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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.