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Saturday, December 26, 2020
DoJ: Hawaii's Lum Crime Family Trades American Hostages in Trump's White House
By Andrew Walden @ 8:54 PM :: 14802 Views :: National News, Ethics, Hawaii History, Obama

The world according to Guo Wengui.

DoJ: Hawaii's Lum Crime Family Trades American Hostages in Trump's White House

by Andrew Walden

Hawaii’s Lum Crime Family is back in the news—allegedly channeling a Malaysian billionaire’s money to buy Chinese communist influence in Donald Trump’s White House via a top Trump fundraiser--convicted fraudster Elliott Broidy--who had been deputy finance chair of the Republican National Committee until his Playboy playmate payoffs were exposed by Qatari hackers. 

Hawaii Democratic Party operators from the 1980s, the Lums were so manini they couldn’t even get Charles Chidiac’sHawaiian Riviera Resort’ off the ground.  They didn’t merit a mention in Land and Power in Hawaii.  But in 1991 the Lums relocated to California, teamed up with Ron Brown and Charlie Trie, and soon put themselves at the center of the Clintons’ 1990s ‘Asian Money’ scandals, allegedly funneling money from Ng Lap Seng, a member of the Chinese communist government ‘People’s Political Consultative Conference,’ to the Clinton campaign.

Its enough to make you rethink the Hawaii brain drain.  If only there had been more opportunity in Hawaii this kind of talent might never have left home.  Ka’u: Was stopping Hawaiian Riviera worth all this? 

Ron Brown dies in plane crash, April 3, 1996 - POLITICO

Dubbed ‘American Guanxi’ by the New Yorker, Nora and Gene Lum and daughter Trisha Lum in 1997 pled guilty to charges that could have been a lot worse – but the investigation was cut short in 1996 when Brown—then Clinton’s Commerce Secretary--had an unfortunate encounter with Croatia.  

Perhaps Trisha’s unindicted sister, Nickie Mali Lum Shapira (now Davis), felt left out. 

(Nickie Lum, the in-between years: Two degrees of separation between Nickie Lum’s ex-husband and Hawaii Senators’ favorite hitman Blake Tek Yoon.  Plus photos of Nickie Lum with Congolese President Joseph Kabila, host to her new husband’sconflict-freeCongo-Rwanda rare earth mining scheme, AV8 Mining.  If you've got $7.25M burning a hole in your pocket, Nickie's house is now for sale.  Its on Kala Place.  But I digress.)   

Across three decades the Lums connected Presidents Clinton, Obama, and Trump to a bi-partisan, trans-generational pipeline of alleged illegal Chinese communist campaign contributions.

In the last 30 years, apparently only President George W Bush was incorruptible. 

Candidate Donald J Trump promised to “Drain the Swamp” but with Trump as President, Nickie Lum finally came into her own.  The prodigal daughter allegedly found herself trading pregnant American hostages, illegal aliens, and renegade Chinese billionaires like baseball cards.  Now Nickie has signed a plea bargain of her own.

Watch President Trump's Rally in West Virginia

Malaysian billionaire Jho Low wanted to ingratiate himself with the communists to secure his sanctuary in China after allegedly teaming up with Malaysia’s now-jailed Prime Minister Najib Razak, and Goldman Sachs (Link: GS $2.8B fine), to steal $4.5B from Malaysia in the 1MDB scandal.

The Chinese communists wanted renegade billionaire Guo Wengui extradited.  (Some may remember seeing Steve Bannon arrested on Guo Wengui’s yacht off Connecticut this summer.) 

Nickie Lum Davis (Clinton Asian money scandals), Haitian Rapper Pras Michel (indicted in 2019 for funneling Chinese Communist money to the 2012 Obama campaign), Trump’s top bundler, convicted felon Elliott Broidy (NY pension fund bribery) and his wife, Robin Rosenzweig, an entertainment industry lawyer, and another entertainment industry lawyer, George Higginbotham—allegedly planted at DoJ by Broidy--allegedly greased the skids.

GOP fundraiser Broidy under investigation for alleged effort to sell  government influence, people familiar with probe say - The Washington Post

Elliott Broidy and Robin Rosenzweig

The scheme became public when Qatari hackers, in December, 2017, broke into Rozenweig’s computer and soon spread the contents all over the Internet.

But, before the hackers ruined everything, the scheme almost worked.

In June, 2017, Donald Trump walked into an Oval Office meeting bellowing, “Where’s the letter that Steve brought?  We need to get this criminal out of the country.”  The letter linked three billionaires.  Advocating the extradition of billionaire Guo Wengui, it was dictated by Chinese then-Vice Premier Sun Lijun (now imprisoned in China) and given to Macao casino billionaire Steve Wynn by Elliott Broidy—who was paid off by billionaire Jho Low, allegedly. 

Here are the details from the US Department of Justice August 17, 2020, ‘Criminal Information’ in US vs Nickie Mali Lum Davis (CR. NO. 20-00068 JAO).

(Using publicly available sources, DoJ identifiers such as ‘Person A’ have been replaced with the alleged names of persons and companies allegedly involved in the scheme.)

  *   *   *   *   *

Excerpts from US Department of Justice August 17, 2020, ‘Criminal Information’ in US vs Nickie Mali Lum Davis:

1. At all times relevant to this information:

2. From no later than March 2017 to at least in or about January 2018, NICKIE LUM DAVIS agreed with Pras Michel and Elliott Broidy to act as agents of Jho Low in exchange for millions of dollars in undisclosed wire transfers originating from foreign accounts associated with Jho Low. DAVIS specifically agreed to facilitate Elliott Broidy 's lobbying of the President of the United States ("the President"), his Administration, and the United States Department of Justice ("DOJ") to drop the investigation of Jho Low for his role in the embezzlement of billions of dollars from 1Malaysia Development Berhad ("1MDB"), a strategic investment and development company wholly owned by the Government of Malaysia. As part of their efforts, the defendant and Elliott Broidy willfully failed to disclose to the Administration and DOJ officials that Elliott Broidy was acting on behalf of Jho Low. Ultimately, DAVIS and Pras Michel and Elliott Broidy were unsuccessful in their efforts to have the 1MDB investigation dropped.

3. During the same approximate period, DAVIS also agreed with Pras Michel and Elliott Broidy to aid their efforts to lobby the Administration and the DOJ to arrange for the removal and return of Guo Wengui-a dissident of the People’s Republic of China (PRC) living in the United States-at the request of Jho Low and PRC Deputy Minister of Public Security Sun Lijun. Here too, DAVIS and Pras Michel and Elliott Broidy were ultimately unsuccessful.

4. To further the interests of Jho Low, DAVIS aided Elliott Broidy in facilitating a meeting between Malaysian Prime Minister Najib Razak and the President in September 2017, in part to allow Malaysian Prime Minister Najib Razak to raise the resolution of the 1MDB matter with the President.

5. DAVIS, Pras Michel, and Elliott Broidy also met with PRC Deputy Minister of Public Security Sun Lijun in the PRC and agreed that Elliott Broidy, assisted by DAVIS, would lobby the Administration to return Guo Wengui to the PRC. DAVIS, Pras Michel, and Elliott Broidy, for the express purpose of providing PRC Deputy Minister of Public Security Sun Lijun an opportunity to discuss the removal of Guo Wengui with high-level United States officials, also agreed to and attempted to facilitate meetings between PRC Deputy Minister of Public Security Sun Lijun and top officials at DOJ and the United States Department of Homeland Security ("DHS"), during PRC Deputy Minister of Public Security Sun Lijun's visit to the United States in May 2017.

8. The defendant, NICKIE MALI LUM DAVIS, was and is a United States citizen, businesswoman, and consultant with personal and business relationships with Pras Michel and Elliott Broidy.

9. Pras Michel was a United States citizen, businessperson, and entertainer with international ties, including ties to Jho Low.

10. Elliott Broidy served as Deputy Finance Chair of [The Republican National Committee] from approximately April 2016 to April 2018. In that capacity, Elliott Broidy raised large political contributions from donors, organized political fundraising events, and coordinated fundraising strategies with the campaign of [Donald J Trump,] a candidate for the Office of the President of the United States during the 2016 election cycle. After the election, Elliott Broidy continued in his role as Deputy Finance Chair and maintained access to, and contact with, high-ranking officials in the Administration of the President, including the President. Over the same period, Elliott Broidy owned and operated several domestic and international businesses and worked as a political consultant.

11. Jho Low was a wealthy businessperson living in East Asia who has been charged separately for his role in orchestrating and executing a multi­ billion-dollar embezzlement scheme from 1MDB.

12. Anicorn LLC was a limited liability company formed by Pras Michel to receive wire transfers from Jho Low to pay Elliott Broidy for his lobbying efforts.

13. George Higginbotham was an associate of Pras Michel and was a licensed attorney employed by DOJ. On November 20, 2019, Higginbotham pleaded guilty in the United States District Court for the District of Columbia to a one-count Information charging conspiracy to make false statements to a financial institution.

14. Colfax Law Office was a law firm operated by Elliott Broidy's spouse, Robin Rosenzweig.

15. Guo Wengui was a dissident of the PRC, living in the United States on a temporary visa. The government of the PRC, including PRC Deputy Minister of Public Security Sun Lijun and the President of the PRC, were seeking the removal of Guo Wengui from the United States back to the PRC.

16. In late 2016 through 2019, DOJ was actively investigating transactions of Jho Low allegedly associated with laundered proceeds of the 1MDB embezzlement scheme. In July 2016, DOJ filed multiple civil forfeiture complaints seeking the forfeiture of millions of dollars in assets allegedly purchased with 1MDB laundered proceeds. On November 1, 2018, DOJ filed a criminal indictment charging Jho Low and others with conspiring to launder billions of dollars embezzled from 1MDB and conspiring to violate the Foreign Corrupt Practices Act by paying bribes to various Malaysian and Abu Dhabi officials.

I. Campaign to Resolve 1MDB Civil Forfeiture Cases

A. Elliott Broidy Agrees to Lobby for Jho Low for $8 Million Retainer

17. In or about March 2017, DAVIS told Elliott Broidy that she had a possible client in Malaysia who could "use help with the forfeiture."

18. On or about March 5, 2017, at the request of Elliott Broidy, DAVIS emailed Elliott Broidy a copy of a civil forfeiture complaint related to 1MDB. That same day, DAVIS emailed Elliott Broidy a Bloomberg article titled "[Jho Low] Trusts Ask to File Late Claims in Forfeiture Lawsuits," and texted Elliott Broidy, "Your email has the court filing[.]" Elliott Broidy responded, "Thx. Will review." DAVIS replied, "Call me when u can- thank you[.]" Elliott Broidy responded again, "Yes. 5 min[.]"

19. Pras Michel requested that DAVIS send him Elliott Broidy's biography describing Elliott Broidy's relationship with high-level officials in the Administration and photographs of Elliott Broidy and the President. On or about March 7, 2017, Elliott Broidy's assistant, at DAVIS's request, emailed photographs to DAVIS featuring Elliott Broidy and the President. Pras Michel said that he wanted the photographs so that Pras Michel could highlight Elliott Broidy's close access to the Administration.

20. On or about March 8, 2017, DAVIS texted Elliott Broidy, "Are you in la to meet on the 16th w [Pras Michel] prior to his travel that weekend to Asia?" Elliott Broidy responded, "I think so. Let's speak later." Later that same day, DAVIS sent Elliott Broidy additional text messages to set up the meeting among Elliott Broidy, Pras Michel, and DAVIS.

21. At the direction of Elliott Broidy, on or about March 13, 2017, DAVIS forwarded to Pras Michel a "Retainer and Fee Agreement - Litigation Services" between Colfax Law Office and Jho Low. The "Retainer and Fee Agreement" stipulated that Jho Low would pay an $8 million retainer fee upfront, and an additional $75 million success fee if the "matter" was resolved within 180 days, or $50 million if the "matter" was resolved within 365 days. The draft agreement included an Exhibit A explaining that the "matter" referred to the 1MDB forfeiture proceedings. In actuality, Pras Michel, Elliott Broidy, Colfax Law Office, DAVIS, and Robin Rosenzweig provided no litigation services or legal advice to Jho Low. The true purpose of the retention agreement was to secure Elliott Broidy 's services to lobby the Administration and DOJ on Jho Low's behalf based on Elliott Broidy's political connections.

22. On or about March 13, 2017, Elliott Broidy met with Pras Michel and DAVIS to discuss Jho Low and his legal issues. At the meeting, Pras Michel described his relationship with Jho Low to Elliott Broidy, and asked if Elliott Broidy could help with the civil forfeiture cases involving Jho Low. Pras Michel said he would speak with Jho Low about the possibility of Elliott Broidy helping with the civil forfeiture cases. That same day, Elliott Broidy texted DAVIS in part, "I'm excited about our business prospects."

23. On or about March 15, 2017, in reference to Jho Low, Elliott Broidy texted DAVIS, "Anything new on ... [Pras Michel's] Associate?" That same day, DAVIS responded, "[Pras Michel] mtg in person tomorrow w the 'promoter' and they hope to travel within the next few week[.]"

24. On or about March 22, 2017, DAVIS emailed Elliott Broidy and his assistant about setting up another meeting among Elliott Broidy, Pras Michel, and DAVIS.

25. At all relevant times, DAVIS, Pras Michel, and Elliott Broidy were aware of FARA and its prohibition on unregistered representation of foreign principals.

26. Despite their knowledge of the requirement to register as agents of a foreign principal, at no time did DAVIS, Pras Michel, or Elliott Broidy register with the FARA Unit in DOJ regarding their work as agents of Jho Low.

B. Pras Michel, Elliott Broidy, and DAVIS Meet Jho Low in Bangkok

27. In or about April 2017, Pras Michel asked Elliott Broidy to travel to Bangkok, Thailand, to meet with Jho Low. Elliott Broidy said he would go only if he were paid $1 million, and that he wanted to be paid by Pras Michel from "untainted" funds.

28. On or about April 28, 2017, Elliott Broidy texted DAVIS advising, "I would like the funds to go to [Colfax Law Office.]" That same day, DAVIS responded, "Ok[.]"

32. On or about May 2, 2017, DAVIS emailed Elliott Broidy stating in part, "Since u land earlier - [Pras Michel] and I will see you at arrivals.. . . Thanks and bon voyage- here 's to the start of an exciting and prosperous adventure!"

33. On or about May 2, 2017, DAVIS, Pras Michel, and Elliott Broidy arrived in Bangkok. During the trip, DAVIS, Pras Michel, and Elliott Broidy met with Jho Low in a hotel suite. Elliott Broidy and Jho Low spoke about the 1MDB investigation and civil forfeiture actions. Elliott Broidy agreed to help Jho Low attempt to resolve the matter. Jho Low agreed to pay Elliott Broidy an $8 million retainer and wanted Elliott Broidy to contact the Attorney General of the United States to get DOJ to drop the 1MDB matter. Elliott Broidy agreed to lobby the Administration and DOJ for a favorable result for Jho Low while concealing the fact that he was working on Jho Low's behalf. With respect to payment, Elliott Broidy stated that the money should not come directly from Jho Low and should be "clean." Jho Low identified a friend who could pay Elliott Broidy and others. Elliott Broidy, Pras Michel, and DAVIS agreed that the money would first be routed through Pras Michel and then be paid to Elliott Broidy through Colfax Law Office. Elliott Broidy and DAVIS agreed that Elliott Broidy would pay DAVIS thirty percent of what Elliott Broidy received. Pras Michel also agreed to pay DAVIS a percentage of the funds that Pras Michel received. Pras Michel told Elliott Broidy and DAVIS that Pras Michel's friend, Higginbotham, was verifying the legitimacy of the funds. Higginbotham did not actually perform any such review.

C. Pras Michel Receives $8.5 Million from Jho Low; Elliott Broidy is Paid $6 Million; DAVIS is Paid $1.7 Million

34. Following the meeting with Jho Low in Thailand, on or about May 8, 2017, Anicorn LLC received a wire transfer directed by Jho Low for approximately $2.8 million from an entity in Hong Kong. That same day, Pras Michel obtained a cashier's check from the Anicorn LLC account for $702,000 payable to Colfax Law Office, which was immediately credited to Colfax Law Office's account. Pras Michel also made a separate wire transfer of $48,000 to Colfax Law Office from the Anicorn LLC account. Also that same day, a third-party company transferred $250,000 to the Colfax Law Office account at Pras Michel's direction, bringing the total amount deposited into the Colfax Law Office account to $1 million. Within several days, approximately $900,000 of the $1 million transferred into the Colfax Law Office account on May 8, 2017 was transferred from the Colfax Law Office account to one of Elliott Broidy's business accounts.

35. On or about May 8, 2017, DAVIS texted Elliott Broidy, "Both wires in [Colfax Law Office] are from [Pras Michel]. The remaining balance was dropped to your office 20 minutes ago-". DAVIS then added, "702 total cashier check[.]"

36. On or about May 9, 2017, Pras Michel caused Anicorn LLC to transfer $250,000 to a company controlled by a family member of DAVIS for the benefit of DAVIS.

37. On or about May 17, 2017, Jho Low caused an international wire to be sent to Anicorn LLC from a Hong Kong company. That same day, Pras Michel transferred $3 million from Anicorn LLC to Colfax Law Office.

38. On or about May 17, 2017, Elliott Broidy and DAVIS exchanged text messages regarding the payments from Jho Low to Elliott Broidy through Pras Michel and Elliott Broidy's payment of a percentage to DAVIS. Among the text messages, DAVIS asked, "Did you get it?" Elliott Broidy responded, "Yes. Sent you Wickr[.] Sending wire to you in morning." Wickr is a messaging application that allows for end-to-end encryption and content expiration. Elliott Broidy later added, "Did you get 2nd confirm?" DAVIS responded, "When Asia opens .... Baby steps at least moving forward now." Elliott Broidy responded, "Yes. Hammer them for the next 2 wires." Elliott Broidy later added in part, "Assuming second 3 is in and confirmation that last 2 is being sent. Please ask [Elliott Broidy 's assistant]."

39. On or about May 18,2017, Colfax Law Office transferred $500,000 to one of Elliott Broidy's business accounts and $900,000 to a business account controlled by DAVIS. Within approximately one week, Colfax Law Office transferred an additional $950,000 in two separate transfers to one of Elliott Broidy's business accounts.

40. On or about May 25, 2017, Jho Low caused a third transfer to be made to Anicorn LLC, this time in the amount of approximately $2.7 million. On or about May 26, 2017, Pras Michel transferred $2 million from Anicorn LLC to Colfax Law Office in partial satisfaction of the $8 million retainer to which Elliott Broidy and Jho Low agreed in return for Elliott Broidy 's lobbying the Administration and the DOJ to drop the 1MDB civil forfeiture cases and any related investigations. That same day, $600,000 was transferred from Colfax Law Office 's account to a business account associated with DAVIS.

D. Elliott Broidy Facilitates Meetings for Malaysian Prime Minister Najib Razak and Lobbies to Resolve the 1MDB Cases

41. On or about May 18, 2017, Elliott Broidy texted Rick Gates, a political consultant and former campaign aide for the President, and requested that Rick Gates work with the Administration to set up a visit for Malaysian Prime Minister Najib Razak: "Hi [Rick Gates]- Please work on Asian country visit. Date in July."

42. On or about June 5, 2017, Elliott Broidy texted Rick Gates again regarding the visit for Malaysian Prime Minister Najib Razak: "Asian country is very motivated re July meeting. Hoping we can confirm date etc asap."

43. The same day, at the request of Pras Michel, DAVIS sent Elliott Broidy text messages regarding Jho Low. Among those messages, DAVIS wrote, based upon information conveyed to her by Pras Michel on behalf of Jho Low, "Please call before u go to bed in ISRAEL if possible ... [Jho Low] keeps calling for news[.]" Elliott Broidy responded, "Yes. Will call you. I am heading to D.C. Tonight to work on [Jho Low] and Asian country[.]"

44. On or about June 15, 2017, relaying a message from Pras Michel, DAVIS texted Elliott Broidy, "Hey he'd like to speak w you this evening. Are u able?" DAVIS added, "Principal", which was a reference to Jho Low. That same day, Elliott Broidy responded, "Yes[.]"

45. On or about June 16, 2017, Elliott Broidy and DAVIS exchanged text messages regarding 1MDB and the seizure of jewelry from a person associated with Jho Low.

46. On or about June 17, 2017, Elliott Broidy and DAVIS discussed Malaysian Prime Minister Najib Razak. In or about June 2017, Elliott Broidy asked the President if he would play golf with Malaysian Prime Minister Najib Razak. Elliott Broidy said, and DAVIS believed, that this would please Jho Low and would allow Malaysian Prime Minister Najib Razak to attempt to resolve the 1 MDB matter. Elliott Broidy also hoped to secure additional business with the government of Malaysian Prime Minister Najib Razak and hoped that arranging golf with the President would further his business interests.

47. On or about June 19, 2017, DAVIS texted Elliott Broidy a link to an article about the Malaysian Prime Minister Najib Razak's office criticizing the 1MDB forfeiture action in the United States.

48. On or about June 25, 2017, DAVIS texted Elliott Broidy a link to an article about Malaysian Prime Minister Najib Razak and the 1MDB forfeiture action involving Jho Low. That same day, Elliott Broidy responded, "Weird article. What can we do?" DAVIS replied, "Call pls. Got news[.]" DAVIS followed up stating that she had sent Elliott Broidy a "What's app request."

49. On or about June 29, 2017, Elliott Broidy sent a text message to a high ranking official in the White House in an effort to arrange a golf outing between Malaysian Prime Minister Najib Razak and the President: "Hi [Reince Priebus], As I mentioned, POTUS agreed to play a round of golf in DC or Bedminster in late July or early August with [Malaysian Prime Minister Najib Razak]. Thank you very much for getting back to me with the date. Also a letter went to the state dept. for a meeting some weeks ago."

50. On or about June 30, 2017, Elliott Broidy sent another text message to Reince Priebus regarding the golf outing: "Hope we can speak this morning on [Guo Wengui] and golf date with POTUS for [Malaysian Prime Minister Najib Razak]." Later that day, Elliott Broidy followed up with, "[Reince Priebus], as discussed, hoping we can get these items completed today. Please call me anytime."

51. On or about July 3, 2017, Elliott Broidy again texted Reince Priebus regarding the golf date for Malaysian Prime Minister Najib Razak and the President: "Good morning [Reince Priebus]. It would be extremely helpful to me if you could confirm the golf date today with POTUS for [Malaysian Prime Minister Najib Razak.] POTUS told me he is glad to play at Bedminster or DC. After we spoke, I mentioned to [Malaysian Prime Minister Najib Razak] that he would have the date last week. Thank you very much! Regards, []." Later that day, Elliott Broidy texted Reince Priebus again: "[Reince Priebus], I'm following up. Please send me the date and time for the [Malaysian Prime Minister Najib Razak] golf with POTUS. Thank you!"

52. On or about July 4, 2017, DAVIS texted Elliott Broidy, "Call me asap" and then "Clear your phone- erase messages[.]"

53. On or about July 5, 2017, Elliott Broidy exchanged messages with Reince Priebus regarding the golf outing. Among other messages, Elliott Broidy texted, "[Reince Priebus],just left you a message. It's been a week. Can you send me the date today? Best, []" Reince Priebus responded, "It's with the NSC[.] They coordinate and negotiate- I'm sure it will get done[.]"

54. On or about July 11, 2017, relaying a message from Pras Michel, DAVIS texted Elliott Broidy, "Wickr[.] It's 5pm ... I think we need to make a move. Date and otherwise. We're getting killed." These messages referred to confirming a date for Malaysian Prime Minister Najib Razak to play golf with the President and Jho Low's displeasure because no date had been confirmed. Relaying urgency from Pras Michel, DAVIS continued, "Please call because we need to strategize - I'm getting inundated[.]" Elliott Broidy responded, "See wikr[.]" The following day, Elliott Broidy texted DAVIS, "Send me text on wikr. I'm taking off and need to get to WH[.] Taking off. Need now[.]" DAVIS responded, "Done[.]" Elliott Broidy responded, "Got it. Thx[.] Trying to get [HR McMaster] to do call asap[.]" HR McMaster was then a high­ ranking official on the National Security Council.

55. On or about July 13, 2017, DAVIS texted Elliott Broidy, "Please call when u can so we can talk- we gotta handle this so pls pls go to D.C. And sit at WH until u get it. I will keep u company if u worry about being lonely!"

56. On or about July 13, 2017, Elliott Broidy texted Reince Priebus again regarding the golf date: "Hi [Reince Priebus], It's been 2 weeks. Checking again on date for golf for [Malaysian Prime Minister Najib Razak] with POTUS. Can you text me date today? Thank you. Best, [][.]" Reince Priebus responded, "I'll check now again[.] These things go through a process -". Elliott Broidy responded "Thank you!!" Reince Priebus replied, "NSC is on it and coordinating[.]" Elliott Broidy responded, "Can we get date today?" Reince Priebus replied, "They're working directly with [Malaysia.] NSC is coordinating a date."

57. On or about July 15, 2017, Elliott Broidy texted DAVIS, "Working on getting meetings for tomorrow."

58. On or about July 17, 2017, conveying urgency expressed by Pras Michel on behalf of Jho Low, DAVIS texted Elliott Broidy, "[Reince Priebus] needs to give u this date now and ask him for update on other thing. We look impotent[.]" This text referred both to setting up a meeting between the President and Malaysian Prime Minister Najib Razak and to the matter involving Guo Wengui. Elliott Broidy responded, "Agree. Hammering away[.]"

59. On or about July 18, 2017, Elliott Broidy and DAVIS exchanged several text messages about setting up a meeting between the President and Malaysian Prime Minister Najib Razak. Among the messages, relaying information from Pras Michel, DAVIS wrote, "Can u check Wikr[.] Really really need that date. It 's been crazy for me all day w this. He's panicking[.]" DAVIS followed up with, "This date is mandatory today- we're getting creamed." According to Pras Michel, Jho Low was panicking because no meeting had yet been scheduled. Elliott Broidy responded, "Calling [Reince Priebus] now[.]" DAVIS replied in part, "Call everyone so they know u are raging mad[.] Call [Madeleine Westerhout] too. We need this today[.]" Madeleine Westerhout was an administrative assistant to the President. Elliott Broidy replied, "Doing it now."

60. On or about July 19, 2017, DAVIS texted Elliott Broidy in reference to scheduling a date for a meeting between Malaysian Prime Minister Najib Razak and the President, "Secondly we need this date bad[.]" Elliott Broidy responded the following day, "Please bear with me. Getting some info on mtg[.]"

61. On or about July 21, 2017, Elliott Broidy texted Reince Priebus regarding the golf outing: "[Reince Priebus], [Malaysia] have heard nothing from NSC. POTUS said he would play golf with Malaysian Prime Minister Najib Razak in late July or early August. POTUS said he was happy to do it. You said it would be scheduled in a day or two. We're in the 4th week. I know you are busy and procedures apply but I've been more than patient. Instead of being positive, this is now causing me damage. I would truly appreciate it if you could get back to me today with a date. Thank you! []."

62. On or about July 24, 2017, Elliott Broidy texted Rick Gates, "Received golf date in NJ in Sept. Sat before the UN General Assembly. Finally! Crossed off my list! Thank you also for helping!" Rick Gates responded, "Let's follow through and make sure the date is confirmed by the NSC. Did he tell you who gave him the date?" Elliott Broidy replied, '"Thank you!! Fantastic. Given to [Steve Wynn] by [Reince Priebus]."

63. On or about July 27, 2017, Elliott Broidy texted Rick Gates, "Just checked again with [Malaysia]. Their Amb to US and Foreign Minister have heard nothing. Please check asap. Best, []." Elliott Broidy followed up with, "Hi [Rick Gates]- Can you call NSA for me re [Malaysia] receiving official word. Still no contact from NSC to [Malaysia] Ambon meeting. Thank you. Best, []" Rick Gates responded,"[] will call again this morning. Talked to [] briefly yesterday .... Will call shortly."

64. On or about July 29, 2017, relaying information that she received from Pras Michel on behalf of Jho Low, DAVIS texted Elliott Broidy in reference to the meeting between Malaysian Prime Minister Najib Razak and the President, "They were told 12 sept is mtg. That's day that un general assembly stars- it's a Tuesday???? No golf??" DAVIS immediately followed by texting "Wickr[.]" Elliott Broidy responded, "May be two mtgs. Amb should ask. Golf at Bedminster on Sat and tues at WH?"

65. On or about August 7, 2017, Elliott Broidy sent his assistant an email with the subject, "Malaysia Talking Points *Final*," with talking points intended for an upcoming meeting between the Secretary of State of the United States and Malaysian Prime Minister Najib Razak. DAVIS received the talking points from Pras Michel-who provided them on behalf of Jho Low-and relayed them to Elliott Broidy, knowing that Elliott Broidy would then provide them to the Secretary of State as background for the meeting. The talking points mentioned, among other things, Elliott Broidy's ongoing relationship and work with [Malaysia], and identified 1MDB as a "[p]riority[.]" The talking points noted the lack of harm caused by 1MDB, and specified that "[t]he involvement of US prosecutors has caused unnecessary tension American [sic], and could cause a negative reaction among Malaysians[.]"

66. On or about August 7, 2017, Elliott Broidy also sent the talking points document to Rick Gates for his review and edits and to obtain details about the timing of a meeting in Malaysia between Malaysian Prime Minister Najib Razak and the Secretary of State: "Hi [Rick Gates]; When is [Secretary of State] mtg?; Already 11:00 am Monday in [Malaysia]. Can you expand and send me final version?" Rick Gates responded by sending a revised version of the talking points to Elliott Broidy and stating, "[]- here is the marked up version I am going to forward to [Secretary of State]'s office. He heads to Bangkok today and then to [Malaysia]. Let me know if you have any other changes. Thanks."

67. Later, on or about August 7, 2017, Elliott Broidy messaged Rick Gates, "[Secretary of State] is meeting with [Malaysian Prime Minister Najib Razak] on 8th and deputy PM on 9th. Let's get a plug in my name. They know my name and might not immediately recognize [my company 's] name. Thank you!" Rick Gates responded, "Definitely important to make this connect. It will not likely be part of the formal meetings but will work to get a plug during their conversations."

68. Also on or about August 7, 2017, Pras Michel executed an agreement between another of Pras Michel 's companies and a representative of Jho Low providing for "Strategic Communications and Crisis Management" in exchange for approximately EUR 8.4 million to be paid on or before August 16, 2017.

69. On or about August 9, 2017, Jho Low caused a Hong Kong company to transfer approximately $12.8 million to Anicorn LLC. Pras Michel then transferred $3 million to Colfax Law Office. Pras Michel also transferred $833,333 to a business account controlled by DAVIS. On or about August 10, 2017, Colfax Law Office transferred $900,000 to a business account associated with DAVIS.

70. On or about August 10, 2017, Elliott Broidy texted Rick Gates regarding the meeting between Malaysian Prime Minister Najib Razak and the Secretary of State: "Heard from [Malaysia] that meetings went very well. They were happy with [Secretary of State]. My name was not mentioned- no plug.;- ...."

71. On or about August 16, 2017, Elliott Broidy and DAVIS exchanged text messages to set up a meeting and a phone call. Among the messages, DAVIS wrote, "[Pras Michel] really wants to see u today if possible since u leave Friday[.]"

72. On or about August 18, 2017, Elliott Broidy and DAVIS exchanged text messages setting up a phone call. Among the messages, DAVIS wrote, "Call me pls. [Pras Michel] wants to conference in[.]"

73. On or about August 19, 2017, Elliott Broidy texted Rick Gates, "Any update on [Malaysia]? Rick Gates responded, "As of now it is going to be in DC. And hard to do golf due to schedule but I am working on it. Might have to go to [John Kelly] directly on this and use the history of the two of them playing golf." Elliott Broidy responded, "Yes. If you think it would help I could directly call one of [John Kelly] deputies or [John Kelly]. Also need to add time to meetings. I would like to discuss details with you. Please let me know what is best." John Kelly was then a high-ranking official at the White House.

74. On or about August 21, 2017, DAVIS wired $375,000 in funds she received as a commission from Pras Michel, to Robin Rosenzweig, the spouse of Elliott Broidy.

75. On or about August 24, 2017, Jho Low directed the transfer of approximately $10 million to Pras Michel's separate company that had entered into the "Strategic Communications and Crisis Management" agreement with a representative of Jho Low for EUR 8.4 million. Based on the prevailing exchange rate on August 24, 2017, EUR 8.4 million converted to approximately $10 million.

76. On or about September 11, 2017, DAVIS typed a letter at Elliott Broidy's direction to be sent from Elliott Broidy to the President in anticipation of Malaysian Prime Minister Najib Razak's meeting with the President. The letter included several positive developments in the relationship between Malaysia and the United States. The letter was never provided to the President.

77. On or about September 12, 2017, Malaysian Prime Minister Najib Razak met with the President at the White House, due in part to the assistance provided by DAVIS for Elliott Broidy 's efforts to facilitate the meeting. Although Elliott Broidy contacted high­ ranking officials in the Administration to arrange a golf meeting between the President of the United States and Malaysian Prime Minister Najib Razak in addition to the official meeting, no golf game between Malaysian Prime Minister Najib Razak and the President took place.

78. On or about October 6, 2017, Elliott Broidy met with the President at the White House. Elliott Broidy represented to Pras Michel, DAVIS, and Jho Low that he raised the LMDB investigation with the President during the meeting.

79. On or about January 5, 2018, Elliott Broidy drafted talking points related to 11\IDB to demonstrate to Jho Low the efforts that Elliott Broidy had undertaken on his behalf. Among other things, the talking points provided: "1. We are working with the DoJ to counter the previous Administration's case against 1MDB in [Malaysia]. I have put a strategy in place to contact parties both at DoJ and the NSC to find a resolution to this issue. 2. I am in the process of scheduling a meeting with the assistant attorney general [] who has the oversight for the [] case. She is a [presidential] appointee and can be helpful .... 3. As I informed you earlier, in my discussion with the President, he committed to getting this issue resolved. It is important that I take his lead but will continue to communicate the importance of this issue." Elliott Broidy greatly exaggerated his efforts regarding the 11\IDB investigation.

80. On or about January 6, 2018, Elliott Broidy met with Pras Michel, who asked Elliott Broidy for a loan. Pras Michel told Elliott Broidy that Pras Michel's friend (George Higginbotham) was "checking on" the money they had received from Jho Low and "helping to keep it clean."

II. Campaign to Remove Guo Wengui from the United States

A. Elliott Broidy Travels to China to Meet with PRC Deputy Minister of Public Security Sun Lijun

81. In or about May 2017, following the trip to Bangkok, Elliott Broidy agreed to travel to Hong Kong to meet again with Jho Low. Prior to the trip, DAVIS and Elliott Broidy discussed that it was important to Jho Low that Guo Wengui be deported from the United States. The purpose of the trip to Hong Kong was to meet with Jho Low and a foreign government official of the PRC to discuss Guo Wengui.

82. On or about May 15, 2017, DAVIS emailed Elliott Broidy's assistant regarding travel arrangements and the itinerary for the trip to Hong Kong. The same day, DAVIS also emailed Elliott Broidy and Robin Rosenzweig banking information for DAVIS's company.

83. On or about May 18, 2017, Pras Michel, Elliott Broidy, and DAVIS traveled to Hong Kong and were transported to Shenzhen, China, where they met with Jho Low and PRC Deputy Minister of Public Security Sun Lijun in a hotel suite. PRC Deputy Minister of Public Security Sun Lijun spoke to Elliott Broidy about Guo Wengui and his alleged crimes and stated that the PRC wanted Guo Wengui to be returned to the PRC. PRC Deputy Minister of Public Security Sun Lijun asked Elliott Broidy to use his influence with high-ranking United States government officials to advocate for Guo Wengui's removal and return to the PRC. PRC Deputy Minister of Public Security Sun Lijun also stated that he would be visiting Washington, D.C. soon and was having trouble scheduling meetings with certain high-ranking United States government officials.

B. Elliott Broidy Lobbies Top U.S. Officials for the Removal of Guo Wengui

84. On or about May 20, 2017, during the return trip from China, Elliott Broidy texted DAVIS, "I'll try to make this a big week for us with [the Attorney General.]"

85. On or about May 21, 2017, Elliott Broidy texted Rick Gates regarding his meeting with Jho Low and PRC Deputy Minister of Public Security Sun Lijun: "[Rick Gates]- Just returned. Huge opportunity. Can we meet Monday morning at 9:30a.m. at [hotel]?[]."

86. On or about May 22, 2017, Elliott Broidy texted Rick Gates, "I will need to meet with [Attorney General] asap. We will discuss." Elliott Broidy followed up with, "I am emailing you a memo. We will discuss." Later the same day, Rick Gates responded, "Have a request into [Attorney General] for mtg."

87. On or about May 22, 2017, Elliott Broidy sent an email to Rick Gates with the subject, "Opportunity for Significantly Increased Law Enforcement Cooperation between US and [the PRC][.]" Elliott Broidy attached to the email a memorandum from Elliott Broidy addressed to the Attorney General, intending that Rick Gates would then provide the memorandum to the Attorney General. The content of the memorandum had been provided to Elliott Broidy by DAVIS, who received it from Pras Michel during the May 2017 trip to China where the content originated from PRC Deputy Minister of Public Security Sun Lijun and Jho Low. Upon receipt, Elliott Broidy and Robin Rosenzweig revised the memorandum.

88. In the memorandum, Elliott Broidy misrepresented the reason for his trip to China and the circumstances leading to his meeting with PRC Deputy Minister of Public Security Sun Lijun. Elliott Broidy.concealed his contact with Jho Low and concealed Jho Low's role in setting up the meeting between Elliott Broidy and PRC Deputy Minister of Public Security Sun Lijun. Elliott Broidy also concealed the $4 million that he had been paid by Jho Low over the two weeks preceding the meeting in Shenzhen with PRC Deputy Minister of Public Security Sun Lijun. Elliott Broidy also did not disclose that his lobbying efforts with respect to Guo Wengui were, at least in part, pursuant to his financial arrangement with Jho Low and could potentially result in additional payment.

89. In the memorandum, Elliott Broidy stated, "I was told by [PRC Deputy Minister of Public Security Sun Lijun] that [the PRC] would like to significantly increase bi-lateral cooperation with the US with respect to law enforcement including cyber security." Elliott Broidy wrote about PRC Deputy Minister of Public Security Sun Lijun's upcoming trip to Washington, D.C., in which PRC Deputy Minister of Public Security Sun Lijun and his delegation planned to meet with several high-ranking United States government officials. Elliott Broidy advocated for the Attorney General to meet with PRC Deputy Minister of Public Security Sun Lijun. Elliott Broidy also noted several items that the PRC, according to PRC Deputy Minister of Public Security Sun Lijun, would be willing to do to improve law enforcement relations between the United States and the PRC. Elliott Broidy then added:

According to my conversation with [PRC Deputy Minister of Public Security Sun Lijun], the one request [the PRC] will make is that [Guo Wengui], who [the PRC] alleges has conspired with others who have been arrested and charged with violations of numerous criminal laws of [the PRC] (including kidnapping and significant financial crimes be deported (his Visa ends within the next month or so) or extradited (Interpol has issued a Red Notice with respect to him which is attached for your reference) as soon as possible from the US to [the PRC] so he can be charged with these violations and go through regular criminal proceedings in [the PRC] with regard to these allegations.

Elliott Broidy appended an Interpol Red Notice for Guo Wengui to the memorandum.

90. On or about May 23, 2017, Elliott Broidy texted Rick Gates, "Hi[] Is meeting set for tomorrow? Has my memo been sent to [Attorney General]? Please update Thanks [][.]" Rick Gates responded, "[Elliott Broidy]- letter was delivered yesterday. Pls see the final version with changes. Working on mtg for tomorrow but shooting for early afternoon. Will call you later today. I am now on redeye tonight so I can get back to DC early." Elliott Broidy responded, "Great. Thank you[]. Also try to determine if his mtg was set or if we can set for thurs or in Alabama on fri or sat." The following day, on or about May 24, 2017, Rick Gates responded, "[W]aiting to hear from DoJ on mtgs - ours and [PRC Deputy Minister of Public Security Sun Lijun]. let me know when you are free and we can meet up to go over other issues. thanks."

91. On or about May 24, 2017, Rick Gates texted Elliott Broidy, "Just got a call from [Attorney General]'s office and he cannot do tonight. But I got a text back from him directly that said he would call me later."

92. On or about May 25, 2017, Elliott Broidy texted Rick Gates, "The meetings are at Justice at 10:00 am this morning. Then FBI and DHS tomorrow. Perhaps I could tell my contact to get there 10 min early and a brief meeting could occur. And then have meet with[] one on one to discuss more details. Please try to see [Attorney General] first thing today. Really important that we pull it off. I need to speak with my contact this morning. Thank you. [ .]" Rick Gates responded, "[ ]- working on it. [Attorney General] is not in the office this morning but trying to see what time he is returning. Stand by." Later the same day, Elliott Broidy texted Rick Gates, "Detail is that the 3 things in my memo are only for [Attorney General]. [PRC Deputy Minister of Public Security Sun Lijun] wants to tell [Attorney General] directly. Mine is legitimate back channel. [PRC Deputy Minister of Public Security Sun Lijun)'s boss wants confirmation that ]Attorney General[ heard the 3 things which really help US].[" Later that day, Rick Gates responded,"][- actually just got off the phone with ]Attorney General[. Not great news. Let me know when you are free to talk. Thanks."

93. On or about May 26, 2017, referencing meetings for PRC Deputy Minister of Public Security Sun Lijun, Elliott Broidy texted Rick Gates, "10 am head of ICE 11:30 FBI Perhaps a play at DHS would save situation. Fly by ]John Kelly[. The three items can be shared." Elliott Broidy followed up with, "Please call me" and "I'm trying to do damage control and need to speak with you. Best is pull aside with ]John Kelly[." John Kelly was a senior official in DHS at the time.

94. On or about May 28, 2017, Elliott Broidy emailed Rick Gates, "transcribed correspondence to and from ]the Attorney General[ and ]the PRC's[ Ambassador to the US." Elliott Broidy noted, "I believe there is an excellent opportunity for ]the Attorney General[ to further US interests. I added comments below. Can we discuss asap? There is another matter of interest that the AG should be made aware of."  Later that same day, Elliott Broidy and Rick Gates exchanged emails to schedule a time to discuss the email and its content.

95. On or about May 30, 2017, relaying information from PRC Deputy Minister of Public Security Sun Lijun and Pras Michel regarding PRC Deputy Minister of Public Security Sun Lijun 's meetings with United States Government officials, DAVIS texted, "Check Wickr- all clear now for meetings].[" Elliott Broidy responded, "Yes. All set].[" DAVIS replied, "He got his Mtgs reinstated].["

96. In or about May 2017, DAVIS, at Pras Michel's request, asked Elliott Broidy to meet with PRC Deputy Minister of Public Security Sun Lijun in Washington, D.C.

97. On or about May 30, 2017, Elliott Broidy met with PRC Deputy Minister of Public Security Sun Lijun at a hotel in Washington, D.C. Elliott Broidy also asked Rick Gates if Rick Gates could help PRC Deputy Minister of Public Security Sun Lijun arrange meetings with high-ranking United States government officials.

98. On or about May 31, 2017, Elliott Broidy texted Rick Gates:

I met with the VM last night. He is on a 4 pm flight back this afternoon. The FBI had him meeting with very low level people and had the person he was to meet with meet with Vietnam instead. His superiors told him to come home unless meeting with ]Attorney General[ or ]John Kelly[. He is happy meeting with ]John Kelly[. .... So far, he has delivered a pregnant woman and the next 2 will be sent shortly. He will accept 60 Chinese Nationals for deportation but only if he has a proper "short meeting". This is a big win for the admin that can be publicized. It is the result of Mara Largo meeting between the two presidents. Please call me and I will tell you more specifics. Thank you.

99. Rick Gates responded, "][-got the info. I will call in a few mins." Elliott Broidy replied, "If you get the meeting, can we have the political WH liaison meet the VM at DHS? He can mention my name. Also try to get ]John Kelly[ to warm up situation. Mention me as well. Thank you! Fingers crossed."

100. On or about May 31,2017, DAVIS texted Elliott Broidy with respect to PRC Deputy Minister of Public Security Sun Lijun's purported meeting with John Kelly, "In principal ]John Kelly[ us ok- just a schedule issue?" Elliott Broidy responded, "Just a short notice scheduling issue. Still might hear in next hour or so. There is no issue with ]PRC Deputy Minister of Public Security Sun Lijun[." Elliott Broidy later continued, "Please pass along my good wishes to the VM. Wait a little while longer." DAVIS responded, "Yes, I'm telling him that." Elliott Broidy replied, "Tell him I'm telling WH and ]Attorney General[ what happened." DAVIS then texted, "Isn't ]John Kelly[ scheduled to be in Haiti this afternoon?" Elliott Broidy responded, "Scheduler did not mention this?? Are you sure? Neither did ]Attorney General'[s people].[" DAVIS responded, "It's on the DHS website].[ He's there for the afternoon].[ Just spoke to VM and he sounded like he was crying].[" Elliott Broidy responded, "Terrible. What a mess. Bottom line not our fault. Normally their Amb would handle. This is a cluster f]*[ck." DAVIS replied, "Wickr."

101. On or about June 9, 2017, DAVIS texted Elliott Broidy a news article titled "]the PRC[-cranks-up-heat-on-exiled tycoon-]Guo Wengui.["

102. On or about June 27, 2017, Elliott Broidy and DAVIS exchanged several text messages regarding Guo Wengui.

103. On or about June 27, 2017, Elliott Broidy texted Steve Wynn's spouse regarding the removal of Guo Wengui. Elliott Broidy knew that Steve Wynn, an internationally successful businessman and frequent contributor to political campaigns with close access to the President, had immediate access to and influence with the President and could be effective in seeking the removal of Guo Wengui. Elliott Broidy texted Steve Wynn's spouse, "On another note, I would like to meet with Steve Wynn tomorrow morning and on important and sensitive matter. Is there a time tomorrow morning that would be convenient or perhaps for lunch? Looking forward to seeing you at the ][ Hotel! Regards, ][].[" Elliott Broidy later continued:

Hi ][, ]Steve Wynn[ asked me to send this information to you via text. I have a number of items I will be sending to you regarding the fugitive ]Guo Wengui[. The first is an Interpol red notice.... The highly time sensitive matter is that ]Guo Wengui['s visa to stay in the US expires on June 30th. It is critically that his new visa application he immediately denied. He must also be placed on the DHS no fly list. ... The order would need to come from the very top as ]Guo Wengui[ is well connected with former FBI who are on his private security detail. The President of the PRC mention to ]the President[ at Mar-A-Lago that he would like ]Guo Wengui[ returned. ]PRC Deputy Minister of Public Security Sun Lijun[ met with me and requested help with regard to ]Guo Wengui[. ... He promised to return certain US citizens held hostage by ]the PRC[ and would accept a very large number of ]the PRC[ illegal immigrants for deportation back to ]the PRC[. Finally he offered new assistance with regard to North Korea.

104. On or about June 28,2017, Elliott Broidy met with Steve Wynn and his spouse at a social gathering. After the meeting, Elliott Broidy exchanged text messages with Steve Wynn's spouse regarding ]Guo Wengui[: "Hi ][, it was great to see you and ]Steve Wynn[ tonight! I just heard from ]PRC Deputy Minister of Public Security Sun Lijun[ again. He would like to know the status of ]Guo Wengui['s VISA as time is of the essence. -Was the VISA issued already or did we deny it? Can we confirm that ]Guo Wengui[ is on the DHS no fly list? ]PRC Deputy Minister of Public Security Sun Lijun[ is very concerned that ]Guo Wengui[ will flee the US this week. I hope we can confirm and move to deportation. This will be an incredible step for our two countries. ]PRC Deputy Minister of Public Security Sun Lijun[ says they are grateful for your help." Steve Wynn's spouse responded, "This is with the highest levels of the state department and the defense department. They are working on this."

105. On or about June 29,2017, Elliott Broidy and DAVIS exchanged text messages regarding Guo Wengui's visa application. Elliott Broidy texted, "Is rejection or acceptance letter already generated?" DAVIS responded, "I have no idea." Elliott Broidy replied, "Sorry always generated. In others words each applicant eventually re wives a yes or no in writing]?[ Sorry receive a yes or no in writing]?[" DAVIS responded, "Yes].[ Check Wickr].["

106. On or about June 30, 2017, DAVIS, in reference to their efforts to facilitate the removal of Foreign National B and the potential return of United States citizens held in Country B, texted Elliott Broidy, "Wickr. You are the man right now. They are going to give you the President's medal of freedom award after what you will accomplish for this country this July 4th].[" Elliott Broidy responded, "I am going to slam until it's done(.]" DAVIS replied, "Let's make sure part 1 happens today. And date for m[.] Don 't leave that dude until we do it." Elliott Broidy responded, "Agree." DAVIS continued, "Let him know- if we get the letter confirming the denial today by close of business (as u need workers to generate that letter) then we will get the 2 Americans home by July 4(.[ After other phase 2- we can do the 60 take back(.]" Elliott Broidy responded, "Sounds good. [Steve Wynn] calling me back shortly. On a call."

107. On or about June 30, 2017, Elliott Broidy and DAVIS exchanged several text messages about Guo Wengui. Elliott Broidy texted, "Heard from [Steve Wynn]. He reiterated to POTUS." Elliott Broidy followed up with, "Separately, [Reince Priebus] texted me that he got tied up but is on top of it." That same date, DAVIS replied, "Can we get proof today about revoke?" DAVIS later specified, "From [Reince Priebus]?"

108. On or about July 1, 2017, Elliott Broidy texted DAVIS, "Spoke to [Reince Priebus] at length. Call me when you can(.[" Elliott Broidy did not speak with Reince Priebus but had exchanged text messages with him about Guo Wengui's visa application. Similar to the representations Elliott Broidy made in the memorandum that he prepared for the Attorney General and his communications with Steve Wynn, Elliott Broidy did not disclose the true nature of his relationship with PRC Deputy Minister of Public Security Sun Lijun to Reince Priebus.

109. On or about July 2, 2017, Elliott Broidy and DAVIS exchanged text messages regarding Guo Wengui and his visa application. Based on public reporting, DAVIS texted, "There is a call Scheduled for today Sunday with ]President of the PRC[ about n Korea. He can ask and confirm about package. He can even say he heard from ]Steve Wynn[."

110. On or about July 3, 2017, again based on public reporting, DAVIS texted Elliott Broidy: "]President[ leaves D.C. Wednesday for Europe].[" DAVIS then followed up: "July 5. Scheduled to meet in person w ]President of the PRC[].["

111. On or about July 18, 2017, Elliott Broidy emailed DAVIS the contact information for Steve Wynn. DAVIS connected multiple calls between PRC Deputy Minister of Public Security Sun Lijun and Steve Wynn in furtherance of the lobbying campaign to remove Guo Wengui.

112. On or about July 26, 2017, Elliott Broidy and DAVIS exchanged text messages regarding Guo Wengui and his removal from the United States to the PRC. Among the messages, DAVIS wrote, "Really need confirm it was officially transmitted. At this point- he says no].[" Elliott Broidy responded, "Asked 3 different people to follow up].[" Elliott Broidy later added, "Called ]Reince Priebus[. Seeing ]Steve Wynn[ in an hour."

113. On or about July 26, 2017, Elliott Broidy texted Steve Wynn to meet at a hotel in Washington, D.C., to discuss Guo Wengui: "Hi ]Steve Wynn[, I understand from staff that you're in DC, as am I, staying at the ]hotel[. Would you like to have a cup of coffee today? Regards, ][." Later the same day, Steve Wynn's spouse texted Elliott Broidy, "Hi ][. Can you text me the details again of the ]the PRC[ man you texted previously thank you].[" Elliott Broidy responded, "Hi ][, You are referring to ]Guo Wengui[ or ]PRC Deputy Minister of Public Security Sun Lijun[? Best, ][].[" Steve Wynn's spouse replied, "]Guo Wengui[." Elliott Broidy then resent the message that he previously sent on June 27.

114. On or about July 27, 2017, Elliott Broidy and DAVIS exchanged text messages regarding Guo Wengui. DAVIS texted Elliott Broidy, "Any word on embassy??" DAVIS later added, "Hey any update about formal notice?" Elliott Broidy responded, "I 'm dealing with people in NSC. Emailing directly. Awaiting response].["

115. On or about August 19, 2017, Elliott Broidy texted DAVIS several times. Among those messages, Elliott Broidy wrote, "Urgent. Call me. Good news].[" Elliott Broidy later added, "im with ]Steve Wynn[. have break thru opportunity].["

116. On or about August 19, 2017, Elliott Broidy met with Steve Wynn on Steve Wynn's yacht. During their time together, Elliott Broidy asked Steve Wynn about the matter involving Guo Wengui, and Steve Wynn suggested that they call the President. Elliott Broidy and Steve Wynn then called the President, asking about Guo Wengui's status within the United States.

117. On or about September 13, 2017, Elliott Broidy texted DAVIS, "Please text me asylum article. And other article].[" That same day, DAVIS texted Elliott Broidy links to articles about Guo Wengui.

118. On or about October 2, 2017, Elliott Broidy texted DAVIS a link to an article about Guo Wengui.

119. On or about January 5, 2018, Elliott Broidy texted DAVIS, "Send me more info on ]Guo Wengui[ involved in funding Dem politicians, ... ASAP].["

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