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APPROVED FOR PUBLIC RELEASE BY COUNSEL TO THE PRESIDENT WARRINGTON on 10 July 2026

From: (5) (8)

Sent: Tuesday, November 16, 2021 4:22 PM
To: (DE) (FBI)
Subject: Fwd

Just so you're aware, I sent the below message to [J ast week. I haven't yet gotten a
response. I'm not really comfortable closing the case at this point without raising these issues. I'm
also not thrilled with the wording from stating that the PIN concurs with our decision not to
pursue it as opposed to the PIN directing us not to pursue it.

From: EE (DE) (FB!)

Sent: Thursday, November 11, 2021 1:31:01 PM
To: (UsAMW) <a
Subject: FW

In our initial meeting regarding this case, | was somewhat unprepared, having not previously been
involved in election-related investigations. | recall from that meeting, you had concerns regarding
proving how the fraudulent voter registration applications could impact the election as well as showing
that it was done “willfully”. | was recently provided with “Federal Prosecution of Election Offenses”, put
out by the DOJ’s Public Integrity Section, December 2017. After reading through it, | have some concerns
regarding whether closing the matter is appropriate. Some of the relevant portions of the manual
include:

e Under the heading, “What is election fraud?”

o “Simply put, then, election fraud is conduct intended to corrupt... the process by which
voters are registered.” (pg. 22)

e Under the heading, “Conduct that Constitutes Federal Election Fraud”

o “Submitting fictitious names to election officers for inclusion on voter registration rolls,
thereby qualifying the ostensible voters to vote in federal elections (52 U.S.C. §§
1037(c), 20511(2))”. (pg. 24)

o “Providing false information concerning a person’s name, address, or period of
residence in a voting district to establish that person’s eligibility to register or to vote in
a federal election (52 U.S.C. §§ 1037(c), 20511(2)). (pg. 25)

o “Causing the production of voter registrations that qualify alleged voters to vote for
federal candidates, or the production of ballots in federal elections, that the actor
knows are materially defective under applicable state law (52 U.S.C. § 20511(2)). (pg.
25)

e Under the heading, “False Information in, and Payments for, Registering and Voting: 52 U.S.C. §

10307(c)”

o “Section 10307(c) is particularly useful for two reasons: (1) it eliminates the unresolved
issue of the scope of the constitutional right to vote in matters not involving racial
discrimination, and (2) it eliminates the need to prove that a given pattern of corrupt
conduct had an actual impact on a federal election. It is sufficient under Section
10307(c) that a pattern of corrupt conduct took place during a mixed election; in that
situation it is presumed that the fraud will expose the federal race to potential harm.
Slone 411 F.3d at 647 (collecting cases).” (pg. 39 — 40)

e Under the heading, “False information to an election official”

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APPROVED FOR PUBLIC RELEASE BY COUNSEL TO THE PRESIDENT WARRINGTON on 10 July 2026

o “The “false information” provision of Section 10307(c) prohibits any person from
furnishing certain false data to an election official to establish eligibility to register or to
vote in a federal election. The statute applies to three types of information: name,
address, and period of residence in the voting district.” (pg. 40)

o “Some, but not all, states permit a practice commonly known as “bounty-hunting,” that
is, paying people to collect voter registrations on a per-registration basis. Where it is
allowed, it is not unusual to find that this method of remuneration provides a motive for
the unscrupulous to forge voter registrations and to enhance the piecework payments
they can receive. While this situation usually does not result in fraudulent votes actually
being cast, it does cause voter registration offices to become overloaded with the task
of processing large numbers of bogus registrations immediately prior to an election,
when the resources of those offices should be directed at preparing ballots and staffing
polling sites. It also risks overloading voter rolls with “deadwood” names , which in turn
undermines public confidence in the election process. Thus, even when no fraudulent
votes result from bounty-hunting, the fraudulent registrations that arise from this
conduct are not victimless offenses. Federal prosecutors should be cognizant of these
circumstances and, when evidence of fraudulent registrations inspired by bounty-
hunting is discovered, should consider prosecuting the individuals submitting the false
registrations, as well as, in appropriate circumstances, the organizations that employ
and pay them, under Section 10307(c).” (pg. 42 - 43)

Although, it doesn’t appear as paying on a per-registration basis, it is reasonable for the
canvassers to believe they would not keep the job if they weren’t somewhat productive, and regardless
of what they believed, they still submitted fraudulent voter registration applications. | understand that
proving this was done “willfully” would still be difficult, but | wanted to raise my concerns before closing
the case.

=
From iS 0c):

Sent: Wednesday, November 3, 2021 9:40 AM

To: (08) (8) a
Subject: Fwd

FYSA

From: i (CRM)

Sent: Wednesday, November 3, 2021, 9:35 AM
‘I )

Subject: [EXTERNAL EMAIL] - RE:

Sorry | missed your calls. I’ll send an email today memorializing PIN’s agreement with the decisions of
the USAO and FBI to not seek prosecution here. Ill also copy i of USAO-W.D. Mich.

|

From:

Sent: Wednesday, October 20, 2021 10:28 AM

To: a

Subject:

Hello

We previously discussed the current state of the investigation, the results of our financial
review, and the content of the Michigan Attorney General's Office casefile that was provided to

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APPROVED FOR PUBLIC RELEASE BY COUNSEL TO THE PRESIDENT WARRINGTON on 10 July 2026

us. Would you be able to provide an undated letter regarding DOJ/PIN's view on

concurrence/nonconcurrence?
Please don't hesitate to call with any questions or if you need additional information.

Thanks,