Special Counsel John Durham says Igor Danchenko's lies materially affected the Russia collusion probe, including misleading agents about his relationship with Russian government officials and a PR executive.
Notably, the survey period entirely falls after Fulton County District Attorney Fani Willis on Monday announced charges against Trump over his efforts to challenge the 2020 presidential election in the Peach State.
U.S. Attorney General Merrick Garland appointed Smith in November 2022.
"Deranged Jack Smith, the hand picked Prosecutor of the Harris-Biden DOJ, and Washington, D.C. based Radical Left Democrats, are HELL BENT on continuing to Weaponize the Justice Department in an attempt to cling to power," he continued.
"No, I shouldn’t have a protective order placed on me because it would impinge upon my right to FREE SPEECH," Trump posted on Monday to Truth Social.
The plot allegedly involved 'dressing up as Santa Claus and handing out candy laced with poison'
Sadow also plans to file a separate motion for dismissal on grounds of presidential immunity, though such claims have attracted legal scrutiny in Trump's other election case.
Fani Willis, a Democrat, held on to her post after defeating Republican Courtney Kramer in Tuesday's election, according to results from the secretary of state's office.
This is the latest roadblock Special Counsel Jack Smith has faced in his prosecutions of former President Trump.