2 speculation that President Trump colluded with Russia in an attempt to influence the outcome of the Presidential election. Incredibly, according to Butowsky, the Presid ent reviewed an art icle written by a Fox News journalist prior to its publication and sought to get the article published “immediately.” Indeed, just before But owsky sent the text message above, he left a voicemail for Mr. Wheeler in which he said, “

A couple minutes ago I got a note that we have the full, uh, attention of the Wh ite House, on this. And, tomorro w, let’s close this deal , whatever we’v e got to do. But you ca n feel free t o say that th e White Hous e is onto thi s now.

”

1

3.

To lend support to this shift the blame theory, Zimmerman, with the knowledge and support of Butowsky, fabricated two quotations and attributed them to Mr. Wheeler:



“‘My investigation up to this point shows there was some degree of email exchange between Seth Rich and Wikileaks,’ said Wheeler.”



“‘My investigation shows someone within the DC government, Democratic National Committee or Clinton team is blocking the murder investigation from going forward,’ Wheeler said. ‘That is unfortunate. Seth Rich’s murder is unsolved as a result of that.’” 4.

Mr. Wheeler – who was the only named source quoted in the article – did not make these statements . According to Butowsky, the statements were falsely attributed to Mr. Wheeler because

that is the way the President wanted the article

. Zimmerman, Butowsky and Fox had created fake news to advance President Trump’s agenda. Mr. W heeler was subsequently forced to correct the false record and, as a result, lost all credibility in the eyes of the public. Mr. Wheeler has suffered irreparable damage t o his reputation and his career wil l likely never recover.

1

Every quotation in this Complaint is from an email, text message, published news article and/or recorded or videotaped conversation.