diGENOVA & TOENSING, LLP
ATTORNEYS-AT-LAW
February 20, 2018
VIA: Hand Delivery and
‘The Hon, Jefferson B. Sessions IIT
Attorney General of the United States
950 Pennsylvania Ave., NW
Washington, DC 20530-0001
Re: Investigation of Department of Justice Officials
Dear Mr. Attorney General:
We write on behalf of our client, William Douglas Campbell, to request an investigation
of disclosures by anonymous “federal officials” to the media and of Congressional briefings by
“senior officials” of the Justice Department. The former provided false information about Mr.
Campbell to the media. The latter provided false information about Mr. Campbell to Senate and
House committee
Beginning in 2008, Mr. Campbell worked undercover for over five years providing
information to the U.S. government about corrupt Russian nuclear energy companies operating
here and abroad. He also exposed Russia’s long term energy strategy to dominate the world’s
uranium supply. Before 2008 he worked for decades for the CIA. Despite having knowledge of
Russia’s desire to make the U.S. dependent on foreign countries for uranium and of widespread
corruption within the Russian companies, the United States authorized the sale of Uranium One
{0 these companies in October 2010.
Anonymous federal officials: The leaks by federal officials, described as having
“detailed knowledge” of Mr. Campbell’s role as an undercover informant for the FBI, were
published on November 16, 2017 by Joel Schectman (Reuters) (App. 1) and on November 17,
2017 by Michael Isikoff (Yahoo News). (App. 2). Even if true, which they are not, the leaks
‘violate Department of Justice regulations.
A government official may not “allow the improper use of nonpublic information to
further his own private interest or that of another, whether through advice or recommendation,
or by knowing unauthorized disclosure.” 5 C.F-R. § 2635.703 (a) (emphasis added). “Nonpublic
information is information that the employee gains by reason of Federal employment and that he
knows or reasonably should know has not been made available to the general public.” Id, at (b).
1776 K STREET, NW - SUITE 737 - WASHINGTON, DC 20008,
202-289-7701 - 202-289-7706 (FACSMALE)The Hon. Jefferson B. Sessions TI
February 20, 2018
Page 2
The leaks were not only illegal but they were also false, intended to attack the credibility
of Mr. Campbell. As such they are libelous. The Reuters article quoted “[t}wo law enforcement
officials with direct involvement in the Rosatom [a corrupt Russian company] bribery case,”
claiming they had “no recollection or record of him mentioning the [Uranium One] deal during
their repeated interviews with him.” That claim is false, Mr, Campbell complained bitterly
when the Uranium One deal was made public and one of his FBI agent handlers told him the
decision was about “polities.” ‘Throughout the investigation, Mr. Campbell provided documents
to the FBI discussing Uranium One. (App. 3).
Citing federal officials, the Yahoo News article claimed Mr. Campbell was “so unreliable
that prosecutors dropped him as a witness in an unrelated case involving Russian uranium
sales...”
Significantly, the case was not “unrelated” but was the main target of the undercover
investigation. It was the indictment of Vadim Mikerin, Head of Uranium Directorate, ‘Tenex
(Moscow) and President of Tenam, USA, two of the corrupt Russian nuclear energy firms about
which Mr, Campbell had been providing evidence of bribes and kickbacks. Moreover, anyone
with knowledge of federal prosecution and national security knows that as a general rule the
government does not put an informant with over 30 years of undercover work for the CIA and
the FBI on the witness stand.' All his past undercover work would have to be revealed to
defense counsel
The Yahoo News article also repeated the same false claim of the Reuters article: that Mr.
Campbell neither discussed nor provided documents regarding Uranium One
‘Most importantly, the U.S. Attorney’s office for Baltimore mishandled the case. It filed a
Complaint without ever talking to Mr. Campbell. Then the office interviewed him and filed an
Indictment improperly claiming he was a “victim,” a term he never used when talking to the
prosecutor. As a matter of law, a willing informant is not a victim. ‘The wording of the
Indictment was not Mr. Campbell's responsibility.
If Mr. Campbell’s credibility was an issue, why did the FBI agents in charge of the case
commend him when they presented him with a check for over $50,000 in carly 2016 afterall the
defendants pled guilty? (App. 4).
On December 4, 2017, John Solomon published an article in The Hill describing his
discussion with a Justice Department official who stated the “leaks were not authorized by the
Justice Department and did not reflect accurately the official thinking of the department.” (App.
5). Thus, we thought the matter was over.
" Indeed, in 2008 in a case unrelated to Russian corruption and Uranium One, Mr. Campbell provided information
about a company’s involvement in certain financial crimes, which resulted in an indictment. The FBI worked with
the US, Attorney's office in Florida to frame the case so that Mr, Campbell did not have to be a witness ifthe case
went to trial‘The Hon, Jefferson B. Sessions IIT
February 20, 2018
Page 3
Senior Justice Department officials: So it came as a surprise that on December 15,
2017, after the Solomon article, “senior officials” briefed the Senate Judiciary and House
Intelligence and Oversight committees with the same false information that was leaked
anonymously to the media and later refuted by the Justice Department.
According to a February 6, 2018 letter from Reps. Adam Schiff and Elijah Cummings to
Chairmen Trey Gowdy and Devin Nunes (App. 6), these senior officials told House committee
staff that Mr, Campbell had “serious credibility concerns” because of “inconsistencies” between
his statement and documents prosecutors obtained.
We have been told that during the House briefing, DOJ “senior officials” complained that
Mr. Campbell was authorized to kick back only $35,000 in November 2009, but that he had paid
an additional $25,000 for a total of $60,000. All the payments came from Mr. Campbell’s own
pocket, specifically from his $50,000 monthly payments. Why would he want to pay more than
he was authorized?
We have documentary evidence that the legal documents the government filed in the
Mikerin case did not accurately reflect the amount of payments Mr. Campbell made and
recorded. Mr. Campbell provided the FBI with a copy of his July 1, 2009 contract, which clearly
states, “WISER [the company receiving the kickback] shall be paid half of the profit from” the
$50,000 monthly payments. (App.7A). (Emphasis added), Mr. Campbell also provided the FBI
a copy of the wire transfer document reflecting the $25,000 payment the “senior officials” claim
they knew nothing about. (App.7B).’ Moreover, Mr. Campbell gave unfettered access to all his
bank accounts to the FBI so they could verify all payments.
When the government filed its affidavit in support of Mikerin’s Complaint, the Agent
erroneously wrote that “Mikerin demanded that CS-1 [Mr. Campbell] kick back one-third of the
contract amount...” (App.7C). (Emphasis added). The error was not Mr. Campbell’s,
The “senior officials,” without any specificity, also falsely accused Mr, Campbell of
“engaging in illegal activity earlier than he initially disclosed,” claiming he “concealed” it from
the FBI However, since the 1980’s Mr. Campbell worked regularly for the CIA before being
tumed over to the FBI in 2008 for the Russian counterintelligence investigation. Mr. Campbell
contracted with Tenex in 2009 and was prepared to provide information to the U.S. government
about Russian nuclear energy programs during his relationship with the Russian entity. As soon
as he learned his contract was also a vehicle for kickbacks and corruption, he informed the FBI
of the criminal conduct. There was no “earlier” time when he was not reporting to the U.S.
government in the 2008-2009 timeframe.
Mr. Campbell was constantly involved in what can be described as illegal conduct, but it
was all at the direction of the FBI. And all of it was regularly reported to the FBI.
in the course of the investigation, Mr. Campbell provided the FBI copies ofall documentation of payments. App.
7B is a copy of the first payment, which is at issue.‘The Hon, Jefferson B. Sessions IIT
February 20, 2018
Page 4
Mr. Campbell began cooperating with the United States because he is a patriot who
desired to help his country. His cooperation placed him in peril from foreign actors who have
brutally murdered opponents who crossed them and who reminded him of that fact throughout
his undercover work. He worked throughout a cancer diagnosis and treatment of a brain tumor
in 2011, And he is now cooperating through a second cancer diagnosis of leukemia and
debilitating chemotherapy.
The Department of Justice has not reciprocated his dedication. First, it negligently
disclosed Mr. Campbell's undercover participation in a public filing, making him unemployable
in the industry and leaving him to survive on Social Security. Now, in response to his going
public to reveal a significant matter of national security, “senior officials” are covertly and
overtly maligning Mr, Campbell for telling the truth. ‘The illegal conduct of these officials is,
appalling and we ask it be investigated and those responsible be held accountable,
Sincerely,
A 3
A
Victoria Toenging
Joseph E. diGenova
Counsel for Willianr Campbell
Ce: Michael Horowitz
Charles Grassley
Dianne Feinstein
Devin Nunes
Adam Schiff’
Trey Gowdy
Elijah Cummings