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Case 1:18-cr-00850-WHP Document 15 Filed 12/07/18 Page 3 of 7

caucus and months before the very first primary.” By publicly presenting this false narrative, the defendant deliberately shifted the timeline of what had occurred in the hopes of limiting the investigations into possible Russian interference in the 2016 U.S. presidential election—an issue of heightened national interest.

The defendant’s false statements obscured the fact that the Moscow Project was a lucrative business opportunity that sought, and likely required, the assistance of the Russian government. If the project was completed, the Company could have received hundreds of millions of dollars from Russian sources in licensing fees and other revenues. The fact that Cohen continued to work on the project and discuss it with Individual 1 well into the campaign was material to the ongoing congressional and SCO investigations, particularly because it occurred at a time of sustained efforts by the Russian government to interfere with the U.S. presidential election. Similarly, it was material that Cohen, during the campaign, had a substantive telephone call about the project with an assistant to the press secretary for the President of Russia.

The defendant’s false statements to Congress began in approximately late August 2017, when he submitted his written statement about the Moscow Project to SSCI and HPSCI. His false statements continued through his oral testimony before the committees in October 2017. And when Cohen first met with the SCO in August 2018, he repeated many of his prior false statements about the circumstances of the Moscow Project.^[1] Only when the defendant met with the SCO a second time on September 12, 2018—after he had pled guilty in United States v. Cohen, 18-cr-602
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↑ This initial meeting with the SCO, on August 7, 2018, was set up at Cohen’s request. In that meeting, Cohen voluntarily provided information relevant to other aspects of the SCO’s ongoing investigation, but when asked questions about the Moscow Project, Cohen provided false answers in what he later explained was an effort not to contradict his congressional testimony.

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[1] This initial meeting with the SCO, on August 7, 2018, was set up at Cohen’s request. In that meeting, Cohen voluntarily provided information relevant to other aspects of the SCO’s ongoing investigation, but when asked questions about the Moscow Project, Cohen provided false answers in what he later explained was an effort not to contradict his congressional testimony.

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