Strzok Complained Of ‘Material Misrepresentations’ In FISA Application

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Chuck Ross Investigative Reporter
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One of Peter Strzok’s text messages shows the embattled FBI agent complaining about a case in which “material misrepresentations” were made to obtain a spy warrant in the FISA Court.

The exchange occurred on Oct. 16, 2015, well before Strzok was tapped to lead the investigation into Russian meddling in the presidential campaign. But it sheds some light on the FISA process, which is at the center of a partisan debate because of the FBI and Justice Department’s use of the unverified Steele dossier to obtain a FISA warrant to spy on former Trump campaign adviser Carter Page.

In the text, which was sent to FBI lawyer Lisa Page, Strzok appears to be criticizing another government official who he claimed bungled an investigation. (RELATED: Senate Committee Releases Massive Trove Of Peter Strzok’s Texts)

The official, whose name is redacted, reopened an investigation, which lead to a discussion within the Justice Department’s Office of Intelligence about whether “material misrepresentations” were made in a FISA application.

The case was closed because of those material misrepresentations, Strzok suggested.

Oct. 16, 2015 text message from Peter Strzok to Lisa Page

At the time he sent the text, Strzok was working on the Hillary Clinton email investigation. The following July, he was tapped to oversee the Russia investigation. It is unclear how deeply Strzok was involved in obtaining the FISAs against Page.

The first warrant to spy on Page was granted on Oct. 21, 2016 and was renewed three times — in January, April and June.

Republican lawmakers have recently alleged that either dossier author Christopher Steele made misrepresentations to the FBI about his Trump investigation, or the agency made materially false representations to a FISA judge in order to get warrants to spy on Carter Page. (RELATED: Senators Accuse Steele And FBI Of Dossier ‘Deception’)

Republicans claim that the agencies failed to disclose that the dossier was funded by the Clinton campaign and DNC and that Steele failed to disclose some of his contacts with reporters while he was working with the FBI.


There is little public information about how frequently the FBI and Justice Department are found to have made misrepresentations to the FISA Court or how many cases are closed because of inaccurate representations in spy warrant applications.

In a recent report, the progressive activist group Demand Progress noted that the court “has no independent means to verify compliance and so must rely on the government to self-report any violations.”

“The government claims it informs the FISC of violations in a timely fashion. But judges have repeatedly complained about delays in notice of violations and other key information, in one 2017 opinion accusing the government of ‘an institutional lack of candor,'” the report reads.

California Republican Rep. Devin Nunes has pushed to reveal some of the inconsistencies in the FBI and DOJ’s applications to spy on Page, a 46-year-old energy consultant who denies the allegations made about him in the dossier.

Steele alleged that Page met secretly with two Kremlin insiders and was the Trump campaign’s main Kremlin liaison for the purposes of collusion.

Iowa Sen. Chuck Grassley and South Carolina Sen. Lindsey Graham have also pointed out discrepancies in the FISA applications.

The two Republicans referred Steele to the FBI last month for possible criminal investigation because of statements he made to the bureau regarding his work on the dossier. They also left open the possibility that the FBI and DOJ knew of inaccuracies in Steele’s statements to FBI agents but included his information in the FISA application anyway.

“The FISA applications are either materially false in claiming that Mr. Steele said he did not provide dossier information to the press prior to October 2016, or Mr. Steele made materially false statements to the FBI when he claimed he only provided the dossier information to his business partner and the FBI,” the senators wrote to FBI Director Christopher Wray and Deputy Attorney General Rod Rosenstein.

In their letter, Grassley and Graham point to Steele’s interactions with Yahoo! News reporter Michael Isikoff in September 2016. Steele briefed Isikoff on his dossier findings at the time, and the reporter published an article on Sept. 23, 2016.

The FBI “extensively” cited that article in its FISA application but appeared unaware that Steele was the source of the information.

Grassley and Graham asserted that the misrepresentations arose from Steele’s claims to that FBI that he “did not have unauthorized contacts with the press” prior to October 2016.

The senators said that Steele’s “apparent deception” seemed to have had “significant” and “material” consequences on the FBI’s investigation and its claims to the FISA Court.

“Mr. Steele’s information formed a significant portion of the FBI’s warrant application, and the FISA application relied more heavily on Mr. Steele’s credibility than on any independent verification or corroboration for his claims,” the wrote.

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