Inspector General report on the Crossfire Hurricane investigation

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Review of Four FISA Applications and Other Aspects of the FBI's Crossfire Hurricane Investigation is a report by the United States Department of Justice Office of the Inspector General which was released on December 9, 2019 by Inspector General Michael E. Horowitz.[1][2] The report reviewed the Crossfire Hurricane investigation by the Federal Bureau of Investigation (FBI), which looked into whether people associated with the Donald Trump 2016 presidential campaign coordinated with Russian interference in the 2016 United States elections.[3]

Several issues examined by the report were: the origins of the Crossfire Hurricane investigation, the FBI's usage of reports from Christopher Steele, the FBI's applications to the Foreign Intelligence Surveillance Court to surveil former Trump campaign adviser Carter Page, and the FBI's use of confidential human sources as part of the investigation, among other issues.[4]

Basis of the report[]

In July 2016, the Crossfire Hurricane investigation was started by the Federal Bureau of Investigation (FBI). The investigation looked into whether people associated with the Donald Trump 2016 presidential campaign coordinated with Russian interference in the 2016 United States elections.[3]

On March 18, 2018, Department of Justice Inspector General Michael Horowitz announced that his office would initiate a review in response to requests from the Attorney General Jeff Sessions and members of Congress.[5][6] This announcement came in the wake of allegations by conservative politicians of misconduct by the FBI and the United States Department of Justice (DOJ). The Republican Party's Nunes memo alleged that the DOJ and FBI abused the Foreign Intelligence Surveillance Act (FISA) in their applications to the Foreign Intelligence Surveillance Court (FISC) to surveil Carter Page, a former member for the 2016 Trump campaign. The Nunes memo also alleged that it was not disclosed that the Steele dossier used to justify the applications was indirectly funded in part by the Hillary Clinton 2016 presidential campaign, and that the dossier had unconfirmed information.[6][7] President Donald Trump criticized Sessions' decision to have Horowitz lead the review, calling it "DISGRACEFUL" as he labelled Horowitz "an Obama guy".[6]

The report was based on a review of over 1 million Justice Department and FBI documents, as well as 170 interviews of over 100 witnesses.[8]

The Office of Inspector General (OIG) does not have the power to subpoena individuals who are not current employees of the government.[9][10] As such, the investigation were unable to interview Glenn Simpson of the company Fusion GPS, as well as ex-Department of State employee , because they denied interview requests by the OIG.[11]

The OIG also does not have the power to prosecute individuals, but is limited to making criminal referrals to the Department of Justice.[12]

Findings[]

Origins of Crossfire Hurricane[]

The Inspector General stated that the review did not find evidence that "political bias or improper motivation influenced" the opening of the Crossfire Hurricane investigation.[3] It was also determined that the opening of the overall investigation "was in compliance" with policies set by the FBI and the Department of Justice.[13] Likewise, the review did not produce evidence that "political bias or improper motivation influenced the decisions to open the four individual investigations" of George Papadopoulos, Paul Manafort, Michael Flynn and Carter Page, who were either associated or formerly associated with Donald Trump's 2016 presidential campaign.[14]

The review found that there was an "authorized purpose" and "adequate factual predication" for launching the Crossfire Hurricane investigation.[4][15] It was confirmed that the investigation was opened due to information shared by a foreign government on George Papadopoulos, which indicated that Papadopoulos was aware of Russia's possession and potential release of information damaging to Trump's rival presidential candidate Hillary Clinton.[14][16] Meanwhile, information provided by Christopher Steele was confirmed to have "played no role" in the investigation's opening.[17] The information on Papadopoulos, which "reasonably indicated activity constituting either a federal crime or a threat to national security" may have happened, "was sufficient to predicate the investigation" given the "low threshold" needed to open such an investigation.[16]

FISA applications[]

While the review did not find evidence that "political bias or improper motivation influenced the FBI's decision to seek FISA authority on Carter Page", it did find 17 "significant inaccuracies and omissions" in the FBI's four FISA applications made to the Foreign Intelligence Surveillance Court to obtain warrants for the surveillance of Page.[2][4] According to the Inspector General, "serious performance failures" reflected badly on "the FBI chain of command's management and supervision" of the FISA processes.[18] The report specifically highlighted the FBI's reliance on information provided by former British intelligence officer Christopher Steele, finding that these reports played a crucial role in justifying surveillance of Page, but that, after gathering information that called Steele's reliability into question, the FBI failed to properly disclose the issues with his reports.[4]

In the FISA applications, there was an omission of information that Carter Page had been an "operational contact" for another government agency from 2008 to 2013, and that Page had reported to the CIA about his communications with Russian intelligence officers.[19][20] This information was provided by the CIA to the FBI in August 2016.[20] Page has since stated that the agency was the Central Intelligence Agency (CIA).[19] Instead, the FBI claimed that Page had a "dated" relationship with the CIA in 2007 or earlier.[21] The FBI also labelled a meeting between Page and Russian official(s) as suspicious activity to justify the application, while omitting mention that Page had already disclosed information about the meeting to the American government agency.[22]

In a FISA application, Kevin Clinesmith, a lawyer for the FBI, altered an email from the CIA to say that Page was "not a source" for the CIA, despite the CIA representative stating that Page was a direct source of information to the agency.[20][22][23] As a result, the Department of Justice did not approach the CIA to determine Page's connection to them.[22] On August 14, 2020, Clinesmith pleaded guilty to a felony violation of altering an email used to maintain Foreign Intelligence Surveillance Act (FISA) warrants. He changed an email to omit the fact that Carter Page had a prior operational relationship with the CIA from 2008 to 2013.

The judge at his plea hearing asked Clinesmith if, when he added “and not a source” to the email, that he knew it was “in fact not true.” There followed a prolonged, awkward silence. Finally, Clinesmith told the court: “At the time I thought the information I was providing was accurate, but I am agreeing the information I inserted was not originally there, and I inserted the information.”

[24][25]

There was an assertion by the FBI to the court that previous information from Christopher Steele had been "corroborated and used in criminal proceedings", when in actuality, the OIG reported that Steele's reporting "was never used in a criminal proceeding", while a group within the FBI had reviewed Steele's past work as "minimally corroborated".[21][23] Also there was an omission of information that discrepancies between Steele's statements and those of some sources "raised doubts about the reliability"[10] of some of Steele's reporting to the FBI.[21][26]

Use of confidential human sources[]

The Inspector General determined that the FBI had "several" confidential sources "with either a connection to candidate Trump or a role in the Trump campaign".[27][28][29] These sources were "not tasked as part of" the Crossfire Hurricane investigation by the FBI, concluded the Inspector General.[27][30] One of these FBI sources "held a position in the Trump campaign", but this source did not inform the FBI about their role until they had left the campaign, according to the Inspector General.[27][29]

The Inspector General wrote that his review "found no evidence that the FBI attempted to place any" FBI source in the Trump campaign.[31][32] The review also "found no evidence" that the FBI had tried to "recruit members of the Trump campaign" to serve as their sources.[32] Finally, the review did not produce evidence that "political bias or improper motivations influenced" the FBI's usage of confidential sources or undercover agents for interactions with members of Trump's campaign.[31]

It also emerged that one of the sources who provided information to the FBI was a Trump supporter, as were the FBI employees handling this source. These FBI employees exchanged pro-Trump and anti-Clinton text messages.[8][32]

Reactions[]

After the report was released, Attorney General William Barr rejected the report's key conclusion that Crossfire Hurricane was justified.[33] Barr opined that the Crossfire Hurricane investigation was launched "on the thinnest of suspicions that, in my view, were insufficient to justify the steps taken. It is also clear that, from its inception, the evidence produced by the investigation was consistently exculpatory."[4]

U.S. Attorney John Durham, who was conducting a similar investigation at the behest of Barr, also disagreed with the report's findings, stating that: "Based on the evidence collected to date, and while our investigation is ongoing, last month we advised the Inspector General that we do not agree with some of the report's conclusions as to predication and how the FBI case was opened."[4] After Durham's statement received significant criticism, Barr said the statement "was necessary to avoid public confusion" because the media was reporting "that the issue of predication was sort of done and over".[34]

After the report's release, Horowitz attributed the warrant problems to "gross incompetence and negligence" rather than intentional malfeasance or political bias,[35] and stated: "The activities we found don't vindicate anyone who touched this. The actions of FBI agents were not up to the standards of the FBI." in a Senate hearing[36] As a result of the findings, Horowitz announced a broader review of the FBI's FISA warrant application process, to study whether problems with the process are systemic.[37] Horowitz reacted to Barr and Durham's statements in congressional testimony by stating that his office stands by their finding. Horowitz expressed surprise at Durham's statement, and in subsequent testimony stated his view that conclusions should not be announced until an investigation is complete.[38] Horowitz testified that he had met Durham in November 2019 and requested from Durham any information relevant to the review by his office. Horowitz also testified that he was not given information by Barr or Durham that would change his finding that the investigation was justified.[38][39] According to Horowitz, Durham's opinion at the time of their meeting was that the information on Papadopoulos was "sufficient to support [a] preliminary investigation", but not necessarily the "full counterintelligence investigation" that Crossfire Hurricane was.[38] A preliminary investigation allows the FBI to use confidential human sources, but not the court-ordered surveillance which Carter Page was subjected to.[39]

James Comey, who had been the FBI Director during the Crossfire Hurricane investigation, claimed in a Washington Post op-ed and on cable news shows that he was vindicated by the report's findings.[40] In subsequent congressional testimony, when asked whether the report vindicates Comey, Horowitz said that it "doesn't vindicate anyone at the FBI who touched this, including the leadership". Horowitz also stated that it would be "fair" to wonder how the 17 events in the FISA applications his office discovered "could be purely incompetence".[41] Comey later responded to the report's findings of 17 "significant errors and omissions" made by the FBI in the FISA applications involving Page and conceded that he had been wrong: Horowitz "was right, I was wrong. I was overconfident, as director, in our procedures."[42] He admitted that members of the FBI were sloppy and that the Horowitz report did find "mistakes and negligence",[43] but staunchly defended the FBI and criticized Trump's attacks on investigators.[44] In an op-ed published in the Washington Post, Comey wrote: "the truth is finally out, ... and those who smeared the FBI are due for an accounting" and called upon Attorney General Barr to "acknowledge the facts" and "stop acting like a Trump spokesperson."[45][46]

Foreign Intelligence Surveillance Court presiding judge Rosemary Collyer reacted to the report by stating that it "calls into question whether information contained in other FBI applications [to the Foreign Intelligence Surveillance Court] is reliable." Judge Collyer ordered the FBI to explain how the FBI will address problems with the FISA process that were uncovered by the report.[47] On January 10, 2020, the FBI responded to the court by providing a list of 12 changes to procedures regarding its applications to the court, which included having more training, and improving checklists. This response was released to the public.[48] The court subsequently appointed David S. Kris, a former senior official in the Obama administration and an expert on FISA, to advise the court on the proposed changes in the FBI's procedures.[49][50] On January 15, 2020, Kris filed a 15-page brief with the court in which he stated that the proposed changes do not appropriately address the problems uncovered by the IG report.[51][52]

FBI director Christopher A. Wray said he accepted the OIG's findings and had "ordered more than 40 corrective steps to address the Report's recommendations", and added it was "important that the inspector general found that, in this particular instance, the investigation was opened with appropriate predication and authorization".[53] Trump responded by attacking Wray by name on Twitter.[54]

See also[]

References[]

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  2. ^ a b Holden, Dominic (December 9, 2019). ""No Evidence": An Official Probe Has Debunked Trump's Claim The FBI Planted A Spy In His Campaign". Buzzfeed News. Archived from the original on December 11, 2019. Retrieved December 30, 2019.
  3. ^ a b c Berenson, Tessa (December 9, 2019). "Inspector General Finds FBI Probe into Trump Campaign Was Justified, But Not Perfect". Time. Archived from the original on December 11, 2019. Retrieved December 30, 2019.
  4. ^ a b c d e f Barrett, Devlin; Zapotosky, Matt; Demirjian, Karoun; Nakashima, Ellen; Helderman, Rosalind (December 9, 2019). "FBI was justified in opening Trump campaign probe, but case plagued by 'serious failures,' inspector general finds". The Washington Post. Archived from the original on December 9, 2019. Retrieved December 30, 2019.
  5. ^ "DOJ OIG Announces Initiation of Review" (PDF) (Press release). Office of the Inspector General. March 28, 2018. Archived (PDF) from the original on January 18, 2020. Retrieved December 30, 2019.
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  9. ^ Lynch, Sarah (December 10, 2019). "U.S. Attorney General Barr says FBI may have acted in 'bad faith' on Russia probe". Reuters. Archived from the original on December 14, 2019. Retrieved December 31, 2019. Durham’s probe is broader than Horowitz’s mandate because it involves talking to multiple U.S. intelligence agencies, such as the CIA, and foreign powers. Durham, unlike Horowitz, also has the power to subpoena non-government witnesses and talk to people who are not Justice Department employees.
  10. ^ a b Office of the Inspector General U.S. Department of Justice (December 9, 2019). "Review of Four FISA Applications and Other Aspects of the FBI's Crossfire Hurricane Investigation" (PDF). justice.gov. Archived (PDF) from the original on December 11, 2019. Retrieved December 9, 2019. The OIG would have directly benefited from the ability to subpoena former government and non-government individuals in this review. In addition to being able to compel the testimony of the small number of individuals who did not testify voluntarily, the ability to subpoena witnesses would have expedited completion of the review, as multiple individuals only agreed to interviews at a late stage in the review.
  11. ^ Saunders, Debra (December 9, 2019). "Justice Department report find errors, but no political bias". Las Vegas Review-Journal. Archived from the original on January 14, 2020. Retrieved January 14, 2020.
  12. ^ Date, Jack (June 1, 2018). "The man who investigates the investigators, DOJ Inspector General Michael Horowitz". ABC News. Archived from the original on December 12, 2019. Retrieved December 31, 2019. While the inspector general lacks prosecutorial powers, he can identify possible criminal behavior and refer it for prosecution.
  13. ^ Breuninger, Kevin (December 11, 2019). "DOJ watchdog Horowitz says FBI's conduct in Trump-Russia probe doesn't 'vindicate anybody'". CNBC. Archived from the original on December 18, 2019. Retrieved December 30, 2019.
  14. ^ a b Chalfant, Morgan; Samuels, Brett (December 9, 2019). "Watchdog report finds FBI not motivated by political bias in Trump probe". The Hill. Archived from the original on December 17, 2019. Retrieved December 30, 2019.
  15. ^ Farivar, Masood (December 11, 2019). "FBI Russia Probe Report Exposes Deep Fissures in Trump Administration". Voice of America. Archived from the original on December 12, 2019. Retrieved December 30, 2019.
  16. ^ a b Mallin, Alexander; Kim, Soo Rin (December 10, 2019). "DOJ watchdog finds Russia investigation not improper, despite missteps". ABC News. Archived from the original on December 9, 2019. Retrieved December 30, 2019.
  17. ^ Cummings, William (December 10, 2019). "Ex-British spy Christopher Steele and Ivanka Trump were 'personal' friends for years, reports say". USA Today. Archived from the original on December 10, 2019. Retrieved December 30, 2019.
  18. ^ Ryan, Barber (December 9, 2019). "'Serious Performance Failures,' But No Anti-Trump Bias: Read the DOJ Watchdog's Report". The National Law Journal. Archived from the original on December 30, 2019. Retrieved December 30, 2019.
  19. ^ a b Kessler, Glenn (December 11, 2019). "A guide to the misleading spin on the IG report". The Washington Post. Archived from the original on December 17, 2019. Retrieved January 17, 2020.
  20. ^ a b c Harris, Shane; Leonnig, Carol; Helderman, Rosalind (December 9, 2019). "In opening an investigation of the Trump campaign, the FBI felt it had reached a 'tipping point,' IG finds". The Washington Post. Archived from the original on December 11, 2019. Retrieved January 17, 2020.
  21. ^ a b c Viswanatha, Aruna; Gurman, Sadie; Tau, Byron (December 9, 2019). "Justice Watchdog Highlights FBI 'Failures' but Says Russia Probe Was Justified". The Wall Street Journal. Archived from the original on January 19, 2020. Retrieved January 19, 2020.
  22. ^ a b c Savage, Charlie; Goldman, Adam; Benner, Katie (December 9, 2019). "Report on F.B.I. Russia Inquiry Finds Serious Errors but Debunks Anti-Trump Plot". The New York Times. Archived from the original on December 9, 2019. Retrieved January 19, 2020.
  23. ^ a b Dilanian, Ken; Williams, Pete; Ainsley, Julia (December 10, 2019). "Internal Justice watchdog finds that Russia probe was justified, not biased against Trump". NBC News. Archived from the original on December 17, 2019. Retrieved January 19, 2020.
  24. ^ Kalmbacher, Colin. Here’s What We Know About ‘FBI Attorney 2’ Kevin Clinesmith, the First Person Charged in Durham Probe, Law & Crime, August 14, 2020.
  25. ^ Katelyn Polantz and David Shortell. "Former FBI lawyer set to plead guilty to altering email during Russia investigation". CNN.
  26. ^ Shane, Scott (December 9, 2019). "Report Details Interactions Between F.B.I. and Dossier Author". The New York Times. Archived from the original on December 12, 2019. Retrieved January 19, 2020.
  27. ^ a b c Kiely, Eugene; Robertson, Lori; Farley, Robert (December 10, 2019). "How Old Claims Compare to IG Report". FactCheck.org. Archived from the original on December 17, 2019. Retrieved December 30, 2019. Lastly, the report said it learned that the FBI had "several other" confidential sources "with either a connection to candidate Trump or a role in the Trump campaign." But they “were not tasked as part of the" investigation. [...] Another FBI source "held a position in the Trump campaign," but did not tell the FBI about his or her role until after leaving the campaign.
  28. ^ Cournoyer, Caroline; Herridge, Catherine; Watson, Kathryn; Quinn, Melissa (December 11, 2019). "Horowitz defends his Trump-Russia report but is "deeply concerned" about FBI's surveillance failures". CBS News. Archived from the original on December 17, 2019. Retrieved December 30, 2019. While the FBI had "several" confidential sources with "either a connection to candidate Trump or a role in the Trump campaign," Horowitz ...
  29. ^ a b Bertrand, Natasha; Samuelsohn, Darren (December 9, 2019). "Inspector general's report on Russia probe: Key takeaways". Politico. Archived from the original on December 12, 2019. Retrieved December 30, 2019. In 2016, "the FBI had several other" confidential human sources [CHS] "with either a connection to candidate Trump or a role in the Trump campaign," Horowitz found. [...] Another was a member of the Trump campaign, but didn’t inform his handler about his role there until after he’d already left the campaign [...] But Horowitz’s report notes that key figures including agents and sources were actually supportive of Trump
  30. ^ Oprysko, Caitlin (December 9, 2019). "Here are the Russia probe conspiracy theories debunked by the DOJ inspector general report". Politico. Archived from the original on December 18, 2019. Retrieved December 30, 2019. Horowitz wrote: "Although the Crossfire Hurricane team was aware of these CHSs during the 2016 presidential campaign, we were told that operational use of these CHSs would not have furthered the investigation, and so these CHSs were not tasked with any investigative activities."
  31. ^ a b Bump, Philip (December 9, 2019). "What Trump claimed about the Russia probe — and what the Justice Department inspector general determined". The Washington Post. Archived from the original on December 27, 2019. Retrieved December 30, 2019. We found no evidence that the FBI used CHSs" — confidential human sources — "or UCEs" — undercover employees — "to interact with members of the Trump campaign prior to the opening of the Crossfire Hurricane investigation," the report states. “After the opening of the investigation, we found no evidence that the FBI placed any CHSs or UCEs within the Trump campaign or tasked any CHSs or UCEs to report on the Trump campaign." Horowitz’s investigators also "found no documentary or testimonial evidence that political bias or improper motivations influenced the FBI's decision to use CHSs or UCEs to interact with Trump campaign officials in the Crossfire Hurricane investigation.
  32. ^ a b c Blake, Aaron (December 9, 2019). "4 takeaways from the Horowitz report on the Russia investigation". The Washington Post. Archived from the original on December 9, 2019. Retrieved December 30, 2019. Third, it addresses allegations that the FBI planted an informant in the Trump campaign, saying "we found no evidence that the FBI attempted to place any CHSs within the Trump campaign, recruit members of the Trump campaign as CHSs, or task CHSs to report on the Trump campaign." [...] One supervisory special agent (SSA) describes believing a confidential human source’s (CHS) information because the source was a Trump backer ... But it turns out that not only was the source a Trump supporter, so too were the agents involved in cultivating him.
  33. ^ Edelman, Adam (December 10, 2019). "AG Barr condemns IG report's finding that FBI probe of Trump campaign was justified". NBC News. Archived from the original on December 12, 2019. Retrieved December 31, 2019.
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  36. ^ Del Quentin Wilber (December 11, 2019). "Justice Department watchdog pushes back at critics of his findings on the Russia probe". Los Angeles Times.
  37. ^ Barrett, Devlin; Zapotosky, Matt; Demirjian, Karoun; Nakashima, Ellen (December 9, 2019). "FBI was justified in opening Trump campaign probe, but case plagued by 'serious failures,' inspector general finds". Washington Post.
  38. ^ a b c Gerstein, Josh; Bertrand, Natasha (December 11, 2019). "Horowitz pushes back at Barr over basis for Trump-Russia probe". Politico. Archived from the original on December 14, 2019. Retrieved December 30, 2019.
  39. ^ a b Gurman, Sadie; Tau, Bryon (December 11, 2019). "Justice Watchdog Testifies About Disagreement With Attorney General Over Report on FBI's Russia Probe". The Wall Street Journal. Archived from the original on December 12, 2019. Retrieved December 31, 2019.
  40. ^ Blake, Aaron (December 11, 2019). "6 takeaways from the Michael Horowitz hearing". The Washington Post. Archived from the original on December 16, 2019. Retrieved January 1, 2020. Former FBI director James B. Comey did a victory lap after Horowitz's report was released Monday, authoring a Washington Post op-ed and going on cable news, where he claimed that he was vindicated by Horowitz's finding that the Russia investigation and investigations of four Trump campaign officials were legitimate.
  41. ^ Barrett, Devlin; Zapotosky, Matt; Demirjian, Karoun (December 11, 2019). "Inspector general says the FBI is not vindicated by his report on Trump campaign probe". The Washington Post. Archived from the original on December 18, 2019. Retrieved January 1, 2020.
  42. ^ Sheth, Sonam (December 15, 2019). "'He was right, I was wrong': Former FBI Director James Comey says he was wrong to defend FBI's use of the FISA surveillance process". Business Insider. Archived from the original on December 17, 2019. Retrieved December 25, 2019.
  43. ^ Fearnow, Benjamin (December 15, 2019). "'I Was Wrong': Former FBI Director James Comey Admits FISA Overstep, Doubles Down on Steele Dossier". Newsweek. Archived from the original on December 18, 2019. Retrieved December 25, 2019.
  44. ^ Michael D. Shear, Comey Admits Errors in Surveillance Warrants, but Defends F.B.I., New York Times (December 15, 2019).
  45. ^ James Comey: The truth is finally out. The FBI fulfilled its mission, Washington Post (December 9, 2019).
  46. ^ Justice Coleman, Comey in op-ed after IG report: 'Barr needs to stop acting like a Trump spokesperson', The Hill (December 9, 2019).
  47. ^ Williams, Pete (December 17, 2019). "Secret FISA court issues highly unusual public rebuke of FBI for mistakes". NBC News. Archived from the original on December 18, 2019. Retrieved December 30, 2019.
  48. ^ Savage, Charlie (January 10, 2020). "F.B.I. Apologizes to Court for Botching Surveillance of Trump Adviser, and Pledges Fixes". The New York Times. Archived from the original on January 17, 2020. Retrieved January 16, 2020.
  49. ^ Barrett, Devlin (January 10, 2020). "FBI assures foreign intelligence court it will tighten standards". The Washington Post. Archived from the original on January 11, 2020. Retrieved January 17, 2020. The FISA court also appointed a former senior Justice Department official, David Kris, to advise the court on the steps the FBI is taking.
  50. ^ Barrett, Devlin (January 15, 2020). "Surveillance court adviser says FBI's changes don't go far enough to fix problems". The Washington Post. Archived from the original on January 17, 2020. Retrieved January 17, 2020. David Kris, who as a senior official in the Obama administration oversaw the Justice Department’s work with the court, was tasked last week with advising its judges on steps the FBI has vowed to take since an inspector general’s report found 17 significant errors and omissions in its applications in 2016 and 2017 to monitor former Trump adviser Carter Page.
  51. ^ Barrett, Devlin (January 15, 2020). "Surveillance court adviser says FBI's changes don't go far enough to fix problems". The Washington Post. Archived from the original on January 17, 2020. Retrieved January 17, 2020. Kris said Wray’s actions “point in the right direction, but they do not go far enough to provide the Court with the necessary assurance of accuracy, and therefore must be expanded and improved,” he wrote in a letter to the court.
  52. ^ Savage, Charlie (January 16, 2020). "F.B.I.'s Proposals to Fix Surveillance Fall Short, Expert Tells FISA Court". The New York Times. Archived from the original on January 17, 2020. Retrieved January 17, 2020. Steps that the bureau listed in a filing last week fail to adequately ensure that judges receive a complete and accurate portrait of the facts about suspects before deciding whether to let the F.B.I. invade their privacy, David S. Kris, an expert in the Foreign Intelligence Surveillance Act, or FISA, told the court in a 15-page brief. "The F.B.I.'s proposed corrective actions are insufficient and must be expanded and improved in order to provide the required assurance to the court," Mr. Kris wrote.
  53. ^ Barrett, Devlin; Zapotosky, Matt; Demirjian, Karoun; Nakashima, Ellen (December 9, 2019). "FBI was justified in opening Trump campaign probe, but case plagued by 'serious failures,' inspector general finds". Washington Post.
  54. ^ Allie Malloy, Trump lashes out at FBI chief Wray for embracing watchdog report, CNN (December 10, 2019).

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