Today we filed a motion for summary judgment, memorandum of points and authorities, and two proposed orders in a FOIA case seeking records on an October 11, 2016 briefing which Christopher Steele gave at the State Department concerning his Steele dossier. This is the case in which the State Department released never-before-seen Kavalec emails proving that the FBI was on notice that the Steele dossier was politically motivated and highly unreliable, even before it was used to obtain the first FISA warrant against Carter Page.
Appended to our memorandum are four documents: Exhibit A — Declaration of Jeremiah L. Morgan; Exhibit B — Declaration of David N. Bossie; Exhibit C — House Permanent Select Committee on Intelligence Staff Report on Steele Dossier; and Exhibit D — Records produced in response to litigation.
The motion, memorandum, and Exhibits A and B are available here.
Exhibit C is available here.
Exhibit D is available here.
The proposed order seeking disclosure is available here.
The alternative proposed order seeing in camera review is available here.