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📑 Embeddings are evidence pointers. Governing evidence is the audit artifact. Focus™ measures evidence coverage—not keyword coverage: 93.4% ℹ️Focus™ measures weighted assertion coverage—not keyword coverage.
Each sentence or chunk is treated as an assertion from the governing document.
Focus™ is calculated after retrieval. It measures how much weighted assertion evidence is supported by retrieved governing evidence.
A low Focus™ score means important assertions were not supported by retrieved evidence.
Supported Assertion Weight: 424.04
Total Assertion Weight: 453.98
Focus™: 93.4
📑 Embeddings are evidence pointers. Governing evidence is the audit artifact. Focus™ measures evidence coverage—not keyword coverage: 93.4% ℹ️Focus™ measures weighted assertion coverage—not keyword coverage.
Each sentence or chunk is treated as an assertion from the governing document.
Focus™ is calculated after retrieval. It measures how much weighted assertion evidence is supported by retrieved governing evidence.
A low Focus™ score means important assertions were not supported by retrieved evidence.
Supported Assertion Weight: 424.04
Total Assertion Weight: 453.98
Focus™: 93.4
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. 11. RETRIEVED EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason BRENNAN,
Notice of address filed under seal,
Plaintiff v. 22. RETRIEVED EVIDENCE:
BRENNAN,
Notice of address filed under seal,
Plaintiff v.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950…O. Brennan ("Plaintiff" or…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in…III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct
TODD W. BLANCHE, in his official capacity as Acting Attorney General,
950 Pennsylvania Avenue, NW Washington, DC 20530
THE UNITED STATES DEPARTMENT OF JUSTICE,
950 Pennsylvania Avenue NW Washington, DC 20530
JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida,
U.S. Attorney's Office
99 N.E. 55. RETRIEVED EVIDENCE:
REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida,
U.S. Attorney's Office
99 N.E.
GOVERNING EVIDENCE:
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney…950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency 4th Street Miami, FL 33132
JOSEPH E. 66. RETRIEVED EVIDENCE:
4th Street Miami, FL 33132
JOSEPH E.
GOVERNING EVIDENCE:
U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald…In an interview the day after Bondi was fired, now-Counsel to the Attorney General Joseph diGenova explained that [t]he President's conversation with [Attorney General Pam Bondi] yesterday…was ripping mad about the fact that there was no progress on the lawfare investigation in Miami. 24In April, the lead career prosecutor on the Brennan investigations was removed from…News (Mar. 19, 2018), https://perma.cc/ZP79-WTLH . 29 Id.; Trump Lawyer diGenova to Lead Miami Grand Conspiracy Probe (1), Bloomberg Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 DIGENOVA, in his official capacity as Counselor to the Attorney General,
U.S. Attorney's Office
99 N.E. 77. RETRIEVED EVIDENCE:
DIGENOVA, in his official capacity as Counselor to the Attorney General,
U.S. Attorney's Office
99 N.E.
GOVERNING EVIDENCE:
W. BLANCHE, in his official capacity as Acting Attorney General…950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington 4th Street Miami, FL 33132
KASH P. 88. RETRIEVED EVIDENCE:
4th Street Miami, FL 33132
KASH P.
GOVERNING EVIDENCE:
U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation…sued in his official capacity. 22. Defendant Kash P. Patel has served as the Director of the FBI…District of Virginia before finding a home in SDFL. Recent reporting indicates that FBI Director Kash Patel also shopped the investigations to the Western District of Virginia in July 2025…personnel in the FBI field office and the main SDFL U.S. Attorney's Office in Miami. It is five states away from Washington, D.C., where the vast majority of the supposed…was ripping mad about the fact that there was no progress on the lawfare investigation in Miami. 24In April, the lead career prosecutor on the Brennan investigations was removed from PATEL, in his official capacity as Director of the Federal Bureau of Investigation,
935 Pennsylvania Ave, NW Washington, DC 20001
DONALD J. TRUMP, in his official capacity as President of the United States,
1600 Pennsylvania Ave NW Washington, DC 20500
Civil Action Case No. _________
26-2323
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46
EXECUTIVE OFFICE OF THE PRESIDENT,
1600 Pennsylvania Avenue NW Washington, DC 20500
SUSAN L. WILES, in her official capacity as White House Chief of Staff,
1600 Pennsylvania Avenue NW Washington, DC 20500
JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency,
Central Intelligence Agency Washington, DC 20505
CENTRAL INTELLIGENCE AGENCY,
Washington, DC 20505
OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE,
1500 Tysons McLean Dr.
McLean, VA 22102
Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46
TABLE OF CONTENTS Page i
COMPLAINT ................................................................................................................................ 1
INTRODUCTION ......................................................................................................................... 3
PARTIES ....................................................................................................................................... 7
JURISDICTION AND VENUE .................................................................................................. 10
STANDING ................................................................................................................................. 11
FACTUAL BACKGROUND ...................................................................................................... 12
I. 1212. RETRIEVED EVIDENCE:
RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency,
Central Intelligence Agency Washington, DC 20505
CENTRAL INTELLIGENCE AGENCY,
Washington, DC 20505
OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE,
1500 Tysons McLean Dr.
McLean, VA 22102
Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46
TABLE OF CONTENTS Page i
COMPLAINT ................................................................................................................................ 1
INTRODUCTION ......................................................................................................................... 3
PARTIES ....................................................................................................................................... 7
JURISDICTION AND VENUE .................................................................................................. 10
STANDING ................................................................................................................................. 11
FACTUAL BACKGROUND ...................................................................................................... 12
I.
GOVERNING EVIDENCE:
BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12
A. 1313. RETRIEVED EVIDENCE:
The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12
A.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel The Grand Conspiracy Investigation ....................................................... 12
B. 1414. RETRIEVED EVIDENCE:
The Grand Conspiracy Investigation ....................................................... 12
B.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…with the Two Brennan Investigations…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions The False-Statements Investigation ......................................................... 13
II. 1515. RETRIEVED EVIDENCE:
The False-Statements Investigation ......................................................... 13
II.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13
A. 1616. RETRIEVED EVIDENCE:
The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13
A.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i Administration Officials Call for Director Brennan's Prosecution ......... 16
B. 1717. RETRIEVED EVIDENCE:
Administration Officials Call for Director Brennan's Prosecution ......... 16
B.
GOVERNING EVIDENCE:
in his official capacity as…U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1 The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18
C. 1818. RETRIEVED EVIDENCE:
The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18
C.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON…Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20
D. 1919. RETRIEVED EVIDENCE:
The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20
D.
GOVERNING EVIDENCE:
Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21
E. The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct .................................... 22
III. 2121. RETRIEVED EVIDENCE:
The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct .................................... 22
III.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th…JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24
IV. 2222. RETRIEVED EVIDENCE:
The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24
IV.
GOVERNING EVIDENCE:
22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and…these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24
V. 2323. RETRIEVED EVIDENCE:
The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24
V.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under…Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25
VI. 2424. RETRIEVED EVIDENCE:
The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25
VI.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O…Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights ........................................................................................... 26
VII. 2525. RETRIEVED EVIDENCE:
Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights ........................................................................................... 26
VII.
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights .......................................................................... 34
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46
TABLE OF CONTENTS
(continued)
Page ii COUNT 1 ..................................................................................................................................... 35
COUNT 2 ..................................................................................................................................... 37
COUNT 3 ..................................................................................................................................... 38
REQUEST FOR RELIEF ............................................................................................................ 39
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461
COMPLAINT
"Being perceived as the President'sadversary has become risky in recent years." In re Grand Jury Subpoenas Nos. 2626. RETRIEVED EVIDENCE:
Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights .......................................................................... 34
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46
TABLE OF CONTENTS
(continued)
Page ii COUNT 1 ..................................................................................................................................... 35
COUNT 2 ..................................................................................................................................... 37
COUNT 3 ..................................................................................................................................... 38
REQUEST FOR RELIEF ............................................................................................................ 39
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461
COMPLAINT
"Being perceived as the President'sadversary has become risky in recent years." In re Grand Jury Subpoenas Nos.
GOVERNING EVIDENCE:
Government has Engaged, and Continues to Engage, in Unprecedented, Irregular…34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1 ..................................................................................................................................... 35 COUNT 2 ..................................................................................................................................... 37 COUNT 3 ..................................................................................................................................... 38 REQUEST FOR RELIEF…Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation…by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend [Redacted] & [Redacted], 823 F. 2727. RETRIEVED EVIDENCE:
[Redacted] & [Redacted], 823 F.
GOVERNING EVIDENCE:
s adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr…court's request to review the grand jury transcripts. 67 At first, they provided only redacted versions, and when the judge insisted on the full transcripts, they even reduced the…release of the Epstein files, where the Justice Department was less than transparent in redacting passages that were inconvenient for President Trump, Nik Popli, Trump Administration Removes Some Redactions from Epstein Files After Outcry from Lawyers, Time (Feb. 9, 2026), https://perma.cc/ZGW3-H6ZK ("Among the material Raskin said he encountered was a redacted passage summarizing comments Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 37 of 4634 will Supp. 2828. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d 1, 5 (D.D.C. 2929. RETRIEVED EVIDENCE:
3d 1, 5 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of 2026),
reconsideration denied, 2026 WL 1224046 (D.D.C. 3030. RETRIEVED EVIDENCE:
2026),
reconsideration denied, 2026 WL 1224046 (D.D.C.
GOVERNING EVIDENCE:
THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second investigation centers on an October 21…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted apolicy of using criminal process and prosecution to punish the President'sperceived adversaries. 3333. RETRIEVED EVIDENCE:
With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted apolicy of using criminal process and prosecution to punish the President'sperceived adversaries.
GOVERNING EVIDENCE:
2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's…been publicly declaring Director Brennan a criminal, not only before securing a conviction in…to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice Department into a tool of retribution against Director Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited
"the backdrop of the Trump administration'swell-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries."
In re Grand Jury Subpoenas Nos. 3434. RETRIEVED EVIDENCE:
Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited
"the backdrop of the Trump administration'swell-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries."
In re Grand Jury Subpoenas Nos.
GOVERNING EVIDENCE:
subpoenas directed at Federal…this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's…than 33 years of nonpartisan government service working for six administrations - three Republican and three Democratic - in a wide variety of national security and intelligence positions. His…has excoriated Director Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying…actively mobilized the machinery of the criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and 2022R00519-A, 2022R00519-B, 2022R00519-C,
2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. 3535. RETRIEVED EVIDENCE:
2022R00519-A, 2022R00519-B, 2022R00519-C,
2022R00519-D, 2022R00519-E, 2022R00519-F, -- F.
GOVERNING EVIDENCE:
the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A, 2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is Supp. 3636. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d --, 2026 WL 1783899, at *7 (D. 3737. RETRIEVED EVIDENCE:
3d --, 2026 WL 1783899, at *7 (D.
GOVERNING EVIDENCE:
& [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of Just., Justice…2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010) (noting that the court did an in camera…documents" in assessing claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive…514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr. 20, 2021) (Contreras, J), and "[t]he government
Minn. 3838. RETRIEVED EVIDENCE:
Minn.
GOVERNING EVIDENCE:
adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the…2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central June 22, 2026).
It is against this backdrop that former Director of the Central Intelligence Agency, John O. 4040. RETRIEVED EVIDENCE:
It is against this backdrop that former Director of the Central Intelligence Agency, John O.
GOVERNING EVIDENCE:
the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations…Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. 4141. RETRIEVED EVIDENCE:
Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution.
GOVERNING EVIDENCE:
official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President As in the above cases, the evidence of vindictiveness in this matter is overwhelming. 4242. RETRIEVED EVIDENCE:
As in the above cases, the evidence of vindictiveness in this matter is overwhelming.
GOVERNING EVIDENCE:
as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and…to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for…1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over President Trump has been condemning and calling for Director Brennan's prosecution for years. 4343. RETRIEVED EVIDENCE:
President Trump has been condemning and calling for Director Brennan's prosecution for years.
GOVERNING EVIDENCE:
99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing aconviction in court but even before afull investigation and an indictment. 4444. RETRIEVED EVIDENCE:
Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing aconviction in court but even before afull investigation and an indictment.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462
Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. 4646. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462
Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution.
GOVERNING EVIDENCE:
22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for…of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over In assessing that challenge, the court presiding over Director Brennan'scriminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government'sactions. 4747. RETRIEVED EVIDENCE:
In assessing that challenge, the court presiding over Director Brennan'scriminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government'sactions.
GOVERNING EVIDENCE:
Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights Given the government'squestionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has awell-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. 4848. RETRIEVED EVIDENCE:
Given the government'squestionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has awell-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness.
GOVERNING EVIDENCE:
to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's…the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully
For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. 4949. RETRIEVED EVIDENCE:
For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. 5050. RETRIEVED EVIDENCE:
Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights Blanche, Acting Attorney General; 5151. RETRIEVED EVIDENCE:
Blanche, Acting Attorney General;
GOVERNING EVIDENCE:
filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW…NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan…Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney the United States Department of Justice; 5252. RETRIEVED EVIDENCE:
the United States Department of Justice;
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small…W. Blanche is the Acting Attorney General of the United States. He leads the Department of Justice and has been in this position since April 2026. In that role, he has Case 1:26-cv-02323…relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; 5454. RETRIEVED EVIDENCE:
Reding Qui ones, the U.S. Attorney for the Southern District of Florida;
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal…NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to Joseph E. 5555. RETRIEVED EVIDENCE:
Joseph E.
GOVERNING EVIDENCE:
District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S.…Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the…under the requested injunctive relief. He is sued in his official capacity. 21. Defendant Joseph E. diGenova has served as Counselor to the Attorney General since April 20, 2026. He…In an interview the day after Bondi was fired, now-Counsel to the Attorney General Joseph diGenova explained that [t]he President's conversation with [Attorney General Pam Bondi] yesterday diGenova, Counselor to the Attorney General; 5656. RETRIEVED EVIDENCE:
diGenova, Counselor to the Attorney General;
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…FBI Director and the Counselor overseeing the Brennan investigations…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has Donald J. Trump,
President of the United States; 5858. RETRIEVED EVIDENCE:
Trump,
President of the United States;
GOVERNING EVIDENCE:
......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos the Executive Office of the President; 5959. RETRIEVED EVIDENCE:
the Executive Office of the President;
GOVERNING EVIDENCE:
26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…to retaliate against and pressure the President's political and personal adversaries Susan L. Wiles, White House Chief of Staff; 6161. RETRIEVED EVIDENCE:
Wiles, White House Chief of Staff;
GOVERNING EVIDENCE:
NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White…President of the United States; the Executive Office of the President; Susan L. Wiles, White House Chief of Staff; John L. Ratcliffe, Director of the Central Intelligence…to be preserved under the requested injunctive relief. 25. Defendant Susan L. Wiles has served as the White House Chief of Staff since January 20, 2025. In that role, she…That concern became so pronounced that undersigned counsel submitted a letter to the Chief Judge of the Southern District of Florida alerting her to the government's judge-shopping and…is to carry out the Justice Department's judge-shopping plan. 38. The letter to Chief Judge Altonaga lays out many of the government's irregular actions up to that time. To…government's conduct in this matter. 11 See Letter from Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https John L. Ratcliffe, Director of the Central Intelligence Agency; 6363. RETRIEVED EVIDENCE:
Ratcliffe, Director of the Central Intelligence Agency;
GOVERNING EVIDENCE:
s Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001…as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the Central Intelligence Agency; 6464. RETRIEVED EVIDENCE:
the Central Intelligence Agency;
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016…grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice Department have succumbed…senior Administration officials in the run-up to the First Gulf War (1990-91); daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95); senior U.S. intelligence official resident in Saudi Arabia (1996-99); Chief of Staff to Director of Central Intelligence George Tenet (1999-2001); and, Deputy Executive Director of the CIA (2001-03). As and the Office of the Director of National Intelligence (collectively
"Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan'slegal and constitutional challenges to any future criminal charges. 6565. RETRIEVED EVIDENCE:
and the Office of the Director of National Intelligence (collectively
"Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan'slegal and constitutional challenges to any future criminal charges.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full
For his Complaint, Director Brennan alleges as follows: 6666. RETRIEVED EVIDENCE:
For his Complaint, Director Brennan alleges as follows:
GOVERNING EVIDENCE:
capacity as Director of the Federal…Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 of 463
INTRODUCTION
1. 6767. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 of 463
INTRODUCTION
1.
GOVERNING EVIDENCE:
of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director
Director Brennan is aformer longtime public servant who provided more than 33 years of nonpartisan government service working for six administrations - three Republican and three Democratic - in awide variety of national security and intelligence positions. 6868. RETRIEVED EVIDENCE:
Director Brennan is aformer longtime public servant who provided more than 33 years of nonpartisan government service working for six administrations - three Republican and three Democratic - in awide variety of national security and intelligence positions.
GOVERNING EVIDENCE:
20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…s Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights His public service career culminated in his term as the Director of the Central Intelligence Agency ("CIA")
from March 8, 2013 to January 20, 2017. 6969. RETRIEVED EVIDENCE:
His public service career culminated in his term as the Director of the Central Intelligence Agency ("CIA")
from March 8, 2013 to January 20, 2017.
GOVERNING EVIDENCE:
99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation
2.
While serving as Director, he participated in coordinating and issuing the January 6, 2017
Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the
2016 presidential election in an effort to boost candidate Donald Trump's chances of winning the election. 7171. RETRIEVED EVIDENCE:
While serving as Director, he participated in coordinating and issuing the January 6, 2017
Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the
2016 presidential election in an effort to boost candidate Donald Trump's chances of winning the election.
GOVERNING EVIDENCE:
25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 7272. RETRIEVED EVIDENCE:
In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the
3.
Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and demonize Director Brennan. 7474. RETRIEVED EVIDENCE:
Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and demonize Director Brennan.
GOVERNING EVIDENCE:
Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from In avariety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan as "avery bad guy," "atotal low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying before Congress, and has twice posted doctored images of Director Brennan in an orange jumpsuit. 7575. RETRIEVED EVIDENCE:
In avariety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan as "avery bad guy," "atotal low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying before Congress, and has twice posted doctored images of Director Brennan in an orange jumpsuit.
GOVERNING EVIDENCE:
Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights
4.
With his return to the White House, the President has gone beyond mere denunciation,
and has actively mobilized the machinery of the criminal justice system against Director Brennan. 7777. RETRIEVED EVIDENCE:
With his return to the White House, the President has gone beyond mere denunciation,
and has actively mobilized the machinery of the criminal justice system against Director Brennan.
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. 7878. RETRIEVED EVIDENCE:
He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal justification.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464
Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice Department into atool of retribution against Director Brennan and the President'sother perceived adversaries. 7979. RETRIEVED EVIDENCE:
Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464
Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice Department into atool of retribution against Director Brennan and the President'sother perceived adversaries.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions
1
5.
This effort has resulted in the opening of two federal investigations that purport to be investigating Director Brennan for what amounts to phantom criminal conduct. 8181. RETRIEVED EVIDENCE:
This effort has resulted in the opening of two federal investigations that purport to be investigating Director Brennan for what amounts to phantom criminal conduct.
GOVERNING EVIDENCE:
his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product of aconspiracy to deny President Trump his civil rights. 8383. RETRIEVED EVIDENCE:
This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product of aconspiracy to deny President Trump his civil rights.
GOVERNING EVIDENCE:
Relevant…March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…or written statements that personally criticize and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and…Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying…Director Brennan and a number of Obama and Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second investigation centers on an October 21 The second investigation centers on an October 21, 2025 referral from Congressman Jim Jordan, Chairman of the House Judiciary Committee, which asserts without valid support that Director Brennan made false statements about the ICA in a 2023 interview with the House Judiciary Committee. 8484. RETRIEVED EVIDENCE:
The second investigation centers on an October 21, 2025 referral from Congressman Jim Jordan, Chairman of the House Judiciary Committee, which asserts without valid support that Director Brennan made false statements about the ICA in a 2023 interview with the House Judiciary Committee.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions…In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan as "a very…He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal…and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice
6.
The Justice Department has undertaken separate grand jury investigations as to each of these matters. 8686. RETRIEVED EVIDENCE:
The Justice Department has undertaken separate grand jury investigations as to each of these matters.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case In November 2025 and January 2026, the Southern District of Florida ("SDFL")
U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to the supposed "grand conspiracy" and the other relating to Director Brennan's alleged false statements to Congress. 8787. RETRIEVED EVIDENCE:
In November 2025 and January 2026, the Southern District of Florida ("SDFL")
U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to the supposed "grand conspiracy" and the other relating to Director Brennan's alleged false statements to Congress.
GOVERNING EVIDENCE:
U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration…2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the Then, over the weekend of April 18, 2026, a federal grand jury in Washington, D.C. 8888. RETRIEVED EVIDENCE:
Then, over the weekend of April 18, 2026, a federal grand jury in Washington, D.C.
GOVERNING EVIDENCE:
Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official…in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed…07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…12 A. The Grand Conspiracy Investigation ....................................................... issued subpoenas to a number of current and former Intelligence Community
1
In detailing how some individuals in the Justice Department have succumbed to pressure from the President to selectively and vindictively target Director Brennan, there is no intent to suggest that responsibility for the resulting lapses is widely shared within the Department. 8989. RETRIEVED EVIDENCE:
issued subpoenas to a number of current and former Intelligence Community
1
In detailing how some individuals in the Justice Department have succumbed to pressure from the President to selectively and vindictively target Director Brennan, there is no intent to suggest that responsibility for the resulting lapses is widely shared within the Department.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…statements - President Trump has excoriated Director Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…Brennan and the President's other perceived adversaries. 1 5. This effort has resulted in the opening of two federal investigations that purport to be investigating Director To the contrary, the concerns that necessitate this complaint apply to only a small subset of officials,
and the vast majority of Justice Department personnel are maintaining adherence to professional standards and carrying out their duties in the best tradition of the Justice Department.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 8 of 465
personnel who had worked on the ICA, requiring them to testify before the grand jury in the false-statements investigation. 9191. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 8 of 465
personnel who had worked on the ICA, requiring them to testify before the grand jury in the false-statements investigation.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions…in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016 presidential election in an Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 9292. RETRIEVED EVIDENCE:
Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews.
GOVERNING EVIDENCE:
..................................................................................................................................... 38 REQUEST FOR…without valid support that Director Brennan made false statements about the ICA in a 2023 interview with the House Judiciary Committee. 6. The Justice Department has undertaken separate grand…District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to the supposed "grand conspiracy" and the other…over the weekend of April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some…them to testify before the grand jury in the false-statements investigation. Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 7. In their work on these presidentially-driven investigations, certain Justice…the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and
7.
In their work on these presidentially-driven investigations, certain Justice Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial conduct. Those overreaching actions have violated Director Brennan'sconstitutional rights and will serve as the basis for challenges to any resulting charges, including motions to dismiss any indictment on the grounds that it is the result of selective and vindictive prosecution. 9595. RETRIEVED EVIDENCE:
Those overreaching actions have violated Director Brennan'sconstitutional rights and will serve as the basis for challenges to any resulting charges, including motions to dismiss any indictment on the grounds that it is the result of selective and vindictive prosecution.
GOVERNING EVIDENCE:
Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean…Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights
8.
To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw, or undertook those actions to determine whether they violated Director Brennan'srights, and specifically whether they were motivated by adesire to vindictively prosecute him as an act of retribution. 9797. RETRIEVED EVIDENCE:
To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw, or undertook those actions to determine whether they violated Director Brennan'srights, and specifically whether they were motivated by adesire to vindictively prosecute him as an act of retribution.
GOVERNING EVIDENCE:
................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong…and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect That scrutiny would be more probing and less deferential to the government than usual because of the Justice Department'srecent record of overreaching in this and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9898. RETRIEVED EVIDENCE:
That scrutiny would be more probing and less deferential to the government than usual because of the Justice Department'srecent record of overreaching in this and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny.
GOVERNING EVIDENCE:
Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other…those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying
9.
To perform that scrutiny after an indictment, the Court would demand access to awide range of the government's communications and materials surrounding its investigative and prosecutive decisions. 100100. RETRIEVED EVIDENCE:
To perform that scrutiny after an indictment, the Court would demand access to awide range of the government's communications and materials surrounding its investigative and prosecutive decisions.
GOVERNING EVIDENCE:
and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably…that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging Acareful examination of the prosecutors' emails, texts, instant messages,
internal memoranda and the like would enable acourt to determine whether their decisions were based on legitimate law enforcement concerns or on adesire to selectively and/or vindictively prosecute Director Brennan. 101101. RETRIEVED EVIDENCE:
Acareful examination of the prosecutors' emails, texts, instant messages,
internal memoranda and the like would enable acourt to determine whether their decisions were based on legitimate law enforcement concerns or on adesire to selectively and/or vindictively prosecute Director Brennan.
GOVERNING EVIDENCE:
Materials and Communications to Assess the Prosecutors' Motivations…and materials surrounding its investigative and prosecutive decisions. A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on legitimate law enforcement concerns or on a desire to selectively and/or vindictively prosecute…These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not…communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions. And Director Brennan and the Court cannot rely on pre-trial…the allegation that Director Brennan made false statements to Congress. The government prosecutors have informed Director Brennan that any false-statements case must be filed in the
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466
10. 102102. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466
10.
GOVERNING EVIDENCE:
of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director
There is avery real risk, however, that some of these materials and communications will no longer exist by the time any such challenges are filed and the court hears them. 103103. RETRIEVED EVIDENCE:
There is avery real risk, however, that some of these materials and communications will no longer exist by the time any such challenges are filed and the court hears them.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His…Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d…directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution This risk exists for two reasons. 104104. RETRIEVED EVIDENCE:
This risk exists for two reasons.
GOVERNING EVIDENCE:
s Intervention, There is a Serious Risk that Highly Relevant Internal…Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that…time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action…2016 election and the other Trump-related investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second investigation…Brennan. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466 10. There is a very real risk, however, that some of these materials and communications will no longer exist by the time any such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are First, as technology changes and becomes more ephemeral, government officials are increasingly relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery obligations. 105105. RETRIEVED EVIDENCE:
First, as technology changes and becomes more ephemeral, government officials are increasingly relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery obligations.
GOVERNING EVIDENCE:
respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the…twice posted doctored images of Director Brennan in an orange jumpsuit. 4. With his return to the White House, the President has gone beyond mere denunciation, and has actively…07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice Department into a tool of retribution against Director Brennan and the…are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are increasingly relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely preserved. 106106. RETRIEVED EVIDENCE:
These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely preserved.
GOVERNING EVIDENCE:
Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which
2
Second, there is ample evidence in the public record that many in the Administration and in the Justice Department specifically are failing to observe their legal obligation to maintain such records. 107107. RETRIEVED EVIDENCE:
2
Second, there is ample evidence in the public record that many in the Administration and in the Justice Department specifically are failing to observe their legal obligation to maintain such records.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th…JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i
11.
The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan'schallenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions. 109109. RETRIEVED EVIDENCE:
The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan'schallenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions.
GOVERNING EVIDENCE:
24 IV. The Court Reviewing the Vindictive and Selective…of selective and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who…are failing to observe their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions. And Director Brennan…investigation. Isn't that a problem?" At that point, Blanche simply responded, "I just completely disagree with the premise," and gave his assurance that DiGenova will be "doing…a proposed regulation that will give the Attorney General the first opportunity to review any complaint against a current or former Department attorney 44 and the right to "take And Director Brennan and the Court cannot rely on pre-trial sanctions as aremedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 110110. RETRIEVED EVIDENCE:
And Director Brennan and the Court cannot rely on pre-trial sanctions as aremedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights
12.
For this reason, Director Brennan brings this action asking the Court to enjoin the government to preserve any and all communications and materials that are potentially relevant to
2
U.S. Dep'tof Just., Private Impact Assessment for the Email and Collaboration Services
(2024),
https://perma.cc/HS8T-K2SY
(announcing DOJ is using Microsoft Teams); 112112. RETRIEVED EVIDENCE:
For this reason, Director Brennan brings this action asking the Court to enjoin the government to preserve any and all communications and materials that are potentially relevant to
2
U.S. Dep'tof Just., Private Impact Assessment for the Email and Collaboration Services
(2024),
https://perma.cc/HS8T-K2SY
(announcing DOJ is using Microsoft Teams);
GOVERNING EVIDENCE:
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his…s Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in U.S. Dep'tof Just., AI Inventory (Jan. 113113. RETRIEVED EVIDENCE:
U.S. Dep'tof Just., AI Inventory (Jan.
GOVERNING EVIDENCE:
that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely preserved. 2 Second, there is ample evidence…//perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of 30, 2026),
https://perma.cc/DG59-PCFZ
; 114114. RETRIEVED EVIDENCE:
30, 2026),
https://perma.cc/DG59-PCFZ
;
GOVERNING EVIDENCE:
Private Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…29, 2025), https://perma.cc/RWM6-6HAN …Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury…into Russiagate Conspiracy Allegations: Sources, Fox News (Aug. 4, 2025), https://perma.cc/Q5JS XTZQ ; LA Times Studios, Straight to the Point: The Grand Conspiracy Against see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep'tof Just.,
https://perma.cc/8ERX-WDY4
(spreadsheet showing more than 300 AI use cases at DOJ); 115115. RETRIEVED EVIDENCE:
see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep'tof Just.,
https://perma.cc/8ERX-WDY4
(spreadsheet showing more than 300 AI use cases at DOJ);
GOVERNING EVIDENCE:
and materials that are potentially relevant to 2 U.S. Dep't of Just., Private Impact Assessment for the Email and…2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How AI and Whistleblowers…22, 2017), https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009), https://perma.cc/W55M-M7FW (Eric Holder 2009 memo). 20 Memorandum from the Attorney General to All Dep't Emps. (Feb. 5, 2025), https://perma.cc/3PPL-BWER . 21 In-Your-Face DOJ Aide Rides…Acting Attorney General Blanche and FBI Director Kash Patel Hold a Press Conference, U.S. Dep't of Just., at 25:04-27:05 (YouTube, Apr. 21, 2026), https Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29,
2025),
https://perma.cc/RWM6-6HAN
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467
the consideration of Director Brennan'slegal and constitutional challenges to any future criminal charges. 116116. RETRIEVED EVIDENCE:
Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29,
2025),
https://perma.cc/RWM6-6HAN
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467
the consideration of Director Brennan'slegal and constitutional challenges to any future criminal charges.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA…....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct
PARTIES
13. 117117. RETRIEVED EVIDENCE:
PARTIES
13.
GOVERNING EVIDENCE:
3 PARTIES…of Director Brennan's legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in…public interest, as "it is always in the public interest to prevent the violation of a party's constitutional rights." Gayle v. Meade, 614 F. Supp. 3d 1175, 1206 (S.D. Fla
Plaintiff John O. 118118. RETRIEVED EVIDENCE:
Plaintiff John O.
GOVERNING EVIDENCE:
FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…perform a duty owed to the plaintiff." Case 1:26-cv-02323 Brennan is the target of agrand jury investigation in Washington, D.C. 119119. RETRIEVED EVIDENCE:
Brennan is the target of agrand jury investigation in Washington, D.C.
GOVERNING EVIDENCE:
07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has
and of investigations in two grand juries in the Southern District of Florida. 120120. RETRIEVED EVIDENCE:
and of investigations in two grand juries in the Southern District of Florida.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W…A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming He is aformer director of the CIA, and he resides in the Commonwealth of Virginia. 121121. RETRIEVED EVIDENCE:
He is aformer director of the CIA, and he resides in the Commonwealth of Virginia.
GOVERNING EVIDENCE:
as Director of the Federal…the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation
14.
Director Brennan's federal government service, which began in August 1980, spanned six Administrations-three Republican and three Democratic. In his 25-year career as a CIA officer, he served in a variety of positions of increasing responsibility, including: intelligence analyst on the Middle East and counterterrorism specialist (1980-96); 125125. RETRIEVED EVIDENCE:
intelligence analyst on the Middle East and counterterrorism specialist (1980-96);
GOVERNING EVIDENCE:
Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323…Agency; the Central Intelligence Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due…- three Republican and three Democratic - in a wide variety of national security and intelligence positions. His public service career culminated in his term as the Director of the…serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016…grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice Department have succumbed political officer at the U.S.
Embassy in Saudi Arabia (1982-84) while assigned to the Department of State during the Reagan Administration; 126126. RETRIEVED EVIDENCE:
political officer at the U.S.
Embassy in Saudi Arabia (1982-84) while assigned to the Department of State during the Reagan Administration;
GOVERNING EVIDENCE:
and pressure the President's political and personal adversaries." In re…federal government service, which began in August 1980, spanned six Administrations-three Republican and three Democratic. In his 25-year career as a CIA officer, he served in a variety of positions of increasing responsibility, including…intelligence analyst on the Middle East and counterterrorism specialist (1980-96); political officer at the U.S. Embassy in Saudi Arabia (1982-84) while assigned to the Department of State during the Reagan Administration; briefer to President George H.W…Gulf War (1990-91); daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95); senior U.S. intelligence official resident in Saudi Arabia (1996-99); Chief of…States Senate confirmed Director Brennan, who has never registered as a member of any political party, as Director of the CIA in a bipartisan 63-34 vote on March 7, 2013. He was sworn into office the following day and served as briefer to President George H.W. 127127. RETRIEVED EVIDENCE:
briefer to President George H.W.
GOVERNING EVIDENCE:
07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A Bush and senior Administration officials in the run-up to the First Gulf War (1990-91); 128128. RETRIEVED EVIDENCE:
Bush and senior Administration officials in the run-up to the First Gulf War (1990-91);
GOVERNING EVIDENCE:
Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95); 129129. RETRIEVED EVIDENCE:
daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95);
GOVERNING EVIDENCE:
Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years senior U.S. intelligence official resident in Saudi Arabia
(1996-99); Chief of Staff to Director of Central Intelligence George Tenet (1999-2001); 131131. RETRIEVED EVIDENCE:
Chief of Staff to Director of Central Intelligence George Tenet (1999-2001);
GOVERNING EVIDENCE:
P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935…the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of…Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of and,
Deputy Executive Director of the CIA (2001-03). 132132. RETRIEVED EVIDENCE:
and,
Deputy Executive Director of the CIA (2001-03).
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…Central Intelligence Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United…grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice Department have succumbed…and senior Administration officials in the run-up to the First Gulf War (1990-91); daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95); senior U.S. intelligence official resident in Saudi Arabia (1996-99); Chief of Staff to Director of Central Intelligence George Tenet (1999-2001); and, Deputy Executive Director of the CIA (2001-03). As testament to the confidence placed in his As testament to the confidence placed in his leadership skills and national security expertise, Director Brennan was selected in 2003 to design and serve as the founding director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W. 133133. RETRIEVED EVIDENCE:
As testament to the confidence placed in his leadership skills and national security expertise, Director Brennan was selected in 2003 to design and serve as the founding director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W.
GOVERNING EVIDENCE:
FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford Bush to address the lack of interagency collaboration within the U.S.
counterterrorism community that contributed to the failure to prevent the 9/11 terrorist attacks. 134134. RETRIEVED EVIDENCE:
Bush to address the lack of interagency collaboration within the U.S.
counterterrorism community that contributed to the failure to prevent the 9/11 terrorist attacks.
GOVERNING EVIDENCE:
Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…Director Brennan was selected in 2003 to design and serve as the founding director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W. Bush to address the lack of interagency collaboration within the U.S. counterterrorism community that contributed to the failure to prevent the 9/11 terrorist attacks. 15. Following his retirement from the CIA in 2005, Director Brennan returned to…Brennan played a lead role in shaping and coordinating Obama Administration policies on counterterrorism, including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama Administration policies
15.
Following his retirement from the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and Counterterrorism and Deputy National Security Advisor in the Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 11 of 468
Executive Office of the President. 136136. RETRIEVED EVIDENCE:
Following his retirement from the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and Counterterrorism and Deputy National Security Advisor in the Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 11 of 468
Executive Office of the President.
GOVERNING EVIDENCE:
the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights During his more than four years at the White House from January 2009 to March 2013, Director Brennan played alead role in shaping and coordinating Obama Administration policies on counterterrorism, including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. 137137. RETRIEVED EVIDENCE:
During his more than four years at the White House from January 2009 to March 2013, Director Brennan played alead role in shaping and coordinating Obama Administration policies on counterterrorism, including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network.
GOVERNING EVIDENCE:
official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation He also was responsible during this time for orchestrating Obama Administration policies on homeland security, pandemics, cyberattacks, and natural disasters. 138138. RETRIEVED EVIDENCE:
He also was responsible during this time for orchestrating Obama Administration policies on homeland security, pandemics, cyberattacks, and natural disasters.
GOVERNING EVIDENCE:
E. The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct ....................................…concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice
16.
The United States Senate confirmed Director Brennan, who has never registered as amember of any political party, as Director of the CIA in a bipartisan 63-34 vote on March 7,
2013. 140140. RETRIEVED EVIDENCE:
The United States Senate confirmed Director Brennan, who has never registered as amember of any political party, as Director of the CIA in a bipartisan 63-34 vote on March 7,
2013.
GOVERNING EVIDENCE:
99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation…Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product He was sworn into office the following day and served as CIA Director until January 20,
2017. 141141. RETRIEVED EVIDENCE:
He was sworn into office the following day and served as CIA Director until January 20,
2017.
GOVERNING EVIDENCE:
his official capacity as Director of the Federal Bureau of Investigation…the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and liaison relationships with foreign intelligence services. 142142. RETRIEVED EVIDENCE:
As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and liaison relationships with foreign intelligence services.
GOVERNING EVIDENCE:
P. PATEL, in his official capacity as Director of the Federal Bureau of…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation He testified to Congressional Committees dozens of times as Director and was unwavering in his commitment to carry out his responsibilities in anonpartisan, apolitical, and objective manner. 143143. RETRIEVED EVIDENCE:
He testified to Congressional Committees dozens of times as Director and was unwavering in his commitment to carry out his responsibilities in anonpartisan, apolitical, and objective manner.
GOVERNING EVIDENCE:
JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A, 2022R00519-B…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in
While Director, Plaintiff initiated amajor reorganization of the CIA - the first in over 50 years
- in order to position the CIA to deal more effectively with the national security challenges of the future. 144144. RETRIEVED EVIDENCE:
While Director, Plaintiff initiated amajor reorganization of the CIA - the first in over 50 years
- in order to position the CIA to deal more effectively with the national security challenges of the future.
GOVERNING EVIDENCE:
seal, Plaintiff v. TODD…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation…Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product The resulting new organizational structure remains in place to this day. 145145. RETRIEVED EVIDENCE:
The resulting new organizational structure remains in place to this day.
GOVERNING EVIDENCE:
16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda…target Director Brennan, there is no intent to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that…Brennan's constitutional rights and will serve as the basis for challenges to any resulting charges, including motions to dismiss any indictment on the grounds that it is the result of selective and vindictive prosecution. 8. To fully consider those motions, the…serve as the founding director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W…CIA to deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the recipient of numerous awards
17.
Director Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA Distinguished Career Intelligence Medal, the CIA Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 147147. RETRIEVED EVIDENCE:
Director Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA Distinguished Career Intelligence Medal, the CIA Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal.
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even
18.
Defendant Todd W. 149149. RETRIEVED EVIDENCE:
Defendant Todd W.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of…his official capacity. 21. Defendant Joseph E. diGenova has served as Blanche is the Acting Attorney General of the United States. 150150. RETRIEVED EVIDENCE:
Blanche is the Acting Attorney General of the United States.
GOVERNING EVIDENCE:
O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to He leads the Department of Justice and has been in this position since April 2026. 151151. RETRIEVED EVIDENCE:
He leads the Department of Justice and has been in this position since April 2026.
GOVERNING EVIDENCE:
this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…Republican and three Democratic - in a wide variety of national security and intelligence positions. His public service career culminated in his term as the Director of the Central…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016 presidential In that role, he has Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 12 of 469
responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief. 152152. RETRIEVED EVIDENCE:
In that role, he has Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 12 of 469
responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and He is sued in his official capacity. 153153. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of
19.
Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. 155155. RETRIEVED EVIDENCE:
Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief. 156156. RETRIEVED EVIDENCE:
It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE
20.
Defendant Jason A. 158158. RETRIEVED EVIDENCE:
Defendant Jason A.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of…his official capacity. 21. Defendant Joseph E. diGenova has served as Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief. 160160. RETRIEVED EVIDENCE:
In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and He is sued in his official capacity. 161161. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of
21.
Defendant Joseph E. 163163. RETRIEVED EVIDENCE:
Defendant Joseph E.
GOVERNING EVIDENCE:
99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws diGenova has served as Counselor to the Attorney General since April 20, 2026. 164164. RETRIEVED EVIDENCE:
diGenova has served as Counselor to the Attorney General since April 20, 2026.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been…Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…Republican and three Democratic. In his 25-year career as a CIA officer, he served in a variety of positions of increasing responsibility, including: intelligence analyst He has been assigned to lead the investigations into the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress. 165165. RETRIEVED EVIDENCE:
He has been assigned to lead the investigations into the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress.
GOVERNING EVIDENCE:
Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief. 166166. RETRIEVED EVIDENCE:
In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and He is sued in his official capacity. 167167. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of
22.
Defendant Kash P. 169169. RETRIEVED EVIDENCE:
Defendant Kash P.
GOVERNING EVIDENCE:
4th Street Miami, FL 33132 KASH P. PATEL, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Patel has served as the Director of the FBI since February 20, 2025. 170170. RETRIEVED EVIDENCE:
Patel has served as the Director of the FBI since February 20, 2025.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel
He supervises FBI agents and other personnel who are working on the Brennan investigations. 171171. RETRIEVED EVIDENCE:
He supervises FBI agents and other personnel who are working on the Brennan investigations.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda…Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct ....................................…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief. 172172. RETRIEVED EVIDENCE:
In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and He is sued in his official capacity. 173173. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of
23.
Defendant Donald J. 175175. RETRIEVED EVIDENCE:
Defendant Donald J.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of…his official capacity. 21. Defendant Joseph E. diGenova has served as Trump has served as the President of the United States since January 20, 2025. 176176. RETRIEVED EVIDENCE:
Trump has served as the President of the United States since January 20, 2025.
GOVERNING EVIDENCE:
935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A He previously served as the President from January 20, 2017 to January 20,
2021. 177177. RETRIEVED EVIDENCE:
He previously served as the President from January 20, 2017 to January 20,
2021.
GOVERNING EVIDENCE:
1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years As the President, he has responsibility over Executive Branch subordinates and record systems that would have the records to be preserved under the requested injunctive relief. 178178. RETRIEVED EVIDENCE:
As the President, he has responsibility over Executive Branch subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…38 REQUEST FOR RELIEF…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A He is sued in his official capacity. 179179. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 13 of 4610
24. 180180. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 13 of 4610
24.
GOVERNING EVIDENCE:
of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director
Defendant Executive Office of the President provides operational and management support to the President. 181181. RETRIEVED EVIDENCE:
Defendant Executive Office of the President provides operational and management support to the President.
GOVERNING EVIDENCE:
16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief. 182182. RETRIEVED EVIDENCE:
It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE
25.
Defendant Susan L. 184184. RETRIEVED EVIDENCE:
Defendant Susan L.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of…his official capacity. 21. Defendant Joseph E. diGenova has served as Wiles has served as the White House Chief of Staff since January 20,
2025. 185185. RETRIEVED EVIDENCE:
Wiles has served as the White House Chief of Staff since January 20,
2025.
GOVERNING EVIDENCE:
Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff…Central Intelligence Agency ("CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017…overreaching actions have violated Director Brennan's constitutional rights and will serve as the basis for challenges to any resulting charges, including motions to dismiss any…Republican and three Democratic. In his 25-year career as a CIA officer, he served in a variety of positions of increasing responsibility, including: intelligence analyst…and national security expertise, Director Brennan was selected in 2003 to design and serve as the founding director of the Terrorist Threat Integration Center and of its successor…returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and Counterterrorism and Deputy In that role, she has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief. 186186. RETRIEVED EVIDENCE:
In that role, she has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and She is sued in her official capacity. 187187. RETRIEVED EVIDENCE:
She is sued in her official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of
26.
Defendant John L. 189189. RETRIEVED EVIDENCE:
Defendant John L.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of…his official capacity. 21. Defendant Joseph E. diGenova has served as Ratcliffe has served as the current Director of the CIA since January
23, 2025. 190190. RETRIEVED EVIDENCE:
Ratcliffe has served as the current Director of the CIA since January
23, 2025.
GOVERNING EVIDENCE:
N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington…Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief. 191191. RETRIEVED EVIDENCE:
In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and He is sued in his official capacity. 192192. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of
27.
Defendant Central Intelligence Agency is an agency that engages in intelligence operations and analysis for the U.S. government. 194194. RETRIEVED EVIDENCE:
Defendant Central Intelligence Agency is an agency that engages in intelligence operations and analysis for the U.S. government.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief. 195195. RETRIEVED EVIDENCE:
It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE
28.
Defendant Office of the Director of National Intelligence is an agency that provides oversight to the intelligence community. 197197. RETRIEVED EVIDENCE:
Defendant Office of the Director of National Intelligence is an agency that provides oversight to the intelligence community.
GOVERNING EVIDENCE:
Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW…the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief. 198198. RETRIEVED EVIDENCE:
It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE
JURISDICTION AND VENUE
29. 199199. RETRIEVED EVIDENCE:
JURISDICTION AND VENUE
29.
GOVERNING EVIDENCE:
7 JURISDICTION AND VENUE…that would have the records to be preserved under the requested injunctive relief. JURISDICTION AND VENUE 29. This Court has jurisdiction under 28 U.S.C. 1331, which provides that "[t]he district courts shall have original…the Constitution, laws, or treaties of the United States." Id. This Court also has jurisdiction pursuant to 28 U.S.C. 1361, which grants original jurisdiction to the district…owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in this district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events…Deputy Attorney General and FBI Director - work in the District of Columbia. Finally, there is venue under 28 U.S.C. 1391(e)(1)(A) because a defendant in the action resides in the…to 28 U.S.C. 1361 and 1651. COUNT 3 Injunctive Relief in Aid Of The Court's Jurisdiction Under the All Writs Act (28 U.S.C. 1651) 75. Director Brennan re-alleges and
This Court has jurisdiction under 28 U.S.C. 200200. RETRIEVED EVIDENCE:
This Court has jurisdiction under 28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal 1331, which provides that "[t]he district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States." Id. 201201. RETRIEVED EVIDENCE:
1331, which provides that "[t]he district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States." Id.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal This Court also has jurisdiction pursuant to 28 U.S.C. 202202. RETRIEVED EVIDENCE:
This Court also has jurisdiction pursuant to 28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason 1361,
which grants original jurisdiction to the district courts over "any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform aduty owed to the plaintiff."
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611
30. 203203. RETRIEVED EVIDENCE:
1361,
which grants original jurisdiction to the district courts over "any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform aduty owed to the plaintiff."
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611
30.
GOVERNING EVIDENCE:
OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…that would have the records to be preserved under the requested injunctive relief. JURISDICTION AND VENUE 29. This Court has jurisdiction under 28 U.S.C. 1331, which provides that "[t]he district courts shall have original…under the Constitution, laws, or treaties of the United States." Id. This Court also has jurisdiction pursuant to 28 U.S.C. 1361, which grants original jurisdiction to the district courts over "any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in
Venue lies in this district under 28 U.S.C. 204204. RETRIEVED EVIDENCE:
Venue lies in this district under 28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates…the records to be preserved under the requested injunctive relief. JURISDICTION AND VENUE 29. This Court has jurisdiction under 28 U.S.C. 1331, which provides that "[t]he 1391(e)(1)(B) because a "substantial part of the events or omissions" has occurred or is occurring in the District of Columbia. 205205. RETRIEVED EVIDENCE:
1391(e)(1)(B) because a "substantial part of the events or omissions" has occurred or is occurring in the District of Columbia.
GOVERNING EVIDENCE:
Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates…Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in this district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events or omissions" has occurred or is occurring in the District of Columbia. A grand jury in the District of Columbia opened an Agrand jury in the District of Columbia opened an investigation and issued subpoenas in relation to the allegation that Director Brennan made false statements to Congress. 206206. RETRIEVED EVIDENCE:
Agrand jury in the District of Columbia opened an investigation and issued subpoenas in relation to the allegation that Director Brennan made false statements to Congress.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel The government prosecutors have informed Director Brennan that any false-statements case must be filed in the District of Columbia because that is where the allegedly criminal act occurred. 207207. RETRIEVED EVIDENCE:
The government prosecutors have informed Director Brennan that any false-statements case must be filed in the District of Columbia because that is where the allegedly criminal act occurred.
GOVERNING EVIDENCE:
L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…Investigation ....................................................... 12 B. The False-Statements Investigation .........................................................…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ...................................................................…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the decision-making and coordination by Obama and Biden Administration officials that current Justice Department officials consider to be overt acts in furtherance of aconspiracy to deny President Trump his civil rights. 208208. RETRIEVED EVIDENCE:
Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the decision-making and coordination by Obama and Biden Administration officials that current Justice Department officials consider to be overt acts in furtherance of aconspiracy to deny President Trump his civil rights.
GOVERNING EVIDENCE:
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney…950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Moreover, a number of the Justice Department officials making decisions about the investigations - including the Acting Attorney General, Deputy Attorney General and FBI Director - work in the District of Columbia. Finally, there is venue under 28
U.S.C. 210210. RETRIEVED EVIDENCE:
Finally, there is venue under 28
U.S.C.
GOVERNING EVIDENCE:
JURISDICTION AND VENUE…owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in this district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events…General, Deputy Attorney General and FBI Director - work in the District of Columbia. Finally, there is venue under 28 U.S.C. 1391(e)(1)(A) because a defendant in the action resides in the…documents case against President Trump was manufactured by the Biden Administration. 30 Finally, diGenova has publicly pronounced Director Brennan guilty of participation in the…weaponization" (see supra note 47), but the post was deleted from his X account the next morning. 61 Finally, in a recent challenge to the Administration's mass terminations of government employees, discovery…//perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 36 of 4633 charges. When the judge finally received and reviewed unredacted copies of the transcripts, she observed, "I have never 1391(e)(1)(A) because a defendant in the action resides in the District of Columbia, i.e.,
the Department of Justice is located at 950 Pennsylvania Ave. 211211. RETRIEVED EVIDENCE:
1391(e)(1)(A) because a defendant in the action resides in the District of Columbia, i.e.,
the Department of Justice is located at 950 Pennsylvania Ave.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E…Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump NW, Washington, D.C. 212212. RETRIEVED EVIDENCE:
NW, Washington, D.C.
GOVERNING EVIDENCE:
in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the…capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed…THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF 20530,
and the Executive Office of the President is located at 1600 Pennsylvania Ave. 213213. RETRIEVED EVIDENCE:
20530,
and the Executive Office of the President is located at 1600 Pennsylvania Ave.
GOVERNING EVIDENCE:
P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss NW,
Washington, D.C. 214214. RETRIEVED EVIDENCE:
NW,
Washington, D.C.
GOVERNING EVIDENCE:
in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the…capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed…THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF 20500.
STANDING
31. 216216. RETRIEVED EVIDENCE:
STANDING
31.
GOVERNING EVIDENCE:
10 STANDING…of the President is located at 1600 Pennsylvania Ave. NW, Washington, D.C. 20500. STANDING 31. Director Brennan has standing because he has been, or imminently will be, injured as a result of the Defendants…Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between
Director Brennan has standing because he has been, or imminently will be, injured as aresult of the Defendants' conduct. 217217. RETRIEVED EVIDENCE:
Director Brennan has standing because he has been, or imminently will be, injured as aresult of the Defendants' conduct.
GOVERNING EVIDENCE:
Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights See U.S. Const. 218218. RETRIEVED EVIDENCE:
See U.S. Const.
GOVERNING EVIDENCE:
been, or imminently will be, injured as a result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of art. 219219. RETRIEVED EVIDENCE:
art.
GOVERNING EVIDENCE:
been, or imminently will be, injured as a result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish III, 2; Lujan v. 221221. RETRIEVED EVIDENCE:
Lujan v.
GOVERNING EVIDENCE:
be, injured as a result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff…or defendants, and a likelihood that the injury will be redressed by a favorable decision. Lujan, 504 U.S. at 560-61. Here, Director Brennan meets those three requirements. The injury is Defs. 222222. RETRIEVED EVIDENCE:
Defs.
GOVERNING EVIDENCE:
as a result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must of Wildlife, 504
U.S. 555, 561 (1992). 223223. RETRIEVED EVIDENCE:
of Wildlife, 504
U.S. 555, 561 (1992).
GOVERNING EVIDENCE:
result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct by the defendant or defendants, and alikelihood that the injury will be redressed by a favorable decision. 224224. RETRIEVED EVIDENCE:
To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct by the defendant or defendants, and alikelihood that the injury will be redressed by a favorable decision.
GOVERNING EVIDENCE:
of address filed under seal, Plaintiff v. TODD W. BLANCHE, in…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Lujan, 504 U.S. at 560-61. 225225. RETRIEVED EVIDENCE:
Lujan, 504 U.S. at 560-61.
GOVERNING EVIDENCE:
be, injured as a result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff…or defendants, and a likelihood that the injury will be redressed by a favorable decision. Lujan, 504 U.S. at 560-61. Here, Director Brennan meets those three requirements. The injury is…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of
Here, Director Brennan meets those three requirements. 226226. RETRIEVED EVIDENCE:
Here, Director Brennan meets those three requirements.
GOVERNING EVIDENCE:
FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave…Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights The injury is the very real prospect that the government will fail to preserve the records he would need to challenge an indictment and Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 15 of 4612
protect his Due Process and Equal Protection rights not to be vindictively or selectively prosecuted. 227227. RETRIEVED EVIDENCE:
The injury is the very real prospect that the government will fail to preserve the records he would need to challenge an indictment and Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 15 of 4612
protect his Due Process and Equal Protection rights not to be vindictively or selectively prosecuted.
GOVERNING EVIDENCE:
Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution That injury will be directly due to the government'saction - or inaction - in regard to its preservation obligations, and the injury will be directly redressed by a judicial injunction ordering the government to preserve those records. 228228. RETRIEVED EVIDENCE:
That injury will be directly due to the government'saction - or inaction - in regard to its preservation obligations, and the injury will be directly redressed by a judicial injunction ordering the government to preserve those records.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE
FACTUAL BACKGROUND I. 229229. RETRIEVED EVIDENCE:
FACTUAL BACKGROUND I.
GOVERNING EVIDENCE:
11 FACTUAL BACKGROUND…by a judicial injunction ordering the government to preserve those records. FACTUAL BACKGROUND I. The Justice Department has Opened Two Criminal Investigations that Target Director…Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution 51. This background provides a strong factual foundation for moving to dismiss any indictment that may
The Justice Department has Opened Two Criminal Investigations that Target Director Brennan
32. 230230. RETRIEVED EVIDENCE:
The Justice Department has Opened Two Criminal Investigations that Target Director Brennan
32.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel
There are currently two ongoing federal grand jury investigations examining past conduct by Director Brennan. 231231. RETRIEVED EVIDENCE:
There are currently two ongoing federal grand jury investigations examining past conduct by Director Brennan.
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg According to conversations with the supervising prosecutors, Director Brennan has been officially designated as the target - in fact, so far as undersigned counsel is aware, the only currently declared target - of both investigations. 232232. RETRIEVED EVIDENCE:
According to conversations with the supervising prosecutors, Director Brennan has been officially designated as the target - in fact, so far as undersigned counsel is aware, the only currently declared target - of both investigations.
GOVERNING EVIDENCE:
20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…1 Filed 07/01/26 Page 8 of 465 personnel who had worked on the ICA, requiring them to testify before the grand jury in the false-statements investigation. Those subpoenas were…need to scrutinize the motivations of the Justice Department officials who directed, oversaw, or undertook those actions to determine whether they violated Director Brennan's rights, and…counterintelligence, and liaison relationships with foreign intelligence services. He testified to Congressional Committees dozens of times as Director and was unwavering in his…Kash P. Patel has served as the Director of the FBI since February 20, 2025. He supervises FBI agents and other personnel who are working on the Brennan investigations. In that These two investigations are the product of acarefully orchestrated series of referrals claiming Director Brennan's involvement in theoretical criminal activity. 233233. RETRIEVED EVIDENCE:
These two investigations are the product of acarefully orchestrated series of referrals claiming Director Brennan's involvement in theoretical criminal activity.
GOVERNING EVIDENCE:
has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from
A.
The Grand Conspiracy Investigation
33. 235235. RETRIEVED EVIDENCE:
The Grand Conspiracy Investigation
33.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…with the Two Brennan Investigations…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions
The "grand conspiracy" investigation originated with two Intelligence Community pronouncements about Director Brennan'sactivities relating to the ICA - one by CIA Director John Ratcliffe on July 8, 2025 and the second by then-Director of National Intelligence Tulsi Gabbard ten days later. 236236. RETRIEVED EVIDENCE:
The "grand conspiracy" investigation originated with two Intelligence Community pronouncements about Director Brennan'sactivities relating to the ICA - one by CIA Director John Ratcliffe on July 8, 2025 and the second by then-Director of National Intelligence Tulsi Gabbard ten days later.
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights Both referrals were styled and publicly trumpeted as "criminal referrals,"
despite their failure to explain how the activities they describe constitute acrime. 237237. RETRIEVED EVIDENCE:
Both referrals were styled and publicly trumpeted as "criminal referrals,"
despite their failure to explain how the activities they describe constitute acrime.
GOVERNING EVIDENCE:
Justice Department Officials Publicly Discuss Grand Jury…his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his…that purport to be investigating Director Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand…record that many in the Administration and in the Justice Department specifically are failing to observe their legal obligation to maintain such records. 11. The loss of these…collaboration within the U.S. counterterrorism community that contributed to the failure to prevent the 9/11 terrorist attacks. 15. Following his retirement from the CIA in…meets those three requirements. The injury is the very real prospect that the government will fail to preserve the records he would need to challenge an indictment and Case 1:26-cv-02323
Notwithstanding the lack of that critical predicate, President Trump's Justice Department dutifully established a "strike force" to investigate whether Director Brennan, President Obama and numerous other Obama and Biden Administration officials conspired to deny President Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 16 of 4613
Trump his civil rights with the series of federal investigations and prosecutions relating to the
2016 election and to President Trump'sconduct in and out of office. 238238. RETRIEVED EVIDENCE:
Notwithstanding the lack of that critical predicate, President Trump's Justice Department dutifully established a "strike force" to investigate whether Director Brennan, President Obama and numerous other Obama and Biden Administration officials conspired to deny President Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 16 of 4613
Trump his civil rights with the series of federal investigations and prosecutions relating to the
2016 election and to President Trump'sconduct in and out of office.
GOVERNING EVIDENCE:
Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A
3
B.
The False-Statements Investigation
34. 240240. RETRIEVED EVIDENCE:
The False-Statements Investigation
34.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in
The false-statements investigation originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi. 241241. RETRIEVED EVIDENCE:
The false-statements investigation originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi.
GOVERNING EVIDENCE:
to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in
4
In that letter, Chairman Jordan, aclose ally of President Trump, refers for investigation - without any valid factual basis - an allegation that Director Brennan lied in
2023 testimony before the House Judiciary Committee when he discussed the role of the Steele Dossier (which was reportedly a batch of materials about then candidate Trump that had been assembled as opposition research by aformer British intelligence officer)
5
in the production of the ICA. 242242. RETRIEVED EVIDENCE:
4
In that letter, Chairman Jordan, aclose ally of President Trump, refers for investigation - without any valid factual basis - an allegation that Director Brennan lied in
2023 testimony before the House Judiciary Committee when he discussed the role of the Steele Dossier (which was reportedly a batch of materials about then candidate Trump that had been assembled as opposition research by aformer British intelligence officer)
5
in the production of the ICA.
GOVERNING EVIDENCE:
Investigation ....................................................... 12 B. The False-Statements Investigation…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions…He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal…and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice
II.
The Government has Engaged, and Continues to Engage, in Unprecedented,
Irregular Conduct in Connection with the Two Brennan Investigations
35. 244244. RETRIEVED EVIDENCE:
The Government has Engaged, and Continues to Engage, in Unprecedented,
Irregular Conduct in Connection with the Two Brennan Investigations
35.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i
Justice Department officials have engaged in avariety of inappropriate activities in their attempt to build aprosecutable case on the hollow foundation of these "criminal referrals."
3
Hannah Rabinowitz, Attorney General Bondi Orders Prosecutors to Start Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 245245. RETRIEVED EVIDENCE:
Justice Department officials have engaged in avariety of inappropriate activities in their attempt to build aprosecutable case on the hollow foundation of these "criminal referrals."
3
Hannah Rabinowitz, Attorney General Bondi Orders Prosecutors to Start Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug.
GOVERNING EVIDENCE:
Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump 4, 2025),
https://perma.cc/HCG8
H5KJ
; 246246. RETRIEVED EVIDENCE:
4, 2025),
https://perma.cc/HCG8
H5KJ
;
GOVERNING EVIDENCE:
Private Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Press Release, U.S. Dep'tof Just., Justice Department Announces Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025),
https://perma.cc/ZFX6-KC5A
; 247247. RETRIEVED EVIDENCE:
Press Release, U.S. Dep'tof Just., Justice Department Announces Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025),
https://perma.cc/ZFX6-KC5A
;
GOVERNING EVIDENCE:
THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016 presidential election in an…his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand
Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Investigation into Russiagate Conspiracy Allegations: 248248. RETRIEVED EVIDENCE:
Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Investigation into Russiagate Conspiracy Allegations:
GOVERNING EVIDENCE:
Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently…two sets of grand jury subpoenas - one set seeking documents relating to the supposed "grand conspiracy" and the other relating to Director Brennan's alleged false statements to…General since April 20, 2026. He has been assigned to lead the investigations into the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress. In that…the allegedly criminal act occurred. Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the decision-making and…claiming Director Brennan's involvement in theoretical criminal activity. A. The Grand Conspiracy Investigation 33. The "grand conspiracy" investigation originated with two Intelligence Community pronouncements about Director Sources, Fox News (Aug. 249249. RETRIEVED EVIDENCE:
Sources, Fox News (Aug.
GOVERNING EVIDENCE:
Gibson, DOJ Launching Grand Jury Investigation into Russiagate Conspiracy Allegations: Sources, Fox News (Aug. 4, 2025), https://perma.cc/Q5JS XTZQ ; LA Times Studios, Straight to the Point: The…h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with…her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https…in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the…CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean 4, 2025),
https://perma.cc/Q5JS XTZQ
; 250250. RETRIEVED EVIDENCE:
4, 2025),
https://perma.cc/Q5JS XTZQ
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury LA Times Studios, Straight to the Point: 251251. RETRIEVED EVIDENCE:
LA Times Studios, Straight to the Point:
GOVERNING EVIDENCE:
will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…of 467 the consideration of Director Brennan's legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand…that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama Administration policies on homeland security, pandemics…with foreign intelligence services. He testified to Congressional Committees dozens of times as Director and was unwavering in his commitment to carry out his responsibilities in a The Grand Conspiracy Against Trump
(YouTube, May 7, 2026),
https://www.youtube.com/watch? 252252. RETRIEVED EVIDENCE:
The Grand Conspiracy Against Trump
(YouTube, May 7, 2026),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L…election in an effort to boost candidate Donald Trump's chances of winning the election. In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that v=h03Rtq3SwYM
(
https://perma.cc/7EBH-NGDC on file with Plaintiff); 253253. RETRIEVED EVIDENCE:
v=h03Rtq3SwYM
(
https://perma.cc/7EBH-NGDC on file with Plaintiff);
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in Hang out with Sean Hannity & Fox News,
Kash Patel Uncovers Secret FBI Documents; 254254. RETRIEVED EVIDENCE:
Hang out with Sean Hannity & Fox News,
Kash Patel Uncovers Secret FBI Documents;
GOVERNING EVIDENCE:
from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions…He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026),
https://www.youtube.com/watch? 255255. RETRIEVED EVIDENCE:
The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
XTZQ ; LA Times Studios, Straight to the Point: The Grand Conspiracy Against Trump (YouTube, May 7, 2026), https://www.youtube.com/watch?v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim…Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts…//perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v=wMZHAfSQ9vo ( https v=0zhi1bmlIjc
(
https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 256256. RETRIEVED EVIDENCE:
v=0zhi1bmlIjc
(
https://perma.cc/QZ2H-WYLZ on file with Plaintiff).
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in
4
Letter from Jim Jordan, Chairman of the H. 257257. RETRIEVED EVIDENCE:
4
Letter from Jim Jordan, Chairman of the H.
GOVERNING EVIDENCE:
federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the…The second investigation centers on an October 21, 2025 referral from Congressman Jim Jordan, Chairman of the House Judiciary Committee, which asserts without valid support that Director…34. The false-statements investigation originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi. 4 In that letter, Chairman Jordan, a close ally of President Trump, refers for investigation - without any valid factual…v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S.…Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had Comm. 258258. RETRIEVED EVIDENCE:
Comm.
GOVERNING EVIDENCE:
on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S. Dep't of Just…Nov. 17, 2025), https://perma.cc/BG4A-UB6V ; Letter from Jamie Raskin, Ranking Member, H. Comm. on the Judiciary, to Edward P. Martin, Jr., Pardon Att'y and Dir., Weaponization…into allegations that he lied in his testimony to the House of Representatives Committee on the Judiciary on May 11, 2023 and the investigation into the "grand conspiracy" being on the Judiciary, 119th Cong., to Pamela J. 259259. RETRIEVED EVIDENCE:
on the Judiciary, 119th Cong., to Pamela J.
GOVERNING EVIDENCE:
of crimes ranging from treason to lying before Congress, and has twice posted doctored images of…conspiracy" and the other relating to Director Brennan's alleged false statements to Congress. Then, over the weekend of April 18, 2026, a federal grand jury in Washington, D.C…and liaison relationships with foreign intelligence services. He testified to Congressional Committees dozens of times as Director and was unwavering in his commitment to carry out…the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress. In that role, he has responsibility over subordinates and record systems that would…subpoenas in relation to the allegation that Director Brennan made false statements to Congress. The government prosecutors have informed Director Brennan that any false-statements…with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S. Dep't of Just. (Oct. 21, 2025), https
Bondi, Att'y Gen., U.S. Dep'tof Just. 260260. RETRIEVED EVIDENCE:
Bondi, Att'y Gen., U.S. Dep'tof Just.
GOVERNING EVIDENCE:
2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases…Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces Formation of Strike Force to Assess Evidence…of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S. Dep't of Just. (Oct. 21, 2025), https://perma.cc/R257-56FL . 5 Trump-Russia Steele…https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009), https://perma.cc/W55M-M7FW (Eric Holder 2009 memo). 20 Memorandum from the Attorney General to All Dep't Emps. (Feb. 5, 2025), https://perma.cc/3PPL-BWER . 21 In-Your-Face DOJ Aide Rides Prosecutors (Oct. 21, 2025),
https://perma.cc/R257-56FL
.
5
Trump-Russia Steele Dossier Source Acquitted of Lying to FBI, BBC (Oct. 262262. RETRIEVED EVIDENCE:
21, 2025),
https://perma.cc/R257-56FL
.
5
Trump-Russia Steele Dossier Source Acquitted of Lying to FBI, BBC (Oct.
GOVERNING EVIDENCE:
from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions…the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016 presidential election in an effort to boost candidate Donald…Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership 18, 2022),
https://perma.cc/2P43-BQ34
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 17 of 4614
Among those activities have been the following: 263263. RETRIEVED EVIDENCE:
18, 2022),
https://perma.cc/2P43-BQ34
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 17 of 4614
Among those activities have been the following:
GOVERNING EVIDENCE:
Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the…in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of issuing pronouncements that evince a pre conceived belief in Director Brennan's guilt; 264264. RETRIEVED EVIDENCE:
issuing pronouncements that evince a pre conceived belief in Director Brennan's guilt;
GOVERNING EVIDENCE:
official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation
6
making statements that disclose matters relating to open grand jury investigations, in apparent violation of Federal Rule of Criminal Procedure
6(e); 265265. RETRIEVED EVIDENCE:
6
making statements that disclose matters relating to open grand jury investigations, in apparent violation of Federal Rule of Criminal Procedure
6(e);
GOVERNING EVIDENCE:
Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming
7
reportedly removing or sidelining career prosecutors who have balked at using the criminal process to promote the President'sretribution agenda; 266266. RETRIEVED EVIDENCE:
7
reportedly removing or sidelining career prosecutors who have balked at using the criminal process to promote the President'sretribution agenda;
GOVERNING EVIDENCE:
Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda…Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and…irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these
8
engaging in apparent forum-shopping by moving the investigations from federal district to federal district in an effort to find a sufficiently pliant United States Attorney;
9
and engaging in apparent judge-shopping. 268268. RETRIEVED EVIDENCE:
9
and engaging in apparent judge-shopping.
GOVERNING EVIDENCE:
13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of…quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will…Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016
10
36.
The scale of this manipulative activity came into focus throughout the fall of 2025, and by December 2025, it became clear that the government was seeking to circumvent standard processes and engineer assignment of the investigation and eventual prosecution of Director Brennan to the docket of a particular judge. 270270. RETRIEVED EVIDENCE:
The scale of this manipulative activity came into focus throughout the fall of 2025, and by December 2025, it became clear that the government was seeking to circumvent standard processes and engineer assignment of the investigation and eventual prosecution of Director Brennan to the docket of a particular judge.
GOVERNING EVIDENCE:
Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to…and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record…issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made…With his return to the White House, the President has gone beyond mere denunciation, and has actively mobilized the machinery of the criminal justice system against Director Brennan. He has…interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second That concern became so pronounced that undersigned counsel submitted aletter to the Chief Judge of the Southern District of Florida alerting her to the government's judge-shopping and asking that she use her supervisory
6
Fox News, DiGenova: 271271. RETRIEVED EVIDENCE:
That concern became so pronounced that undersigned counsel submitted aletter to the Chief Judge of the Southern District of Florida alerting her to the government's judge-shopping and asking that she use her supervisory
6
Fox News, DiGenova:
GOVERNING EVIDENCE:
vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those…of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw, or undertook those actions to determine whether they violated Director Brennan's rights, and John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018)
(clip of Fox News television broadcast),
https://www.youtube.com/watch? 272272. RETRIEVED EVIDENCE:
John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018)
(clip of Fox News television broadcast),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has…Launching Grand Jury Investigation into Russiagate Conspiracy Allegations: Sources, Fox News (Aug. 4, 2025), https://perma.cc/Q5JS XTZQ ; LA Times Studios, Straight to the Point: The Grand Conspiracy Against Trump (YouTube, May 7, 2026), https://www.youtube.com/watch?v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim Jordan v=e7v22N2QrW8
(
https://perma.cc/W5XD-GR43
on file with Plaintiff); 273273. RETRIEVED EVIDENCE:
v=e7v22N2QrW8
(
https://perma.cc/W5XD-GR43
on file with Plaintiff);
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 274274. RETRIEVED EVIDENCE:
Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr.
GOVERNING EVIDENCE:
and Communications to Assess the Prosecutors' Motivations…past conduct by Director Brennan. According to conversations with the supervising prosecutors, Director Brennan has been officially designated as the target - in fact, so far as…of these "criminal referrals." 3 Hannah Rabinowitz, Attorney General Bondi Orders Prosecutors to Start Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4…of Federal Rule of Criminal Procedure 6(e); 7 reportedly removing or sidelining career prosecutors who have balked at using the criminal process to promote the President's retribution…v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https://perma.cc/3LTF-UPW2 . 7 Appendix A, at 15-16. 8 Eric Tucker, Key Prosecutor in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr 27, 2026),
https://perma.cc/3LTF-UPW2
.
7
Appendix A, at 15-16. 275275. RETRIEVED EVIDENCE:
27, 2026),
https://perma.cc/3LTF-UPW2
.
7
Appendix A, at 15-16.
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury
8
Eric Tucker, Key Prosecutor in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr. 276276. RETRIEVED EVIDENCE:
8
Eric Tucker, Key Prosecutor in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions 17, 2026),
https://perma.cc/4362-XJE5
.
9
Appendix A, at8. 277277. RETRIEVED EVIDENCE:
17, 2026),
https://perma.cc/4362-XJE5
.
9
Appendix A, at8.
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had migrated through the U.S. Attorneys' Offices for the Eastern District of Pennsylvania and the Eastern District of Virginia before finding ahome in SDFL. 278278. RETRIEVED EVIDENCE:
As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had migrated through the U.S. Attorneys' Offices for the Eastern District of Pennsylvania and the Eastern District of Virginia before finding ahome in SDFL.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Recent reporting indicates that FBI Director Kash Patel also shopped the investigations to the Western District of Virginia in July 2025. 279279. RETRIEVED EVIDENCE:
Recent reporting indicates that FBI Director Kash Patel also shopped the investigations to the Western District of Virginia in July 2025.
GOVERNING EVIDENCE:
Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE…Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel See Devlin Barrett, How the Drive to Find a Conspiracy Against Trump Rocked the Justice Dept., N.Y. 280280. RETRIEVED EVIDENCE:
See Devlin Barrett, How the Drive to Find a Conspiracy Against Trump Rocked the Justice Dept., N.Y.
GOVERNING EVIDENCE:
NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A…13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case Times (June 8, 2026),
https://perma.cc/63DZ-3KUH
.
10
Appendix A, at 10-11. 281281. RETRIEVED EVIDENCE:
Times (June 8, 2026),
https://perma.cc/63DZ-3KUH
.
10
Appendix A, at 10-11.
GOVERNING EVIDENCE:
will not be preserved until such time as the court can review them for evidence of…potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1…as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying before…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…of 467 the consideration of Director Brennan's legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 18 of 4615
authority to ensure that any judicial assignment be done pursuant to the court's neutral and impartial processes. 282282. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 18 of 4615
authority to ensure that any judicial assignment be done pursuant to the court's neutral and impartial processes.
GOVERNING EVIDENCE:
24 IV. The Court Reviewing the Vindictive and Selective Prosecution…of selective and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who…of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9. To perform that scrutiny after an indictment, the Court would demand…relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery obligations. These technologies include…records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous…laws, or treaties of the United States." Id. This Court also has jurisdiction pursuant to 28 U.S.C. 1361, which grants original jurisdiction to the district courts over
11
37.
Despite the concerns laid out in that letter, the Justice Department remains seemingly committed to its plan to steer any investigation and eventual prosecution of the "grand conspiracy" case to the Fort Pierce Division of the Southern District of Florida and to the only judge in that Division - Judge Aileen Cannon. 284284. RETRIEVED EVIDENCE:
Despite the concerns laid out in that letter, the Justice Department remains seemingly committed to its plan to steer any investigation and eventual prosecution of the "grand conspiracy" case to the Fort Pierce Division of the Southern District of Florida and to the only judge in that Division - Judge Aileen Cannon.
GOVERNING EVIDENCE:
THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming This April, the prosecution team established its headquarters in the U.S. Attorney's Office in Fort Pierce. 285285. RETRIEVED EVIDENCE:
This April, the prosecution team established its headquarters in the U.S. Attorney's Office in Fort Pierce.
GOVERNING EVIDENCE:
JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL…Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the…the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent
12
Fort Pierce is situated approximately
130 miles away from the currently open grand juries and from the investigating personnel in the FBI field office and the main SDFL U.S. Attorney's Office in Miami. 286286. RETRIEVED EVIDENCE:
12
Fort Pierce is situated approximately
130 miles away from the currently open grand juries and from the investigating personnel in the FBI field office and the main SDFL U.S. Attorney's Office in Miami.
GOVERNING EVIDENCE:
QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and It is five states away from Washington, D.C., where the vast majority of the supposed conspiratorial acts in the "grand conspiracy" took place. 287287. RETRIEVED EVIDENCE:
It is five states away from Washington, D.C., where the vast majority of the supposed conspiratorial acts in the "grand conspiracy" took place.
GOVERNING EVIDENCE:
as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The…823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed…as publicly described by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the As such, the only apparent rationale for locating in Fort Pierce is to carry out the Justice Department's judge-shopping plan. 288288. RETRIEVED EVIDENCE:
As such, the only apparent rationale for locating in Fort Pierce is to carry out the Justice Department's judge-shopping plan.
GOVERNING EVIDENCE:
THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016…of a conspiracy to deny President Trump his civil rights. The second investigation centers on an October 21, 2025 referral from Congressman Jim Jordan, Chairman of the House…to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small…and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw
38.
The letter to Chief Judge Altonaga lays out many of the government'sirregular actions up to that time. 290290. RETRIEVED EVIDENCE:
The letter to Chief Judge Altonaga lays out many of the government'sirregular actions up to that time.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i To avoid repeating their details here, that letter is incorporated by reference and included as Appendix A, and this complaint will focus on the occurrence of like incidents since its submission on December 22, 2025. 291291. RETRIEVED EVIDENCE:
To avoid repeating their details here, that letter is incorporated by reference and included as Appendix A, and this complaint will focus on the occurrence of like incidents since its submission on December 22, 2025.
GOVERNING EVIDENCE:
TABLE OF CONTENTS Page i COMPLAINT…D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice Department have succumbed to pressure from the…widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small subset of officials, and the vast majority of Justice Department…be, pursuant to the government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such…of Justice is a federal agency responsible for enforcing federal criminal laws. It includes government personnel and record systems that would have the records to be preserved under the…Office of the President provides operational and management support to the President. It includes government personnel and record systems that would have the records to be preserved under the
13
The record shows that government officials have not only maintained - but have actually increased - the pace of irregular activities over the past six months. 292292. RETRIEVED EVIDENCE:
13
The record shows that government officials have not only maintained - but have actually increased - the pace of irregular activities over the past six months.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington This irregularity is evident in numerous areas of the government's conduct in this matter. 293293. RETRIEVED EVIDENCE:
This irregularity is evident in numerous areas of the government's conduct in this matter.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i
11
See Letter from Counsel for Director John O. 294294. RETRIEVED EVIDENCE:
11
See Letter from Counsel for Director John O.
GOVERNING EVIDENCE:
capacity as Director of the Federal Bureau…Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in Brennan to Chief Judge Cecilia M. 295295. RETRIEVED EVIDENCE:
Brennan to Chief Judge Cecilia M.
GOVERNING EVIDENCE:
in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…fully consider those motions, the reviewing judge would need to scrutinize the…effort to find a sufficiently pliant United States Attorney; 9 and engaging in apparent judge-shopping. 10 36. The scale of this manipulative activity came into focus throughout…the investigation and eventual prosecution of Director Brennan to the docket of a particular judge. That concern became so pronounced that undersigned counsel submitted a letter to the Chief Judge of the Southern District of Florida alerting her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Altonaga,
U.S. Dist. 296296. RETRIEVED EVIDENCE:
Altonaga,
U.S. Dist.
GOVERNING EVIDENCE:
from Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https://perma.cc/3UX5-XCMT (Appendix A). 12…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of Ct. 297297. RETRIEVED EVIDENCE:
Ct.
GOVERNING EVIDENCE:
Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https://perma.cc/3UX5-XCMT (Appendix A for S.D. 298298. RETRIEVED EVIDENCE:
for S.D.
GOVERNING EVIDENCE:
Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https://perma.cc/3UX5-XCMT (Appendix A). 12 Paula…Authors Guild v. Nat'l Endowment for the Humanities, 2025 WL 3678097, at *12 (S.D.N.Y. Dec. 18, 2025). Finally, in a recent challenge to the termination of federal…of a party's constitutional rights." Gayle v. Meade, 614 F. Supp. 3d 1175, 1206 (S.D. Fla. 2020) (internal quotation marks omitted); see Honeyfund.com Inc. v. Governor of Florida Fla., at 15-16 (Dec. 299299. RETRIEVED EVIDENCE:
Fla., at 15-16 (Dec.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia…Attorney for the Southern District of Florida since August 13, 2025. In 22, 2025),
https://perma.cc/3UX5-XCMT
(Appendix A). 300300. RETRIEVED EVIDENCE:
22, 2025),
https://perma.cc/3UX5-XCMT
(Appendix A).
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury
12
Paula Reld & Evan Perez, Justice Department Adds Former Trump Lawyer to Investigation of Trump Critic John Brennan, CNN (Apr. 301301. RETRIEVED EVIDENCE:
12
Paula Reld & Evan Perez, Justice Department Adds Former Trump Lawyer to Investigation of Trump Critic John Brennan, CNN (Apr.
GOVERNING EVIDENCE:
STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th…....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate 18, 2026),
https://perma.cc/Z6XV-DNK3
; 302302. RETRIEVED EVIDENCE:
18, 2026),
https://perma.cc/Z6XV-DNK3
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Evan Perez
& Hannah Rabinowitz, Inside the Justice Department's Shakeup of the John Brennan Investigation, CNN (May 8, 2026),
https://perma.cc/S58G-9MTK
.
13
See generally Appendix A. 303303. RETRIEVED EVIDENCE:
Evan Perez
& Hannah Rabinowitz, Inside the Justice Department's Shakeup of the John Brennan Investigation, CNN (May 8, 2026),
https://perma.cc/S58G-9MTK
.
13
See generally Appendix A.
GOVERNING EVIDENCE:
UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama Administration…W. Blanche is the Acting Attorney General of the United States. He leads the Department of Justice and has been in this position since April 2026. In that role, he has Case 1:26-cv-02323…relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes…a defendant in the action resides in the District of Columbia, i.e., the Department of Justice is located at 950 Pennsylvania Ave. NW, Washington, D.C. 20530, and the Executive
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 19 of 4616
A. 304304. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 19 of 4616
A.
GOVERNING EVIDENCE:
of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director
Administration Officials Call for Director Brennan's Prosecution
39. 305305. RETRIEVED EVIDENCE:
Administration Officials Call for Director Brennan's Prosecution
39.
GOVERNING EVIDENCE:
in his official capacity as…U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1
Administration officials have increased the drumbeat of explicit calls for Director Brennan'sprosecution over the course of this year. 306306. RETRIEVED EVIDENCE:
Administration officials have increased the drumbeat of explicit calls for Director Brennan'sprosecution over the course of this year.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1 For example, FBI Director Patel said, "We're going to continue to make people like Comey and Brennan and Clapper and Page and Strzok and so many others answer for what Ibelieve are their acts of criminal conduct."
14
Then, on June 2,
2026, in his interview with Sean Hannity, Acting Attorney General Blanche identified alleged members of the "grand conspiracy" as Director Brennan, Comey, Clapper, Biden and Obama and rendered the verdict that "those folks were ... certainly part of it."
15
40. 307307. RETRIEVED EVIDENCE:
For example, FBI Director Patel said, "We're going to continue to make people like Comey and Brennan and Clapper and Page and Strzok and so many others answer for what Ibelieve are their acts of criminal conduct."
14
Then, on June 2,
2026, in his interview with Sean Hannity, Acting Attorney General Blanche identified alleged members of the "grand conspiracy" as Director Brennan, Comey, Clapper, Biden and Obama and rendered the verdict that "those folks were ... certainly part of it."
15
40.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and
The President has also continued to opine about Director Brennan'sguilt, recently reposting a Truth Social post stating that "Barack Obama and his CIA puppet John Brennan cooked up the entire Russia Hoax to steal the 2016 election and overthrow aduly elected President Trump."
16
More significantly, the President has affirmatively demanded that his Justice Department serve up aprosecution, posting a Truth Social message on May 11, 2026 expressly urging Acting Attorney General Blanche to indict Director Brennan, Hillary Clinton and President Obama,
17
and following up two weeks later with the posting of aconcocted image showing Director Brennan with seven other Obama Administration officials in orange
14
Katelyn Polantz, Hannah Rabinowitz & Evan Perez, Justice Department Leans on Prosecutors in Brennan Probe as Other Trump-Foe Investigations Fizzle, CNN (Mar. 308308. RETRIEVED EVIDENCE:
The President has also continued to opine about Director Brennan'sguilt, recently reposting a Truth Social post stating that "Barack Obama and his CIA puppet John Brennan cooked up the entire Russia Hoax to steal the 2016 election and overthrow aduly elected President Trump."
16
More significantly, the President has affirmatively demanded that his Justice Department serve up aprosecution, posting a Truth Social message on May 11, 2026 expressly urging Acting Attorney General Blanche to indict Director Brennan, Hillary Clinton and President Obama,
17
and following up two weeks later with the posting of aconcocted image showing Director Brennan with seven other Obama Administration officials in orange
14
Katelyn Polantz, Hannah Rabinowitz & Evan Perez, Justice Department Leans on Prosecutors in Brennan Probe as Other Trump-Foe Investigations Fizzle, CNN (Mar.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants…11 FACTUAL BACKGROUND…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss 10, 2026),
https://perma.cc/HNA6-LTUF
.
15
Hang Out with Sean Hannity & Fox News, Todd Blanche: 309309. RETRIEVED EVIDENCE:
10, 2026),
https://perma.cc/HNA6-LTUF
.
15
Hang Out with Sean Hannity & Fox News, Todd Blanche:
GOVERNING EVIDENCE:
v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc…Other Trump-Foe Investigations Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v…that Fox News felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean Hannity reminding the audience that none of the accused individuals has been charged with any…TzjzcAZauPc ( https://perma.cc/BAE6-YVH6 on file with Plaintiff). 32 Tamar Auber, Joe diGenova to Hannity: John Brennan is the "Real Traitor", Mediaite (July 18, 2018) (clip of Fox News The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube,
June 2, 2026),
https://www.youtube.com/watch? 310310. RETRIEVED EVIDENCE:
The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube,
June 2, 2026),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
As in the above cases, the evidence of vindictiveness in this matter is…a very real risk, however, that some of these materials and communications will no longer exist by the time any such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government…AI queries, and the like that are not routinely preserved. 2 Second, there is ample evidence in the public record that many in the Administration and in the Justice Department…fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true…on pre-trial sanctions as a remedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 12. For this v=wMZHAfSQ9vo
(
https://perma.cc/9X48
5XX5
on file with Plaintiff). 311311. RETRIEVED EVIDENCE:
v=wMZHAfSQ9vo
(
https://perma.cc/9X48
5XX5
on file with Plaintiff).
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in The accusations in the interview were so pointed and unsupported that Fox News felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean Hannity reminding the audience that none of the accused individuals has been charged with any crime. 312312. RETRIEVED EVIDENCE:
The accusations in the interview were so pointed and unsupported that Fox News felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean Hannity reminding the audience that none of the accused individuals has been charged with any crime.
GOVERNING EVIDENCE:
and Truth Social posts to formal media interviews and Presidential statements -…despite their failure to explain how the activities they describe constitute a crime. Notwithstanding the lack of that critical predicate, President Trump's Justice…v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v…what I believe are their acts of criminal conduct." 14 Then, on June 2, 2026, in his interview with Sean Hannity, Acting Attorney General Blanche identified alleged members of the…Other Trump-Foe Investigations Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https See id. at 1:38:39-1:38:59.
16
Donald J. Trump (@realDonaldTrump), Truth Social (May 11, 2026, at 22:15 ET),
https://perma.cc/D4JU-SWQV
.
17
Donald J. 316316. RETRIEVED EVIDENCE:
Trump (@realDonaldTrump), Truth Social (May 11, 2026, at 22:15 ET),
https://perma.cc/D4JU-SWQV
.
17
Donald J.
GOVERNING EVIDENCE:
11 FACTUAL BACKGROUND…records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent…and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has…to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal…from Congressman Jim Jordan, Chairman of the House Judiciary Committee, which asserts without valid support that Director Brennan made false statements about the ICA in a 2023 interview…Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466 10. There is a very real risk, however, that some of these materials and communications will no longer exist by Trump (@realDonaldTrump), Truth Social (May 11, 2026, at 22:40 ET),
https://perma.cc/T2GH-LLC2
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 20 of 4617
jumpsuits. 317317. RETRIEVED EVIDENCE:
Trump (@realDonaldTrump), Truth Social (May 11, 2026, at 22:40 ET),
https://perma.cc/T2GH-LLC2
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 20 of 4617
jumpsuits.
GOVERNING EVIDENCE:
11 FACTUAL BACKGROUND…and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has…to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal…from Congressman Jim Jordan, Chairman of the House Judiciary Committee, which asserts without valid support that Director Brennan made false statements about the ICA in a 2023 interview…Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466 10. There is a very real risk, however, that some of these materials and communications will no longer exist by…the full record of contemporaneous communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions. And Director Brennan and the
18
See Appendix Bfor a selection of President Trump'sposts and statements regarding Director Brennan. 318318. RETRIEVED EVIDENCE:
18
See Appendix Bfor a selection of President Trump'sposts and statements regarding Director Brennan.
GOVERNING EVIDENCE:
as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in…Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss
41.
The President's direct demand for action against Director Brennan has been taken to heart by this Justice Department. 320320. RETRIEVED EVIDENCE:
The President's direct demand for action against Director Brennan has been taken to heart by this Justice Department.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & Contrary to the tradition of insulating prosecutorial decision making from White House influence,
19
the Justice Department leaders in this administration have shed any pretense of honoring such limitations and have unapologetically accepted direction on criminal cases from the White House. 321321. RETRIEVED EVIDENCE:
Contrary to the tradition of insulating prosecutorial decision making from White House influence,
19
the Justice Department leaders in this administration have shed any pretense of honoring such limitations and have unapologetically accepted direction on criminal cases from the White House.
GOVERNING EVIDENCE:
THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small subset of officials, and…W. Blanche is the Acting Attorney General of the United States. He leads the Department of Justice and has been in this position since April 2026. In that role, he has Case 1:26-cv-02323…relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes…a defendant in the action resides in the District of Columbia, i.e., the Department of Justice is located at 950 Pennsylvania Ave. NW, Washington, D.C. 20530, and the Executive…2025. See Devlin Barrett, How the Drive to Find a Conspiracy Against Trump Rocked the Justice Dept., N.Y. Times (June 8, 2026), https://perma.cc/63DZ-3KUH . 10 Appendix A, at 10-11. Case Soon after President Trump'sinauguration, then-Attorney General Bondi issued amemorandum advising Department attorneys that they are to serve the
"interests ... of the United States" as defined by the President and to serve as "his lawyers."
20
More recently, Associate Deputy Attorney General Aakash Singh gathered the United States Attorneys on avideo call and reminded them that President Trump is their "chief client."
21
42. 322322. RETRIEVED EVIDENCE:
Soon after President Trump'sinauguration, then-Attorney General Bondi issued amemorandum advising Department attorneys that they are to serve the
"interests ... of the United States" as defined by the President and to serve as "his lawyers."
20
More recently, Associate Deputy Attorney General Aakash Singh gathered the United States Attorneys on avideo call and reminded them that President Trump is their "chief client."
21
42.
GOVERNING EVIDENCE:
official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A
Acting Attorney General Blanche has made clear that this direction to consider President Trump as the "chief client" and act as "his lawyers" translates into allowing the President to dictate the Justice Department'sprosecutorial decision-making. 323323. RETRIEVED EVIDENCE:
Acting Attorney General Blanche has made clear that this direction to consider President Trump as the "chief client" and act as "his lawyers" translates into allowing the President to dictate the Justice Department'sprosecutorial decision-making.
GOVERNING EVIDENCE:
of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P…26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has In recent comments defending the President's September 20, 2025, order to then-Attorney General Bondi to prosecute three of
18
Donald J. 324324. RETRIEVED EVIDENCE:
In recent comments defending the President's September 20, 2025, order to then-Attorney General Bondi to prosecute three of
18
Donald J.
GOVERNING EVIDENCE:
REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A Trump (@realDonaldTrump), Truth Social (May 24, 2026, at 08:01 ET),
https://perma.cc/PN5S-24D9
.
19
Since the post-Watergate era, successive administrations have adopted and largely followed policies limiting communications between the White House and the Justice Department about criminal matters. 325325. RETRIEVED EVIDENCE:
Trump (@realDonaldTrump), Truth Social (May 24, 2026, at 08:01 ET),
https://perma.cc/PN5S-24D9
.
19
Since the post-Watergate era, successive administrations have adopted and largely followed policies limiting communications between the White House and the Justice Department about criminal matters.
GOVERNING EVIDENCE:
Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING…Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the…of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications…and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal These policies were designed to prevent both the reality and the appearance that the Department made charging and other prosecutorial decisions based on the political or personal preferences of the President and the White House. 326326. RETRIEVED EVIDENCE:
These policies were designed to prevent both the reality and the appearance that the Department made charging and other prosecutorial decisions based on the political or personal preferences of the President and the White House.
GOVERNING EVIDENCE:
Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ......................…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A, 2022R00519-B…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these Justin Florence, On the Importance of Limiting White House-DOJ Contacts: 327327. RETRIEVED EVIDENCE:
Justin Florence, On the Importance of Limiting White House-DOJ Contacts:
GOVERNING EVIDENCE:
on the political or personal preferences of the President and the White House. Justin Florence, On the Importance of Limiting White House-DOJ Contacts: It's Not Just About Obstruction, Lawfare (May 22, 2017), https://perma.cc/KS5W-NY27…might be tempted to follow President Trump's orders without regard to legal or ethical limitations. And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL…2. 51 Memorandum from William Fischer, Chief Records Officer, to Fed. Records Mgmt. Contacts (May 2, 2025), https://perma.cc/TAB5-E2ZX . 52 Bernd Debusmann Jr., Trump Deletes Post Depicting…for Crises Across the World, Politico (Apr. 2, 2025), https://perma.cc/6WKP-3K5W . Importantly, the messages about the Yemen strikes were ultimately deleted from the phone of CIA…07/01/26 Page 35 of 4632 memo 64 significantly limited the circumstances under which text communications need to be retained. 62. Importantly, the concern about the preservation of records of It's Not Just About Obstruction, Lawfare (May 22,
2017), https://perma.cc/KS5W-NY27; 328328. RETRIEVED EVIDENCE:
It's Not Just About Obstruction, Lawfare (May 22,
2017), https://perma.cc/KS5W-NY27;
GOVERNING EVIDENCE:
had interfered in the 2016…but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years…Florence, On the Importance of Limiting White House-DOJ Contacts: It's Not Just About Obstruction, Lawfare (May 22, 2017), https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to the Heads of Dep't Components, All U.S.…the right to "take appropriate action to prevent the bar disciplinary authorities from interfering with the Attorney General's review of the allegations." 45 And, the President himself is using…a controversial post indicating that the Department would pursue an alternative to the derailed plan to establish a fund to compensate victims of supposed "weaponization" (see supra…its interests. For example, in the prosecution of Congresswoman LaMonica McIver for interfering with federal officers during a fracas while conducting an oversight visit to an ICE Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009),
https://perma.cc/W55M-M7FW
(Eric Holder 2009 memo). 329329. RETRIEVED EVIDENCE:
Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009),
https://perma.cc/W55M-M7FW
(Eric Holder 2009 memo).
GOVERNING EVIDENCE:
In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on…Private Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How
20
Memorandum from the Attorney General to All Dep't Emps. 330330. RETRIEVED EVIDENCE:
20
Memorandum from the Attorney General to All Dep't Emps.
GOVERNING EVIDENCE:
U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99…JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on (Feb. 5, 2025),
https://perma.cc/3PPL-BWER
.
21
In-Your-Face DOJ Aide Rides Prosecutors for 'Chief Client' Trump, Bloomberg Law (Feb. 332332. RETRIEVED EVIDENCE:
5, 2025),
https://perma.cc/3PPL-BWER
.
21
In-Your-Face DOJ Aide Rides Prosecutors for 'Chief Client' Trump, Bloomberg Law (Feb.
GOVERNING EVIDENCE:
and Communications to Assess the Prosecutors' Motivations…communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions. And Director Brennan and the Court cannot rely on pre-trial…the allegation that Director Brennan made false statements to Congress. The government prosecutors have informed Director Brennan that any false-statements case must be filed in the…past conduct by Director Brennan. According to conversations with the supervising prosecutors, Director Brennan has been officially designated as the target - in fact, so far as…of these "criminal referrals." 3 Hannah Rabinowitz, Attorney General Bondi Orders Prosecutors to Start Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4…of Federal Rule of Criminal Procedure 6(e); 7 reportedly removing or sidelining career prosecutors who have balked at using the criminal process to promote the President's retribution
19, 2026),
https://perma.cc/6VQG-3HUM
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 21 of 4618
his adversaries,
22
he contended that the American people should be "happy" that the President is directing the Justice Department'sprosecution decisions. 333333. RETRIEVED EVIDENCE:
19, 2026),
https://perma.cc/6VQG-3HUM
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 21 of 4618
his adversaries,
22
he contended that the American people should be "happy" that the President is directing the Justice Department'sprosecution decisions.
GOVERNING EVIDENCE:
16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department…D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A, 2022R00519-B, 2022R00519-C
23
B.
The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda
43. 335335. RETRIEVED EVIDENCE:
The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda
43.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON…Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida
Contrary to established norms, the Justice Department has made a number of extraordinary personnel moves to carry out the President'sretribution campaign against Director Brennan. 336336. RETRIEVED EVIDENCE:
Contrary to established norms, the Justice Department has made a number of extraordinary personnel moves to carry out the President'sretribution campaign against Director Brennan.
GOVERNING EVIDENCE:
Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights The most notable such move was the removal of Attorney General Bondi. 337337. RETRIEVED EVIDENCE:
The most notable such move was the removal of Attorney General Bondi.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are…that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 12. For this reason, Director Brennan brings this action It has been reported that the President fired Attorney General Bondi in part out of frustration that she had not served up the grand conspiracy prosecution that he was demanding. 338338. RETRIEVED EVIDENCE:
It has been reported that the President fired Attorney General Bondi in part out of frustration that she had not served up the grand conspiracy prosecution that he was demanding.
GOVERNING EVIDENCE:
official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A In an interview the day after Bondi was fired, now-Counsel to the Attorney General Joseph diGenova explained that
[t]he President's conversation with [Attorney General Pam Bondi] yesterday coming back from the Supreme Court was not pleasant. 339339. RETRIEVED EVIDENCE:
In an interview the day after Bondi was fired, now-Counsel to the Attorney General Joseph diGenova explained that
[t]he President's conversation with [Attorney General Pam Bondi] yesterday coming back from the Supreme Court was not pleasant.
GOVERNING EVIDENCE:
QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal We are told by people who were briefed on it and by other meetings that she held that day that the president was ripping mad about the fact that there was no progress on the lawfare investigation in Miami. 340340. RETRIEVED EVIDENCE:
We are told by people who were briefed on it and by other meetings that she held that day that the president was ripping mad about the fact that there was no progress on the lawfare investigation in Miami.
GOVERNING EVIDENCE:
to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and
24In April, the lead career prosecutor on the Brennan investigations was removed from the case. 341341. RETRIEVED EVIDENCE:
24In April, the lead career prosecutor on the Brennan investigations was removed from the case.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ...................................................................….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and
Maria Medetis Long, ahighly respected, long-tenured Justice Department veteran with deep experience in complex investigations and prosecutions, was reportedly removed shortly after telling senior DOJ leaders that "the case against [Director] Brennan was too weak to bring."
25
In AUSA Medetis Long'splace, diGenova was appointed as Counselor to the Attorney General and
22
Kristen Welker & Rebecca Shabad, Trump Accidentally Posted Message Pressuring Pam Bondi to Charge his Enemies, Source Says, NBC News (Oct. 342342. RETRIEVED EVIDENCE:
Maria Medetis Long, ahighly respected, long-tenured Justice Department veteran with deep experience in complex investigations and prosecutions, was reportedly removed shortly after telling senior DOJ leaders that "the case against [Director] Brennan was too weak to bring."
25
In AUSA Medetis Long'splace, diGenova was appointed as Counselor to the Attorney General and
22
Kristen Welker & Rebecca Shabad, Trump Accidentally Posted Message Pressuring Pam Bondi to Charge his Enemies, Source Says, NBC News (Oct.
GOVERNING EVIDENCE:
20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…prosecute him as an act of retribution. That scrutiny would be more probing and less deferential to the government than usual because of the Justice Department's recent record of…obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are…that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 12. For this reason, Director Brennan brings this action…of Virginia. 14. Director Brennan's federal government service, which began in August 1980, spanned six Administrations-three Republican and three Democratic. In his 25-year…W. Blanche is the Acting Attorney General of the United States. He leads the Department of Justice and has been in this position since April 2026. In that role, he has Case 1:26-cv-02323 10, 2025),
https://perma.cc/LX38
A439
.
23
Laura Jarrett & Ryan J. 343343. RETRIEVED EVIDENCE:
10, 2025),
https://perma.cc/LX38
A439
.
23
Laura Jarrett & Ryan J.
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Reilly, Todd Blanche Says Americans Should be 'Happy' Trump is Deeply Involved in DOJ, NBC News (Apr. 344344. RETRIEVED EVIDENCE:
Reilly, Todd Blanche Says Americans Should be 'Happy' Trump is Deeply Involved in DOJ, NBC News (Apr.
GOVERNING EVIDENCE:
seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as…t of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN …director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W. Bush to…Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA Distinguished Career…under the requested injunctive relief. 28. Defendant Office of the Director of National Intelligence is an agency that provides oversight to the intelligence community. It 14, 2026),
https://perma.cc/YYJ4-FW67
.
24
Rudolph Giuliani, America's Mayor Live (899): 345345. RETRIEVED EVIDENCE:
14, 2026),
https://perma.cc/YYJ4-FW67
.
24
Rudolph Giuliani, America's Mayor Live (899):
GOVERNING EVIDENCE:
DOJ, NBC News (Apr. 14, 2026), https://perma.cc/YYJ4-FW67 . 24 Rudolph Giuliani, America's Mayor Live (899): Pam Bondi Out as Attorney General with Top Names Emerging to Lead DOJ, at 1…46 These include Rudy Giuliani, Sydney Powell, John…Jan. 20, 2021), https://perma.cc/WCW6-XGRF ; Alan Feuer & Glenn Thrush, Trump Pardons Giuliani and Others Involved in Effort to Overturn 2020 Election, N.Y. Times (Nov. 10, 2025…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of…Kenneth L. Wainstein, DC Bar # 451058 Natasha Harnwell-Davis, DC Bar # 1719228 Mayer Brown LLP 1999 K Street, NW Washington, DC 20006-1101 Telephone: (202) 263-3000 Pam Bondi Out as Attorney General with Top Names Emerging to Lead DOJ, at 1:48-2:07 (YouTube, streamed Apr. 346346. RETRIEVED EVIDENCE:
Pam Bondi Out as Attorney General with Top Names Emerging to Lead DOJ, at 1:48-2:07 (YouTube, streamed Apr.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has 2, 2026, at 20:00 ET),
https://www.youtube.com/watch? 347347. RETRIEVED EVIDENCE:
2, 2026, at 20:00 ET),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
to the Point: The Grand Conspiracy Against Trump (YouTube, May 7, 2026), https://www.youtube.com/watch?v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity…Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim…Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts…Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v=wMZHAfSQ9vo ( https://perma.cc/9X48 5XX5 on file with Plaintiff). The accusations in…to Lead DOJ, at 1:48-2:07 (YouTube, streamed Apr. 2, 2026, at 20:00 ET), https://www.youtube.com/watch?v=5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah v=5G_nT7kFLPA
(
https://perma.cc/F3SB-MFZ2
on file with Plaintiff). 348348. RETRIEVED EVIDENCE:
v=5G_nT7kFLPA
(
https://perma.cc/F3SB-MFZ2
on file with Plaintiff).
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in
25
Evan Perez & Hannah Rabinowitz, supra note 12; 349349. RETRIEVED EVIDENCE:
25
Evan Perez & Hannah Rabinowitz, supra note 12;
GOVERNING EVIDENCE:
criminal referrals." 3 Hannah Rabinowitz, Attorney General Bondi Orders…John Brennan, CNN (Apr. 18, 2026), https://perma.cc/Z6XV-DNK3 ; Evan Perez & Hannah Rabinowitz, Inside the Justice Department's Shakeup of the John Brennan Investigation, CNN (May 8…with seven other Obama Administration officials in orange 14 Katelyn Polantz, Hannah Rabinowitz & Evan Perez, Justice Department Leans on Prosecutors in Brennan Probe as Other Trump-Foe Investigations…https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA Director…Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority over…Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA Director John Brennan is Removed from Case, Sources Say,
CBS News (Apr. 351351. RETRIEVED EVIDENCE:
Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA Director John Brennan is Removed from Case, Sources Say,
CBS News (Apr.
GOVERNING EVIDENCE:
DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation 17, 2026),
https://perma.cc/37LC-YYMA
; 352352. RETRIEVED EVIDENCE:
17, 2026),
https://perma.cc/37LC-YYMA
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Eric Tucker, supra note 8. 353353. RETRIEVED EVIDENCE:
Eric Tucker, supra note 8.
GOVERNING EVIDENCE:
7 Appendix A, at 15-16. 8 Eric Tucker, Key Prosecutor in John Brennan…https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA Director…from Case, Sources Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority over…Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS…Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622 direction
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619
given authority over all aspects of the investigation into the supposed "grand conspiracy" and Director Brennan's alleged false statements to Congress. 354354. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619
given authority over all aspects of the investigation into the supposed "grand conspiracy" and Director Brennan's alleged false statements to Congress.
GOVERNING EVIDENCE:
JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Since that time, diGenova has been building a team to pursue the investigation. 355355. RETRIEVED EVIDENCE:
Since that time, diGenova has been building a team to pursue the investigation.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions
26
44.
diGenova is a former United States Attorney and a vocal ally of President Trump.
According to diGenova, the President personally appointed him to run the investigations targeting Director Brennan. 358358. RETRIEVED EVIDENCE:
According to diGenova, the President personally appointed him to run the investigations targeting Director Brennan.
GOVERNING EVIDENCE:
12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice
27
Despite being out of the employ of the Justice Department for many decades, diGenova has several qualities that reportedly made him particularly appealing to the President. 359359. RETRIEVED EVIDENCE:
27
Despite being out of the employ of the Justice Department for many decades, diGenova has several qualities that reportedly made him particularly appealing to the President.
GOVERNING EVIDENCE:
B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these He has staunchly supported the President with his public commentary over the years. 360360. RETRIEVED EVIDENCE:
He has staunchly supported the President with his public commentary over the years.
GOVERNING EVIDENCE:
s Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full
28
He has provided legal services in support of the President's causes, temporarily joining the President's team of lawyers dealing with the Mueller Special Counsel investigation and serving on the legal team challenging the results of the 2020 presidential election. 361361. RETRIEVED EVIDENCE:
28
He has provided legal services in support of the President's causes, temporarily joining the President's team of lawyers dealing with the Mueller Special Counsel investigation and serving on the legal team challenging the results of the 2020 presidential election.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel
29
He has been a passionate advocate for the President's pet conspiracy theories, including that President Trump was the winner of the 2020 election and that the classified documents case against President Trump was manufactured by the Biden Administration. 362362. RETRIEVED EVIDENCE:
29
He has been a passionate advocate for the President's pet conspiracy theories, including that President Trump was the winner of the 2020 election and that the classified documents case against President Trump was manufactured by the Biden Administration.
GOVERNING EVIDENCE:
Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ......................…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these…Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that
30
Finally, diGenova has publicly pronounced Director Brennan guilty of participation in the supposed "grand conspiracy," calling
26
In building that team, diGenova has recruited attorneys with demonstrated devotion to President Trump and his retribution agenda. 363363. RETRIEVED EVIDENCE:
30
Finally, diGenova has publicly pronounced Director Brennan guilty of participation in the supposed "grand conspiracy," calling
26
In building that team, diGenova has recruited attorneys with demonstrated devotion to President Trump and his retribution agenda.
GOVERNING EVIDENCE:
20 D. Justice Department Officials Publicly Discuss Grand Jury Activity .......…apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely preserved. 2 Second, there is ample…Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also…of National Intelligence Tulsi Gabbard ten days later. Both referrals were styled and publicly trumpeted as "criminal referrals," despite their failure to explain how the activities…officials have engaged in a variety of inappropriate activities in their attempt to build a prosecutable case on the hollow foundation of these "criminal referrals." 3 Hannah…Dep't of Just., Justice Department Announces Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & U.S. Attorney Jason Reding Qui ones
(@USAReding), X (May 19, 2026, at 20:15 ET),
https://perma.cc/WZ7Y-CSUT
; 364364. RETRIEVED EVIDENCE:
U.S. Attorney Jason Reding Qui ones
(@USAReding), X (May 19, 2026, at 20:15 ET),
https://perma.cc/WZ7Y-CSUT
;
GOVERNING EVIDENCE:
capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th…JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has…that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https Erin Banco and Andrew Goudsward, Trump 2020 Election Denier Kurt Olsen Joins Justice Department,
Reuters (June 2, 2026),
https://perma.cc/N4YM-UWX5
; 365365. RETRIEVED EVIDENCE:
Erin Banco and Andrew Goudsward, Trump 2020 Election Denier Kurt Olsen Joins Justice Department,
Reuters (June 2, 2026),
https://perma.cc/N4YM-UWX5
;
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC…to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small…W. Blanche is the Acting Attorney General of the United States. He leads the Department of Justice and has been in this position since April 2026. In that role, he has Case 1:26-cv-02323…relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes…a defendant in the action resides in the District of Columbia, i.e., the Department of Justice is located at 950 Pennsylvania Ave. NW, Washington, D.C. 20530, and the Executive…2025. See Devlin Barrett, How the Drive to Find a Conspiracy Against Trump Rocked the Justice Dept., N.Y. Times (June 8, 2026), https://perma.cc/63DZ-3KUH . 10 Appendix A, at 10-11. Case Shawn McCreesh, Alexandra Berzon &
Nick Corasaniti, Trump's Director of Election Security is an Election Denier, N.Y. 366366. RETRIEVED EVIDENCE:
Shawn McCreesh, Alexandra Berzon &
Nick Corasaniti, Trump's Director of Election Security is an Election Denier, N.Y.
GOVERNING EVIDENCE:
L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons…13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights Times (Feb.
12, 2026),
https://perma.cc/483P-DP3P
; 368368. RETRIEVED EVIDENCE:
12, 2026),
https://perma.cc/483P-DP3P
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Trump-Russia: 369369. RETRIEVED EVIDENCE:
Trump-Russia:
GOVERNING EVIDENCE:
officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L…that Russia had interfered in the 2016 presidential election in an effort to boost candidate Donald Trump's chances of winning the election. In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made President's Legal Team Shake-Up Falters, BBC News (Mar. 370370. RETRIEVED EVIDENCE:
President's Legal Team Shake-Up Falters, BBC News (Mar.
GOVERNING EVIDENCE:
NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity…26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan 25, 2018),
https://perma.cc/WR69-UGFH
.
27
Anna Bower & Molly Roberts, supra note 6. 371371. RETRIEVED EVIDENCE:
25, 2018),
https://perma.cc/WR69-UGFH
.
27
Anna Bower & Molly Roberts, supra note 6.
GOVERNING EVIDENCE:
v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability…Hannah Rabinowitz, supra note 12; Sarah N. Lynch…Legal Team Shake-Up Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Grand Conspiracy Probe (1), Bloomberg Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Professional Responsibility 43 to eliminate 38 Kash Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ Official Trained Pam Bondi on Ethics Rules in the
28
Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News
(Mar. 372372. RETRIEVED EVIDENCE:
28
Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News
(Mar.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in 19, 2018),
https://perma.cc/ZP79-WTLH
.
29
Id.; 373373. RETRIEVED EVIDENCE:
19, 2018),
https://perma.cc/ZP79-WTLH
.
29
Id.;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Trump Lawyer diGenova to Lead Miami Grand Conspiracy Probe (1), Bloomberg Law
(Apr. 374374. RETRIEVED EVIDENCE:
Trump Lawyer diGenova to Lead Miami Grand Conspiracy Probe (1), Bloomberg Law
(Apr.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity…NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 18, 2026),
https://perma.cc/P9BA-WX28
.
30
Anna Bower & Molly Roberts, supra note 6. 375375. RETRIEVED EVIDENCE:
18, 2026),
https://perma.cc/P9BA-WX28
.
30
Anna Bower & Molly Roberts, supra note 6.
GOVERNING EVIDENCE:
v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability…Hannah Rabinowitz, supra note 12; Sarah N. Lynch…Legal Team Shake-Up Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Grand Conspiracy Probe (1), Bloomberg Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Professional Responsibility 43 to eliminate 38 Kash Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ Official Trained Pam Bondi on Ethics Rules in the
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620
Director Brennan "evil,"
31
branding him a "traitor,"
32
and declaring that "[t]his conspiracy began with John Brennan and ends with John Brennan."
33
C. 376376. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620
Director Brennan "evil,"
31
branding him a "traitor,"
32
and declaring that "[t]his conspiracy began with John Brennan and ends with John Brennan."
33
C.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in
The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda
45. 377377. RETRIEVED EVIDENCE:
The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda
45.
GOVERNING EVIDENCE:
Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years
Besides these personnel moves, there has been apattern of frantic and haphazard activity as Justice Department leadership has scrambled to appease the President and his insistence on action against Director Brennan and the other retribution targets. 378378. RETRIEVED EVIDENCE:
Besides these personnel moves, there has been apattern of frantic and haphazard activity as Justice Department leadership has scrambled to appease the President and his insistence on action against Director Brennan and the other retribution targets.
GOVERNING EVIDENCE:
JUSTICE, 950…........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these…and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida
46.
The government opened an investigation before a Miami grand jury in early November
2025, which issued subpoenas to Director Brennan and 30-odd current and former Intelligence Community officials seeking documents relating to the ICA from adate range in 2016-2017. 380380. RETRIEVED EVIDENCE:
The government opened an investigation before a Miami grand jury in early November
2025, which issued subpoenas to Director Brennan and 30-odd current and former Intelligence Community officials seeking documents relating to the ICA from adate range in 2016-2017.
GOVERNING EVIDENCE:
U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has
After Director Brennan and others complied with that subpoena, DOJ prosecutors opened a second investigation before a different grand jury in Miami, which issued subpoenas in January
2026 seeking the same category of documents from 2016 all the way up to the present.
31
James Hoft, Joe diGenova on John Brennan's Lost Security Clearance: 382382. RETRIEVED EVIDENCE:
31
James Hoft, Joe diGenova on John Brennan's Lost Security Clearance:
GOVERNING EVIDENCE:
a criminal, not only before securing a conviction in court but…are failing to observe their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing…at the request of President Obama to serve as Assistant to the President for Homeland Security and Counterterrorism and Deputy National Security Advisor in the Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 11 of 468 Executive…was responsible during this time for orchestrating Obama Administration policies on homeland security, pandemics, cyberattacks, and natural disasters. 16. The United States Senate…day. 17. Director Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA…Shawn McCreesh, Alexandra Berzon & Nick Corasaniti, Trump's Director of Election Security is an Election Denier, N.Y. Times (Feb. 12, 2026), https://perma.cc/483P-DP3P "A Glorious Day for America", at 1:26 (YouTube, Aug. 383383. RETRIEVED EVIDENCE:
"A Glorious Day for America", at 1:26 (YouTube, Aug.
GOVERNING EVIDENCE:
YouTube, May 7, 2026), https…FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from…she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna…Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v=wMZHAfSQ9vo ( https://perma.cc/9X48 5XX5 on file with Plaintiff). The…Pam Bondi Out as Attorney General with Top Names Emerging to Lead DOJ, at 1:48-2:07 (YouTube, streamed Apr. 2, 2026, at 20:00 ET), https://www.youtube.com/watch?v=5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan 16, 2018) (clip of Fox News television broadcast, aired May
1, 2018, at 19:15 PM ET),
https://www.youtube.com/watch? 384384. RETRIEVED EVIDENCE:
16, 2018) (clip of Fox News television broadcast, aired May
1, 2018, at 19:15 PM ET),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
Conspiracy Allegations: Sources, Fox News (Aug. 4, 2025), https://perma.cc/Q5JS XTZQ ; LA…h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with…her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts…Prosecutor in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the…Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean v=TzjzcAZauPc
(
https://perma.cc/BAE6-YVH6
on file with Plaintiff). 385385. RETRIEVED EVIDENCE:
v=TzjzcAZauPc
(
https://perma.cc/BAE6-YVH6
on file with Plaintiff).
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in
32
Tamar Auber, Joe diGenova to Hannity: 386386. RETRIEVED EVIDENCE:
32
Tamar Auber, Joe diGenova to Hannity:
GOVERNING EVIDENCE:
https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc…their acts of criminal conduct." 14 Then, on June 2, 2026, in his interview with Sean Hannity, Acting Attorney General Blanche identified alleged members of the "grand conspiracy" as…Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v…felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean Hannity reminding the audience that none of the accused individuals has been charged with any John Brennan is the "Real Traitor", Mediaite (July
18, 2018) (clip of Fox News television broadcast, aired July 18, 2018, at 09:41 ET),
https://www.mediaite.com/media/tv/joe-digenova-to-hannity-john-brennan-is-the-real-traitor/
(
https://perma.cc/JDX4-P4WG on file with Plaintiff). 387387. RETRIEVED EVIDENCE:
John Brennan is the "Real Traitor", Mediaite (July
18, 2018) (clip of Fox News television broadcast, aired July 18, 2018, at 09:41 ET),
https://www.mediaite.com/media/tv/joe-digenova-to-hannity-john-brennan-is-the-real-traitor/
(
https://perma.cc/JDX4-P4WG on file with Plaintiff).
GOVERNING EVIDENCE:
4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to…Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States…Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466 10. There is a very real risk, however, that some of these materials and communications will no longer exist by…injunctive relief. He is sued in his official capacity. 21. Defendant Joseph E. diGenova has served as Counselor to the Attorney General since April 20, 2026. He has been…at 560-61. Here, Director Brennan meets those three requirements. The injury is the very real prospect that the government will fail to preserve the records he would need to challenge an…her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News
33
Charlie Savage & Alan Feuer, U.S. Installs a Trump Loyalist to Lead 'Grand Conspiracy'
Case Into Trump Foes, N.Y. 388388. RETRIEVED EVIDENCE:
33
Charlie Savage & Alan Feuer, U.S. Installs a Trump Loyalist to Lead 'Grand Conspiracy'
Case Into Trump Foes, N.Y.
GOVERNING EVIDENCE:
described by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical…two sets of grand jury subpoenas - one set seeking documents relating to the supposed "grand conspiracy" and the other relating to Director Brennan's alleged false statements to…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the…General since April 20, 2026. He has been assigned to lead the investigations into the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress. In that…the allegedly criminal act occurred. Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the decision-making and Times (Apr. 18, 2026),
https://perma.cc/55WV-DDBJ
. When asked about those comments upon diGenova'sappointment, Acting Attorney General Blanche dismissed any bias concerns saying, "I'mnot sure what the conflict of interest would be because somebody has said something in the past about, about a particular matter. 390390. RETRIEVED EVIDENCE:
18, 2026),
https://perma.cc/55WV-DDBJ
. When asked about those comments upon diGenova'sappointment, Acting Attorney General Blanche dismissed any bias concerns saying, "I'mnot sure what the conflict of interest would be because somebody has said something in the past about, about a particular matter.
GOVERNING EVIDENCE:
official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama That doesn't create a conflict necessarily." The reporter then asked, "Well, it creates a sense of bias, doesn'tit? 391391. RETRIEVED EVIDENCE:
That doesn't create a conflict necessarily." The reporter then asked, "Well, it creates a sense of bias, doesn'tit?
GOVERNING EVIDENCE:
as the President's adversary has become risky in…into a tool of retribution against Director Brennan and the President's other perceived adversaries. 1 5. This effort has resulted in the opening of two federal investigations that…2016 election and the other Trump-related investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second investigation…lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small subset of officials, and the vast majority of…on pre-trial sanctions as a remedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication…skills and national security expertise, Director Brennan was selected in 2003 to design and serve as the founding director of the Terrorist Threat Integration Center and of its successor organization the National That he'scoming into the investigation with preconceived views about a target of your investigation. 392392. RETRIEVED EVIDENCE:
That he'scoming into the investigation with preconceived views about a target of your investigation.
GOVERNING EVIDENCE:
12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming
Isn'tthat a problem? 393393. RETRIEVED EVIDENCE:
Isn'tthat a problem?
GOVERNING EVIDENCE:
with preconceived views about a target of your investigation. Isn't that a problem?" At that point, Blanche simply responded, "I just completely disagree with the premise," and " At that point, Blanche simply responded, "Ijust completely disagree with the premise," and gave his assurance that DiGenova will be "doing everything ethically" and
"will follow the facts." The National Desk, Acting Attorney General Blanche and FBI Director Kash Patel Hold a Press Conference, U.S. Dep'tof Just., at 25:04-27:05 (YouTube, Apr. 394394. RETRIEVED EVIDENCE:
" At that point, Blanche simply responded, "Ijust completely disagree with the premise," and gave his assurance that DiGenova will be "doing everything ethically" and
"will follow the facts." The National Desk, Acting Attorney General Blanche and FBI Director Kash Patel Hold a Press Conference, U.S. Dep'tof Just., at 25:04-27:05 (YouTube, Apr.
GOVERNING EVIDENCE:
QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully 21,
2026),
https://www.youtube.com/live/i4H6gQPcdkg
(
https://perma.cc/7LTP-V42Ron file with Plaintiff). 395395. RETRIEVED EVIDENCE:
21,
2026),
https://www.youtube.com/live/i4H6gQPcdkg
(
https://perma.cc/7LTP-V42Ron file with Plaintiff).
GOVERNING EVIDENCE:
to the Point: The Grand Conspiracy Against Trump (YouTube, May 7, 2026), https://www.youtube.com/watch?v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff…Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff…Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff…Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v=wMZHAfSQ9vo ( https://perma.cc/9X48 5XX5 on file with Plaintiff…to Lead DOJ, at 1:48-2:07 (YouTube, streamed Apr. 2, 2026, at 20:00 ET), https://www.youtube.com/watch?v=5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff…broadcast, aired May 1, 2018, at 19:15 PM ET), https://www.youtube.com/watch?v=TzjzcAZauPc ( https://perma.cc/BAE6-YVH6 on
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 24 of 4621
47. 396396. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 24 of 4621
47.
GOVERNING EVIDENCE:
of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director
Following the document subpoenas, the investigation team reached out to a number of witnesses (or their counsel) to arrange voluntary interviews. 397397. RETRIEVED EVIDENCE:
Following the document subpoenas, the investigation team reached out to a number of witnesses (or their counsel) to arrange voluntary interviews.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The…and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A, 2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, --…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in While those interviews were being arranged, the investigation team suddenly withdrew the interview requests and served several witnesses with grand jury subpoenas compelling their appearance before agrand jury in Washington, D.C. 398398. RETRIEVED EVIDENCE:
While those interviews were being arranged, the investigation team suddenly withdrew the interview requests and served several witnesses with grand jury subpoenas compelling their appearance before agrand jury in Washington, D.C.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions that had been empaneled to investigate the Chairman Jordan referral. 399399. RETRIEVED EVIDENCE:
that had been empaneled to investigate the Chairman Jordan referral.
GOVERNING EVIDENCE:
With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in
34
Within two days, however, the investigation team reversed course again, withdrawing the District of Columbia grand jury subpoenas and renewing the invitations for voluntary interviews. 400400. RETRIEVED EVIDENCE:
34
Within two days, however, the investigation team reversed course again, withdrawing the District of Columbia grand jury subpoenas and renewing the invitations for voluntary interviews.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in
35
D.
Justice Department Officials Publicly Discuss Grand Jury Activity
48.
While this frantic activity is ongoing, there continues to be an unprecedented amount of public discussion by DOJ officials detailing investigative activity that is ostensibly covered by grand jury secrecy under Federal Rule of Criminal Procedure 6(e). 403403. RETRIEVED EVIDENCE:
While this frantic activity is ongoing, there continues to be an unprecedented amount of public discussion by DOJ officials detailing investigative activity that is ostensibly covered by grand jury secrecy under Federal Rule of Criminal Procedure 6(e).
GOVERNING EVIDENCE:
12 A. The Grand…s Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from…in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1…and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record…his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made…With his return to the White House, the President has gone beyond mere denunciation, and has actively mobilized the machinery of the criminal justice system against Director Brennan. He has In his June 2, 2026 interview with Sean Hannity, for example, Acting Attorney General Blanche acknowledged, among other things, that "we've issued 200 grand jury subpoenas" and that agrand jury is investigating
"whether or not apattern of behavior has taken place to destroy [President Trump]."
36
When Hannity asked about "Comey," "Biden, Clapper" and "Biden," in the context of discussing the government's investigation, Blanche said, "All those folks were, were certainly part of it."
37
Earlier, on May 4, 2026, FBI Director Patel appeared on Hannity'sshow and engaged in alengthy discussion of the current investigations. 404404. RETRIEVED EVIDENCE:
In his June 2, 2026 interview with Sean Hannity, for example, Acting Attorney General Blanche acknowledged, among other things, that "we've issued 200 grand jury subpoenas" and that agrand jury is investigating
"whether or not apattern of behavior has taken place to destroy [President Trump]."
36
When Hannity asked about "Comey," "Biden, Clapper" and "Biden," in the context of discussing the government's investigation, Blanche said, "All those folks were, were certainly part of it."
37
Earlier, on May 4, 2026, FBI Director Patel appeared on Hannity'sshow and engaged in alengthy discussion of the current investigations.
GOVERNING EVIDENCE:
to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…s Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in He confirmed the existence, scope, and general
34
Daniel Klaidman & Sarah N. 405405. RETRIEVED EVIDENCE:
He confirmed the existence, scope, and general
34
Daniel Klaidman & Sarah N.
GOVERNING EVIDENCE:
any eventual indictment as the product of an unconstitutionally vindictive…a very real risk, however, that some of these materials and communications will no longer exist by the time any such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government…on pre-trial sanctions as a remedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 12. For this…juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia. 14. Director Brennan's federal government service…Bill Clinton and Vice President Al Gore (1994-95); senior U.S. intelligence official resident in Saudi Arabia (1996-99); Chief of Staff to Director of Central Intelligence George Lynch, Witnesses in Criminal Probe of Ex-CIA Director Brennan Subpoenaed to Testify Before Grand Jury, Sources Say, CBS News (Apr. 406406. RETRIEVED EVIDENCE:
Lynch, Witnesses in Criminal Probe of Ex-CIA Director Brennan Subpoenaed to Testify Before Grand Jury, Sources Say, CBS News (Apr.
GOVERNING EVIDENCE:
DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and 20, 2026),
https://perma.cc/Z9G7-CUBZ
.
35
Id.; 407407. RETRIEVED EVIDENCE:
20, 2026),
https://perma.cc/Z9G7-CUBZ
.
35
Id.;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Erin Banco, Andrew Goudsward & Jonathan Landay, FBI Questions CIA Officers Over Russia Assessment in Brennan Probe, Sources Say, Reuters (May 12, 2026),
https://perma.cc/K3YQ-ZULR
.
36
Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 408408. RETRIEVED EVIDENCE:
Erin Banco, Andrew Goudsward & Jonathan Landay, FBI Questions CIA Officers Over Russia Assessment in Brennan Probe, Sources Say, Reuters (May 12, 2026),
https://perma.cc/K3YQ-ZULR
.
36
Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15.
GOVERNING EVIDENCE:
Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in
37
Id. at 57:43-53.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622
direction of the investigations, and identified Director Brennan and the other retribution targets as falling within their scope. 411411. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622
direction of the investigations, and identified Director Brennan and the other retribution targets as falling within their scope.
GOVERNING EVIDENCE:
N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW…Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel
38
E.
The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct
49. 413413. RETRIEVED EVIDENCE:
The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct
49.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th…JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i
At the same time that government personnel are accelerating their overreaching efforts against Director Brennan, the Administration is involved in aconcerted effort to insulate those personnel from any accountability for their misconduct by subverting the various mechanisms for investigating or sanctioning official DOJ misconduct. 414414. RETRIEVED EVIDENCE:
At the same time that government personnel are accelerating their overreaching efforts against Director Brennan, the Administration is involved in aconcerted effort to insulate those personnel from any accountability for their misconduct by subverting the various mechanisms for investigating or sanctioning official DOJ misconduct.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington It has been methodically removing or silencing those career civil servants who are responsible for internally enforcing ethics, with Attorney General Bondi firing the head of the Office of Professional Responsibility
39
and the Director of the Departmental Ethics Office
40
(who had previously given then-Deputy Attorney General Blanche the unwelcome advice that he must recuse himself from investigations involving President Trump). 415415. RETRIEVED EVIDENCE:
It has been methodically removing or silencing those career civil servants who are responsible for internally enforcing ethics, with Attorney General Bondi firing the head of the Office of Professional Responsibility
39
and the Director of the Departmental Ethics Office
40
(who had previously given then-Deputy Attorney General Blanche the unwelcome advice that he must recuse himself from investigations involving President Trump).
GOVERNING EVIDENCE:
20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in…investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to
41
It is working to deny state bar authorities the ability to conduct oversight of DOJ attorneys,
42
suing the D.C. 416416. RETRIEVED EVIDENCE:
41
It is working to deny state bar authorities the ability to conduct oversight of DOJ attorneys,
42
suing the D.C.
GOVERNING EVIDENCE:
FOR THE DISTRICT OF COLUMBIA JOHN O…JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…Justice Department's recent record of overreaching in this and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government Board on Professional Responsibility
43
to eliminate
38
Kash Patel interview with Sean Hannity, supra note 3. 417417. RETRIEVED EVIDENCE:
Board on Professional Responsibility
43
to eliminate
38
Kash Patel interview with Sean Hannity, supra note 3.
GOVERNING EVIDENCE:
Government Personnel from Accountability for Their Irregular Conduct…In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan as "a very…without valid support that Director Brennan made false statements about the ICA in a 2023 interview with the House Judiciary Committee. 6. The Justice Department has undertaken separate grand…to selectively and vindictively target Director Brennan, there is no intent to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the…personnel are maintaining adherence to professional standards and carrying out their duties in the best tradition of the Justice Department. Case 1:26-cv-02323 Document 1 Filed…Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 7. In their work on these presidentially-driven investigations, certain Justice
39
Sam Levine, A Top DOJ Official Trained Pam Bondi on Ethics Rules in the Department. 418418. RETRIEVED EVIDENCE:
39
Sam Levine, A Top DOJ Official Trained Pam Bondi on Ethics Rules in the Department.
GOVERNING EVIDENCE:
JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal…Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Then He was Fired, Guardian (Jan. 419419. RETRIEVED EVIDENCE:
Then He was Fired, Guardian (Jan.
GOVERNING EVIDENCE:
Top DOJ Official Trained Pam Bondi on Ethics Rules in the Department. Then He was Fired, Guardian (Jan. 3, 2026), https://perma.cc/8JHJ-PGM3 . The same day, the U.S. Pardon Attorney…Helmore, Photos Suggest Trump Blocked Toilets with Ripped-up White House Documents, Guardian (Aug. 8, 2022), https://perma.cc/A7VV-GP25 ; Mike Allen, Exclusive Photos: Trump's 3, 2026),
https://perma.cc/8JHJ-PGM3
. The same day, the U.S.
Pardon Attorney, who was acareer civil servant, was terminated by aletter signed by Deputy Attorney General Todd Blanche. 420420. RETRIEVED EVIDENCE:
3, 2026),
https://perma.cc/8JHJ-PGM3
. The same day, the U.S.
Pardon Attorney, who was acareer civil servant, was terminated by aletter signed by Deputy Attorney General Todd Blanche.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has Perry Stein et al., Trump's Justice Department Ousts Several Top Career Officials, Washington Post (Mar. 8, 2025),
https://perma.cc/5DCT-GLU2
.
40
Sam Levine, supra note 39; 422422. RETRIEVED EVIDENCE:
8, 2025),
https://perma.cc/5DCT-GLU2
.
40
Sam Levine, supra note 39;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Katelyn Polantz, Evan Perez & Hannah Rabinowitz, Exclusive: 423423. RETRIEVED EVIDENCE:
Katelyn Polantz, Evan Perez & Hannah Rabinowitz, Exclusive:
GOVERNING EVIDENCE:
Director Brennan with seven other Obama Administration officials in orange 14 Katelyn Polantz, Hannah Rabinowitz & Evan Perez, Justice Department Leans on Prosecutors in Brennan Probe as…Mar. 8, 2025), https://perma.cc/5DCT-GLU2 . 40 Sam Levine, supra note 39; Katelyn Polantz, Evan Perez & Hannah Rabinowitz, Exclusive: Acting AG Todd Blanche was Told Last Year to Recuse from Justice Department Matters…House Documents, Guardian (Aug. 8, 2022), https://perma.cc/A7VV-GP25 ; Mike Allen, Exclusive Photos: Trump's Telltale Toilet, Axios (Aug. 8, 2022), https://perma.cc/98QG-ULBK
Acting AG Todd Blanche was Told Last Year to Recuse from Justice Department Matters Involving Trump, CNN (May 14, 2026),
https://perma.cc/79WB-488R
.
41
These firings have apparently had their intended effect on the internal watchdog workforce, as evidenced by recent reports that the Department of Justice Office of the Inspector General has
"seemingly ignored 20 instances of possible wrongdoing by the Trump administration." Devlin Barrett, Justice Dept. 424424. RETRIEVED EVIDENCE:
Acting AG Todd Blanche was Told Last Year to Recuse from Justice Department Matters Involving Trump, CNN (May 14, 2026),
https://perma.cc/79WB-488R
.
41
These firings have apparently had their intended effect on the internal watchdog workforce, as evidenced by recent reports that the Department of Justice Office of the Inspector General has
"seemingly ignored 20 instances of possible wrongdoing by the Trump administration." Devlin Barrett, Justice Dept.
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530…and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 Watchdog Has Gone Silent, Lawyers for Whistle-Blower Say, N.Y. 425425. RETRIEVED EVIDENCE:
Watchdog Has Gone Silent, Lawyers for Whistle-Blower Say, N.Y.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the Times
(Mar. 426426. RETRIEVED EVIDENCE:
Times
(Mar.
GOVERNING EVIDENCE:
concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that…potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1…as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying before…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan 30, 2026),
https://perma.cc/UQ7V-YQBW
.
42
Currently, each Department of Justice attorney is "subject to State laws and rules, and local Federal court rules, governing attorneys in each State where such attorney engages in that attorney'sduties, to the same extent and in the same manner as other attorneys in that State." 28
U.S.C. 427427. RETRIEVED EVIDENCE:
30, 2026),
https://perma.cc/UQ7V-YQBW
.
42
Currently, each Department of Justice attorney is "subject to State laws and rules, and local Federal court rules, governing attorneys in each State where such attorney engages in that attorney'sduties, to the same extent and in the same manner as other attorneys in that State." 28
U.S.C.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has 530B (the McDade Amendment). 428428. RETRIEVED EVIDENCE:
530B (the McDade Amendment).
GOVERNING EVIDENCE:
same extent and in the same manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1…regard to legal or ethical limitations. And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of…United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive prosecution claim, the court considered in camera material from…equally to records on non official electronic messaging channels. In 2014, Congress amended both the PRA and the FRA to prohibit executive department personnel from using…at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub. L. No. 113-187, 10, 128 Stat. 2003, 2014-15); see also United States See generally In re Clark, 678 F. 429429. RETRIEVED EVIDENCE:
See generally In re Clark, 678 F.
GOVERNING EVIDENCE:
and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…of the John Brennan Investigation, CNN (May 8, 2026), https://perma.cc/S58G-9MTK . 13 See generally Appendix A. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 19 of 4616 A…lengthy discussion of the current investigations. He confirmed the existence, scope, and general 34 Daniel Klaidman & Sarah N. Lynch, Witnesses in Criminal Probe of Ex-CIA Director…manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26…57 See generally A Disappearing Data Supp. 430430. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d 112, 116
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623
its oversight of federal attorneys, and issuing aproposed regulation that will give the Attorney General the first opportunity to review any complaint against acurrent or former Department attorney
44
and the right to "take appropriate action to prevent the bar disciplinary authorities from interfering with the Attorney General's review of the allegations."
45
And, the President himself is using his pardon power to prevent accountability in the criminal justice system. 431431. RETRIEVED EVIDENCE:
3d 112, 116
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623
its oversight of federal attorneys, and issuing aproposed regulation that will give the Attorney General the first opportunity to review any complaint against acurrent or former Department attorney
44
and the right to "take appropriate action to prevent the bar disciplinary authorities from interfering with the Attorney General's review of the allegations."
45
And, the President himself is using his pardon power to prevent accountability in the criminal justice system.
GOVERNING EVIDENCE:
DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis…of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government…Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &
Having pardoned numerous officials who were found guilty of or credibly charged with criminal conduct during his first administration,
46
he has now made clear that he will pardon those who serve his will in this term, stating, "I'll pardon everyone who has come within 200 feet of the Oval" and making other similar statements. 432432. RETRIEVED EVIDENCE:
Having pardoned numerous officials who were found guilty of or credibly charged with criminal conduct during his first administration,
46
he has now made clear that he will pardon those who serve his will in this term, stating, "I'll pardon everyone who has come within 200 feet of the Oval" and making other similar statements.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…10 STANDING…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda
47
50.
The clear point of these combined efforts is to greatly reduce the deterrent effect of legal and ethical limitations and enforcement mechanisms on those government employees - like some of those involved in the investigations involving Director Brennan - who might be tempted to follow President Trump'sorders without regard to legal or ethical limitations. 434434. RETRIEVED EVIDENCE:
The clear point of these combined efforts is to greatly reduce the deterrent effect of legal and ethical limitations and enforcement mechanisms on those government employees - like some of those involved in the investigations involving Director Brennan - who might be tempted to follow President Trump'sorders without regard to legal or ethical limitations.
GOVERNING EVIDENCE:
NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel And
18 (D.D.C. 435435. RETRIEVED EVIDENCE:
And
18 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. 436436. RETRIEVED EVIDENCE:
2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…6 of 463 INTRODUCTION 1. Director Brennan is a former longtime public servant who provided more than 33 years of nonpartisan government service working for six administrations -…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of
Cir. July 12, 2024).
43
Press Release, U.S. Dep'tof Just., Justice Department Files Complaint Against D.C. 439439. RETRIEVED EVIDENCE:
43
Press Release, U.S. Dep'tof Just., Justice Department Files Complaint Against D.C.
GOVERNING EVIDENCE:
UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 Bar Disciplinary Authorities Over Their Weaponization of the Bar Disciplinary Process Against Federal Government Attorneys (May 13, 2026),
https://perma.cc/CXC6-RMUH
.
44
91 Fed. 440440. RETRIEVED EVIDENCE:
Bar Disciplinary Authorities Over Their Weaponization of the Bar Disciplinary Process Against Federal Government Attorneys (May 13, 2026),
https://perma.cc/CXC6-RMUH
.
44
91 Fed.
GOVERNING EVIDENCE:
to "take appropriate action to prevent the bar disciplinary authorities from interfering with the Attorney General…43 Press Release, U.S. Dep't of Just., Justice Department Files Complaint Against D.C. Bar Disciplinary Authorities Over Their Weaponization of the Bar Disciplinary Process Against Federal Government Attorneys (May 13, 2026), https://perma.cc/CXC6-RMUH . 44 91 Fed. Reg. 10780 (Mar. 5, 2026) (codified at 28 C.F.R. pt. 77). 45 Id. 46 These…50 See supra note 2. 51 Memorandum from William Fischer, Chief Records Officer, to Fed. Records Mgmt. Contacts (May 2, 2025), https://perma.cc/TAB5-E2ZX . 52 Bernd…from White House Counsel David Warrington. The Warrington 62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt…retain the internal records that 68 Id. 69 Order on Cross-Mots. for Summ. J. 15-16, Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025 Reg. 10780 (Mar. 5, 2026) (codified at 28 C.F.R. 443443. RETRIEVED EVIDENCE:
5, 2026) (codified at 28 C.F.R.
GOVERNING EVIDENCE:
May 13, 2026), https://perma.cc/CXC6-RMUH . 44 91 Fed. Reg. 10780 (Mar. 5, 2026) (codified at 28 C.F.R. pt. 77). 45 Id. 46 These include Rudy Giuliani, Sydney Powell, John pt. 444444. RETRIEVED EVIDENCE:
pt.
GOVERNING EVIDENCE:
//perma.cc/CXC6-RMUH . 44 91 Fed. Reg. 10780 (Mar. 5, 2026) (codified at 28 C.F.R. pt. 77). 45 Id. 46 These include Rudy Giuliani, Sydney Powell, John Eastman, Boris 77).
45
Id.
46
These include Rudy Giuliani, Sydney Powell, John Eastman, Boris Epshteyn, Jeffrey Clark,
Mark Meadows, Paul Manafort, Roger Stone, Steve Bannon, and Michael Flynn, to name but afew. 447447. RETRIEVED EVIDENCE:
46
These include Rudy Giuliani, Sydney Powell, John Eastman, Boris Epshteyn, Jeffrey Clark,
Mark Meadows, Paul Manafort, Roger Stone, Steve Bannon, and Michael Flynn, to name but afew.
GOVERNING EVIDENCE:
this Administration has adopted a policy of using criminal process…of Justice is a federal agency responsible for enforcing federal criminal laws. It includes government personnel and record systems that would have the records to be preserved under the…Office of the President provides operational and management support to the President. It includes government personnel and record systems that would have the records to be preserved under the…an agency that engages in intelligence operations and analysis for the U.S. government. It includes government personnel and record systems that would have the records to be preserved under the…Intelligence is an agency that provides oversight to the intelligence community. It includes government personnel and record systems that would have the records to be preserved under the…because that is where the allegedly criminal act occurred. Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the Jonathan Lemire, Eric Tucker & Jill Colvin, Trump Pardons Ex-Strategist Steve Bannon,
Dozens of Others, AP News (Jan. 448448. RETRIEVED EVIDENCE:
Jonathan Lemire, Eric Tucker & Jill Colvin, Trump Pardons Ex-Strategist Steve Bannon,
Dozens of Others, AP News (Jan.
GOVERNING EVIDENCE:
Fired, Guardian (Jan. 3, 2026), https://perma.cc/8JHJ-PGM3 . The same day, the U.S. Pardon Attorney, who was a career civil servant, was terminated by a letter signed by Deputy…General's review of the allegations." 45 And, the President himself is using his pardon power to prevent accountability in the criminal justice system. Having pardoned numerous officials who were found guilty of or credibly charged with criminal conduct during his first administration, 46 he has now made clear that he will pardon those who serve his will in this term, stating, "I'll pardon everyone who has come within 200 feet of the Oval" and making other similar statements. 47…Steve Bannon, and Michael Flynn, to name but a few. Jonathan Lemire, Eric Tucker & Jill Colvin, Trump Pardons Ex-Strategist Steve Bannon, Dozens of Others, AP News (Jan. 20, 2021), https://perma.cc/WCW6-XGRF ; Alan Feuer & Glenn Thrush, Trump Pardons Giuliani and Others Involved in Effort to Overturn 2020 Election, N.Y 20, 2021),
https://perma.cc/WCW6-XGRF
; 449449. RETRIEVED EVIDENCE:
20, 2021),
https://perma.cc/WCW6-XGRF
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury
Alan Feuer & Glenn Thrush, Trump Pardons Giuliani and Others Involved in Effort to Overturn
2020 Election, N.Y. 450450. RETRIEVED EVIDENCE:
Alan Feuer & Glenn Thrush, Trump Pardons Giuliani and Others Involved in Effort to Overturn
2020 Election, N.Y.
GOVERNING EVIDENCE:
and Continues to Engage, in Unprecedented, Irregular Conduct in Connection…based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the…because that is where the allegedly criminal act occurred. Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the…the product of a carefully orchestrated series of referrals claiming Director Brennan's involvement in theoretical criminal activity. A. The Grand Conspiracy Investigation 33. The…rights with the series of federal investigations and prosecutions relating to the 2016 election and to President Trump's conduct in and out of office. 3 B. The False-Statements Times (Nov. 10, 2025),
https://perma.cc/N8JQ-HTLS
.
47
Josh Dawsey, Trump Promises Mass Pardons to Staff Before Leaving Office, Wall Street Journal (Apr. 452452. RETRIEVED EVIDENCE:
10, 2025),
https://perma.cc/N8JQ-HTLS
.
47
Josh Dawsey, Trump Promises Mass Pardons to Staff Before Leaving Office, Wall Street Journal (Apr.
GOVERNING EVIDENCE:
of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as…Effort to Overturn 2020 Election, N.Y. Times (Nov. 10, 2025), https://perma.cc/N8JQ-HTLS . 47 Josh Dawsey, Trump Promises Mass Pardons to Staff Before Leaving Office, Wall Street Journal…X account the next morning. 61 Finally, in a recent challenge to the Administration's mass terminations of government employees, discovery revealed that high-level communications,' which…Working Grp., U.S. Dep't of Just. (Nov. 17, 2025), https://perma.cc/AZ83-JPKH . 60 Josh Gerstein & Kyle Cheney, Judge Orders Trump Administration to Preserve Signal Chats…a grand jury that I saw in those transcripts." 68 In a recent civil case involving the mass termination of grants awarded by the National Endowment for the Humanities, the judge 10, 2026),
https://perma.cc/FCP6-TT6R
. And, to message assurance that those followers will suffer no financial impact due to any misdeeds in his service, the Justice Department recently mounted - and was ultimately forced to abandon - an effort to establish a
$1.776 billion dollar fund to make payments to those who have "suffered weaponization and lawfare." Press Release, U.S. Dep't of Just., Justice Department Announces Anti-Weaponization Fund (May 18, 2026),
https://perma.cc/UM4V-D3AT
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 27 of 4624
the result thereof is a continuing crescendo in the incidence of conduct that falls far short of professional standards.
III.
The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution
51. 455455. RETRIEVED EVIDENCE:
The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution
51.
GOVERNING EVIDENCE:
22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…Reviewing the Vindictive and Selective Prosecution Challenges Would Require…Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for
This background provides a strong factual foundation for moving to dismiss any indictment that may ultimately arise from the government'scurrent investigations as avindictive and/or selective prosecution The above-described government conduct in this case makes it abundantly clear that the driving force behind the investigations targeting Director Brennan is the President'sobsession with punishing him for his lawful conduct as CIA Director and for his constitutionally protected criticism of the President and the President'spolicies. 456456. RETRIEVED EVIDENCE:
This background provides a strong factual foundation for moving to dismiss any indictment that may ultimately arise from the government'scurrent investigations as avindictive and/or selective prosecution The above-described government conduct in this case makes it abundantly clear that the driving force behind the investigations targeting Director Brennan is the President'sobsession with punishing him for his lawful conduct as CIA Director and for his constitutionally protected criticism of the President and the President'spolicies.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution That is the reason he is being singled out for investigation of concocted theories of criminal activity, and that will be the dominant reason for any criminal charges resulting from that investigation. 457457. RETRIEVED EVIDENCE:
That is the reason he is being singled out for investigation of concocted theories of criminal activity, and that will be the dominant reason for any criminal charges resulting from that investigation.
GOVERNING EVIDENCE:
......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel…Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming That is also why Director Brennan will have an extremely strong basis to challenge those charges as the product of vindictive and selective prosecution. 458458. RETRIEVED EVIDENCE:
That is also why Director Brennan will have an extremely strong basis to challenge those charges as the product of vindictive and selective prosecution.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations
IV. 459459. RETRIEVED EVIDENCE:
IV.
GOVERNING EVIDENCE:
24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a…to challenge those charges as the product of vindictive and selective prosecution. IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage
The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government
52. 460460. RETRIEVED EVIDENCE:
The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government
52.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under…Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government
A court evaluating Director Brennan's well-founded challenges would do so without granting the deference traditionally afforded to representatives of the government under the
"presumption of regularity." Traditionally, "in the absence of clear evidence to the contrary,
courts presume that [government representatives] have properly discharged their official duties,"
United States v. Chem. 462462. RETRIEVED EVIDENCE:
Chem.
GOVERNING EVIDENCE:
representatives] have properly discharged their official duties," United States v. Chem. Found., 272 U.S. 1, 14-15 (1926), and thereby refrain from closely scrutinizing the Found., 272 U.S. 1, 14-15 (1926), and thereby refrain from closely scrutinizing the propriety of their activities. As demonstrated by the above-recited litany of irregular activities (see supra 35-37), however, there is more than "clear evidence to the contrary" in this case. 464464. RETRIEVED EVIDENCE:
As demonstrated by the above-recited litany of irregular activities (see supra 35-37), however, there is more than "clear evidence to the contrary" in this case.
GOVERNING EVIDENCE:
Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks…in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1…issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made…With his return to the White House, the President has gone beyond mere denunciation, and has actively mobilized the machinery of the criminal justice system against Director Brennan. He has…interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second As of December 22, 2025 - when undersigned counsel for Director Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 28 of 4625
Brennan sent the attached letter to Chief Judge Altonaga in the U.S. District Court for the Southern District of Florida - the Department had already engaged in more than enough irregular conduct to lose the presumption of regularity. 465465. RETRIEVED EVIDENCE:
As of December 22, 2025 - when undersigned counsel for Director Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 28 of 4625
Brennan sent the attached letter to Chief Judge Altonaga in the U.S. District Court for the Southern District of Florida - the Department had already engaged in more than enough irregular conduct to lose the presumption of regularity.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001…JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights
48
And, the intensified pace of irregular activity since then, described supra 39-50, has only confirmed the need for the courts to carefully examine all allegations of government overreaching targeted towards Director Brennan,
particularly his vindictive and selective prosecution challenges against any eventual indictment in this case. 466466. RETRIEVED EVIDENCE:
48
And, the intensified pace of irregular activity since then, described supra 39-50, has only confirmed the need for the courts to carefully examine all allegations of government overreaching targeted towards Director Brennan,
particularly his vindictive and selective prosecution challenges against any eventual indictment in this case.
GOVERNING EVIDENCE:
Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for…in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over
V.
The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations
53. 468468. RETRIEVED EVIDENCE:
The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations
53.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O…Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His
That careful examination would require the court hearing Director Brennan'schallenges to review the materials and communications relating to the government'sdecision-making throughout the investigation and ultimate prosecution. 469469. RETRIEVED EVIDENCE:
That careful examination would require the court hearing Director Brennan'schallenges to review the materials and communications relating to the government'sdecision-making throughout the investigation and ultimate prosecution.
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights To assess his claim that the prosecution is vindictive and selective, the court would need to evaluate the motivations of the involved government personnel, up to the President of the United States. 470470. RETRIEVED EVIDENCE:
To assess his claim that the prosecution is vindictive and selective, the court would need to evaluate the motivations of the involved government personnel, up to the President of the United States.
GOVERNING EVIDENCE:
the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A That would be accomplished via the thorough examination of the contemporaneous statements, communications, and writings that reflect and reveal these motivations. 471471. RETRIEVED EVIDENCE:
That would be accomplished via the thorough examination of the contemporaneous statements, communications, and writings that reflect and reveal these motivations.
GOVERNING EVIDENCE:
over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect…legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of…the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any…his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Examples of such records include: 472472. RETRIEVED EVIDENCE:
Examples of such records include:
GOVERNING EVIDENCE:
Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence…counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This communications from President Trump and the White House pushing for a prosecution; 473473. RETRIEVED EVIDENCE:
communications from President Trump and the White House pushing for a prosecution;
GOVERNING EVIDENCE:
13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations internal emails among DOJ officials discussing the "grand conspiracy" referrals and their search for a sufficiently pliant U.S.
Attorney to handle the resulting far-fetched investigation (see supra note 8); 474474. RETRIEVED EVIDENCE:
internal emails among DOJ officials discussing the "grand conspiracy" referrals and their search for a sufficiently pliant U.S.
Attorney to handle the resulting far-fetched investigation (see supra note 8);
GOVERNING EVIDENCE:
DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The prosecution memoranda and other materials reflecting assessments about the strength of any potential cases against Director Brennan; 475475. RETRIEVED EVIDENCE:
prosecution memoranda and other materials reflecting assessments about the strength of any potential cases against Director Brennan;
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President…Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations communications reflecting the reaction to AUSA Meditas Long'sreport that there was insufficient evidence to support the false-statements case; 476476. RETRIEVED EVIDENCE:
communications reflecting the reaction to AUSA Meditas Long'sreport that there was insufficient evidence to support the false-statements case;
GOVERNING EVIDENCE:
....................................................... 12 B. The False-Statements Investigation…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind…legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an and records reflecting the reasons why she and others who expressed such misgivings about the Brennan
48
See Appendix A; 477477. RETRIEVED EVIDENCE:
and records reflecting the reasons why she and others who expressed such misgivings about the Brennan
48
See Appendix A;
GOVERNING EVIDENCE:
Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to…time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…time any such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are…Department specifically are failing to observe their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true supra 35-36. 478478. RETRIEVED EVIDENCE:
supra 35-36.
GOVERNING EVIDENCE:
5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA…Sources Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority…Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 29 of 4626
cases - like those prosecutors in the other districts to which the cases were initially shopped -
were then pushed aside. 479479. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 29 of 4626
cases - like those prosecutors in the other districts to which the cases were initially shopped -
were then pushed aside.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD…INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ...................................................................…34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will Courts reviewing colorable vindictive and selective prosecution claims like those in this case routinely require the government to produce these records in its assessment whether the government acted vindictively or selectively in bringing aprosecution. 480480. RETRIEVED EVIDENCE:
Courts reviewing colorable vindictive and selective prosecution claims like those in this case routinely require the government to produce these records in its assessment whether the government acted vindictively or selectively in bringing aprosecution.
GOVERNING EVIDENCE:
Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal See, e.g.,
United States v. 481481. RETRIEVED EVIDENCE:
See, e.g.,
United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of Abrego, 802 F. Supp. 483483. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d 1055, 1065 (M.D. Tenn. 484484. RETRIEVED EVIDENCE:
3d 1055, 1065 (M.D. Tenn.
GOVERNING EVIDENCE:
bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670 2025) (considering emails,
internal DOJ memoranda); 485485. RETRIEVED EVIDENCE:
2025) (considering emails,
internal DOJ memoranda);
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The…Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government…Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent United States v. 486486. RETRIEVED EVIDENCE:
United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of Jarrett, 2010 WL 1577670, at *4 (N.D. 487487. RETRIEVED EVIDENCE:
Jarrett, 2010 WL 1577670, at *4 (N.D.
GOVERNING EVIDENCE:
Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of Just., Justice…2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010) (noting that the court did an in camera review of "hundreds of…documents" in assessing claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive…v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr. 20, 2021) (Contreras, J), and "[t]he government has a Ind. Apr. 20,
2010) (noting that the court did an in camera review of "hundreds of documents" in assessing claim of vindictive prosecution); 490490. RETRIEVED EVIDENCE:
20,
2010) (noting that the court did an in camera review of "hundreds of documents" in assessing claim of vindictive prosecution);
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for United States v. 491491. RETRIEVED EVIDENCE:
United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of Fieger, 2008 WL 205244, at *8 (E.D. 492492. RETRIEVED EVIDENCE:
Fieger, 2008 WL 205244, at *8 (E.D.
GOVERNING EVIDENCE:
3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of Just., Justice…2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010) (noting that the court did an in camera…of "hundreds of documents" in assessing claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive…v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr. 20, 2021) (Contreras, J), and "[t]he government has a Mich. 493493. RETRIEVED EVIDENCE:
Mich.
GOVERNING EVIDENCE:
claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive prosecution claim, the court considered…in camera material from the government "related to the DOJ's recusal of the three principal Detroit U.S. Attorneys" and ordered that evidence turned over to defendant); United States v…In re Mohammad, 866 F.3d 473, 475 (D.C. Cir. 2017) (same); Dascola v. City of Ann Arbor, 22 F. Supp. 3d 736, 746 (E.D. Mich. 2014). The very purpose of the requested order in this matter is to ensure that the
Jan. 24, 2008), as amended (Feb. 495495. RETRIEVED EVIDENCE:
24, 2008), as amended (Feb.
GOVERNING EVIDENCE:
extent and in the same manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1…to legal or ethical limitations. And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of…United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive prosecution claim, the court considered in camera material from…equally to records on non official electronic messaging channels. In 2014, Congress amended both the PRA and the FRA to prohibit executive department personnel from using…at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub. L. No. 113-187, 10, 128 Stat. 2003, 2014-15); see also United States 1, 2008) (in vindictive prosecution claim, the court considered in camera material from the government "related to the DOJ'srecusal of the three principal Detroit U.S. Attorneys" and ordered that evidence turned over to defendant); 496496. RETRIEVED EVIDENCE:
1, 2008) (in vindictive prosecution claim, the court considered in camera material from the government "related to the DOJ'srecusal of the three principal Detroit U.S. Attorneys" and ordered that evidence turned over to defendant);
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional United States v. 497497. RETRIEVED EVIDENCE:
United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of
P.H.E., Inc., 965 F.2d 848, 850, 853, 858 (10th Cir. 498498. RETRIEVED EVIDENCE:
P.H.E., Inc., 965 F.2d 848, 850, 853, 858 (10th Cir.
GOVERNING EVIDENCE:
and ordered that evidence turned over to defendant); United States v. P.H.E., Inc., 965 F.2d 848, 850, 853, 858 (10th Cir. 1992) (district court reviewed prosecution memoranda and…195 F. App'x 902, 903 (11th Cir. 2006); United States v. Rolande-Gabriel, 938 F.2d 1231, 1238 (11th Cir. 1991) (same). As the Supreme Court has explained, the 49 1992) (district court reviewed prosecution memoranda and letter from U.S. Attorney to Attorney General to evaluate vindictive prosecution claim implicating the First Amendment). 499499. RETRIEVED EVIDENCE:
1992) (district court reviewed prosecution memoranda and letter from U.S. Attorney to Attorney General to evaluate vindictive prosecution claim implicating the First Amendment).
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government
VI. 500500. RETRIEVED EVIDENCE:
VI.
GOVERNING EVIDENCE:
Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…General to evaluate vindictive prosecution claim implicating the First Amendment). VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant
Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved,
Which Would Prevent Director Brennan from Vindicating His Constitutional Rights
54. 501501. RETRIEVED EVIDENCE:
Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved,
Which Would Prevent Director Brennan from Vindicating His Constitutional Rights
54.
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights
Though critical to the consideration of such claims, there is strong reason to think that many of those materials and communications will no longer exist by the time those claims are raised in this matter. 502502. RETRIEVED EVIDENCE:
Though critical to the consideration of such claims, there is strong reason to think that many of those materials and communications will no longer exist by the time those claims are raised in this matter.
GOVERNING EVIDENCE:
1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government…and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His…Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Many officials in this Administration are failing to retain - or are intentionally eliminating - communications and documents that must be preserved. 503503. RETRIEVED EVIDENCE:
Many officials in this Administration are failing to retain - or are intentionally eliminating - communications and documents that must be preserved.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes…of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to
55.
The government has ongoing statutory and constitutional obligations to preserve evidence and records of the type that will be relevant to Director Brennan'schallenges to an indictment in this matter. 505505. RETRIEVED EVIDENCE:
The government has ongoing statutory and constitutional obligations to preserve evidence and records of the type that will be relevant to Director Brennan'schallenges to an indictment in this matter.
GOVERNING EVIDENCE:
Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights Many of these communications and materials - including the communications by Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 30 of 4627
which the President is influencing the Justice Department's decision-making - are covered by the Presidential Records Act ("PRA"), 44 U.S.C. 506506. RETRIEVED EVIDENCE:
Many of these communications and materials - including the communications by Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 30 of 4627
which the President is influencing the Justice Department's decision-making - are covered by the Presidential Records Act ("PRA"), 44 U.S.C.
GOVERNING EVIDENCE:
Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His…Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights .......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii 2201-09, which governs the preservation of records that are created in the course of the President, Vice President, their staff and their advisers carrying out their constitutional, statutory or other responsibilities. 507507. RETRIEVED EVIDENCE:
2201-09, which governs the preservation of records that are created in the course of the President, Vice President, their staff and their advisers carrying out their constitutional, statutory or other responsibilities.
GOVERNING EVIDENCE:
Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ......................…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years Others are covered by the Federal Records Act ("FRA"), which requires an agency to "make and preserve records containing adequate and proper documentation" of its activities "to protect the legal ... rights ...
of persons directly affected by the agency's activities." 44 U.S.C. 508508. RETRIEVED EVIDENCE:
Others are covered by the Federal Records Act ("FRA"), which requires an agency to "make and preserve records containing adequate and proper documentation" of its activities "to protect the legal ... rights ...
of persons directly affected by the agency's activities." 44 U.S.C.
GOVERNING EVIDENCE:
capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from 3101.
49
56.
Those materials and communications also clearly fall within the category of evidence that the court would require the government to provide in discovery relating to Director Brennan's vindictive and selective prosecution challenges. 511511. RETRIEVED EVIDENCE:
Those materials and communications also clearly fall within the category of evidence that the court would require the government to provide in discovery relating to Director Brennan's vindictive and selective prosecution challenges.
GOVERNING EVIDENCE:
Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning See supra 53. 512512. RETRIEVED EVIDENCE:
See supra 53.
GOVERNING EVIDENCE:
5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA…Sources Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority…Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ As courts have repeatedly stated,
that discovery obligation to produce evidence carries with it a corresponding obligation to preserve that evidence. 513513. RETRIEVED EVIDENCE:
As courts have repeatedly stated,
that discovery obligation to produce evidence carries with it a corresponding obligation to preserve that evidence.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…s questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the "[The] duties to disclose include[] a correlative duty to preserve that evidence in the first place," United States v. 514514. RETRIEVED EVIDENCE:
"[The] duties to disclose include[] a correlative duty to preserve that evidence in the first place," United States v.
GOVERNING EVIDENCE:
Not be Preserved, Which Would…Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This…personnel are maintaining adherence to professional standards and carrying out their duties in the best tradition of the Justice Department. Case 1:26-cv-02323 Document 1 Filed Vega, 826 F.3d 514, 533 (D.C. 515515. RETRIEVED EVIDENCE:
Vega, 826 F.3d 514, 533 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed…JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E…recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set Cir. 2016); see United States v. 518518. RETRIEVED EVIDENCE:
see United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of Harris, 2021 WL 1546541, at *2 (D.D.C. 519519. RETRIEVED EVIDENCE:
Harris, 2021 WL 1546541, at *2 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Apr. 20, 2021) (Contreras, J), and
"[t]he government has a responsibility to try in good faith to preserve material evidence." United States v. 521521. RETRIEVED EVIDENCE:
20, 2021) (Contreras, J), and
"[t]he government has a responsibility to try in good faith to preserve material evidence." United States v.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE Roberson, 195 F. App'x 902, 903 (11th Cir. 523523. RETRIEVED EVIDENCE:
App'x 902, 903 (11th Cir.
GOVERNING EVIDENCE:
responsibility to try in good faith to preserve material evidence." United States v. Roberson, 195 F. App'x 902, 903 (11th Cir. 2006); United States v. Rolande-Gabriel, 938 F.2d 1231, 1238 2006); United States v. 525525. RETRIEVED EVIDENCE:
United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of Rolande-Gabriel,
938 F.2d 1231, 1238 (11th Cir. 526526. RETRIEVED EVIDENCE:
Rolande-Gabriel,
938 F.2d 1231, 1238 (11th Cir.
GOVERNING EVIDENCE:
evidence." United States v. Roberson, 195 F. App'x 902, 903 (11th Cir. 2006); United States v. Rolande-Gabriel, 938 F.2d 1231, 1238 (11th Cir. 1991) (same). As the Supreme Court has 1991) (same). 527527. RETRIEVED EVIDENCE:
1991) (same).
GOVERNING EVIDENCE:
process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim…Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying…a different grand jury in Miami, which issued subpoenas in January 2026 seeking the same category of documents from 2016 all the way up to the present. 31 James Hoft, Joe…Government Personnel from Accountability for Their Irregular Conduct 49. At the same time that government personnel are accelerating their overreaching efforts against…Then He was Fired, Guardian (Jan. 3, 2026), https://perma.cc/8JHJ-PGM3 . The same day, the U.S. Pardon Attorney, who was a career civil servant, was terminated by a…engages in that attorney's duties, to the same extent and in the same manner as other attorneys in that State." 28 As the Supreme Court has explained, the
49
Congress has made clear that these preservation requirements apply equally to records on non official electronic messaging channels. 528528. RETRIEVED EVIDENCE:
As the Supreme Court has explained, the
49
Congress has made clear that these preservation requirements apply equally to records on non official electronic messaging channels.
GOVERNING EVIDENCE:
JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal…Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes In 2014, Congress amended both the PRA and the FRA to prohibit executive department personnel from using non-official electronic messaging accounts, such as on personal devices, unless they take steps to ensure the conversation is preserved. 529529. RETRIEVED EVIDENCE:
In 2014, Congress amended both the PRA and the FRA to prohibit executive department personnel from using non-official electronic messaging accounts, such as on personal devices, unless they take steps to ensure the conversation is preserved.
GOVERNING EVIDENCE:
Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes 44 U.S.C. 530530. RETRIEVED EVIDENCE:
44 U.S.C.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of 2911; see Am. Hist. 533533. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 Ass'n v. 534534. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding Trump, --- F. 535535. RETRIEVED EVIDENCE:
Trump, --- F.
GOVERNING EVIDENCE:
Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L Supp. 536536. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d. 537537. RETRIEVED EVIDENCE:
3d.
GOVERNING EVIDENCE:
recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr…2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J ----, 2026 WL
1412395, at *2 (D.D.C. 538538. RETRIEVED EVIDENCE:
----, 2026 WL
1412395, at *2 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of May 20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub. 539539. RETRIEVED EVIDENCE:
May 20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub.
GOVERNING EVIDENCE:
Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years L. No. 113-187, 10, 128 Stat. 541541. RETRIEVED EVIDENCE:
No. 113-187, 10, 128 Stat.
GOVERNING EVIDENCE:
Presidential and Federal Records Act Amendments of 2014, Pub. L. No. 113-187, 10, 128 Stat. 2003, 2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C 2003, 2014-15); see also United States v. 543543. RETRIEVED EVIDENCE:
see also United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of Navarro, 664 F. Supp. 545545. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d 48, 57 (D.D.C. 546546. RETRIEVED EVIDENCE:
3d 48, 57 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of 2023) (the PRA applies to records such as emails or texts sent and received on personal accounts if "they arose out of [aperson's]
employment in the administration"), aff'd, 2024 WL 1364354 (D.C. 547547. RETRIEVED EVIDENCE:
2023) (the PRA applies to records such as emails or texts sent and received on personal accounts if "they arose out of [aperson's]
employment in the administration"), aff'd, 2024 WL 1364354 (D.C.
GOVERNING EVIDENCE:
STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…organizational structure remains in place to this day. 17. Director Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates…plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in this district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events or omissions Cir. Apr. 1, 2024).
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 31 of 4628
government has aduty to preserve evidence that "might be expected to play a significant role in the suspect'sdefense." California v. 551551. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 31 of 4628
government has aduty to preserve evidence that "might be expected to play a significant role in the suspect'sdefense." California v.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i Trombetta, 467 U.S. 479, 488 (1984). 552552. RETRIEVED EVIDENCE:
Trombetta, 467 U.S. 479, 488 (1984).
GOVERNING EVIDENCE:
might be expected to play a significant role in the suspect's defense." California v. Trombetta, 467 U.S. 479, 488 (1984). 57. Administration officials are failing to uphold those…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of
57.
Administration officials are failing to uphold those preservation obligations in ways that are both inadvertent and advertent. 554554. RETRIEVED EVIDENCE:
Administration officials are failing to uphold those preservation obligations in ways that are both inadvertent and advertent.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes…of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to First, with the evolution of technology, government officials have access to arange of communications technologies that, unlike the traditional government email system, are not amenable to standard preservation processes consistent with the FRA
(discussed infra 58-59). 555555. RETRIEVED EVIDENCE:
First, with the evolution of technology, government officials have access to arange of communications technologies that, unlike the traditional government email system, are not amenable to standard preservation processes consistent with the FRA
(discussed infra 58-59).
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington Particularly under the current administration, government officials are increasingly relying on avariety of ephemeral methods of communication, to include social media posts, encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like. 556556. RETRIEVED EVIDENCE:
Particularly under the current administration, government officials are increasingly relying on avariety of ephemeral methods of communication, to include social media posts, encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like.
GOVERNING EVIDENCE:
by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…and prosecutive decisions. A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their…them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are increasingly relying on communications that are not routinely preserved, even though they should be, pursuant…government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not
50
While these ephemeral communications are fully subject to the above-listed preservation requirements, the preservation processes have not been implemented to ensure those requirements are being consistently satisfied. 557557. RETRIEVED EVIDENCE:
50
While these ephemeral communications are fully subject to the above-listed preservation requirements, the preservation processes have not been implemented to ensure those requirements are being consistently satisfied.
GOVERNING EVIDENCE:
Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging…over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional This is despite clear guidance from the National Archives and Research Administration warning federal agencies that "[t]he auto-delete functions of third party messaging apps may violate federal record-keeping requirements" and instructing them on the "strict requirements" in the Federal Records Act for the preservation of all such records. 558558. RETRIEVED EVIDENCE:
This is despite clear guidance from the National Archives and Research Administration warning federal agencies that "[t]he auto-delete functions of third party messaging apps may violate federal record-keeping requirements" and instructing them on the "strict requirements" in the Federal Records Act for the preservation of all such records.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…Document 1 Filed 07/01/26 Page 8 of 465 personnel who had worked on the ICA, requiring them to testify before the grand jury in the false-statements investigation. Those…and prosecutive decisions. A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their…government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely…director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W. Bush to…Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA Distinguished Career
51
58.
Beyond that arguably inadvertent failure to preserve, officials of this Administration have shown an advertent disdain for their preservation obligations. 560560. RETRIEVED EVIDENCE:
Beyond that arguably inadvertent failure to preserve, officials of this Administration have shown an advertent disdain for their preservation obligations.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes…of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to President Trump has repeatedly deleted social media posts that should be retained. 561561. RETRIEVED EVIDENCE:
President Trump has repeatedly deleted social media posts that should be retained.
GOVERNING EVIDENCE:
16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these
52
On September 20, 2025, for example, he posted a message on Truth Social directing then-Attorney General Bondi to accelerate
50
See supra note 2. 562562. RETRIEVED EVIDENCE:
52
On September 20, 2025, for example, he posted a message on Truth Social directing then-Attorney General Bondi to accelerate
50
See supra note 2.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL…adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong…records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney
51
Memorandum from William Fischer, Chief Records Officer, to Fed. 563563. RETRIEVED EVIDENCE:
51
Memorandum from William Fischer, Chief Records Officer, to Fed.
GOVERNING EVIDENCE:
and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence…counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…and less deferential to the government than usual because of the Justice Department's recent record of overreaching in this and similar matters, which has negated the traditional…A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on…their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous communications and Records Mgmt. 564564. RETRIEVED EVIDENCE:
Records Mgmt.
GOVERNING EVIDENCE:
s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence…counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…and less deferential to the government than usual because of the Justice Department's recent record of overreaching in this and similar matters, which has negated the traditional…specifically are failing to observe their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true Contacts
(May 2, 2025),
https://perma.cc/TAB5-E2ZX
.
52
Bernd Debusmann Jr., Trump Deletes Post Depicting Him as Jesus-like Figure After Backlash,
BBC News (Apr. 565565. RETRIEVED EVIDENCE:
Contacts
(May 2, 2025),
https://perma.cc/TAB5-E2ZX
.
52
Bernd Debusmann Jr., Trump Deletes Post Depicting Him as Jesus-like Figure After Backlash,
BBC News (Apr.
GOVERNING EVIDENCE:
can be set to auto delete, internal messaging…National Archives and Research Administration warning federal agencies that "[t]he auto-delete functions of third party messaging apps may violate federal record-keeping requirements…shown an advertent disdain for their preservation obligations. President Trump has repeatedly deleted social media posts that should be retained. 52 On September 20, 2025, for example, he…Chief Records Officer, to Fed. Records Mgmt. Contacts (May 2, 2025), https://perma.cc/TAB5-E2ZX . 52 Bernd Debusmann Jr., Trump Deletes Post Depicting Him as Jesus-like Figure After Backlash, BBC News (Apr. 13, 2026), https://perma.cc/6EBF-N3EJ ; Alex Nguyen, A Non-Exhaustive List of Trump's Deleted Posts, Mother Jones (Apr. 13, 2026), https://perma.cc/M8M7-WARP . Case 1:26-cv-02323…James. Though clearly a government record to be preserved under the PRA, the President deleted the post after it became clear that it was in the public domain. 53 It has also been 13, 2026),
https://perma.cc/6EBF-N3EJ
; 566566. RETRIEVED EVIDENCE:
13, 2026),
https://perma.cc/6EBF-N3EJ
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Alex Nguyen, A Non-Exhaustive List of Trump's Deleted Posts, Mother Jones (Apr. 567567. RETRIEVED EVIDENCE:
Alex Nguyen, A Non-Exhaustive List of Trump's Deleted Posts, Mother Jones (Apr.
GOVERNING EVIDENCE:
NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L…Russia had interfered in the 2016 presidential election in an effort to boost candidate Donald Trump's chances of winning the election. In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and…and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan as "a very bad guy," "a total low-life," a "loser" and a "political 13, 2026),
https://perma.cc/M8M7-WARP
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 32 of 4629
prosecutions against James Comey, Adam Schiff and Letitia James. 568568. RETRIEVED EVIDENCE:
13, 2026),
https://perma.cc/M8M7-WARP
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 32 of 4629
prosecutions against James Comey, Adam Schiff and Letitia James.
GOVERNING EVIDENCE:
1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE…Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will…Director Brennan alleges as follows: Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 of 463 INTRODUCTION 1. Director Brennan is a former longtime public servant who…Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are Though clearly a government record to be preserved under the PRA, the President deleted the post after it became clear that it was in the public domain. 569569. RETRIEVED EVIDENCE:
Though clearly a government record to be preserved under the PRA, the President deleted the post after it became clear that it was in the public domain.
GOVERNING EVIDENCE:
Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE
53
It has also been recently reported that President Trump sent a number of direct messages about official matters during his first administration that were never preserved. 570570. RETRIEVED EVIDENCE:
53
It has also been recently reported that President Trump sent a number of direct messages about official matters during his first administration that were never preserved.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency
54
And he has acted similarly with regard to hard-copy government records,
reportedly once flushing some down a toilet
55
and ripping others into confetti-size pieces. 571571. RETRIEVED EVIDENCE:
54
And he has acted similarly with regard to hard-copy government records,
reportedly once flushing some down a toilet
55
and ripping others into confetti-size pieces.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i
56
59.
Officials across the Executive Branch are exhibiting that same cavalier attitude about their duty to preserve records. 573573. RETRIEVED EVIDENCE:
Officials across the Executive Branch are exhibiting that same cavalier attitude about their duty to preserve records.
GOVERNING EVIDENCE:
Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes
57
For example, during the time that Lindsey Halligan purported to serve as the U.S. Attorney in the Eastern District of Virginia, she used Signal to communicate with a journalist about a grand jury investigation under her official authority - i.e., the investigation into New York Attorney General Letitia James - and set the messages to disappear after eight hours.
58
A whistleblower reportedly accused Ed Martin, formerly head of
53
Kristen Welker & Rebecca Shabad, supra note 22; 575575. RETRIEVED EVIDENCE:
58
A whistleblower reportedly accused Ed Martin, formerly head of
53
Kristen Welker & Rebecca Shabad, supra note 22;
GOVERNING EVIDENCE:
use cases at DOJ); Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The…Responsibility 39 and the Director of the Departmental Ethics Office 40 (who had previously given then-Deputy Attorney General Blanche the unwelcome advice that he must recuse…General Letitia James - and set the messages to disappear after eight hours. 58 A whistleblower reportedly accused Ed Martin, formerly head of 53 Kristen Welker & Rebecca Shabad, supra note 22; Josh Dawsey, Sadie Gurman & Aruna Viswanatha, Inside the Justice…prosecution . . . regardless of content"). U.S. Dep't of Just., Just. Manual 9-5.004 (2019). 59 Rebecca Beitsch, Whistleblower Accuses Ed Martin of 'Concealing and Destroying' Records Related to DOJ's Weaponization Group, Hill (Nov…//perma.cc/BG4A-UB6V ; Letter from Jamie Raskin, Ranking Member, H. Comm. on the Judiciary, to Edward P. Martin, Jr., Pardon Att'y and Dir., Weaponization Working Grp., U.S. Dep't of Just. (Nov. 17, 2025 Josh Dawsey, Sadie Gurman & Aruna Viswanatha, Inside the Justice Department Where the President Calls the Shots, Wall Street Journal (Oct. 576576. RETRIEVED EVIDENCE:
Josh Dawsey, Sadie Gurman & Aruna Viswanatha, Inside the Justice Department Where the President Calls the Shots, Wall Street Journal (Oct.
GOVERNING EVIDENCE:
of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A 8, 2025),
https://perma.cc/DD4C-35MH
.
54
Nate Jones, Trump Library Says no Twitter DMs Can be Found, Despite Evidence he Sent Them, Washington Post (June 3, 2026),
https://perma.cc/95LK-AWUR
.
55
Edward Helmore, Photos Suggest Trump Blocked Toilets with Ripped-up White House Documents, Guardian (Aug. 577577. RETRIEVED EVIDENCE:
8, 2025),
https://perma.cc/DD4C-35MH
.
54
Nate Jones, Trump Library Says no Twitter DMs Can be Found, Despite Evidence he Sent Them, Washington Post (June 3, 2026),
https://perma.cc/95LK-AWUR
.
55
Edward Helmore, Photos Suggest Trump Blocked Toilets with Ripped-up White House Documents, Guardian (Aug.
GOVERNING EVIDENCE:
as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official…capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning…and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through…Brennan guilty of crimes ranging from treason to lying before Congress, and has twice posted doctored images of Director Brennan in an orange jumpsuit. 4. With his return to the 8, 2022),
https://perma.cc/A7VV-GP25
; 578578. RETRIEVED EVIDENCE:
8, 2022),
https://perma.cc/A7VV-GP25
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Mike Allen, Exclusive Photos: 579579. RETRIEVED EVIDENCE:
Mike Allen, Exclusive Photos:
GOVERNING EVIDENCE:
40 Sam Levine, supra note 39; Katelyn Polantz, Evan Perez & Hannah Rabinowitz, Exclusive: Acting AG Todd Blanche was Told Last Year to Recuse from Justice Department Matters…Them, Washington Post (June 3, 2026), https://perma.cc/95LK-AWUR . 55 Edward Helmore, Photos Suggest Trump Blocked Toilets with Ripped-up White House Documents, Guardian (Aug. 8, 2022), https://perma.cc/A7VV-GP25 ; Mike Allen, Exclusive Photos: Trump's Telltale Toilet, Axios (Aug. 8, 2022), https://perma.cc/98QG-ULBK …Working Group. 59 There was also the incident in which National Security Advisor Mike Waltz, Vice President J.D. Vance, CIA Director John Ratcliffe, Treasury Secretary Scott Trump's Telltale Toilet, Axios (Aug. 580580. RETRIEVED EVIDENCE:
Trump's Telltale Toilet, Axios (Aug.
GOVERNING EVIDENCE:
Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L…Russia had interfered in the 2016 presidential election in an effort to boost candidate Donald Trump's chances of winning the election. In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and 8, 2022),
https://perma.cc/98QG-ULBK
.
56
Annie Karni, Meet the Guys who Tape Trump's Papers Back Together, Politico (June 10,
2018),
https://perma.cc/3A7S-6HZY
.
57
See generally A Disappearing Data Chronology, Nat'l Sec. 581581. RETRIEVED EVIDENCE:
8, 2022),
https://perma.cc/98QG-ULBK
.
56
Annie Karni, Meet the Guys who Tape Trump's Papers Back Together, Politico (June 10,
2018),
https://perma.cc/3A7S-6HZY
.
57
See generally A Disappearing Data Chronology, Nat'l Sec.
GOVERNING EVIDENCE:
of the John Brennan Investigation, CNN (May 8, 2026), https://perma.cc/S58G-9MTK . 13 See generally Appendix A. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 19 of 4616 A…the investigation. 26 44. diGenova is a former United States Attorney and a vocal ally of President Trump. According to diGenova, the President personally appointed him to…lengthy discussion of the current investigations. He confirmed the existence, scope, and general 34 Daniel Klaidman & Sarah N. Lynch, Witnesses in Criminal Probe of Ex-CIA Director…manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26…Aug. 8, 2022), https://perma.cc/98QG-ULBK . 56 Annie Karni, Meet the Guys who Tape Trump's Papers Back Together, Politico (June 10, 2018), https://perma.cc/3A7S-6HZY . 57 See generally A Disappearing Data Chronology, Nat'l Sec. Archive, https Archive,
https://perma.cc/55SN
66EV
(last visited June 5, 2026) (collecting instances of the Trump Administration changing or removing information). 582582. RETRIEVED EVIDENCE:
Archive,
https://perma.cc/55SN
66EV
(last visited June 5, 2026) (collecting instances of the Trump Administration changing or removing information).
GOVERNING EVIDENCE:
orange jumpsuit. 4. With his return to the White House, the…that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 12. For this reason, Director Brennan brings this action…Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…attacks. 15. Following his retirement from the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as See also DON'T SHRED ON ME! 583583. RETRIEVED EVIDENCE:
See also DON'T SHRED ON ME!
GOVERNING EVIDENCE:
collecting instances of the Trump Administration changing or removing information). See also DON'T SHRED ON ME! USAID Documents Destruction Breaks the Law, According to National Security…National Security Archive (USAID's Acting Executive Secretary inviting employees to shred or burn classified records and personnel files in March 2025); Kayla Epstein, USAID Staff Told to Shred and Burn Classified Documents, BBC News (Mar. 11, 2025), https://perma.cc/5M2F-JQMZ USAID Documents Destruction Breaks the Law, According to National Security Archive, National Security Archive (USAID's Acting Executive Secretary inviting employees to shred or burn classified records and personnel files in March 2025); 584584. RETRIEVED EVIDENCE:
USAID Documents Destruction Breaks the Law, According to National Security Archive, National Security Archive (USAID's Acting Executive Secretary inviting employees to shred or burn classified records and personnel files in March 2025);
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as…N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel Kayla Epstein, USAID Staff Told to Shred and Burn Classified Documents,
BBC News (Mar. 585585. RETRIEVED EVIDENCE:
Kayla Epstein, USAID Staff Told to Shred and Burn Classified Documents,
BBC News (Mar.
GOVERNING EVIDENCE:
as opposition research by a former British intelligence officer) 5 in the…DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https…Prosecutor in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the…Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean…Plaintiff). The accusations in the interview were so pointed and unsupported that Fox News felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean…Trump Accidentally Posted Message Pressuring Pam Bondi to Charge his Enemies, Source Says, NBC News (Oct. 10, 2025), https://perma.cc/LX38 A439 . 23 Laura Jarrett & Ryan J. Reilly, Todd Blanche 11, 2025),
https://perma.cc/5M2F-JQMZ
.
58
Anna Bower, "Anna, Lindsey Halligan Here.", Lawfare (Oct. 586586. RETRIEVED EVIDENCE:
11, 2025),
https://perma.cc/5M2F-JQMZ
.
58
Anna Bower, "Anna, Lindsey Halligan Here.", Lawfare (Oct.
GOVERNING EVIDENCE:
v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https://perma.cc/3LTF-UPW2 . 7 Appendix A, at 15-16. 8 Eric Tucker, Key…the Importance of Limiting White House-DOJ Contacts: It's Not Just About Obstruction, Lawfare (May 22, 2017), https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to…day that the president was ripping mad about the fact that there was no progress on the lawfare investigation in Miami. 24In April, the lead career prosecutor on the Brennan…Legal Team Shake-Up Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to…Grand Conspiracy Probe (1), Bloomberg Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 20, 2025),
https://perma.cc/DP74-U7XN
. This was contrary to Section 9-5.004 of the federal Justice Manual, which states that "[a]ll prosecution team members should be aware of the government'sobligations regarding the preservation and disclosure of electronic communications, or 'e Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 33 of 4630
the DOJ Weaponization Group, of concealing and destroying communications relating to his work on the Weaponization Working Group. 587587. RETRIEVED EVIDENCE:
20, 2025),
https://perma.cc/DP74-U7XN
. This was contrary to Section 9-5.004 of the federal Justice Manual, which states that "[a]ll prosecution team members should be aware of the government'sobligations regarding the preservation and disclosure of electronic communications, or 'e Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 33 of 4630
the DOJ Weaponization Group, of concealing and destroying communications relating to his work on the Weaponization Working Group.
GOVERNING EVIDENCE:
in his order quashing federal subpoenas directed at…apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely preserved. 2 Second, there is ample…Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for…relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes government personnel and record systems that would have the…Investigations that Target Director Brennan 32. There are currently two ongoing federal grand jury investigations examining past conduct by Director Brennan. According to
59
There was also the incident in which National Security Advisor Mike Waltz, Vice President J.D. 588588. RETRIEVED EVIDENCE:
59
There was also the incident in which National Security Advisor Mike Waltz, Vice President J.D.
GOVERNING EVIDENCE:
Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And Vance, CIA Director John Ratcliffe, Treasury Secretary Scott Bessent, DNI Director Tulsi Gabbard, Secretary of War Pete Hegseth, Secretary of State Marco Rubio, and others communicated in a Signal chat (which accidentally included areporter from the Atlantic) about upcoming strikes against Huthi targets in Yemen with messages that indicated on their face that they would disappear at certain intervals - 1 week and 4
weeks. 589589. RETRIEVED EVIDENCE:
Vance, CIA Director John Ratcliffe, Treasury Secretary Scott Bessent, DNI Director Tulsi Gabbard, Secretary of War Pete Hegseth, Secretary of State Marco Rubio, and others communicated in a Signal chat (which accidentally included areporter from the Atlantic) about upcoming strikes against Huthi targets in Yemen with messages that indicated on their face that they would disappear at certain intervals - 1 week and 4
weeks.
GOVERNING EVIDENCE:
P. PATEL, in his official capacity as Director of the Federal Bureau of…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation
60
And on one recent evening, the Associate Attorney General issued a controversial post indicating that the Department would pursue an alternative to the derailed plan to establish a fund to compensate victims of supposed "weaponization" (see supra note 47), but the post was deleted from his Xaccount the next morning. 590590. RETRIEVED EVIDENCE:
60
And on one recent evening, the Associate Attorney General issued a controversial post indicating that the Department would pursue an alternative to the derailed plan to establish a fund to compensate victims of supposed "weaponization" (see supra note 47), but the post was deleted from his Xaccount the next morning.
GOVERNING EVIDENCE:
QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery obligations. These technologies include…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has…laws, or treaties of the United States." Id. This Court also has jurisdiction pursuant to 28 U.S.C. 1361, which grants original jurisdiction to the district courts over
61
Finally, in arecent challenge to the Administration'smass terminations of government employees, discovery revealed that high-level communications,' which include emails, text messages, SMS (short message service), instant messages, voice mail, pin-to-pin communications, and similar means of electronic communication. 591591. RETRIEVED EVIDENCE:
61
Finally, in arecent challenge to the Administration'smass terminations of government employees, discovery revealed that high-level communications,' which include emails, text messages, SMS (short message service), instant messages, voice mail, pin-to-pin communications, and similar means of electronic communication.
GOVERNING EVIDENCE:
Strong Grounds for Challenging any Criminal…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim…product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…and communications potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying . . . Prosecution team members should preserve for later review and possible disclosure all substantive e-communications created or received by team members during the course of an investigation and prosecution . . . regardless of content"). U.S. Dep'tof Just., Just. 592592. RETRIEVED EVIDENCE:
. . . Prosecution team members should preserve for later review and possible disclosure all substantive e-communications created or received by team members during the course of an investigation and prosecution . . . regardless of content"). U.S. Dep'tof Just., Just.
GOVERNING EVIDENCE:
11 FACTUAL BACKGROUND…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution…records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by
Manual 9-5.004 (2019). 593593. RETRIEVED EVIDENCE:
Manual 9-5.004 (2019).
GOVERNING EVIDENCE:
//perma.cc/DP74-U7XN . This was contrary to Section 9-5.004 of the federal Justice Manual, which states that "[a]ll prosecution team members should be aware of the government's…investigation and prosecution . . . regardless of content"). U.S. Dep't of Just., Just. Manual 9-5.004 (2019). 59 Rebecca Beitsch, Whistleblower Accuses Ed Martin of 'Concealing
59
Rebecca Beitsch, Whistleblower Accuses Ed Martin of 'Concealing and Destroying' Records Related to DOJ's Weaponization Group, Hill (Nov. 594594. RETRIEVED EVIDENCE:
59
Rebecca Beitsch, Whistleblower Accuses Ed Martin of 'Concealing and Destroying' Records Related to DOJ's Weaponization Group, Hill (Nov.
GOVERNING EVIDENCE:
that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion…and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For…working for six administrations - three Republican and three Democratic - in a wide variety of national security and intelligence positions. His public service career culminated in his…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016 presidential…or written statements that personally criticize and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and 17, 2025),
https://perma.cc/BG4A-UB6V
; 595595. RETRIEVED EVIDENCE:
17, 2025),
https://perma.cc/BG4A-UB6V
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury
Letter from Jamie Raskin, Ranking Member, H. 596596. RETRIEVED EVIDENCE:
Letter from Jamie Raskin, Ranking Member, H.
GOVERNING EVIDENCE:
who has never registered as a member of any political party, as…District of Florida since August 13, 2025. In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested…Brennan's alleged false statements to Congress. In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested…personnel who are working on the Brennan investigations. In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested…2017 to January 20, 2021. As the President, he has responsibility over Executive Branch subordinates and record systems that would have the records to be preserved under the requested…White House Chief of Staff since January 20, 2025. In that role, she has responsibility over subordinates and record systems that would have the records to be preserved under the requested Comm. 597597. RETRIEVED EVIDENCE:
Comm.
GOVERNING EVIDENCE:
on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S. Dep't of Just…Nov. 17, 2025), https://perma.cc/BG4A-UB6V ; Letter from Jamie Raskin, Ranking Member, H. Comm. on the Judiciary, to Edward P. Martin, Jr., Pardon Att'y and Dir., Weaponization…into allegations that he lied in his testimony to the House of Representatives Committee on the Judiciary on May 11, 2023 and the investigation into the "grand conspiracy" being on the Judiciary, to Edward P. Martin,
Jr., Pardon Att'yand Dir., Weaponization Working Grp., U.S. Dep'tof Just. 599599. RETRIEVED EVIDENCE:
Martin,
Jr., Pardon Att'yand Dir., Weaponization Working Grp., U.S. Dep'tof Just.
GOVERNING EVIDENCE:
2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use…Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces Formation of Strike Force to Assess Evidence…of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S. Dep't of Just. (Oct. 21, 2025), https://perma.cc/R257-56FL . 5 Trump-Russia Steele…22, 2017), https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009), https://perma.cc/W55M-M7FW (Eric Holder 2009 memo). 20 Memorandum from the Attorney General to All Dep't Emps. (Feb. 5, 2025), https://perma.cc/3PPL-BWER . 21 In-Your-Face DOJ Aide Rides (Nov. 17, 2025),
https://perma.cc/AZ83-JPKH
.
60
Josh Gerstein & Kyle Cheney, Judge Orders Trump Administration to Preserve Signal Chats,
Politico (Mar. 601601. RETRIEVED EVIDENCE:
17, 2025),
https://perma.cc/AZ83-JPKH
.
60
Josh Gerstein & Kyle Cheney, Judge Orders Trump Administration to Preserve Signal Chats,
Politico (Mar.
GOVERNING EVIDENCE:
Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw 27, 2025),
https://perma.cc/AL4Q-NJJ5
. According to reports, the National Security Advisor's team had set up at least 20 Signal group chats to discuss crises in Ukraine,
China, Gaza, the broader Middle East, Africa and Europe. 602602. RETRIEVED EVIDENCE:
27, 2025),
https://perma.cc/AL4Q-NJJ5
. According to reports, the National Security Advisor's team had set up at least 20 Signal group chats to discuss crises in Ukraine,
China, Gaza, the broader Middle East, Africa and Europe.
GOVERNING EVIDENCE:
Officials Publicly Discuss Grand Jury Activity…at the request of President Obama to serve as Assistant to the President for Homeland Security and Counterterrorism and Deputy National Security Advisor in the Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 11 of 468 Executive…was responsible during this time for orchestrating Obama Administration policies on homeland security, pandemics, cyberattacks, and natural disasters. 16. The United States Senate…day. 17. Director Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA…Director Brennan lied in 2023 testimony before the House Judiciary Committee when he discussed the role of the Steele Dossier (which was reportedly a batch of materials about then…to the only judge in that Division - Judge Aileen Cannon. This April, the prosecution team established its headquarters in the U.S. Attorney's Office in Fort Pierce. 12 Fort Dasha Burns, Waltz's Team Set Up at Least 20 Signal Group Chats for Crises Across the World, Politico (Apr. 603603. RETRIEVED EVIDENCE:
Dasha Burns, Waltz's Team Set Up at Least 20 Signal Group Chats for Crises Across the World, Politico (Apr.
GOVERNING EVIDENCE:
opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge…provided legal services in support of the President's causes, temporarily joining the President's team of lawyers dealing with the Mueller Special Counsel investigation and serving on the legal team challenging the results of the 2020 presidential election. 29 He has been a passionate…guilty of participation in the supposed "grand conspiracy," calling 26 In building that team, diGenova has recruited attorneys with demonstrated devotion to President Trump and his…N.Y. Times (Feb. 12, 2026), https://perma.cc/483P-DP3P ; Trump-Russia: President's Legal Team Shake-Up Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower &…Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News (Mar. 19, 2018), https://perma.cc/ZP79-WTLH . 29 Id.; Trump Lawyer 2, 2025),
https://perma.cc/6WKP-3K5W
. Importantly, the messages about the Yemen strikes were ultimately deleted from the phone of CIA Director John Ratcliffe. 604604. RETRIEVED EVIDENCE:
2, 2025),
https://perma.cc/6WKP-3K5W
. Importantly, the messages about the Yemen strikes were ultimately deleted from the phone of CIA Director John Ratcliffe.
GOVERNING EVIDENCE:
99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation…Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product Julian E. Barnes, C.I.A. 606606. RETRIEVED EVIDENCE:
Barnes, C.I.A.
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016…grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice Department have succumbed…senior Administration officials in the run-up to the First Gulf War (1990-91); daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95); senior U.S. intelligence official resident in Saudi Arabia (1996-99); Chief of Staff to Director of Central Intelligence George Tenet (1999-2001); and, Deputy Executive Director of the CIA (2001-03). As
Director's Messages in Leaked Chat Were Deleted, Agency Says, N.Y. 607607. RETRIEVED EVIDENCE:
Director's Messages in Leaked Chat Were Deleted, Agency Says, N.Y.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights Times (Apr. 15, 2025),
https://perma.cc/BF54-6CS2
.
61
Alexander Mallin, Top DOJ Official Deletes Post on Alternate 'Anti-weaponization'
Compensation Plan, ABC News (June 3, 2026),
https://perma.cc/QNU3-RX5L
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 34 of 4631
officials in the Department of Homeland Security used Signal groups on their personal phones to communicate, and that Justice Department attorneys failed to adequately preserve those materials. 609609. RETRIEVED EVIDENCE:
15, 2025),
https://perma.cc/BF54-6CS2
.
61
Alexander Mallin, Top DOJ Official Deletes Post on Alternate 'Anti-weaponization'
Compensation Plan, ABC News (June 3, 2026),
https://perma.cc/QNU3-RX5L
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 34 of 4631
officials in the Department of Homeland Security used Signal groups on their personal phones to communicate, and that Justice Department attorneys failed to adequately preserve those materials.
GOVERNING EVIDENCE:
v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency
62
60.
This preservation concern is only exacerbated by the frequent personnel changes among those in the chain of command in these retribution cases. 611611. RETRIEVED EVIDENCE:
This preservation concern is only exacerbated by the frequent personnel changes among those in the chain of command in these retribution cases.
GOVERNING EVIDENCE:
......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional Many of those involved in different stages of Director Brennan'sinvestigations have left or are leaving government service, to include a number of DOJ line prosecutors and supervisors, former Attorney General Bondi, and DNI Tulsi Gabbard, the source of one of the "grand conspiracy" referrals. 612612. RETRIEVED EVIDENCE:
Many of those involved in different stages of Director Brennan'sinvestigations have left or are leaving government service, to include a number of DOJ line prosecutors and supervisors, former Attorney General Bondi, and DNI Tulsi Gabbard, the source of one of the "grand conspiracy" referrals.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave…Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel As these personnel depart and surrender their electronic devices, there is heightened risk that information will be lost and little reason for confidence that the necessary steps will be taken to preserve it. 613613. RETRIEVED EVIDENCE:
As these personnel depart and surrender their electronic devices, there is heightened risk that information will be lost and little reason for confidence that the necessary steps will be taken to preserve it.
GOVERNING EVIDENCE:
questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…work on these presidentially-driven investigations, certain Justice Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial…government officials are increasingly relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery See Letter Mot. 614614. RETRIEVED EVIDENCE:
See Letter Mot.
GOVERNING EVIDENCE:
originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi. 4 In that letter, Chairman Jordan, a close ally of President Trump, refers for investigation - without any valid…v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi…particular judge. That concern became so pronounced that undersigned counsel submitted a letter to the Chief Judge of the Southern District of Florida alerting her to the government's…Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had…s neutral and impartial processes. 11 37. Despite the concerns laid out in that letter, the Justice Department remains seemingly committed to its plan to steer any at 8, United States v. 615615. RETRIEVED EVIDENCE:
at 8, United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of McIver, No. 25-cr-388 (D.N.J. 616616. RETRIEVED EVIDENCE:
McIver, No. 25-cr-388 (D.N.J.
GOVERNING EVIDENCE:
13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the…production of the ICA. II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations 35. Justice…on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https…& Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News (Mar. 19 Dec. 23, 2025), Dkt. 618618. RETRIEVED EVIDENCE:
23, 2025), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed No. 57 ("[T]he senior official's government device had been wiped when he left government service ... months after the government had supposedly instituted a preservation hold.").
61. 619619. RETRIEVED EVIDENCE:
No. 57 ("[T]he senior official's government device had been wiped when he left government service ... months after the government had supposedly instituted a preservation hold.").
61.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington
This Administration has also demonstrated a willingness to defy record preservation laws and conventions as amatter of policy. 620620. RETRIEVED EVIDENCE:
This Administration has also demonstrated a willingness to defy record preservation laws and conventions as amatter of policy.
GOVERNING EVIDENCE:
QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice…Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel In April 2026, the Office of Legal Counsel (OLC) at the Justice Department issued an opinion that the PRA is unconstitutional,
63
which was followed the next day with amemorandum from White House Counsel David Warrington. 621621. RETRIEVED EVIDENCE:
In April 2026, the Office of Legal Counsel (OLC) at the Justice Department issued an opinion that the PRA is unconstitutional,
63
which was followed the next day with amemorandum from White House Counsel David Warrington.
GOVERNING EVIDENCE:
be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small…counterterrorism community that contributed to the failure to prevent the 9/11 terrorist attacks. 15. Following his retirement from the CIA in 2005, Director Brennan returned to government service in…of the CIA in a bipartisan 63-34 vote on March 7, 2013. He was sworn into office the following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff The Warrington
62
Reply at 3, 11-14, Am. 622622. RETRIEVED EVIDENCE:
The Warrington
62
Reply at 3, 11-14, Am.
GOVERNING EVIDENCE:
63 which was followed the next day with a memorandum from White House Counsel David Warrington. The Warrington 62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal…the grand jury proceeding that had produced the felony 64 Memorandum from David Alan Warrington, Assistant to the President and Counsel to the President, to Staff, Executive Office of the President (Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21 Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. 624624. RETRIEVED EVIDENCE:
Trump, No. 25-cv-3698 (N.D.
GOVERNING EVIDENCE:
officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L…election in an effort to boost candidate Donald Trump's chances of winning the election. In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that Cal. 625625. RETRIEVED EVIDENCE:
Cal.
GOVERNING EVIDENCE:
62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to…Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025), Dkt. No. 261. 70 Id. 71 An example of this practice can be seen
June 17, 2026), Dkt. 626626. RETRIEVED EVIDENCE:
June 17, 2026), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients' extensive use of disappearing Signal messages in disregard of their obligation to investigate, or they knowingly participated in the concealment.").
63
See Constitutionality of the Presidential Records Act, 50 Op. 627627. RETRIEVED EVIDENCE:
No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients' extensive use of disappearing Signal messages in disregard of their obligation to investigate, or they knowingly participated in the concealment.").
63
See Constitutionality of the Presidential Records Act, 50 Op.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in O.L.C. (Apr, 1, 2026) (slip op. 629629. RETRIEVED EVIDENCE:
(Apr, 1, 2026) (slip op.
GOVERNING EVIDENCE:
63 See Constitutionality of the Presidential Records Act, 50 Op. O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- at
1, 50),
https://perma.cc/V4M7-NQFA
; 630630. RETRIEVED EVIDENCE:
at
1, 50),
https://perma.cc/V4M7-NQFA
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury see generally Am. 631631. RETRIEVED EVIDENCE:
see generally Am.
GOVERNING EVIDENCE:
and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…of the John Brennan Investigation, CNN (May 8, 2026), https://perma.cc/S58G-9MTK . 13 See generally Appendix A. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 19 of 4616 A…lengthy discussion of the current investigations. He confirmed the existence, scope, and general 34 Daniel Klaidman & Sarah N. Lynch, Witnesses in Criminal Probe of Ex-CIA Director…manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26…57 See generally A Disappearing Data Hist. 632632. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 Ass'n v. 633633. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding Trump,
--- F. 634634. RETRIEVED EVIDENCE:
Trump,
--- F.
GOVERNING EVIDENCE:
Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L Supp. 635635. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d. 636636. RETRIEVED EVIDENCE:
3d.
GOVERNING EVIDENCE:
recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr…2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J ---, 2026 WL 1412395 (D.D.C. 637637. RETRIEVED EVIDENCE:
---, 2026 WL 1412395 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of May 20, 2026).
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 35 of 4632
memo
64
significantly limited the circumstances under which text communications need to be retained. 639639. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 35 of 4632
memo
64
significantly limited the circumstances under which text communications need to be retained.
GOVERNING EVIDENCE:
Would Require Access to Government Materials and Communications to Assess the…over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind…legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of…the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any…his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan
62.
Importantly, the concern about the preservation of records of value to Director Brennan is only heightened by the evidence that this Administration has shown itself willing to withhold records that cut against its interests. 641641. RETRIEVED EVIDENCE:
Importantly, the concern about the preservation of records of value to Director Brennan is only heightened by the evidence that this Administration has shown itself willing to withhold records that cut against its interests.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in For example, in the prosecution of Congresswoman LaMonica McIver for interfering with federal officers during afracas while conducting an oversight visit to an ICE facility, the prosecutors initially refused to provide any discovery. 642642. RETRIEVED EVIDENCE:
For example, in the prosecution of Congresswoman LaMonica McIver for interfering with federal officers during afracas while conducting an oversight visit to an ICE facility, the prosecutors initially refused to provide any discovery.
GOVERNING EVIDENCE:
13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective…to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation…s other perceived adversaries. 1 5. This effort has resulted in the opening of two federal investigations that purport to be investigating Director Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials…but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years
65
When compelled to do so by the court, it was revealed that significant important discovery material had been lost, including relevant messages on the phones of federal agents at the scene that had not been collected and information on asenior official's phone that had been wiped,
despite the existence of alitigation hold. 643643. RETRIEVED EVIDENCE:
65
When compelled to do so by the court, it was revealed that significant important discovery material had been lost, including relevant messages on the phones of federal agents at the scene that had not been collected and information on asenior official's phone that had been wiped,
despite the existence of alitigation hold.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes…of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to
66
In the criminal prosecution of protesters in United States v. 644644. RETRIEVED EVIDENCE:
66
In the criminal prosecution of protesters in United States v.
GOVERNING EVIDENCE:
Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the…Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent…or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and Rabbitt (known as the Broadview 6 case), federal prosecutors balked at the court's request to review the grand jury transcripts. 645645. RETRIEVED EVIDENCE:
Rabbitt (known as the Broadview 6 case), federal prosecutors balked at the court's request to review the grand jury transcripts.
GOVERNING EVIDENCE:
................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by…to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation…s other perceived adversaries. 1 5. This effort has resulted in the opening of two federal investigations that purport to be investigating Director Brennan for what amounts to…s alleged false statements to Congress. Then, over the weekend of April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former
67
At first, they provided only redacted versions, and when the judge insisted on the full transcripts, they even reduced the felony charges to misdemeanors in an attempt to moot out the grand jury proceeding that had produced the felony
64
Memorandum from David Alan Warrington, Assistant to the President and Counsel to the President, to Staff, Executive Office of the President (Apr. 646646. RETRIEVED EVIDENCE:
67
At first, they provided only redacted versions, and when the judge insisted on the full transcripts, they even reduced the felony charges to misdemeanors in an attempt to moot out the grand jury proceeding that had produced the felony
64
Memorandum from David Alan Warrington, Assistant to the President and Counsel to the President, to Staff, Executive Office of the President (Apr.
GOVERNING EVIDENCE:
Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in…s adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr…quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A 2, 2026),
https://perma.cc/R5G5
UAFW
("Warrington Memo"). See Mem. 647647. RETRIEVED EVIDENCE:
2, 2026),
https://perma.cc/R5G5
UAFW
("Warrington Memo"). See Mem.
GOVERNING EVIDENCE:
emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their…Contacts: It's Not Just About Obstruction, Lawfare (May 22, 2017), https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009), https://perma.cc/W55M-M7FW (Eric Holder 2009 memo). 20 Memorandum from the Attorney General to All Dep't Emps. (Feb. 5, 2025), https…to handle the resulting far-fetched investigation (see supra note 8); prosecution memoranda and other materials reflecting assessments about the strength of any potential cases…802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010…P.H.E., Inc., 965 F.2d 848, 850, 853, 858 (10th Cir. 1992) (district court reviewed prosecution memoranda and letter from U.S. Attorney to Attorney General to evaluate vindictive prosecution 3-4, Am. Hist. 649649. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 Ass'n v. 650650. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding Trump, No. 26-cv-1169
(D.D.C. Apr. 21, 2026), Dkt. 653653. RETRIEVED EVIDENCE:
21, 2026), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. 655655. RETRIEVED EVIDENCE:
A federal judge of this Court has since enjoined implementation of the OLC opinion, Am.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA…2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason Hist. 656656. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 Ass'n v. 657657. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding Trump,
--- F. 658658. RETRIEVED EVIDENCE:
Trump,
--- F.
GOVERNING EVIDENCE:
Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L Supp. 659659. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d. 660660. RETRIEVED EVIDENCE:
3d.
GOVERNING EVIDENCE:
recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr…2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J ---, 2026 WL 1412395, rejecting the government'sclaim that it did not need to preserve text messages (or other related messaging apps such as Signal and WhatsApp). 661661. RETRIEVED EVIDENCE:
---, 2026 WL 1412395, rejecting the government'sclaim that it did not need to preserve text messages (or other related messaging apps such as Signal and WhatsApp).
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i Am.
Hist. 663663. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 Ass'n v. 664664. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding Trump,
--- F. 665665. RETRIEVED EVIDENCE:
Trump,
--- F.
GOVERNING EVIDENCE:
Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L Supp. 666666. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d. 667667. RETRIEVED EVIDENCE:
3d.
GOVERNING EVIDENCE:
recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr…2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J ---, 2026 WL 1412395, at *7 & n.6. 668668. RETRIEVED EVIDENCE:
---, 2026 WL 1412395, at *7 & n.6.
GOVERNING EVIDENCE:
& [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of Just., Justice…2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010) (noting that the court did an in camera…documents" in assessing claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive…514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr. 20, 2021) (Contreras, J), and "[t]he government
65
Letter, United States v. 669669. RETRIEVED EVIDENCE:
65
Letter, United States v.
GOVERNING EVIDENCE:
originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi. 4 In that letter, Chairman Jordan, a close ally of President Trump, refers for investigation - without any valid…v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi…particular judge. That concern became so pronounced that undersigned counsel submitted a letter to the Chief Judge of the Southern District of Florida alerting her to the government's…Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had…s neutral and impartial processes. 11 37. Despite the concerns laid out in that letter, the Justice Department remains seemingly committed to its plan to steer any McIver, No. 25-cr-388 (D.N.J. 670670. RETRIEVED EVIDENCE:
McIver, No. 25-cr-388 (D.N.J.
GOVERNING EVIDENCE:
13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the…production of the ICA. II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations 35. Justice…on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https…& Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News (Mar. 19 Sep. 10, 2025), Dkt. 672672. RETRIEVED EVIDENCE:
10, 2025), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed No. 26-2
(government stating it would not provide any discovery). 673673. RETRIEVED EVIDENCE:
No. 26-2
(government stating it would not provide any discovery).
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF…filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i
66
Letter Mot. 674674. RETRIEVED EVIDENCE:
66
Letter Mot.
GOVERNING EVIDENCE:
originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi. 4 In that letter, Chairman Jordan, a close ally of President Trump, refers for investigation - without any valid…v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi…particular judge. That concern became so pronounced that undersigned counsel submitted a letter to the Chief Judge of the Southern District of Florida alerting her to the government's…Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had…s neutral and impartial processes. 11 37. Despite the concerns laid out in that letter, the Justice Department remains seemingly committed to its plan to steer any at 2-11, United States v. 675675. RETRIEVED EVIDENCE:
at 2-11, United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of McIver, No. 25-cr-388 (D.N.J. 676676. RETRIEVED EVIDENCE:
McIver, No. 25-cr-388 (D.N.J.
GOVERNING EVIDENCE:
13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the…production of the ICA. II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations 35. Justice…on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https…& Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News (Mar. 19 Dec. 23, 2025), Dkt. 678678. RETRIEVED EVIDENCE:
23, 2025), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed No.
57.
67
Hr'g Tr. at 20-24, United States v. 681681. RETRIEVED EVIDENCE:
at 20-24, United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of Rabbitt, No. 25-cr-693 (N.D. 682682. RETRIEVED EVIDENCE:
Rabbitt, No. 25-cr-693 (N.D.
GOVERNING EVIDENCE:
emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010) (noting that the court did an in camera review of "hundreds of…62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully…23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323…Summ. J. 15-16, Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025), Dkt. No. 261. 70 Id. 71 An example of this practice can be Ill. 683683. RETRIEVED EVIDENCE:
Ill.
GOVERNING EVIDENCE:
interviews and Presidential statements - President Trump has excoriated Director Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has…to adequately preserve those materials. 62 60. This preservation concern is only exacerbated by the frequent personnel changes among those in the chain of command in these…No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 May 21, 2026), Dkt. 684684. RETRIEVED EVIDENCE:
May 21, 2026), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed No.
187,
https://perma.cc/S55U-H2GJ
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 36 of 4633
charges. 685685. RETRIEVED EVIDENCE:
No.
187,
https://perma.cc/S55U-H2GJ
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 36 of 4633
charges.
GOVERNING EVIDENCE:
Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF…22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will…look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the…Director Brennan alleges as follows: Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 of 463 INTRODUCTION 1. Director Brennan is a former longtime public servant who…Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are When the judge finally received and reviewed unredacted copies of the transcripts, she observed, "Ihave never seen the types of prosecutorial behavior before agrand jury that Isaw in those transcripts."
68
In arecent civil case involving the mass termination of grants awarded by the National Endowment for the Humanities, the judge faulted the government for conducting an inadequate search for relevant documents, determined that the government had provided arecord that omitted clearly relevant materials, and therefore concluded that "the presumption of regularity gives way" in light of these irregularities. 686686. RETRIEVED EVIDENCE:
When the judge finally received and reviewed unredacted copies of the transcripts, she observed, "Ihave never seen the types of prosecutorial behavior before agrand jury that Isaw in those transcripts."
68
In arecent civil case involving the mass termination of grants awarded by the National Endowment for the Humanities, the judge faulted the government for conducting an inadequate search for relevant documents, determined that the government had provided arecord that omitted clearly relevant materials, and therefore concluded that "the presumption of regularity gives way" in light of these irregularities.
GOVERNING EVIDENCE:
There is a Serious Risk that Highly Relevant Internal Government Materials and…investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record preservation and…and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For…by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This…investigations, certain Justice Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial conduct. Those…and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw Authors Guild v. 687687. RETRIEVED EVIDENCE:
Authors Guild v.
GOVERNING EVIDENCE:
that "the presumption of regularity gives way" in light of these irregularities. Authors Guild v. Nat'l Endowment for the Humanities, 2025 WL 3678097, at *12 (S.D.N.Y. Dec. 18, 2025). Finally Nat'l Endowment for the Humanities, 2025 WL 3678097, at *12 (S.D.N.Y. 688688. RETRIEVED EVIDENCE:
Nat'l Endowment for the Humanities, 2025 WL 3678097, at *12 (S.D.N.Y.
GOVERNING EVIDENCE:
Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…production of the ICA. II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations 35. Justice…on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https…Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https://perma.cc/3UX5-XCMT (Appendix A). 12 Paula…27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News (Mar. 19, 2018), https…Jury Activity 48. While this frantic activity is ongoing, there continues to be an unprecedented amount of public discussion by DOJ officials detailing investigative activity that is Dec. 18, 2025). Finally, in arecent challenge to the termination of federal probationary employees, adistrict court found the administrative record was a "sham" that was "scattered with innumerable references to calls, discussions,
documents, and decisions that underpin, but have been excluded from, the government'snarrow record."
69
As the judge colorfully explained, the experience of reviewing the government's intentionally incomplete record was as though one were "being led, blindfolded, along acarefully plotted path through adense, unseen wood. 691691. RETRIEVED EVIDENCE:
Finally, in arecent challenge to the termination of federal probationary employees, adistrict court found the administrative record was a "sham" that was "scattered with innumerable references to calls, discussions,
documents, and decisions that underpin, but have been excluded from, the government'snarrow record."
69
As the judge colorfully explained, the experience of reviewing the government's intentionally incomplete record was as though one were "being led, blindfolded, along acarefully plotted path through adense, unseen wood.
GOVERNING EVIDENCE:
Strong Grounds for Challenging any Criminal Charges…of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by Here and there, he may hear arustle in the trees, feel the dark silhouette of a towering form, or intuit some other hint at the forest beyond,
but never is he afforded an unfettered view of the landscape through which he passes."
70
63. 692692. RETRIEVED EVIDENCE:
Here and there, he may hear arustle in the trees, feel the dark silhouette of a towering form, or intuit some other hint at the forest beyond,
but never is he afforded an unfettered view of the landscape through which he passes."
70
63.
GOVERNING EVIDENCE:
and the court hears them. This…wrongdoing by the Trump administration." Devlin Barrett, Justice Dept. Watchdog Has Gone Silent, Lawyers for Whistle-Blower Say, N.Y. Times (Mar. 30, 2026), https…along a carefully plotted path through a dense, unseen wood. Here and there, he may hear a rustle in the trees, feel the dark silhouette of a towering form, or intuit some other hint at the forest beyond, but never is he afforded an unfettered view of the landscape…that will require access to the government's internal materials and communications at a hearing on a vindictive prosecution motion. The vast majority of defendants cannot show such…that the government will be obligated to produce those records at a post-indictment hearing. As such, they will be unable to establish a pre-indictment right to judicial…records until such time as they are required for production and review in a pre-trial hearing about whether the government acted vindictively and selectively in charging Director
Given that record of obfuscation
71
and disregard of record preservation requirements, it is difficult to have confidence that Justice Department officials will retain the internal records that
68
Id. 693693. RETRIEVED EVIDENCE:
Given that record of obfuscation
71
and disregard of record preservation requirements, it is difficult to have confidence that Justice Department officials will retain the internal records that
68
Id.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC…challenge, the court presiding over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida
69
Order on Cross-Mots. 694694. RETRIEVED EVIDENCE:
69
Order on Cross-Mots.
GOVERNING EVIDENCE:
1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve…foundation of these "criminal referrals." 3 Hannah Rabinowitz, Attorney General Bondi Orders Prosecutors to Start Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug…decision-making. In recent comments defending the President's September 20, 2025, order to then-Attorney General Bondi to prosecute three of 18 Donald J. Trump…various mechanisms for investigating or sanctioning official DOJ misconduct. It has been methodically removing or silencing those career civil servants who are responsible for internally…involving Director Brennan - who might be tempted to follow President Trump's orders without regard to legal or ethical limitations. And 18 (D.D.C. 2023) (providing…related to the DOJ's recusal of the three principal Detroit U.S. Attorneys" and ordered that evidence turned over to defendant); United States v. P.H.E., Inc., 965 F.2d 848 for Summ. 695695. RETRIEVED EVIDENCE:
for Summ.
GOVERNING EVIDENCE:
officials will retain the internal records that 68 Id. 69 Order on Cross-Mots. for Summ. J. 15-16, Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D J. 15-16, Am. Fed. 698698. RETRIEVED EVIDENCE:
Fed.
GOVERNING EVIDENCE:
Against Federal Government Attorneys (May 13, 2026), https://perma.cc/CXC6-RMUH . 44 91 Fed. Reg. 10780 (Mar. 5, 2026) (codified at 28 C.F.R. pt. 77). 45 Id. 46 These…50 See supra note 2. 51 Memorandum from William Fischer, Chief Records Officer, to Fed. Records Mgmt. Contacts (May 2, 2025), https://perma.cc/TAB5-E2ZX . 52 Bernd…from White House Counsel David Warrington. The Warrington 62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt…retain the internal records that 68 Id. 69 Order on Cross-Mots. for Summ. J. 15-16, Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025 Of Gov. Emps. 700700. RETRIEVED EVIDENCE:
Emps.
GOVERNING EVIDENCE:
Eric Holder 2009 memo). 20 Memorandum from the Attorney General to All Dep't Emps. (Feb. 5, 2025), https://perma.cc/3PPL-BWER . 21 In-Your-Face DOJ Aide Rides…Counsel David Warrington. The Warrington 62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3…that 68 Id. 69 Order on Cross-Mots. for Summ. J. 15-16, Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025), Dkt v. U.S. Off. 702702. RETRIEVED EVIDENCE:
U.S. Off.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of of Personnel Mgmt., No. 25-cv-1780 (N.D. 703703. RETRIEVED EVIDENCE:
of Personnel Mgmt., No. 25-cv-1780 (N.D.
GOVERNING EVIDENCE:
Personnel…apply to only a small subset of officials, and the vast majority of Justice Department personnel are maintaining adherence to professional standards and carrying out their duties in the…of the Justice Department. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 8 of 465 personnel who had worked on the ICA, requiring them to testify before the grand jury in the…a federal agency responsible for enforcing federal criminal laws. It includes government personnel and record systems that would have the records to be preserved under the requested…served as the Director of the FBI since February 20, 2025. He supervises FBI agents and other personnel who are working on the Brennan investigations. In that role, he has responsibility over…13 of 4610 24. Defendant Executive Office of the President provides operational and management support to the President. It includes government personnel and record systems that would have the records to be preserved under the requested Cal. 704704. RETRIEVED EVIDENCE:
Cal.
GOVERNING EVIDENCE:
62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to…Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025), Dkt. No. 261. 70 Id. 71 An example of this practice can be seen Sep. 12, 2025), Dkt. 706706. RETRIEVED EVIDENCE:
12, 2025), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed No. 261.
70
Id.
71
An example of this practice can be seen in the recent release of the Epstein files, where the Justice Department was less than transparent in redacting passages that were inconvenient for President Trump, Nik Popli, Trump Administration Removes Some Redactions from Epstein Files After Outcry from Lawyers, Time (Feb. 709709. RETRIEVED EVIDENCE:
71
An example of this practice can be seen in the recent release of the Epstein files, where the Justice Department was less than transparent in redacting passages that were inconvenient for President Trump, Nik Popli, Trump Administration Removes Some Redactions from Epstein Files After Outcry from Lawyers, Time (Feb.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1…as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying before…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 9, 2026),
https://perma.cc/ZGW3-H6ZK
("Among the material Raskin said he encountered was a redacted passage summarizing comments Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 37 of 4634
will be central to Director Brennan'seffort to defend his constitutional rights in the absence of judicial intervention. 710710. RETRIEVED EVIDENCE:
9, 2026),
https://perma.cc/ZGW3-H6ZK
("Among the material Raskin said he encountered was a redacted passage summarizing comments Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 37 of 4634
will be central to Director Brennan'seffort to defend his constitutional rights in the absence of judicial intervention.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis…of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…s adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr
VII. 711711. RETRIEVED EVIDENCE:
VII.
GOVERNING EVIDENCE:
26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials…s effort to defend his constitutional rights in the absence of judicial intervention. VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and
Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights
64. 712712. RETRIEVED EVIDENCE:
Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights
64.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights
Based on the foregoing, Director Brennan and this Court cannot rely on the government'sadherence to its standard discovery obligations to ensure he will have the ability to protect his constitutional rights. 713713. RETRIEVED EVIDENCE:
Based on the foregoing, Director Brennan and this Court cannot rely on the government'sadherence to its standard discovery obligations to ensure he will have the ability to protect his constitutional rights.
GOVERNING EVIDENCE:
JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights That is abundantly clear from salient points about the government's conduct that clearly come through in the foregoing factual discussion - the Justice Department's consistent pattern of irregular conduct in this and other retribution cases; 714714. RETRIEVED EVIDENCE:
That is abundantly clear from salient points about the government's conduct that clearly come through in the foregoing factual discussion - the Justice Department's consistent pattern of irregular conduct in this and other retribution cases;
GOVERNING EVIDENCE:
Personnel from Accountability for Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…that purport to be investigating Director Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials…to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small…investigations, certain Justice Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial conduct. Those overreaching actions have violated Director Brennan's constitutional rights and the repeated flouting of its discovery obligations; 715715. RETRIEVED EVIDENCE:
the repeated flouting of its discovery obligations;
GOVERNING EVIDENCE:
obligations…preserved, even though they should be, pursuant to the government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete…as a remedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not…will be directly due to the government's action - or inaction - in regard to its preservation obligations, and the injury will be directly redressed by a judicial injunction ordering the…Altonaga lays out many of the government's irregular actions up to that time. To avoid repeating their details here, that letter is incorporated by reference and included as Appendix A…that must be preserved. 55. The government has ongoing statutory and constitutional obligations to preserve evidence and records of the type that will be relevant to Director Brennan's and the widespread disregard for the preservation requirements for government records. 716716. RETRIEVED EVIDENCE:
and the widespread disregard for the preservation requirements for government records.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i Under these circumstances, Director Brennan is entitled to injunctive relief,
as there is every reason to believe that he will be limited in his ability to protect his constitutional rights without an injunction directing the government to preserve those records. 717717. RETRIEVED EVIDENCE:
Under these circumstances, Director Brennan is entitled to injunctive relief,
as there is every reason to believe that he will be limited in his ability to protect his constitutional rights without an injunction directing the government to preserve those records.
GOVERNING EVIDENCE:
capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in
65.
For the same reasons Director Brennan is entitled to injunctive relief, he is equally and alternatively entitled to awrit of mandamus compelling the government to preserve those records to permit the defense of his constitutional rights. 719719. RETRIEVED EVIDENCE:
For the same reasons Director Brennan is entitled to injunctive relief, he is equally and alternatively entitled to awrit of mandamus compelling the government to preserve those records to permit the defense of his constitutional rights.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full Director Brennan therefore alternatively requests that the Court issue awrit of mandamus compelling the government to preserve the records enumerated below. 720720. RETRIEVED EVIDENCE:
Director Brennan therefore alternatively requests that the Court issue awrit of mandamus compelling the government to preserve the records enumerated below.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights
attributed to President Trump by Epstein's lawyers that contradicted Trump's public claims that he had expelled Epstein from his Mar-a-Lago club in Florida."); 721721. RETRIEVED EVIDENCE:
attributed to President Trump by Epstein's lawyers that contradicted Trump's public claims that he had expelled Epstein from his Mar-a-Lago club in Florida.");
GOVERNING EVIDENCE:
for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A Rep. Davis Min, U.S. House of Representatives, Rep. 723723. RETRIEVED EVIDENCE:
Davis Min, U.S. House of Representatives, Rep.
GOVERNING EVIDENCE:
to representatives of the government under the "presumption of regularity." Traditionally, "in the absence of clear evidence to the contrary, courts presume that [government representatives] have…public claims that he had expelled Epstein from his Mar-a-Lago club in Florida."); Rep. Davis Min, U.S. House of Representatives, Rep. Dave Min on CNN 02/10/2026, at 4:49-6:04 (YouTube, Feb. 10, 2026) (clip of CNN television broadcast, aired Feb. 10, 2026, at 07:40 ET), https://min.house.gov/media/press-releases/watch-rep-min-cnn-all-reeks-cover-right-now-and we-need-release-entire-epstein ( https…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of…Department personnel or with any persons outside of the Justice Department, including representatives or staff of the White House and of Congress; e) All records of communications, public Dave Min on CNN 02/10/2026, at 4:49-6:04 (YouTube, Feb. 724724. RETRIEVED EVIDENCE:
Dave Min on CNN 02/10/2026, at 4:49-6:04 (YouTube, Feb.
GOVERNING EVIDENCE:
against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama Administration…XTZQ ; LA Times Studios, Straight to the Point: The Grand Conspiracy Against Trump (YouTube, May 7, 2026), https://www.youtube.com/watch?v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from…her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna 10, 2026)
(clip of CNN television broadcast, aired Feb. 725725. RETRIEVED EVIDENCE:
10, 2026)
(clip of CNN television broadcast, aired Feb.
GOVERNING EVIDENCE:
Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama Administration…her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https…Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean…Plaintiff). The accusations in the interview were so pointed and unsupported that Fox News felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean…Trump Accidentally Posted Message Pressuring Pam Bondi to Charge his Enemies, Source Says, NBC News (Oct. 10, 2025), https://perma.cc/LX38 A439 . 23 Laura Jarrett & Ryan J. Reilly, Todd Blanche 10, 2026, at 07:40 ET),
https://min.house.gov/media/press-releases/watch-rep-min-cnn-all-reeks-cover-right-now-and we-need-release-entire-epstein
(
https://perma.cc/4SNG-HK2Bon file with Plaintiff), and in withholding documents that alleged wrongdoing by him, Stephen Fowler, Justice Department Withheld and Removed Some Epstein Files Related to Trump, NPR (Feb. 726726. RETRIEVED EVIDENCE:
10, 2026, at 07:40 ET),
https://min.house.gov/media/press-releases/watch-rep-min-cnn-all-reeks-cover-right-now-and we-need-release-entire-epstein
(
https://perma.cc/4SNG-HK2Bon file with Plaintiff), and in withholding documents that alleged wrongdoing by him, Stephen Fowler, Justice Department Withheld and Removed Some Epstein Files Related to Trump, NPR (Feb.
GOVERNING EVIDENCE:
documents relating to the supposed "grand conspiracy" and the other relating to Director Brennan's alleged false statements to Congress. Then, over the weekend of April 18, 2026, a federal grand…as the basis for challenges to any resulting charges, including motions to dismiss any indictment on the grounds that it is the result of selective and vindictive prosecution. 8. To…activity from probing judicial scrutiny. 9. To perform that scrutiny after an indictment, the Court would demand access to a wide range of the government's communications and…General since April 20, 2026. He has been assigned to lead the investigations into the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress. In that role, he has responsibility over subordinates and…in the District of Columbia opened an investigation and issued subpoenas in relation to the allegation that Director Brennan made false statements to Congress. The government prosecutors have informed 24, 2026),
https://perma.cc/9BZ2-9ZAU
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 38 of 4635
COUNT 1
Equitable Action to Enjoin Unconstitutional Conduct
66. 727727. RETRIEVED EVIDENCE:
24, 2026),
https://perma.cc/9BZ2-9ZAU
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 38 of 4635
COUNT 1
Equitable Action to Enjoin Unconstitutional Conduct
66.
GOVERNING EVIDENCE:
action asking the Court to enjoin the government to preserve any and…D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026…Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 38 of 4635 COUNT 1 Equitable Action to Enjoin Unconstitutional Conduct 66. Director Brennan re-alleges and incorporates by reference paragraphs…1 through 65. Based on the foregoing, Director Brennan requests that this Court enjoin Defendants to preserve all records enumerated below in the Request for Relief until such…v. Exceptional Child Ctr., Inc., 575 U.S. 320, 327 (2015) ("The ability to sue to enjoin unconstitutional actions by state and federal officers is the creation of courts of…England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding plaintiffs likely had an equitable cause of action under Armstrong to require that White House officials preserve records
Director Brennan re-alleges and incorporates by reference paragraphs 1 through 65. 728728. RETRIEVED EVIDENCE:
Director Brennan re-alleges and incorporates by reference paragraphs 1 through 65.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in
Based on the foregoing, Director Brennan requests that this Court enjoin Defendants to preserve all records enumerated below in the Request for Relief until such time as the Court releases the injunction upon its determination that those records will no longer be needed for the protection of Director Brennan'sconstitutional rights in the criminal justice system. 729729. RETRIEVED EVIDENCE:
Based on the foregoing, Director Brennan requests that this Court enjoin Defendants to preserve all records enumerated below in the Request for Relief until such time as the Court releases the injunction upon its determination that those records will no longer be needed for the protection of Director Brennan'sconstitutional rights in the criminal justice system.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights
67.
It is well established that the courts have the inherent authority to provide injunctive relief in asituation where the government is taking action that may violate an individual'sconstitutional rights. 731731. RETRIEVED EVIDENCE:
It is well established that the courts have the inherent authority to provide injunctive relief in asituation where the government is taking action that may violate an individual'sconstitutional rights.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under…subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason See Armstrong v. Exceptional Child Ctr., Inc., 575 U.S. 320, 327 (2015)
("The ability to sue to enjoin unconstitutional actions by state and federal officers is the creation of courts of equity, and reflects a long history of judicial review of illegal executive action,
tracing back to England."); 733733. RETRIEVED EVIDENCE:
Exceptional Child Ctr., Inc., 575 U.S. 320, 327 (2015)
("The ability to sue to enjoin unconstitutional actions by state and federal officers is the creation of courts of equity, and reflects a long history of judicial review of illegal executive action,
tracing back to England.");
GOVERNING EVIDENCE:
Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell…that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes government personnel and record systems that would have the…that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 22. Defendant Kash P. Patel has served as the Director of…that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 23. Defendant Donald J. Trump has served as the President…that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 13 of 4610 24 Am. Hist. 735735. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 Ass'n v. 736736. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding Trump, 2026 WL 1412395, at *13 (finding plaintiffs likely had an equitable cause of action under Armstrong to require that White House officials preserve records pursuant to the PRA). 737737. RETRIEVED EVIDENCE:
Trump, 2026 WL 1412395, at *13 (finding plaintiffs likely had an equitable cause of action under Armstrong to require that White House officials preserve records pursuant to the PRA).
GOVERNING EVIDENCE:
Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes
68.
A plaintiff seeking a permanent injunction must demonstrate aright to relief from a current or impending violation of his rights and aclear governmental duty to act to remedy that violation. 739739. RETRIEVED EVIDENCE:
A plaintiff seeking a permanent injunction must demonstrate aright to relief from a current or impending violation of his rights and aclear governmental duty to act to remedy that violation.
GOVERNING EVIDENCE:
THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950…by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…personnel are maintaining adherence to professional standards and carrying out their duties in the best tradition of the Justice Department. Case 1:26-cv-02323 Document 1 Filed…investigations, certain Justice Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial conduct. Those overreaching actions have violated Director Brennan's constitutional rights and will serve as the basis for challenges to In addition, a plaintiff must demonstrate four factors: 740740. RETRIEVED EVIDENCE:
In addition, a plaintiff must demonstrate four factors:
GOVERNING EVIDENCE:
under seal, Plaintiff v. TODD W. BLANCHE…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in…III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct by the (1) that the plaintiff has suffered or is likely to suffer an irreparable harm without an injunction; 741741. RETRIEVED EVIDENCE:
(1) that the plaintiff has suffered or is likely to suffer an irreparable harm without an injunction;
GOVERNING EVIDENCE:
following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in…of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct by the defendant or defendants, and a likelihood that the injury will be redressed by a favorable decision. Lujan, 504 U.S. at 560-61. Here, Director Brennan meets those three requirements. The injury is the very real prospect that the government will fail to (2) that remedies available at law,
such as monetary damages, are inadequate; 742742. RETRIEVED EVIDENCE:
(2) that remedies available at law,
such as monetary damages, are inadequate;
GOVERNING EVIDENCE:
REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel (3) that the balance of the equities between the plaintiff and defendant favor an injunction; 743743. RETRIEVED EVIDENCE:
(3) that the balance of the equities between the plaintiff and defendant favor an injunction;
GOVERNING EVIDENCE:
under seal, Plaintiff v. TODD W…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws and (4) that the public interest would not be
"disserved by a permanent injunction." Anatol Zukerman & Charles Krause Reporting, LLC v. 744744. RETRIEVED EVIDENCE:
and (4) that the public interest would not be
"disserved by a permanent injunction." Anatol Zukerman & Charles Krause Reporting, LLC v.
GOVERNING EVIDENCE:
...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity .......…a former longtime public servant who provided more than 33 years of nonpartisan government service working for six administrations - three Republican and three Democratic - in a wide…his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his…Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand…he resides in the Commonwealth of Virginia. 14. Director Brennan's federal government service, which began in August 1980, spanned six Administrations-three Republican and three…15. Following his retirement from the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President
USPS, 64 F.4th 1354, 1363 (D.C. 745745. RETRIEVED EVIDENCE:
USPS, 64 F.4th 1354, 1363 (D.C.
GOVERNING EVIDENCE:
JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…a former longtime public servant who provided more than 33 years of nonpartisan government service working for six administrations - three Republican and three Democratic - in a wide…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia. 14. Director Brennan's federal government service, which began in August 1980, spanned six Cir. 2023) (quoting eBay, Inc. v. 747747. RETRIEVED EVIDENCE:
2023) (quoting eBay, Inc. v.
GOVERNING EVIDENCE:
& Charles Krause Reporting, LLC v. USPS, 64 F.4th 1354, 1363 (D.C. Cir. 2023) (quoting eBay, Inc. v. MercExchange, L.L.C., 547 U.S. 388, 391 (2006)); Nat'l Pub. Radio, Inc.…public interest.'" (first quotation marks omitted, remaining quotation marks ultimately quoting Gordon v. Holder, 721 F.3d 638, 653 (D.C. Cir. 2013))). 72 70. For these reasons MercExchange, L.L.C., 547
U.S. 388, 391 (2006)); 748748. RETRIEVED EVIDENCE:
MercExchange, L.L.C., 547
U.S. 388, 391 (2006));
GOVERNING EVIDENCE:
Krause Reporting, LLC v. USPS, 64 F.4th 1354, 1363 (D.C. Cir. 2023) (quoting eBay, Inc. v. MercExchange, L.L.C., 547 U.S. 388, 391 (2006)); Nat'l Pub. Radio, Inc. v. Trump, 2026 WL 877434…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of Nat'l Pub. 749749. RETRIEVED EVIDENCE:
Nat'l Pub.
GOVERNING EVIDENCE:
20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub. L. No. 113-187, 10, 128 Stat. 2003, 2014-15); see also United States v. Navarro…10, 2018), https://perma.cc/3A7S-6HZY . 57 See generally A Disappearing Data Chronology, Nat'l Sec. Archive, https://perma.cc/55SN 66EV (last visited June 5, 2026) (collecting…presumption of regularity gives way" in light of these irregularities. Authors Guild v. Nat'l Endowment for the Humanities, 2025 WL 3678097, at *12 (S.D.N.Y. Dec. 18, 2025…D.C. Cir. 2023) (quoting eBay, Inc. v. MercExchange, L.L.C., 547 U.S. 388, 391 (2006)); Nat'l Pub. Radio, Inc. v. Trump, 2026 WL 877434, at *28 (D.D.C. Mar. Case 1:26-cv-02323…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to Radio, Inc. v. Trump, 2026 WL 877434, at *28 (D.D.C. Mar.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 39 of 4636
31, 2026) (Moss, J.) ("Entry of a permanent injunction is appropriate here because Plaintiffs are likely to suffer irreparable harm-'retaliation against them in response to their exercise of their First Amendment rights'-in the absence of injunctive relief."); 753753. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 39 of 4636
31, 2026) (Moss, J.) ("Entry of a permanent injunction is appropriate here because Plaintiffs are likely to suffer irreparable harm-'retaliation against them in response to their exercise of their First Amendment rights'-in the absence of injunctive relief.");
GOVERNING EVIDENCE:
26 VII. Injunctive Relief is Necessary to Ensure Preservation of…such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are increasingly…to President George H.W. Bush and senior Administration officials in the run-up to the First Gulf War (1990-91); daily intelligence briefer for President Bill Clinton and Vice…manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to position the CIA to deal more effectively with the…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a…record systems that would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the see generally League of United Latin Am. 754754. RETRIEVED EVIDENCE:
see generally League of United Latin Am.
GOVERNING EVIDENCE:
of regularity" that generally insulates most government…lengthy discussion of the current investigations. He confirmed the existence, scope, and general 34 Daniel Klaidman & Sarah N. Lynch, Witnesses in Criminal Probe of Ex-CIA Director…manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26…Trump's Papers Back Together, Politico (June 10, 2018), https://perma.cc/3A7S-6HZY . 57 See generally A Disappearing Data Chronology, Nat'l Sec. Archive, https://perma.cc/55SN 66EV (last…Act, 50 Op. O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20…other retribution cases; the repeated flouting of its discovery obligations; and the widespread disregard for the preservation requirements for government records. Under these Citizens v. 755755. RETRIEVED EVIDENCE:
Citizens v.
GOVERNING EVIDENCE:
-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026 Exec. 756756. RETRIEVED EVIDENCE:
Exec.
GOVERNING EVIDENCE:
the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026) (Kollar-Kotelly, J. Off. of the President, 818 F. 758758. RETRIEVED EVIDENCE:
of the President, 818 F.
GOVERNING EVIDENCE:
26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…to retaliate against and pressure the President's political and personal adversaries Supp. 759759. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d 34, 74-75 (D.D.C. 760760. RETRIEVED EVIDENCE:
3d 34, 74-75 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of 2026)
(Kollar-Kotelly, J.).
69. 761761. RETRIEVED EVIDENCE:
2026)
(Kollar-Kotelly, J.).
69.
GOVERNING EVIDENCE:
Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026) (Kollar-Kotelly, J.). 69. Director Brennan meets the elements to be entitled to injunctive relief. He will
Director Brennan meets the elements to be entitled to injunctive relief. 762762. RETRIEVED EVIDENCE:
Director Brennan meets the elements to be entitled to injunctive relief.
GOVERNING EVIDENCE:
L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…38 REQUEST FOR RELIEF…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in He will prevail on the merits because there is aclear factual predicate that his constitutional rights are being jeopardized by the government'sfailure to uphold its duty to preserve records. 763763. RETRIEVED EVIDENCE:
He will prevail on the merits because there is aclear factual predicate that his constitutional rights are being jeopardized by the government'sfailure to uphold its duty to preserve records.
GOVERNING EVIDENCE:
Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights ...........................................................................................…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and And he will suffer irreparable harm to his constitutional rights in the absence of injunctive relief, given the government'sdemonstrated inability and/or unwillingness to preserve relevant records and the centrality of those records to his constitutional challenge to an eventual indictment. 764764. RETRIEVED EVIDENCE:
And he will suffer irreparable harm to his constitutional rights in the absence of injunctive relief, given the government'sdemonstrated inability and/or unwillingness to preserve relevant records and the centrality of those records to his constitutional challenge to an eventual indictment.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved See supra
54-63. 765765. RETRIEVED EVIDENCE:
See supra
54-63.
GOVERNING EVIDENCE:
5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA…Sources Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority…Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ There are no other remedies at law that can redress that harm, given that pre-trial sanctions are inadequate because the court may never know that the unpreserved communications ever existed in the first place. 766766. RETRIEVED EVIDENCE:
There are no other remedies at law that can redress that harm, given that pre-trial sanctions are inadequate because the court may never know that the unpreserved communications ever existed in the first place.
GOVERNING EVIDENCE:
Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that…over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record preservation and…the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any…first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Next, the balance of equities tips strongly in favor of Director Brennan'sinterest in vindicating his constitutional rights over any claimed governmental interest in failing to satisfy well-established federal record preservation and discovery requirements. 767767. RETRIEVED EVIDENCE:
Next, the balance of equities tips strongly in favor of Director Brennan'sinterest in vindicating his constitutional rights over any claimed governmental interest in failing to satisfy well-established federal record preservation and discovery requirements.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in And finally, the requested injunction is squarely in the public interest, as
"it is always in the public interest to prevent the violation of aparty'sconstitutional rights."
Gayle v. 768768. RETRIEVED EVIDENCE:
And finally, the requested injunction is squarely in the public interest, as
"it is always in the public interest to prevent the violation of aparty'sconstitutional rights."
Gayle v.
GOVERNING EVIDENCE:
20 D. Justice Department Officials Publicly Discuss Grand Jury Activity .......…his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his…Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand…the false-statements investigation. Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 7. In their work on these presidentially-driven…oversaw, or undertook those actions to determine whether they violated Director Brennan's rights, and specifically whether they were motivated by a desire to vindictively prosecute him…1 Filed 07/01/26 Page 10 of 467 the consideration of Director Brennan's legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the Meade, 614 F. 769769. RETRIEVED EVIDENCE:
Meade, 614 F.
GOVERNING EVIDENCE:
the public interest to prevent the violation of a party's constitutional rights." Gayle v. Meade, 614 F. Supp. 3d 1175, 1206 (S.D. Fla. 2020) (internal quotation marks omitted Supp. 770770. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d 1175, 1206 (S.D. 771771. RETRIEVED EVIDENCE:
3d 1175, 1206 (S.D.
GOVERNING EVIDENCE:
Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https://perma.cc/3UX5-XCMT (Appendix A). 12 Paula…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr Fla. 772772. RETRIEVED EVIDENCE:
Fla.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia…Attorney for the Southern District of Florida since August 13, 2025. In 2020) (internal quotation marks omitted); 773773. RETRIEVED EVIDENCE:
2020) (internal quotation marks omitted);
GOVERNING EVIDENCE:
is a Serious Risk that Highly Relevant Internal Government Materials and Communications…decisions. A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were…These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not…district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events or omissions" has occurred or is occurring in the District of Columbia. A grand jury in the District…methodically removing or silencing those career civil servants who are responsible for internally enforcing ethics, with Attorney General Bondi firing the head of the Office of…//perma.cc/79WB-488R . 41 These firings have apparently had their intended effect on the internal watchdog workforce, as evidenced by recent reports that the Department of Justice Office
see Honeyfund.com Inc. v. 774774. RETRIEVED EVIDENCE:
see Honeyfund.com Inc. v.
GOVERNING EVIDENCE:
614 F. Supp. 3d 1175, 1206 (S.D. Fla. 2020) (internal quotation marks omitted); see Honeyfund.com Inc. v. Governor of Florida, 94 F.4th 1272, 1283 (11th Cir. 2024) ("[A Governor of Florida, 94 F.4th 1272, 1283 (11th Cir. 775775. RETRIEVED EVIDENCE:
Governor of Florida, 94 F.4th 1272, 1283 (11th Cir.
GOVERNING EVIDENCE:
for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia 2024) ("[A]
preliminary injunction is not contrary to the public interest because it is in the public interest to protect First Amendment rights."); 776776. RETRIEVED EVIDENCE:
2024) ("[A]
preliminary injunction is not contrary to the public interest because it is in the public interest to protect First Amendment rights.");
GOVERNING EVIDENCE:
D. Justice Department Officials Publicly Discuss Grand Jury Activity…his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the United States Department…of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written…to be investigating Director Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand…oversaw, or undertook those actions to determine whether they violated Director Brennan's rights, and specifically whether they were motivated by a desire to vindictively prosecute him…such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are increasingly A.B.A. 777777. RETRIEVED EVIDENCE:
A.B.A.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC v. DOJ, 783 F. 779779. RETRIEVED EVIDENCE:
DOJ, 783 F.
GOVERNING EVIDENCE:
system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan…for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN …July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Investigation into Russiagate Conspiracy Allegations: Sources, Fox…Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Supp. 780780. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d 236, 247-48 (D.D.C. 781781. RETRIEVED EVIDENCE:
3d 236, 247-48 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of 2025)
(Cooper, J.) ("Government actions in contravention of the Constitution are 'always contrary to Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 40 of 4637
the public interest.'" (first quotation marks omitted, remaining quotation marks ultimately quoting Gordon v. 782782. RETRIEVED EVIDENCE:
2025)
(Cooper, J.) ("Government actions in contravention of the Constitution are 'always contrary to Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 40 of 4637
the public interest.'" (first quotation marks omitted, remaining quotation marks ultimately quoting Gordon v.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Holder, 721 F.3d 638, 653 (D.C. 783783. RETRIEVED EVIDENCE:
Holder, 721 F.3d 638, 653 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates…plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in this district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events or omissions Cir. 2013))).
72
70.
For these reasons, Director Brennan is entitled to injunctive relief to require the government to preserve any and all materials and communications that are potentially relevant to the consideration of Director Brennan'sconstitutional challenges to any future criminal charges. 786786. RETRIEVED EVIDENCE:
For these reasons, Director Brennan is entitled to injunctive relief to require the government to preserve any and all materials and communications that are potentially relevant to the consideration of Director Brennan'sconstitutional challenges to any future criminal charges.
GOVERNING EVIDENCE:
Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in
COUNT 2
Writ of Mandamus Under The Mandamus Act (28 U.S.C. 787787. RETRIEVED EVIDENCE:
COUNT 2
Writ of Mandamus Under The Mandamus Act (28 U.S.C.
GOVERNING EVIDENCE:
1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1 ..................................................................................................................................... 35 COUNT 2 ..................................................................................................................................... 37 COUNT 3…grants original jurisdiction to the district courts over "any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a…Brennan is entitled to injunctive relief, he is equally and alternatively entitled to a writ of mandamus compelling the government to preserve those records to permit the defense of his…rights. Director Brennan therefore alternatively requests that the Court issue a writ of mandamus compelling the government to preserve the records enumerated below. attributed to 1361) And The All Writs Act
(28 U.S.C. 788788. RETRIEVED EVIDENCE:
1361) And The All Writs Act
(28 U.S.C.
GOVERNING EVIDENCE:
rights. Director Brennan therefore alternatively requests that the Court issue a writ of mandamus compelling the government to preserve the records enumerated below…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…Director Brennan's constitutional challenges to any future criminal charges. COUNT 2 Writ of Mandamus Under The Mandamus Act (28 U.S.C. 1361) And The All Writs Act (28 U.S.C. 1651) To Protect Director Brennan's Constitutional Rights 71…Based on the foregoing, Director Brennan requests, in the alternative, that this Court issue a writ of mandamus ordering the Defendants to preserve all records enumerated below in the…985 F.3d 893, 910 (D.C. Cir. 2021) (citation modified). To be entitled to a writ of mandamus under the All Writs Act, this Court must find: "(1) the petitioner has no other adequate means of 1651) To Protect Director Brennan's Constitutional Rights
71. 789789. RETRIEVED EVIDENCE:
1651) To Protect Director Brennan's Constitutional Rights
71.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in
Director Brennan re-alleges and incorporates by reference paragraphs 1 through 70. 790790. RETRIEVED EVIDENCE:
Director Brennan re-alleges and incorporates by reference paragraphs 1 through 70.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in
Based on the foregoing, Director Brennan requests, in the alternative, that this Court issue awrit of mandamus ordering the Defendants to preserve all records enumerated below in the Request for Relief. 791791. RETRIEVED EVIDENCE:
Based on the foregoing, Director Brennan requests, in the alternative, that this Court issue awrit of mandamus ordering the Defendants to preserve all records enumerated below in the Request for Relief.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights
72.
The Mandamus Act, 28 U.S.C. 793793. RETRIEVED EVIDENCE:
The Mandamus Act, 28 U.S.C.
GOVERNING EVIDENCE:
is entitled to injunctive relief, he is equally and alternatively entitled to a writ of mandamus compelling the government to preserve those records to permit the defense of his…rights. Director Brennan therefore alternatively requests that the Court issue a writ of mandamus compelling the government to preserve the records enumerated below. attributed to…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…Brennan's constitutional challenges to any future criminal charges. COUNT 2 Writ of Mandamus Under The Mandamus Act (28 U.S.C. 1361) And The All Writs Act (28 U.S.C. 1651) To Protect Director…writ of mandamus ordering the Defendants to preserve all records enumerated below in the Request for Relief. 72. The Mandamus Act, 28 U.S.C. 1361, vests this Court with original jurisdiction over "any action in the nature of mandamus to 1361, vests this Court with original jurisdiction over
"any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform aduty owed to the plaintiff" - which, in this case, is the duty the government owes to Director Brennan to preserve (and ultimately produce) all materials and communications that may be relevant to his challenges to an eventual indictment. 794794. RETRIEVED EVIDENCE:
1361, vests this Court with original jurisdiction over
"any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform aduty owed to the plaintiff" - which, in this case, is the duty the government owes to Director Brennan to preserve (and ultimately produce) all materials and communications that may be relevant to his challenges to an eventual indictment.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason Under the Mandamus Act, "a court may grant mandamus relief only if: 795795. RETRIEVED EVIDENCE:
Under the Mandamus Act, "a court may grant mandamus relief only if:
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications…38 REQUEST FOR RELIEF…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason (1) the plaintiff has a clear right to
72
In gauging the public interest in granting this requested injunction, the Court need not worry that granting an injunction in this case will open the floodgates to similar suits from other criminal defendants seeking the courts' assistance in forcing the government to observe its preservation obligations in their cases. The exceptionally strong indication of vindictiveness in this case sets it apart from other criminal matters, as it so clearly establishes the need for the judicial scrutiny that will require access to the government's internal materials and communications at a hearing on a vindictive prosecution motion. The vast majority of defendants cannot show such clear vindictiveness, and therefore cannot demonstrate that the government will be obligated to produce those records at apost-indictment hearing. 798798. RETRIEVED EVIDENCE:
The vast majority of defendants cannot show such clear vindictiveness, and therefore cannot demonstrate that the government will be obligated to produce those records at apost-indictment hearing.
GOVERNING EVIDENCE:
Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…concerns that necessitate this complaint apply to only a small subset of officials, and the vast majority of Justice Department personnel are maintaining adherence to professional standards and…will no longer exist by the time any such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more…even though they should be, pursuant to the government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete…and in the Justice Department specifically are failing to observe their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the As such, they will be unable to establish a pre-indictment right to judicial enforcement of the government's obligation to preserve those records. 799799. RETRIEVED EVIDENCE:
As such, they will be unable to establish a pre-indictment right to judicial enforcement of the government's obligation to preserve those records.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 41 of 4638
relief; 800800. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 41 of 4638
relief;
GOVERNING EVIDENCE:
States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…38 REQUEST FOR RELIEF ............................................................................................................ 39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in (2) the defendant has aclear duty to act; 801801. RETRIEVED EVIDENCE:
(2) the defendant has aclear duty to act;
GOVERNING EVIDENCE:
Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…personnel are maintaining adherence to professional standards and carrying out their duties in the best tradition of the Justice Department. Case 1:26-cv-02323 Document 1 Filed…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of and (3) there is no other adequate remedy available to plaintiff." Muthana v. 802802. RETRIEVED EVIDENCE:
and (3) there is no other adequate remedy available to plaintiff." Muthana v.
GOVERNING EVIDENCE:
under seal, Plaintiff v. TODD W…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in…III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct Pompeo, 985 F.3d 893, 910 (D.C. 803803. RETRIEVED EVIDENCE:
Pompeo, 985 F.3d 893, 910 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Cir. 2021) (citation modified). 805805. RETRIEVED EVIDENCE:
2021) (citation modified).
GOVERNING EVIDENCE:
Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal…--- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub. L. No. 113-187, 10, 128 Stat…remedy available to plaintiff." Muthana v. Pompeo, 985 F.3d 893, 910 (D.C. Cir. 2021) (citation modified). To be entitled to a writ of mandamus under the All Writs Act, this Court must find: "(1 To be entitled to a writ of mandamus under the All Writs Act, this Court must find: 806806. RETRIEVED EVIDENCE:
To be entitled to a writ of mandamus under the All Writs Act, this Court must find:
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the
"(1) the petitioner has no other adequate means of relief; 807807. RETRIEVED EVIDENCE:
"(1) the petitioner has no other adequate means of relief;
GOVERNING EVIDENCE:
26 VII. Injunctive Relief is Necessary to Ensure Preservation of…by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a…record systems that would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 21. Defendant Joseph E. diGenova has served…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 22. Defendant Kash P. Patel has served as the Director (2) there is aclear and indisputable right to relief; 808808. RETRIEVED EVIDENCE:
(2) there is aclear and indisputable right to relief;
GOVERNING EVIDENCE:
26 VII. Injunctive Relief is Necessary to Ensure…38 REQUEST FOR RELIEF…by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend…March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…House from January 2009 to March 2013, Director Brennan played a lead role in shaping and coordinating Obama Administration policies on counterterrorism, including the successful operation…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a…record systems that would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the and (3) the court is satisfied that mandamus is appropriate under the circumstances." In re Trump, 172 F.4th 44, 51-52 (D.C. 809809. RETRIEVED EVIDENCE:
and (3) the court is satisfied that mandamus is appropriate under the circumstances." In re Trump, 172 F.4th 44, 51-52 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal…Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate Cir. 2026) (internal quotation marks omitted), vacated, 2026 WL 1785978 (D.C. 811811. RETRIEVED EVIDENCE:
2026) (internal quotation marks omitted), vacated, 2026 WL 1785978 (D.C.
GOVERNING EVIDENCE:
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…challenge, the court presiding over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…decisions. A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were Cir. June 22, 2026) (granting rehearing en banc). 813813. RETRIEVED EVIDENCE:
June 22, 2026) (granting rehearing en banc).
GOVERNING EVIDENCE:
to 28 U.S.C. 1361, which grants original jurisdiction to the…I saw in those transcripts." 68 In a recent civil case involving the mass termination of grants awarded by the National Endowment for the Humanities, the judge faulted the government…to his challenges to an eventual indictment. Under the Mandamus Act, "a court may grant mandamus relief only if: (1) the plaintiff has a clear right to 72 In gauging the public interest in granting this requested injunction, the Court need not worry that granting an injunction in this case will open the floodgates to similar suits from other criminal…2026) (internal quotation marks omitted), vacated, 2026 WL 1785978 (D.C. Cir. June 22, 2026) (granting rehearing en banc). 73. Director Brennan meets the three elements to be entitled to a writ of mandamus…the above listed materials and that that obligation applies prior to indictment. (3) Grant such other relief as the Court may deem just and proper. Dated: July 1, 2026 /s/
73.
Director Brennan meets the three elements to be entitled to a writ of mandamus to protect his constitutional rights. 815815. RETRIEVED EVIDENCE:
Director Brennan meets the three elements to be entitled to a writ of mandamus to protect his constitutional rights.
GOVERNING EVIDENCE:
to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation…26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal records and He has aclear right to relief, given the demonstrated danger that the government will fail to preserve the records needed for acourt to fully consider his constitutional challenge to any future indictment. 816816. RETRIEVED EVIDENCE:
He has aclear right to relief, given the demonstrated danger that the government will fail to preserve the records needed for acourt to fully consider his constitutional challenge to any future indictment.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's See supra 57-63. 817817. RETRIEVED EVIDENCE:
See supra 57-63.
GOVERNING EVIDENCE:
5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA…Sources Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority…Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ The Defendants have aclear duty to act,
i.e., to ensure the preservation of all such relevant records, given their obligations to preserve them for potential use in pre-trial litigation, see supra 56, and under the Federal Records Act and the Presidential Records Act, see supra 55. 818818. RETRIEVED EVIDENCE:
The Defendants have aclear duty to act,
i.e., to ensure the preservation of all such relevant records, given their obligations to preserve them for potential use in pre-trial litigation, see supra 56, and under the Federal Records Act and the Presidential Records Act, see supra 55.
GOVERNING EVIDENCE:
................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully…investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional And finally, absent injunctive relief - and in light of the government'sdemonstrated unwillingness to self-correct its deficient records preservation practices - it is clear that Director Brennan will be left with no other adequate remedy to avoid irreparable harm to his ability to vindicate his constitutional rights. 819819. RETRIEVED EVIDENCE:
And finally, absent injunctive relief - and in light of the government'sdemonstrated unwillingness to self-correct its deficient records preservation practices - it is clear that Director Brennan will be left with no other adequate remedy to avoid irreparable harm to his ability to vindicate his constitutional rights.
GOVERNING EVIDENCE:
25 VI. Absent this Court's Intervention, There is…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 21. Defendant Joseph E. diGenova has served…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 22. Defendant Kash P. Patel has served as the Director…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 23. Defendant Donald J. Trump has served as…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. Case 1:26-cv-02323 Document 1 Filed 07/01/26…record systems that would have the records to be preserved under the requested injunctive relief. 25. Defendant Susan L. Wiles has served as the White House Chief of Staff since
74.
For these reasons, it is necessary and appropriate for this Court, in the alternative, to issue a writ of mandamus pursuant to 28 U.S.C. 821821. RETRIEVED EVIDENCE:
For these reasons, it is necessary and appropriate for this Court, in the alternative, to issue a writ of mandamus pursuant to 28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the…activity from probing judicial scrutiny. 9. To perform that scrutiny after an indictment, the Court would demand access to a wide range of the government's communications and materials…emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on legitimate law enforcement concerns or on 1361 and 1651.
COUNT 3
Injunctive Relief in Aid Of The Court's Jurisdiction Under the All Writs Act (28 U.S.C. 823823. RETRIEVED EVIDENCE:
COUNT 3
Injunctive Relief in Aid Of The Court's Jurisdiction Under the All Writs Act (28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications…38 REQUEST FOR RELIEF…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason 1651)
75.
Director Brennan re-alleges and incorporates by reference paragraphs 1 through 74. 825825. RETRIEVED EVIDENCE:
Director Brennan re-alleges and incorporates by reference paragraphs 1 through 74.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in
Based on the foregoing, Director Brennan requests, in the alternative, that this Court issue an Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 42 of 4639
order in aid of its jurisdiction directing Defendants to preserve all records enumerated below in the Request for Relief. 826826. RETRIEVED EVIDENCE:
Based on the foregoing, Director Brennan requests, in the alternative, that this Court issue an Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 42 of 4639
order in aid of its jurisdiction directing Defendants to preserve all records enumerated below in the Request for Relief.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…38 REQUEST FOR RELIEF…denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this…adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and
76.
The All Writs Act, 28 U.S.C. 828828. RETRIEVED EVIDENCE:
The All Writs Act, 28 U.S.C.
GOVERNING EVIDENCE:
rights. Director Brennan therefore alternatively requests that the Court issue a writ of mandamus compelling the government to preserve the records enumerated below…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…Director Brennan's constitutional challenges to any future criminal charges. COUNT 2 Writ of Mandamus Under The Mandamus Act (28 U.S.C. 1361) And The All Writs Act (28 U.S.C. 1651) To Protect Director Brennan's Constitutional Rights 71…Based on the foregoing, Director Brennan requests, in the alternative, that this Court issue a writ of mandamus ordering the Defendants to preserve all records enumerated below in the…985 F.3d 893, 910 (D.C. Cir. 2021) (citation modified). To be entitled to a writ of mandamus under the All Writs Act, this Court must find: "(1) the petitioner has no other adequate means of 1651, authorizes this Court to issue all writs "necessary or appropriate" in aid of its jurisdiction, which includes its jurisdiction over criminal proceedings. 829829. RETRIEVED EVIDENCE:
1651, authorizes this Court to issue all writs "necessary or appropriate" in aid of its jurisdiction, which includes its jurisdiction over criminal proceedings.
GOVERNING EVIDENCE:
Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…Director Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden
See 18 U.S.C. 830830. RETRIEVED EVIDENCE:
See 18 U.S.C.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. 832832. RETRIEVED EVIDENCE:
In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates Cir. 2022) (finding the court had jurisdiction to issue a writ of mandamus in aid of future jurisdiction); 834834. RETRIEVED EVIDENCE:
2022) (finding the court had jurisdiction to issue a writ of mandamus in aid of future jurisdiction);
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the United…potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1 In re al-Nashiri,
791 F.3d 71, 76 (D.C. 835835. RETRIEVED EVIDENCE:
In re al-Nashiri,
791 F.3d 71, 76 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Cir. 2015) (a court can "can issue a writ of mandamus now to protect the exercise of [its] appellate jurisdiction later"); 837837. RETRIEVED EVIDENCE:
2015) (a court can "can issue a writ of mandamus now to protect the exercise of [its] appellate jurisdiction later");
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason…action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the United In re Mohammad, 866 F.3d 473, 475 (D.C. 838838. RETRIEVED EVIDENCE:
In re Mohammad, 866 F.3d 473, 475 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Cir.
2017) (same); 840840. RETRIEVED EVIDENCE:
2017) (same);
GOVERNING EVIDENCE:
process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim…Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying…a different grand jury in Miami, which issued subpoenas in January 2026 seeking the same category of documents from 2016 all the way up to the present. 31 James Hoft, Joe…Government Personnel from Accountability for Their Irregular Conduct 49. At the same time that government personnel are accelerating their overreaching efforts against…Then He was Fired, Guardian (Jan. 3, 2026), https://perma.cc/8JHJ-PGM3 . The same day, the U.S. Pardon Attorney, who was a career civil servant, was terminated by a…engages in that attorney's duties, to the same extent and in the same manner as other attorneys in that State." 28 Dascola v. 841841. RETRIEVED EVIDENCE:
Dascola v.
GOVERNING EVIDENCE:
jurisdiction later"); In re Mohammad, 866 F.3d 473, 475 (D.C. Cir. 2017) (same); Dascola v. City of Ann Arbor, 22 F. Supp. 3d 736, 746 (E.D. Mich. 2014). The very purpose City of Ann Arbor, 22 F. 842842. RETRIEVED EVIDENCE:
City of Ann Arbor, 22 F.
GOVERNING EVIDENCE:
later"); In re Mohammad, 866 F.3d 473, 475 (D.C. Cir. 2017) (same); Dascola v. City of Ann Arbor, 22 F. Supp. 3d 736, 746 (E.D. Mich. 2014). The very purpose of the Supp. 843843. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies 3d 736, 746 (E.D. 844844. RETRIEVED EVIDENCE:
3d 736, 746 (E.D.
GOVERNING EVIDENCE:
recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr…2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J Mich. 845845. RETRIEVED EVIDENCE:
Mich.
GOVERNING EVIDENCE:
claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive prosecution claim, the court considered…in camera material from the government "related to the DOJ's recusal of the three principal Detroit U.S. Attorneys" and ordered that evidence turned over to defendant); United States v…In re Mohammad, 866 F.3d 473, 475 (D.C. Cir. 2017) (same); Dascola v. City of Ann Arbor, 22 F. Supp. 3d 736, 746 (E.D. Mich. 2014). The very purpose of the requested order in this matter is to ensure that the 2014). The very purpose of the requested order in this matter is to ensure that the Court may properly carry out the responsibility to review the evidence necessary to evaluate the challenges that will be filed in the event that charges are brought against Director Brennan. 847847. RETRIEVED EVIDENCE:
The very purpose of the requested order in this matter is to ensure that the Court may properly carry out the responsibility to review the evidence necessary to evaluate the challenges that will be filed in the event that charges are brought against Director Brennan.
GOVERNING EVIDENCE:
24 IV. The Court Reviewing the Vindictive and Selective…those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by…the false-statements investigation. Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 7. In their work on these presidentially-driven…of selective and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who…records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous…the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and It is therefore "necessary"
and "appropriate" that the Court now enjoin the government to preserve those records until such time as they are required for production and review in apre-trial hearing about whether the government acted vindictively and selectively in charging Director Brennan. 848848. RETRIEVED EVIDENCE:
It is therefore "necessary"
and "appropriate" that the Court now enjoin the government to preserve those records until such time as they are required for production and review in apre-trial hearing about whether the government acted vindictively and selectively in charging Director Brennan.
GOVERNING EVIDENCE:
any Criminal Charges as Vindictive and Selective Prosecution…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for…1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's
77.
For these reasons, it is necessary and appropriate for this Court, in the alternative, to issue a writ of mandamus pursuant to 28 U.S.C. 850850. RETRIEVED EVIDENCE:
For these reasons, it is necessary and appropriate for this Court, in the alternative, to issue a writ of mandamus pursuant to 28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the…activity from probing judicial scrutiny. 9. To perform that scrutiny after an indictment, the Court would demand access to a wide range of the government's communications and materials…emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on legitimate law enforcement concerns or on 1651.
REQUEST FOR RELIEF WHEREFORE, Director Brennan respectfully requests that this Court: 852852. RETRIEVED EVIDENCE:
REQUEST FOR RELIEF WHEREFORE, Director Brennan respectfully requests that this Court:
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights
(1) Issue an order requiring Defendants to preserve, and to cause their personnel and subordinates and others to preserve, any and all materials and communications that currently exist or that come into existence that are potentially relevant to the consideration of Director Brennan'slegal and constitutional challenges to any future criminal charges. 853853. RETRIEVED EVIDENCE:
(1) Issue an order requiring Defendants to preserve, and to cause their personnel and subordinates and others to preserve, any and all materials and communications that currently exist or that come into existence that are potentially relevant to the consideration of Director Brennan'slegal and constitutional challenges to any future criminal charges.
GOVERNING EVIDENCE:
Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 This requested relief encompasses but is not limited to: 854854. RETRIEVED EVIDENCE:
This requested relief encompasses but is not limited to:
GOVERNING EVIDENCE:
Injunctive Relief is Necessary to Ensure…38 REQUEST FOR RELIEF…the false-statements investigation. Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 7. In their work on these presidentially-driven…Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial conduct. Those overreaching actions have violated Director Brennan's…the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and…subordinates and record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a…personnel and record systems that would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 43 of 4640
a)
All records relating to any federal investigation into Director Brennan's conduct, to include the investigation into allegations that he lied in his testimony to the House of Representatives Committee on the Judiciary on May 11, 2023 and the investigation into the "grand conspiracy" being conducted out of the U.S. Attorney's Office in the Southern District of Florida; 855855. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 43 of 4640
a)
All records relating to any federal investigation into Director Brennan's conduct, to include the investigation into allegations that he lied in his testimony to the House of Representatives Committee on the Judiciary on May 11, 2023 and the investigation into the "grand conspiracy" being conducted out of the U.S. Attorney's Office in the Southern District of Florida;
GOVERNING EVIDENCE:
s Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel
b)
All status reports, witness statements, legal memoranda, updates, emails, messages,
prosecution memoranda, communications, AI queries, calendar entries, and documents of any type relating to the two pending investigations and any possible prosecution of Director Brennan, including any assessments, analysis or evaluations of the strength or weakness of any potential criminal case against Director Brennan or others involved in the investigations; 856856. RETRIEVED EVIDENCE:
b)
All status reports, witness statements, legal memoranda, updates, emails, messages,
prosecution memoranda, communications, AI queries, calendar entries, and documents of any type relating to the two pending investigations and any possible prosecution of Director Brennan, including any assessments, analysis or evaluations of the strength or weakness of any potential criminal case against Director Brennan or others involved in the investigations;
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation
c)
All records of communications relating to any investigation and/or possible prosecution of Director Brennan and any alleged co-conspirators, whether in person, telephonic or via any communication device or online platform, including AI platforms; 857857. RETRIEVED EVIDENCE:
c)
All records of communications relating to any investigation and/or possible prosecution of Director Brennan and any alleged co-conspirators, whether in person, telephonic or via any communication device or online platform, including AI platforms;
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel
d)
All documents or communications related to meetings about any investigation involving Director Brennan and that of any alleged coconspirators, including meetings with Justice Department personnel or with any persons outside of the Justice Department, including representatives or staff of the White House and of Congress; 858858. RETRIEVED EVIDENCE:
d)
All documents or communications related to meetings about any investigation involving Director Brennan and that of any alleged coconspirators, including meetings with Justice Department personnel or with any persons outside of the Justice Department, including representatives or staff of the White House and of Congress;
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants…....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations
e)
All records of communications, public or private, by President Trump and White House employees or any government staff acting on President Trump'sbehalf, including all Department of Justice employees or contractors, relating to any investigation of Director Brennan or any alleged co-conspirator, including any efforts to advance the investigation or otherwise to be apprised of the status of the investigation; 859859. RETRIEVED EVIDENCE:
e)
All records of communications, public or private, by President Trump and White House employees or any government staff acting on President Trump'sbehalf, including all Department of Justice employees or contractors, relating to any investigation of Director Brennan or any alleged co-conspirator, including any efforts to advance the investigation or otherwise to be apprised of the status of the investigation;
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His…Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 44 of 4641
f)
All records relating to any decisions regarding personnel assigned to, removed from or conflicted from investigating or managing the investigations involving Director Brennan,
including any internal emails, chats, messages, memos, meeting notices and personnel paperwork related in any manner to the assignment, removal or oversight of personnel,
including U.S. Attorneys, Assistant U.S. Attorneys, supervisors, or agents involved in any manner with those investigations; 860860. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 44 of 4641
f)
All records relating to any decisions regarding personnel assigned to, removed from or conflicted from investigating or managing the investigations involving Director Brennan,
including any internal emails, chats, messages, memos, meeting notices and personnel paperwork related in any manner to the assignment, removal or oversight of personnel,
including U.S. Attorneys, Assistant U.S. Attorneys, supervisors, or agents involved in any manner with those investigations;
GOVERNING EVIDENCE:
U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming
g)
All records relating to any discussions or decisions regarding where any investigation or prosecution of the false-statements case or the "grand conspiracy" case will be pursued; 861861. RETRIEVED EVIDENCE:
g)
All records relating to any discussions or decisions regarding where any investigation or prosecution of the false-statements case or the "grand conspiracy" case will be pursued;
GOVERNING EVIDENCE:
A. The Grand…Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's
h)
All records or communications regarding any investigation or possible prosecution of Director Brennan between Justice Department personnel and Congressman Jim Jordan and/or his staff, including any such records or communications relating to the October 21,
2025 referral to Attorney General Pam Bondi and any and all discussion about plans or suggestions for the substance or process of that referral; 862862. RETRIEVED EVIDENCE:
h)
All records or communications regarding any investigation or possible prosecution of Director Brennan between Justice Department personnel and Congressman Jim Jordan and/or his staff, including any such records or communications relating to the October 21,
2025 referral to Attorney General Pam Bondi and any and all discussion about plans or suggestions for the substance or process of that referral;
GOVERNING EVIDENCE:
capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights
i)
All records or communications regarding any investigation or possible prosecution of Director Brennan or any alleged co-conspirators between Justice Department personnel and DNI Director Tulsi Gabbard and/or her staff and CIA Director John Ratcliffe and/or his staff, including any such records or communications relating to the July 2025 referrals to Attorney General Pam Bondi and any and all discussion about plans or suggestions for the substance or process of those referrals; 863863. RETRIEVED EVIDENCE:
i)
All records or communications regarding any investigation or possible prosecution of Director Brennan or any alleged co-conspirators between Justice Department personnel and DNI Director Tulsi Gabbard and/or her staff and CIA Director John Ratcliffe and/or his staff, including any such records or communications relating to the July 2025 referrals to Attorney General Pam Bondi and any and all discussion about plans or suggestions for the substance or process of those referrals;
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights
j)
All records or communications relating to press or public statements about Director Brennan or any of alleged co-conspirators relating to any interaction between the Department of Justice and the press or members of the press about Director Brennan or the investigations involving his or his alleged co-conspirators' activities; 864864. RETRIEVED EVIDENCE:
j)
All records or communications relating to press or public statements about Director Brennan or any of alleged co-conspirators relating to any interaction between the Department of Justice and the press or members of the press about Director Brennan or the investigations involving his or his alleged co-conspirators' activities;
GOVERNING EVIDENCE:
L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean…and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim and Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 45 of 4642
k)
all records or communications relating to any investigation of Director Brennan or his alleged co-conspirators that were held or received by any Department of Justice personnel who have been involved in such investigation, including personnel who have stopped working on the investigation or have left employment at the Department of Justice. 865865. RETRIEVED EVIDENCE:
and Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 45 of 4642
k)
all records or communications relating to any investigation of Director Brennan or his alleged co-conspirators that were held or received by any Department of Justice personnel who have been involved in such investigation, including personnel who have stopped working on the investigation or have left employment at the Department of Justice.
GOVERNING EVIDENCE:
950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case…vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In
(2) Issue a declaratory judgment that the government has the obligation to preserve the above listed materials and that that obligation applies prior to indictment. 866866. RETRIEVED EVIDENCE:
(2) Issue a declaratory judgment that the government has the obligation to preserve the above listed materials and that that obligation applies prior to indictment.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE
(3) Grant such other relief as the Court may deem just and proper. 867867. RETRIEVED EVIDENCE:
(3) Grant such other relief as the Court may deem just and proper.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications…38 REQUEST FOR RELIEF…to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the
Dated: July 1, 2026 /s/ Kenneth L. Wainstein Kenneth L. 870870. RETRIEVED EVIDENCE:
Wainstein Kenneth L.
GOVERNING EVIDENCE:
relief as the Court may deem just and proper. Dated: July 1, 2026 /s/ Kenneth L. Wainstein Kenneth L. Wainstein, DC Bar # 451058 Natasha Harnwell-Davis, DC Bar # 1719228 Mayer Brown LLP 1999 K Wainstein, DC Bar # 451058
Natasha Harnwell-Davis, DC Bar # 1719228
Mayer Brown LLP
1999 K Street, NW Washington, DC 20006-1101
Telephone: (202) 263-3000
KWainstein@mayerbrown.com Dan Gelber Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A. 872872. RETRIEVED EVIDENCE:
(202) 263-3000
KWainstein@mayerbrown.com Dan Gelber Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A.
GOVERNING EVIDENCE:
Street, NW Washington, DC 20006-1101 Telephone: (202) 263-3000 KWainstein@mayerbrown.com Dan Gelber Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A. One Southeast Third Avenue, Suite 2600 Miami, Florida 33131-1715 Telephone: (305) 728-0954 dan@gsgpa.com Joan Silverstein Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A. One Southeast Third Avenue, Suite 2600 Miami, Florida
One Southeast Third Avenue, Suite 2600
Miami, Florida 33131-1715
Telephone: 873873. RETRIEVED EVIDENCE:
One Southeast Third Avenue, Suite 2600
Miami, Florida 33131-1715
Telephone:
GOVERNING EVIDENCE:
NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia (305) 728-0954
dan@gsgpa.com Joan Silverstein Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A. 874874. RETRIEVED EVIDENCE:
(305) 728-0954
dan@gsgpa.com Joan Silverstein Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A.
GOVERNING EVIDENCE:
DC 20006-1101 Telephone: (202) 263-3000 KWainstein@mayerbrown.com Dan Gelber Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A. One Southeast Third Avenue, Suite 2600 Miami, Florida 33131-1715 Telephone: (305) 728-0954 dan@gsgpa.com Joan Silverstein Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A. One Southeast Third Avenue, Suite 2600 Miami
One Southeast Third Avenue, Suite 2600
Miami, Florida 33131-1715
Telephone: 875875. RETRIEVED EVIDENCE:
One Southeast Third Avenue, Suite 2600
Miami, Florida 33131-1715
Telephone:
GOVERNING EVIDENCE:
NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia (305) 728-0950
jsilverstein@gsgpa.com Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 46 of 46
876876. RETRIEVED EVIDENCE:
(305) 728-0950
jsilverstein@gsgpa.com Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 46 of 46
GOVERNING EVIDENCE:
States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will…Brennan alleges as follows: Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 of 463 INTRODUCTION 1
∎
EVIDENCE
- 1. RETRIEVED EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason - 2. RETRIEVED EVIDENCE:
BRENNAN,
Notice of address filed under seal,
Plaintiff v.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950…O. Brennan ("Plaintiff" or…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in…III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct - 3. RETRIEVED EVIDENCE:
TODD W.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 4. RETRIEVED EVIDENCE:
BLANCHE, in his official capacity as Acting Attorney General,
950 Pennsylvania Avenue, NW Washington, DC 20530
THE UNITED STATES DEPARTMENT OF JUSTICE,
950 Pennsylvania Avenue NW Washington, DC 20530
JASON A.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 5. RETRIEVED EVIDENCE:
REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida,
U.S. Attorney's Office
99 N.E.
GOVERNING EVIDENCE:
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney…950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency - 6. RETRIEVED EVIDENCE:
4th Street Miami, FL 33132
JOSEPH E.
GOVERNING EVIDENCE:
U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald…In an interview the day after Bondi was fired, now-Counsel to the Attorney General Joseph diGenova explained that [t]he President's conversation with [Attorney General Pam Bondi] yesterday…was ripping mad about the fact that there was no progress on the lawfare investigation in Miami. 24In April, the lead career prosecutor on the Brennan investigations was removed from…News (Mar. 19, 2018), https://perma.cc/ZP79-WTLH . 29 Id.; Trump Lawyer diGenova to Lead Miami Grand Conspiracy Probe (1), Bloomberg Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 - 7. RETRIEVED EVIDENCE:
DIGENOVA, in his official capacity as Counselor to the Attorney General,
U.S. Attorney's Office
99 N.E.
GOVERNING EVIDENCE:
W. BLANCHE, in his official capacity as Acting Attorney General…950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington - 8. RETRIEVED EVIDENCE:
4th Street Miami, FL 33132
KASH P.
GOVERNING EVIDENCE:
U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation…sued in his official capacity. 22. Defendant Kash P. Patel has served as the Director of the FBI…District of Virginia before finding a home in SDFL. Recent reporting indicates that FBI Director Kash Patel also shopped the investigations to the Western District of Virginia in July 2025…personnel in the FBI field office and the main SDFL U.S. Attorney's Office in Miami. It is five states away from Washington, D.C., where the vast majority of the supposed…was ripping mad about the fact that there was no progress on the lawfare investigation in Miami. 24In April, the lead career prosecutor on the Brennan investigations was removed from - 9. RETRIEVED EVIDENCE:
PATEL, in his official capacity as Director of the Federal Bureau of Investigation,
935 Pennsylvania Ave, NW Washington, DC 20001
DONALD J.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 10. RETRIEVED EVIDENCE:
TRUMP, in his official capacity as President of the United States,
1600 Pennsylvania Ave NW Washington, DC 20500
Civil Action Case No. _________
26-2323
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46
EXECUTIVE OFFICE OF THE PRESIDENT,
1600 Pennsylvania Avenue NW Washington, DC 20500
SUSAN L.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 11. RETRIEVED EVIDENCE:
WILES, in her official capacity as White House Chief of Staff,
1600 Pennsylvania Avenue NW Washington, DC 20500
JOHN L.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 12. RETRIEVED EVIDENCE:
RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency,
Central Intelligence Agency Washington, DC 20505
CENTRAL INTELLIGENCE AGENCY,
Washington, DC 20505
OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE,
1500 Tysons McLean Dr.
McLean, VA 22102
Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46
TABLE OF CONTENTS Page i
COMPLAINT ................................................................................................................................ 1
INTRODUCTION ......................................................................................................................... 3
PARTIES ....................................................................................................................................... 7
JURISDICTION AND VENUE .................................................................................................. 10
STANDING ................................................................................................................................. 11
FACTUAL BACKGROUND ...................................................................................................... 12
I.
GOVERNING EVIDENCE:
BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed - 13. RETRIEVED EVIDENCE:
The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12
A.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel - 14. RETRIEVED EVIDENCE:
The Grand Conspiracy Investigation ....................................................... 12
B.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…with the Two Brennan Investigations…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions - 15. RETRIEVED EVIDENCE:
The False-Statements Investigation ......................................................... 13
II.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in - 16. RETRIEVED EVIDENCE:
The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13
A.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 17. RETRIEVED EVIDENCE:
Administration Officials Call for Director Brennan's Prosecution ......... 16
B.
GOVERNING EVIDENCE:
in his official capacity as…U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1 - 18. RETRIEVED EVIDENCE:
The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18
C.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON…Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida - 19. RETRIEVED EVIDENCE:
The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20
D.
GOVERNING EVIDENCE:
Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years - 20. RETRIEVED EVIDENCE:
Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21
E.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 21. RETRIEVED EVIDENCE:
The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct .................................... 22
III.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th…JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 22. RETRIEVED EVIDENCE:
The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24
IV.
GOVERNING EVIDENCE:
22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and…these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging - 23. RETRIEVED EVIDENCE:
The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24
V.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under…Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government - 24. RETRIEVED EVIDENCE:
The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25
VI.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O…Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His - 25. RETRIEVED EVIDENCE:
Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights ........................................................................................... 26
VII.
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 26. RETRIEVED EVIDENCE:
Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights .......................................................................... 34
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46
TABLE OF CONTENTS
(continued)
Page ii COUNT 1 ..................................................................................................................................... 35
COUNT 2 ..................................................................................................................................... 37
COUNT 3 ..................................................................................................................................... 38
REQUEST FOR RELIEF ............................................................................................................ 39
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461
COMPLAINT
"Being perceived as the President'sadversary has become risky in recent years." In re Grand Jury Subpoenas Nos.
GOVERNING EVIDENCE:
Government has Engaged, and Continues to Engage, in Unprecedented, Irregular…34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1 ..................................................................................................................................... 35 COUNT 2 ..................................................................................................................................... 37 COUNT 3 ..................................................................................................................................... 38 REQUEST FOR RELIEF…Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation…by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend - 27. RETRIEVED EVIDENCE:
[Redacted] & [Redacted], 823 F.
GOVERNING EVIDENCE:
s adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr…court's request to review the grand jury transcripts. 67 At first, they provided only redacted versions, and when the judge insisted on the full transcripts, they even reduced the…release of the Epstein files, where the Justice Department was less than transparent in redacting passages that were inconvenient for President Trump, Nik Popli, Trump Administration Removes Some Redactions from Epstein Files After Outcry from Lawyers, Time (Feb. 9, 2026), https://perma.cc/ZGW3-H6ZK ("Among the material Raskin said he encountered was a redacted passage summarizing comments Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 37 of 4634 will - 28. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 29. RETRIEVED EVIDENCE:
3d 1, 5 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 30. RETRIEVED EVIDENCE:
2026),
reconsideration denied, 2026 WL 1224046 (D.D.C.
GOVERNING EVIDENCE:
THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second investigation centers on an October 21…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set - 31. RETRIEVED EVIDENCE:
Apr.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 32. RETRIEVED EVIDENCE:
3, 2026).
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 33. RETRIEVED EVIDENCE:
With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted apolicy of using criminal process and prosecution to punish the President'sperceived adversaries.
GOVERNING EVIDENCE:
2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's…been publicly declaring Director Brennan a criminal, not only before securing a conviction in…to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice Department into a tool of retribution against Director - 34. RETRIEVED EVIDENCE:
Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited
"the backdrop of the Trump administration'swell-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries."
In re Grand Jury Subpoenas Nos.
GOVERNING EVIDENCE:
subpoenas directed at Federal…this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's…than 33 years of nonpartisan government service working for six administrations - three Republican and three Democratic - in a wide variety of national security and intelligence positions. His…has excoriated Director Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying…actively mobilized the machinery of the criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and - 35. RETRIEVED EVIDENCE:
2022R00519-A, 2022R00519-B, 2022R00519-C,
2022R00519-D, 2022R00519-E, 2022R00519-F, -- F.
GOVERNING EVIDENCE:
the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A, 2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is - 36. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 37. RETRIEVED EVIDENCE:
3d --, 2026 WL 1783899, at *7 (D.
GOVERNING EVIDENCE:
& [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of Just., Justice…2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010) (noting that the court did an in camera…documents" in assessing claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive…514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr. 20, 2021) (Contreras, J), and "[t]he government - 38. RETRIEVED EVIDENCE:
Minn.
GOVERNING EVIDENCE:
adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the…2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central - 39. RETRIEVED EVIDENCE:
June 22, 2026).
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 40. RETRIEVED EVIDENCE:
It is against this backdrop that former Director of the Central Intelligence Agency, John O.
GOVERNING EVIDENCE:
the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations…Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution - 41. RETRIEVED EVIDENCE:
Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution.
GOVERNING EVIDENCE:
official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President - 42. RETRIEVED EVIDENCE:
As in the above cases, the evidence of vindictiveness in this matter is overwhelming.
GOVERNING EVIDENCE:
as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and…to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for…1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over - 43. RETRIEVED EVIDENCE:
President Trump has been condemning and calling for Director Brennan's prosecution for years.
GOVERNING EVIDENCE:
99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss - 44. RETRIEVED EVIDENCE:
Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing aconviction in court but even before afull investigation and an indictment.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA - 45. RETRIEVED EVIDENCE:
And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 46. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462
Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution.
GOVERNING EVIDENCE:
22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for…of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over - 47. RETRIEVED EVIDENCE:
In assessing that challenge, the court presiding over Director Brennan'scriminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government'sactions.
GOVERNING EVIDENCE:
Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 48. RETRIEVED EVIDENCE:
Given the government'squestionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has awell-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness.
GOVERNING EVIDENCE:
to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's…the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully - 49. RETRIEVED EVIDENCE:
For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full - 50. RETRIEVED EVIDENCE:
Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 51. RETRIEVED EVIDENCE:
Blanche, Acting Attorney General;
GOVERNING EVIDENCE:
filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW…NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan…Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney - 52. RETRIEVED EVIDENCE:
the United States Department of Justice;
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small…W. Blanche is the Acting Attorney General of the United States. He leads the Department of Justice and has been in this position since April 2026. In that role, he has Case 1:26-cv-02323…relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes - 53. RETRIEVED EVIDENCE:
Jason A.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 54. RETRIEVED EVIDENCE:
Reding Qui ones, the U.S. Attorney for the Southern District of Florida;
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal…NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to - 55. RETRIEVED EVIDENCE:
Joseph E.
GOVERNING EVIDENCE:
District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S.…Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the…under the requested injunctive relief. He is sued in his official capacity. 21. Defendant Joseph E. diGenova has served as Counselor to the Attorney General since April 20, 2026. He…In an interview the day after Bondi was fired, now-Counsel to the Attorney General Joseph diGenova explained that [t]he President's conversation with [Attorney General Pam Bondi] yesterday - 56. RETRIEVED EVIDENCE:
diGenova, Counselor to the Attorney General;
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…FBI Director and the Counselor overseeing the Brennan investigations…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has - 57. RETRIEVED EVIDENCE:
Donald J.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 58. RETRIEVED EVIDENCE:
Trump,
President of the United States;
GOVERNING EVIDENCE:
......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos - 59. RETRIEVED EVIDENCE:
the Executive Office of the President;
GOVERNING EVIDENCE:
26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…to retaliate against and pressure the President's political and personal adversaries - 60. RETRIEVED EVIDENCE:
Susan L.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 61. RETRIEVED EVIDENCE:
Wiles, White House Chief of Staff;
GOVERNING EVIDENCE:
NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White…President of the United States; the Executive Office of the President; Susan L. Wiles, White House Chief of Staff; John L. Ratcliffe, Director of the Central Intelligence…to be preserved under the requested injunctive relief. 25. Defendant Susan L. Wiles has served as the White House Chief of Staff since January 20, 2025. In that role, she…That concern became so pronounced that undersigned counsel submitted a letter to the Chief Judge of the Southern District of Florida alerting her to the government's judge-shopping and…is to carry out the Justice Department's judge-shopping plan. 38. The letter to Chief Judge Altonaga lays out many of the government's irregular actions up to that time. To…government's conduct in this matter. 11 See Letter from Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https - 62. RETRIEVED EVIDENCE:
John L.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 63. RETRIEVED EVIDENCE:
Ratcliffe, Director of the Central Intelligence Agency;
GOVERNING EVIDENCE:
s Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001…as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 64. RETRIEVED EVIDENCE:
the Central Intelligence Agency;
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016…grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice Department have succumbed…senior Administration officials in the run-up to the First Gulf War (1990-91); daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95); senior U.S. intelligence official resident in Saudi Arabia (1996-99); Chief of Staff to Director of Central Intelligence George Tenet (1999-2001); and, Deputy Executive Director of the CIA (2001-03). As - 65. RETRIEVED EVIDENCE:
and the Office of the Director of National Intelligence (collectively
"Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan'slegal and constitutional challenges to any future criminal charges.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full - 66. RETRIEVED EVIDENCE:
For his Complaint, Director Brennan alleges as follows:
GOVERNING EVIDENCE:
capacity as Director of the Federal…Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re - 67. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 of 463
INTRODUCTION
1.
GOVERNING EVIDENCE:
of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director - 68. RETRIEVED EVIDENCE:
Director Brennan is aformer longtime public servant who provided more than 33 years of nonpartisan government service working for six administrations - three Republican and three Democratic - in awide variety of national security and intelligence positions.
GOVERNING EVIDENCE:
20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…s Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 69. RETRIEVED EVIDENCE:
His public service career culminated in his term as the Director of the Central Intelligence Agency ("CIA")
from March 8, 2013 to January 20, 2017.
GOVERNING EVIDENCE:
99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation - 70. RETRIEVED EVIDENCE:
2.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 71. RETRIEVED EVIDENCE:
While serving as Director, he participated in coordinating and issuing the January 6, 2017
Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the
2016 presidential election in an effort to boost candidate Donald Trump's chances of winning the election.
GOVERNING EVIDENCE:
25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not - 72. RETRIEVED EVIDENCE:
In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the - 73. RETRIEVED EVIDENCE:
3.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 74. RETRIEVED EVIDENCE:
Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and demonize Director Brennan.
GOVERNING EVIDENCE:
Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from - 75. RETRIEVED EVIDENCE:
In avariety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan as "avery bad guy," "atotal low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying before Congress, and has twice posted doctored images of Director Brennan in an orange jumpsuit.
GOVERNING EVIDENCE:
Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 76. RETRIEVED EVIDENCE:
4.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 77. RETRIEVED EVIDENCE:
With his return to the White House, the President has gone beyond mere denunciation,
and has actively mobilized the machinery of the criminal justice system against Director Brennan.
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 78. RETRIEVED EVIDENCE:
He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal justification.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 79. RETRIEVED EVIDENCE:
Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464
Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice Department into atool of retribution against Director Brennan and the President'sother perceived adversaries.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions - 80. RETRIEVED EVIDENCE:
1
5.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 81. RETRIEVED EVIDENCE:
This effort has resulted in the opening of two federal investigations that purport to be investigating Director Brennan for what amounts to phantom criminal conduct.
GOVERNING EVIDENCE:
his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 82. RETRIEVED EVIDENCE:
The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 83. RETRIEVED EVIDENCE:
This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product of aconspiracy to deny President Trump his civil rights.
GOVERNING EVIDENCE:
Relevant…March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…or written statements that personally criticize and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and…Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying…Director Brennan and a number of Obama and Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second investigation centers on an October 21 - 84. RETRIEVED EVIDENCE:
The second investigation centers on an October 21, 2025 referral from Congressman Jim Jordan, Chairman of the House Judiciary Committee, which asserts without valid support that Director Brennan made false statements about the ICA in a 2023 interview with the House Judiciary Committee.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions…In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan as "a very…He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal…and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice - 85. RETRIEVED EVIDENCE:
6.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 86. RETRIEVED EVIDENCE:
The Justice Department has undertaken separate grand jury investigations as to each of these matters.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case - 87. RETRIEVED EVIDENCE:
In November 2025 and January 2026, the Southern District of Florida ("SDFL")
U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to the supposed "grand conspiracy" and the other relating to Director Brennan's alleged false statements to Congress.
GOVERNING EVIDENCE:
U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration…2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the - 88. RETRIEVED EVIDENCE:
Then, over the weekend of April 18, 2026, a federal grand jury in Washington, D.C.
GOVERNING EVIDENCE:
Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official…in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed…07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…12 A. The Grand Conspiracy Investigation ....................................................... - 89. RETRIEVED EVIDENCE:
issued subpoenas to a number of current and former Intelligence Community
1
In detailing how some individuals in the Justice Department have succumbed to pressure from the President to selectively and vindictively target Director Brennan, there is no intent to suggest that responsibility for the resulting lapses is widely shared within the Department.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…statements - President Trump has excoriated Director Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…Brennan and the President's other perceived adversaries. 1 5. This effort has resulted in the opening of two federal investigations that purport to be investigating Director - 90. RETRIEVED EVIDENCE:
To the contrary, the concerns that necessitate this complaint apply to only a small subset of officials,
and the vast majority of Justice Department personnel are maintaining adherence to professional standards and carrying out their duties in the best tradition of the Justice Department.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 91. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 8 of 465
personnel who had worked on the ICA, requiring them to testify before the grand jury in the false-statements investigation.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions…in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016 presidential election in an - 92. RETRIEVED EVIDENCE:
Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews.
GOVERNING EVIDENCE:
..................................................................................................................................... 38 REQUEST FOR…without valid support that Director Brennan made false statements about the ICA in a 2023 interview with the House Judiciary Committee. 6. The Justice Department has undertaken separate grand…District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to the supposed "grand conspiracy" and the other…over the weekend of April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some…them to testify before the grand jury in the false-statements investigation. Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 7. In their work on these presidentially-driven investigations, certain Justice…the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and - 93. RETRIEVED EVIDENCE:
7.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 94. RETRIEVED EVIDENCE:
In their work on these presidentially-driven investigations, certain Justice Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial conduct.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 95. RETRIEVED EVIDENCE:
Those overreaching actions have violated Director Brennan'sconstitutional rights and will serve as the basis for challenges to any resulting charges, including motions to dismiss any indictment on the grounds that it is the result of selective and vindictive prosecution.
GOVERNING EVIDENCE:
Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean…Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 96. RETRIEVED EVIDENCE:
8.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 97. RETRIEVED EVIDENCE:
To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw, or undertook those actions to determine whether they violated Director Brennan'srights, and specifically whether they were motivated by adesire to vindictively prosecute him as an act of retribution.
GOVERNING EVIDENCE:
................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong…and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect - 98. RETRIEVED EVIDENCE:
That scrutiny would be more probing and less deferential to the government than usual because of the Justice Department'srecent record of overreaching in this and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny.
GOVERNING EVIDENCE:
Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other…those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying - 99. RETRIEVED EVIDENCE:
9.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 100. RETRIEVED EVIDENCE:
To perform that scrutiny after an indictment, the Court would demand access to awide range of the government's communications and materials surrounding its investigative and prosecutive decisions.
GOVERNING EVIDENCE:
and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably…that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging - 101. RETRIEVED EVIDENCE:
Acareful examination of the prosecutors' emails, texts, instant messages,
internal memoranda and the like would enable acourt to determine whether their decisions were based on legitimate law enforcement concerns or on adesire to selectively and/or vindictively prosecute Director Brennan.
GOVERNING EVIDENCE:
Materials and Communications to Assess the Prosecutors' Motivations…and materials surrounding its investigative and prosecutive decisions. A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on legitimate law enforcement concerns or on a desire to selectively and/or vindictively prosecute…These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not…communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions. And Director Brennan and the Court cannot rely on pre-trial…the allegation that Director Brennan made false statements to Congress. The government prosecutors have informed Director Brennan that any false-statements case must be filed in the - 102. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466
10.
GOVERNING EVIDENCE:
of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director - 103. RETRIEVED EVIDENCE:
There is avery real risk, however, that some of these materials and communications will no longer exist by the time any such challenges are filed and the court hears them.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His…Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d…directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution - 104. RETRIEVED EVIDENCE:
This risk exists for two reasons.
GOVERNING EVIDENCE:
s Intervention, There is a Serious Risk that Highly Relevant Internal…Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that…time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action…2016 election and the other Trump-related investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second investigation…Brennan. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466 10. There is a very real risk, however, that some of these materials and communications will no longer exist by the time any such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are - 105. RETRIEVED EVIDENCE:
First, as technology changes and becomes more ephemeral, government officials are increasingly relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery obligations.
GOVERNING EVIDENCE:
respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the…twice posted doctored images of Director Brennan in an orange jumpsuit. 4. With his return to the White House, the President has gone beyond mere denunciation, and has actively…07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice Department into a tool of retribution against Director Brennan and the…are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are increasingly relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging - 106. RETRIEVED EVIDENCE:
These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely preserved.
GOVERNING EVIDENCE:
Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which - 107. RETRIEVED EVIDENCE:
2
Second, there is ample evidence in the public record that many in the Administration and in the Justice Department specifically are failing to observe their legal obligation to maintain such records.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th…JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 108. RETRIEVED EVIDENCE:
11.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 109. RETRIEVED EVIDENCE:
The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan'schallenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions.
GOVERNING EVIDENCE:
24 IV. The Court Reviewing the Vindictive and Selective…of selective and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who…are failing to observe their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions. And Director Brennan…investigation. Isn't that a problem?" At that point, Blanche simply responded, "I just completely disagree with the premise," and gave his assurance that DiGenova will be "doing…a proposed regulation that will give the Attorney General the first opportunity to review any complaint against a current or former Department attorney 44 and the right to "take - 110. RETRIEVED EVIDENCE:
And Director Brennan and the Court cannot rely on pre-trial sanctions as aremedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 111. RETRIEVED EVIDENCE:
12.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 112. RETRIEVED EVIDENCE:
For this reason, Director Brennan brings this action asking the Court to enjoin the government to preserve any and all communications and materials that are potentially relevant to
2
U.S. Dep'tof Just., Private Impact Assessment for the Email and Collaboration Services
(2024),
https://perma.cc/HS8T-K2SY
(announcing DOJ is using Microsoft Teams);
GOVERNING EVIDENCE:
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his…s Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 113. RETRIEVED EVIDENCE:
U.S. Dep'tof Just., AI Inventory (Jan.
GOVERNING EVIDENCE:
that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely preserved. 2 Second, there is ample evidence…//perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 114. RETRIEVED EVIDENCE:
30, 2026),
https://perma.cc/DG59-PCFZ
;
GOVERNING EVIDENCE:
Private Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…29, 2025), https://perma.cc/RWM6-6HAN …Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury…into Russiagate Conspiracy Allegations: Sources, Fox News (Aug. 4, 2025), https://perma.cc/Q5JS XTZQ ; LA Times Studios, Straight to the Point: The Grand Conspiracy Against - 115. RETRIEVED EVIDENCE:
see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep'tof Just.,
https://perma.cc/8ERX-WDY4
(spreadsheet showing more than 300 AI use cases at DOJ);
GOVERNING EVIDENCE:
and materials that are potentially relevant to 2 U.S. Dep't of Just., Private Impact Assessment for the Email and…2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How AI and Whistleblowers…22, 2017), https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009), https://perma.cc/W55M-M7FW (Eric Holder 2009 memo). 20 Memorandum from the Attorney General to All Dep't Emps. (Feb. 5, 2025), https://perma.cc/3PPL-BWER . 21 In-Your-Face DOJ Aide Rides…Acting Attorney General Blanche and FBI Director Kash Patel Hold a Press Conference, U.S. Dep't of Just., at 25:04-27:05 (YouTube, Apr. 21, 2026), https - 116. RETRIEVED EVIDENCE:
Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29,
2025),
https://perma.cc/RWM6-6HAN
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467
the consideration of Director Brennan'slegal and constitutional challenges to any future criminal charges.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA…....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct - 117. RETRIEVED EVIDENCE:
PARTIES
13.
GOVERNING EVIDENCE:
3 PARTIES…of Director Brennan's legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in…public interest, as "it is always in the public interest to prevent the violation of a party's constitutional rights." Gayle v. Meade, 614 F. Supp. 3d 1175, 1206 (S.D. Fla - 118. RETRIEVED EVIDENCE:
Plaintiff John O.
GOVERNING EVIDENCE:
FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…perform a duty owed to the plaintiff." Case 1:26-cv-02323 - 119. RETRIEVED EVIDENCE:
Brennan is the target of agrand jury investigation in Washington, D.C.
GOVERNING EVIDENCE:
07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has - 120. RETRIEVED EVIDENCE:
and of investigations in two grand juries in the Southern District of Florida.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W…A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming - 121. RETRIEVED EVIDENCE:
He is aformer director of the CIA, and he resides in the Commonwealth of Virginia.
GOVERNING EVIDENCE:
as Director of the Federal…the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation - 122. RETRIEVED EVIDENCE:
14.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 123. RETRIEVED EVIDENCE:
Director Brennan's federal government service, which began in August 1980, spanned six Administrations-three Republican and three Democratic.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 124. RETRIEVED EVIDENCE:
In his 25-year career as a CIA officer, he served in a variety of positions of increasing responsibility, including:
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 125. RETRIEVED EVIDENCE:
intelligence analyst on the Middle East and counterterrorism specialist (1980-96);
GOVERNING EVIDENCE:
Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323…Agency; the Central Intelligence Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due…- three Republican and three Democratic - in a wide variety of national security and intelligence positions. His public service career culminated in his term as the Director of the…serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016…grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice Department have succumbed - 126. RETRIEVED EVIDENCE:
political officer at the U.S.
Embassy in Saudi Arabia (1982-84) while assigned to the Department of State during the Reagan Administration;
GOVERNING EVIDENCE:
and pressure the President's political and personal adversaries." In re…federal government service, which began in August 1980, spanned six Administrations-three Republican and three Democratic. In his 25-year career as a CIA officer, he served in a variety of positions of increasing responsibility, including…intelligence analyst on the Middle East and counterterrorism specialist (1980-96); political officer at the U.S. Embassy in Saudi Arabia (1982-84) while assigned to the Department of State during the Reagan Administration; briefer to President George H.W…Gulf War (1990-91); daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95); senior U.S. intelligence official resident in Saudi Arabia (1996-99); Chief of…States Senate confirmed Director Brennan, who has never registered as a member of any political party, as Director of the CIA in a bipartisan 63-34 vote on March 7, 2013. He was sworn into office the following day and served as - 127. RETRIEVED EVIDENCE:
briefer to President George H.W.
GOVERNING EVIDENCE:
07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 128. RETRIEVED EVIDENCE:
Bush and senior Administration officials in the run-up to the First Gulf War (1990-91);
GOVERNING EVIDENCE:
Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes - 129. RETRIEVED EVIDENCE:
daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95);
GOVERNING EVIDENCE:
Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years - 130. RETRIEVED EVIDENCE:
senior U.S. intelligence official resident in Saudi Arabia
(1996-99);
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 131. RETRIEVED EVIDENCE:
Chief of Staff to Director of Central Intelligence George Tenet (1999-2001);
GOVERNING EVIDENCE:
P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935…the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of…Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of - 132. RETRIEVED EVIDENCE:
and,
Deputy Executive Director of the CIA (2001-03).
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…Central Intelligence Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United…grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice Department have succumbed…and senior Administration officials in the run-up to the First Gulf War (1990-91); daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95); senior U.S. intelligence official resident in Saudi Arabia (1996-99); Chief of Staff to Director of Central Intelligence George Tenet (1999-2001); and, Deputy Executive Director of the CIA (2001-03). As testament to the confidence placed in his - 133. RETRIEVED EVIDENCE:
As testament to the confidence placed in his leadership skills and national security expertise, Director Brennan was selected in 2003 to design and serve as the founding director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W.
GOVERNING EVIDENCE:
FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford - 134. RETRIEVED EVIDENCE:
Bush to address the lack of interagency collaboration within the U.S.
counterterrorism community that contributed to the failure to prevent the 9/11 terrorist attacks.
GOVERNING EVIDENCE:
Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…Director Brennan was selected in 2003 to design and serve as the founding director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W. Bush to address the lack of interagency collaboration within the U.S. counterterrorism community that contributed to the failure to prevent the 9/11 terrorist attacks. 15. Following his retirement from the CIA in 2005, Director Brennan returned to…Brennan played a lead role in shaping and coordinating Obama Administration policies on counterterrorism, including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama Administration policies - 135. RETRIEVED EVIDENCE:
15.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 136. RETRIEVED EVIDENCE:
Following his retirement from the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and Counterterrorism and Deputy National Security Advisor in the Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 11 of 468
Executive Office of the President.
GOVERNING EVIDENCE:
the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 137. RETRIEVED EVIDENCE:
During his more than four years at the White House from January 2009 to March 2013, Director Brennan played alead role in shaping and coordinating Obama Administration policies on counterterrorism, including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network.
GOVERNING EVIDENCE:
official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation - 138. RETRIEVED EVIDENCE:
He also was responsible during this time for orchestrating Obama Administration policies on homeland security, pandemics, cyberattacks, and natural disasters.
GOVERNING EVIDENCE:
E. The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct ....................................…concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice - 139. RETRIEVED EVIDENCE:
16.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 140. RETRIEVED EVIDENCE:
The United States Senate confirmed Director Brennan, who has never registered as amember of any political party, as Director of the CIA in a bipartisan 63-34 vote on March 7,
2013.
GOVERNING EVIDENCE:
99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation…Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product - 141. RETRIEVED EVIDENCE:
He was sworn into office the following day and served as CIA Director until January 20,
2017.
GOVERNING EVIDENCE:
his official capacity as Director of the Federal Bureau of Investigation…the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation - 142. RETRIEVED EVIDENCE:
As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and liaison relationships with foreign intelligence services.
GOVERNING EVIDENCE:
P. PATEL, in his official capacity as Director of the Federal Bureau of…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation - 143. RETRIEVED EVIDENCE:
He testified to Congressional Committees dozens of times as Director and was unwavering in his commitment to carry out his responsibilities in anonpartisan, apolitical, and objective manner.
GOVERNING EVIDENCE:
JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A, 2022R00519-B…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 144. RETRIEVED EVIDENCE:
While Director, Plaintiff initiated amajor reorganization of the CIA - the first in over 50 years
- in order to position the CIA to deal more effectively with the national security challenges of the future.
GOVERNING EVIDENCE:
seal, Plaintiff v. TODD…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation…Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product - 145. RETRIEVED EVIDENCE:
The resulting new organizational structure remains in place to this day.
GOVERNING EVIDENCE:
16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda…target Director Brennan, there is no intent to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that…Brennan's constitutional rights and will serve as the basis for challenges to any resulting charges, including motions to dismiss any indictment on the grounds that it is the result of selective and vindictive prosecution. 8. To fully consider those motions, the…serve as the founding director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W…CIA to deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the recipient of numerous awards - 146. RETRIEVED EVIDENCE:
17.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 147. RETRIEVED EVIDENCE:
Director Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA Distinguished Career Intelligence Medal, the CIA Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal.
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even - 148. RETRIEVED EVIDENCE:
18.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 149. RETRIEVED EVIDENCE:
Defendant Todd W.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of…his official capacity. 21. Defendant Joseph E. diGenova has served as - 150. RETRIEVED EVIDENCE:
Blanche is the Acting Attorney General of the United States.
GOVERNING EVIDENCE:
O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to - 151. RETRIEVED EVIDENCE:
He leads the Department of Justice and has been in this position since April 2026.
GOVERNING EVIDENCE:
this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…Republican and three Democratic - in a wide variety of national security and intelligence positions. His public service career culminated in his term as the Director of the Central…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016 presidential - 152. RETRIEVED EVIDENCE:
In that role, he has Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 12 of 469
responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and - 153. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of - 154. RETRIEVED EVIDENCE:
19.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 155. RETRIEVED EVIDENCE:
Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan - 156. RETRIEVED EVIDENCE:
It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE - 157. RETRIEVED EVIDENCE:
20.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 158. RETRIEVED EVIDENCE:
Defendant Jason A.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of…his official capacity. 21. Defendant Joseph E. diGenova has served as - 159. RETRIEVED EVIDENCE:
Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 160. RETRIEVED EVIDENCE:
In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and - 161. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of - 162. RETRIEVED EVIDENCE:
21.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 163. RETRIEVED EVIDENCE:
Defendant Joseph E.
GOVERNING EVIDENCE:
99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws - 164. RETRIEVED EVIDENCE:
diGenova has served as Counselor to the Attorney General since April 20, 2026.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been…Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…Republican and three Democratic. In his 25-year career as a CIA officer, he served in a variety of positions of increasing responsibility, including: intelligence analyst - 165. RETRIEVED EVIDENCE:
He has been assigned to lead the investigations into the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress.
GOVERNING EVIDENCE:
Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 166. RETRIEVED EVIDENCE:
In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and - 167. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of - 168. RETRIEVED EVIDENCE:
22.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 169. RETRIEVED EVIDENCE:
Defendant Kash P.
GOVERNING EVIDENCE:
4th Street Miami, FL 33132 KASH P. PATEL, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of - 170. RETRIEVED EVIDENCE:
Patel has served as the Director of the FBI since February 20, 2025.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel - 171. RETRIEVED EVIDENCE:
He supervises FBI agents and other personnel who are working on the Brennan investigations.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda…Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct ....................................…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming - 172. RETRIEVED EVIDENCE:
In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and - 173. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of - 174. RETRIEVED EVIDENCE:
23.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 175. RETRIEVED EVIDENCE:
Defendant Donald J.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of…his official capacity. 21. Defendant Joseph E. diGenova has served as - 176. RETRIEVED EVIDENCE:
Trump has served as the President of the United States since January 20, 2025.
GOVERNING EVIDENCE:
935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 177. RETRIEVED EVIDENCE:
He previously served as the President from January 20, 2017 to January 20,
2021.
GOVERNING EVIDENCE:
1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years - 178. RETRIEVED EVIDENCE:
As the President, he has responsibility over Executive Branch subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…38 REQUEST FOR RELIEF…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 179. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of - 180. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 13 of 4610
24.
GOVERNING EVIDENCE:
of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director - 181. RETRIEVED EVIDENCE:
Defendant Executive Office of the President provides operational and management support to the President.
GOVERNING EVIDENCE:
16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 182. RETRIEVED EVIDENCE:
It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE - 183. RETRIEVED EVIDENCE:
25.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 184. RETRIEVED EVIDENCE:
Defendant Susan L.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of…his official capacity. 21. Defendant Joseph E. diGenova has served as - 185. RETRIEVED EVIDENCE:
Wiles has served as the White House Chief of Staff since January 20,
2025.
GOVERNING EVIDENCE:
Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff…Central Intelligence Agency ("CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017…overreaching actions have violated Director Brennan's constitutional rights and will serve as the basis for challenges to any resulting charges, including motions to dismiss any…Republican and three Democratic. In his 25-year career as a CIA officer, he served in a variety of positions of increasing responsibility, including: intelligence analyst…and national security expertise, Director Brennan was selected in 2003 to design and serve as the founding director of the Terrorist Threat Integration Center and of its successor…returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and Counterterrorism and Deputy - 186. RETRIEVED EVIDENCE:
In that role, she has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and - 187. RETRIEVED EVIDENCE:
She is sued in her official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of - 188. RETRIEVED EVIDENCE:
26.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 189. RETRIEVED EVIDENCE:
Defendant John L.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of…his official capacity. 21. Defendant Joseph E. diGenova has served as - 190. RETRIEVED EVIDENCE:
Ratcliffe has served as the current Director of the CIA since January
23, 2025.
GOVERNING EVIDENCE:
N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington…Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation - 191. RETRIEVED EVIDENCE:
In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and - 192. RETRIEVED EVIDENCE:
He is sued in his official capacity.
GOVERNING EVIDENCE:
Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES…Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of - 193. RETRIEVED EVIDENCE:
27.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 194. RETRIEVED EVIDENCE:
Defendant Central Intelligence Agency is an agency that engages in intelligence operations and analysis for the U.S. government.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE - 195. RETRIEVED EVIDENCE:
It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE - 196. RETRIEVED EVIDENCE:
28.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 197. RETRIEVED EVIDENCE:
Defendant Office of the Director of National Intelligence is an agency that provides oversight to the intelligence community.
GOVERNING EVIDENCE:
Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW…the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 198. RETRIEVED EVIDENCE:
It includes government personnel and record systems that would have the records to be preserved under the requested injunctive relief.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE - 199. RETRIEVED EVIDENCE:
JURISDICTION AND VENUE
29.
GOVERNING EVIDENCE:
7 JURISDICTION AND VENUE…that would have the records to be preserved under the requested injunctive relief. JURISDICTION AND VENUE 29. This Court has jurisdiction under 28 U.S.C. 1331, which provides that "[t]he district courts shall have original…the Constitution, laws, or treaties of the United States." Id. This Court also has jurisdiction pursuant to 28 U.S.C. 1361, which grants original jurisdiction to the district…owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in this district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events…Deputy Attorney General and FBI Director - work in the District of Columbia. Finally, there is venue under 28 U.S.C. 1391(e)(1)(A) because a defendant in the action resides in the…to 28 U.S.C. 1361 and 1651. COUNT 3 Injunctive Relief in Aid Of The Court's Jurisdiction Under the All Writs Act (28 U.S.C. 1651) 75. Director Brennan re-alleges and - 200. RETRIEVED EVIDENCE:
This Court has jurisdiction under 28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal - 201. RETRIEVED EVIDENCE:
1331, which provides that "[t]he district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States." Id.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal - 202. RETRIEVED EVIDENCE:
This Court also has jurisdiction pursuant to 28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason - 203. RETRIEVED EVIDENCE:
1361,
which grants original jurisdiction to the district courts over "any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform aduty owed to the plaintiff."
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611
30.
GOVERNING EVIDENCE:
OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…that would have the records to be preserved under the requested injunctive relief. JURISDICTION AND VENUE 29. This Court has jurisdiction under 28 U.S.C. 1331, which provides that "[t]he district courts shall have original…under the Constitution, laws, or treaties of the United States." Id. This Court also has jurisdiction pursuant to 28 U.S.C. 1361, which grants original jurisdiction to the district courts over "any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in - 204. RETRIEVED EVIDENCE:
Venue lies in this district under 28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates…the records to be preserved under the requested injunctive relief. JURISDICTION AND VENUE 29. This Court has jurisdiction under 28 U.S.C. 1331, which provides that "[t]he - 205. RETRIEVED EVIDENCE:
1391(e)(1)(B) because a "substantial part of the events or omissions" has occurred or is occurring in the District of Columbia.
GOVERNING EVIDENCE:
Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates…Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in this district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events or omissions" has occurred or is occurring in the District of Columbia. A grand jury in the District of Columbia opened an - 206. RETRIEVED EVIDENCE:
Agrand jury in the District of Columbia opened an investigation and issued subpoenas in relation to the allegation that Director Brennan made false statements to Congress.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel - 207. RETRIEVED EVIDENCE:
The government prosecutors have informed Director Brennan that any false-statements case must be filed in the District of Columbia because that is where the allegedly criminal act occurred.
GOVERNING EVIDENCE:
L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…Investigation ....................................................... 12 B. The False-Statements Investigation .........................................................…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ...................................................................…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 208. RETRIEVED EVIDENCE:
Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the decision-making and coordination by Obama and Biden Administration officials that current Justice Department officials consider to be overt acts in furtherance of aconspiracy to deny President Trump his civil rights.
GOVERNING EVIDENCE:
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney…950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency - 209. RETRIEVED EVIDENCE:
Moreover, a number of the Justice Department officials making decisions about the investigations - including the Acting Attorney General, Deputy Attorney General and FBI Director - work in the District of Columbia.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 210. RETRIEVED EVIDENCE:
Finally, there is venue under 28
U.S.C.
GOVERNING EVIDENCE:
JURISDICTION AND VENUE…owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in this district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events…General, Deputy Attorney General and FBI Director - work in the District of Columbia. Finally, there is venue under 28 U.S.C. 1391(e)(1)(A) because a defendant in the action resides in the…documents case against President Trump was manufactured by the Biden Administration. 30 Finally, diGenova has publicly pronounced Director Brennan guilty of participation in the…weaponization" (see supra note 47), but the post was deleted from his X account the next morning. 61 Finally, in a recent challenge to the Administration's mass terminations of government employees, discovery…//perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 36 of 4633 charges. When the judge finally received and reviewed unredacted copies of the transcripts, she observed, "I have never - 211. RETRIEVED EVIDENCE:
1391(e)(1)(A) because a defendant in the action resides in the District of Columbia, i.e.,
the Department of Justice is located at 950 Pennsylvania Ave.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E…Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump - 212. RETRIEVED EVIDENCE:
NW, Washington, D.C.
GOVERNING EVIDENCE:
in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the…capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed…THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF - 213. RETRIEVED EVIDENCE:
20530,
and the Executive Office of the President is located at 1600 Pennsylvania Ave.
GOVERNING EVIDENCE:
P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss - 214. RETRIEVED EVIDENCE:
NW,
Washington, D.C.
GOVERNING EVIDENCE:
in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the…capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed…THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF - 215. RETRIEVED EVIDENCE:
20500.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 216. RETRIEVED EVIDENCE:
STANDING
31.
GOVERNING EVIDENCE:
10 STANDING…of the President is located at 1600 Pennsylvania Ave. NW, Washington, D.C. 20500. STANDING 31. Director Brennan has standing because he has been, or imminently will be, injured as a result of the Defendants…Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between - 217. RETRIEVED EVIDENCE:
Director Brennan has standing because he has been, or imminently will be, injured as aresult of the Defendants' conduct.
GOVERNING EVIDENCE:
Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 218. RETRIEVED EVIDENCE:
See U.S. Const.
GOVERNING EVIDENCE:
been, or imminently will be, injured as a result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 219. RETRIEVED EVIDENCE:
art.
GOVERNING EVIDENCE:
been, or imminently will be, injured as a result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish - 220. RETRIEVED EVIDENCE:
III, 2;
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 221. RETRIEVED EVIDENCE:
Lujan v.
GOVERNING EVIDENCE:
be, injured as a result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff…or defendants, and a likelihood that the injury will be redressed by a favorable decision. Lujan, 504 U.S. at 560-61. Here, Director Brennan meets those three requirements. The injury is - 222. RETRIEVED EVIDENCE:
Defs.
GOVERNING EVIDENCE:
as a result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must - 223. RETRIEVED EVIDENCE:
of Wildlife, 504
U.S. 555, 561 (1992).
GOVERNING EVIDENCE:
result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 224. RETRIEVED EVIDENCE:
To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct by the defendant or defendants, and alikelihood that the injury will be redressed by a favorable decision.
GOVERNING EVIDENCE:
of address filed under seal, Plaintiff v. TODD W. BLANCHE, in…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of - 225. RETRIEVED EVIDENCE:
Lujan, 504 U.S. at 560-61.
GOVERNING EVIDENCE:
be, injured as a result of the Defendants' conduct. See U.S. Const. art. III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff…or defendants, and a likelihood that the injury will be redressed by a favorable decision. Lujan, 504 U.S. at 560-61. Here, Director Brennan meets those three requirements. The injury is…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 226. RETRIEVED EVIDENCE:
Here, Director Brennan meets those three requirements.
GOVERNING EVIDENCE:
FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave…Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 227. RETRIEVED EVIDENCE:
The injury is the very real prospect that the government will fail to preserve the records he would need to challenge an indictment and Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 15 of 4612
protect his Due Process and Equal Protection rights not to be vindictively or selectively prosecuted.
GOVERNING EVIDENCE:
Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution - 228. RETRIEVED EVIDENCE:
That injury will be directly due to the government'saction - or inaction - in regard to its preservation obligations, and the injury will be directly redressed by a judicial injunction ordering the government to preserve those records.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE - 229. RETRIEVED EVIDENCE:
FACTUAL BACKGROUND I.
GOVERNING EVIDENCE:
11 FACTUAL BACKGROUND…by a judicial injunction ordering the government to preserve those records. FACTUAL BACKGROUND I. The Justice Department has Opened Two Criminal Investigations that Target Director…Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution 51. This background provides a strong factual foundation for moving to dismiss any indictment that may - 230. RETRIEVED EVIDENCE:
The Justice Department has Opened Two Criminal Investigations that Target Director Brennan
32.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel - 231. RETRIEVED EVIDENCE:
There are currently two ongoing federal grand jury investigations examining past conduct by Director Brennan.
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg - 232. RETRIEVED EVIDENCE:
According to conversations with the supervising prosecutors, Director Brennan has been officially designated as the target - in fact, so far as undersigned counsel is aware, the only currently declared target - of both investigations.
GOVERNING EVIDENCE:
20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…1 Filed 07/01/26 Page 8 of 465 personnel who had worked on the ICA, requiring them to testify before the grand jury in the false-statements investigation. Those subpoenas were…need to scrutinize the motivations of the Justice Department officials who directed, oversaw, or undertook those actions to determine whether they violated Director Brennan's rights, and…counterintelligence, and liaison relationships with foreign intelligence services. He testified to Congressional Committees dozens of times as Director and was unwavering in his…Kash P. Patel has served as the Director of the FBI since February 20, 2025. He supervises FBI agents and other personnel who are working on the Brennan investigations. In that - 233. RETRIEVED EVIDENCE:
These two investigations are the product of acarefully orchestrated series of referrals claiming Director Brennan's involvement in theoretical criminal activity.
GOVERNING EVIDENCE:
has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from - 234. RETRIEVED EVIDENCE:
A.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 235. RETRIEVED EVIDENCE:
The Grand Conspiracy Investigation
33.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…with the Two Brennan Investigations…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions - 236. RETRIEVED EVIDENCE:
The "grand conspiracy" investigation originated with two Intelligence Community pronouncements about Director Brennan'sactivities relating to the ICA - one by CIA Director John Ratcliffe on July 8, 2025 and the second by then-Director of National Intelligence Tulsi Gabbard ten days later.
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 237. RETRIEVED EVIDENCE:
Both referrals were styled and publicly trumpeted as "criminal referrals,"
despite their failure to explain how the activities they describe constitute acrime.
GOVERNING EVIDENCE:
Justice Department Officials Publicly Discuss Grand Jury…his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his…that purport to be investigating Director Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand…record that many in the Administration and in the Justice Department specifically are failing to observe their legal obligation to maintain such records. 11. The loss of these…collaboration within the U.S. counterterrorism community that contributed to the failure to prevent the 9/11 terrorist attacks. 15. Following his retirement from the CIA in…meets those three requirements. The injury is the very real prospect that the government will fail to preserve the records he would need to challenge an indictment and Case 1:26-cv-02323 - 238. RETRIEVED EVIDENCE:
Notwithstanding the lack of that critical predicate, President Trump's Justice Department dutifully established a "strike force" to investigate whether Director Brennan, President Obama and numerous other Obama and Biden Administration officials conspired to deny President Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 16 of 4613
Trump his civil rights with the series of federal investigations and prosecutions relating to the
2016 election and to President Trump'sconduct in and out of office.
GOVERNING EVIDENCE:
Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 239. RETRIEVED EVIDENCE:
3
B.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 240. RETRIEVED EVIDENCE:
The False-Statements Investigation
34.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in - 241. RETRIEVED EVIDENCE:
The false-statements investigation originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi.
GOVERNING EVIDENCE:
to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in - 242. RETRIEVED EVIDENCE:
4
In that letter, Chairman Jordan, aclose ally of President Trump, refers for investigation - without any valid factual basis - an allegation that Director Brennan lied in
2023 testimony before the House Judiciary Committee when he discussed the role of the Steele Dossier (which was reportedly a batch of materials about then candidate Trump that had been assembled as opposition research by aformer British intelligence officer)
5
in the production of the ICA.
GOVERNING EVIDENCE:
Investigation ....................................................... 12 B. The False-Statements Investigation…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions…He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal…and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice - 243. RETRIEVED EVIDENCE:
II.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 244. RETRIEVED EVIDENCE:
The Government has Engaged, and Continues to Engage, in Unprecedented,
Irregular Conduct in Connection with the Two Brennan Investigations
35.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 245. RETRIEVED EVIDENCE:
Justice Department officials have engaged in avariety of inappropriate activities in their attempt to build aprosecutable case on the hollow foundation of these "criminal referrals."
3
Hannah Rabinowitz, Attorney General Bondi Orders Prosecutors to Start Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug.
GOVERNING EVIDENCE:
Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump - 246. RETRIEVED EVIDENCE:
4, 2025),
https://perma.cc/HCG8
H5KJ
;
GOVERNING EVIDENCE:
Private Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 247. RETRIEVED EVIDENCE:
Press Release, U.S. Dep'tof Just., Justice Department Announces Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025),
https://perma.cc/ZFX6-KC5A
;
GOVERNING EVIDENCE:
THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016 presidential election in an…his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand - 248. RETRIEVED EVIDENCE:
Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Investigation into Russiagate Conspiracy Allegations:
GOVERNING EVIDENCE:
Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently…two sets of grand jury subpoenas - one set seeking documents relating to the supposed "grand conspiracy" and the other relating to Director Brennan's alleged false statements to…General since April 20, 2026. He has been assigned to lead the investigations into the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress. In that…the allegedly criminal act occurred. Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the decision-making and…claiming Director Brennan's involvement in theoretical criminal activity. A. The Grand Conspiracy Investigation 33. The "grand conspiracy" investigation originated with two Intelligence Community pronouncements about Director - 249. RETRIEVED EVIDENCE:
Sources, Fox News (Aug.
GOVERNING EVIDENCE:
Gibson, DOJ Launching Grand Jury Investigation into Russiagate Conspiracy Allegations: Sources, Fox News (Aug. 4, 2025), https://perma.cc/Q5JS XTZQ ; LA Times Studios, Straight to the Point: The…h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with…her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https…in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the…CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean - 250. RETRIEVED EVIDENCE:
4, 2025),
https://perma.cc/Q5JS XTZQ
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 251. RETRIEVED EVIDENCE:
LA Times Studios, Straight to the Point:
GOVERNING EVIDENCE:
will not be preserved until such time as the court can review them for evidence of unconstitutional…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…of 467 the consideration of Director Brennan's legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand…that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama Administration policies on homeland security, pandemics…with foreign intelligence services. He testified to Congressional Committees dozens of times as Director and was unwavering in his commitment to carry out his responsibilities in a - 252. RETRIEVED EVIDENCE:
The Grand Conspiracy Against Trump
(YouTube, May 7, 2026),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L…election in an effort to boost candidate Donald Trump's chances of winning the election. In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that - 253. RETRIEVED EVIDENCE:
v=h03Rtq3SwYM
(
https://perma.cc/7EBH-NGDC on file with Plaintiff);
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in - 254. RETRIEVED EVIDENCE:
Hang out with Sean Hannity & Fox News,
Kash Patel Uncovers Secret FBI Documents;
GOVERNING EVIDENCE:
from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions…He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are converting the Justice - 255. RETRIEVED EVIDENCE:
The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
XTZQ ; LA Times Studios, Straight to the Point: The Grand Conspiracy Against Trump (YouTube, May 7, 2026), https://www.youtube.com/watch?v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim…Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts…//perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v=wMZHAfSQ9vo ( https - 256. RETRIEVED EVIDENCE:
v=0zhi1bmlIjc
(
https://perma.cc/QZ2H-WYLZ on file with Plaintiff).
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in - 257. RETRIEVED EVIDENCE:
4
Letter from Jim Jordan, Chairman of the H.
GOVERNING EVIDENCE:
federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the…The second investigation centers on an October 21, 2025 referral from Congressman Jim Jordan, Chairman of the House Judiciary Committee, which asserts without valid support that Director…34. The false-statements investigation originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi. 4 In that letter, Chairman Jordan, a close ally of President Trump, refers for investigation - without any valid factual…v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S.…Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had - 258. RETRIEVED EVIDENCE:
Comm.
GOVERNING EVIDENCE:
on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S. Dep't of Just…Nov. 17, 2025), https://perma.cc/BG4A-UB6V ; Letter from Jamie Raskin, Ranking Member, H. Comm. on the Judiciary, to Edward P. Martin, Jr., Pardon Att'y and Dir., Weaponization…into allegations that he lied in his testimony to the House of Representatives Committee on the Judiciary on May 11, 2023 and the investigation into the "grand conspiracy" being - 259. RETRIEVED EVIDENCE:
on the Judiciary, 119th Cong., to Pamela J.
GOVERNING EVIDENCE:
of crimes ranging from treason to lying before Congress, and has twice posted doctored images of…conspiracy" and the other relating to Director Brennan's alleged false statements to Congress. Then, over the weekend of April 18, 2026, a federal grand jury in Washington, D.C…and liaison relationships with foreign intelligence services. He testified to Congressional Committees dozens of times as Director and was unwavering in his commitment to carry out…the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress. In that role, he has responsibility over subordinates and record systems that would…subpoenas in relation to the allegation that Director Brennan made false statements to Congress. The government prosecutors have informed Director Brennan that any false-statements…with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S. Dep't of Just. (Oct. 21, 2025), https - 260. RETRIEVED EVIDENCE:
Bondi, Att'y Gen., U.S. Dep'tof Just.
GOVERNING EVIDENCE:
2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases…Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces Formation of Strike Force to Assess Evidence…of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S. Dep't of Just. (Oct. 21, 2025), https://perma.cc/R257-56FL . 5 Trump-Russia Steele…https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009), https://perma.cc/W55M-M7FW (Eric Holder 2009 memo). 20 Memorandum from the Attorney General to All Dep't Emps. (Feb. 5, 2025), https://perma.cc/3PPL-BWER . 21 In-Your-Face DOJ Aide Rides Prosecutors - 261. RETRIEVED EVIDENCE:
(Oct.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 262. RETRIEVED EVIDENCE:
21, 2025),
https://perma.cc/R257-56FL
.
5
Trump-Russia Steele Dossier Source Acquitted of Lying to FBI, BBC (Oct.
GOVERNING EVIDENCE:
from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions…the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016 presidential election in an effort to boost candidate Donald…Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership - 263. RETRIEVED EVIDENCE:
18, 2022),
https://perma.cc/2P43-BQ34
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 17 of 4614
Among those activities have been the following:
GOVERNING EVIDENCE:
Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the…in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of - 264. RETRIEVED EVIDENCE:
issuing pronouncements that evince a pre conceived belief in Director Brennan's guilt;
GOVERNING EVIDENCE:
official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation - 265. RETRIEVED EVIDENCE:
6
making statements that disclose matters relating to open grand jury investigations, in apparent violation of Federal Rule of Criminal Procedure
6(e);
GOVERNING EVIDENCE:
Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming - 266. RETRIEVED EVIDENCE:
7
reportedly removing or sidelining career prosecutors who have balked at using the criminal process to promote the President'sretribution agenda;
GOVERNING EVIDENCE:
Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda…Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and…irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these - 267. RETRIEVED EVIDENCE:
8
engaging in apparent forum-shopping by moving the investigations from federal district to federal district in an effort to find a sufficiently pliant United States Attorney;
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 268. RETRIEVED EVIDENCE:
9
and engaging in apparent judge-shopping.
GOVERNING EVIDENCE:
13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of…quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will…Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 - 269. RETRIEVED EVIDENCE:
10
36.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 270. RETRIEVED EVIDENCE:
The scale of this manipulative activity came into focus throughout the fall of 2025, and by December 2025, it became clear that the government was seeking to circumvent standard processes and engineer assignment of the investigation and eventual prosecution of Director Brennan to the docket of a particular judge.
GOVERNING EVIDENCE:
Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to…and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record…issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made…With his return to the White House, the President has gone beyond mere denunciation, and has actively mobilized the machinery of the criminal justice system against Director Brennan. He has…interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second - 271. RETRIEVED EVIDENCE:
That concern became so pronounced that undersigned counsel submitted aletter to the Chief Judge of the Southern District of Florida alerting her to the government's judge-shopping and asking that she use her supervisory
6
Fox News, DiGenova:
GOVERNING EVIDENCE:
vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those…of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw, or undertook those actions to determine whether they violated Director Brennan's rights, and - 272. RETRIEVED EVIDENCE:
John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018)
(clip of Fox News television broadcast),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has…Launching Grand Jury Investigation into Russiagate Conspiracy Allegations: Sources, Fox News (Aug. 4, 2025), https://perma.cc/Q5JS XTZQ ; LA Times Studios, Straight to the Point: The Grand Conspiracy Against Trump (YouTube, May 7, 2026), https://www.youtube.com/watch?v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim Jordan - 273. RETRIEVED EVIDENCE:
v=e7v22N2QrW8
(
https://perma.cc/W5XD-GR43
on file with Plaintiff);
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in - 274. RETRIEVED EVIDENCE:
Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr.
GOVERNING EVIDENCE:
and Communications to Assess the Prosecutors' Motivations…past conduct by Director Brennan. According to conversations with the supervising prosecutors, Director Brennan has been officially designated as the target - in fact, so far as…of these "criminal referrals." 3 Hannah Rabinowitz, Attorney General Bondi Orders Prosecutors to Start Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4…of Federal Rule of Criminal Procedure 6(e); 7 reportedly removing or sidelining career prosecutors who have balked at using the criminal process to promote the President's retribution…v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https://perma.cc/3LTF-UPW2 . 7 Appendix A, at 15-16. 8 Eric Tucker, Key Prosecutor in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr - 275. RETRIEVED EVIDENCE:
27, 2026),
https://perma.cc/3LTF-UPW2
.
7
Appendix A, at 15-16.
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 276. RETRIEVED EVIDENCE:
8
Eric Tucker, Key Prosecutor in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions - 277. RETRIEVED EVIDENCE:
17, 2026),
https://perma.cc/4362-XJE5
.
9
Appendix A, at8.
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 278. RETRIEVED EVIDENCE:
As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had migrated through the U.S. Attorneys' Offices for the Eastern District of Pennsylvania and the Eastern District of Virginia before finding ahome in SDFL.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 - 279. RETRIEVED EVIDENCE:
Recent reporting indicates that FBI Director Kash Patel also shopped the investigations to the Western District of Virginia in July 2025.
GOVERNING EVIDENCE:
Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE…Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel - 280. RETRIEVED EVIDENCE:
See Devlin Barrett, How the Drive to Find a Conspiracy Against Trump Rocked the Justice Dept., N.Y.
GOVERNING EVIDENCE:
NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A…13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case - 281. RETRIEVED EVIDENCE:
Times (June 8, 2026),
https://perma.cc/63DZ-3KUH
.
10
Appendix A, at 10-11.
GOVERNING EVIDENCE:
will not be preserved until such time as the court can review them for evidence of…potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1…as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying before…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…of 467 the consideration of Director Brennan's legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand - 282. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 18 of 4615
authority to ensure that any judicial assignment be done pursuant to the court's neutral and impartial processes.
GOVERNING EVIDENCE:
24 IV. The Court Reviewing the Vindictive and Selective Prosecution…of selective and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who…of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9. To perform that scrutiny after an indictment, the Court would demand…relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery obligations. These technologies include…records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous…laws, or treaties of the United States." Id. This Court also has jurisdiction pursuant to 28 U.S.C. 1361, which grants original jurisdiction to the district courts over - 283. RETRIEVED EVIDENCE:
11
37.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 284. RETRIEVED EVIDENCE:
Despite the concerns laid out in that letter, the Justice Department remains seemingly committed to its plan to steer any investigation and eventual prosecution of the "grand conspiracy" case to the Fort Pierce Division of the Southern District of Florida and to the only judge in that Division - Judge Aileen Cannon.
GOVERNING EVIDENCE:
THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming - 285. RETRIEVED EVIDENCE:
This April, the prosecution team established its headquarters in the U.S. Attorney's Office in Fort Pierce.
GOVERNING EVIDENCE:
JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL…Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the…the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent - 286. RETRIEVED EVIDENCE:
12
Fort Pierce is situated approximately
130 miles away from the currently open grand juries and from the investigating personnel in the FBI field office and the main SDFL U.S. Attorney's Office in Miami.
GOVERNING EVIDENCE:
QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and - 287. RETRIEVED EVIDENCE:
It is five states away from Washington, D.C., where the vast majority of the supposed conspiratorial acts in the "grand conspiracy" took place.
GOVERNING EVIDENCE:
as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The…823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed…as publicly described by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the - 288. RETRIEVED EVIDENCE:
As such, the only apparent rationale for locating in Fort Pierce is to carry out the Justice Department's judge-shopping plan.
GOVERNING EVIDENCE:
THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016…of a conspiracy to deny President Trump his civil rights. The second investigation centers on an October 21, 2025 referral from Congressman Jim Jordan, Chairman of the House…to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small…and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw - 289. RETRIEVED EVIDENCE:
38.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 290. RETRIEVED EVIDENCE:
The letter to Chief Judge Altonaga lays out many of the government'sirregular actions up to that time.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 291. RETRIEVED EVIDENCE:
To avoid repeating their details here, that letter is incorporated by reference and included as Appendix A, and this complaint will focus on the occurrence of like incidents since its submission on December 22, 2025.
GOVERNING EVIDENCE:
TABLE OF CONTENTS Page i COMPLAINT…D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice Department have succumbed to pressure from the…widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small subset of officials, and the vast majority of Justice Department…be, pursuant to the government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such…of Justice is a federal agency responsible for enforcing federal criminal laws. It includes government personnel and record systems that would have the records to be preserved under the…Office of the President provides operational and management support to the President. It includes government personnel and record systems that would have the records to be preserved under the - 292. RETRIEVED EVIDENCE:
13
The record shows that government officials have not only maintained - but have actually increased - the pace of irregular activities over the past six months.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington - 293. RETRIEVED EVIDENCE:
This irregularity is evident in numerous areas of the government's conduct in this matter.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 294. RETRIEVED EVIDENCE:
11
See Letter from Counsel for Director John O.
GOVERNING EVIDENCE:
capacity as Director of the Federal Bureau…Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 295. RETRIEVED EVIDENCE:
Brennan to Chief Judge Cecilia M.
GOVERNING EVIDENCE:
in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…fully consider those motions, the reviewing judge would need to scrutinize the…effort to find a sufficiently pliant United States Attorney; 9 and engaging in apparent judge-shopping. 10 36. The scale of this manipulative activity came into focus throughout…the investigation and eventual prosecution of Director Brennan to the docket of a particular judge. That concern became so pronounced that undersigned counsel submitted a letter to the Chief Judge of the Southern District of Florida alerting her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan - 296. RETRIEVED EVIDENCE:
Altonaga,
U.S. Dist.
GOVERNING EVIDENCE:
from Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https://perma.cc/3UX5-XCMT (Appendix A). 12…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 297. RETRIEVED EVIDENCE:
Ct.
GOVERNING EVIDENCE:
Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https://perma.cc/3UX5-XCMT (Appendix A - 298. RETRIEVED EVIDENCE:
for S.D.
GOVERNING EVIDENCE:
Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https://perma.cc/3UX5-XCMT (Appendix A). 12 Paula…Authors Guild v. Nat'l Endowment for the Humanities, 2025 WL 3678097, at *12 (S.D.N.Y. Dec. 18, 2025). Finally, in a recent challenge to the termination of federal…of a party's constitutional rights." Gayle v. Meade, 614 F. Supp. 3d 1175, 1206 (S.D. Fla. 2020) (internal quotation marks omitted); see Honeyfund.com Inc. v. Governor of Florida - 299. RETRIEVED EVIDENCE:
Fla., at 15-16 (Dec.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia…Attorney for the Southern District of Florida since August 13, 2025. In - 300. RETRIEVED EVIDENCE:
22, 2025),
https://perma.cc/3UX5-XCMT
(Appendix A).
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 301. RETRIEVED EVIDENCE:
12
Paula Reld & Evan Perez, Justice Department Adds Former Trump Lawyer to Investigation of Trump Critic John Brennan, CNN (Apr.
GOVERNING EVIDENCE:
STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th…....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate - 302. RETRIEVED EVIDENCE:
18, 2026),
https://perma.cc/Z6XV-DNK3
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 303. RETRIEVED EVIDENCE:
Evan Perez
& Hannah Rabinowitz, Inside the Justice Department's Shakeup of the John Brennan Investigation, CNN (May 8, 2026),
https://perma.cc/S58G-9MTK
.
13
See generally Appendix A.
GOVERNING EVIDENCE:
UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama Administration…W. Blanche is the Acting Attorney General of the United States. He leads the Department of Justice and has been in this position since April 2026. In that role, he has Case 1:26-cv-02323…relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes…a defendant in the action resides in the District of Columbia, i.e., the Department of Justice is located at 950 Pennsylvania Ave. NW, Washington, D.C. 20530, and the Executive - 304. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 19 of 4616
A.
GOVERNING EVIDENCE:
of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director - 305. RETRIEVED EVIDENCE:
Administration Officials Call for Director Brennan's Prosecution
39.
GOVERNING EVIDENCE:
in his official capacity as…U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1 - 306. RETRIEVED EVIDENCE:
Administration officials have increased the drumbeat of explicit calls for Director Brennan'sprosecution over the course of this year.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1 - 307. RETRIEVED EVIDENCE:
For example, FBI Director Patel said, "We're going to continue to make people like Comey and Brennan and Clapper and Page and Strzok and so many others answer for what Ibelieve are their acts of criminal conduct."
14
Then, on June 2,
2026, in his interview with Sean Hannity, Acting Attorney General Blanche identified alleged members of the "grand conspiracy" as Director Brennan, Comey, Clapper, Biden and Obama and rendered the verdict that "those folks were ... certainly part of it."
15
40.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and - 308. RETRIEVED EVIDENCE:
The President has also continued to opine about Director Brennan'sguilt, recently reposting a Truth Social post stating that "Barack Obama and his CIA puppet John Brennan cooked up the entire Russia Hoax to steal the 2016 election and overthrow aduly elected President Trump."
16
More significantly, the President has affirmatively demanded that his Justice Department serve up aprosecution, posting a Truth Social message on May 11, 2026 expressly urging Acting Attorney General Blanche to indict Director Brennan, Hillary Clinton and President Obama,
17
and following up two weeks later with the posting of aconcocted image showing Director Brennan with seven other Obama Administration officials in orange
14
Katelyn Polantz, Hannah Rabinowitz & Evan Perez, Justice Department Leans on Prosecutors in Brennan Probe as Other Trump-Foe Investigations Fizzle, CNN (Mar.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants…11 FACTUAL BACKGROUND…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss - 309. RETRIEVED EVIDENCE:
10, 2026),
https://perma.cc/HNA6-LTUF
.
15
Hang Out with Sean Hannity & Fox News, Todd Blanche:
GOVERNING EVIDENCE:
v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc…Other Trump-Foe Investigations Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v…that Fox News felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean Hannity reminding the audience that none of the accused individuals has been charged with any…TzjzcAZauPc ( https://perma.cc/BAE6-YVH6 on file with Plaintiff). 32 Tamar Auber, Joe diGenova to Hannity: John Brennan is the "Real Traitor", Mediaite (July 18, 2018) (clip of Fox News - 310. RETRIEVED EVIDENCE:
The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube,
June 2, 2026),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
As in the above cases, the evidence of vindictiveness in this matter is…a very real risk, however, that some of these materials and communications will no longer exist by the time any such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government…AI queries, and the like that are not routinely preserved. 2 Second, there is ample evidence in the public record that many in the Administration and in the Justice Department…fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true…on pre-trial sanctions as a remedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 12. For this - 311. RETRIEVED EVIDENCE:
v=wMZHAfSQ9vo
(
https://perma.cc/9X48
5XX5
on file with Plaintiff).
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in - 312. RETRIEVED EVIDENCE:
The accusations in the interview were so pointed and unsupported that Fox News felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean Hannity reminding the audience that none of the accused individuals has been charged with any crime.
GOVERNING EVIDENCE:
and Truth Social posts to formal media interviews and Presidential statements -…despite their failure to explain how the activities they describe constitute a crime. Notwithstanding the lack of that critical predicate, President Trump's Justice…v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v…what I believe are their acts of criminal conduct." 14 Then, on June 2, 2026, in his interview with Sean Hannity, Acting Attorney General Blanche identified alleged members of the…Other Trump-Foe Investigations Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https - 313. RETRIEVED EVIDENCE:
See id.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 314. RETRIEVED EVIDENCE:
at 1:38:39-1:38:59.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 315. RETRIEVED EVIDENCE:
16
Donald J.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 316. RETRIEVED EVIDENCE:
Trump (@realDonaldTrump), Truth Social (May 11, 2026, at 22:15 ET),
https://perma.cc/D4JU-SWQV
.
17
Donald J.
GOVERNING EVIDENCE:
11 FACTUAL BACKGROUND…records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent…and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has…to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal…from Congressman Jim Jordan, Chairman of the House Judiciary Committee, which asserts without valid support that Director Brennan made false statements about the ICA in a 2023 interview…Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466 10. There is a very real risk, however, that some of these materials and communications will no longer exist by - 317. RETRIEVED EVIDENCE:
Trump (@realDonaldTrump), Truth Social (May 11, 2026, at 22:40 ET),
https://perma.cc/T2GH-LLC2
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 20 of 4617
jumpsuits.
GOVERNING EVIDENCE:
11 FACTUAL BACKGROUND…and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has…to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal…from Congressman Jim Jordan, Chairman of the House Judiciary Committee, which asserts without valid support that Director Brennan made false statements about the ICA in a 2023 interview…Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466 10. There is a very real risk, however, that some of these materials and communications will no longer exist by…the full record of contemporaneous communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions. And Director Brennan and the - 318. RETRIEVED EVIDENCE:
18
See Appendix Bfor a selection of President Trump'sposts and statements regarding Director Brennan.
GOVERNING EVIDENCE:
as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in…Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss - 319. RETRIEVED EVIDENCE:
41.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 320. RETRIEVED EVIDENCE:
The President's direct demand for action against Director Brennan has been taken to heart by this Justice Department.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & - 321. RETRIEVED EVIDENCE:
Contrary to the tradition of insulating prosecutorial decision making from White House influence,
19
the Justice Department leaders in this administration have shed any pretense of honoring such limitations and have unapologetically accepted direction on criminal cases from the White House.
GOVERNING EVIDENCE:
THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small subset of officials, and…W. Blanche is the Acting Attorney General of the United States. He leads the Department of Justice and has been in this position since April 2026. In that role, he has Case 1:26-cv-02323…relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes…a defendant in the action resides in the District of Columbia, i.e., the Department of Justice is located at 950 Pennsylvania Ave. NW, Washington, D.C. 20530, and the Executive…2025. See Devlin Barrett, How the Drive to Find a Conspiracy Against Trump Rocked the Justice Dept., N.Y. Times (June 8, 2026), https://perma.cc/63DZ-3KUH . 10 Appendix A, at 10-11. Case - 322. RETRIEVED EVIDENCE:
Soon after President Trump'sinauguration, then-Attorney General Bondi issued amemorandum advising Department attorneys that they are to serve the
"interests ... of the United States" as defined by the President and to serve as "his lawyers."
20
More recently, Associate Deputy Attorney General Aakash Singh gathered the United States Attorneys on avideo call and reminded them that President Trump is their "chief client."
21
42.
GOVERNING EVIDENCE:
official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 323. RETRIEVED EVIDENCE:
Acting Attorney General Blanche has made clear that this direction to consider President Trump as the "chief client" and act as "his lawyers" translates into allowing the President to dictate the Justice Department'sprosecutorial decision-making.
GOVERNING EVIDENCE:
of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P…26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has - 324. RETRIEVED EVIDENCE:
In recent comments defending the President's September 20, 2025, order to then-Attorney General Bondi to prosecute three of
18
Donald J.
GOVERNING EVIDENCE:
REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 325. RETRIEVED EVIDENCE:
Trump (@realDonaldTrump), Truth Social (May 24, 2026, at 08:01 ET),
https://perma.cc/PN5S-24D9
.
19
Since the post-Watergate era, successive administrations have adopted and largely followed policies limiting communications between the White House and the Justice Department about criminal matters.
GOVERNING EVIDENCE:
Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING…Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the…of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications…and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal - 326. RETRIEVED EVIDENCE:
These policies were designed to prevent both the reality and the appearance that the Department made charging and other prosecutorial decisions based on the political or personal preferences of the President and the White House.
GOVERNING EVIDENCE:
Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ......................…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A, 2022R00519-B…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these - 327. RETRIEVED EVIDENCE:
Justin Florence, On the Importance of Limiting White House-DOJ Contacts:
GOVERNING EVIDENCE:
on the political or personal preferences of the President and the White House. Justin Florence, On the Importance of Limiting White House-DOJ Contacts: It's Not Just About Obstruction, Lawfare (May 22, 2017), https://perma.cc/KS5W-NY27…might be tempted to follow President Trump's orders without regard to legal or ethical limitations. And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL…2. 51 Memorandum from William Fischer, Chief Records Officer, to Fed. Records Mgmt. Contacts (May 2, 2025), https://perma.cc/TAB5-E2ZX . 52 Bernd Debusmann Jr., Trump Deletes Post Depicting…for Crises Across the World, Politico (Apr. 2, 2025), https://perma.cc/6WKP-3K5W . Importantly, the messages about the Yemen strikes were ultimately deleted from the phone of CIA…07/01/26 Page 35 of 4632 memo 64 significantly limited the circumstances under which text communications need to be retained. 62. Importantly, the concern about the preservation of records of - 328. RETRIEVED EVIDENCE:
It's Not Just About Obstruction, Lawfare (May 22,
2017), https://perma.cc/KS5W-NY27;
GOVERNING EVIDENCE:
had interfered in the 2016…but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years…Florence, On the Importance of Limiting White House-DOJ Contacts: It's Not Just About Obstruction, Lawfare (May 22, 2017), https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to the Heads of Dep't Components, All U.S.…the right to "take appropriate action to prevent the bar disciplinary authorities from interfering with the Attorney General's review of the allegations." 45 And, the President himself is using…a controversial post indicating that the Department would pursue an alternative to the derailed plan to establish a fund to compensate victims of supposed "weaponization" (see supra…its interests. For example, in the prosecution of Congresswoman LaMonica McIver for interfering with federal officers during a fracas while conducting an oversight visit to an ICE - 329. RETRIEVED EVIDENCE:
Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009),
https://perma.cc/W55M-M7FW
(Eric Holder 2009 memo).
GOVERNING EVIDENCE:
In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on…Private Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How - 330. RETRIEVED EVIDENCE:
20
Memorandum from the Attorney General to All Dep't Emps.
GOVERNING EVIDENCE:
U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99…JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on - 331. RETRIEVED EVIDENCE:
(Feb.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 332. RETRIEVED EVIDENCE:
5, 2025),
https://perma.cc/3PPL-BWER
.
21
In-Your-Face DOJ Aide Rides Prosecutors for 'Chief Client' Trump, Bloomberg Law (Feb.
GOVERNING EVIDENCE:
and Communications to Assess the Prosecutors' Motivations…communications and materials that is needed to divine the true intentions behind the prosecutors' decisions and actions. And Director Brennan and the Court cannot rely on pre-trial…the allegation that Director Brennan made false statements to Congress. The government prosecutors have informed Director Brennan that any false-statements case must be filed in the…past conduct by Director Brennan. According to conversations with the supervising prosecutors, Director Brennan has been officially designated as the target - in fact, so far as…of these "criminal referrals." 3 Hannah Rabinowitz, Attorney General Bondi Orders Prosecutors to Start Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4…of Federal Rule of Criminal Procedure 6(e); 7 reportedly removing or sidelining career prosecutors who have balked at using the criminal process to promote the President's retribution - 333. RETRIEVED EVIDENCE:
19, 2026),
https://perma.cc/6VQG-3HUM
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 21 of 4618
his adversaries,
22
he contended that the American people should be "happy" that the President is directing the Justice Department'sprosecution decisions.
GOVERNING EVIDENCE:
16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department…D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A, 2022R00519-B, 2022R00519-C - 334. RETRIEVED EVIDENCE:
23
B.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 335. RETRIEVED EVIDENCE:
The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda
43.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON…Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida - 336. RETRIEVED EVIDENCE:
Contrary to established norms, the Justice Department has made a number of extraordinary personnel moves to carry out the President'sretribution campaign against Director Brennan.
GOVERNING EVIDENCE:
Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 337. RETRIEVED EVIDENCE:
The most notable such move was the removal of Attorney General Bondi.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are…that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 12. For this reason, Director Brennan brings this action - 338. RETRIEVED EVIDENCE:
It has been reported that the President fired Attorney General Bondi in part out of frustration that she had not served up the grand conspiracy prosecution that he was demanding.
GOVERNING EVIDENCE:
official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 339. RETRIEVED EVIDENCE:
In an interview the day after Bondi was fired, now-Counsel to the Attorney General Joseph diGenova explained that
[t]he President's conversation with [Attorney General Pam Bondi] yesterday coming back from the Supreme Court was not pleasant.
GOVERNING EVIDENCE:
QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal - 340. RETRIEVED EVIDENCE:
We are told by people who were briefed on it and by other meetings that she held that day that the president was ripping mad about the fact that there was no progress on the lawfare investigation in Miami.
GOVERNING EVIDENCE:
to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and - 341. RETRIEVED EVIDENCE:
24In April, the lead career prosecutor on the Brennan investigations was removed from the case.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ...................................................................….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and - 342. RETRIEVED EVIDENCE:
Maria Medetis Long, ahighly respected, long-tenured Justice Department veteran with deep experience in complex investigations and prosecutions, was reportedly removed shortly after telling senior DOJ leaders that "the case against [Director] Brennan was too weak to bring."
25
In AUSA Medetis Long'splace, diGenova was appointed as Counselor to the Attorney General and
22
Kristen Welker & Rebecca Shabad, Trump Accidentally Posted Message Pressuring Pam Bondi to Charge his Enemies, Source Says, NBC News (Oct.
GOVERNING EVIDENCE:
20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…prosecute him as an act of retribution. That scrutiny would be more probing and less deferential to the government than usual because of the Justice Department's recent record of…obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are…that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 12. For this reason, Director Brennan brings this action…of Virginia. 14. Director Brennan's federal government service, which began in August 1980, spanned six Administrations-three Republican and three Democratic. In his 25-year…W. Blanche is the Acting Attorney General of the United States. He leads the Department of Justice and has been in this position since April 2026. In that role, he has Case 1:26-cv-02323 - 343. RETRIEVED EVIDENCE:
10, 2025),
https://perma.cc/LX38
A439
.
23
Laura Jarrett & Ryan J.
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 344. RETRIEVED EVIDENCE:
Reilly, Todd Blanche Says Americans Should be 'Happy' Trump is Deeply Involved in DOJ, NBC News (Apr.
GOVERNING EVIDENCE:
seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as…t of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN …director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W. Bush to…Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA Distinguished Career…under the requested injunctive relief. 28. Defendant Office of the Director of National Intelligence is an agency that provides oversight to the intelligence community. It - 345. RETRIEVED EVIDENCE:
14, 2026),
https://perma.cc/YYJ4-FW67
.
24
Rudolph Giuliani, America's Mayor Live (899):
GOVERNING EVIDENCE:
DOJ, NBC News (Apr. 14, 2026), https://perma.cc/YYJ4-FW67 . 24 Rudolph Giuliani, America's Mayor Live (899): Pam Bondi Out as Attorney General with Top Names Emerging to Lead DOJ, at 1…46 These include Rudy Giuliani, Sydney Powell, John…Jan. 20, 2021), https://perma.cc/WCW6-XGRF ; Alan Feuer & Glenn Thrush, Trump Pardons Giuliani and Others Involved in Effort to Overturn 2020 Election, N.Y. Times (Nov. 10, 2025…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of…Kenneth L. Wainstein, DC Bar # 451058 Natasha Harnwell-Davis, DC Bar # 1719228 Mayer Brown LLP 1999 K Street, NW Washington, DC 20006-1101 Telephone: (202) 263-3000 - 346. RETRIEVED EVIDENCE:
Pam Bondi Out as Attorney General with Top Names Emerging to Lead DOJ, at 1:48-2:07 (YouTube, streamed Apr.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has - 347. RETRIEVED EVIDENCE:
2, 2026, at 20:00 ET),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
to the Point: The Grand Conspiracy Against Trump (YouTube, May 7, 2026), https://www.youtube.com/watch?v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity…Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim…Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts…Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v=wMZHAfSQ9vo ( https://perma.cc/9X48 5XX5 on file with Plaintiff). The accusations in…to Lead DOJ, at 1:48-2:07 (YouTube, streamed Apr. 2, 2026, at 20:00 ET), https://www.youtube.com/watch?v=5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah - 348. RETRIEVED EVIDENCE:
v=5G_nT7kFLPA
(
https://perma.cc/F3SB-MFZ2
on file with Plaintiff).
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in - 349. RETRIEVED EVIDENCE:
25
Evan Perez & Hannah Rabinowitz, supra note 12;
GOVERNING EVIDENCE:
criminal referrals." 3 Hannah Rabinowitz, Attorney General Bondi Orders…John Brennan, CNN (Apr. 18, 2026), https://perma.cc/Z6XV-DNK3 ; Evan Perez & Hannah Rabinowitz, Inside the Justice Department's Shakeup of the John Brennan Investigation, CNN (May 8…with seven other Obama Administration officials in orange 14 Katelyn Polantz, Hannah Rabinowitz & Evan Perez, Justice Department Leans on Prosecutors in Brennan Probe as Other Trump-Foe Investigations…https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA Director…Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority over…Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS - 350. RETRIEVED EVIDENCE:
Sarah N.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 351. RETRIEVED EVIDENCE:
Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA Director John Brennan is Removed from Case, Sources Say,
CBS News (Apr.
GOVERNING EVIDENCE:
DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation - 352. RETRIEVED EVIDENCE:
17, 2026),
https://perma.cc/37LC-YYMA
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 353. RETRIEVED EVIDENCE:
Eric Tucker, supra note 8.
GOVERNING EVIDENCE:
7 Appendix A, at 15-16. 8 Eric Tucker, Key Prosecutor in John Brennan…https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA Director…from Case, Sources Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority over…Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS…Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622 direction - 354. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619
given authority over all aspects of the investigation into the supposed "grand conspiracy" and Director Brennan's alleged false statements to Congress.
GOVERNING EVIDENCE:
JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel - 355. RETRIEVED EVIDENCE:
Since that time, diGenova has been building a team to pursue the investigation.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions - 356. RETRIEVED EVIDENCE:
26
44.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 357. RETRIEVED EVIDENCE:
diGenova is a former United States Attorney and a vocal ally of President Trump.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 358. RETRIEVED EVIDENCE:
According to diGenova, the President personally appointed him to run the investigations targeting Director Brennan.
GOVERNING EVIDENCE:
12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice - 359. RETRIEVED EVIDENCE:
27
Despite being out of the employ of the Justice Department for many decades, diGenova has several qualities that reportedly made him particularly appealing to the President.
GOVERNING EVIDENCE:
B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these - 360. RETRIEVED EVIDENCE:
He has staunchly supported the President with his public commentary over the years.
GOVERNING EVIDENCE:
s Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full - 361. RETRIEVED EVIDENCE:
28
He has provided legal services in support of the President's causes, temporarily joining the President's team of lawyers dealing with the Mueller Special Counsel investigation and serving on the legal team challenging the results of the 2020 presidential election.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel - 362. RETRIEVED EVIDENCE:
29
He has been a passionate advocate for the President's pet conspiracy theories, including that President Trump was the winner of the 2020 election and that the classified documents case against President Trump was manufactured by the Biden Administration.
GOVERNING EVIDENCE:
Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ......................…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these…Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that - 363. RETRIEVED EVIDENCE:
30
Finally, diGenova has publicly pronounced Director Brennan guilty of participation in the supposed "grand conspiracy," calling
26
In building that team, diGenova has recruited attorneys with demonstrated devotion to President Trump and his retribution agenda.
GOVERNING EVIDENCE:
20 D. Justice Department Officials Publicly Discuss Grand Jury Activity .......…apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely preserved. 2 Second, there is ample…Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also…of National Intelligence Tulsi Gabbard ten days later. Both referrals were styled and publicly trumpeted as "criminal referrals," despite their failure to explain how the activities…officials have engaged in a variety of inappropriate activities in their attempt to build a prosecutable case on the hollow foundation of these "criminal referrals." 3 Hannah…Dep't of Just., Justice Department Announces Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & - 364. RETRIEVED EVIDENCE:
U.S. Attorney Jason Reding Qui ones
(@USAReding), X (May 19, 2026, at 20:15 ET),
https://perma.cc/WZ7Y-CSUT
;
GOVERNING EVIDENCE:
capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th…JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has…that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https - 365. RETRIEVED EVIDENCE:
Erin Banco and Andrew Goudsward, Trump 2020 Election Denier Kurt Olsen Joins Justice Department,
Reuters (June 2, 2026),
https://perma.cc/N4YM-UWX5
;
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC…to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small…W. Blanche is the Acting Attorney General of the United States. He leads the Department of Justice and has been in this position since April 2026. In that role, he has Case 1:26-cv-02323…relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes…a defendant in the action resides in the District of Columbia, i.e., the Department of Justice is located at 950 Pennsylvania Ave. NW, Washington, D.C. 20530, and the Executive…2025. See Devlin Barrett, How the Drive to Find a Conspiracy Against Trump Rocked the Justice Dept., N.Y. Times (June 8, 2026), https://perma.cc/63DZ-3KUH . 10 Appendix A, at 10-11. Case - 366. RETRIEVED EVIDENCE:
Shawn McCreesh, Alexandra Berzon &
Nick Corasaniti, Trump's Director of Election Security is an Election Denier, N.Y.
GOVERNING EVIDENCE:
L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons…13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 367. RETRIEVED EVIDENCE:
Times (Feb.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 368. RETRIEVED EVIDENCE:
12, 2026),
https://perma.cc/483P-DP3P
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 369. RETRIEVED EVIDENCE:
Trump-Russia:
GOVERNING EVIDENCE:
officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L…that Russia had interfered in the 2016 presidential election in an effort to boost candidate Donald Trump's chances of winning the election. In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made - 370. RETRIEVED EVIDENCE:
President's Legal Team Shake-Up Falters, BBC News (Mar.
GOVERNING EVIDENCE:
NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity…26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan - 371. RETRIEVED EVIDENCE:
25, 2018),
https://perma.cc/WR69-UGFH
.
27
Anna Bower & Molly Roberts, supra note 6.
GOVERNING EVIDENCE:
v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability…Hannah Rabinowitz, supra note 12; Sarah N. Lynch…Legal Team Shake-Up Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Grand Conspiracy Probe (1), Bloomberg Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Professional Responsibility 43 to eliminate 38 Kash Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ Official Trained Pam Bondi on Ethics Rules in the - 372. RETRIEVED EVIDENCE:
28
Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News
(Mar.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in - 373. RETRIEVED EVIDENCE:
19, 2018),
https://perma.cc/ZP79-WTLH
.
29
Id.;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 374. RETRIEVED EVIDENCE:
Trump Lawyer diGenova to Lead Miami Grand Conspiracy Probe (1), Bloomberg Law
(Apr.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity…NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... - 375. RETRIEVED EVIDENCE:
18, 2026),
https://perma.cc/P9BA-WX28
.
30
Anna Bower & Molly Roberts, supra note 6.
GOVERNING EVIDENCE:
v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability…Hannah Rabinowitz, supra note 12; Sarah N. Lynch…Legal Team Shake-Up Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Grand Conspiracy Probe (1), Bloomberg Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Professional Responsibility 43 to eliminate 38 Kash Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ Official Trained Pam Bondi on Ethics Rules in the - 376. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620
Director Brennan "evil,"
31
branding him a "traitor,"
32
and declaring that "[t]his conspiracy began with John Brennan and ends with John Brennan."
33
C.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 377. RETRIEVED EVIDENCE:
The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda
45.
GOVERNING EVIDENCE:
Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years - 378. RETRIEVED EVIDENCE:
Besides these personnel moves, there has been apattern of frantic and haphazard activity as Justice Department leadership has scrambled to appease the President and his insistence on action against Director Brennan and the other retribution targets.
GOVERNING EVIDENCE:
JUSTICE, 950…........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these…and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida - 379. RETRIEVED EVIDENCE:
46.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 380. RETRIEVED EVIDENCE:
The government opened an investigation before a Miami grand jury in early November
2025, which issued subpoenas to Director Brennan and 30-odd current and former Intelligence Community officials seeking documents relating to the ICA from adate range in 2016-2017.
GOVERNING EVIDENCE:
U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has - 381. RETRIEVED EVIDENCE:
After Director Brennan and others complied with that subpoena, DOJ prosecutors opened a second investigation before a different grand jury in Miami, which issued subpoenas in January
2026 seeking the same category of documents from 2016 all the way up to the present.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 382. RETRIEVED EVIDENCE:
31
James Hoft, Joe diGenova on John Brennan's Lost Security Clearance:
GOVERNING EVIDENCE:
a criminal, not only before securing a conviction in court but…are failing to observe their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing…at the request of President Obama to serve as Assistant to the President for Homeland Security and Counterterrorism and Deputy National Security Advisor in the Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 11 of 468 Executive…was responsible during this time for orchestrating Obama Administration policies on homeland security, pandemics, cyberattacks, and natural disasters. 16. The United States Senate…day. 17. Director Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA…Shawn McCreesh, Alexandra Berzon & Nick Corasaniti, Trump's Director of Election Security is an Election Denier, N.Y. Times (Feb. 12, 2026), https://perma.cc/483P-DP3P - 383. RETRIEVED EVIDENCE:
"A Glorious Day for America", at 1:26 (YouTube, Aug.
GOVERNING EVIDENCE:
YouTube, May 7, 2026), https…FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from…she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna…Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v=wMZHAfSQ9vo ( https://perma.cc/9X48 5XX5 on file with Plaintiff). The…Pam Bondi Out as Attorney General with Top Names Emerging to Lead DOJ, at 1:48-2:07 (YouTube, streamed Apr. 2, 2026, at 20:00 ET), https://www.youtube.com/watch?v=5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan - 384. RETRIEVED EVIDENCE:
16, 2018) (clip of Fox News television broadcast, aired May
1, 2018, at 19:15 PM ET),
https://www.youtube.com/watch?
GOVERNING EVIDENCE:
Conspiracy Allegations: Sources, Fox News (Aug. 4, 2025), https://perma.cc/Q5JS XTZQ ; LA…h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with…her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts…Prosecutor in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the…Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean - 385. RETRIEVED EVIDENCE:
v=TzjzcAZauPc
(
https://perma.cc/BAE6-YVH6
on file with Plaintiff).
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in…this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in - 386. RETRIEVED EVIDENCE:
32
Tamar Auber, Joe diGenova to Hannity:
GOVERNING EVIDENCE:
https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc…their acts of criminal conduct." 14 Then, on June 2, 2026, in his interview with Sean Hannity, Acting Attorney General Blanche identified alleged members of the "grand conspiracy" as…Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v…felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean Hannity reminding the audience that none of the accused individuals has been charged with any - 387. RETRIEVED EVIDENCE:
John Brennan is the "Real Traitor", Mediaite (July
18, 2018) (clip of Fox News television broadcast, aired July 18, 2018, at 09:41 ET),
https://www.mediaite.com/media/tv/joe-digenova-to-hannity-john-brennan-is-the-real-traitor/
(
https://perma.cc/JDX4-P4WG on file with Plaintiff).
GOVERNING EVIDENCE:
4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to…Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States…Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 9 of 466 10. There is a very real risk, however, that some of these materials and communications will no longer exist by…injunctive relief. He is sued in his official capacity. 21. Defendant Joseph E. diGenova has served as Counselor to the Attorney General since April 20, 2026. He has been…at 560-61. Here, Director Brennan meets those three requirements. The injury is the very real prospect that the government will fail to preserve the records he would need to challenge an…her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News - 388. RETRIEVED EVIDENCE:
33
Charlie Savage & Alan Feuer, U.S. Installs a Trump Loyalist to Lead 'Grand Conspiracy'
Case Into Trump Foes, N.Y.
GOVERNING EVIDENCE:
described by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical…two sets of grand jury subpoenas - one set seeking documents relating to the supposed "grand conspiracy" and the other relating to Director Brennan's alleged false statements to…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the…General since April 20, 2026. He has been assigned to lead the investigations into the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress. In that…the allegedly criminal act occurred. Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the decision-making and - 389. RETRIEVED EVIDENCE:
Times (Apr.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 390. RETRIEVED EVIDENCE:
18, 2026),
https://perma.cc/55WV-DDBJ
. When asked about those comments upon diGenova'sappointment, Acting Attorney General Blanche dismissed any bias concerns saying, "I'mnot sure what the conflict of interest would be because somebody has said something in the past about, about a particular matter.
GOVERNING EVIDENCE:
official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama - 391. RETRIEVED EVIDENCE:
That doesn't create a conflict necessarily." The reporter then asked, "Well, it creates a sense of bias, doesn'tit?
GOVERNING EVIDENCE:
as the President's adversary has become risky in…into a tool of retribution against Director Brennan and the President's other perceived adversaries. 1 5. This effort has resulted in the opening of two federal investigations that…2016 election and the other Trump-related investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second investigation…lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small subset of officials, and the vast majority of…on pre-trial sanctions as a remedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication…skills and national security expertise, Director Brennan was selected in 2003 to design and serve as the founding director of the Terrorist Threat Integration Center and of its successor organization the National - 392. RETRIEVED EVIDENCE:
That he'scoming into the investigation with preconceived views about a target of your investigation.
GOVERNING EVIDENCE:
12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming - 393. RETRIEVED EVIDENCE:
Isn'tthat a problem?
GOVERNING EVIDENCE:
with preconceived views about a target of your investigation. Isn't that a problem?" At that point, Blanche simply responded, "I just completely disagree with the premise," and - 394. RETRIEVED EVIDENCE:
" At that point, Blanche simply responded, "Ijust completely disagree with the premise," and gave his assurance that DiGenova will be "doing everything ethically" and
"will follow the facts." The National Desk, Acting Attorney General Blanche and FBI Director Kash Patel Hold a Press Conference, U.S. Dep'tof Just., at 25:04-27:05 (YouTube, Apr.
GOVERNING EVIDENCE:
QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully - 395. RETRIEVED EVIDENCE:
21,
2026),
https://www.youtube.com/live/i4H6gQPcdkg
(
https://perma.cc/7LTP-V42Ron file with Plaintiff).
GOVERNING EVIDENCE:
to the Point: The Grand Conspiracy Against Trump (YouTube, May 7, 2026), https://www.youtube.com/watch?v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff…Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff…Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff…Out with Sean Hannity, at 26:58-27:14, 57:54-59:25 (YouTube, June 2, 2026), https://www.youtube.com/watch?v=wMZHAfSQ9vo ( https://perma.cc/9X48 5XX5 on file with Plaintiff…to Lead DOJ, at 1:48-2:07 (YouTube, streamed Apr. 2, 2026, at 20:00 ET), https://www.youtube.com/watch?v=5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff…broadcast, aired May 1, 2018, at 19:15 PM ET), https://www.youtube.com/watch?v=TzjzcAZauPc ( https://perma.cc/BAE6-YVH6 on - 396. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 24 of 4621
47.
GOVERNING EVIDENCE:
of the United States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director - 397. RETRIEVED EVIDENCE:
Following the document subpoenas, the investigation team reached out to a number of witnesses (or their counsel) to arrange voluntary interviews.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The…and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A, 2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, --…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in - 398. RETRIEVED EVIDENCE:
While those interviews were being arranged, the investigation team suddenly withdrew the interview requests and served several witnesses with grand jury subpoenas compelling their appearance before agrand jury in Washington, D.C.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions - 399. RETRIEVED EVIDENCE:
that had been empaneled to investigate the Chairman Jordan referral.
GOVERNING EVIDENCE:
With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in - 400. RETRIEVED EVIDENCE:
34
Within two days, however, the investigation team reversed course again, withdrawing the District of Columbia grand jury subpoenas and renewing the invitations for voluntary interviews.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in - 401. RETRIEVED EVIDENCE:
35
D.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 402. RETRIEVED EVIDENCE:
Justice Department Officials Publicly Discuss Grand Jury Activity
48.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 403. RETRIEVED EVIDENCE:
While this frantic activity is ongoing, there continues to be an unprecedented amount of public discussion by DOJ officials detailing investigative activity that is ostensibly covered by grand jury secrecy under Federal Rule of Criminal Procedure 6(e).
GOVERNING EVIDENCE:
12 A. The Grand…s Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from…in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1…and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record…his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made…With his return to the White House, the President has gone beyond mere denunciation, and has actively mobilized the machinery of the criminal justice system against Director Brennan. He has - 404. RETRIEVED EVIDENCE:
In his June 2, 2026 interview with Sean Hannity, for example, Acting Attorney General Blanche acknowledged, among other things, that "we've issued 200 grand jury subpoenas" and that agrand jury is investigating
"whether or not apattern of behavior has taken place to destroy [President Trump]."
36
When Hannity asked about "Comey," "Biden, Clapper" and "Biden," in the context of discussing the government's investigation, Blanche said, "All those folks were, were certainly part of it."
37
Earlier, on May 4, 2026, FBI Director Patel appeared on Hannity'sshow and engaged in alengthy discussion of the current investigations.
GOVERNING EVIDENCE:
to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…s Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in - 405. RETRIEVED EVIDENCE:
He confirmed the existence, scope, and general
34
Daniel Klaidman & Sarah N.
GOVERNING EVIDENCE:
any eventual indictment as the product of an unconstitutionally vindictive…a very real risk, however, that some of these materials and communications will no longer exist by the time any such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government…on pre-trial sanctions as a remedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 12. For this…juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia. 14. Director Brennan's federal government service…Bill Clinton and Vice President Al Gore (1994-95); senior U.S. intelligence official resident in Saudi Arabia (1996-99); Chief of Staff to Director of Central Intelligence George - 406. RETRIEVED EVIDENCE:
Lynch, Witnesses in Criminal Probe of Ex-CIA Director Brennan Subpoenaed to Testify Before Grand Jury, Sources Say, CBS News (Apr.
GOVERNING EVIDENCE:
DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and - 407. RETRIEVED EVIDENCE:
20, 2026),
https://perma.cc/Z9G7-CUBZ
.
35
Id.;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 408. RETRIEVED EVIDENCE:
Erin Banco, Andrew Goudsward & Jonathan Landay, FBI Questions CIA Officers Over Russia Assessment in Brennan Probe, Sources Say, Reuters (May 12, 2026),
https://perma.cc/K3YQ-ZULR
.
36
Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15.
GOVERNING EVIDENCE:
Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in - 409. RETRIEVED EVIDENCE:
37
Id.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 410. RETRIEVED EVIDENCE:
at 57:43-53.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 411. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622
direction of the investigations, and identified Director Brennan and the other retribution targets as falling within their scope.
GOVERNING EVIDENCE:
N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW…Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel - 412. RETRIEVED EVIDENCE:
38
E.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 413. RETRIEVED EVIDENCE:
The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct
49.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th…JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 414. RETRIEVED EVIDENCE:
At the same time that government personnel are accelerating their overreaching efforts against Director Brennan, the Administration is involved in aconcerted effort to insulate those personnel from any accountability for their misconduct by subverting the various mechanisms for investigating or sanctioning official DOJ misconduct.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington - 415. RETRIEVED EVIDENCE:
It has been methodically removing or silencing those career civil servants who are responsible for internally enforcing ethics, with Attorney General Bondi firing the head of the Office of Professional Responsibility
39
and the Director of the Departmental Ethics Office
40
(who had previously given then-Deputy Attorney General Blanche the unwelcome advice that he must recuse himself from investigations involving President Trump).
GOVERNING EVIDENCE:
20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in…investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to - 416. RETRIEVED EVIDENCE:
41
It is working to deny state bar authorities the ability to conduct oversight of DOJ attorneys,
42
suing the D.C.
GOVERNING EVIDENCE:
FOR THE DISTRICT OF COLUMBIA JOHN O…JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…Justice Department's recent record of overreaching in this and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government - 417. RETRIEVED EVIDENCE:
Board on Professional Responsibility
43
to eliminate
38
Kash Patel interview with Sean Hannity, supra note 3.
GOVERNING EVIDENCE:
Government Personnel from Accountability for Their Irregular Conduct…In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan as "a very…without valid support that Director Brennan made false statements about the ICA in a 2023 interview with the House Judiciary Committee. 6. The Justice Department has undertaken separate grand…to selectively and vindictively target Director Brennan, there is no intent to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the…personnel are maintaining adherence to professional standards and carrying out their duties in the best tradition of the Justice Department. Case 1:26-cv-02323 Document 1 Filed…Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 7. In their work on these presidentially-driven investigations, certain Justice - 418. RETRIEVED EVIDENCE:
39
Sam Levine, A Top DOJ Official Trained Pam Bondi on Ethics Rules in the Department.
GOVERNING EVIDENCE:
JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal…Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes - 419. RETRIEVED EVIDENCE:
Then He was Fired, Guardian (Jan.
GOVERNING EVIDENCE:
Top DOJ Official Trained Pam Bondi on Ethics Rules in the Department. Then He was Fired, Guardian (Jan. 3, 2026), https://perma.cc/8JHJ-PGM3 . The same day, the U.S. Pardon Attorney…Helmore, Photos Suggest Trump Blocked Toilets with Ripped-up White House Documents, Guardian (Aug. 8, 2022), https://perma.cc/A7VV-GP25 ; Mike Allen, Exclusive Photos: Trump's - 420. RETRIEVED EVIDENCE:
3, 2026),
https://perma.cc/8JHJ-PGM3
. The same day, the U.S.
Pardon Attorney, who was acareer civil servant, was terminated by aletter signed by Deputy Attorney General Todd Blanche.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has - 421. RETRIEVED EVIDENCE:
Perry Stein et al., Trump's Justice Department Ousts Several Top Career Officials, Washington Post (Mar.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 422. RETRIEVED EVIDENCE:
8, 2025),
https://perma.cc/5DCT-GLU2
.
40
Sam Levine, supra note 39;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 423. RETRIEVED EVIDENCE:
Katelyn Polantz, Evan Perez & Hannah Rabinowitz, Exclusive:
GOVERNING EVIDENCE:
Director Brennan with seven other Obama Administration officials in orange 14 Katelyn Polantz, Hannah Rabinowitz & Evan Perez, Justice Department Leans on Prosecutors in Brennan Probe as…Mar. 8, 2025), https://perma.cc/5DCT-GLU2 . 40 Sam Levine, supra note 39; Katelyn Polantz, Evan Perez & Hannah Rabinowitz, Exclusive: Acting AG Todd Blanche was Told Last Year to Recuse from Justice Department Matters…House Documents, Guardian (Aug. 8, 2022), https://perma.cc/A7VV-GP25 ; Mike Allen, Exclusive Photos: Trump's Telltale Toilet, Axios (Aug. 8, 2022), https://perma.cc/98QG-ULBK - 424. RETRIEVED EVIDENCE:
Acting AG Todd Blanche was Told Last Year to Recuse from Justice Department Matters Involving Trump, CNN (May 14, 2026),
https://perma.cc/79WB-488R
.
41
These firings have apparently had their intended effect on the internal watchdog workforce, as evidenced by recent reports that the Department of Justice Office of the Inspector General has
"seemingly ignored 20 instances of possible wrongdoing by the Trump administration." Devlin Barrett, Justice Dept.
GOVERNING EVIDENCE:
address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530…and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…Biden Administration officials. This fictitious "grand conspiracy" is ill-defined but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 - 425. RETRIEVED EVIDENCE:
Watchdog Has Gone Silent, Lawyers for Whistle-Blower Say, N.Y.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the - 426. RETRIEVED EVIDENCE:
Times
(Mar.
GOVERNING EVIDENCE:
concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that…potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1…as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying before…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan - 427. RETRIEVED EVIDENCE:
30, 2026),
https://perma.cc/UQ7V-YQBW
.
42
Currently, each Department of Justice attorney is "subject to State laws and rules, and local Federal court rules, governing attorneys in each State where such attorney engages in that attorney'sduties, to the same extent and in the same manner as other attorneys in that State." 28
U.S.C.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26…In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set seeking documents relating to…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has - 428. RETRIEVED EVIDENCE:
530B (the McDade Amendment).
GOVERNING EVIDENCE:
same extent and in the same manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1…regard to legal or ethical limitations. And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of…United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive prosecution claim, the court considered in camera material from…equally to records on non official electronic messaging channels. In 2014, Congress amended both the PRA and the FRA to prohibit executive department personnel from using…at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub. L. No. 113-187, 10, 128 Stat. 2003, 2014-15); see also United States - 429. RETRIEVED EVIDENCE:
See generally In re Clark, 678 F.
GOVERNING EVIDENCE:
and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…of the John Brennan Investigation, CNN (May 8, 2026), https://perma.cc/S58G-9MTK . 13 See generally Appendix A. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 19 of 4616 A…lengthy discussion of the current investigations. He confirmed the existence, scope, and general 34 Daniel Klaidman & Sarah N. Lynch, Witnesses in Criminal Probe of Ex-CIA Director…manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26…57 See generally A Disappearing Data - 430. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 431. RETRIEVED EVIDENCE:
3d 112, 116
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623
its oversight of federal attorneys, and issuing aproposed regulation that will give the Attorney General the first opportunity to review any complaint against acurrent or former Department attorney
44
and the right to "take appropriate action to prevent the bar disciplinary authorities from interfering with the Attorney General's review of the allegations."
45
And, the President himself is using his pardon power to prevent accountability in the criminal justice system.
GOVERNING EVIDENCE:
DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis…of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government…Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & - 432. RETRIEVED EVIDENCE:
Having pardoned numerous officials who were found guilty of or credibly charged with criminal conduct during his first administration,
46
he has now made clear that he will pardon those who serve his will in this term, stating, "I'll pardon everyone who has come within 200 feet of the Oval" and making other similar statements.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…10 STANDING…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda - 433. RETRIEVED EVIDENCE:
47
50.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 434. RETRIEVED EVIDENCE:
The clear point of these combined efforts is to greatly reduce the deterrent effect of legal and ethical limitations and enforcement mechanisms on those government employees - like some of those involved in the investigations involving Director Brennan - who might be tempted to follow President Trump'sorders without regard to legal or ethical limitations.
GOVERNING EVIDENCE:
NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel - 435. RETRIEVED EVIDENCE:
And
18 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates - 436. RETRIEVED EVIDENCE:
2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…6 of 463 INTRODUCTION 1. Director Brennan is a former longtime public servant who provided more than 33 years of nonpartisan government service working for six administrations -…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 437. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 438. RETRIEVED EVIDENCE:
July 12, 2024).
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 439. RETRIEVED EVIDENCE:
43
Press Release, U.S. Dep'tof Just., Justice Department Files Complaint Against D.C.
GOVERNING EVIDENCE:
UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re…a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 - 440. RETRIEVED EVIDENCE:
Bar Disciplinary Authorities Over Their Weaponization of the Bar Disciplinary Process Against Federal Government Attorneys (May 13, 2026),
https://perma.cc/CXC6-RMUH
.
44
91 Fed.
GOVERNING EVIDENCE:
to "take appropriate action to prevent the bar disciplinary authorities from interfering with the Attorney General…43 Press Release, U.S. Dep't of Just., Justice Department Files Complaint Against D.C. Bar Disciplinary Authorities Over Their Weaponization of the Bar Disciplinary Process Against Federal Government Attorneys (May 13, 2026), https://perma.cc/CXC6-RMUH . 44 91 Fed. Reg. 10780 (Mar. 5, 2026) (codified at 28 C.F.R. pt. 77). 45 Id. 46 These…50 See supra note 2. 51 Memorandum from William Fischer, Chief Records Officer, to Fed. Records Mgmt. Contacts (May 2, 2025), https://perma.cc/TAB5-E2ZX . 52 Bernd…from White House Counsel David Warrington. The Warrington 62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt…retain the internal records that 68 Id. 69 Order on Cross-Mots. for Summ. J. 15-16, Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025 - 441. RETRIEVED EVIDENCE:
Reg.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 442. RETRIEVED EVIDENCE:
10780 (Mar.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 443. RETRIEVED EVIDENCE:
5, 2026) (codified at 28 C.F.R.
GOVERNING EVIDENCE:
May 13, 2026), https://perma.cc/CXC6-RMUH . 44 91 Fed. Reg. 10780 (Mar. 5, 2026) (codified at 28 C.F.R. pt. 77). 45 Id. 46 These include Rudy Giuliani, Sydney Powell, John - 444. RETRIEVED EVIDENCE:
pt.
GOVERNING EVIDENCE:
//perma.cc/CXC6-RMUH . 44 91 Fed. Reg. 10780 (Mar. 5, 2026) (codified at 28 C.F.R. pt. 77). 45 Id. 46 These include Rudy Giuliani, Sydney Powell, John Eastman, Boris - 445. RETRIEVED EVIDENCE:
77).
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 446. RETRIEVED EVIDENCE:
45
Id.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 447. RETRIEVED EVIDENCE:
46
These include Rudy Giuliani, Sydney Powell, John Eastman, Boris Epshteyn, Jeffrey Clark,
Mark Meadows, Paul Manafort, Roger Stone, Steve Bannon, and Michael Flynn, to name but afew.
GOVERNING EVIDENCE:
this Administration has adopted a policy of using criminal process…of Justice is a federal agency responsible for enforcing federal criminal laws. It includes government personnel and record systems that would have the records to be preserved under the…Office of the President provides operational and management support to the President. It includes government personnel and record systems that would have the records to be preserved under the…an agency that engages in intelligence operations and analysis for the U.S. government. It includes government personnel and record systems that would have the records to be preserved under the…Intelligence is an agency that provides oversight to the intelligence community. It includes government personnel and record systems that would have the records to be preserved under the…because that is where the allegedly criminal act occurred. Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the - 448. RETRIEVED EVIDENCE:
Jonathan Lemire, Eric Tucker & Jill Colvin, Trump Pardons Ex-Strategist Steve Bannon,
Dozens of Others, AP News (Jan.
GOVERNING EVIDENCE:
Fired, Guardian (Jan. 3, 2026), https://perma.cc/8JHJ-PGM3 . The same day, the U.S. Pardon Attorney, who was a career civil servant, was terminated by a letter signed by Deputy…General's review of the allegations." 45 And, the President himself is using his pardon power to prevent accountability in the criminal justice system. Having pardoned numerous officials who were found guilty of or credibly charged with criminal conduct during his first administration, 46 he has now made clear that he will pardon those who serve his will in this term, stating, "I'll pardon everyone who has come within 200 feet of the Oval" and making other similar statements. 47…Steve Bannon, and Michael Flynn, to name but a few. Jonathan Lemire, Eric Tucker & Jill Colvin, Trump Pardons Ex-Strategist Steve Bannon, Dozens of Others, AP News (Jan. 20, 2021), https://perma.cc/WCW6-XGRF ; Alan Feuer & Glenn Thrush, Trump Pardons Giuliani and Others Involved in Effort to Overturn 2020 Election, N.Y - 449. RETRIEVED EVIDENCE:
20, 2021),
https://perma.cc/WCW6-XGRF
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 450. RETRIEVED EVIDENCE:
Alan Feuer & Glenn Thrush, Trump Pardons Giuliani and Others Involved in Effort to Overturn
2020 Election, N.Y.
GOVERNING EVIDENCE:
and Continues to Engage, in Unprecedented, Irregular Conduct in Connection…based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the…because that is where the allegedly criminal act occurred. Most of the activities involved in the supposed "grand conspiracy" took place in the District of Columbia including the…the product of a carefully orchestrated series of referrals claiming Director Brennan's involvement in theoretical criminal activity. A. The Grand Conspiracy Investigation 33. The…rights with the series of federal investigations and prosecutions relating to the 2016 election and to President Trump's conduct in and out of office. 3 B. The False-Statements - 451. RETRIEVED EVIDENCE:
Times (Nov.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 452. RETRIEVED EVIDENCE:
10, 2025),
https://perma.cc/N8JQ-HTLS
.
47
Josh Dawsey, Trump Promises Mass Pardons to Staff Before Leaving Office, Wall Street Journal (Apr.
GOVERNING EVIDENCE:
of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as…Effort to Overturn 2020 Election, N.Y. Times (Nov. 10, 2025), https://perma.cc/N8JQ-HTLS . 47 Josh Dawsey, Trump Promises Mass Pardons to Staff Before Leaving Office, Wall Street Journal…X account the next morning. 61 Finally, in a recent challenge to the Administration's mass terminations of government employees, discovery revealed that high-level communications,' which…Working Grp., U.S. Dep't of Just. (Nov. 17, 2025), https://perma.cc/AZ83-JPKH . 60 Josh Gerstein & Kyle Cheney, Judge Orders Trump Administration to Preserve Signal Chats…a grand jury that I saw in those transcripts." 68 In a recent civil case involving the mass termination of grants awarded by the National Endowment for the Humanities, the judge - 453. RETRIEVED EVIDENCE:
10, 2026),
https://perma.cc/FCP6-TT6R
. And, to message assurance that those followers will suffer no financial impact due to any misdeeds in his service, the Justice Department recently mounted - and was ultimately forced to abandon - an effort to establish a
$1.776 billion dollar fund to make payments to those who have "suffered weaponization and lawfare." Press Release, U.S. Dep't of Just., Justice Department Announces Anti-Weaponization Fund (May 18, 2026),
https://perma.cc/UM4V-D3AT
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 27 of 4624
the result thereof is a continuing crescendo in the incidence of conduct that falls far short of professional standards.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 454. RETRIEVED EVIDENCE:
III.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 455. RETRIEVED EVIDENCE:
The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution
51.
GOVERNING EVIDENCE:
22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…Reviewing the Vindictive and Selective Prosecution Challenges Would Require…Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for - 456. RETRIEVED EVIDENCE:
This background provides a strong factual foundation for moving to dismiss any indictment that may ultimately arise from the government'scurrent investigations as avindictive and/or selective prosecution The above-described government conduct in this case makes it abundantly clear that the driving force behind the investigations targeting Director Brennan is the President'sobsession with punishing him for his lawful conduct as CIA Director and for his constitutionally protected criticism of the President and the President'spolicies.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution - 457. RETRIEVED EVIDENCE:
That is the reason he is being singled out for investigation of concocted theories of criminal activity, and that will be the dominant reason for any criminal charges resulting from that investigation.
GOVERNING EVIDENCE:
......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel…Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming - 458. RETRIEVED EVIDENCE:
That is also why Director Brennan will have an extremely strong basis to challenge those charges as the product of vindictive and selective prosecution.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional…to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations - 459. RETRIEVED EVIDENCE:
IV.
GOVERNING EVIDENCE:
24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a…to challenge those charges as the product of vindictive and selective prosecution. IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage - 460. RETRIEVED EVIDENCE:
The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government
52.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under…Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government - 461. RETRIEVED EVIDENCE:
A court evaluating Director Brennan's well-founded challenges would do so without granting the deference traditionally afforded to representatives of the government under the
"presumption of regularity." Traditionally, "in the absence of clear evidence to the contrary,
courts presume that [government representatives] have properly discharged their official duties,"
United States v.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 462. RETRIEVED EVIDENCE:
Chem.
GOVERNING EVIDENCE:
representatives] have properly discharged their official duties," United States v. Chem. Found., 272 U.S. 1, 14-15 (1926), and thereby refrain from closely scrutinizing the - 463. RETRIEVED EVIDENCE:
Found., 272 U.S. 1, 14-15 (1926), and thereby refrain from closely scrutinizing the propriety of their activities.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 464. RETRIEVED EVIDENCE:
As demonstrated by the above-recited litany of irregular activities (see supra 35-37), however, there is more than "clear evidence to the contrary" in this case.
GOVERNING EVIDENCE:
Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks…in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1…issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made…With his return to the White House, the President has gone beyond mere denunciation, and has actively mobilized the machinery of the criminal justice system against Director Brennan. He has…interference in the 2016 election and the other Trump-related investigations in the succeeding years were all the product of a conspiracy to deny President Trump his civil rights. The second - 465. RETRIEVED EVIDENCE:
As of December 22, 2025 - when undersigned counsel for Director Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 28 of 4625
Brennan sent the attached letter to Chief Judge Altonaga in the U.S. District Court for the Southern District of Florida - the Department had already engaged in more than enough irregular conduct to lose the presumption of regularity.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001…JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 466. RETRIEVED EVIDENCE:
48
And, the intensified pace of irregular activity since then, described supra 39-50, has only confirmed the need for the courts to carefully examine all allegations of government overreaching targeted towards Director Brennan,
particularly his vindictive and selective prosecution challenges against any eventual indictment in this case.
GOVERNING EVIDENCE:
Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for…in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over - 467. RETRIEVED EVIDENCE:
V.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 468. RETRIEVED EVIDENCE:
The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations
53.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O…Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His - 469. RETRIEVED EVIDENCE:
That careful examination would require the court hearing Director Brennan'schallenges to review the materials and communications relating to the government'sdecision-making throughout the investigation and ultimate prosecution.
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 470. RETRIEVED EVIDENCE:
To assess his claim that the prosecution is vindictive and selective, the court would need to evaluate the motivations of the involved government personnel, up to the President of the United States.
GOVERNING EVIDENCE:
the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 471. RETRIEVED EVIDENCE:
That would be accomplished via the thorough examination of the contemporaneous statements, communications, and writings that reflect and reveal these motivations.
GOVERNING EVIDENCE:
over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect…legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of…the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any…his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director - 472. RETRIEVED EVIDENCE:
Examples of such records include:
GOVERNING EVIDENCE:
Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence…counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This - 473. RETRIEVED EVIDENCE:
communications from President Trump and the White House pushing for a prosecution;
GOVERNING EVIDENCE:
13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations - 474. RETRIEVED EVIDENCE:
internal emails among DOJ officials discussing the "grand conspiracy" referrals and their search for a sufficiently pliant U.S.
Attorney to handle the resulting far-fetched investigation (see supra note 8);
GOVERNING EVIDENCE:
DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The - 475. RETRIEVED EVIDENCE:
prosecution memoranda and other materials reflecting assessments about the strength of any potential cases against Director Brennan;
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President…Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations - 476. RETRIEVED EVIDENCE:
communications reflecting the reaction to AUSA Meditas Long'sreport that there was insufficient evidence to support the false-statements case;
GOVERNING EVIDENCE:
....................................................... 12 B. The False-Statements Investigation…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind…legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an - 477. RETRIEVED EVIDENCE:
and records reflecting the reasons why she and others who expressed such misgivings about the Brennan
48
See Appendix A;
GOVERNING EVIDENCE:
Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to…time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…time any such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are…Department specifically are failing to observe their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true - 478. RETRIEVED EVIDENCE:
supra 35-36.
GOVERNING EVIDENCE:
5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA…Sources Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority…Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ - 479. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 29 of 4626
cases - like those prosecutors in the other districts to which the cases were initially shopped -
were then pushed aside.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD…INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ...................................................................…34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will - 480. RETRIEVED EVIDENCE:
Courts reviewing colorable vindictive and selective prosecution claims like those in this case routinely require the government to produce these records in its assessment whether the government acted vindictively or selectively in bringing aprosecution.
GOVERNING EVIDENCE:
Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal - 481. RETRIEVED EVIDENCE:
See, e.g.,
United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 482. RETRIEVED EVIDENCE:
Abrego, 802 F.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 483. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 484. RETRIEVED EVIDENCE:
3d 1055, 1065 (M.D. Tenn.
GOVERNING EVIDENCE:
bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670 - 485. RETRIEVED EVIDENCE:
2025) (considering emails,
internal DOJ memoranda);
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The…Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from Accountability for Their Irregular Conduct…The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government…Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent - 486. RETRIEVED EVIDENCE:
United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 487. RETRIEVED EVIDENCE:
Jarrett, 2010 WL 1577670, at *4 (N.D.
GOVERNING EVIDENCE:
Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of Just., Justice…2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010) (noting that the court did an in camera review of "hundreds of…documents" in assessing claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive…v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr. 20, 2021) (Contreras, J), and "[t]he government has a - 488. RETRIEVED EVIDENCE:
Ind.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 489. RETRIEVED EVIDENCE:
Apr.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 490. RETRIEVED EVIDENCE:
20,
2010) (noting that the court did an in camera review of "hundreds of documents" in assessing claim of vindictive prosecution);
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for - 491. RETRIEVED EVIDENCE:
United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 492. RETRIEVED EVIDENCE:
Fieger, 2008 WL 205244, at *8 (E.D.
GOVERNING EVIDENCE:
3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of Just., Justice…2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010) (noting that the court did an in camera…of "hundreds of documents" in assessing claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive…v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr. 20, 2021) (Contreras, J), and "[t]he government has a - 493. RETRIEVED EVIDENCE:
Mich.
GOVERNING EVIDENCE:
claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive prosecution claim, the court considered…in camera material from the government "related to the DOJ's recusal of the three principal Detroit U.S. Attorneys" and ordered that evidence turned over to defendant); United States v…In re Mohammad, 866 F.3d 473, 475 (D.C. Cir. 2017) (same); Dascola v. City of Ann Arbor, 22 F. Supp. 3d 736, 746 (E.D. Mich. 2014). The very purpose of the requested order in this matter is to ensure that the - 494. RETRIEVED EVIDENCE:
Jan.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 495. RETRIEVED EVIDENCE:
24, 2008), as amended (Feb.
GOVERNING EVIDENCE:
extent and in the same manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1…to legal or ethical limitations. And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of…United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive prosecution claim, the court considered in camera material from…equally to records on non official electronic messaging channels. In 2014, Congress amended both the PRA and the FRA to prohibit executive department personnel from using…at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub. L. No. 113-187, 10, 128 Stat. 2003, 2014-15); see also United States - 496. RETRIEVED EVIDENCE:
1, 2008) (in vindictive prosecution claim, the court considered in camera material from the government "related to the DOJ'srecusal of the three principal Detroit U.S. Attorneys" and ordered that evidence turned over to defendant);
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional - 497. RETRIEVED EVIDENCE:
United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 498. RETRIEVED EVIDENCE:
P.H.E., Inc., 965 F.2d 848, 850, 853, 858 (10th Cir.
GOVERNING EVIDENCE:
and ordered that evidence turned over to defendant); United States v. P.H.E., Inc., 965 F.2d 848, 850, 853, 858 (10th Cir. 1992) (district court reviewed prosecution memoranda and…195 F. App'x 902, 903 (11th Cir. 2006); United States v. Rolande-Gabriel, 938 F.2d 1231, 1238 (11th Cir. 1991) (same). As the Supreme Court has explained, the 49 - 499. RETRIEVED EVIDENCE:
1992) (district court reviewed prosecution memoranda and letter from U.S. Attorney to Attorney General to evaluate vindictive prosecution claim implicating the First Amendment).
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government - 500. RETRIEVED EVIDENCE:
VI.
GOVERNING EVIDENCE:
Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…General to evaluate vindictive prosecution claim implicating the First Amendment). VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant - 501. RETRIEVED EVIDENCE:
Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved,
Which Would Prevent Director Brennan from Vindicating His Constitutional Rights
54.
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations ................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 502. RETRIEVED EVIDENCE:
Though critical to the consideration of such claims, there is strong reason to think that many of those materials and communications will no longer exist by the time those claims are raised in this matter.
GOVERNING EVIDENCE:
1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government…and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His…Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re - 503. RETRIEVED EVIDENCE:
Many officials in this Administration are failing to retain - or are intentionally eliminating - communications and documents that must be preserved.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes…of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to - 504. RETRIEVED EVIDENCE:
55.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 505. RETRIEVED EVIDENCE:
The government has ongoing statutory and constitutional obligations to preserve evidence and records of the type that will be relevant to Director Brennan'schallenges to an indictment in this matter.
GOVERNING EVIDENCE:
Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights - 506. RETRIEVED EVIDENCE:
Many of these communications and materials - including the communications by Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 30 of 4627
which the President is influencing the Justice Department's decision-making - are covered by the Presidential Records Act ("PRA"), 44 U.S.C.
GOVERNING EVIDENCE:
Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His…Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights .......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii - 507. RETRIEVED EVIDENCE:
2201-09, which governs the preservation of records that are created in the course of the President, Vice President, their staff and their advisers carrying out their constitutional, statutory or other responsibilities.
GOVERNING EVIDENCE:
Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ......................…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years - 508. RETRIEVED EVIDENCE:
Others are covered by the Federal Records Act ("FRA"), which requires an agency to "make and preserve records containing adequate and proper documentation" of its activities "to protect the legal ... rights ...
of persons directly affected by the agency's activities." 44 U.S.C.
GOVERNING EVIDENCE:
capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel from - 509. RETRIEVED EVIDENCE:
3101.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 510. RETRIEVED EVIDENCE:
49
56.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 511. RETRIEVED EVIDENCE:
Those materials and communications also clearly fall within the category of evidence that the court would require the government to provide in discovery relating to Director Brennan's vindictive and selective prosecution challenges.
GOVERNING EVIDENCE:
Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim…Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning - 512. RETRIEVED EVIDENCE:
See supra 53.
GOVERNING EVIDENCE:
5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA…Sources Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority…Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ - 513. RETRIEVED EVIDENCE:
As courts have repeatedly stated,
that discovery obligation to produce evidence carries with it a corresponding obligation to preserve that evidence.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…s questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the - 514. RETRIEVED EVIDENCE:
"[The] duties to disclose include[] a correlative duty to preserve that evidence in the first place," United States v.
GOVERNING EVIDENCE:
Not be Preserved, Which Would…Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This…personnel are maintaining adherence to professional standards and carrying out their duties in the best tradition of the Justice Department. Case 1:26-cv-02323 Document 1 Filed - 515. RETRIEVED EVIDENCE:
Vega, 826 F.3d 514, 533 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed…JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E…recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set - 516. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 517. RETRIEVED EVIDENCE:
2016);
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 518. RETRIEVED EVIDENCE:
see United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 519. RETRIEVED EVIDENCE:
Harris, 2021 WL 1546541, at *2 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 520. RETRIEVED EVIDENCE:
Apr.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 521. RETRIEVED EVIDENCE:
20, 2021) (Contreras, J), and
"[t]he government has a responsibility to try in good faith to preserve material evidence." United States v.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE - 522. RETRIEVED EVIDENCE:
Roberson, 195 F.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 523. RETRIEVED EVIDENCE:
App'x 902, 903 (11th Cir.
GOVERNING EVIDENCE:
responsibility to try in good faith to preserve material evidence." United States v. Roberson, 195 F. App'x 902, 903 (11th Cir. 2006); United States v. Rolande-Gabriel, 938 F.2d 1231, 1238 - 524. RETRIEVED EVIDENCE:
2006);
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 525. RETRIEVED EVIDENCE:
United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 526. RETRIEVED EVIDENCE:
Rolande-Gabriel,
938 F.2d 1231, 1238 (11th Cir.
GOVERNING EVIDENCE:
evidence." United States v. Roberson, 195 F. App'x 902, 903 (11th Cir. 2006); United States v. Rolande-Gabriel, 938 F.2d 1231, 1238 (11th Cir. 1991) (same). As the Supreme Court has - 527. RETRIEVED EVIDENCE:
1991) (same).
GOVERNING EVIDENCE:
process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim…Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying…a different grand jury in Miami, which issued subpoenas in January 2026 seeking the same category of documents from 2016 all the way up to the present. 31 James Hoft, Joe…Government Personnel from Accountability for Their Irregular Conduct 49. At the same time that government personnel are accelerating their overreaching efforts against…Then He was Fired, Guardian (Jan. 3, 2026), https://perma.cc/8JHJ-PGM3 . The same day, the U.S. Pardon Attorney, who was a career civil servant, was terminated by a…engages in that attorney's duties, to the same extent and in the same manner as other attorneys in that State." 28 - 528. RETRIEVED EVIDENCE:
As the Supreme Court has explained, the
49
Congress has made clear that these preservation requirements apply equally to records on non official electronic messaging channels.
GOVERNING EVIDENCE:
JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal…Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes - 529. RETRIEVED EVIDENCE:
In 2014, Congress amended both the PRA and the FRA to prohibit executive department personnel from using non-official electronic messaging accounts, such as on personal devices, unless they take steps to ensure the conversation is preserved.
GOVERNING EVIDENCE:
Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes - 530. RETRIEVED EVIDENCE:
44 U.S.C.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 531. RETRIEVED EVIDENCE:
2911;
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 532. RETRIEVED EVIDENCE:
see Am.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 533. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 - 534. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding - 535. RETRIEVED EVIDENCE:
Trump, --- F.
GOVERNING EVIDENCE:
Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L - 536. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 537. RETRIEVED EVIDENCE:
3d.
GOVERNING EVIDENCE:
recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr…2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J - 538. RETRIEVED EVIDENCE:
----, 2026 WL
1412395, at *2 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 539. RETRIEVED EVIDENCE:
May 20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub.
GOVERNING EVIDENCE:
Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years - 540. RETRIEVED EVIDENCE:
L.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 541. RETRIEVED EVIDENCE:
No. 113-187, 10, 128 Stat.
GOVERNING EVIDENCE:
Presidential and Federal Records Act Amendments of 2014, Pub. L. No. 113-187, 10, 128 Stat. 2003, 2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C - 542. RETRIEVED EVIDENCE:
2003, 2014-15);
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 543. RETRIEVED EVIDENCE:
see also United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 544. RETRIEVED EVIDENCE:
Navarro, 664 F.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 545. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 546. RETRIEVED EVIDENCE:
3d 48, 57 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 547. RETRIEVED EVIDENCE:
2023) (the PRA applies to records such as emails or texts sent and received on personal accounts if "they arose out of [aperson's]
employment in the administration"), aff'd, 2024 WL 1364354 (D.C.
GOVERNING EVIDENCE:
STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…organizational structure remains in place to this day. 17. Director Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates…plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in this district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events or omissions - 548. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 549. RETRIEVED EVIDENCE:
Apr.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 550. RETRIEVED EVIDENCE:
1, 2024).
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 551. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 31 of 4628
government has aduty to preserve evidence that "might be expected to play a significant role in the suspect'sdefense." California v.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 552. RETRIEVED EVIDENCE:
Trombetta, 467 U.S. 479, 488 (1984).
GOVERNING EVIDENCE:
might be expected to play a significant role in the suspect's defense." California v. Trombetta, 467 U.S. 479, 488 (1984). 57. Administration officials are failing to uphold those…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 553. RETRIEVED EVIDENCE:
57.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 554. RETRIEVED EVIDENCE:
Administration officials are failing to uphold those preservation obligations in ways that are both inadvertent and advertent.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes…of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to - 555. RETRIEVED EVIDENCE:
First, with the evolution of technology, government officials have access to arange of communications technologies that, unlike the traditional government email system, are not amenable to standard preservation processes consistent with the FRA
(discussed infra 58-59).
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington - 556. RETRIEVED EVIDENCE:
Particularly under the current administration, government officials are increasingly relying on avariety of ephemeral methods of communication, to include social media posts, encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like.
GOVERNING EVIDENCE:
by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…and prosecutive decisions. A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their…them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are increasingly relying on communications that are not routinely preserved, even though they should be, pursuant…government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not - 557. RETRIEVED EVIDENCE:
50
While these ephemeral communications are fully subject to the above-listed preservation requirements, the preservation processes have not been implemented to ensure those requirements are being consistently satisfied.
GOVERNING EVIDENCE:
Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging…over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional - 558. RETRIEVED EVIDENCE:
This is despite clear guidance from the National Archives and Research Administration warning federal agencies that "[t]he auto-delete functions of third party messaging apps may violate federal record-keeping requirements" and instructing them on the "strict requirements" in the Federal Records Act for the preservation of all such records.
GOVERNING EVIDENCE:
OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…Document 1 Filed 07/01/26 Page 8 of 465 personnel who had worked on the ICA, requiring them to testify before the grand jury in the false-statements investigation. Those…and prosecutive decisions. A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their…government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely…director of the Terrorist Threat Integration Center and of its successor organization the National Counterterrorism Center, which were established under President George W. Bush to…Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA Distinguished Career - 559. RETRIEVED EVIDENCE:
51
58.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 560. RETRIEVED EVIDENCE:
Beyond that arguably inadvertent failure to preserve, officials of this Administration have shown an advertent disdain for their preservation obligations.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes…of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to - 561. RETRIEVED EVIDENCE:
President Trump has repeatedly deleted social media posts that should be retained.
GOVERNING EVIDENCE:
16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…irregular prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these - 562. RETRIEVED EVIDENCE:
52
On September 20, 2025, for example, he posted a message on Truth Social directing then-Attorney General Bondi to accelerate
50
See supra note 2.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL…adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…prosecutorial activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong…records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent…General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney - 563. RETRIEVED EVIDENCE:
51
Memorandum from William Fischer, Chief Records Officer, to Fed.
GOVERNING EVIDENCE:
and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence…counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…and less deferential to the government than usual because of the Justice Department's recent record of overreaching in this and similar matters, which has negated the traditional…A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on…their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous communications and - 564. RETRIEVED EVIDENCE:
Records Mgmt.
GOVERNING EVIDENCE:
s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence…counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…and less deferential to the government than usual because of the Justice Department's recent record of overreaching in this and similar matters, which has negated the traditional…specifically are failing to observe their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous communications and materials that is needed to divine the true - 565. RETRIEVED EVIDENCE:
Contacts
(May 2, 2025),
https://perma.cc/TAB5-E2ZX
.
52
Bernd Debusmann Jr., Trump Deletes Post Depicting Him as Jesus-like Figure After Backlash,
BBC News (Apr.
GOVERNING EVIDENCE:
can be set to auto delete, internal messaging…National Archives and Research Administration warning federal agencies that "[t]he auto-delete functions of third party messaging apps may violate federal record-keeping requirements…shown an advertent disdain for their preservation obligations. President Trump has repeatedly deleted social media posts that should be retained. 52 On September 20, 2025, for example, he…Chief Records Officer, to Fed. Records Mgmt. Contacts (May 2, 2025), https://perma.cc/TAB5-E2ZX . 52 Bernd Debusmann Jr., Trump Deletes Post Depicting Him as Jesus-like Figure After Backlash, BBC News (Apr. 13, 2026), https://perma.cc/6EBF-N3EJ ; Alex Nguyen, A Non-Exhaustive List of Trump's Deleted Posts, Mother Jones (Apr. 13, 2026), https://perma.cc/M8M7-WARP . Case 1:26-cv-02323…James. Though clearly a government record to be preserved under the PRA, the President deleted the post after it became clear that it was in the public domain. 53 It has also been - 566. RETRIEVED EVIDENCE:
13, 2026),
https://perma.cc/6EBF-N3EJ
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 567. RETRIEVED EVIDENCE:
Alex Nguyen, A Non-Exhaustive List of Trump's Deleted Posts, Mother Jones (Apr.
GOVERNING EVIDENCE:
NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L…Russia had interfered in the 2016 presidential election in an effort to boost candidate Donald Trump's chances of winning the election. In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and…and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan as "a very bad guy," "a total low-life," a "loser" and a "political - 568. RETRIEVED EVIDENCE:
13, 2026),
https://perma.cc/M8M7-WARP
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 32 of 4629
prosecutions against James Comey, Adam Schiff and Letitia James.
GOVERNING EVIDENCE:
1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE…Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will…Director Brennan alleges as follows: Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 of 463 INTRODUCTION 1. Director Brennan is a former longtime public servant who…Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are - 569. RETRIEVED EVIDENCE:
Though clearly a government record to be preserved under the PRA, the President deleted the post after it became clear that it was in the public domain.
GOVERNING EVIDENCE:
Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE - 570. RETRIEVED EVIDENCE:
53
It has also been recently reported that President Trump sent a number of direct messages about official matters during his first administration that were never preserved.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency - 571. RETRIEVED EVIDENCE:
54
And he has acted similarly with regard to hard-copy government records,
reportedly once flushing some down a toilet
55
and ripping others into confetti-size pieces.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 572. RETRIEVED EVIDENCE:
56
59.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 573. RETRIEVED EVIDENCE:
Officials across the Executive Branch are exhibiting that same cavalier attitude about their duty to preserve records.
GOVERNING EVIDENCE:
Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes - 574. RETRIEVED EVIDENCE:
57
For example, during the time that Lindsey Halligan purported to serve as the U.S. Attorney in the Eastern District of Virginia, she used Signal to communicate with a journalist about a grand jury investigation under her official authority - i.e., the investigation into New York Attorney General Letitia James - and set the messages to disappear after eight hours.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 575. RETRIEVED EVIDENCE:
58
A whistleblower reportedly accused Ed Martin, formerly head of
53
Kristen Welker & Rebecca Shabad, supra note 22;
GOVERNING EVIDENCE:
use cases at DOJ); Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The…Responsibility 39 and the Director of the Departmental Ethics Office 40 (who had previously given then-Deputy Attorney General Blanche the unwelcome advice that he must recuse…General Letitia James - and set the messages to disappear after eight hours. 58 A whistleblower reportedly accused Ed Martin, formerly head of 53 Kristen Welker & Rebecca Shabad, supra note 22; Josh Dawsey, Sadie Gurman & Aruna Viswanatha, Inside the Justice…prosecution . . . regardless of content"). U.S. Dep't of Just., Just. Manual 9-5.004 (2019). 59 Rebecca Beitsch, Whistleblower Accuses Ed Martin of 'Concealing and Destroying' Records Related to DOJ's Weaponization Group, Hill (Nov…//perma.cc/BG4A-UB6V ; Letter from Jamie Raskin, Ranking Member, H. Comm. on the Judiciary, to Edward P. Martin, Jr., Pardon Att'y and Dir., Weaponization Working Grp., U.S. Dep't of Just. (Nov. 17, 2025 - 576. RETRIEVED EVIDENCE:
Josh Dawsey, Sadie Gurman & Aruna Viswanatha, Inside the Justice Department Where the President Calls the Shots, Wall Street Journal (Oct.
GOVERNING EVIDENCE:
of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 577. RETRIEVED EVIDENCE:
8, 2025),
https://perma.cc/DD4C-35MH
.
54
Nate Jones, Trump Library Says no Twitter DMs Can be Found, Despite Evidence he Sent Them, Washington Post (June 3, 2026),
https://perma.cc/95LK-AWUR
.
55
Edward Helmore, Photos Suggest Trump Blocked Toilets with Ripped-up White House Documents, Guardian (Aug.
GOVERNING EVIDENCE:
as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official…capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning…and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through…Brennan guilty of crimes ranging from treason to lying before Congress, and has twice posted doctored images of Director Brennan in an orange jumpsuit. 4. With his return to the - 578. RETRIEVED EVIDENCE:
8, 2022),
https://perma.cc/A7VV-GP25
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 579. RETRIEVED EVIDENCE:
Mike Allen, Exclusive Photos:
GOVERNING EVIDENCE:
40 Sam Levine, supra note 39; Katelyn Polantz, Evan Perez & Hannah Rabinowitz, Exclusive: Acting AG Todd Blanche was Told Last Year to Recuse from Justice Department Matters…Them, Washington Post (June 3, 2026), https://perma.cc/95LK-AWUR . 55 Edward Helmore, Photos Suggest Trump Blocked Toilets with Ripped-up White House Documents, Guardian (Aug. 8, 2022), https://perma.cc/A7VV-GP25 ; Mike Allen, Exclusive Photos: Trump's Telltale Toilet, Axios (Aug. 8, 2022), https://perma.cc/98QG-ULBK …Working Group. 59 There was also the incident in which National Security Advisor Mike Waltz, Vice President J.D. Vance, CIA Director John Ratcliffe, Treasury Secretary Scott - 580. RETRIEVED EVIDENCE:
Trump's Telltale Toilet, Axios (Aug.
GOVERNING EVIDENCE:
Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L…Russia had interfered in the 2016 presidential election in an effort to boost candidate Donald Trump's chances of winning the election. In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and - 581. RETRIEVED EVIDENCE:
8, 2022),
https://perma.cc/98QG-ULBK
.
56
Annie Karni, Meet the Guys who Tape Trump's Papers Back Together, Politico (June 10,
2018),
https://perma.cc/3A7S-6HZY
.
57
See generally A Disappearing Data Chronology, Nat'l Sec.
GOVERNING EVIDENCE:
of the John Brennan Investigation, CNN (May 8, 2026), https://perma.cc/S58G-9MTK . 13 See generally Appendix A. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 19 of 4616 A…the investigation. 26 44. diGenova is a former United States Attorney and a vocal ally of President Trump. According to diGenova, the President personally appointed him to…lengthy discussion of the current investigations. He confirmed the existence, scope, and general 34 Daniel Klaidman & Sarah N. Lynch, Witnesses in Criminal Probe of Ex-CIA Director…manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26…Aug. 8, 2022), https://perma.cc/98QG-ULBK . 56 Annie Karni, Meet the Guys who Tape Trump's Papers Back Together, Politico (June 10, 2018), https://perma.cc/3A7S-6HZY . 57 See generally A Disappearing Data Chronology, Nat'l Sec. Archive, https - 582. RETRIEVED EVIDENCE:
Archive,
https://perma.cc/55SN
66EV
(last visited June 5, 2026) (collecting instances of the Trump Administration changing or removing information).
GOVERNING EVIDENCE:
orange jumpsuit. 4. With his return to the White House, the…that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not preserved. 12. For this reason, Director Brennan brings this action…Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…attacks. 15. Following his retirement from the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as - 583. RETRIEVED EVIDENCE:
See also DON'T SHRED ON ME!
GOVERNING EVIDENCE:
collecting instances of the Trump Administration changing or removing information). See also DON'T SHRED ON ME! USAID Documents Destruction Breaks the Law, According to National Security…National Security Archive (USAID's Acting Executive Secretary inviting employees to shred or burn classified records and personnel files in March 2025); Kayla Epstein, USAID Staff Told to Shred and Burn Classified Documents, BBC News (Mar. 11, 2025), https://perma.cc/5M2F-JQMZ - 584. RETRIEVED EVIDENCE:
USAID Documents Destruction Breaks the Law, According to National Security Archive, National Security Archive (USAID's Acting Executive Secretary inviting employees to shred or burn classified records and personnel files in March 2025);
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as…N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel - 585. RETRIEVED EVIDENCE:
Kayla Epstein, USAID Staff Told to Shred and Burn Classified Documents,
BBC News (Mar.
GOVERNING EVIDENCE:
as opposition research by a former British intelligence officer) 5 in the…DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https…Prosecutor in John Brennan Investigation Has Been Removed From Case, AP Source Says, AP News (Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the…Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean…Plaintiff). The accusations in the interview were so pointed and unsupported that Fox News felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean…Trump Accidentally Posted Message Pressuring Pam Bondi to Charge his Enemies, Source Says, NBC News (Oct. 10, 2025), https://perma.cc/LX38 A439 . 23 Laura Jarrett & Ryan J. Reilly, Todd Blanche - 586. RETRIEVED EVIDENCE:
11, 2025),
https://perma.cc/5M2F-JQMZ
.
58
Anna Bower, "Anna, Lindsey Halligan Here.", Lawfare (Oct.
GOVERNING EVIDENCE:
v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https://perma.cc/3LTF-UPW2 . 7 Appendix A, at 15-16. 8 Eric Tucker, Key…the Importance of Limiting White House-DOJ Contacts: It's Not Just About Obstruction, Lawfare (May 22, 2017), https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to…day that the president was ripping mad about the fact that there was no progress on the lawfare investigation in Miami. 24In April, the lead career prosecutor on the Brennan…Legal Team Shake-Up Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to…Grand Conspiracy Probe (1), Bloomberg Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page - 587. RETRIEVED EVIDENCE:
20, 2025),
https://perma.cc/DP74-U7XN
. This was contrary to Section 9-5.004 of the federal Justice Manual, which states that "[a]ll prosecution team members should be aware of the government'sobligations regarding the preservation and disclosure of electronic communications, or 'e Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 33 of 4630
the DOJ Weaponization Group, of concealing and destroying communications relating to his work on the Weaponization Working Group.
GOVERNING EVIDENCE:
in his order quashing federal subpoenas directed at…apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not routinely preserved. 2 Second, there is ample…Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for…relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes government personnel and record systems that would have the…Investigations that Target Director Brennan 32. There are currently two ongoing federal grand jury investigations examining past conduct by Director Brennan. According to - 588. RETRIEVED EVIDENCE:
59
There was also the incident in which National Security Advisor Mike Waltz, Vice President J.D.
GOVERNING EVIDENCE:
Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited…prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And - 589. RETRIEVED EVIDENCE:
Vance, CIA Director John Ratcliffe, Treasury Secretary Scott Bessent, DNI Director Tulsi Gabbard, Secretary of War Pete Hegseth, Secretary of State Marco Rubio, and others communicated in a Signal chat (which accidentally included areporter from the Atlantic) about upcoming strikes against Huthi targets in Yemen with messages that indicated on their face that they would disappear at certain intervals - 1 week and 4
weeks.
GOVERNING EVIDENCE:
P. PATEL, in his official capacity as Director of the Federal Bureau of…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation - 590. RETRIEVED EVIDENCE:
60
And on one recent evening, the Associate Attorney General issued a controversial post indicating that the Department would pursue an alternative to the derailed plan to establish a fund to compensate victims of supposed "weaponization" (see supra note 47), but the post was deleted from his Xaccount the next morning.
GOVERNING EVIDENCE:
QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery obligations. These technologies include…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has…laws, or treaties of the United States." Id. This Court also has jurisdiction pursuant to 28 U.S.C. 1361, which grants original jurisdiction to the district courts over - 591. RETRIEVED EVIDENCE:
61
Finally, in arecent challenge to the Administration'smass terminations of government employees, discovery revealed that high-level communications,' which include emails, text messages, SMS (short message service), instant messages, voice mail, pin-to-pin communications, and similar means of electronic communication.
GOVERNING EVIDENCE:
Strong Grounds for Challenging any Criminal…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim…product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…and communications potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying - 592. RETRIEVED EVIDENCE:
. . . Prosecution team members should preserve for later review and possible disclosure all substantive e-communications created or received by team members during the course of an investigation and prosecution . . . regardless of content"). U.S. Dep'tof Just., Just.
GOVERNING EVIDENCE:
11 FACTUAL BACKGROUND…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution…records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by - 593. RETRIEVED EVIDENCE:
Manual 9-5.004 (2019).
GOVERNING EVIDENCE:
//perma.cc/DP74-U7XN . This was contrary to Section 9-5.004 of the federal Justice Manual, which states that "[a]ll prosecution team members should be aware of the government's…investigation and prosecution . . . regardless of content"). U.S. Dep't of Just., Just. Manual 9-5.004 (2019). 59 Rebecca Beitsch, Whistleblower Accuses Ed Martin of 'Concealing - 594. RETRIEVED EVIDENCE:
59
Rebecca Beitsch, Whistleblower Accuses Ed Martin of 'Concealing and Destroying' Records Related to DOJ's Weaponization Group, Hill (Nov.
GOVERNING EVIDENCE:
that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion…and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For…working for six administrations - three Republican and three Democratic - in a wide variety of national security and intelligence positions. His public service career culminated in his…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016 presidential…or written statements that personally criticize and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and - 595. RETRIEVED EVIDENCE:
17, 2025),
https://perma.cc/BG4A-UB6V
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 596. RETRIEVED EVIDENCE:
Letter from Jamie Raskin, Ranking Member, H.
GOVERNING EVIDENCE:
who has never registered as a member of any political party, as…District of Florida since August 13, 2025. In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested…Brennan's alleged false statements to Congress. In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested…personnel who are working on the Brennan investigations. In that role, he has responsibility over subordinates and record systems that would have the records to be preserved under the requested…2017 to January 20, 2021. As the President, he has responsibility over Executive Branch subordinates and record systems that would have the records to be preserved under the requested…White House Chief of Staff since January 20, 2025. In that role, she has responsibility over subordinates and record systems that would have the records to be preserved under the requested - 597. RETRIEVED EVIDENCE:
Comm.
GOVERNING EVIDENCE:
on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S. Dep't of Just…Nov. 17, 2025), https://perma.cc/BG4A-UB6V ; Letter from Jamie Raskin, Ranking Member, H. Comm. on the Judiciary, to Edward P. Martin, Jr., Pardon Att'y and Dir., Weaponization…into allegations that he lied in his testimony to the House of Representatives Committee on the Judiciary on May 11, 2023 and the investigation into the "grand conspiracy" being - 598. RETRIEVED EVIDENCE:
on the Judiciary, to Edward P.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 599. RETRIEVED EVIDENCE:
Martin,
Jr., Pardon Att'yand Dir., Weaponization Working Grp., U.S. Dep'tof Just.
GOVERNING EVIDENCE:
2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use…Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces Formation of Strike Force to Assess Evidence…of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi, Att'y Gen., U.S. Dep't of Just. (Oct. 21, 2025), https://perma.cc/R257-56FL . 5 Trump-Russia Steele…22, 2017), https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009), https://perma.cc/W55M-M7FW (Eric Holder 2009 memo). 20 Memorandum from the Attorney General to All Dep't Emps. (Feb. 5, 2025), https://perma.cc/3PPL-BWER . 21 In-Your-Face DOJ Aide Rides - 600. RETRIEVED EVIDENCE:
(Nov.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 601. RETRIEVED EVIDENCE:
17, 2025),
https://perma.cc/AZ83-JPKH
.
60
Josh Gerstein & Kyle Cheney, Judge Orders Trump Administration to Preserve Signal Chats,
Politico (Mar.
GOVERNING EVIDENCE:
Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw - 602. RETRIEVED EVIDENCE:
27, 2025),
https://perma.cc/AL4Q-NJJ5
. According to reports, the National Security Advisor's team had set up at least 20 Signal group chats to discuss crises in Ukraine,
China, Gaza, the broader Middle East, Africa and Europe.
GOVERNING EVIDENCE:
Officials Publicly Discuss Grand Jury Activity…at the request of President Obama to serve as Assistant to the President for Homeland Security and Counterterrorism and Deputy National Security Advisor in the Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 11 of 468 Executive…was responsible during this time for orchestrating Obama Administration policies on homeland security, pandemics, cyberattacks, and natural disasters. 16. The United States Senate…day. 17. Director Brennan is the recipient of numerous awards, including the National Security Medal, the National Intelligence Distinguished Public Service Medal, the CIA…Director Brennan lied in 2023 testimony before the House Judiciary Committee when he discussed the role of the Steele Dossier (which was reportedly a batch of materials about then…to the only judge in that Division - Judge Aileen Cannon. This April, the prosecution team established its headquarters in the U.S. Attorney's Office in Fort Pierce. 12 Fort - 603. RETRIEVED EVIDENCE:
Dasha Burns, Waltz's Team Set Up at Least 20 Signal Group Chats for Crises Across the World, Politico (Apr.
GOVERNING EVIDENCE:
opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge…provided legal services in support of the President's causes, temporarily joining the President's team of lawyers dealing with the Mueller Special Counsel investigation and serving on the legal team challenging the results of the 2020 presidential election. 29 He has been a passionate…guilty of participation in the supposed "grand conspiracy," calling 26 In building that team, diGenova has recruited attorneys with demonstrated devotion to President Trump and his…N.Y. Times (Feb. 12, 2026), https://perma.cc/483P-DP3P ; Trump-Russia: President's Legal Team Shake-Up Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower &…Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News (Mar. 19, 2018), https://perma.cc/ZP79-WTLH . 29 Id.; Trump Lawyer - 604. RETRIEVED EVIDENCE:
2, 2025),
https://perma.cc/6WKP-3K5W
. Importantly, the messages about the Yemen strikes were ultimately deleted from the phone of CIA Director John Ratcliffe.
GOVERNING EVIDENCE:
99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington…Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation…Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product - 605. RETRIEVED EVIDENCE:
Julian E.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 606. RETRIEVED EVIDENCE:
Barnes, C.I.A.
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which concluded that Russia had interfered in the 2016…grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice Department have succumbed…senior Administration officials in the run-up to the First Gulf War (1990-91); daily intelligence briefer for President Bill Clinton and Vice President Al Gore (1994-95); senior U.S. intelligence official resident in Saudi Arabia (1996-99); Chief of Staff to Director of Central Intelligence George Tenet (1999-2001); and, Deputy Executive Director of the CIA (2001-03). As - 607. RETRIEVED EVIDENCE:
Director's Messages in Leaked Chat Were Deleted, Agency Says, N.Y.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr.…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 608. RETRIEVED EVIDENCE:
Times (Apr.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 609. RETRIEVED EVIDENCE:
15, 2025),
https://perma.cc/BF54-6CS2
.
61
Alexander Mallin, Top DOJ Official Deletes Post on Alternate 'Anti-weaponization'
Compensation Plan, ABC News (June 3, 2026),
https://perma.cc/QNU3-RX5L
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 34 of 4631
officials in the Department of Homeland Security used Signal groups on their personal phones to communicate, and that Justice Department attorneys failed to adequately preserve those materials.
GOVERNING EVIDENCE:
v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington, DC…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency - 610. RETRIEVED EVIDENCE:
62
60.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 611. RETRIEVED EVIDENCE:
This preservation concern is only exacerbated by the frequent personnel changes among those in the chain of command in these retribution cases.
GOVERNING EVIDENCE:
......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional - 612. RETRIEVED EVIDENCE:
Many of those involved in different stages of Director Brennan'sinvestigations have left or are leaving government service, to include a number of DOJ line prosecutors and supervisors, former Attorney General Bondi, and DNI Tulsi Gabbard, the source of one of the "grand conspiracy" referrals.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave…Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel - 613. RETRIEVED EVIDENCE:
As these personnel depart and surrender their electronic devices, there is heightened risk that information will be lost and little reason for confidence that the necessary steps will be taken to preserve it.
GOVERNING EVIDENCE:
questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…work on these presidentially-driven investigations, certain Justice Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial…government officials are increasingly relying on communications that are not routinely preserved, even though they should be, pursuant to the government's statutory and discovery - 614. RETRIEVED EVIDENCE:
See Letter Mot.
GOVERNING EVIDENCE:
originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi. 4 In that letter, Chairman Jordan, a close ally of President Trump, refers for investigation - without any valid…v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi…particular judge. That concern became so pronounced that undersigned counsel submitted a letter to the Chief Judge of the Southern District of Florida alerting her to the government's…Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had…s neutral and impartial processes. 11 37. Despite the concerns laid out in that letter, the Justice Department remains seemingly committed to its plan to steer any - 615. RETRIEVED EVIDENCE:
at 8, United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 616. RETRIEVED EVIDENCE:
McIver, No. 25-cr-388 (D.N.J.
GOVERNING EVIDENCE:
13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the…production of the ICA. II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations 35. Justice…on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https…& Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News (Mar. 19 - 617. RETRIEVED EVIDENCE:
Dec.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 618. RETRIEVED EVIDENCE:
23, 2025), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed - 619. RETRIEVED EVIDENCE:
No. 57 ("[T]he senior official's government device had been wiped when he left government service ... months after the government had supposedly instituted a preservation hold.").
61.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW Washington - 620. RETRIEVED EVIDENCE:
This Administration has also demonstrated a willingness to defy record preservation laws and conventions as amatter of policy.
GOVERNING EVIDENCE:
QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice…Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel - 621. RETRIEVED EVIDENCE:
In April 2026, the Office of Legal Counsel (OLC) at the Justice Department issued an opinion that the PRA is unconstitutional,
63
which was followed the next day with amemorandum from White House Counsel David Warrington.
GOVERNING EVIDENCE:
be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small…counterterrorism community that contributed to the failure to prevent the 9/11 terrorist attacks. 15. Following his retirement from the CIA in 2005, Director Brennan returned to government service in…of the CIA in a bipartisan 63-34 vote on March 7, 2013. He was sworn into office the following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff - 622. RETRIEVED EVIDENCE:
The Warrington
62
Reply at 3, 11-14, Am.
GOVERNING EVIDENCE:
63 which was followed the next day with a memorandum from White House Counsel David Warrington. The Warrington 62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal…the grand jury proceeding that had produced the felony 64 Memorandum from David Alan Warrington, Assistant to the President and Counsel to the President, to Staff, Executive Office of the President (Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21 - 623. RETRIEVED EVIDENCE:
Fed'n of Gov't Emps., AFL-CIO v.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 624. RETRIEVED EVIDENCE:
Trump, No. 25-cv-3698 (N.D.
GOVERNING EVIDENCE:
officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L…election in an effort to boost candidate Donald Trump's chances of winning the election. In the years since the issuance of the ICA, President Trump has often expressed his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written statements that - 625. RETRIEVED EVIDENCE:
Cal.
GOVERNING EVIDENCE:
62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to…Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025), Dkt. No. 261. 70 Id. 71 An example of this practice can be seen - 626. RETRIEVED EVIDENCE:
June 17, 2026), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed - 627. RETRIEVED EVIDENCE:
No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients' extensive use of disappearing Signal messages in disregard of their obligation to investigate, or they knowingly participated in the concealment.").
63
See Constitutionality of the Presidential Records Act, 50 Op.
GOVERNING EVIDENCE:
in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street…s perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in - 628. RETRIEVED EVIDENCE:
O.L.C.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 629. RETRIEVED EVIDENCE:
(Apr, 1, 2026) (slip op.
GOVERNING EVIDENCE:
63 See Constitutionality of the Presidential Records Act, 50 Op. O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- - 630. RETRIEVED EVIDENCE:
at
1, 50),
https://perma.cc/V4M7-NQFA
;
GOVERNING EVIDENCE:
Impact Assessment for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How…Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN . Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 10 of 467 the…Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug. 4, 2025), https://perma.cc/HCG8 H5KJ ; Press Release, U.S. Dep't of Just., Justice Department Announces…Formation of Strike Force to Assess Evidence Publicized by ODNI (July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury - 631. RETRIEVED EVIDENCE:
see generally Am.
GOVERNING EVIDENCE:
and similar matters, which has negated the traditional "presumption of regularity" that generally insulates most government investigative activity from probing judicial scrutiny. 9…including the successful operation against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama…of the John Brennan Investigation, CNN (May 8, 2026), https://perma.cc/S58G-9MTK . 13 See generally Appendix A. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 19 of 4616 A…lengthy discussion of the current investigations. He confirmed the existence, scope, and general 34 Daniel Klaidman & Sarah N. Lynch, Witnesses in Criminal Probe of Ex-CIA Director…manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26…57 See generally A Disappearing Data - 632. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 - 633. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding - 634. RETRIEVED EVIDENCE:
Trump,
--- F.
GOVERNING EVIDENCE:
Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L - 635. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 636. RETRIEVED EVIDENCE:
3d.
GOVERNING EVIDENCE:
recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr…2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J - 637. RETRIEVED EVIDENCE:
---, 2026 WL 1412395 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 638. RETRIEVED EVIDENCE:
May 20, 2026).
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 639. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 35 of 4632
memo
64
significantly limited the circumstances under which text communications need to be retained.
GOVERNING EVIDENCE:
Would Require Access to Government Materials and Communications to Assess the…over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind…legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of…the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any…his first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated Director Brennan - 640. RETRIEVED EVIDENCE:
62.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 641. RETRIEVED EVIDENCE:
Importantly, the concern about the preservation of records of value to Director Brennan is only heightened by the evidence that this Administration has shown itself willing to withhold records that cut against its interests.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in - 642. RETRIEVED EVIDENCE:
For example, in the prosecution of Congresswoman LaMonica McIver for interfering with federal officers during afracas while conducting an oversight visit to an ICE facility, the prosecutors initially refused to provide any discovery.
GOVERNING EVIDENCE:
13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as Vindictive and Selective…to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation…s other perceived adversaries. 1 5. This effort has resulted in the opening of two federal investigations that purport to be investigating Director Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials…but is apparently based on the theoretical premise that the investigations into Russian interference in the 2016 election and the other Trump-related investigations in the succeeding years - 643. RETRIEVED EVIDENCE:
65
When compelled to do so by the court, it was revealed that significant important discovery material had been lost, including relevant messages on the phones of federal agents at the scene that had not been collected and information on asenior official's phone that had been wiped,
despite the existence of alitigation hold.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of…Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes…of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to - 644. RETRIEVED EVIDENCE:
66
In the criminal prosecution of protesters in United States v.
GOVERNING EVIDENCE:
Charges as Vindictive and Selective Prosecution ........................................................................................... 24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the…Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent…or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and - 645. RETRIEVED EVIDENCE:
Rabbitt (known as the Broadview 6 case), federal prosecutors balked at the court's request to review the grand jury transcripts.
GOVERNING EVIDENCE:
................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by…to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation…s other perceived adversaries. 1 5. This effort has resulted in the opening of two federal investigations that purport to be investigating Director Brennan for what amounts to…s alleged false statements to Congress. Then, over the weekend of April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former - 646. RETRIEVED EVIDENCE:
67
At first, they provided only redacted versions, and when the judge insisted on the full transcripts, they even reduced the felony charges to misdemeanors in an attempt to moot out the grand jury proceeding that had produced the felony
64
Memorandum from David Alan Warrington, Assistant to the President and Counsel to the President, to Staff, Executive Office of the President (Apr.
GOVERNING EVIDENCE:
Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in…s adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr…quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 647. RETRIEVED EVIDENCE:
2, 2026),
https://perma.cc/R5G5
UAFW
("Warrington Memo"). See Mem.
GOVERNING EVIDENCE:
emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their…Contacts: It's Not Just About Obstruction, Lawfare (May 22, 2017), https://perma.cc/KS5W-NY27; Memorandum from the Attorney General to the Heads of Dep't Components, All U.S. Att'ys (May 11, 2009), https://perma.cc/W55M-M7FW (Eric Holder 2009 memo). 20 Memorandum from the Attorney General to All Dep't Emps. (Feb. 5, 2025), https…to handle the resulting far-fetched investigation (see supra note 8); prosecution memoranda and other materials reflecting assessments about the strength of any potential cases…802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010…P.H.E., Inc., 965 F.2d 848, 850, 853, 858 (10th Cir. 1992) (district court reviewed prosecution memoranda and letter from U.S. Attorney to Attorney General to evaluate vindictive prosecution - 648. RETRIEVED EVIDENCE:
3-4, Am.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 649. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 - 650. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding - 651. RETRIEVED EVIDENCE:
Trump, No. 26-cv-1169
(D.D.C.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 652. RETRIEVED EVIDENCE:
Apr.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 653. RETRIEVED EVIDENCE:
21, 2026), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed - 654. RETRIEVED EVIDENCE:
No. 19-2.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 655. RETRIEVED EVIDENCE:
A federal judge of this Court has since enjoined implementation of the OLC opinion, Am.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA…2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using…to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason - 656. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 - 657. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding - 658. RETRIEVED EVIDENCE:
Trump,
--- F.
GOVERNING EVIDENCE:
Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L - 659. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 660. RETRIEVED EVIDENCE:
3d.
GOVERNING EVIDENCE:
recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr…2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J - 661. RETRIEVED EVIDENCE:
---, 2026 WL 1412395, rejecting the government'sclaim that it did not need to preserve text messages (or other related messaging apps such as Signal and WhatsApp).
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 662. RETRIEVED EVIDENCE:
Am.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 663. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 - 664. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding - 665. RETRIEVED EVIDENCE:
Trump,
--- F.
GOVERNING EVIDENCE:
Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate…above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years…District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President of the United States; the Executive Office of the President; Susan L - 666. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 667. RETRIEVED EVIDENCE:
3d.
GOVERNING EVIDENCE:
recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr…2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J - 668. RETRIEVED EVIDENCE:
---, 2026 WL 1412395, at *7 & n.6.
GOVERNING EVIDENCE:
& [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…And 18 (D.D.C. 2023) (providing overview of McDade Amendment), aff'd, 2024 WL 3385251 (D.C. Cir. July 12, 2024). 43 Press Release, U.S. Dep't of Just., Justice…2025) (considering emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010) (noting that the court did an in camera…documents" in assessing claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive…514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr. 20, 2021) (Contreras, J), and "[t]he government - 669. RETRIEVED EVIDENCE:
65
Letter, United States v.
GOVERNING EVIDENCE:
originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi. 4 In that letter, Chairman Jordan, a close ally of President Trump, refers for investigation - without any valid…v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi…particular judge. That concern became so pronounced that undersigned counsel submitted a letter to the Chief Judge of the Southern District of Florida alerting her to the government's…Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had…s neutral and impartial processes. 11 37. Despite the concerns laid out in that letter, the Justice Department remains seemingly committed to its plan to steer any - 670. RETRIEVED EVIDENCE:
McIver, No. 25-cr-388 (D.N.J.
GOVERNING EVIDENCE:
13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the…production of the ICA. II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations 35. Justice…on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https…& Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News (Mar. 19 - 671. RETRIEVED EVIDENCE:
Sep.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 672. RETRIEVED EVIDENCE:
10, 2025), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed - 673. RETRIEVED EVIDENCE:
No. 26-2
(government stating it would not provide any discovery).
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF…filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 674. RETRIEVED EVIDENCE:
66
Letter Mot.
GOVERNING EVIDENCE:
originated with an October 21, 2025, letter from Congressman Jim Jordan, Chairman of the House Judiciary Committee, to then-Attorney General Pam Bondi. 4 In that letter, Chairman Jordan, a close ally of President Trump, refers for investigation - without any valid…v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from Jim Jordan, Chairman of the H. Comm. on the Judiciary, 119th Cong., to Pamela J. Bondi…particular judge. That concern became so pronounced that undersigned counsel submitted a letter to the Chief Judge of the Southern District of Florida alerting her to the government's…Apr. 17, 2026), https://perma.cc/4362-XJE5 . 9 Appendix A, at8. As of the writing of the letter in Appendix A, it was public knowledge that the investigations targeting Director Brennan had…s neutral and impartial processes. 11 37. Despite the concerns laid out in that letter, the Justice Department remains seemingly committed to its plan to steer any - 675. RETRIEVED EVIDENCE:
at 2-11, United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 676. RETRIEVED EVIDENCE:
McIver, No. 25-cr-388 (D.N.J.
GOVERNING EVIDENCE:
13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any Criminal Charges as…deal more effectively with the national security challenges of the future. The resulting new organizational structure remains in place to this day. 17. Director Brennan is the…production of the ICA. II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations 35. Justice…on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https…& Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News (Mar. 19 - 677. RETRIEVED EVIDENCE:
Dec.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 678. RETRIEVED EVIDENCE:
23, 2025), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed - 679. RETRIEVED EVIDENCE:
No.
57.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 680. RETRIEVED EVIDENCE:
67
Hr'g Tr.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 681. RETRIEVED EVIDENCE:
at 20-24, United States v.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 682. RETRIEVED EVIDENCE:
Rabbitt, No. 25-cr-693 (N.D.
GOVERNING EVIDENCE:
emails, internal DOJ memoranda); United States v. Jarrett, 2010 WL 1577670, at *4 (N.D. Ind. Apr. 20, 2010) (noting that the court did an in camera review of "hundreds of…62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully…23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323…Summ. J. 15-16, Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025), Dkt. No. 261. 70 Id. 71 An example of this practice can be - 683. RETRIEVED EVIDENCE:
Ill.
GOVERNING EVIDENCE:
interviews and Presidential statements - President Trump has excoriated Director Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has…to adequately preserve those materials. 62 60. This preservation concern is only exacerbated by the frequent personnel changes among those in the chain of command in these…No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 - 684. RETRIEVED EVIDENCE:
May 21, 2026), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed - 685. RETRIEVED EVIDENCE:
No.
187,
https://perma.cc/S55U-H2GJ
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 36 of 4633
charges.
GOVERNING EVIDENCE:
Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF…22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will…look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the…Director Brennan alleges as follows: Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 of 463 INTRODUCTION 1. Director Brennan is a former longtime public servant who…Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 7 of 464 Investigation ("FBI") leadership have acceded to that direction, and are - 686. RETRIEVED EVIDENCE:
When the judge finally received and reviewed unredacted copies of the transcripts, she observed, "Ihave never seen the types of prosecutorial behavior before agrand jury that Isaw in those transcripts."
68
In arecent civil case involving the mass termination of grants awarded by the National Endowment for the Humanities, the judge faulted the government for conducting an inadequate search for relevant documents, determined that the government had provided arecord that omitted clearly relevant materials, and therefore concluded that "the presumption of regularity gives way" in light of these irregularities.
GOVERNING EVIDENCE:
There is a Serious Risk that Highly Relevant Internal Government Materials and…investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record preservation and…and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For…by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden Administration officials. This…investigations, certain Justice Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial conduct. Those…and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who directed, oversaw - 687. RETRIEVED EVIDENCE:
Authors Guild v.
GOVERNING EVIDENCE:
that "the presumption of regularity gives way" in light of these irregularities. Authors Guild v. Nat'l Endowment for the Humanities, 2025 WL 3678097, at *12 (S.D.N.Y. Dec. 18, 2025). Finally - 688. RETRIEVED EVIDENCE:
Nat'l Endowment for the Humanities, 2025 WL 3678097, at *12 (S.D.N.Y.
GOVERNING EVIDENCE:
Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations…production of the ICA. II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations 35. Justice…on file with Plaintiff); Anna Bower & Molly Roberts, The Grand Conspiracy's New Prosecutor May be the Case's Biggest Liability, Lawfare (Apr. 27, 2026), https…Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https://perma.cc/3UX5-XCMT (Appendix A). 12 Paula…27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team, PBS News (Mar. 19, 2018), https…Jury Activity 48. While this frantic activity is ongoing, there continues to be an unprecedented amount of public discussion by DOJ officials detailing investigative activity that is - 689. RETRIEVED EVIDENCE:
Dec.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 690. RETRIEVED EVIDENCE:
18, 2025).
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 691. RETRIEVED EVIDENCE:
Finally, in arecent challenge to the termination of federal probationary employees, adistrict court found the administrative record was a "sham" that was "scattered with innumerable references to calls, discussions,
documents, and decisions that underpin, but have been excluded from, the government'snarrow record."
69
As the judge colorfully explained, the experience of reviewing the government's intentionally incomplete record was as though one were "being led, blindfolded, along acarefully plotted path through adense, unseen wood.
GOVERNING EVIDENCE:
Strong Grounds for Challenging any Criminal Charges…of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…Governor Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of…Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by - 692. RETRIEVED EVIDENCE:
Here and there, he may hear arustle in the trees, feel the dark silhouette of a towering form, or intuit some other hint at the forest beyond,
but never is he afforded an unfettered view of the landscape through which he passes."
70
63.
GOVERNING EVIDENCE:
and the court hears them. This…wrongdoing by the Trump administration." Devlin Barrett, Justice Dept. Watchdog Has Gone Silent, Lawyers for Whistle-Blower Say, N.Y. Times (Mar. 30, 2026), https…along a carefully plotted path through a dense, unseen wood. Here and there, he may hear a rustle in the trees, feel the dark silhouette of a towering form, or intuit some other hint at the forest beyond, but never is he afforded an unfettered view of the landscape…that will require access to the government's internal materials and communications at a hearing on a vindictive prosecution motion. The vast majority of defendants cannot show such…that the government will be obligated to produce those records at a post-indictment hearing. As such, they will be unable to establish a pre-indictment right to judicial…records until such time as they are required for production and review in a pre-trial hearing about whether the government acted vindictively and selectively in charging Director - 693. RETRIEVED EVIDENCE:
Given that record of obfuscation
71
and disregard of record preservation requirements, it is difficult to have confidence that Justice Department officials will retain the internal records that
68
Id.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC…challenge, the court presiding over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida - 694. RETRIEVED EVIDENCE:
69
Order on Cross-Mots.
GOVERNING EVIDENCE:
1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve…foundation of these "criminal referrals." 3 Hannah Rabinowitz, Attorney General Bondi Orders Prosecutors to Start Grand Jury Probe into Obama Officials Over Russia Investigation, CNN (Aug…decision-making. In recent comments defending the President's September 20, 2025, order to then-Attorney General Bondi to prosecute three of 18 Donald J. Trump…various mechanisms for investigating or sanctioning official DOJ misconduct. It has been methodically removing or silencing those career civil servants who are responsible for internally…involving Director Brennan - who might be tempted to follow President Trump's orders without regard to legal or ethical limitations. And 18 (D.D.C. 2023) (providing…related to the DOJ's recusal of the three principal Detroit U.S. Attorneys" and ordered that evidence turned over to defendant); United States v. P.H.E., Inc., 965 F.2d 848 - 695. RETRIEVED EVIDENCE:
for Summ.
GOVERNING EVIDENCE:
officials will retain the internal records that 68 Id. 69 Order on Cross-Mots. for Summ. J. 15-16, Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D - 696. RETRIEVED EVIDENCE:
J.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 697. RETRIEVED EVIDENCE:
15-16, Am.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 698. RETRIEVED EVIDENCE:
Fed.
GOVERNING EVIDENCE:
Against Federal Government Attorneys (May 13, 2026), https://perma.cc/CXC6-RMUH . 44 91 Fed. Reg. 10780 (Mar. 5, 2026) (codified at 28 C.F.R. pt. 77). 45 Id. 46 These…50 See supra note 2. 51 Memorandum from William Fischer, Chief Records Officer, to Fed. Records Mgmt. Contacts (May 2, 2025), https://perma.cc/TAB5-E2ZX . 52 Bernd…from White House Counsel David Warrington. The Warrington 62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt…retain the internal records that 68 Id. 69 Order on Cross-Mots. for Summ. J. 15-16, Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025 - 699. RETRIEVED EVIDENCE:
Of Gov.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 700. RETRIEVED EVIDENCE:
Emps.
GOVERNING EVIDENCE:
Eric Holder 2009 memo). 20 Memorandum from the Attorney General to All Dep't Emps. (Feb. 5, 2025), https://perma.cc/3PPL-BWER . 21 In-Your-Face DOJ Aide Rides…Counsel David Warrington. The Warrington 62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3…that 68 Id. 69 Order on Cross-Mots. for Summ. J. 15-16, Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025), Dkt - 701. RETRIEVED EVIDENCE:
v.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 702. RETRIEVED EVIDENCE:
U.S. Off.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 703. RETRIEVED EVIDENCE:
of Personnel Mgmt., No. 25-cv-1780 (N.D.
GOVERNING EVIDENCE:
Personnel…apply to only a small subset of officials, and the vast majority of Justice Department personnel are maintaining adherence to professional standards and carrying out their duties in the…of the Justice Department. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 8 of 465 personnel who had worked on the ICA, requiring them to testify before the grand jury in the…a federal agency responsible for enforcing federal criminal laws. It includes government personnel and record systems that would have the records to be preserved under the requested…served as the Director of the FBI since February 20, 2025. He supervises FBI agents and other personnel who are working on the Brennan investigations. In that role, he has responsibility over…13 of 4610 24. Defendant Executive Office of the President provides operational and management support to the President. It includes government personnel and record systems that would have the records to be preserved under the requested - 704. RETRIEVED EVIDENCE:
Cal.
GOVERNING EVIDENCE:
62 Reply at 3, 11-14, Am. Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to…Am. Fed. Of Gov. Emps. v. U.S. Off. of Personnel Mgmt., No. 25-cv-1780 (N.D. Cal. Sep. 12, 2025), Dkt. No. 261. 70 Id. 71 An example of this practice can be seen - 705. RETRIEVED EVIDENCE:
Sep.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 706. RETRIEVED EVIDENCE:
12, 2025), Dkt.
GOVERNING EVIDENCE:
it. See Letter Mot. at 8, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57 ("[T]he senior official's government device had been wiped when he left…Fed'n of Gov't Emps., AFL-CIO v. Trump, No. 25-cv-3698 (N.D. Cal. June 17, 2026), Dkt. No. 421, at 3, 11-14 ("Either DOJ attorneys were willfully blind to their clients…Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC…at *7 & n.6. 65 Letter, United States v. McIver, No. 25-cr-388 (D.N.J. Sep. 10, 2025), Dkt. No. 26-2 (government stating it would not provide any discovery). 66 Letter Mot. at 2-11, United States v. McIver, No. 25-cr-388 (D.N.J. Dec. 23, 2025), Dkt. No. 57. 67 Hr'g Tr. at 20-24, United States v. Rabbitt, No. 25-cr-693 (N.D. Ill. May 21, 2026), Dkt. No. 187, https://perma.cc/S55U-H2GJ . Case 1:26-cv-02323 Document 1 Filed - 707. RETRIEVED EVIDENCE:
No. 261.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 708. RETRIEVED EVIDENCE:
70
Id.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 709. RETRIEVED EVIDENCE:
71
An example of this practice can be seen in the recent release of the Epstein files, where the Justice Department was less than transparent in redacting passages that were inconvenient for President Trump, Nik Popli, Trump Administration Removes Some Redactions from Epstein Files After Outcry from Lawyers, Time (Feb.
GOVERNING EVIDENCE:
DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON…ensure that Todd W. Blanche, Acting Attorney General; the United States Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida…potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1…as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying before…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 - 710. RETRIEVED EVIDENCE:
9, 2026),
https://perma.cc/ZGW3-H6ZK
("Among the material Raskin said he encountered was a redacted passage summarizing comments Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 37 of 4634
will be central to Director Brennan'seffort to defend his constitutional rights in the absence of judicial intervention.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis…of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…s adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr - 711. RETRIEVED EVIDENCE:
VII.
GOVERNING EVIDENCE:
26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials…s effort to defend his constitutional rights in the absence of judicial intervention. VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and - 712. RETRIEVED EVIDENCE:
Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights
64.
GOVERNING EVIDENCE:
DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 713. RETRIEVED EVIDENCE:
Based on the foregoing, Director Brennan and this Court cannot rely on the government'sadherence to its standard discovery obligations to ensure he will have the ability to protect his constitutional rights.
GOVERNING EVIDENCE:
JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 714. RETRIEVED EVIDENCE:
That is abundantly clear from salient points about the government's conduct that clearly come through in the foregoing factual discussion - the Justice Department's consistent pattern of irregular conduct in this and other retribution cases;
GOVERNING EVIDENCE:
Personnel from Accountability for Their Irregular Conduct .................................... 22 III. The Government's Unprecedented, Irregular Conduct Will Provide Strong Grounds for Challenging any…criminal justice system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director…that purport to be investigating Director Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials…to suggest that responsibility for the resulting lapses is widely shared within the Department. To the contrary, the concerns that necessitate this complaint apply to only a small…investigations, certain Justice Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial conduct. Those overreaching actions have violated Director Brennan's constitutional rights and - 715. RETRIEVED EVIDENCE:
the repeated flouting of its discovery obligations;
GOVERNING EVIDENCE:
obligations…preserved, even though they should be, pursuant to the government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete…as a remedy for spoliation of records that should been preserved and produced in discovery, as it may never come to light that a particular discoverable communication ever existed in the first place and was auto deleted or otherwise not…will be directly due to the government's action - or inaction - in regard to its preservation obligations, and the injury will be directly redressed by a judicial injunction ordering the…Altonaga lays out many of the government's irregular actions up to that time. To avoid repeating their details here, that letter is incorporated by reference and included as Appendix A…that must be preserved. 55. The government has ongoing statutory and constitutional obligations to preserve evidence and records of the type that will be relevant to Director Brennan's - 716. RETRIEVED EVIDENCE:
and the widespread disregard for the preservation requirements for government records.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i - 717. RETRIEVED EVIDENCE:
Under these circumstances, Director Brennan is entitled to injunctive relief,
as there is every reason to believe that he will be limited in his ability to protect his constitutional rights without an injunction directing the government to preserve those records.
GOVERNING EVIDENCE:
capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 718. RETRIEVED EVIDENCE:
65.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 719. RETRIEVED EVIDENCE:
For the same reasons Director Brennan is entitled to injunctive relief, he is equally and alternatively entitled to awrit of mandamus compelling the government to preserve those records to permit the defense of his constitutional rights.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full - 720. RETRIEVED EVIDENCE:
Director Brennan therefore alternatively requests that the Court issue awrit of mandamus compelling the government to preserve the records enumerated below.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 721. RETRIEVED EVIDENCE:
attributed to President Trump by Epstein's lawyers that contradicted Trump's public claims that he had expelled Epstein from his Mar-a-Lago club in Florida.");
GOVERNING EVIDENCE:
for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…history of using criminal investigations to retaliate against and pressure the President's political and personal adversaries." In re Grand Jury Subpoenas Nos. 2022R00519-A - 722. RETRIEVED EVIDENCE:
Rep.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 723. RETRIEVED EVIDENCE:
Davis Min, U.S. House of Representatives, Rep.
GOVERNING EVIDENCE:
to representatives of the government under the "presumption of regularity." Traditionally, "in the absence of clear evidence to the contrary, courts presume that [government representatives] have…public claims that he had expelled Epstein from his Mar-a-Lago club in Florida."); Rep. Davis Min, U.S. House of Representatives, Rep. Dave Min on CNN 02/10/2026, at 4:49-6:04 (YouTube, Feb. 10, 2026) (clip of CNN television broadcast, aired Feb. 10, 2026, at 07:40 ET), https://min.house.gov/media/press-releases/watch-rep-min-cnn-all-reeks-cover-right-now-and we-need-release-entire-epstein ( https…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of…Department personnel or with any persons outside of the Justice Department, including representatives or staff of the White House and of Congress; e) All records of communications, public - 724. RETRIEVED EVIDENCE:
Dave Min on CNN 02/10/2026, at 4:49-6:04 (YouTube, Feb.
GOVERNING EVIDENCE:
against Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama Administration…XTZQ ; LA Times Studios, Straight to the Point: The Grand Conspiracy Against Trump (YouTube, May 7, 2026), https://www.youtube.com/watch?v=h03Rtq3SwYM ( https://perma.cc/7EBH-NGDC on file with Plaintiff); Hang out with Sean Hannity & Fox News, Kash Patel Uncovers Secret FBI Documents; The De-Weaponization Plan | Hang Out with Sean Hannity, at 38:00-39:40 (YouTube, May 5, 2026), https://www.youtube.com/watch?v=0zhi1bmlIjc ( https://perma.cc/QZ2H-WYLZ on file with Plaintiff). 4 Letter from…her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https://perma.cc/W5XD-GR43 on file with Plaintiff); Anna - 725. RETRIEVED EVIDENCE:
10, 2026)
(clip of CNN television broadcast, aired Feb.
GOVERNING EVIDENCE:
Osama Bin Ladin and actions that dismantled Al Qa'ida's worldwide terrorist network. He also was responsible during this time for orchestrating Obama Administration…her to the government's judge-shopping and asking that she use her supervisory 6 Fox News, DiGenova: John Brennan Should Get a Good Lawyer (YouTube, May 18, 2018) (clip of Fox News television broadcast), https://www.youtube.com/watch?v=e7v22N2QrW8 ( https…Fizzle, CNN (Mar. 10, 2026), https://perma.cc/HNA6-LTUF . 15 Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with Sean…Plaintiff). The accusations in the interview were so pointed and unsupported that Fox News felt compelled to add an extraordinary disclaimer to that episode of Hang Out with Sean…Trump Accidentally Posted Message Pressuring Pam Bondi to Charge his Enemies, Source Says, NBC News (Oct. 10, 2025), https://perma.cc/LX38 A439 . 23 Laura Jarrett & Ryan J. Reilly, Todd Blanche - 726. RETRIEVED EVIDENCE:
10, 2026, at 07:40 ET),
https://min.house.gov/media/press-releases/watch-rep-min-cnn-all-reeks-cover-right-now-and we-need-release-entire-epstein
(
https://perma.cc/4SNG-HK2Bon file with Plaintiff), and in withholding documents that alleged wrongdoing by him, Stephen Fowler, Justice Department Withheld and Removed Some Epstein Files Related to Trump, NPR (Feb.
GOVERNING EVIDENCE:
documents relating to the supposed "grand conspiracy" and the other relating to Director Brennan's alleged false statements to Congress. Then, over the weekend of April 18, 2026, a federal grand…as the basis for challenges to any resulting charges, including motions to dismiss any indictment on the grounds that it is the result of selective and vindictive prosecution. 8. To…activity from probing judicial scrutiny. 9. To perform that scrutiny after an indictment, the Court would demand access to a wide range of the government's communications and…General since April 20, 2026. He has been assigned to lead the investigations into the alleged "grand conspiracy" and into Director Brennan's alleged false statements to Congress. In that role, he has responsibility over subordinates and…in the District of Columbia opened an investigation and issued subpoenas in relation to the allegation that Director Brennan made false statements to Congress. The government prosecutors have informed - 727. RETRIEVED EVIDENCE:
24, 2026),
https://perma.cc/9BZ2-9ZAU
.
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 38 of 4635
COUNT 1
Equitable Action to Enjoin Unconstitutional Conduct
66.
GOVERNING EVIDENCE:
action asking the Court to enjoin the government to preserve any and…D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026…Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 38 of 4635 COUNT 1 Equitable Action to Enjoin Unconstitutional Conduct 66. Director Brennan re-alleges and incorporates by reference paragraphs…1 through 65. Based on the foregoing, Director Brennan requests that this Court enjoin Defendants to preserve all records enumerated below in the Request for Relief until such…v. Exceptional Child Ctr., Inc., 575 U.S. 320, 327 (2015) ("The ability to sue to enjoin unconstitutional actions by state and federal officers is the creation of courts of…England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding plaintiffs likely had an equitable cause of action under Armstrong to require that White House officials preserve records - 728. RETRIEVED EVIDENCE:
Director Brennan re-alleges and incorporates by reference paragraphs 1 through 65.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 729. RETRIEVED EVIDENCE:
Based on the foregoing, Director Brennan requests that this Court enjoin Defendants to preserve all records enumerated below in the Request for Relief until such time as the Court releases the injunction upon its determination that those records will no longer be needed for the protection of Director Brennan'sconstitutional rights in the criminal justice system.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 730. RETRIEVED EVIDENCE:
67.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 731. RETRIEVED EVIDENCE:
It is well established that the courts have the inherent authority to provide injunctive relief in asituation where the government is taking action that may violate an individual'sconstitutional rights.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under…subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this Administration has adopted a policy of using criminal process and…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason - 732. RETRIEVED EVIDENCE:
See Armstrong v.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 733. RETRIEVED EVIDENCE:
Exceptional Child Ctr., Inc., 575 U.S. 320, 327 (2015)
("The ability to sue to enjoin unconstitutional actions by state and federal officers is the creation of courts of equity, and reflects a long history of judicial review of illegal executive action,
tracing back to England.");
GOVERNING EVIDENCE:
Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell…that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws. It includes government personnel and record systems that would have the…that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 22. Defendant Kash P. Patel has served as the Director of…that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 23. Defendant Donald J. Trump has served as the President…that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 13 of 4610 24 - 734. RETRIEVED EVIDENCE:
Am.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 735. RETRIEVED EVIDENCE:
Hist.
GOVERNING EVIDENCE:
they take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20…O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026…Apr. 2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's…text messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter…action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 - 736. RETRIEVED EVIDENCE:
Ass'n v.
GOVERNING EVIDENCE:
take steps to ensure the conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026…Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20, 2026). Case 1…2, 2026), https://perma.cc/R5G5 UAFW ("Warrington Memo"). See Mem. 3-4, Am. Hist. Ass'n v. Trump, No. 26-cv-1169 (D.D.C. Apr. 21, 2026), Dkt. No. 19-2. A federal judge of this Court has since enjoined implementation of the OLC opinion, Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, rejecting the government's claim…messages (or other related messaging apps such as Signal and WhatsApp). Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395, at *7 & n.6. 65 Letter, United…executive action, tracing back to England."); Am. Hist. Ass'n v. Trump, 2026 WL 1412395, at *13 (finding - 737. RETRIEVED EVIDENCE:
Trump, 2026 WL 1412395, at *13 (finding plaintiffs likely had an equitable cause of action under Armstrong to require that White House officials preserve records pursuant to the PRA).
GOVERNING EVIDENCE:
Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600…PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes - 738. RETRIEVED EVIDENCE:
68.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 739. RETRIEVED EVIDENCE:
A plaintiff seeking a permanent injunction must demonstrate aright to relief from a current or impending violation of his rights and aclear governmental duty to act to remedy that violation.
GOVERNING EVIDENCE:
THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950…by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend…April 18, 2026, a federal grand jury in Washington, D.C. issued subpoenas to a number of current and former Intelligence Community 1 In detailing how some individuals in the Justice…personnel are maintaining adherence to professional standards and carrying out their duties in the best tradition of the Justice Department. Case 1:26-cv-02323 Document 1 Filed…investigations, certain Justice Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial conduct. Those overreaching actions have violated Director Brennan's constitutional rights and will serve as the basis for challenges to - 740. RETRIEVED EVIDENCE:
In addition, a plaintiff must demonstrate four factors:
GOVERNING EVIDENCE:
under seal, Plaintiff v. TODD W. BLANCHE…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in…III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct by the - 741. RETRIEVED EVIDENCE:
(1) that the plaintiff has suffered or is likely to suffer an irreparable harm without an injunction;
GOVERNING EVIDENCE:
following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in…of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct by the defendant or defendants, and a likelihood that the injury will be redressed by a favorable decision. Lujan, 504 U.S. at 560-61. Here, Director Brennan meets those three requirements. The injury is the very real prospect that the government will fail to - 742. RETRIEVED EVIDENCE:
(2) that remedies available at law,
such as monetary damages, are inadequate;
GOVERNING EVIDENCE:
REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i…7 JURISDICTION AND VENUE…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate Government Personnel - 743. RETRIEVED EVIDENCE:
(3) that the balance of the equities between the plaintiff and defendant favor an injunction;
GOVERNING EVIDENCE:
under seal, Plaintiff v. TODD W…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws - 744. RETRIEVED EVIDENCE:
and (4) that the public interest would not be
"disserved by a permanent injunction." Anatol Zukerman & Charles Krause Reporting, LLC v.
GOVERNING EVIDENCE:
...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity .......…a former longtime public servant who provided more than 33 years of nonpartisan government service working for six administrations - three Republican and three Democratic - in a wide…his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his…Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand…he resides in the Commonwealth of Virginia. 14. Director Brennan's federal government service, which began in August 1980, spanned six Administrations-three Republican and three…15. Following his retirement from the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President - 745. RETRIEVED EVIDENCE:
USPS, 64 F.4th 1354, 1363 (D.C.
GOVERNING EVIDENCE:
JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…a former longtime public servant who provided more than 33 years of nonpartisan government service working for six administrations - three Republican and three Democratic - in a wide…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia. 14. Director Brennan's federal government service, which began in August 1980, spanned six - 746. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 747. RETRIEVED EVIDENCE:
2023) (quoting eBay, Inc. v.
GOVERNING EVIDENCE:
& Charles Krause Reporting, LLC v. USPS, 64 F.4th 1354, 1363 (D.C. Cir. 2023) (quoting eBay, Inc. v. MercExchange, L.L.C., 547 U.S. 388, 391 (2006)); Nat'l Pub. Radio, Inc.…public interest.'" (first quotation marks omitted, remaining quotation marks ultimately quoting Gordon v. Holder, 721 F.3d 638, 653 (D.C. Cir. 2013))). 72 70. For these reasons - 748. RETRIEVED EVIDENCE:
MercExchange, L.L.C., 547
U.S. 388, 391 (2006));
GOVERNING EVIDENCE:
Krause Reporting, LLC v. USPS, 64 F.4th 1354, 1363 (D.C. Cir. 2023) (quoting eBay, Inc. v. MercExchange, L.L.C., 547 U.S. 388, 391 (2006)); Nat'l Pub. Radio, Inc. v. Trump, 2026 WL 877434…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 749. RETRIEVED EVIDENCE:
Nat'l Pub.
GOVERNING EVIDENCE:
20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub. L. No. 113-187, 10, 128 Stat. 2003, 2014-15); see also United States v. Navarro…10, 2018), https://perma.cc/3A7S-6HZY . 57 See generally A Disappearing Data Chronology, Nat'l Sec. Archive, https://perma.cc/55SN 66EV (last visited June 5, 2026) (collecting…presumption of regularity gives way" in light of these irregularities. Authors Guild v. Nat'l Endowment for the Humanities, 2025 WL 3678097, at *12 (S.D.N.Y. Dec. 18, 2025…D.C. Cir. 2023) (quoting eBay, Inc. v. MercExchange, L.L.C., 547 U.S. 388, 391 (2006)); Nat'l Pub. Radio, Inc. v. Trump, 2026 WL 877434, at *28 (D.D.C. Mar. Case 1:26-cv-02323…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to - 750. RETRIEVED EVIDENCE:
Radio, Inc. v.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 751. RETRIEVED EVIDENCE:
Trump, 2026 WL 877434, at *28 (D.D.C.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 752. RETRIEVED EVIDENCE:
Mar.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 753. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 39 of 4636
31, 2026) (Moss, J.) ("Entry of a permanent injunction is appropriate here because Plaintiffs are likely to suffer irreparable harm-'retaliation against them in response to their exercise of their First Amendment rights'-in the absence of injunctive relief.");
GOVERNING EVIDENCE:
26 VII. Injunctive Relief is Necessary to Ensure Preservation of…such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are increasingly…to President George H.W. Bush and senior Administration officials in the run-up to the First Gulf War (1990-91); daily intelligence briefer for President Bill Clinton and Vice…manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to position the CIA to deal more effectively with the…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a…record systems that would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the - 754. RETRIEVED EVIDENCE:
see generally League of United Latin Am.
GOVERNING EVIDENCE:
of regularity" that generally insulates most government…lengthy discussion of the current investigations. He confirmed the existence, scope, and general 34 Daniel Klaidman & Sarah N. Lynch, Witnesses in Criminal Probe of Ex-CIA Director…manner as other attorneys in that State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26…Trump's Papers Back Together, Politico (June 10, 2018), https://perma.cc/3A7S-6HZY . 57 See generally A Disappearing Data Chronology, Nat'l Sec. Archive, https://perma.cc/55SN 66EV (last…Act, 50 Op. O.L.C. (Apr, 1, 2026) (slip op. at 1, 50), https://perma.cc/V4M7-NQFA ; see generally Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ---, 2026 WL 1412395 (D.D.C. May 20…other retribution cases; the repeated flouting of its discovery obligations; and the widespread disregard for the preservation requirements for government records. Under these - 755. RETRIEVED EVIDENCE:
Citizens v.
GOVERNING EVIDENCE:
-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026 - 756. RETRIEVED EVIDENCE:
Exec.
GOVERNING EVIDENCE:
the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026) (Kollar-Kotelly, J. - 757. RETRIEVED EVIDENCE:
Off.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 758. RETRIEVED EVIDENCE:
of the President, 818 F.
GOVERNING EVIDENCE:
26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official…......... 16 B. The Justice Department Makes Numerous Personnel Moves to Effectuate the President's Retribution Agenda ........................................ 18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] &…has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the…to retaliate against and pressure the President's political and personal adversaries - 759. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 760. RETRIEVED EVIDENCE:
3d 34, 74-75 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 761. RETRIEVED EVIDENCE:
2026)
(Kollar-Kotelly, J.).
69.
GOVERNING EVIDENCE:
Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026) (Kollar-Kotelly, J.). 69. Director Brennan meets the elements to be entitled to injunctive relief. He will - 762. RETRIEVED EVIDENCE:
Director Brennan meets the elements to be entitled to injunctive relief.
GOVERNING EVIDENCE:
L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…38 REQUEST FOR RELIEF…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 763. RETRIEVED EVIDENCE:
He will prevail on the merits because there is aclear factual predicate that his constitutional rights are being jeopardized by the government'sfailure to uphold its duty to preserve records.
GOVERNING EVIDENCE:
Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights ...........................................................................................…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and - 764. RETRIEVED EVIDENCE:
And he will suffer irreparable harm to his constitutional rights in the absence of injunctive relief, given the government'sdemonstrated inability and/or unwillingness to preserve relevant records and the centrality of those records to his constitutional challenge to an eventual indictment.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved - 765. RETRIEVED EVIDENCE:
See supra
54-63.
GOVERNING EVIDENCE:
5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA…Sources Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority…Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ - 766. RETRIEVED EVIDENCE:
There are no other remedies at law that can redress that harm, given that pre-trial sanctions are inadequate because the court may never know that the unpreserved communications ever existed in the first place.
GOVERNING EVIDENCE:
Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that…over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record preservation and…the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and constitutional challenges to any…first administration in 2017, President Trump has also made more than 100 verbal or written statements that personally criticize and demonize Director Brennan. In a variety of communications - from Tweets and Truth Social posts to formal media interviews and Presidential statements - President Trump has excoriated - 767. RETRIEVED EVIDENCE:
Next, the balance of equities tips strongly in favor of Director Brennan'sinterest in vindicating his constitutional rights over any claimed governmental interest in failing to satisfy well-established federal record preservation and discovery requirements.
GOVERNING EVIDENCE:
Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in - 768. RETRIEVED EVIDENCE:
And finally, the requested injunction is squarely in the public interest, as
"it is always in the public interest to prevent the violation of aparty'sconstitutional rights."
Gayle v.
GOVERNING EVIDENCE:
20 D. Justice Department Officials Publicly Discuss Grand Jury Activity .......…his anger at Director Brennan for his role in the issuance of the ICA and for his regular public criticism of President Trump, his policies and his actions. 3. Since the beginning of his…Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand…the false-statements investigation. Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 7. In their work on these presidentially-driven…oversaw, or undertook those actions to determine whether they violated Director Brennan's rights, and specifically whether they were motivated by a desire to vindictively prosecute him…1 Filed 07/01/26 Page 10 of 467 the consideration of Director Brennan's legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the - 769. RETRIEVED EVIDENCE:
Meade, 614 F.
GOVERNING EVIDENCE:
the public interest to prevent the violation of a party's constitutional rights." Gayle v. Meade, 614 F. Supp. 3d 1175, 1206 (S.D. Fla. 2020) (internal quotation marks omitted - 770. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 771. RETRIEVED EVIDENCE:
3d 1175, 1206 (S.D.
GOVERNING EVIDENCE:
Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Counsel for Director John O. Brennan to Chief Judge Cecilia M. Altonaga, U.S. Dist. Ct. for S.D. Fla., at 15-16 (Dec. 22, 2025), https://perma.cc/3UX5-XCMT (Appendix A). 12 Paula…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr - 772. RETRIEVED EVIDENCE:
Fla.
GOVERNING EVIDENCE:
A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia…Attorney for the Southern District of Florida since August 13, 2025. In - 773. RETRIEVED EVIDENCE:
2020) (internal quotation marks omitted);
GOVERNING EVIDENCE:
is a Serious Risk that Highly Relevant Internal Government Materials and Communications…decisions. A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were…These technologies include encrypted messaging apps that can be set to auto delete, internal messaging systems such as Microsoft Teams, AI queries, and the like that are not…district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events or omissions" has occurred or is occurring in the District of Columbia. A grand jury in the District…methodically removing or silencing those career civil servants who are responsible for internally enforcing ethics, with Attorney General Bondi firing the head of the Office of…//perma.cc/79WB-488R . 41 These firings have apparently had their intended effect on the internal watchdog workforce, as evidenced by recent reports that the Department of Justice Office - 774. RETRIEVED EVIDENCE:
see Honeyfund.com Inc. v.
GOVERNING EVIDENCE:
614 F. Supp. 3d 1175, 1206 (S.D. Fla. 2020) (internal quotation marks omitted); see Honeyfund.com Inc. v. Governor of Florida, 94 F.4th 1272, 1283 (11th Cir. 2024) ("[A - 775. RETRIEVED EVIDENCE:
Governor of Florida, 94 F.4th 1272, 1283 (11th Cir.
GOVERNING EVIDENCE:
for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump, President…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia - 776. RETRIEVED EVIDENCE:
2024) ("[A]
preliminary injunction is not contrary to the public interest because it is in the public interest to protect First Amendment rights.");
GOVERNING EVIDENCE:
D. Justice Department Officials Publicly Discuss Grand Jury Activity…his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the United States Department…of President Trump, his policies and his actions. 3. Since the beginning of his first administration in 2017, President Trump has also made more than 100 verbal or written…to be investigating Director Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand…oversaw, or undertook those actions to determine whether they violated Director Brennan's rights, and specifically whether they were motivated by a desire to vindictively prosecute him…such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more ephemeral, government officials are increasingly - 777. RETRIEVED EVIDENCE:
A.B.A.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC - 778. RETRIEVED EVIDENCE:
v.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 779. RETRIEVED EVIDENCE:
DOJ, 783 F.
GOVERNING EVIDENCE:
system against Director Brennan. He has directed the U.S. Department of Justice ("DOJ" or "Justice Department") to investigate and prosecute cases against Director Brennan…for the Email and Collaboration Services (2024), https://perma.cc/HS8T-K2SY (announcing DOJ is using Microsoft Teams); U.S. Dep't of Just., AI Inventory (Jan. 30, 2026), https://perma.cc/DG59-PCFZ ; see also 2025 DOJ AI Use Case Inventory_downloadable.xlsx, U.S. Dep't of Just., https://perma.cc/8ERX-WDY4 (spreadsheet showing more than 300 AI use cases at DOJ); Sara Mieczkowski, How AI and Whistleblowers Are Reshaping DOJ Enforcement Strategy, The Suarez Law Firm (July 29, 2025), https://perma.cc/RWM6-6HAN …July 23, 2025), https://perma.cc/ZFX6-KC5A ; Ashley Oliver, David Spunt & Jake Gibson, DOJ Launching Grand Jury Investigation into Russiagate Conspiracy Allegations: Sources, Fox…Hang Out with Sean Hannity & Fox News, Todd Blanche: The DOJ Room Full of Evidence Nobody Knew Existed | Hang Out with - 780. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 781. RETRIEVED EVIDENCE:
3d 236, 247-48 (D.D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 782. RETRIEVED EVIDENCE:
2025)
(Cooper, J.) ("Government actions in contravention of the Constitution are 'always contrary to Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 40 of 4637
the public interest.'" (first quotation marks omitted, remaining quotation marks ultimately quoting Gordon v.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 - 783. RETRIEVED EVIDENCE:
Holder, 721 F.3d 638, 653 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates…plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in this district under 28 U.S.C. 1391(e)(1)(B) because a "substantial part of the events or omissions - 784. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 785. RETRIEVED EVIDENCE:
2013))).
72
70.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 786. RETRIEVED EVIDENCE:
For these reasons, Director Brennan is entitled to injunctive relief to require the government to preserve any and all materials and communications that are potentially relevant to the consideration of Director Brennan'sconstitutional challenges to any future criminal charges.
GOVERNING EVIDENCE:
Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 787. RETRIEVED EVIDENCE:
COUNT 2
Writ of Mandamus Under The Mandamus Act (28 U.S.C.
GOVERNING EVIDENCE:
1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1 ..................................................................................................................................... 35 COUNT 2 ..................................................................................................................................... 37 COUNT 3…grants original jurisdiction to the district courts over "any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a…Brennan is entitled to injunctive relief, he is equally and alternatively entitled to a writ of mandamus compelling the government to preserve those records to permit the defense of his…rights. Director Brennan therefore alternatively requests that the Court issue a writ of mandamus compelling the government to preserve the records enumerated below. attributed to - 788. RETRIEVED EVIDENCE:
1361) And The All Writs Act
(28 U.S.C.
GOVERNING EVIDENCE:
rights. Director Brennan therefore alternatively requests that the Court issue a writ of mandamus compelling the government to preserve the records enumerated below…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…Director Brennan's constitutional challenges to any future criminal charges. COUNT 2 Writ of Mandamus Under The Mandamus Act (28 U.S.C. 1361) And The All Writs Act (28 U.S.C. 1651) To Protect Director Brennan's Constitutional Rights 71…Based on the foregoing, Director Brennan requests, in the alternative, that this Court issue a writ of mandamus ordering the Defendants to preserve all records enumerated below in the…985 F.3d 893, 910 (D.C. Cir. 2021) (citation modified). To be entitled to a writ of mandamus under the All Writs Act, this Court must find: "(1) the petitioner has no other adequate means of - 789. RETRIEVED EVIDENCE:
1651) To Protect Director Brennan's Constitutional Rights
71.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 790. RETRIEVED EVIDENCE:
Director Brennan re-alleges and incorporates by reference paragraphs 1 through 70.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 791. RETRIEVED EVIDENCE:
Based on the foregoing, Director Brennan requests, in the alternative, that this Court issue awrit of mandamus ordering the Defendants to preserve all records enumerated below in the Request for Relief.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights - 792. RETRIEVED EVIDENCE:
72.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 793. RETRIEVED EVIDENCE:
The Mandamus Act, 28 U.S.C.
GOVERNING EVIDENCE:
is entitled to injunctive relief, he is equally and alternatively entitled to a writ of mandamus compelling the government to preserve those records to permit the defense of his…rights. Director Brennan therefore alternatively requests that the Court issue a writ of mandamus compelling the government to preserve the records enumerated below. attributed to…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…Brennan's constitutional challenges to any future criminal charges. COUNT 2 Writ of Mandamus Under The Mandamus Act (28 U.S.C. 1361) And The All Writs Act (28 U.S.C. 1651) To Protect Director…writ of mandamus ordering the Defendants to preserve all records enumerated below in the Request for Relief. 72. The Mandamus Act, 28 U.S.C. 1361, vests this Court with original jurisdiction over "any action in the nature of mandamus to - 794. RETRIEVED EVIDENCE:
1361, vests this Court with original jurisdiction over
"any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform aduty owed to the plaintiff" - which, in this case, is the duty the government owes to Director Brennan to preserve (and ultimately produce) all materials and communications that may be relevant to his challenges to an eventual indictment.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason - 795. RETRIEVED EVIDENCE:
Under the Mandamus Act, "a court may grant mandamus relief only if:
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications…38 REQUEST FOR RELIEF…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason - 796. RETRIEVED EVIDENCE:
(1) the plaintiff has a clear right to
72
In gauging the public interest in granting this requested injunction, the Court need not worry that granting an injunction in this case will open the floodgates to similar suits from other criminal defendants seeking the courts' assistance in forcing the government to observe its preservation obligations in their cases.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 797. RETRIEVED EVIDENCE:
The exceptionally strong indication of vindictiveness in this case sets it apart from other criminal matters, as it so clearly establishes the need for the judicial scrutiny that will require access to the government's internal materials and communications at a hearing on a vindictive prosecution motion.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 798. RETRIEVED EVIDENCE:
The vast majority of defendants cannot show such clear vindictiveness, and therefore cannot demonstrate that the government will be obligated to produce those records at apost-indictment hearing.
GOVERNING EVIDENCE:
Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…concerns that necessitate this complaint apply to only a small subset of officials, and the vast majority of Justice Department personnel are maintaining adherence to professional standards and…will no longer exist by the time any such challenges are filed and the court hears them. This risk exists for two reasons. First, as technology changes and becomes more…even though they should be, pursuant to the government's statutory and discovery obligations. These technologies include encrypted messaging apps that can be set to auto delete…and in the Justice Department specifically are failing to observe their legal obligation to maintain such records. 11. The loss of these records will impair, perhaps fatally, the - 799. RETRIEVED EVIDENCE:
As such, they will be unable to establish a pre-indictment right to judicial enforcement of the government's obligation to preserve those records.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE - 800. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 41 of 4638
relief;
GOVERNING EVIDENCE:
States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and….......................................................................... 34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…38 REQUEST FOR RELIEF ............................................................................................................ 39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in - 801. RETRIEVED EVIDENCE:
(2) the defendant has aclear duty to act;
GOVERNING EVIDENCE:
Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…Agency; and the Office of the Director of National Intelligence (collectively "Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve…personnel are maintaining adherence to professional standards and carrying out their duties in the best tradition of the Justice Department. Case 1:26-cv-02323 Document 1 Filed…Medal for Distinguished Service, and the Defense Intelligence Agency Director's Medal. 18. Defendant Todd W. Blanche is the Acting Attorney General of the United States. He leads the…under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a federal agency responsible for enforcing federal criminal laws…would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of - 802. RETRIEVED EVIDENCE:
and (3) there is no other adequate remedy available to plaintiff." Muthana v.
GOVERNING EVIDENCE:
under seal, Plaintiff v. TODD W…s legal and constitutional challenges to any future criminal charges. PARTIES 13. Plaintiff John O. Brennan is the target of a grand jury investigation in Washington, D.C. and of investigations…following day and served as CIA Director until January 20, 2017. As the CIA Director, Plaintiff was responsible for intelligence collection, analysis, covert action, counterintelligence, and…responsibilities in a nonpartisan, apolitical, and objective manner. While Director, Plaintiff initiated a major reorganization of the CIA - the first in over 50 years - in order to…or employee of the United States or any agency thereof to perform a duty owed to the plaintiff." Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 14 of 4611 30. Venue lies in…III, 2; Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). To establish standing, a plaintiff must demonstrate an injury in fact, a sufficient causal connection between the injury and conduct - 803. RETRIEVED EVIDENCE:
Pompeo, 985 F.3d 893, 910 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 804. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 805. RETRIEVED EVIDENCE:
2021) (citation modified).
GOVERNING EVIDENCE:
Tim Walz and other Minnesota officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal…--- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing Presidential and Federal Records Act Amendments of 2014, Pub. L. No. 113-187, 10, 128 Stat…remedy available to plaintiff." Muthana v. Pompeo, 985 F.3d 893, 910 (D.C. Cir. 2021) (citation modified). To be entitled to a writ of mandamus under the All Writs Act, this Court must find: "(1 - 806. RETRIEVED EVIDENCE:
To be entitled to a writ of mandamus under the All Writs Act, this Court must find:
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the - 807. RETRIEVED EVIDENCE:
"(1) the petitioner has no other adequate means of relief;
GOVERNING EVIDENCE:
26 VII. Injunctive Relief is Necessary to Ensure Preservation of…by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a…record systems that would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 21. Defendant Joseph E. diGenova has served…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 22. Defendant Kash P. Patel has served as the Director - 808. RETRIEVED EVIDENCE:
(2) there is aclear and indisputable right to relief;
GOVERNING EVIDENCE:
26 VII. Injunctive Relief is Necessary to Ensure…38 REQUEST FOR RELIEF…by and through his undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend…March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…House from January 2009 to March 2013, Director Brennan played a lead role in shaping and coordinating Obama Administration policies on counterterrorism, including the successful operation…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a…record systems that would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the - 809. RETRIEVED EVIDENCE:
and (3) the court is satisfied that mandamus is appropriate under the circumstances." In re Trump, 172 F.4th 44, 51-52 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal…Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official capacity as President of the United States, 1600 Pennsylvania Ave NW…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…officials to be punitive and coercive, Chief Judge Schiltz cited "the backdrop of the Trump administration's well-established history of using criminal investigations to retaliate - 810. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 811. RETRIEVED EVIDENCE:
2026) (internal quotation marks omitted), vacated, 2026 WL 1785978 (D.C.
GOVERNING EVIDENCE:
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of…2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former…challenge, the court presiding over Director Brennan's criminal case would look to the government's internal records and communications around its investigation and charging decisions to discern the true…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…decisions. A careful examination of the prosecutors' emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were - 812. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 813. RETRIEVED EVIDENCE:
June 22, 2026) (granting rehearing en banc).
GOVERNING EVIDENCE:
to 28 U.S.C. 1361, which grants original jurisdiction to the…I saw in those transcripts." 68 In a recent civil case involving the mass termination of grants awarded by the National Endowment for the Humanities, the judge faulted the government…to his challenges to an eventual indictment. Under the Mandamus Act, "a court may grant mandamus relief only if: (1) the plaintiff has a clear right to 72 In gauging the public interest in granting this requested injunction, the Court need not worry that granting an injunction in this case will open the floodgates to similar suits from other criminal…2026) (internal quotation marks omitted), vacated, 2026 WL 1785978 (D.C. Cir. June 22, 2026) (granting rehearing en banc). 73. Director Brennan meets the three elements to be entitled to a writ of mandamus…the above listed materials and that that obligation applies prior to indictment. (3) Grant such other relief as the Court may deem just and proper. Dated: July 1, 2026 /s/ - 814. RETRIEVED EVIDENCE:
73.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 815. RETRIEVED EVIDENCE:
Director Brennan meets the three elements to be entitled to a writ of mandamus to protect his constitutional rights.
GOVERNING EVIDENCE:
to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation…26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal records and - 816. RETRIEVED EVIDENCE:
He has aclear right to relief, given the demonstrated danger that the government will fail to preserve the records needed for acourt to fully consider his constitutional challenge to any future indictment.
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford the Traditional Presumption of Regularity to the Government…24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's - 817. RETRIEVED EVIDENCE:
See supra 57-63.
GOVERNING EVIDENCE:
5G_nT7kFLPA ( https://perma.cc/F3SB-MFZ2 on file with Plaintiff). 25 Evan Perez & Hannah Rabinowitz, supra note 12; Sarah N. Lynch & Daniel Klaidman, Lead Prosecutor on Probe Into Ex-CIA…Sources Say, CBS News (Apr. 17, 2026), https://perma.cc/37LC-YYMA ; Eric Tucker, supra note 8. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 22 of 4619 given authority…Falters, BBC News (Mar. 25, 2018), https://perma.cc/WR69-UGFH . 27 Anna Bower & Molly Roberts, supra note 6. 28 Associated Press, Trump Adds New Lawyer to Russia Investigation Legal Team…Law (Apr. 18, 2026), https://perma.cc/P9BA-WX28 . 30 Anna Bower & Molly Roberts, supra note 6. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 23 of 4620 Director Brennan "evil…36 Todd Blanche interview with Sean Hannity, at 14:37-39, 38:49-39:41, supra note 15. 37 Id. at 57:43-53. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 25 of 4622…Patel interview with Sean Hannity, supra note 3. 39 Sam Levine, A Top DOJ - 818. RETRIEVED EVIDENCE:
The Defendants have aclear duty to act,
i.e., to ensure the preservation of all such relevant records, given their obligations to preserve them for potential use in pre-trial litigation, see supra 56, and under the Federal Records Act and the Presidential Records Act, see supra 55.
GOVERNING EVIDENCE:
................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully…investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional - 819. RETRIEVED EVIDENCE:
And finally, absent injunctive relief - and in light of the government'sdemonstrated unwillingness to self-correct its deficient records preservation practices - it is clear that Director Brennan will be left with no other adequate remedy to avoid irreparable harm to his ability to vindicate his constitutional rights.
GOVERNING EVIDENCE:
25 VI. Absent this Court's Intervention, There is…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 21. Defendant Joseph E. diGenova has served…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 22. Defendant Kash P. Patel has served as the Director…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 23. Defendant Donald J. Trump has served as…record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. Case 1:26-cv-02323 Document 1 Filed 07/01/26…record systems that would have the records to be preserved under the requested injunctive relief. 25. Defendant Susan L. Wiles has served as the White House Chief of Staff since - 820. RETRIEVED EVIDENCE:
74.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 821. RETRIEVED EVIDENCE:
For these reasons, it is necessary and appropriate for this Court, in the alternative, to issue a writ of mandamus pursuant to 28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the…activity from probing judicial scrutiny. 9. To perform that scrutiny after an indictment, the Court would demand access to a wide range of the government's communications and materials…emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on legitimate law enforcement concerns or on - 822. RETRIEVED EVIDENCE:
1361 and 1651.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 823. RETRIEVED EVIDENCE:
COUNT 3
Injunctive Relief in Aid Of The Court's Jurisdiction Under the All Writs Act (28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications…38 REQUEST FOR RELIEF…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason - 824. RETRIEVED EVIDENCE:
1651)
75.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 825. RETRIEVED EVIDENCE:
Director Brennan re-alleges and incorporates by reference paragraphs 1 through 74.
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in - 826. RETRIEVED EVIDENCE:
Based on the foregoing, Director Brennan requests, in the alternative, that this Court issue an Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 42 of 4639
order in aid of its jurisdiction directing Defendants to preserve all records enumerated below in the Request for Relief.
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons…Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…38 REQUEST FOR RELIEF…denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With this observation in his order quashing federal subpoenas directed at Federal Reserve Chairman Jerome Powell, Chief Judge Boasberg captured the reality that this…adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and - 827. RETRIEVED EVIDENCE:
76.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 828. RETRIEVED EVIDENCE:
The All Writs Act, 28 U.S.C.
GOVERNING EVIDENCE:
rights. Director Brennan therefore alternatively requests that the Court issue a writ of mandamus compelling the government to preserve the records enumerated below…their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…Director Brennan's constitutional challenges to any future criminal charges. COUNT 2 Writ of Mandamus Under The Mandamus Act (28 U.S.C. 1361) And The All Writs Act (28 U.S.C. 1651) To Protect Director Brennan's Constitutional Rights 71…Based on the foregoing, Director Brennan requests, in the alternative, that this Court issue a writ of mandamus ordering the Defendants to preserve all records enumerated below in the…985 F.3d 893, 910 (D.C. Cir. 2021) (citation modified). To be entitled to a writ of mandamus under the All Writs Act, this Court must find: "(1) the petitioner has no other adequate means of - 829. RETRIEVED EVIDENCE:
1651, authorizes this Court to issue all writs "necessary or appropriate" in aid of its jurisdiction, which includes its jurisdiction over criminal proceedings.
GOVERNING EVIDENCE:
Boasberg captured the reality that this Administration has adopted a policy of using criminal process and prosecution to punish the President's perceived adversaries. Echoing the…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the…CIA") from March 8, 2013 to January 20, 2017. 2. While serving as Director, he participated in coordinating and issuing the January 6, 2017 Intelligence Community Assessment ("ICA"), which…Director Brennan for what amounts to phantom criminal conduct. The first investigation, as publicly described by senior Justice Department officials, is examining an alleged "grand conspiracy" involving Director Brennan and a number of Obama and Biden - 830. RETRIEVED EVIDENCE:
See 18 U.S.C.
GOVERNING EVIDENCE:
their First Amendment rights'-in the absence of injunctive relief."); see generally League of United Latin Am. Citizens v. Exec. Off. of the President, 818 F. Supp. 3d 34, 74-75 (D.D.C. 2026…includes its jurisdiction over criminal proceedings. See 18 U.S.C. 3231; In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C. Cir. 2022) (finding the court had jurisdiction to issue a writ of - 831. RETRIEVED EVIDENCE:
3231;
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 832. RETRIEVED EVIDENCE:
In re Nat'l Nurses United, 47 F.4th 746, 752 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of…Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the Southern District of Florida since August 13, 2025. In that role, he has responsibility over subordinates - 833. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 834. RETRIEVED EVIDENCE:
2022) (finding the court had jurisdiction to issue a writ of mandamus in aid of future jurisdiction);
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the United…potentially relevant to Director Brennan's legal and constitutional challenges to any future criminal charges. For his Complaint, Director Brennan alleges as follows: Case 1 - 835. RETRIEVED EVIDENCE:
In re al-Nashiri,
791 F.3d 71, 76 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 836. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 837. RETRIEVED EVIDENCE:
2015) (a court can "can issue a writ of mandamus now to protect the exercise of [its] appellate jurisdiction later");
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the…vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's criminal case would look to the government's internal…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason…action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the United - 838. RETRIEVED EVIDENCE:
In re Mohammad, 866 F.3d 473, 475 (D.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE…in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…Department of Justice; Jason A. Reding Qui ones, the U.S. Attorney for the Southern District of Florida; Joseph E. diGenova, Counselor to the Attorney General; Donald J. Trump…as to each of these matters. In November 2025 and January 2026, the Southern District of Florida ("SDFL") U.S. Attorney's Office issued two sets of grand jury subpoenas - one set…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of - 839. RETRIEVED EVIDENCE:
Cir.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 840. RETRIEVED EVIDENCE:
2017) (same);
GOVERNING EVIDENCE:
process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim…Brennan as "a very bad guy," "a total low-life," a "loser" and a "political hack." At the same time, he has declared Director Brennan guilty of crimes ranging from treason to lying…a different grand jury in Miami, which issued subpoenas in January 2026 seeking the same category of documents from 2016 all the way up to the present. 31 James Hoft, Joe…Government Personnel from Accountability for Their Irregular Conduct 49. At the same time that government personnel are accelerating their overreaching efforts against…Then He was Fired, Guardian (Jan. 3, 2026), https://perma.cc/8JHJ-PGM3 . The same day, the U.S. Pardon Attorney, who was a career civil servant, was terminated by a…engages in that attorney's duties, to the same extent and in the same manner as other attorneys in that State." 28 - 841. RETRIEVED EVIDENCE:
Dascola v.
GOVERNING EVIDENCE:
jurisdiction later"); In re Mohammad, 866 F.3d 473, 475 (D.C. Cir. 2017) (same); Dascola v. City of Ann Arbor, 22 F. Supp. 3d 736, 746 (E.D. Mich. 2014). The very purpose - 842. RETRIEVED EVIDENCE:
City of Ann Arbor, 22 F.
GOVERNING EVIDENCE:
later"); In re Mohammad, 866 F.3d 473, 475 (D.C. Cir. 2017) (same); Dascola v. City of Ann Arbor, 22 F. Supp. 3d 736, 746 (E.D. Mich. 2014). The very purpose of the - 843. RETRIEVED EVIDENCE:
Supp.
GOVERNING EVIDENCE:
risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026). With…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this…State." 28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its…vindictively or selectively in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United States…conversation is preserved. 44 U.S.C. 2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J.) (citing…2014-15); see also United States v. Navarro, 664 F. Supp. 3d 48, 57 (D.D.C. 2023) (the PRA applies - 844. RETRIEVED EVIDENCE:
3d 736, 746 (E.D.
GOVERNING EVIDENCE:
recent years." In re Grand Jury Subpoenas Nos. [Redacted] & [Redacted], 823 F. Supp. 3d 1, 5 (D.D.C. 2026), reconsideration denied, 2026 WL 1224046 (D.D.C. Apr. 3, 2026…2022R00519-B, 2022R00519-C, 2022R00519-D, 2022R00519-E, 2022R00519-F, -- F. Supp. 3d --, 2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop…28 U.S.C. 530B (the McDade Amendment). See generally In re Clark, 678 F. Supp. 3d 112, 116 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 26 of 4623 its oversight of…in bringing a prosecution. See, e.g., United States v. Abrego, 802 F. Supp. 3d 1055, 1065 (M.D. Tenn. 2025) (considering emails, internal DOJ memoranda); United…duty to preserve that evidence in the first place," United States v. Vega, 826 F.3d 514, 533 (D.C. Cir. 2016); see United States v. Harris, 2021 WL 1546541, at *2 (D.D.C. Apr…2911; see Am. Hist. Ass'n v. Trump, --- F. Supp. 3d. ----, 2026 WL 1412395, at *2 (D.D.C. May 20, 2026) (Bates, J - 845. RETRIEVED EVIDENCE:
Mich.
GOVERNING EVIDENCE:
claim of vindictive prosecution); United States v. Fieger, 2008 WL 205244, at *8 (E.D. Mich. Jan. 24, 2008), as amended (Feb. 1, 2008) (in vindictive prosecution claim, the court considered…in camera material from the government "related to the DOJ's recusal of the three principal Detroit U.S. Attorneys" and ordered that evidence turned over to defendant); United States v…In re Mohammad, 866 F.3d 473, 475 (D.C. Cir. 2017) (same); Dascola v. City of Ann Arbor, 22 F. Supp. 3d 736, 746 (E.D. Mich. 2014). The very purpose of the requested order in this matter is to ensure that the - 846. RETRIEVED EVIDENCE:
2014).
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 847. RETRIEVED EVIDENCE:
The very purpose of the requested order in this matter is to ensure that the Court may properly carry out the responsibility to review the evidence necessary to evaluate the challenges that will be filed in the event that charges are brought against Director Brennan.
GOVERNING EVIDENCE:
24 IV. The Court Reviewing the Vindictive and Selective…those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by…the false-statements investigation. Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 7. In their work on these presidentially-driven…of selective and vindictive prosecution. 8. To fully consider those motions, the reviewing judge would need to scrutinize the motivations of the Justice Department officials who…records. 11. The loss of these records will impair, perhaps fatally, the ability of the court reviewing Director Brennan's challenges to do so on the full record of contemporaneous…the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and - 848. RETRIEVED EVIDENCE:
It is therefore "necessary"
and "appropriate" that the Court now enjoin the government to preserve those records until such time as they are required for production and review in apre-trial hearing about whether the government acted vindictively and selectively in charging Director Brennan.
GOVERNING EVIDENCE:
any Criminal Charges as Vindictive and Selective Prosecution…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing Analysis, as It will No Longer Afford…of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming. President Trump has been condemning and calling for…1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In assessing that challenge, the court presiding over Director Brennan's - 849. RETRIEVED EVIDENCE:
77.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 850. RETRIEVED EVIDENCE:
For these reasons, it is necessary and appropriate for this Court, in the alternative, to issue a writ of mandamus pursuant to 28 U.S.C.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff…that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional vindictiveness. For that reason, Director Brennan, by and through his undersigned counsel, today brings this action…his ability to defend his constitutional rights. Specifically, Director Brennan asks the court to issue an injunction to ensure that Todd W. Blanche, Acting Attorney General; the…activity from probing judicial scrutiny. 9. To perform that scrutiny after an indictment, the Court would demand access to a wide range of the government's communications and materials…emails, texts, instant messages, internal memoranda and the like would enable a court to determine whether their decisions were based on legitimate law enforcement concerns or on - 851. RETRIEVED EVIDENCE:
1651.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 852. RETRIEVED EVIDENCE:
REQUEST FOR RELIEF WHEREFORE, Director Brennan respectfully requests that this Court:
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…24 IV. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Engage in a Probing…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 853. RETRIEVED EVIDENCE:
(1) Issue an order requiring Defendants to preserve, and to cause their personnel and subordinates and others to preserve, any and all materials and communications that currently exist or that come into existence that are potentially relevant to the consideration of Director Brennan'slegal and constitutional challenges to any future criminal charges.
GOVERNING EVIDENCE:
Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to…s actions. Given the government's questionable recent history with respect to its record preservation and other legal obligations, however, Director Brennan has a well-founded concern that those records and communications will not be preserved until such time as the court can review them for evidence of unconstitutional…undersigned counsel, today brings this action seeking injunctive relief to enforce the preservation of those records and thereby protect his ability to defend his constitutional rights…Defendants") appropriately follow the laws of the United States and their Due Process obligations to preserve materials and communications potentially relevant to Director Brennan's legal and…Brennan without regard to factual or legal justification. Regrettably, some in the current Justice Department and Federal Bureau of Case 1:26-cv-02323 Document 1 Filed 07/01/26 - 854. RETRIEVED EVIDENCE:
This requested relief encompasses but is not limited to:
GOVERNING EVIDENCE:
Injunctive Relief is Necessary to Ensure…38 REQUEST FOR RELIEF…the false-statements investigation. Those subpoenas were subsequently withdrawn in favor of requests for voluntary interviews. 7. In their work on these presidentially-driven…Department officials have taken steps that clearly violate well-established norms and limitations on prosecutorial conduct. Those overreaching actions have violated Director Brennan's…the CIA in 2005, Director Brennan returned to government service in January 2009 at the request of President Obama to serve as Assistant to the President for Homeland Security and…subordinates and record systems that would have the records to be preserved under the requested injunctive relief. He is sued in his official capacity. 19. Defendant U.S. Department of Justice is a…personnel and record systems that would have the records to be preserved under the requested injunctive relief. 20. Defendant Jason A. Reding Qui ones has served as the U.S. Attorney for the - 855. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 43 of 4640
a)
All records relating to any federal investigation into Director Brennan's conduct, to include the investigation into allegations that he lied in his testimony to the House of Representatives Committee on the Judiciary on May 11, 2023 and the investigation into the "grand conspiracy" being conducted out of the U.S. Attorney's Office in the Southern District of Florida;
GOVERNING EVIDENCE:
s Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has Engaged, and Continues to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel - 856. RETRIEVED EVIDENCE:
b)
All status reports, witness statements, legal memoranda, updates, emails, messages,
prosecution memoranda, communications, AI queries, calendar entries, and documents of any type relating to the two pending investigations and any possible prosecution of Director Brennan, including any assessments, analysis or evaluations of the strength or weakness of any potential criminal case against Director Brennan or others involved in the investigations;
GOVERNING EVIDENCE:
NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102…2026 WL 1783899, at *7 (D. Minn. June 22, 2026). It is against this backdrop that former Director of the Central Intelligence Agency, John O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in…in this matter is overwhelming. President Trump has been condemning and calling for Director Brennan's prosecution for years. Administration officials from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation - 857. RETRIEVED EVIDENCE:
c)
All records of communications relating to any investigation and/or possible prosecution of Director Brennan and any alleged co-conspirators, whether in person, telephonic or via any communication device or online platform, including AI platforms;
GOVERNING EVIDENCE:
in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel - 858. RETRIEVED EVIDENCE:
d)
All documents or communications related to meetings about any investigation involving Director Brennan and that of any alleged coconspirators, including meetings with Justice Department personnel or with any persons outside of the Justice Department, including representatives or staff of the White House and of Congress;
GOVERNING EVIDENCE:
Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants…....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…to Engage, in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations - 859. RETRIEVED EVIDENCE:
e)
All records of communications, public or private, by President Trump and White House employees or any government staff acting on President Trump'sbehalf, including all Department of Justice employees or contractors, relating to any investigation of Director Brennan or any alleged co-conspirator, including any efforts to advance the investigation or otherwise to be apprised of the status of the investigation;
GOVERNING EVIDENCE:
12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation…18 C. The Justice Department Engages in Haphazard Investigative Activity in Pursuit of the President's Retribution Agenda ...................... 20 D. Justice Department Officials Publicly Discuss Grand Jury Activity ....... 21 E. The Justice Department Seeks to Insulate…There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His…Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in recent years." In re Grand Jury Subpoenas Nos. [Redacted] & - 860. RETRIEVED EVIDENCE:
Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 44 of 4641
f)
All records relating to any decisions regarding personnel assigned to, removed from or conflicted from investigating or managing the investigations involving Director Brennan,
including any internal emails, chats, messages, memos, meeting notices and personnel paperwork related in any manner to the assignment, removal or oversight of personnel,
including U.S. Attorneys, Assistant U.S. Attorneys, supervisors, or agents involved in any manner with those investigations;
GOVERNING EVIDENCE:
U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…O. Brennan ("Plaintiff" or "Director Brennan"), is being vindictively singled out for investigation and prosecution. As in the above cases, the evidence of vindictiveness in this matter is overwhelming - 861. RETRIEVED EVIDENCE:
g)
All records relating to any discussions or decisions regarding where any investigation or prosecution of the false-statements case or the "grand conspiracy" case will be pursued;
GOVERNING EVIDENCE:
A. The Grand…Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in…case would look to the government's internal records and communications around its investigation and charging decisions to discern the true motivations behind the government's actions. Given the government's - 862. RETRIEVED EVIDENCE:
h)
All records or communications regarding any investigation or possible prosecution of Director Brennan between Justice Department personnel and Congressman Jim Jordan and/or his staff, including any such records or communications relating to the October 21,
2025 referral to Attorney General Pam Bondi and any and all discussion about plans or suggestions for the substance or process of that referral;
GOVERNING EVIDENCE:
capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL…12 I. The Justice Department has Opened Two Criminal Investigations that Target Director Brennan ...................................................................................... 12 A. The Grand Conspiracy Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes Numerous Personnel…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 863. RETRIEVED EVIDENCE:
i)
All records or communications regarding any investigation or possible prosecution of Director Brennan or any alleged co-conspirators between Justice Department personnel and DNI Director Tulsi Gabbard and/or her staff and CIA Director John Ratcliffe and/or his staff, including any such records or communications relating to the July 2025 referrals to Attorney General Pam Bondi and any and all discussion about plans or suggestions for the substance or process of those referrals;
GOVERNING EVIDENCE:
Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1…Investigation ....................................................... 12 B. The False-Statements Investigation ......................................................... 13 II. The Government has…in Unprecedented, Irregular Conduct in Connection with the Two Brennan Investigations ....................................................................................................... 13 A. Administration Officials Call for Director Brennan's Prosecution ......... 16 B. The Justice Department Makes…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights - 864. RETRIEVED EVIDENCE:
j)
All records or communications relating to press or public statements about Director Brennan or any of alleged co-conspirators relating to any interaction between the Department of Justice and the press or members of the press about Director Brennan or the investigations involving his or his alleged co-conspirators' activities;
GOVERNING EVIDENCE:
L. RATCLIFFE, in his official capacity as Director of the Central Intelligence Agency, Central Intelligence Agency Washington, DC 20505 CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505 OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, 1500 Tysons McLean…and Selective Prosecution Challenges Would Require Access to Government Materials and Communications to Assess the Prosecutors' Motivations…25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government Materials and Communications Will Not be Preserved, Which Would Prevent Director Brennan from Vindicating His Constitutional Rights…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications and to Protect Director Brennan's Constitutional Rights…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim - 865. RETRIEVED EVIDENCE:
and Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 45 of 4642
k)
all records or communications relating to any investigation of Director Brennan or his alleged co-conspirators that were held or received by any Department of Justice personnel who have been involved in such investigation, including personnel who have stopped working on the investigation or have left employment at the Department of Justice.
GOVERNING EVIDENCE:
950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in…process and prosecution to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other Minnesota officials to be punitive and…from the Acting Attorney General to the FBI Director and the Counselor overseeing the Brennan investigations have been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the Department of Justice are engaging in demonstrably irregular prosecutorial activity in order to gin up a case…vindictiveness, Director Brennan expects that he will forcefully challenge any eventual indictment as the product of an unconstitutionally vindictive and selective prosecution. In - 866. RETRIEVED EVIDENCE:
(2) Issue a declaratory judgment that the government has the obligation to preserve the above listed materials and that that obligation applies prior to indictment.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN, Notice of address filed under seal, Plaintiff v. TODD W. BLANCHE, in his official capacity as Acting Attorney General, 950 Pennsylvania Avenue, NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's…Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of Investigation, 935 Pennsylvania Ave, NW Washington, DC 20001 DONALD J. TRUMP, in his official…Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE - 867. RETRIEVED EVIDENCE:
(3) Grant such other relief as the Court may deem just and proper.
GOVERNING EVIDENCE:
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JOHN O. BRENNAN…Presumption of Regularity to the Government ................................. 24 V. The Court Reviewing the Vindictive and Selective Prosecution Challenges Would Require Access to Government…................................................................... 25 VI. Absent this Court's Intervention, There is a Serious Risk that Highly Relevant Internal Government…26 VII. Injunctive Relief is Necessary to Ensure Preservation of Relevant Government Materials and Communications…38 REQUEST FOR RELIEF…to punish the President's perceived adversaries. Echoing the same theme in his recent opinion finding the investigation directed against Minnesota Governor Tim Walz and other…been publicly declaring Director Brennan a criminal, not only before securing a conviction in court but even before a full investigation and an indictment. And, certain officials in the - 868. RETRIEVED EVIDENCE:
Dated:
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 869. RETRIEVED EVIDENCE:
July 1, 2026 /s/ Kenneth L.
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 870. RETRIEVED EVIDENCE:
Wainstein Kenneth L.
GOVERNING EVIDENCE:
relief as the Court may deem just and proper. Dated: July 1, 2026 /s/ Kenneth L. Wainstein Kenneth L. Wainstein, DC Bar # 451058 Natasha Harnwell-Davis, DC Bar # 1719228 Mayer Brown LLP 1999 K - 871. RETRIEVED EVIDENCE:
Wainstein, DC Bar # 451058
Natasha Harnwell-Davis, DC Bar # 1719228
Mayer Brown LLP
1999 K Street, NW Washington, DC 20006-1101
Telephone:
GOVERNING EVIDENCE:
Not available—retrieved text is not a complete linguistic sentence. - 872. RETRIEVED EVIDENCE:
(202) 263-3000
KWainstein@mayerbrown.com Dan Gelber Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A.
GOVERNING EVIDENCE:
Street, NW Washington, DC 20006-1101 Telephone: (202) 263-3000 KWainstein@mayerbrown.com Dan Gelber Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A. One Southeast Third Avenue, Suite 2600 Miami, Florida 33131-1715 Telephone: (305) 728-0954 dan@gsgpa.com Joan Silverstein Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A. One Southeast Third Avenue, Suite 2600 Miami, Florida - 873. RETRIEVED EVIDENCE:
One Southeast Third Avenue, Suite 2600
Miami, Florida 33131-1715
Telephone:
GOVERNING EVIDENCE:
NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia - 874. RETRIEVED EVIDENCE:
(305) 728-0954
dan@gsgpa.com Joan Silverstein Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A.
GOVERNING EVIDENCE:
DC 20006-1101 Telephone: (202) 263-3000 KWainstein@mayerbrown.com Dan Gelber Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A. One Southeast Third Avenue, Suite 2600 Miami, Florida 33131-1715 Telephone: (305) 728-0954 dan@gsgpa.com Joan Silverstein Pro hac vice forthcoming Gelber Schachter & Greenberg, P.A. One Southeast Third Avenue, Suite 2600 Miami - 875. RETRIEVED EVIDENCE:
One Southeast Third Avenue, Suite 2600
Miami, Florida 33131-1715
Telephone:
GOVERNING EVIDENCE:
NW Washington, DC 20530 THE UNITED STATES DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530 JASON A. REDING QUI ONES, in his official capacity as U.S. Attorney for the Southern District of Florida, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 JOSEPH E. DIGENOVA, in his official capacity as Counselor to the Attorney General, U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 KASH P. PATEL, in his official capacity as Director of the Federal Bureau of…1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC 20500 SUSAN L. WILES, in her official capacity as White House Chief of Staff, 1600 Pennsylvania Avenue NW Washington, DC 20500 JOHN L. RATCLIFFE, in his official capacity as Director of…in Washington, D.C. and of investigations in two grand juries in the Southern District of Florida. He is a former director of the CIA, and he resides in the Commonwealth of Virginia - 876. RETRIEVED EVIDENCE:
(305) 728-0950
jsilverstein@gsgpa.com Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 46 of 46
GOVERNING EVIDENCE:
States, 1600 Pennsylvania Ave NW Washington, DC 20500 Civil Action Case No. _________ 26-2323 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 1 of 46 EXECUTIVE OFFICE OF THE PRESIDENT, 1600 Pennsylvania Avenue NW Washington, DC…INTELLIGENCE, 1500 Tysons McLean Dr. McLean, VA 22102 Defendants Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 2 of 46 TABLE OF CONTENTS Page i COMPLAINT…34 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 3 of 46 TABLE OF CONTENTS (continued) Page ii COUNT 1…39 Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 4 of 461 COMPLAINT "Being perceived as the President's adversary has become risky in…activity in order to gin up a case that will satisfy the President's direction. Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 5 of 462 Given these strong indicia of vindictiveness, Director Brennan expects that he will…Brennan alleges as follows: Case 1:26-cv-02323 Document 1 Filed 07/01/26 Page 6 of 463 INTRODUCTION 1