In the first case against James Comey for allegedly lying to Congress, there was no dismissal; instead, the judge rejected US Attorney Lindsey Halligan’s involvement. After that, the statute of limitations ran out.  However, if the report below is accurate, this would represent the third currently active investigation against former FBI Director James Comey, and Lindsey Halligan might get the last laugh.

The first investigative notice to Comey was in mid-March from the Sunshine State.  Essentially the ‘conspiracy case’ being reviewed by Jason A. Reding Quiñones, the U.S. attorney for the Southern District of Florida {SOURCE}.  The second investigative case was in North Carolina, where a grand jury released an indictment for threats against President Trump {SOURCE}.  Now, Bloomberg is reporting on a third investigation against Comey for leaking classified documents to his friend and special government employee, Daniel Richman.

BLOOMBERG – […] The investigation is tied to his dissemination of documents to Columbia University Law Professor Daniel Richman, the individuals added. If successful, it would be the Trump DOJ’s third time indicting Comey since last fall.

[…] It hasn’t been decided if the department will present an indictment to a grand jury in Eastern Virginia, where Comey resides, or if the case could be pursued in a different location—such as in Richman’s home of New York. (read more)

It doesn’t really matter whether New York or the Eastern District of Virginia (EDVA), either location would be the third state where the disgraced former FBI Director Comey would have to defend himself. Again, I remind everyone of ‘pressure points’ in Lawfare.

If the EDVA/NY case proceeds it is based around James Comey leaking his memos to his friend Daniel Richman.

In addition to being a close personal friend to James Comey, Daniel Richman is part of the Lawfare network and close friends with Benjamin Wittes, another member of Comey’s tribe.  The evidence of this leaking operation is solid, very solid.  The only defense James Comey holds in this matter is to claim his memos were not ‘classified’ material.

In fact, several months ago I was told the reason Comey was not yet indicted was due to an internal debate within the DOJ as to the classification status of the Comey memos.  To wit I replied, “there is a profound irony in this question the DOJ is asking itself.”

You see, in the Mar-a-Lago documents case Jack Smith appealed the ‘classification’ ruling by Judge Aileen Cannon when she appointed a “Special Master” to review the documents and determine the classification status.

The DOJ/FBI Special Counsel, previously said to the Florida court they would not reveal the content of the Mar-a-Lago document information because it was “classified” under “national security” grounds.  You might remember President Trump’s legal position was to make the content public because Trump said there was no classified material.

To reconcile the issue, during discovery phase Florida Judge Cannon appointed a Special Master to review the “classified” documents.  The FBI and Jack Smith balked at the demand and filed an appeal with the 11th Circuit to keep the Trump defense from reviewing what Jack Smith said were “documents marked classified.”

Smith didn’t want the documents made public or revealed to President Trump, so the DOJ/FBI position was that the documents were too sensitive (TSCI) with “national security” implications.

The Eleventh Circuit Court of Appeals ruled the “classification status” of the Mar-a-Lago documents was whatever the national security apparatus of the federal government (DOJ, FBI and Intelligence Community) said it was.  The judicial branch could not interfere in the classification status applied by the executive branch.

The 11th Circuit Court of Appeals agreed with the government position that any documents defined as “classified” by the executive branch (then Biden) that claimed, “national security,” should not be disclosed to the defendant, Donald Trump.  The court of appeals essentially determined that all definitions by the executive branch, are not questionable by the judicial branch.

This precedent now applies to James Comey’s memos.  If the DOJ/FBI/IC define the Comey memos as classified documents because they specifically pertain to private discussions with President Donald Trump about ongoing security matters and Russia, then the Comey memos are legally classified information – regardless of what James Comey says about them.

The DOJ can prosecute James Comey for leaking classified documents by using the same legal approach the DOJ used against Donald Trump.  Classified documents are whatever the federal government says they are.

When I reminded the DC people about this specific precedent, you could have heard a pin drop.

♦ Back to Richman….  Though USAO Lindsey Halligan could not get beyond the technicality ruling of her appointment, she smartly dropped all the evidence against Comey for leaking classified documents inside a legal response about Comey lying to congress. {GO DEEP}

This was either super smart or just legally serendipitous, because that approach made visible the evidence now being considered to indict Comey on a matter that does not have a statute of limitations.

♦ Lindsey Halligan provided the evidence of James Comey’s extensive use of Daniel Richman to act as a cut out for leaks and communications with the media [Attachments HERE].

Beginning on January 2, 2015, James Comey hired Daniel Richman to be his conduit to the media for all things around the Clinton investigation.  Exhibit #3 highlights Richman emails to Office of Legal Counsel, Patrick Findlay, to begin the process of officially working for Comey as a special government employee. [Attachment #3 HERE].

There are multiple exhibits highlighting emails between James Comey (aka Reinhold Niebuhr7) and Daniel Richman [HERE-4 and HERE-5 and HERE-6 and HERE-7] proving the former FBI director did intentionally direct Daniel Richman to contact media persons on his behalf and leak investigative background information, or instruct them on information, James Comey provided. The evidence on this issue is overwhelming.

Daniel Richman, working directly on the instructions of James Comey, worked closely with New York Times journalist Mike Schmidt, husband of MSNBC’s Nicole Wallace, to publish material [ex. Exhibit #8].  Richman then coordinated the FBI director’s message with dozens of national journalists, writing the scripts for them to publish on behalf of James Comey [ex Exhibit #9].   Again, the evidence on this collaborative endeavor is overwhelming.

Interestingly, [Govt Exhibit #12] is the criminal complaint stemming from the FBI investigation which began on July 21, 2025.   The investigative summary notes the purposeful use of Room #9582 at FBI headquarters, intended to destroy classified evidence concealed in five burn bags.

[SOURCE Exhibit #12, page 2]

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Florida – Conspiracy case.

North Carolina – Comey threats against Trump.

NY or EDVA – Comey leaking classified documents.

Warmest best,

Sundance