PAGE v. COMEY: The FBI in 2014 did a directive in Virginia and other places ALL Public Corruption to be investigated by DC FBI the Cover- Up begins

COMPLAINT
1. On November 10, 2020, Defendant Andrew McCabe testified in front of the Senate
Judiciary Hearing that “any material misrepresentation or error in a FISA application is
unacceptable. Period. The FBI should be held to the standard of scrupulous accuracy that the
[FISA] court demands.” When pushed to explain “Who is responsible for ruining Mr. Carter
Page’s life?” McCabe finally responded, “We are all responsible for the work that went into that
FISA.” This lawsuit seeks that accountability and damages against the individuals and agencies
who wronged Plaintiff, Carter W. Page (“Dr. Page”).
2. Specifically, Dr. Page seeks relief herein for Defendants’ multiple violations of his
Constitutional and other legal rights in connection with unlawful surveillance and investigation of
him by the United States Government. Dr. Page was targeted because of his lawful association
with the 2016 Presidential campaign of Donald Trump. Dr. Page is entitled to relief for
Defendants’ unjustified and illegal actions (including violations of federal criminal law), which
violated federal statutes enacted to prevent unlawful spying on United States persons, as well as
the Constitution.

3. The complained of misconduct occurred in connection with the submission of four
false and misleading warrant applications to engage in electronic surveillance of Dr. Page,
ostensibly pursuant to the Foreign Intelligence Surveillance Act (“FISA”). Four separate Article
III judges unwittingly approved the false applications, submitted in October 2016, January 2017,
April 2017, and June 2017, thereby unlawfully resulting in spying on Dr. Page. As has now been
admitted by (i) the U.S. Department of Justice (“DOJ”), (and (ii) the Federal Bureau of
Investigation (“FBI”), and/or has been acknowledged by (iii) the Foreign Intelligence Surveillance
Court (“FISC”), the four separate applications for FISA warrants and renewals (collectively, the
“FISA Warrants”1
) to surveil Dr. Page were submitted despite there being no probable cause to
suspect that Dr. Page was acting as a Foreign Agent of Russia. Consequently, the Defendants’
unlawful actions allowed them to illegally spy (domestically and internationally) on Dr. Page, a
patriotic American citizen.
4. The Defendants’ conduct, which began not later than August 2016, and continued
through at least September 2017, constituted a fraud on the FISC and violated the Constitutional
and other rights of Dr. Page.
I. OVERVIEW OF THE VIOLATIONS
5. On July 31, 2016, the FBI opened a counterintelligence investigation named
Operation Crossfire Hurricane, putatively concerning the Foreign Agent Registration Act (FARA),
to determine whether “individual(s) associated with the Trump campaign are witting of and/or
coordinating activities with the Government of Russia.” Soon thereafter, Dr. Page and three other
individuals with whom he had little or no relationship were targeted by the FBI in the Crossfire
Hurricane investigation.
6. The FBI investigation soon devolved into an effort to obtain from the FISC a FISA
warrant authorizing spying and electronic surveillance on Dr. Page.
7. The FBI did not have probable cause to lawfully obtain a FISA warrant. Instead,
the FBI used documents furnished by Christopher Steele, a Confidential Human Source (“CHS”).
As the Crossfire Hurricane team knew, CHS Steele had been paid by the Democratic Party and/or
the Hillary Clinton presidential campaign to perform “political opposition research” and dig up
dirt on a connection between the Trump campaign and Russia in order to divert attention from the
investigation of Clinton’s email practices while she was Secretary of State.
8. In accordance with core principles of the U.S. Constitution, reinforced by the
nation’s legal and cultural aversion to spying on its citizens, Congress and the executive branch
have enacted rigorous requirements that must be met before electronic surveillance of a U.S.
citizen is legally permitted. To surveil an American citizen, the FISA requires that there be
probable cause that the target is an “agent of a foreign power” who is “knowingly engag[ing]…in
clandestine intelligence activities.” In short, to legitimately obtain a FISA warrant against Dr.
Page, the FBI had to demonstrate that he was a Russian agent who was knowingly engaging in
intelligence activities on behalf of Russia.
9. On August 17, 2016, shortly after the inception of the Crossfire Hurricane
investigation, the Central Intelligence Agency (“CIA”), provided information regarding Dr. Page
to members of the Crossfire Hurricane team. This information established that Dr. Page had been
a CIA “operational contact” from 2008 – 2013 (and had similar interactions with the FBI).
Dr. Page had assisted the CIA in combatting intelligence-related activities pursued by Russia and
other foreign countries against the United States’ interests. Further, the CIA’s employee had given
a positive assessment of Dr. Page’s candor. Further, on September 7, 2016, the CIA sent an
investigative referral to FBI Director James Comey and Deputy Assistant Director of
Counterintelligence Peter Strzok advising them that Hillary Clinton had approved a plan
concerning U.S. Presidential candidate Donald Trump and Russian hackers hampering U.S.
elections as a means of distracting the public from her use of a private mail server. (Letter of
Director of National Intelligence, dated September 29, 2020.)
10. During this same investigative phase, the FBI used a second CHS to surreptitiously
ask Dr. Page about his activities. In this monitored conversation, Dr. Page denied that he either:
(i) knew anything about improper or unlawful communications or activities between Russian and
American citizens, or (ii) had engaged in any improper—much less illegal—activity with any
individual that was harmful to the interests of the United States. This conversation was recorded
without Dr. Page’s knowledge and was provided to the FBI.
11. On September 19, 2016, as referenced above, the FBI received information
regarding Dr. Page from CHS Steele. In particular, two documents, prepared by CHS Steele,
falsely alleged unlawful communications and activities involving Dr. Page and two Russians with
close ties to Russian President Vladimir Putin. The FBI “focused on” these two documents from
Steele to base its claim that there was probable cause to obtain a FISA warrant against Dr. Page.
12. On September 23, 2016, an article was published in YAHOO! NEWS alleging
meetings between Dr. Page and the same two Russian individuals. The FBI treated this article as
corroboration for CHS Steele’s claims when, in fact, Steele was also the source for the Yahoo
article. Further, on September 25, 2016, Dr. Page sent a letter to then-FBI Director Comey in
which he categorically denied that he had any such communications with the Russian individuals
and documented his previous cooperation with the CIA and the FBI to combat Russian spying.
These false allegations against Dr. Page made by CHS Steele were not investigated by the FBI in
accordance with its own manuals and procedures. For the FBI to disregard its procedures was
particularly egregious in this case because the FBI knew that CHS Steele: (a) was being paid to
provide political “opposition research” on this topic; (b) was essentially the exclusive source of
information supporting probable cause for the FISA warrant applications, and (c) the CIA had
warned the FBI of a potential political scheme involving false reporting of collaboration between
the Trump campaign and Russians.
13. The more fundamental problem was that the FBI was so intent on obtaining a FISA
warrant to enable it to spy on the Trump campaign that it did not fully and accurately disclose to
the FISC the evidence it had obtained as to whether Dr. Page was a Russian agent. To persuade
the FISC that there was probable cause to believe that Dr. Page was a Russian agent, the
Defendants provided false or misleading information to the FISC.
14. The FBI did not advise the FISC that Page had been for many years an “operational
contact” of the CIA. The FBI did not advise the FISC that CHS Steele had been paid by the
Democrat party and/or the Clinton campaign to provide opposition research on Donald Trump.
The FBI did not advise the FISC that Steele’s source (“Primary Sub-source") of information
against Dr. Page had himself been investigated for attempting to recruit Americans to help spy for
Russia. The FBI did not advise the FISC that Steele’s Primary Sub-source contradicted critical
information that Steele attributed to him. Instead, the FBI represented to the FISC that the Primary
Sub-source was “credible,” without disclosing to the FISC that what the Primary Sub-Source had
“credibly” reported to the FBI was that the information Steele attributed to him was inaccurate and
misleading.
15. Ultimately an FBI attorney altered an email from the CIA in order to falsely deny
that Dr. Page had been a CIA source serving for many years as an operational contact.
16. In reality, there was no “probable cause” to support surveillance of Dr. Page. If FBI
procedures had been followed and an honest and thorough investigation conducted, and if the FBI
had fully and accurately reported what it knew, the FISA warrants against Dr. Page would neither
have been sought nor issued.
17. The individual Defendants fabricated or intentionally disregarded critical evidence,
and misled the FISC, in order to obtain the FISA warrants. This case is about holding accountable
the entities and individuals who are responsible for the most egregious violation and abuse of the
FISA statute since it was enacted over forty years ago.

to read more: https://www.courtlistener.com/recap/gov.uscourts.dcd.224507/gov.uscourts.dcd.224507.1.0.pdf