ANALYSIS:

The unidentified whistleblower at the CIA makes scores of references to Rudolph W. Giuliani in the complaint against President Trump, with most of the information coming from Mr. Giuliani’s own public statements and news reports.

Whistleblower complaints typically contain confirmed inside information not known to investigators until they are tipped off.

In the case of Mr. Trump’s lawyer, who is a private citizen, congressional Democrats could have gathered most of the whistleblower’s tidbits about Mr. Giuliani from the internet.

Nonetheless, the complaint has prompted House Democrats to put the former New York mayor under investigation.

Other Giuliani allegations are based on unnamed sources in a style similar to that of the discredited Democratic Party-financed dossier used in 2017 by the FBI to try to bring down Mr. Trump. It quoted unknown Kremlin sources and it was eventually debunked.

“It is quite dumbfounding that an intelligence community whistleblower is targeting Giuliani, someone who certainly does not have a security clearance,” Brett L. Tolman, a Republican-aligned former U.S. attorney for Utah, told The Washington Times. “The credibility of the whistleblower is further brought into question when it is apparent that they were not present for any of the alleged misconduct of Giuliani.”

For months, Mr. Giuliani has been investigating how the Ukrainian government interfered in the 2016 election by cooperating with the Democratic Party and the Hillary Clinton presidential campaign. He has traveled to Ukraine and Europe for interviews, and talked about it with the press.

The anti-Trump whistleblower disapproves. The nine-page complaint refers to Mr. Giuliani 30 times in a footnoted narrative that implies Mr. Giuliani did something wrong.

“The President’s personal lawyer, Mr. Rudolph Giuliani, is a central figure in this effort,” the whistleblower wrote in his Aug. 12 complaint to the Senate and House intelligence committees.

A Justice Department memo described the whistleblower as a political partisan.

Intelligence community guidelines make clear that whistleblowers should not use the complaint process because they disagree with policy. The complaint form “is designed for reporting wrongdoing and not personal grievances, policy disputes or management disagreements,” the guidance says.

Jay Sekulow, who is on the president’s legal team, told The Washington Times: “Rudy was representing his client. Appropriate and ethical.”

The Office of the Intelligence Community Inspector General, which receives and assesses whistleblower complaints, states on its website that wrongdoing must have occurred “within” the community to qualify as an “urgent concern.” Once designated, a complaint automatically goes to the House and Senate intelligence committees.

“Lawful whistleblowing provides information about wrongdoing within the IC to those who can take action,” the policy states.

Mr. Giuliani is not a government employee. He is Mr. Trump’s personal attorney. He portrays himself as a whistleblower gathering facts on Ukrainian corruption and election interference.

Sidney Powell is a defense attorney for retired Army Lt. Gen. Michael Flynn, briefly Mr. Trump’s national security adviser. She is, in a sense, on a Giuliani-type mission. She has filed motions in U.S. District Court to force federal prosecutors to disclose more documents on how they conducted the nearly three-year Trump-Russia investigation.

On the whistleblower complaint, Ms. Powell said: “I have little doubt it was all orchestrated and contrived. Stunning things people are doing now.”

‘I’m the messenger’

Mr. Giuliani has been open about his work, depicting it as an anti-corruption investigation in a country that a receives millions of dollars in U.S. aid and is riddled with thieves and bribe-takers.

He also has looked into Democratic presidential candidate and former Vice President Joseph R. Biden and his son’s lucrative appointment to a Ukrainian natural gas firm’s board of directors in 2014. At the time, Mr. Biden was President Obama’s point man on Ukraine.

During a 30-minute phone call in July with Ukrainian President Volodymyr Zelensky, Mr. Trump asked him to talk to Attorney General William Barr about the Bidens. That request was contained in a call transcript as well as the whistleblower complaint. The whistleblower described Mr. Trump’s request as “pressured.”

The whistleblower narrative is filled with references to a public Mr. Giuliani. The complainant cites the same liberal press that promoted a Trump-Russia election conspiracy that special counsel Robert Mueller didn’t find.

Some examples of the whistleblower’s dossier-style writing:

• “It was also publicly reported that Mr. Giuliani had met on at least two occasions with Mr. Lutsenko: once in New York in late January and again in Warsaw in mid-February. In addition, it was publicly reported that Mr. Giuliani had spoken in late 2018 to former Prosecutor General Shokin, in a Skype call arranged by two associates of Mr. Giuliani.”

“Shokin” is Viktor Shokin, the former Ukrainian prosecutor who was fired at Mr. Biden’s request. “Lutsenko” is Yuriy Lutsenko, also a former prosecutor.

• “On 9 May, The New York Times reported that Mr. Giuliani planned to travel to Ukraine to press the Ukrainian government to pursue investigations that would help the President in his 2020 reelection bid.”

• “On 21 June, Mr. Giuliani tweeted: ‘New Pres of Ukraine still silent on investigation of Ukrainian interference in 2016 and alleged Biden bribery of Poroshenko. Time for leadership and investigate both if you want to purge how Ukraine was abused by Hillary and Clinton people.’”

“Poroshenko” is former Ukrainian President Petro Poroshenko, who was defeated by Mr. Zelensky.

The intelligence inspector general stated there is “some indication of an arguable political bias on the part of the Complainant in favor of a rival political candidate,” according to a Department of Justice memo.

The whistleblower also relies on hearsay when writing about Mr. Giuliani.

For example, he writes: “I heard from multiple U.S. officials that they were deeply concerned by what they viewed as Mr. Giuliani’s circumvention of national security decision making processes to engage with Ukrainian officials and relay messages back and forth between Kiev and the president.”

Mr. Giuliani defends his work for the president. He criticizes the New York Times, The Washington Post and other liberal outlets for years of protecting Mr. Biden and not investigating anything he does.

“WP, NBC, and CNN are going after me because I’m the messenger, and covering up the message, Dem corruption,” Mr. Giuliani tweeted. “Meanwhile, they have yet to ask Biden difficult questions because he is protected and immune like the Clintons and crooked Clinton Foundation!”

Although regulations by the Office of the Director of National Intelligence say that “urgent concern” whistleblower complaints must involve misconduct within the intelligence community, Inspector General Michael K. Atkinson approved the anti-Trump complaint with that designation.

He did this because the director of national intelligence is involved in countering election interference and the whistleblower argued that Mr. Trump was asking Ukraine to meddle.

A Justice Department Sept. 24 opinion from its Office of Legal Counsel disagreed with Mr. Atkinson.

“The complaint does not arise in connection with the operation of any U.S. government intelligence activity, and the alleged misconduct does not involve any member of the intelligence community,” the opinion said. “Rather, the complaint arises out of a confidential diplomatic communication between the President and a foreign leader that the intelligence-community complainant received secondhand.”

“The ICIG’s reporting responsibilities, however, do not concern officials outside the intelligence community, let alone the President,” the legal counsel said.

The opinion said the IG should have forwarded the complaint to the Justice Department, which would decide whether to open a criminal investigation.

The day after the opinion was written, the Trump administration relented. The administration publicly released the complaint and the call transcript.

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