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Legal Viability of Claims in Durham Annex Document
Overview
The declassified Durham Annex is a 29-page intelligence appendix to Special Counsel John Durham’s 2023 report, made public in July 2025. It purports to contain foreign-intelligence summaries of conversations in 2016 suggesting that the Hillary Clinton campaign contemplated a plan to falsely link Donald Trump to Russia. The Annex names specific persons and entities (see below) and quotes documents and emails allegedly obtained by foreign sources. We analyze whether this material – largely hearsay from foreign intelligence – could support federal criminal charges. In short, while the Annex raises questions, it does not provide admissible, firsthand evidence sufficient for criminal convictions under U.S. law.
Individuals and Entities Implicated
The Annex repeatedly names or implicates the following U.S. and foreign individuals or groups:
Hillary Clinton’s 2016 campaign and affiliates. ...