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From:
Kenerson, Erik (USADC) <Erik.Kenerson@usdoj.gov>
Sent:
Wednesday, April 17, 2019 7:31 PM
To:
Driscoll, Robert; Carry, Alfred
Cc:
Saunders, Thomas (USADC); Zimmerman, Jolie (USADC); Mackie, Will (NSD) (JMD)
Subject:
Sentencing Notice
Attachments:
CDL BA Release 022919.docx; EAD-Anderson-bio (1).pdf; Robert Anderson Bio May 2018.docx; Robert Anderson navigant bio.docx; BIO.docx; Anderson Notice.pdf 
Bob, Alfred: Please see attached and let us know if you have any questions. Erik
Case 1:18-cr-00218-TSC Document 102-1 Filed 04/21/19 Page 1 of 12
 
 U.S. Department of Justice Jessie K. Liu United States Attorney
 District of Columbia
 
 Judiciary Center 555 Fourth St., N.W. Washington, D.C. 20530
 
April 17, 2019 BY EMAIL Robert Driscoll, Esq. McGlinchey Stafford, LLP 1275 Pennsylvania Avenue N.W. Suite 420 Washington, D.C. 20004 Re: United States v. Mariia Butina, Case No. 18-218 (TSC) Dear Mr. Driscoll: As I indicated in our phone call last week, the government may call Robert Anderson, Jr., to testify as an expert witness at sentencing in this matter. Mr. Anderson served as the Assistant Director of the Federal Bureau of Investigation (FBI)’s Counterintelligence Division; Executive Assistant Director of the FBI’s Criminal, Cyber, and Response and Services Branch; and Special Agent in Charge of the Intelligence Division of the FBI’s Washington Field Office. In total, he served for 21 years as a Special Agent with the FBI. Mr. Anderson retired at the end of 2016 and is currently the Chief Executive Officer of Cyber Defense Labs in Dallas, Texas. He has testified as an expert witness in two civil litigation depositions. His testimony in those matters concerned cyber security and intrusions by nation-state actors. Several of Mr. Anderson’s bios are attached. If the government decides to call Mr. Anderson to the stand, the government anticipates that he will testify about the intelligence goals, priorities, tradecraft, and activities of the Russian Federation, as well as the interplay among the various Russian government components that are involved in intelligence and political influence operations. The government anticipates that Mr. Anderson will testify as to how the Russian Federation benefits from receiving information like that provided by Ms. Butina during the conspiracy underlying her guilty plea. The government anticipates attaching a declaration by Mr. Anderson to its sentencing materials. Regardless of whether the government calls Mr. Anderson affirmatively as a witness at the sentencing hearing, it plans to make him available at that hearing, should you or the Court have any questions for him based on his declaration.
Case 1:18-cr-00218-TSC Document 102-1 Filed 04/21/19 Page 2 of 12
 
The government anticipates that Mr. Anderson’s expert opinions will be based on his review of: open source materials, such as media reports and interviews; public filings in this case; discussions with the case agents; and evidence collected throughout the investigation that has been  produced in discovery. We anticipate his opinions also will be based on his vast experience in investigating and prosecuting counterintelligence cases. The government believes that Mr. Anderson’s testimony will assist the Court evaluating the defendant’s actions in context. The government believes that such testimony would be appropriate to assist the Court in evaluating the factors to be considered under 18 U.S.C. § 3553(a), such as the nature and characteristics of the offense and the need for the sentence imposed to: (1) reflect the seriousness of the offense, to promote respect for the law, and to provide just punishment for the offense; and (2) afford adequate deterrence to criminal conduct.
See
 18 U.S.C. § 3553(a)(1), (2)(A) & (B). Please let us know if you have any questions. Sincerely, Jessie K. Liu United States Attorney By: __/s/___________________ Erik Kenerson Thomas N. Saunders Jolie F. Zimmerman Assistant U.S. Attorneys
Case 1:18-cr-00218-TSC Document 102-1 Filed 04/21/19 Page 3 of 12

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