Trump v. Clinton (2:22-cv-14102)
Date Filed: March 24, 2022
Date of Last Known Filing: June 27, 2022
Cause: 18:1962 Racketeering (RICO) Act
Nature of Suit: 470 Racketeer/Corrupt Organization
Jury Demand: Plaintiff
Jurisdiction Type: Federal Question
ANDREW MCCABE
BRUCE OHR
CHRISTOPHER STEELE
DEBBIE WASSERMAN SCHULTZ
DEMOCRATIC NATIONAL COMMITTEE
DNC SERVICES CORPORATION
FUSION GPS
GLENN SIMPSON
HFACC, INC.
HILLARY R CLINTON
IGOR DANCHENKO
JAKE SULLIVAN
JAMES COMEY
JOHN DOES 1 THROUGH 10
JOHN PODESTA
Jr. CHARLES HALLIDAY DOLAN
KEVIN CLINESMITH
LISA PAGE
MARK ELIAS
MICHAEL SUSSMANN
NELLIE OHR
NEUSTAR, INC
ORBIS BUSINESS INTELLIGANCE, LTD
PERKINS COIE, LLC
PETER FRITSCH
PETER STRZOK
PHILLIPE REINES
ROBERT E MOOK
RODNEY JOFFE
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COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY
The Plaintiff, Donald J. Trump, by and through his undersigned counsel, hereby serves his
suit against the Defendants, 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,
1
Case 2:22-cv-14102-DMM Document 1 Entered on FLSD Docket 03/24/2022 Page 2 of 108
Phillipe Reines, Fusion GPS, Glenn Simpson, Peter Fritsch, Nellie Ohr, Bruce Ohr, Orbis Business
Intelligence, 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 fictious and unknown persons), and ABC Corporations 1 through 10 (said names being
fictitious and unknown entities) and alleges as follows:
Introduction
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
1
U.S. Dep’t of Justice, Office of the Inspector General, Review of Four FISA Applications and Other Aspects of the
FBI’s Crossfire Hurricane Investigation at 96 (2019) (hereinafter “IG Report”).
2
Case 2:22-cv-14102-DMM Document 1 Entered on FLSD Docket 03/24/2022 Page 3 of 108
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
bank.
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.
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Here for FULL complaint and summons':
https://www.courtlistener.com/docket/63184300/trump-v-clinton/
