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| Meta Title | ‘Clinton Plan’ Emails Were Likely Made by Russian Spies, Declassified Report Shows - The New York Times |
| Meta Description | An annex to a report by the special counsel John H. Durham was the latest in a series of disclosures about the Russia inquiry, as the Trump team seeks to distract from the Jeffrey Epstein files. |
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An annex to a report by the special counsel John H. Durham was the latest in a series of disclosures about the Russia inquiry, as the Trump team seeks to distract from the Jeffrey Epstein files.
The release of the annex to a report by the special counsel John H. Durham, right, adds new details to the public’s understanding of a complex trove of 2016 Russian intelligence reports analyzing purported emails that Russian hackers stole from Americans.
Credit...
Samuel Corum for The New York Times
July 31, 2025
The Trump-era special counsel who scoured the Russia investigation for wrongdoing gathered evidence that undermines a theory pushed by some Republicans that Hillary Clinton’s campaign conspired to frame Donald J. Trump for colluding with Moscow in the 2016 election, information declassified on Thursday shows.
The information, a
29-page annex
to the special counsel’s 2023 report, reveals that a foundational document for that theory was most likely stitched together by Russian spies. The document is a purported email from July 27, 2016, that said Mrs. Clinton had approved a campaign proposal to tie Mr. Trump to Russia to distract from the scandal over her use of a private email server.
The release of the annex adds new details to the public’s understanding of a complex trove of 2016 Russian intelligence reports analyzing purported emails that Russian hackers stole from Americans. It also shows how the special counsel, John H. Durham, went to great lengths to try to prove that several of the emails were real, only to ultimately conclude otherwise.
The declassification is the latest disclosure in recent weeks concerning the Russia investigation. The wave has come as the administration is seeking to change the subject from its broken promise to release files related to the disgraced financier Jeffrey Epstein.
Image
The report annex indicates that a key piece of supposed evidence for the claim that Hillary Clinton approved a plan to tie Donald J. Trump to Russia in 2016 is not credible.
Credit...
Eric Lee for The New York Times
In reality, the annex shows the opposite, indicating that a key piece of supposed evidence for the claim that Mrs. Clinton approved a plan to tie Mr. Trump to Russia is not credible: Mr. Durham concluded that the email from July 27, 2016, and a related one dated two days earlier were probably manufactured.
Ahead of the 2020 election, Mr. Ratcliffe, as director of national intelligence in Mr. Trump’s first term, had
declassified and released the crux of the July 27 email
, even though he acknowledged doubts about its credibility. Officials did “not know the accuracy of this allegation or the extent to which the Russian intelligence analysis may reflect exaggeration or fabrication,” he said.
Among some Trump supporters, the message became known as the “Clinton Plan intelligence,” as Mr. Durham
put it in his final report
.
In his report, Mr. Durham used the U.S. government’s knowledge of the supposed plan, via the Russian memos, to criticize F.B.I. officials involved in the Russia investigation for not being more skeptical when they later received a copy of the Steele dossier and used it to obtain a wiretap order. The dossier, a compendium of Trump-Russia claims compiled by a former British spy, stemmed from a Democratic opposition research effort and was later discredited.
“Whether or not the Clinton Plan intelligence was based on reliable or unreliable information, or was ultimately true or false,” Mr. Durham wrote, agents should have been more cautious when approaching material that appeared to have partisan origins.
Image
Mrs. Clinton in 2016. Mr. Durham was never able to prove any Clinton campaign conspiracy to frame Mr. Trump by spreading information that it knew to be false about his ties to Russia.
Credit...
Ruth Fremson/The New York Times
Mr. Durham’s report also mentioned that Mrs. Clinton and others in the campaign dismissed the allegation as ridiculous, positing that it was Russian disinformation. But Mr. Durham banished to the annex concrete details he had found that bolstered her campaign’s rebuttal, burying until now the conclusion that the email he called the “Clinton Plan intelligence” was almost certainly a product of Russian disinformation.
The annex shows that the person who supposedly sent the July 27 email, Leonard Benardo of the Open Society Foundations network, told Mr. Durham in 2021 that he had never seen the message and did not write it. The network is the philanthropic arm of the liberal financier George Soros, who has been made out to be a villain by Russian state media and by some American conservatives.
The annex also cited a purported email from July 25, 2016, also attributed to Mr. Benardo. Referring to President Vladimir V. Putin of Russia, the message claimed that a Clinton adviser was proposing a plan “to demonize Putin and Trump,” adding, “Later the F.B.I. will put more oil into the fire.”
That message identified the adviser as “Julie,” while the July 27 one said “Julia.” An accompanying Russian intelligence memo identified the aide as Julianne Smith, a foreign policy adviser for the Clinton campaign who worked at the Center for a New American Security.
But the trove of Russian files contained two different versions of the July 25 message — one that somehow had an additional sentence. And Mr. Benardo denied sending it, telling Mr. Durham’s team that he did not know who “Julie” was and would not use a phrase like “put more oil into the fire.”
Ms. Smith informed Mr. Durham in 2021 that she had no memory of proposing anything to campaign leadership about attacking Mr. Trump over Russia, although she “recalled conversations with others in the campaign expressing their genuine concerns that the D.N.C. hack was a threat to the electoral system, and that Trump and his advisers appeared to have troubling ties to Russia.”
The annex also shows that Mr. Durham obtained emails from several liberal-leaning think tanks mentioned in the Russian memos and did not find copies of the messages supposedly written by Mr. Benardo. The think tanks included the Open Society Foundations, the Atlantic Council, the Carnegie Endowment for International Peace and the Center for a New American Security.
But Mr. Durham found other “emails, attachments and documents that contain language and references with the exact same or similar verbiage” to those messages. Those included a July 25 email by a Carnegie Endowment cyberexpert that contained an extensive passage about Russian hacking that was echoed, verbatim, in the purported July 25 message attributed to Mr. Benardo.
Mr. Durham also obtained text messages from Ms. Smith on July 25 showing that she had unsuccessfully tried to determine whether the F.B.I. had opened an investigation into the Democratic National Committee breach, although they did not mention Mr. Trump. And he obtained a July 27 email from Ms. Smith asking her colleagues at the think tank to sign a bipartisan statement criticizing Mr. Trump’s denunciations of the NATO alliance as reckless and too friendly to Russia.
Mr. Durham wrote that it would have been logical for someone to conclude that she played a role in efforts by the Clinton campaign to tie Mr. Trump to Russia. Her July 25 texts and July 27 email could be seen as support for the idea that such a plan existed, he added.
But ultimately, in weighing all the evidence, Mr. Durham concluded that the Russians had probably faked the key emails, the annex shows.
“The office’s best assessment is that the July 25 and July 27 emails that purport to be from Benardo were ultimately a composite of several emails that were obtained through Russian intelligence hacking of the U.S.-based think tanks, including the Open Society Foundations, the Carnegie Endowment and others,” it says.
The Russian intelligence memos first came to public attention in 2017 after
The New York Times
and
The Washington Post
explored a decision by James B. Comey Jr., the former F.B.I. director, to violate Justice Department procedure. In publicly addressing the investigation into Mrs. Clinton, he sharply criticized her use of a private email server but said no charges could be brought over it.
Mr. Comey later told Congress and an inspector general that he decided to be the face of the decision, rather than allowing Justice Department officials to do so, as is typical, in part because of something in the Russian memos. A
Dutch spy agency had hacked the memos from a Russian spy agency’s server in 2016 and gave copies to the U.S. government
.
Two of the memos described purported communications in January 2016 and March 2016 involving a top Democratic Party leader, Representative Debbie Wasserman Schultz of Florida, one with Mr. Benardo and the other with a different official at the Open Society Foundations. The memos indicated that the attorney general at the time, Loretta E. Lynch, was pressuring the F.B.I. about the email inquiry and sharing confidential information about it with the Clinton campaign.
But Mr. Comey and other officials also
said
they believed that the memos described fake emails, in part because the January one also said that Mr. Comey himself was trying to help Republicans win the election. In 2017, Mr. Benardo and Ms. Wasserman Schultz said that they had never even met, let alone communicated about Mrs. Clinton’s emails.
The Trump administration has also declassified and released
a report by Republicans on the House Intelligence Committee
that summarized unflattering claims about Mrs. Clinton from the Russian memos without flagging suspicions that the trove contained misinformation.
After the special counsel investigating the Trump campaign’s ties to Russia, Robert S. Mueller III, issued his final report, the attorney general at the time, William P. Barr, assigned Mr. Durham to hunt for evidence proving Mr. Trump’s conspiracy theory that the investigation had stemmed from a deep-state plot against him.
In 2020, as
The New York Times has reported
, after Mr. Durham failed to find evidence of intelligence abuses, he shifted to instead trying to find a basis to blame the Clinton campaign for the fact that Mr. Trump’s campaign had come under suspicion of colluding with Russia.
Mr. Durham was never able to prove any Clinton campaign conspiracy to frame Mr. Trump by spreading information that it knew to be false about his ties to Russia, but he nevertheless used court filings and his final report to insinuate such suspicions. He brought charges of false statements against two people involved in outside efforts to scrutinize possible ties between Mr. Trump and Russia, both of which ended in quick acquittals.
Charlie Savage
writes about national security and legal policy for The Times.
Adam Goldman
writes about the F.B.I. and national security for The Times. He has been a journalist for more than two decades.
A version of this article appears in print on
Aug. 2, 2025
, Section A, Page 12 of the New York edition with the headline: New Disclosure Upends Claims Against Clinton
.
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# ‘Clinton Plan’ Emails Were Likely Made by Russian Spies, Declassified Report Shows
An annex to a report by the special counsel John H. Durham was the latest in a series of disclosures about the Russia inquiry, as the Trump team seeks to distract from the Jeffrey Epstein files.
- Share full article

The release of the annex to a report by the special counsel John H. Durham, right, adds new details to the public’s understanding of a complex trove of 2016 Russian intelligence reports analyzing purported emails that Russian hackers stole from Americans.Credit...Samuel Corum for The New York Times
[](https://www.nytimes.com/by/charlie-savage)[](https://www.nytimes.com/by/adam-goldman)
By [Charlie Savage](https://www.nytimes.com/by/charlie-savage) and [Adam Goldman](https://www.nytimes.com/by/adam-goldman)
Reporting from Washington
July 31, 2025
The Trump-era special counsel who scoured the Russia investigation for wrongdoing gathered evidence that undermines a theory pushed by some Republicans that Hillary Clinton’s campaign conspired to frame Donald J. Trump for colluding with Moscow in the 2016 election, information declassified on Thursday shows.
The information, a [29-page annex](https://static01.nyt.com/newsgraphics/documenttools/6d15e0e33b27f7e3/c842303b-full.pdf) to the special counsel’s 2023 report, reveals that a foundational document for that theory was most likely stitched together by Russian spies. The document is a purported email from July 27, 2016, that said Mrs. Clinton had approved a campaign proposal to tie Mr. Trump to Russia to distract from the scandal over her use of a private email server.
DECLASSIFIED REPORTS
[Read the report about emails likely faked by Russian spies.](https://static01.nyt.com/newsgraphics/documenttools/6d15e0e33b27f7e3/c842303b-full.pdf)
The release of the annex adds new details to the public’s understanding of a complex trove of 2016 Russian intelligence reports analyzing purported emails that Russian hackers stole from Americans. It also shows how the special counsel, John H. Durham, went to great lengths to try to prove that several of the emails were real, only to ultimately conclude otherwise.
The declassification is the latest disclosure in recent weeks concerning the Russia investigation. The wave has come as the administration is seeking to change the subject from its broken promise to release files related to the disgraced financier Jeffrey Epstein.
Image

The report annex indicates that a key piece of supposed evidence for the claim that Hillary Clinton approved a plan to tie Donald J. Trump to Russia in 2016 is not credible.Credit...Eric Lee for The New York Times
Even as the releases shed more light on a seismic political period nearly a decade ago, Mr. Trump and his allies have wildly overstated [what the documents show, accusing former President Barack Obama of “treason](https://www.nytimes.com/2025/07/25/us/trump-obama-russia.html).”
The release of the annex was no exception. John Ratcliffe, the C.I.A. director, said in a statement that the materials proved that suspicions of Russian collusion stemmed from “a coordinated plan to prevent and destroy Donald Trump’s presidency.”
And Kash Patel, the F.B.I. director, who has [a long history of pushing false claims about the Russia investigation](https://www.nytimes.com/2025/01/23/us/politics/kash-patel-trump-fbi-inquiries.html), [declared on social media that the annex](https://x.com/FBIDirectorKash/status/1951012713930354869) revealed “evidence that the Clinton campaign plotted to frame President Trump and fabricate the Russia collusion hoax.”
In reality, the annex shows the opposite, indicating that a key piece of supposed evidence for the claim that Mrs. Clinton approved a plan to tie Mr. Trump to Russia is not credible: Mr. Durham concluded that the email from July 27, 2016, and a related one dated two days earlier were probably manufactured.
Ahead of the 2020 election, Mr. Ratcliffe, as director of national intelligence in Mr. Trump’s first term, had [declassified and released the crux of the July 27 email](https://www.judiciary.senate.gov/imo/media/doc/09-29-20_Letter%20to%20Sen.%20Graham_Declassification%20of%20FBI's%20Crossfire%20Hurricane%20Investigations_20-00912_U_SIGNED-FINAL.pdf), even though he acknowledged doubts about its credibility. Officials did “not know the accuracy of this allegation or the extent to which the Russian intelligence analysis may reflect exaggeration or fabrication,” he said.
Among some Trump supporters, the message became known as the “Clinton Plan intelligence,” as Mr. Durham [put it in his final report](https://www.nytimes.com/2023/05/15/us/politics/trump-russia-investigation-durham.html).
In his report, Mr. Durham used the U.S. government’s knowledge of the supposed plan, via the Russian memos, to criticize F.B.I. officials involved in the Russia investigation for not being more skeptical when they later received a copy of the Steele dossier and used it to obtain a wiretap order. The dossier, a compendium of Trump-Russia claims compiled by a former British spy, stemmed from a Democratic opposition research effort and was later discredited.
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“Whether or not the Clinton Plan intelligence was based on reliable or unreliable information, or was ultimately true or false,” Mr. Durham wrote, agents should have been more cautious when approaching material that appeared to have partisan origins.
Image

Mrs. Clinton in 2016. Mr. Durham was never able to prove any Clinton campaign conspiracy to frame Mr. Trump by spreading information that it knew to be false about his ties to Russia.Credit...Ruth Fremson/The New York Times
Mr. Durham’s report also mentioned that Mrs. Clinton and others in the campaign dismissed the allegation as ridiculous, positing that it was Russian disinformation. But Mr. Durham banished to the annex concrete details he had found that bolstered her campaign’s rebuttal, burying until now the conclusion that the email he called the “Clinton Plan intelligence” was almost certainly a product of Russian disinformation.
The annex shows that the person who supposedly sent the July 27 email, Leonard Benardo of the Open Society Foundations network, told Mr. Durham in 2021 that he had never seen the message and did not write it. The network is the philanthropic arm of the liberal financier George Soros, who has been made out to be a villain by Russian state media and by some American conservatives.
The annex also cited a purported email from July 25, 2016, also attributed to Mr. Benardo. Referring to President Vladimir V. Putin of Russia, the message claimed that a Clinton adviser was proposing a plan “to demonize Putin and Trump,” adding, “Later the F.B.I. will put more oil into the fire.”
That message identified the adviser as “Julie,” while the July 27 one said “Julia.” An accompanying Russian intelligence memo identified the aide as Julianne Smith, a foreign policy adviser for the Clinton campaign who worked at the Center for a New American Security.
But the trove of Russian files contained two different versions of the July 25 message — one that somehow had an additional sentence. And Mr. Benardo denied sending it, telling Mr. Durham’s team that he did not know who “Julie” was and would not use a phrase like “put more oil into the fire.”
Ms. Smith informed Mr. Durham in 2021 that she had no memory of proposing anything to campaign leadership about attacking Mr. Trump over Russia, although she “recalled conversations with others in the campaign expressing their genuine concerns that the D.N.C. hack was a threat to the electoral system, and that Trump and his advisers appeared to have troubling ties to Russia.”
The annex also shows that Mr. Durham obtained emails from several liberal-leaning think tanks mentioned in the Russian memos and did not find copies of the messages supposedly written by Mr. Benardo. The think tanks included the Open Society Foundations, the Atlantic Council, the Carnegie Endowment for International Peace and the Center for a New American Security.
But Mr. Durham found other “emails, attachments and documents that contain language and references with the exact same or similar verbiage” to those messages. Those included a July 25 email by a Carnegie Endowment cyberexpert that contained an extensive passage about Russian hacking that was echoed, verbatim, in the purported July 25 message attributed to Mr. Benardo.
Mr. Durham also obtained text messages from Ms. Smith on July 25 showing that she had unsuccessfully tried to determine whether the F.B.I. had opened an investigation into the Democratic National Committee breach, although they did not mention Mr. Trump. And he obtained a July 27 email from Ms. Smith asking her colleagues at the think tank to sign a bipartisan statement criticizing Mr. Trump’s denunciations of the NATO alliance as reckless and too friendly to Russia.
Mr. Durham wrote that it would have been logical for someone to conclude that she played a role in efforts by the Clinton campaign to tie Mr. Trump to Russia. Her July 25 texts and July 27 email could be seen as support for the idea that such a plan existed, he added.
But ultimately, in weighing all the evidence, Mr. Durham concluded that the Russians had probably faked the key emails, the annex shows.
“The office’s best assessment is that the July 25 and July 27 emails that purport to be from Benardo were ultimately a composite of several emails that were obtained through Russian intelligence hacking of the U.S.-based think tanks, including the Open Society Foundations, the Carnegie Endowment and others,” it says.
The Russian intelligence memos first came to public attention in 2017 after [The New York Times](https://www.nytimes.com/2017/04/22/us/politics/james-comey-election.html) and [The Washington Post](https://www.washingtonpost.com/world/national-security/how-a-dubious-russian-document-influenced-the-fbis-handling-of-the-clinton-probe/2017/05/24/f375c07c-3a95-11e7-9e48-c4f199710b69_story.html) explored a decision by James B. Comey Jr., the former F.B.I. director, to violate Justice Department procedure. In publicly addressing the investigation into Mrs. Clinton, he sharply criticized her use of a private email server but said no charges could be brought over it.
Mr. Comey later told Congress and an inspector general that he decided to be the face of the decision, rather than allowing Justice Department officials to do so, as is typical, in part because of something in the Russian memos. A [Dutch spy agency had hacked the memos from a Russian spy agency’s server in 2016 and gave copies to the U.S. government](https://myprivacy.dpgmedia.nl/consent?siteKey=PUBX2BuuZfEPJ6vF&callbackUrl=https%3A%2F%2Fwww.volkskrant.nl%2Fprivacy-wall%2Faccept%3FredirectUri%3D%252fwetenschap%252fdutch-agencies-provide-crucial-intel-about-russia-s-interference-in-us-elections%257eb4f8111b%252f%253freferer%253dhttps%25253A%25252F%25252Fwww.google.com%25252F).
Two of the memos described purported communications in January 2016 and March 2016 involving a top Democratic Party leader, Representative Debbie Wasserman Schultz of Florida, one with Mr. Benardo and the other with a different official at the Open Society Foundations. The memos indicated that the attorney general at the time, Loretta E. Lynch, was pressuring the F.B.I. about the email inquiry and sharing confidential information about it with the Clinton campaign.
But Mr. Comey and other officials also [said](https://www.grassley.senate.gov/imo/media/doc/horowitz_2018_midyear_appendix_released_by_chairman_grassley.pdf) they believed that the memos described fake emails, in part because the January one also said that Mr. Comey himself was trying to help Republicans win the election. In 2017, Mr. Benardo and Ms. Wasserman Schultz said that they had never even met, let alone communicated about Mrs. Clinton’s emails.
The Trump administration has also declassified and released [a report by Republicans on the House Intelligence Committee](https://www.dni.gov/files/ODNI/documents/DIG/DIG-Declassified-HPSCI-Report-Manufactured-Russia-Hoax-July2025.pdf) that summarized unflattering claims about Mrs. Clinton from the Russian memos without flagging suspicions that the trove contained misinformation.
After the special counsel investigating the Trump campaign’s ties to Russia, Robert S. Mueller III, issued his final report, the attorney general at the time, William P. Barr, assigned Mr. Durham to hunt for evidence proving Mr. Trump’s conspiracy theory that the investigation had stemmed from a deep-state plot against him.
In 2020, as [The New York Times has reported](https://www.nytimes.com/2023/01/26/us/politics/durham-trump-russia-barr.html), after Mr. Durham failed to find evidence of intelligence abuses, he shifted to instead trying to find a basis to blame the Clinton campaign for the fact that Mr. Trump’s campaign had come under suspicion of colluding with Russia.
Mr. Durham was never able to prove any Clinton campaign conspiracy to frame Mr. Trump by spreading information that it knew to be false about his ties to Russia, but he nevertheless used court filings and his final report to insinuate such suspicions. He brought charges of false statements against two people involved in outside efforts to scrutinize possible ties between Mr. Trump and Russia, both of which ended in quick acquittals.
[Charlie Savage](https://www.nytimes.com/by/charlie-savage) writes about national security and legal policy for The Times.
[Adam Goldman](https://www.nytimes.com/by/adam-goldman) writes about the F.B.I. and national security for The Times. He has been a journalist for more than two decades.
A version of this article appears in print on Aug. 2, 2025, Section A, Page 12 of the New York edition with the headline: New Disclosure Upends Claims Against Clinton. [Order Reprints](https://nytimes.wrightsmedia.com/) \| [Today’s Paper](https://www.nytimes.com/section/todayspaper) \| [Subscribe](https://www.nytimes.com/subscriptions/Multiproduct/lp8HYKU.html?campaignId=48JQY)
See more on: [U.S. Justice Department](https://www.nytimes.com/topic/organization/us-justice-department), [Hillary Rodham Clinton](https://www.nytimes.com/topic/person/hillary-rodham-clinton), [John H Durham](https://www.nytimes.com/topic/john-h-durham), [Robert S. Mueller III](https://www.nytimes.com/topic/person/robert-s-mueller), [Kashyap Patel](https://www.nytimes.com/topic/kashyap-patel), [Donald Trump](https://www.nytimes.com/spotlight/donald-trump)
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***
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***
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**How We Report on the Trump Administration**
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An annex to a report by the special counsel John H. Durham was the latest in a series of disclosures about the Russia inquiry, as the Trump team seeks to distract from the Jeffrey Epstein files.

The release of the annex to a report by the special counsel John H. Durham, right, adds new details to the public’s understanding of a complex trove of 2016 Russian intelligence reports analyzing purported emails that Russian hackers stole from Americans.Credit...Samuel Corum for The New York Times
July 31, 2025
The Trump-era special counsel who scoured the Russia investigation for wrongdoing gathered evidence that undermines a theory pushed by some Republicans that Hillary Clinton’s campaign conspired to frame Donald J. Trump for colluding with Moscow in the 2016 election, information declassified on Thursday shows.
The information, a [29-page annex](https://static01.nyt.com/newsgraphics/documenttools/6d15e0e33b27f7e3/c842303b-full.pdf) to the special counsel’s 2023 report, reveals that a foundational document for that theory was most likely stitched together by Russian spies. The document is a purported email from July 27, 2016, that said Mrs. Clinton had approved a campaign proposal to tie Mr. Trump to Russia to distract from the scandal over her use of a private email server.
The release of the annex adds new details to the public’s understanding of a complex trove of 2016 Russian intelligence reports analyzing purported emails that Russian hackers stole from Americans. It also shows how the special counsel, John H. Durham, went to great lengths to try to prove that several of the emails were real, only to ultimately conclude otherwise.
The declassification is the latest disclosure in recent weeks concerning the Russia investigation. The wave has come as the administration is seeking to change the subject from its broken promise to release files related to the disgraced financier Jeffrey Epstein.
Image

The report annex indicates that a key piece of supposed evidence for the claim that Hillary Clinton approved a plan to tie Donald J. Trump to Russia in 2016 is not credible.Credit...Eric Lee for The New York Times
In reality, the annex shows the opposite, indicating that a key piece of supposed evidence for the claim that Mrs. Clinton approved a plan to tie Mr. Trump to Russia is not credible: Mr. Durham concluded that the email from July 27, 2016, and a related one dated two days earlier were probably manufactured.
Ahead of the 2020 election, Mr. Ratcliffe, as director of national intelligence in Mr. Trump’s first term, had [declassified and released the crux of the July 27 email](https://www.judiciary.senate.gov/imo/media/doc/09-29-20_Letter%20to%20Sen.%20Graham_Declassification%20of%20FBI's%20Crossfire%20Hurricane%20Investigations_20-00912_U_SIGNED-FINAL.pdf), even though he acknowledged doubts about its credibility. Officials did “not know the accuracy of this allegation or the extent to which the Russian intelligence analysis may reflect exaggeration or fabrication,” he said.
Among some Trump supporters, the message became known as the “Clinton Plan intelligence,” as Mr. Durham [put it in his final report](https://www.nytimes.com/2023/05/15/us/politics/trump-russia-investigation-durham.html).
In his report, Mr. Durham used the U.S. government’s knowledge of the supposed plan, via the Russian memos, to criticize F.B.I. officials involved in the Russia investigation for not being more skeptical when they later received a copy of the Steele dossier and used it to obtain a wiretap order. The dossier, a compendium of Trump-Russia claims compiled by a former British spy, stemmed from a Democratic opposition research effort and was later discredited.
“Whether or not the Clinton Plan intelligence was based on reliable or unreliable information, or was ultimately true or false,” Mr. Durham wrote, agents should have been more cautious when approaching material that appeared to have partisan origins.
Image

Mrs. Clinton in 2016. Mr. Durham was never able to prove any Clinton campaign conspiracy to frame Mr. Trump by spreading information that it knew to be false about his ties to Russia.Credit...Ruth Fremson/The New York Times
Mr. Durham’s report also mentioned that Mrs. Clinton and others in the campaign dismissed the allegation as ridiculous, positing that it was Russian disinformation. But Mr. Durham banished to the annex concrete details he had found that bolstered her campaign’s rebuttal, burying until now the conclusion that the email he called the “Clinton Plan intelligence” was almost certainly a product of Russian disinformation.
The annex shows that the person who supposedly sent the July 27 email, Leonard Benardo of the Open Society Foundations network, told Mr. Durham in 2021 that he had never seen the message and did not write it. The network is the philanthropic arm of the liberal financier George Soros, who has been made out to be a villain by Russian state media and by some American conservatives.
The annex also cited a purported email from July 25, 2016, also attributed to Mr. Benardo. Referring to President Vladimir V. Putin of Russia, the message claimed that a Clinton adviser was proposing a plan “to demonize Putin and Trump,” adding, “Later the F.B.I. will put more oil into the fire.”
That message identified the adviser as “Julie,” while the July 27 one said “Julia.” An accompanying Russian intelligence memo identified the aide as Julianne Smith, a foreign policy adviser for the Clinton campaign who worked at the Center for a New American Security.
But the trove of Russian files contained two different versions of the July 25 message — one that somehow had an additional sentence. And Mr. Benardo denied sending it, telling Mr. Durham’s team that he did not know who “Julie” was and would not use a phrase like “put more oil into the fire.”
Ms. Smith informed Mr. Durham in 2021 that she had no memory of proposing anything to campaign leadership about attacking Mr. Trump over Russia, although she “recalled conversations with others in the campaign expressing their genuine concerns that the D.N.C. hack was a threat to the electoral system, and that Trump and his advisers appeared to have troubling ties to Russia.”
The annex also shows that Mr. Durham obtained emails from several liberal-leaning think tanks mentioned in the Russian memos and did not find copies of the messages supposedly written by Mr. Benardo. The think tanks included the Open Society Foundations, the Atlantic Council, the Carnegie Endowment for International Peace and the Center for a New American Security.
But Mr. Durham found other “emails, attachments and documents that contain language and references with the exact same or similar verbiage” to those messages. Those included a July 25 email by a Carnegie Endowment cyberexpert that contained an extensive passage about Russian hacking that was echoed, verbatim, in the purported July 25 message attributed to Mr. Benardo.
Mr. Durham also obtained text messages from Ms. Smith on July 25 showing that she had unsuccessfully tried to determine whether the F.B.I. had opened an investigation into the Democratic National Committee breach, although they did not mention Mr. Trump. And he obtained a July 27 email from Ms. Smith asking her colleagues at the think tank to sign a bipartisan statement criticizing Mr. Trump’s denunciations of the NATO alliance as reckless and too friendly to Russia.
Mr. Durham wrote that it would have been logical for someone to conclude that she played a role in efforts by the Clinton campaign to tie Mr. Trump to Russia. Her July 25 texts and July 27 email could be seen as support for the idea that such a plan existed, he added.
But ultimately, in weighing all the evidence, Mr. Durham concluded that the Russians had probably faked the key emails, the annex shows.
“The office’s best assessment is that the July 25 and July 27 emails that purport to be from Benardo were ultimately a composite of several emails that were obtained through Russian intelligence hacking of the U.S.-based think tanks, including the Open Society Foundations, the Carnegie Endowment and others,” it says.
The Russian intelligence memos first came to public attention in 2017 after [The New York Times](https://www.nytimes.com/2017/04/22/us/politics/james-comey-election.html) and [The Washington Post](https://www.washingtonpost.com/world/national-security/how-a-dubious-russian-document-influenced-the-fbis-handling-of-the-clinton-probe/2017/05/24/f375c07c-3a95-11e7-9e48-c4f199710b69_story.html) explored a decision by James B. Comey Jr., the former F.B.I. director, to violate Justice Department procedure. In publicly addressing the investigation into Mrs. Clinton, he sharply criticized her use of a private email server but said no charges could be brought over it.
Mr. Comey later told Congress and an inspector general that he decided to be the face of the decision, rather than allowing Justice Department officials to do so, as is typical, in part because of something in the Russian memos. A [Dutch spy agency had hacked the memos from a Russian spy agency’s server in 2016 and gave copies to the U.S. government](https://myprivacy.dpgmedia.nl/consent?siteKey=PUBX2BuuZfEPJ6vF&callbackUrl=https%3A%2F%2Fwww.volkskrant.nl%2Fprivacy-wall%2Faccept%3FredirectUri%3D%252fwetenschap%252fdutch-agencies-provide-crucial-intel-about-russia-s-interference-in-us-elections%257eb4f8111b%252f%253freferer%253dhttps%25253A%25252F%25252Fwww.google.com%25252F).
Two of the memos described purported communications in January 2016 and March 2016 involving a top Democratic Party leader, Representative Debbie Wasserman Schultz of Florida, one with Mr. Benardo and the other with a different official at the Open Society Foundations. The memos indicated that the attorney general at the time, Loretta E. Lynch, was pressuring the F.B.I. about the email inquiry and sharing confidential information about it with the Clinton campaign.
But Mr. Comey and other officials also [said](https://www.grassley.senate.gov/imo/media/doc/horowitz_2018_midyear_appendix_released_by_chairman_grassley.pdf) they believed that the memos described fake emails, in part because the January one also said that Mr. Comey himself was trying to help Republicans win the election. In 2017, Mr. Benardo and Ms. Wasserman Schultz said that they had never even met, let alone communicated about Mrs. Clinton’s emails.
The Trump administration has also declassified and released [a report by Republicans on the House Intelligence Committee](https://www.dni.gov/files/ODNI/documents/DIG/DIG-Declassified-HPSCI-Report-Manufactured-Russia-Hoax-July2025.pdf) that summarized unflattering claims about Mrs. Clinton from the Russian memos without flagging suspicions that the trove contained misinformation.
After the special counsel investigating the Trump campaign’s ties to Russia, Robert S. Mueller III, issued his final report, the attorney general at the time, William P. Barr, assigned Mr. Durham to hunt for evidence proving Mr. Trump’s conspiracy theory that the investigation had stemmed from a deep-state plot against him.
In 2020, as [The New York Times has reported](https://www.nytimes.com/2023/01/26/us/politics/durham-trump-russia-barr.html), after Mr. Durham failed to find evidence of intelligence abuses, he shifted to instead trying to find a basis to blame the Clinton campaign for the fact that Mr. Trump’s campaign had come under suspicion of colluding with Russia.
Mr. Durham was never able to prove any Clinton campaign conspiracy to frame Mr. Trump by spreading information that it knew to be false about his ties to Russia, but he nevertheless used court filings and his final report to insinuate such suspicions. He brought charges of false statements against two people involved in outside efforts to scrutinize possible ties between Mr. Trump and Russia, both of which ended in quick acquittals.
[Charlie Savage](https://www.nytimes.com/by/charlie-savage) writes about national security and legal policy for The Times.
[Adam Goldman](https://www.nytimes.com/by/adam-goldman) writes about the F.B.I. and national security for The Times. He has been a journalist for more than two decades.
A version of this article appears in print on Aug. 2, 2025, Section A, Page 12 of the New York edition with the headline: New Disclosure Upends Claims Against Clinton. [Order Reprints](https://nytimes.wrightsmedia.com/) \| [Today’s Paper](https://www.nytimes.com/section/todayspaper) \| [Subscribe](https://www.nytimes.com/subscriptions/Multiproduct/lp8HYKU.html?campaignId=48JQY)
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