to the media and shamelessly
promoted their false narratives. All the while, Hillary Clinton, Jake Sullivan, Debbie Wasserman
Schultz, and others did their best to proliferate the spread of those dubious and false claims through
press releases, social media, and other public statements.
7. The fallout from the Defendants’ actions was not limited to the public denigration
of Trump and his campaign. The Federal Bureau of Investigation (FBI)—relying on the
Defendants’ fraudulent evidence—commenced a large-scale investigation and expended precious
time, resources and taxpayer dollars looking into the spurious allegation that the Trump Campaign
had colluded with the Russian Government to interfere in the 2016 presidential election. The
effects of this unfounded investigation were prolonged and exacerbated by the presence of a small
faction of Clinton loyalists who were well-positioned within the Department of Justice and the FBI
– James Comey, Andrew McCabe, Peter Strzok, Lisa Page, Kevin Clinesmith, and Bruce Ohr.
These government officials were willing to abuse their positions of public trust to advance the
baseless probe to new levels, including obtaining an extrajudicial FISA warrant and instigating the
commencement of an oversight investigation headed by Special Counsel Robert Mueller. As a
result, Donald J. Trump and his campaign were forced to expend tens of millions of dollars in legal
fees to defend against these contrived and unwarranted proceedings. Justice would ultimately
prevail – following a two-year investigation, Special Counsel Mueller went on to exonerate Donald
J. Trump and his campaign with his finding that there was no evidence of collusion with Russia.
8. The full extent of the Defendants’ wrongdoing has been steadily and gradually
exposed by Special Counsel John Durham, who has been heading a DOJ investigation into the
origins of the Trump-Russia conspiracy. To date, he has already issued indictments to Sussmann
and Danchenko, among others, for proffering false statements to law enforcement officials. As
outlined below, these ‘speaking’ indictments not only implicate many of the Defendants named
herein but also provide a great deal of insight into the inner-workings of the Defendants’
conspiratorial enterprise. Based on recent developments and the overall direction of Durham’s
investigation, it seems all but certain that additional indictments are forthcoming.
9. In short, the Defendants, blinded by political ambition, orchestrated a malicious
conspiracy to disseminate patently false and injurious information about Donald J. Trump and his
campaign, all in the hopes of destroying his life, his political career and rigging the 2016
Presidential Election in favor of Hillary Clinton. When their gambit failed, and Donald J. Trump
was elected, the Defendants’ efforts continued unabated, merely shifting their focus to
undermining his presidential administration. Worse still, the Defendants continue to spread their
vicious lies to this day as they unabashedly publicize their thoroughly debunked falsehoods in an
effort to ensure that he will never be elected again. The deception, malice, and treachery
perpetrated by the Defendants has caused significant harm to the American people, and to the
Plaintiff, Donald J. Trump, and they must be held accountable for their heinous acts.
(18 U.S.C. § 1962(C))
(Against Clinton, Clinton Campaign, DNC, Perkins Coie, Elias, and Sussmann)
312. The Plaintiff has been injured in his business and property as a direct and proximate
result of Defendants’ violation of 18 U.S.C. § 1962(c).
313. As a direct and proximate result of Defendants’ actions, the Plaintiff has suffered,
and continues to suffer, significant damages, including but not limited to, actual, compensatory,
special, incidental, and consequential damages in addition to costs of defense and attorneys’ fees.
314. Among other things, the Plaintiff was forced to incur expenses in an amount to be
determined at trial, but known to be in excess of twenty-four million dollars ($24,000,000) and
continuing to accrue, in the form of defense costs, legal fees, and related expenses incurred in
connection with his effort to defend against the Defendants’ actions and the various federal
investigations and/or official proceedings which arose therefrom, in addition to the loss of existing
and future business opportunities for himself, the Trump Campaign, and the Trump Organization LLC.
315. All of these injuries were sustained within, and were the result of conduct occurring
within the United States.
316. The Plaintiff is entitled to recover, pursuant to Title 18 United States Code
§ 1964(c), treble damages in the amount to be determined by offer of proof at time of trial. The
Plaintiff is also entitled to recover attorneys’ fees and costs of this litigation, as well as damages
arising from lost profits and/or lost business opportunities attributable to the activities engaged in
by defendants committed in furtherance of the Enterprise.
WHEREFORE, the Plaintiff, Donald J. Trump, respectfully requests that this Court enter
a Judgment for Donald J. Trump and against the Defendants, Hillary Clinton, HFACC, Inc., the
Democratic National Committee, Perkins Coie, LLP, Michael Sussmann, and Marc Elias for
damages, including Compensatory and Treble damages, costs, attorneys’ fees, and such further
and other relief as this honorable Court may deem just and proper.