Case 0:17-cv-60426-UU Document 169 Entered on FLSD Docket 06/04/2018 Page 3 of 22
The dossier, which is a collection of memos written over a period of months,
includes specific, unverified, and potentially unverifiable allegations . . . .
BuzzFeed News reporters in the US and Europe have been investigating various
alleged facts in the dossier but have not verified or falsified them . . . [The
Dossier] is not just unconfirmed: It includes some clear errors.
Id. ¶ 3, D.E. 1-2, p. 20.
The Article stated that the Dossier had “circulated at the highest levels of the US
Government.” Id. It explained that a summary of the Dossier was shown to President Obama
and President-elect Trump. Id. Additionally, it asserted that Senators Harry Reid and John
McCain saw the Dossier and informed the FBI about it, although the FBI had copies of some of
the documents within Dossier before being contacted by the Senators. Id.
The Article cited and included a hyperlink to a CNN article: Evan Perez, et al., Intel
chiefs presented Trump with claims of Russian efforts to compromise him, CNN (Jan. 10, 2017),
https://www.cnn.com/2017/01/10/politics/donald-trump-intelligence-report-russia/index.html.
That article reported that four U.S. intelligence directors—Director of National Intelligence
James Clapper, FBI Director James Comey, CIA Director John Brennan, and NSA Director
Admiral Mike Rogers—presented a two-page synopsis of the Dossier to President Obama and
then President-elect Trump to brief them on the allegations in the Dossier. It also reported that
the FBI was investigating the credibility and accuracy of the allegations. Finally, it stated that
US intelligence agencies “checked out” the former British intelligence operative who compiled
the Dossier and “[found] him and his sources to be credible enough to include some of the
information in the presentations to the President and President-elect.” Id.
Plaintiffs allege that the Dossier’s statements about them are false. D.E. 1-3 ¶ 27.
Plaintiffs also allege that although BuzzFeed tasked its reporters with investigating the
allegations, Defendants never contacted Plaintiffs to determine whether the allegations that they
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