EXHIBIT A 

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Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION

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UNITED STATES OF AMERICA,

Plaintiff,

vs.

YANJUN XU, also known as XU

YANJUN, also known as QU HUI,

also known as ZHANG HUI,

Defendant.

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CASE NO. 1:18-cr-0043

TRIAL EXCERPT

29th of OCTOBER, 2021

1:55 P.M.

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TRANSCRIPT OF PROCEEDINGS

BEFORE THE HONORABLE TIMOTHY S. BLACK, JUDGE

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APPEARANCES:

For the Plaintiff:

Timothy S. Mangan, Esq.

Emily N. Glatfelter, Esq.

Assistant United States Attorneys

221 East Fourth Street, Suite 400

Cincinnati, Ohio 45202

and

Matthew John McKenzie, Esq.

United States Department of Justice

National Security Division

950 Pennsylvania Avenue NW

Washington, D.C. 20530

and

Jacqueline K. Prim

Special Assistant, Paralegal

United States Department of Justice

National Security Division

950 Pennsylvania Avenue NW

Washington, D.C. 20530

For the Defendant:

Ralph William Kohnen, Esq.

Jeanne Marie Cors, Esq.

Sanna-Rae Taylor, Esq.

Taft Stettinius and Hollister

425 East Walnut Street, Suite 1800

Cincinnati, Ohio 45202

and

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Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Robert K. McBride, Esq.

Amanda Johnson, Esq.

Taft Stettinius and Hollister

50 East RiverCenter Boulevard

Suite 850

Covington, Kentucky 41011

and

Florian Miedel, Esq.

Miedel & Mysliwiec, LLP

80 Broad Street, Suite 1900

New York, New York 10004

Also present: Mae Harmon, Interpreter

Robin Murphy, Interpreter

Yanjun Xu, Defendant

Law Clerk: Cristina V. Frankian, Esq.

Courtroom Deputy: Bill Miller

Stenographer: Mary Schweinhagen, RPR, RMR, RDR, CRR

United States District Court

200 West Second Street, Room 910

Dayton, Ohio 45402

Proceedings reported by mechanical stenography,

transcript produced by computer.

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Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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INDEX OF WITNESSES

FRIDAY, OCTOBER 29, 2021

DIRECT CROSS REDIRECT RECROSS

PLAINTIFF'S WITNESSES

JAMES OLSON 5 73 91 92

* * * * *

INDEX OF EXHIBITS

GOVERNMENT'S ADMITTED

100 - Demonstrative 20

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Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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P-R-O-C-E-E-D-I-N-G-S 1:55 P.M.

(Proceedings reported but not transcribed.)

THE COURT: Where do we stand from the government's

perspective? MR. MANGAN: We have a witness ready to go, Your

Honor.

THE COURT: Okay. Do you want to call that witness?

MR. MANGAN: Yes, Your Honor. The government calls

Jim Olson.

THE COURT: Is somebody going to get him or her?

MS. GLATFELTER: Yes, Your Honor.

THE COURT: If the witness would be willing to

approach, we're going to put you on the witness stand.

Sir, if you'd be willing to pause. I am going to

administer the oath to tell the truth.

Would you raise your right hand. Do you solemnly swear

or affirm that your testimony today will be the truth, subject

to the penalty of perjury?

THE WITNESS: I do.

THE COURT: Very well. Be seated in the witness

stand.

In the spirit of full disclosure that seat sometimes tips

back, okay? We'll need you close to that microphone. Thank

you, sir.

Mr. Mangan, you can begin.

You will have some questions from the government's

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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lawyer.

MR. MANGAN: Thank you, Your Honor.

DIRECT EXAMINATION

BY MR. MANGAN:

Q. Good afternoon, Mr. Olson.

A. Good afternoon.

Q. Could you state your full name and spell your last name?

A. My full name is James Michael Olson, O-L-S-O-N.

Q. And, Mr. Olson, could you tell the jury your educational

background?

A. Yes. I have a bachelor's in law degrees from the

University of Iowa.

Q. And did you ever serve in the military?

A. Yes, I did. I was in the United States Navy, served

aboard guided missile destroyers and frigates and stayed in

the reserves after three and a half years of active duty.

And eventually achieved the rank of lieutenant commander.

Q. And when did you complete your service with the Navy?

A. I completed my service in the Navy in 1966.

Q. Thank you. Can you explain to the jury where you worked

for most of your career?

A. Most of my career was with the Central Intelligence

Agency. I served there for 31 years.

Q. Let's start with what the CIA does. That agency is

typically referred to as the CIA, correct?

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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A. Yes. The CIA is responsible for collection,

dissemination, analysis of intelligence from foreign sources

to provide necessary intelligence to U.S. policymakers.

Q. And during your service with the CIA, what was your

primary role?

A. I was what we call a case officer. I was undercover

the entire time, and my job was to collect intelligence

overseas in foreign countries.

Q. Have you heard the term "clandestine service"?

A. Yes. I was part of the clandestine service, or the

director of operations, as we sometimes call it.

Q. Can you explain what that is?

A. The clandestine service is the part of the CIA that is

undercover and conducts espionage and covert action on

behalf the of the United States government.

Q. Explain what you mean by "undercover." You said most of

your career you were operating undercover?

A. Yes. I was undercover the entire time. In fact, my

parents did not know that I was in the CIA. Our children

did not know. And you have cover for purposes of concealing

your identity and your intelligence affiliation and your

purpose while you are overseas.

Q. By the way, was your wife also in the service?

A. Yes. I met my wife, Meredith, at the CIA. We were an

undercover husband and wife CIA team.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Q. All right. Can you explain what kind of training a

person goes through to do what you do?

A. Training is rigorous. Most of the clandestine service

training takes place at an undercover base that we call The

Farm. And we learn all the techniques of espionage, the

tradecraft, what we call the recruitment cycle, and we also

have some paramilitary training to go along with that.

Q. You mentioned that you worked in the CIA for about 31

years. About how many of those years were you operational

overseas?

A. I was operational probably 25 of those 31 years,

outside the country.

Q. And generally what continent did you typically work in?

A. I worked primarily in Europe, but I also served in

Latin America.

Q. And during those overseas postings, did you perform what

might be called intelligence operations?

A. Yes, I did. I was collecting intelligence through

intelligence operations against foreign targets.

Q. Can you just explain a little bit more about what that

means, to do an intelligence operation?

A. It's spying. It is finding foreign people who have

access to information that our country needs for its own

security. And our job is to induce them to share that

information with us in return for money or some other

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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consideration.

Q. Later in your career, did you end up taking a position at

CIA headquarters?

A. Yes. I had a couple of assignments at CIA

headquarters. At one point I was chief of Soviet

operations, and then later my most significant position at

CIA headquarters was as chief of counterintelligence.

Q. And how long were you the chief of counterintelligence at

the CIA?

A. I was deputy chief of counterintelligence for one year

and chief for two years.

Q. What do you oversee as the chief of counterintelligence?

A. As chief of counterintelligence, my responsibility was

to monitor the activities of foreign intelligence services

around the world and do what we could to identify who they

were and what they were doing and to support those

activities, to bring with the aid of U.S. government

prosecutors those guilty of treason against the United

States to justice.

Q. All right. As part of your training and your work, what

languages do you speak?

A. I speak French, Russian, German, Spanish, Swedish, and

I read Latin.

Q. During your time with the CIA, did you receive any

commendations for your work?

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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A. Yes, I did. I was awarded the Intelligence Medal of

Merit, the Career Intelligence Medal, the Distinguished

Intelligence Medal, the Counterintelligence Medal, and the

Donovan Award, and maybe a few others.

Q. Are you familiar with something called the Joint Military

Intelligence College?

A. Yes, the Joint Military Intelligence College is one of

the leading training facilities for the United States

military, teaching intelligence and counterintelligence.

And I actually taught there for a year.

Q. What kinds of things did you teach?

A. Counterintelligence.

Q. All right. At some point did you take on a role at Texas

A&M University?

A. Yes, I did. After lengthy service in the CIA, I had

always thought I might like to teach some day. And when

President George Bush decided to put his presidential

library and museum at Texas A&M University, he wanted to

have a school of government in his name. He wanted to make

certain that intelligence was part of the curriculum. And

so he asked the director of the CIA to send someone to Texas

A&M University to build the intelligence studies program,

and I had the honor to be chosen to do that.

Q. When you were selected to do that, did you need to come

out from cover?

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OLSON - DIRECT (Mangan)

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A. Yes, yes. The CIA does not allow its officers to be on

college compuses covertly. And that was a traumatic

decision for Meredith and me because we had never wanted to

come out from undercover. But it was such a privilege to be

able to go there and to work at that school that we decided

we'd accept the consequences of coming out.

Q. And what does that mean, to come out from cover?

A. It means announcing to the whole world that you were a

spy, that you were lying to your friends and your family for

many, many years. It's something that we don't enjoy doing,

but it is necessary to have the opportunity to be a

professor, as I am now.

Q. Are you still at Texas A&M?

A. Yes, I am.

Q. And what is your position?

A. I am a professor of the practice and also the director

of the intelligence studies program at the Bush school.

Q. You mentioned you were still with the CIA when you

started at the university.

A. Yes. For the first two and a half years at Texas A&M

University I was still a serving counterintelligence officer

for the CIA. I was on loan to the Bush school of Texas A&M

University. But after two and a half years, I was eligible

to retire, and the CIA offered some attractive positions

back in Washington. But the Bush school came in and said,

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OLSON - DIRECT (Mangan)

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Jim, if you would like to stay here, we will offer you a

professorship. And that was very appealing to me because I

identified with the mission of preparing young men and women

for careers in intelligence.

Q. What year did you retire from the CIA?

A. I retired in the year 2000.

Q. All right. And have you been at Texas A&M ever since?

A. Yes, I have.

Q. In your current work at the university, how do you stay

apprised of current matters related to espionage and

counterintelligence?

A. I follow all the literature. I follow the press

reporting. I follow the FBI Department of Justice

affidavits. I read the indictments and other sources. One

of the best sources that I followed is the reports of the

National Counterintelligence Security Center. Those are

excellent.

I'm also in regular contact with the currently serving

counterintelligence professionals around the community.

Q. Is there a close relationship between your program at

Texas A&M and the agency?

A. Yes.

Q. Have you written any books related to espionage or

spying?

A. I have written two books, the first book was called

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OLSON - DIRECT (Mangan)

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Fair Play, The Moral Limits of Spying. And then my more

recent book, which was published in 2019, is called To Catch

a Spy, The Art of Counterintelligence.

Q. Now, Mr. Olson, based on your experience, are you

familiar with the methods and techniques used by intelligence

officers to acquire information?

A. Yes, I am.

Q. Are you familiar with China's intelligence-gathering

operations?

A. Yes, I am.

Q. And are you familiar with China's intelligence-gathering

agencies and methods?

A. Yes.

Q. Now, let me talk generally about intelligence gathering,

if we might. Can you explain from your experience, you know,

what the typical goal is for an intelligence-gathering agency

for a country?

A. The intelligence services of a foreign country are to

collect intelligence, to enhance the security of that

country, or its economy or its technological sector. They

have many, many objectives to use the tools of espionage to

enhance the security, the well-being of their people.

Q. All right. If you use the word "espionage," what does

that mean in your -- your parlance?

A. Espionage is spying. It's stealing secrets. It's

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OLSON - DIRECT (Mangan)

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collecting intelligence.

Q. Are you familiar with the term "industrial espionage"?

A. Yes, I am.

Q. And what would that mean?

A. Industrial espionage is stealing another country's

industrial secrets, its trade secrets, proprietary

information, its technology for the benefit of your own

country.

Q. All right. In working for an intelligence agency --

let's go back to your role when you were a case officer. How

do you know what information is needed?

A. We call that the requirements process, and it is a

formal process of determining what your consumers need. And

you then talk to them. You obtain lists of requirements,

information, and, for some countries, technology, other

things that they need. And so that's your starting point in

the process of collecting intelligence. You have got to

need to know up front what it is that you're seeking.

Q. All right. You said you're gathering information for

your consumers. What do you mean by "consumers"?

A. Well, for us it would be the U.S. policymakers. It

would be the President of the United States in the first

place. It would be the Department of Defense. It would be,

for all the mainline agencies, the policymakers of the

United States government. They depend on us to provide them

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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with the best intelligence that we can.

Q. All right. Have you heard the term "open-source

information"?

A. Yes.

Q. And can you explain what your understanding of that is?

A. Every intelligence service has analysts whose job it is

to monitor the international press, the speeches, the public

documents, things that are in the public domain. And we

call that open-source. Those are things that are publicly

available. And that is something that every intelligence

service does through its analysts.

Q. When you talk about the requirements that an intelligence

officer is looking for, are those typically found in

open-source areas?

A. Not at all, no.

Q. Can you explain that?

A. Yes. Operators are different, and I was an operator.

And we operators do not want to waste our time and resources

on what is publicly or commercially available. We go after

what is secret and controlled. That is our mission, and

that's what we do.

Q. So is your focus strictly on that category of information

that may not be available?

A. Completely. We do not go after open-source.

Q. Does the open-source information help define the

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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requirements?

A. Yes. It's useful as a starting point, as a foundation,

as a basis. You need to know what's out there in the public

domain, and then you have to identify what's not in the

public domain, and that's what you go after as a clandestine

service officer.

Q. All right. Sir, are you familiar with China's

intelligence-gathering operations?

A. Yes, I am.

Q. All right. What is the primary agency within China that

conducts external intelligence operations?

A. That is the Ministry of State Security, or MSS as we

call it.

Q. All right. In terms of a parallel agency for the CIA,

what would that parallel be in China?

A. The MSS.

Q. All right. Do they also have some domestic

responsibilities as well?

A. Yes, the MSS does have some collateral responsibilities

for counterintelligence, for tracking political dissidents,

but their overriding mission is overseas espionage outside

China.

Q. All right. Is there another ministry in China that is

strictly for internal intelligence?

A. Yes, it's the Ministry of Public Safety, or MPS as we

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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call it. And it is in charge of domestic security, counterterrorism, counterintelligence, that kind of thing.

Q. Have you heard of the term the "PLA"?

A. Yes.

Q. Is that the People's Liberation Army?

A. Yes. That's the Chinese military, and the PLA,

People's Liberation Army, also has an intelligence arm. And

they, for one thing, are responsible for most of the cyber

attacks on the United States.

Q. When it comes to intelligence-gathering operations, is

there one particular ministry that is the most dominant in

China?

A. The MSS is dominant.

Q. Can you talk a little bit about what are China's

espionage efforts geared towards?

A. The MSS does collect against the traditional espionage

targets of political and military secrets, but its number

one objective is to acquire western technology, to steal

western technology. That is the main purpose of the MSS.

Q. Is that different from how the CIA worked?

A. Yes, it's completely different because we do not do

that kind of thing. We do not engage in industrial

espionage in our country.

Q. All right. Let me talk about -- go back to this idea of

the requirements, if I might. When you're trying to define

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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those requirements for the case officers, do you sometimes

have to work with technical experts?

A. Yes, you do. If you are going after technical

intelligence, you want to talk to technical experts in your

country to determine what it is that they need.

Q. Okay. Do they help define those requirements --

A. Yes, they do.

Q. -- for you?

A. Yes, they do.

Q. And after you've gathered information, does the officer

sometimes go back to those experts to help understand whether

they hit the requirements or not?

A. Yes, that's very common.

Q. All right. To what extent is the intelligence officer's

mission driven by those requirements?

A. They guide what we do. I mean, we only go after secret

information that is desired, which is a priority of the

United States government. We do not stray away from that.

We know exactly what our marching orders are, what the

United States government needs in terms of intelligence, and

that's what our objectives are.

Q. Okay. Let me go through a couple terms just to make sure

we're all learning your lingo or using the same lingo here.

A. Sure.

Q. I think you referred to yourself as a case officer; is

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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that correct?

A. I'm a case officer.

Q. Or you were?

A. Yes. I'm proud of being called a case officer.

Q. If someone says "intelligence officer," is that a similar

term?

A. Yes.

Q. All right. And would you consider that a spy?

A. Yes.

Q. All right. How about when a case officer recruits a

person in a foreign country to help provide information, what

do you refer to that person as?

A. An agent.

Q. All right.

A. So in our jargon, our parlance, it's a case officer who

recruits and handles an agent.

Q. Okay. Are there sometimes other words used for an agent?

A. Spy, source, informant.

Q. All right. I think we already talked about covers.

Let me ask you about, are some operation -- in your area,

are most of the operations considered covert?

A. Yes.

Q. And can you explain what you mean by that?

A. "Covert" just means secret, that we protect the purpose

of our operations and our methodologies. We keep secrets as

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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well.

Q. Okay. And then I wanted to ask you about the term --

have you heard of the term "humint," H-U-M-I-N-T?

A. Oh, yes, I have.

Q. What is that?

A. That was my specialty. Humint is H-U-M-I-N-T. It is

short for human intelligence. And it is going after

individuals, human beings, who have the access that we are

looking for, and they are our target.

Q. And is humint intelligence different from other types of

collection?

A. Yes, it is. There's also technical collection. We

might call that signals intelligence. We have imagery

intelligence based on what we are seeing from our

satellites. So those are the main categories of

intelligence.

Q. Are there times when someone who works in humint

intelligence, like yourself, has to work with another person

who's doing cyber or signals intelligence?

A. Yes. The intelligence process is combining all those

different sources, all those different approaches to provide

the best intelligence possible for U.S. government policymakers.

Q. All right, sir. Have you heard of the term "recruitment

cycle"?

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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A. Yes. Recruitment cycle I am very familiar with.

MR. MANGAN: If I could, Your Honor, could we show

the witness Exhibit 100? It has not yet been admitted.

THE COURT: Yes, we'll show it to the witness.

BY MR. MANGAN:

Q. It will show up on your screen there.

Do you see that, Mr. Olson?

A. Not yet.

Yes, there it is.

Q. Okay. And would this exhibit help you explain the

recruitment cycle to the jury?

A. Yes, it will be helpful.

MR. MANGAN: Your Honor --

THE WITNESS: Generally, we describe the recruitment

cycle --

BY MR. MANGAN:

Q. Hang on. Before I get it, I want to show it to the jury.

So they don't see it yet.

A. Sorry.

MR. MANGAN: Your Honor, we'd move to admit Exhibit

100 as a demonstrative exhibit.

MR. McBRIDE: No objection, Your Honor.

THE COURT: It's admitted as a demonstrative

exhibit.

(Government's Exhibit 100 was received in evidence.)

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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MR. MANGAN: May we publish?

THE COURT: Yes. We will show it to the jury.

BY MR. MANGAN:

Q. One moment and it will come up on their screens.

A. All right.

Q. And then I wanted to ask you, Mr. Olson, if you can go

ahead and tell us, what is the recruitment cycle? And then

we'll walk through the steps.

A. The recruitment cycle is what we spies do. It's

something that's universal. All intelligence services go

through the same process to recruit spies, and it is the

bread and butter of our human intelligence business. And it

is a step-by-step process.

Q. All right. Let's talk through the beginning parts of it.

Can you walk through these steps and explain what they mean?

A. Yes. Spotting is looking for individuals who have the

information or the technology that corresponds to your

requirements. This is what you are looking for, and you are

looking for people who have that information, who have that

access, who have that technology. So that is spotting,

finding people that are potential sources for you.

Q. Let me -- before we kind of go through some of these

other items, with respect to the MSS, can you talk about how

they do spotting?

A. Their spotting is very aggressive. It's very

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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efficient. They look at American agencies or companies that

they are interested in. They look for indications of who's

employed there, who's working on the specific project that

they are interested in. They use a lot of social media also

for that purpose. So they are looking for people in those

companies or in those organizations or agencies that have

access to the information or technology they are looking

for. That's called spotting.

Q. So with respect -- to let's talk about the acquisition of

technology. What types of folks does the MSS target for

recruitment?

A. They will recruit any American, for example, who has

secret information or access to technology that they're

interested in.

Q. Is ethnicity a factor?

A. Ethnicity has been a big factor for the MSS.

Q. Explain what you mean by that.

A. The MSS likes to play the ethnic card, and that means

that the Chinese intelligence service is looking for ethnic

Chinese as targets. So, for example, if they find a Chinese

American who has U.S. citizenship or a green card, that

would be someone that they will look at very closely because

they believe that ethnic Chinese in the United States may

still have some loyalty to Mother China. They may feel a

cultural affinity. They speak the same language. And then

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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they may actually have relatives who still live in China,

which gives them leverage.

So they look, in the first place, for ethnic Chinese as

their targets. Not exclusively, but when they find it in

the Chinese, that's something that they look at very, very

carefully.

Q. Is -- are you familiar with LinkedIn?

A. I am, yes.

Q. Is LinkedIn used in the spotting process for the MSS?

A. Massively.

Q. Can you explain that.

A. It may be one of their major spotting mechanisms,

because on LinkedIn, what do they find? They find the

resumes of American government officials, former military

officers, engineers in high-tech companies, employees at

national laboratories who are looking for new employment.

And those people post their resumes, in many cases indicate

what U.S. government security clearances they had. They

talk about the projects they were involved in.

So LinkedIn is like a candy store, if I can put it that

way, for Chinese intelligence, because they've already

identified people who meet their criteria.

Q. All right. I'd like to return, if you could walk us

through the recruiting cycle.

A. Yes.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Q. We talked a little bit about spotting. If you could just

kind of walk us through some of these other steps so that the

jury understands what -- what these terms mean.

A. Right. After you've spotted a potential target for

recruitment, the next step is called assessing. And

assessing is trying to determine, first of all, does this

person, in fact, have the access to the information or

technology that you're interested in.

And then, secondly, you want to know what makes this

person tick: Does this person have some kind of sympathy

for Russia -- for China? Does this person have some kind of

vulnerability? Does this person have relatives in China?

Is there something about this person that might make him or

her susceptible? Is this person willing to cut corners?

So you're sizing that person up for the expectation

that you'd eventually be ale to move down the recruitment

cycle.

Q. All right. As you move through this process -- and I

imagine this process may have different speeds for different

people; is that fair?

A. Yes. Yes, it's variable.

Q. Walk us through the next phases of developing and

pitching.

A. Once you assess someone positively, you enter into what

we call developing. And that's where you try to establish a

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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personal relationship with this person. You try to befriend

this person. You wine and dine this person. You hold out

the possibility of a lucrative relationship. You are trying

to urge that person in your direction. And so you probably

will try to introduce some clandestinity in the

relationship. You will gradually test the waters by pushing

harder and harder for information and technology to see if

this person's willing to move in your direction or not.

Q. All right. And then as it moves into pitching, is

that -- walk us through what you mean by pitching.

A. Pitching is when you actually solicit the cooperation

of this person to provide the information or the technology

that you're after.

Q. All right.

A. And you generally will present that in terms of some

kind of a joint relationship, a cooperation, a

collaboration.

Q. All right. And in this pitching process, I imagine --

well, are there circumstances where the person on the other

side knows that they are dealing with an intelligence officer

and some instances where they don't know they are dealing with

an intelligence officer?

A. Yes, it goes both ways. Sometimes you, in effect,

break cover and announce that you are working for an

intelligence service and you're recruiting this person as a

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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formal spy. But if you're getting what you want already,

you may not need to break cover, and you just kind of

continue the pretext of the cover relationship.

The important thing is that you're getting the

information, the technology that you were after in the first

place.

Q. All right. And then the next few steps are formalizing,

producing, and termination.

A. Yes.

Q. Walk us through what you mean by those terms.

A. Well, once you have the cooperation of this individual,

and you want to formalize the relationship, and so you begin

to build a file on that person. You try to compromise that

person, usually with money. You want to really kind of sink

the hook, we call it, making certain that you do have a

person who is working on your behalf.

In our system, we might conduct a polygraph

examination. We might ask this person to sign an official

agreement with us. Not always, and that's not always

appropriate, but we all do that in our business.

Q. All right. And then once you have that person more or

less working on your side --

A. Yes.

Q. -- are there tasks that you might give the person?

A. Yes, yes. You give them tasking. You give them

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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objectives to accomplish. And once they start doing that,

once they are passing information to you, we've moved into

the producing phase of the operation.

And this is really the purpose of everything. You're

getting the intelligence and the technology that you sought

after from the beginning. So this is the payment. This is

what you are getting for your country, intelligence or

technology that is going to be valuable to your country.

That's why we spy, to reach the producing phase.

Q. All right. And then I imagine termination, these things

end sometimes?

A. Sure. All good things come to an end. Maybe the

person no longer has access, maybe you've recruited someone

who has better access and you no longer need this person.

Maybe this person has started to whine to you, fabricating.

Maybe the person is not reliable. Maybe the person is

getting cold feet. Maybe the person is under suspicion and

you terminate the person to protect that person from

discovery by the local counterintelligence forces.

A lot of reasons why that relationship can come to an

end.

Q. Okay. So let me ask you, are you familiar with something

called "exchange programs" in China to recruit foreign

technology experts?

A. Yes.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Q. All right. And does the MSS get involved in these

exchanges?

A. Yes.

Q. All right. Can you explain how the MSS uses those

exchanges?

A. Well, there are a lot of exchange programs. The

Thousand Talents Program I think is the most prominent,

where the MSS works toward identifying people, in the United

States primarily, who have access to cutting-edge research.

It can be in any area that is going to be valuable to China.

It could be in industry. It could be in high tech. It

could be in agriculture. It could be in medicine. Anything

that's going to be of value to China.

And they find experts in those fields, perhaps on a

college campus, and they establish a relationship with them.

They cast it as a normal scientific or technical exchange,

cultural exchange, something that sounds innocent. But

their purpose is to gradually induce that person to go

farther and farther and provide research and information

that goes beyond what they would be authorized to do.

Q. This recruitment cycle, how long could this take, you

know, on the long end?

A. It can take a long time. Sometimes it just falls into

your hands. People are willing to cooperate with you

because of varying reasons. Maybe because they are

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

29

sympathetic to your country. Maybe because they are just so

venal, so money hungry, that once you put money on the table

it's game over. Sometimes it requires more sophisticated

developing of a person to get the person to the point of

being willing to provide you with sensitive information of

sorts.

I've done cases where it was a matter of a couple

weeks. I've done cases where it's been -- I've done cases

where it's been a matter of a couple years.

Q. All right. And as the case officer goes through this

recruitment cycle with the agent -- correct? Am I using the

terms right?

A. Yes, you are. Good job.

Q. As the case officer goes through this process with the

agent and they have those communications, is there also a risk

for the case officer that they have to, you know, stay aware

of?

A. This is a high-risk profession. Intelligence is not

risk free. Those of us who enter this profession know that

we are going to encounter risks.

And the risks really come in two forms. There are

basically two categories of case officers. You have case

officers who are under diplomatic cover. They are operating

out of a U.S. embassy or a consulate, for example. They are

credited officially to the United States government as

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

30

diplomats. So they have diplomatic status, and they have

diplomatic immunity, and that means that if they get caught

spying, the worst that's going to happen to them is going to

be they are going to be declared persona non grata. They

are going to be expelled from the country. That's not good,

but it's not imprisonment.

Now, if you don't have diplomatic immunity, then it's

all different. Because if you get caught spying without

diplomatic immunity, you can go to -- you are subject to

arrest and imprisonment.

Q. So the first category, you said they are under diplomatic

cover?

A. Yes.

Q. The second category, when they do not have diplomatic

cover, is there a term for that?

A. We call that nonofficial cover. Other countries call

it other things, but it all boils down to the same thing.

If you do not have diplomatic cover, your cover's going to

be as a business person or as a member of an institute or a

member of an association. It could be anything that gives

you status for being in that country and to be operating as

a spy.

Q. So when you say "nonofficial cover," the initials for

that, NOC?

A. Yes, NOC.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Q. That's where that term comes from?

A. NOC, nonofficial cover. It means that you are posing

as something other than a diplomat. You do not have

diplomatic immunity.

Q. Okay.

A. When you go into a position without diplomatic

immunity, you know what the risks are, and they are quite

severe.

Q. So let's get back to sort of how the MSS operates. From

a risk standpoint, is there an advantage to them in recruiting

people to come to China?

A. Oh, very definitely. They are much more comfortable

working on their own turf, in the safety of China.

Q. And does that reduce the risk of arrest?

A. Oh, absolutely, absolutely. They're not going to be

arrested in China.

Q. Is the MSS careful about exposing any officers in the

U.S.?

A. Absolutely. When they operate in the United States,

they operate very aggressively here. They, of course, have

a large cadre of people who are here under diplomatic cover.

So that's one thing.

But they are very wary of operating in the United

States without diplomatic immunity because they know what

the risk is. They are afraid of the FBI, quite frankly, and

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

32

they don't want to have their people get caught in the

United States and be arrested and prosecuted.

Q. All right. Let me turn to a slightly different topic.

In the recruitment cycle, I think we talked about covers.

Are aliases used by intelligence officers?

A. All the time. Yeah, we all use aliases.

Q. Okay. Do you have multiple aliases?

A. Yes.

Q. Is that something you used?

A. Yes.

Q. And are you familiar if MSS operates the same way?

A. Absolutely, yes. Yes, their officers use aliases

routinely.

Q. Okay. Let me ask you about -- have you heard the term a

"front company" or a "cover company"?

A. Yes.

Q. Can you explain what that means for the officer?

A. Intelligence services sometimes set up companies. Some

of them actually have legitimate functions, but in some

cases they are completely bogus, only for the purpose of

providing cover for their personnel.

They set up these companies to conceal the fact that

they are actually operating on behalf of the intelligence

services of that company. That provides cover for

intelligence officers to operate.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Q. So is that company affiliation used in conjunction with

the alias?

A. Yes, yes. You would most likely as part of your alias

have a cover that conceals your identity and your

intelligence affiliation.

Q. All right. Does that give the alias some kind of

employment or background?

A. Yes. You would have ostensible duties in that cover

company. You would have a title. You'd probably have a

business card. You would represent yourself as an employee

of that cover.

And the cover company's usually are innocent sounding.

They sound legitimate. They are not in any way identifiable

as a front company for intelligence.

Q. I'd like to ask you about science and technology

associations in China.

A. Yes.

Q. Are you familiar with those?

A. Yes, I am.

Q. All right. And are they at times used by the MSS in

their operations?

A. Frequently.

Q. Can you explain how they're used?

A. They use these technical associations, these scientific

associations, these industrial associations to make

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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themselves appear legitimate. It's good cover because you

sound as if you are doing something that is innocent, that

is in no way affected with or connected with intelligence.

So, yes, they use associations, think tank institute,

university covers routinely in China.

Q. You just mentioned academic, I think. Do they sometimes

use university or academic covers as well?

A. Yes.

Q. Okay. And they use them in a similar manner as the

science and technology associations?

A. Yes, sir.

Q. Okay. Now, let me ask you, when we talk about this

recruitment cycle and the initial invitation to an agent or

potential agent, does the MSS sometimes use another person or

a proxy to do the initial invite?

A. That's quite common. In fact, the front person may be

somebody who is prestigious, maybe legitimate but is

cooperating with the intelligence services. So it's quite

often another individual who makes the initial contact and

probably will issue the invitation to come to China.

Q. From your perspective as a case officer, what's the

advantage of using that proxy or that front person?

A. It adds a little bit of prestige, a little bit of

luster, a little bit of legitimacy to the process if you

have someone who is a known, distinguished person in that

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

35

field to reach out to you with an invitation. You're

flattered by it.

Q. All right. Let's talk about those exchange trips where,

you know, let's say an employee from a U.S. technology company

is invited over for an exchange.

A. Yes.

Q. Are those typically paid for by China?

A. Yes.

Q. All right. And does the MSS get involved in that

funding?

A. The MSS pays. They provide the funding for that.

That's part of the mechanism that they're using to bring

these candidates to the -- to China.

Q. When that individual -- let's say the U.S. employee goes

over for one of these exchanges. Is there a risk for them if

they bring over their laptop or personal cell phone?

A. Oh, there could be, definitely, because it's well-known

that the Chinese will tamper with -- with computers brought

by visitors if they can get access to them.

Q. And if China does get access to them, what ministries in

China might be involved in that activity?

A. That's an MSS operation.

Q. In terms of talking about these potential agents or

sources, I wonder if you could explain the process from the

standpoint of, do you have to be subtle at the beginning?

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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A. Yes, you -- you are kind of keeping up the pretense of

a legitimate purpose, and so you are making it sound as

though it is a normal exchange. It is something that is not

out of the ordinary, that you are not asking them to do

anything inappropriate.

But while you are there, then you really get into the

assessment process in earnest to see if this person will

move a little bit farther.

And that's their objective, of course, to lure these

people into a more extensive relationship, to give up more

and more.

Q. Over time, does the officer, case officer elevate the

sensitivity of the information it sought?

A. Absolutely. They push. They become increasingly

aggressive, more specific in what they're looking for.

Q. And is it -- is that one of the difficult judgment calls

as to how quickly to escalate?

A. Yes.

Q. In talking about this recruitment cycle, you mention the

producing part of it.

A. Yes.

Q. Is that when you already have an agent or an asset in

place somewhere?

A. Yes. And that person's providing you with information

or technology or whatever the objective is.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Q. So if you have an asset within a -- let's say MSS has an

asset within a technology company. Do they want to be

selective in which tasks they give that person?

A. Yes. Yes, you want to be specific to that person's

access. You want to learn what that person's working on,

what his or her research area is, what the access is to

important information, what kind of computer access they

have. You learn all those things, and then you tailor the

tasking accordingly.

Q. Did you review the communication summary related to the

planting of malware on a French employee's --

A. Yes, I did.

Q. From your assessment, would that involve the tasking of

an in-place agent?

A. Yes. It was quite clear what was going on there. It

was an MSS operation using Chinese national employees in

that French company to plant a device, malware, into the

computer of a visiting French engineer.

Q. Would that fall under the category of producing?

A. Yes.

Q. All right. And would you consider that a humint

operation?

A. It would be a humint operation if the ultimate

objective were to recruit the French engineer, but it would

be more of a technical operation.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Q. All right. But the agents that you're using inside the

company, would they be considered humint agents?

A. Yes, yes. The people you have inside the company would

be humint sources.

Q. Okay.

MR. MANGAN: Are we at a -- this is a logical

breaking point, Your Honor.

THE COURT: Yes.

MR. MANGAN: This might be a good point.

THE COURT: Very well. We are going to take our

midafternoon break. We will break for 20 minutes, up until 3.

During the break, take the break. Breathe deeply. Don't

discuss the case among yourselves or with anyone else.

Continue to keep an open mind. No independent research.

Out of respect for you, we'll rise as you leave for a

20-minute break.

THE COURTROOM DEPUTY: All rise for the jury.

(Jury out at 2:37 p.m.)

THE COURT: The jury's left the room. We're going

to break for 20 minutes. Anything require my attention before

we start that break from the government?

MR. MANGAN: No, Your Honor.

THE COURT: From the defense?

MR. McBRIDE: No, Your Honor.

THE COURT: The government will take care of the

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

39

witness and admonish.

We are in recess until that time.

THE COURTROOM DEPUTY: The court is now in recess.

(Recess from 2:37 p.m. until 3:07 p.m.)

THE COURT: Back in the courtroom. Is the

government ready to proceed?

MR. MANGAN: Yes, Your Honor.

THE COURT: The defense as well?

MR. McBRIDE: Yes, sir.

THE COURT: Let's call for the jury, please.

The witness can take his mask off if he wants to. He

doesn't have to.

THE WITNESS: Thank you, Your Honor.

THE COURTROOM DEPUTY: All rise for the jury.

(Jury in at 3:01 p.m.)

THE COURT: You may all be seated.

The jury has rejoined us after break. One more time,

thank you for your continuing attention and hard work.

We'll continue with this witness who remains under oath.

Mr. Mangan, you may proceed when you're read.

MR. MANGAN: Thank you, Your Honor.

If we could put Exhibit 100 back up on the screen.

BY MR. MANGAN:

Q. Mr. Olson, in terms of going back to this recruitment

cycle, we talked a little bit about the exchanges that are

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

40

done in China with technical experts. Do you recall that?

A. Yes.

Q. And in walking through kind of how -- could we walk

through how that fits the recruitment cycle? So when an

individual is invited over for a presentation, what phase

would you consider that to be?

A. I would phase that as the beginning of assessment.

Q. All right. And so when they are listening to the

presentation, is that necessarily to get the ultimate

production at that point or is it more a matter of starting

the -- starting this process?

THE COURT: Is there an objection?

MR. McBRIDE: Lack of foundation, Your Honor.

THE COURT: Sustained as to form.

BY MR. MANGAN:

Q. If you could -- we were talking about when folks get

invited over for these presentations. You mention that that

might be the assessing part of the assessing step?

A. Yes, that's part of the assessment.

Q. Okay. Is there usually a payment related to those?

A. Yes.

Q. Okay. And how does that factor into the cycle?

A. That's still the assessment and beginning of the

development phase.

Q. All right. And then what other steps are taken in

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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relation to those exchanges towards developing that particular

agent?

A. Well, invitation is a pretext to get that person on to

Chinese soil. And while that person is there, they're being

sized up. They're confirming that they have the technology,

the information that they are looking for. They are looking

for the personality characteristics, the affinity to China,

if any, the existence of relatives in communist China. They

are wining and dining them. They are playing to their ego.

They are flattering them. They are holding out the

opportunity for a continuing positive relationship. And

they are just looking for any indication that this person is

a good follow-on target.

MR. MANGAN: All right. We can take that down.

BY MR. MANGAN:

Q. Mr. Olson, did you review communications between Xu

Yanjun and a GE employee leading up to the arrest in April of

2018?

A. Yes, I did.

Q. And did you evaluate those communications in light of

your experience as an intelligence officer?

A. Yes, I analyzed it very carefully.

Q. Did you notice any aspects of the recruitment cycle in

that sequence?

A. Yes. By that stage they were far into development. He

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

42

was pushing for more and more sensitive technology. He was

building rapport.

Q. Let me go back to the beginning. Did you see --

Let's talk about the initial invitation through LinkedIn.

Where would that fit in the recruitment cycle?

A. That would be the end of the spotting process. Once

they saw his LinkedIn posting, that constituted spotting of

someone who potentially had good access that fit their

requirements. And then they would pursue it to try to get

that person to China for assessment and development.

Q. How about the use of the university person named Chen

Feng to extend the invitation?

A. That was quite typical of a Chinese intelligence

operation. They would use someone like Chen Feng as kind of

a front. He was a distinguished, knowledgeable person in

the aviation industry in China. I'm sure that the defendant

was flattered that someone of that level would take an

interest in him and would invite him to China.

But the longer-term purpose was, of course, to turn him

over, turn the GE engineer over to an intelligence officer.

MR. MANGAN: If we could show Exhibit 63b, which has

been previously admitted, Your Honor.

THE COURT: Yes. You can show it to everyone.

BY MR. MANGAN:

Q. With respect to this business card, did you see this

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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previously, Mr. Olson?

A. Yes, I saw that.

Q. All right. I think previously we talked about the

science and technology associations?

A. Yes.

Q. How would this be consistent with the use of aliases or

cover companies?

A. It's very consistent with the cover used by an

intelligence officer. It sounds prestigious. It gives him

reason to be pursuing someone in the aviation industry.

Q. All right. In the follow-on communications, there were

emails and there were WeChats using a couple different

handles.

A. Yes.

Q. What significance, if any, did you attribute to those

modes of communication?

A. They were very characteristic of an intelligence

operation. Intelligence officer will use email, phone

calls, messaging services like WeChat routinely in their

communications with their -- their target.

Q. All right. After the initial visit, what would be the

typical step in terms of a subsequent visit or what the goals

are for the case officer?

A. If the pretext visit, the invitation for the lecture,

for the consulting is encouraging --

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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MR. McBRIDE: Your Honor?

THE COURT: Yes.

MR. McBRIDE: Objection. This is really getting

into speculation.

THE COURT: It's overruled. Subject to cross.

You may reask the question, or he can answer it if he

remembers it.

BY MR. MANGAN:

Q. Are you able to continue with your answer?

A. I can continue.

If the results of that pretext visit are encouraging

and they think that they have potential for someone with

access to maintain a relationship with, they will follow up.

And the follow-up will be done by email, by phone calls, or

by WeChat.

MR. MANGAN: All right. If we could take this

exhibit down. I'd like to show Exhibit 69. If we could start

with the email on page 2.

This has previously been admitted, Your Honor.

THE COURT: And you wish to publish it?

MR. MANGAN: Yes, Your Honor.

THE COURT: Okay. Everybody can see it.

BY MR. MANGAN:

Q. All right. If we take a look at the bottom there, can

you see it, Mr. Olson?

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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A. Yes, I can.

Q. All right. And with respect to this particular email,

let me turn to the second sentence. And I'll read it. "Since

I am not the expert in this field, I want you to spend some

time to dialog with the experts in China for a more precise

connection.

Based on your experience as a case officer, what do

you -- how do you understand that?

A. Well, that is an important step in the recruitment

cycle. They want to sit this person down with true experts

in the field who can ask more direct questions, who can get

to the heart of the access that this person has, and to

continue a technical and personal assessment of the

individual.

Q. From an espionage tradecraft perspective, how are these

experts used by the case officer?

A. They are --

MR. McBRIDE: Objection.

THE COURT: Basis?

MR. McBRIDE: Your Honor, again, we're getting to

speculation, Your Honor.

THE COURT: Overruled.

THE WITNESS: They are an integral part of the

process. The Chinese intelligence services rely heavily on

experts in the different technologies as their collaborators

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

46

in this -- in this operation.

BY MR. MANGAN:

Q. We talked previously about trying -- for a case officer

to try to determine requirements.

A. Yes.

Q. Right? Would this be consistent with what you explained

earlier?

A. Yes, it's very consistent. The Chinese MSS system

requires the interaction with the aviation industry people,

for example, to provide them with the requirements for what

it is exactly they are looking for in the way of advanced

U.S. technology.

Q. If we look to the last sentence on that page, where it

says, "Also, attached file is some domestic requirements that

I know of. Can you take a look and let me know if you're

familiar with those?"

A. Yes.

Q. And what was your understanding from reading that

sentence?

A. My understanding was this is intelligence officer's

pressing, who is pushing for additional cooperation, wants

to see how the target will respond to that request.

MR. MANGAN: If I could turn to page 4, which is the

attachment that was discussed in the previous email.

BY MR. MANGAN:

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Q. In looking at the top there, Mr. Olson, do you see the

top sentence where it says, "Regarding the current development

situation and future development direction of foreign

countries' structural materials for fan rotor blades made from

composite materials."

Did you see any significance in the use of that phrase

"foreign countries"?

A. Yes. It meant that the objective was to obtain this

technology from foreign countries.

Q. All right. How consistent is this kind of list with the

type of requirements that you were discussing earlier that a

case officer might typically be pursuing?

MR. McBRIDE: Objection, Your Honor.

THE COURT: Excuse me. Objection.

MR. McBRIDE: This gentleman's not an expert on

aviation, Your Honor.

THE COURT: This is his opinion based on his

experience. The objection is overruled.

BY MR. MANGAN:

Q. Mr. Olson, how is -- is this consistent with the type of

requirements you were testifying about earlier?

A. Yes, it's consistent with what I believe an

intelligence service would have in the form of requirements.

Q. All right. And we talked earlier about the importance of

those requirements to the case officer's mission, correct?

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

48

A. Yes.

Q. Can you again explain to the jury how those requirements

fit into the steps that an officer takes?

A. Yes. An intelligence officer's working from these

requirements, and they guide all of his or her actions to

make certain that the espionage operations under way here is

responsive to what the country needs. And so for that

purpose you are paying close attention to the requirements

and you are issuing these requirements to the target to see

how that target will respond.

Q. All right.

MR. MANGAN: If we could take that exhibit down.

Your Honor, I'd like to publish Exhibit 70, please, which

has previously been admitted.

THE COURT: Yes, we'll publish it to all. Perhaps.

There it is.

MR. MANGAN: If we could turn to the second page.

BY MR. MANGAN:

Q. Mr. Olson, do you recall seeing emails where there was a

request for a directory of a computer?

A. Yes, I remember that.

Q. All right. And from your perspective as an experienced

case officer, what was your assessment of that request for a

computer directory?

A. My assessment was --

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

49

MR. McBRIDE: Objection. Lack of foundation, Your

Honor.

THE COURT: Overruled. His testimony's been the

foundation.

You may answer.

THE WITNESS: My assessment was this was a further

step in the process of determining how cooperative this

person's going to be, asking for a directory of something that

would be highly desirable for an intelligence service to find

out what files are existing in that company. And if he

complies with that, which he did, that was a very positive

indication that you are getting cooperation.

BY MR. MANGAN:

Q. All right. So if the directory is sent back to the case

officer, is this still -- are we still in the assessing phase

at that point?

A. Yes, you're still assessing but you are also trying to

strengthen the relationship and determine how cooperative

this person's going to be. So that is already into the

development phase as well.

MR. MANGAN: All right. If we could turn to -- if I

could publish Exhibit 67c, Your Honor, which was previously

admitted.

THE COURT: Yes.

MR. MANGAN: I'd like to turn to page 20.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

50

BY MR. MANGAN:

Q. Mr. Olson, did you read these WeChat communications that

went back and forth?

You can go further down.

A. Yes, I saw that.

Q. All right. So these communications are the first

communications after that directory was sent back?

A. Yes.

Q. From the case officer?

A. Yes.

Q. So from your perspective, what do these communications

indicate to you?

A. Indicates to me that the MSS is encouraged by what's

going on. They want to pursue it. They want to see how far

this person will go. They want to have a further meeting, a

personal meeting.

As an intelligence officer, I actually chuckled as the

last statement, "The U.S. is not in my plan." That, of

course, is consistent with my knowledge that the MSS does

not like to operate inside the United States without

diplomatic immunity.

Q. We talked earlier about the preference to invite

individuals to China and operate on their own home turf,

correct?

A. Yes.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

51

Q. In this, there is an indication about meeting in a

foreign country?

A. Yes.

Q. Does that indicate to you a change in this relationship

or at least a willing to take a different risk?

A. It's a definite advancement in the relationship. The

fact that they were willing to meet in another country

indicates that they had reason to believe that this was

going very, very well.

Q. I assume most of your career you were operating in a

foreign country, correct?

A. Yes.

Q. All right. If an officer is able to operate within their

own country, is that considerably safer for the officer?

A. Oh, absolutely.

Q. What type of precautions do you need to take if a case

officer is going to operate in a foreign country?

A. Without diplomatic immunity?

Q. Yes.

A. Extreme precautions. You would plan it very, very

carefully. You would be particular about which location it

was, what the circumstances of the meeting, where the

meeting was to take place, how you would communicate once

you got there. It would be meticulously planned.

MR. MANGAN: All right. If we could take this down.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Your Honor, I'd like to publish Exhibit 75b, which was

previously admitted.

THE COURT: Yes.

BY MR. MANGAN:

Q. Mr. Olson, do you recall repeat -- excuse me -- do you

recall reading a transcript of a phone recording with the GE

employee and the defendant?

A. Yes, I recall that message.

Q. All right. I'll move down in a few minutes to one of the

later pages, but with respect to the discussion about personal

items, such as family matters or worklife, can you explain why

that is significant to a case officer?

A. It's standard MO for all of us in the intelligence

business. We want to know as much about this person as we

possibly can. We want to build a file. We want to know

everything we can about that person's family status,

employment, interests, everything we possibly can.

It's just part of our business. You never know what's

going to be useful later on. So you do everything you can

to assemble as much personal knowledge as you can about this

person.

Q. So when a case officer is talking to a potential agent

and they're talking about how work is going --

A. Yes.

Q. -- or just family issues or child care, is that different

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

53

from chitchat for an everyday person?

A. It's different from chitchat because there's a purpose

to it. What the case officer is doing is trying to build

rapport, a personal relationship with this agent, to build

some kind of friendship, some kind of a closeness on a

personal level, which will then facilitate their progress

and the professional side of the relationship.

MR. MANGAN: All right. If we could turn to page 7,

please. Towards the bottom half there.

BY MR. MANGAN:

Q. If you'll see the part starting with Mr. Qu, where it

says, "by the way, because you sent me a document list last

time," and he says, "we took a look. I think that that is

pretty good stuff. I wonder if it is convenient for you to

bring that stuff, this time to Europe, if you can bring that

stuff along."

And then the employee responds, "I for sure will bring my

computer with me."

What is the -- from the standpoint of a case officer in

the recruitment cycle, what is the significance of that kind

of ask?

MR. McBRIDE: Your Honor?

THE COURT: Yes.

MR. McBRIDE: Objection. May we have a sidebar?

THE COURT: Yes.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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(At sidebar.)

MR. McBRIDE: Sir, I understand that this man is an

expert and widely educated and very experienced, but I think

his testimony is really getting into the province of the jury

where he looks at some language that's in evidence and makes

an opinion about what this -- what our defendant is doing or

his co-conspirators are doing. That's really a fact for the

jury to determine. So I think it's excludable under 704(b),

Your Honor.

MR. MANGAN: Our response, Your Honor, is that we're

dealing with a different kind of case where we're talking

about espionage tradecraft. And this language and these steps

where they are asking for things or telling things have a

significance within the world of espionage, and that's why we

brought on an espionage tradecraft expert, to opine on the

significance.

THE COURT: Do you want a last word before I confer

with my law clerk?

MR. McBRIDE: Yes, sir.

THE COURT: Okay.

MR. McBRIDE: I understand what the government is

doing and that they are certainly allowed to lay out espionage

techniques and how spies operate. That will all be subject to

cross-examination. However, I think they are going a step too

far where this gentleman is saying this is an indication that

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

55

this defendant is doing A, B, and C, or X, Y, and Z. I think

that remains the province of the jury, Your Honor.

THE COURT: Very well. If you will give me a

moment.

MR. McBRIDE: Yes, sir.

(Pause.)

THE COURT: I just wanted to check with my law clerk

to confirm my visceral reaction.

The objection is overruled. He's not testifying to

ultimate facts. He's laying out his opinion based on his

experience, and I find it acceptable.

Your objection is of record and overruled.

MR. McBRIDE: Thank you for hearing me, Your Honor.

THE COURT: Very well.

(In open court.)

THE COURT: You may proceed.

MR. MANGAN: Yes. If we could bring that exhibit

back up, please.

BY MR. MANGAN:

Q. Mr. Olson, if you recall, we were talking about this

discussion related to bringing the computer to Europe. Do you

recall that?

A. Yes.

Q. And based on your experience and the recruitment cycle we

discussed previously, what is your assessment of this?

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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A. I assess this as moving into the producing stage.

They've already been producing documents. And I see here a

case officer, in my opinion, from China who is increasingly

aggressive, pushing for the additional stuff, to bring the

computer. I think that he's very encouraged by how this is

going. He has a -- an agent, potential agent who he thinks

is going to be very compliant. So this is a very nice step

for him.

THE COURT: What happened to your volume?

THE WITNESS: Excuse me, sir?

THE COURT: What happened to your volume? Will you

speak up?

THE WITNESS: I will speak up.

BY MR. MANGAN:

Q. You can pull that a little closer.

A. I've got it.

MR. MANGAN: If we can turn in this exhibit to page

12. About midway down.

BY MR. MANGAN:

Q. There's a statement in the middle there, Mr. Olson, where

it says, "All right. We really don't need to rush to do

everything in one time, because, if we are going to do

business together, this won't be the last time, right?"

A. Yes.

Q. All right. And how is that indicative of the recruitment

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

57

cycle in espionage work?

A. It's very significant.

Q. Can you explain to the jury why?

A. It's significant because we, as case officers, always

want to have a long-term relationship with our agents, with

our sources. We don't want a one-time hit. We want to see

this thing continue. And so right from the beginning of the

relationship the case officer will be looking for every

opportunity to reinforce the fact that you and I are going

to work together for an extended period.

This is Case Officer 101, as far as I was concerned.

MR. MANGAN: Thank you. If we could take that

exhibit down.

Your Honor, I'd like to publish Exhibit 67c, which has

previously been admitted.

THE COURT: Yes.

MR. MANGAN: And if we could turn to pages 33. If

we could go midway down. Further down, please.

BY MR. MANGAN:

Q. Mr. Olson, do you recall an exchange about whether or not

the company -- whether or not those company documents would be

able to be downloaded and viewed back in China?

A. Yes.

MR. MANGAN: All right. And then if we could turn

to page -- the top of page 34, please. And further down.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Thank you.

BY MR. MANGAN:

Q. Part way down there, sir, do you see the question,

"Regarding the document directly you sent last time, is it

possible to dump it to a portable hard drive or USB drive from

work computer in advance?"

A. Yes, I saw that.

Q. And in your professional assessment and experience, what

is your assessment of this particular request?

A. I see that very consistent with a case officer's effort

to maximize the production.

Case officers, all of us love downloads because you can

get access to a lot of information that way.

MR. MANGAN: If we could turn to page 36. About

midway down.

BY MR. MANGAN:

Q. You mentioned case officers like downloads. You see the

statement there on March 10, 2018?

A. Yes, I see it.

Q. That states, "Since there's still more time, download

more data and bring them. Anything design related will would

work."

A. Yes.

Q. Explain to the jury what you mean by, you know, how case

agents love downloads. Why is that significant?

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

59

A. It's significant because it's a very efficient way to

acquire a lot of information safely and quickly. It's the

new era of spying. It used to be that we had small

quantities of paper documents, and the new age is spying

with downloads with databases. You can get the entire

store. You can empty out the database of everything you're

interested in.

So it is something that all case officers push for

early on in the relationship. Let's get things downloaded.

Bring them out in disk. Do you have access to your

computer? Can you download it? It's a standard practice by

all case officers.

MR. MANGAN: Thank you. We can take this exhibit

down.

BY MR. MANGAN:

Q. Let me turn to -- before we turn to the actual visit in

Belgium, as far as the process of traveling into another

country to do an intelligence operation -- we talked about

sort of the risks and the precautions that you need to take.

A. Yes.

Q. In traveling into a new or a foreign country, would a

case officer use an alias or could they travel in true name?

A. You could do it either way. Sometimes a true name is

easier and safer because it's so well backstopped. It

depends on the security procedures, how deep your cover is.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

60

But in any case, even if you go in in true name, you

are going to assume an alias for operational purposes once

you get into that country.

Q. Okay. Is it possible to travel in true name but using an

employment cover?

A. Yes, yes.

Q. Did you review some of the documents related to a company

called Nanjing Luote?

A. Yes.

Q. When traveling oversees for an operation, are there

certain steps that case officers need to take to make sure

everyone knows each other's cover story?

A. Yes.

Q. And how does that work?

A. You want to make certain that you are sufficiently

briefed on your cover company and who the officers are and

what the mission of that cover company is. Because you're

not actually doing that work. It is all fiction. And so

you want to make certain that you are at least sufficiently

conversant with the activities and the personnel of that

company to withstand kind of first-level questioning.

Q. And is that information conveyed verbally or in writing?

How is that often done?

A. In my experience, we always did that by memorizing it

before we went. But I suppose you could also have some kind

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

61

of company documentation with you to refresh your memory.

MR. MANGAN: Your Honor, if we could publish Exhibit

56b?

THE COURT: Yes.

MR. MANGAN: Which has previously been admitted.

BY MR. MANGAN:

Q. Did you see this previously, Mr. Olson?

A. Yes, I did.

Q. And based on your experience, did this relate to the

discussion we just had about background information for a

cover?

A. Yes. In my opinion, this was a pre-briefing document,

operational preparation for someone who was traveling to

Europe. It listed specific questions on the next page that

related to various countries. It's a kind of -- we would

call it a gouge. Kind of an overview of the cover company

that you would then be able to use to withstand kind of a

first level of questioning.

Q. So what is a gouge, and how do you spell that?

A. G-O-U-G-E. That's slang in the intelligence business.

It is a short operational briefing paper or statement that

gives you kind of useful information that you may be called

upon to -- to use.

Q. All right.

MR. MANGAN: Thank you. If we could take this down.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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BY MR. MANGAN:

Q. Mr. Olson, I believe you saw some of the communications

back and forth about which country --

A. Yes.

Q. -- they would meet in. What is the significance to a

case officer of moving a meeting place from one country to

another?

A. You move it to one country to another if you have some

kind of concerns about the security in that country. You

want to make certain that you are meeting in a country where

you are comfortable, where the security forces are not

likely to be a problem for you. You're always assessing the

risk factors in various countries, and I think that was what

was going on here.

Q. All right. Let's talk about the actual meeting in

Brussels, Belgium, and some of the items that were found.

A. Yes.

Q. Based on what you reviewed, did you observe any aspects

of tradecrafts specific to that meeting?

A. It was tradecraft across the board. The case officer

was planning a meeting very, very carefully. He was quite

interested in where the meetings were to take place -- a

cafe in the hotel, whether or not the employees, associates,

colleagues would be in a position to observe the fact that

they were together.

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

63

Yeah, it was very, very systematic, and they were

preparing it as an operational meeting.

Q. In terms of the target or the agent pushing for a

different meeting location, does that create operational

problems for a case officer?

A. It could, depending on which country it's being moved

to. But if you're comfortable with that other country and

you are eager to meet, as I think was the case here, you

would probably accede to the convenience, the professional

requirements of the agent.

Q. All right. Does the presence of the envelopes of cash

have any significance to you in your assessment?

A. Yes, it does.

Q. How's that?

A. Very significant. A case officer is very eager to get

the recruit to accept cash, to accept money, because that

compromises the agent and it establishes a complicity

between the two of them. It makes it harder for that person

to back away later on. So we always try to get our agents

to accept money.

Q. When you have that situation and an agent turns over

secret information in exchange for cash, does the nature of

the relationship change?

A. By then it's very clear to both parties what's going

on, and the agent realizes that he is selling information

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

64

for money.

Q. There were -- I believe you saw some of the records

relating to the fact that each individual who was arrested had

two different phones.

A. Yes.

Q. How would phones typically be handled with respect to an

intelligence operation?

A. When you're operational overseas, you would have phones

for different purposes, and I think that was what I would

interpret was going on here. If the case officers had more

than one phone, they had designated them for specific

purposes.

Q. Before an operation, are steps taken to clean those

devices or remove some history on them?

A. They should, yes.

Q. All right. To the extent there is the use of code names

for individuals, you know, not their real names but names like

Tom or Jerry, is that ever used in intelligence operations?

A. Almost always.

Q. Always?

A. Yes.

Q. All right. Are these related to your aliases, or are

these completely different names?

A. They can be randomly chosen, but you don't want to use

true names or even your alias names in most cases on any

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

65

kind of an operational phone call.

Q. All right. And are these for communications within the

intelligence team?

A. Yes.

Q. All right. Now, I believe you saw the information

related to photos of the GE employee's family?

A. Yes.

Q. From your assessment as someone who's worked as a case

officer, why would a case officer want that type of

information?

A. A case officer would want that kind of information

because it contributes to your knowledge of this person from

a personal standpoint. As I said earlier, you want to

really know everything you can about this person, and family

is extremely important in your dealings with this -- with

this agent because you may have a position -- have the

opportunity to call upon loyalty concerns about the family

later on to increase the relationship.

Q. All right. Are there multiple uses for that kind of

information?

A. There could be. I could conceive of a situation where

you would use personal information like that just to remind

the agent of how much you know about him, how deep this

relationship is already becoming. I could see that it could

even be used potentially for some kind of subtle

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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intimidation. I think that would probably not be a wise

move for a case officer, but it's possible.

Q. Regardless of how it's used, is this the type of

information a case officer would want to gather and have?

A. You would scrub everything you could to get as much

information about the agent, including photographs, as you

possibly can.

Q. All right. What about the things like the laptops and

the storage devices that were recovered, what did that

indicate to you?

A. They could have been used for spy purposes. They could

have had uses for downloading. They could have been used

for communications among themselves. They might have had

documents there they wanted to refer to. A lot of multiple

reasons you would want that with respect to a spy.

Q. With respect to the phone, you are aware of one of the

phones being wiped, correct?

A. Yes.

Q. From your standpoint, in terms of an intelligence

operation, why would someone want to wipe a phone afterwards?

A. You would want to wipe a phone because it has

incriminating information on it. It's got communications,

it's got data that you don't want the adversary to see. So

whenever possible you would wipe your phone.

Q. And would that be indicative of espionage tradecraft?

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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A. Yes.

MR. MANGAN: I'd also like to publish, if I could,

Your Honor, Exhibit 6f.

THE COURT: It's been admitted?

MR. MANGAN: It has, Your Honor. Yes, I'm sorry.

THE COURT: Yes, you may.

MR. MANGAN: If we could turn to the next page. We

will start at the top half.

BY MR. MANGAN:

Q. Do you recall seeing this letter that was on one of the

phones in Belgium?

A. Yes, I do.

Q. And based on your experience, do you see indications of

espionage tradecraft with respect to this list?

A. Yes, I do. In fact, I smiled when I saw that. The

Chinese are using questionnaires similar to the ones that we

use where you want to know everything you can about

biographical information, family information, interests,

personality. This is quite typical.

Q. If we walk through this, if you can explain to the jury

sort of, you know, what is this -- you said this is typical of

a list that you would have used in the CIA?

A. Yes.

Q. All right. And have you trained people on this kind

of -- this list of questions?

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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A. Right. It's expected of a case officer when you have a

relationship with an agent to have obtained all of this

information, this personal biographic information, so that

it's included in the front part of the file.

Q. So the first two topics cover family situation and work

situation. Why is that information important to a case

officer?

A. You want to understand the work situation because

that's where your agent is going to be able to provide the

information, the technology you are looking for. If you

want to understand exactly what the employment status is,

you would also want to know the wife's employment status

because that could figure in in some way in the future as

well.

Q. If we look under Number 1 in that second line, it talks

about family finance, living expenses, and economical or other

pressures/difficulties.

A. Yes.

Q. For a case officer, why are financial difficulties for a

potential agent significant?

A. That's significant because if you have an agent who has

financial problems, the incentive for that person to accept

money from you to deal with those problems can be increased

greatly.

This is something that a case officer likes to see. He

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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likes to see someone who needs money because if you can

provide that money, in many cases the person will agree to

cooperate.

Q. I mean, to put this in blunt terms, I mean, was part of

your job as a case officer to exploit these kinds of

difficulties?

A. Yes.

Q. All right. If we could turn to the work situation.

Going down a couple lines where it talks about -- the very

last part of the third line, where it says, "whether the job

is secure." Do you see that?

A. Yes.

Q. All right. Does that fit into the same kind of analysis

you just mentioned?

A. Yes. And in other transcripts, I saw kind of a

preoccupation by the case officer about whether or not the

employment at GE is secure, because if not, this is no

longer worthwhile. So you're hoping that this person has

stable employment, will be there for a long time, his

relationship will be profitable for an extended period of

time.

MR. MANGAN: All right. If we could scroll down a

little further. A little bit further.

BY MR. MANGAN:

Q. So there's a section called "Information. What else do

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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we know?"

And then the next one is called "Personal needs." Do you

see that?

A. Yes.

Q. And then it goes through a few different -- a few

different topics.

When it goes through things like, at the very bottom,

"How to contact, how's the working environment, the actual

operating procedure, who treats" you know, what do those

statements mean to you?

A. That is providing guidance on how you will interact

with the agent, whether you will use a formal relationship

or you will make it more relaxed. How do you address the

person. Who pays for your meals, other expenses like that.

All very standard for establishing what kind of relationship

you're going to have with this person.

MR. MANGAN: If we could take that down.

BY MR. MANGAN:

Q. So, Mr. Olson, have you looked at the information

relating to this GE employee and these events?

A. Yes.

Q. Did you see aspects of espionage tradecraft in that

cycle?

A. Yes, I did. In fact, the conversations and the actions

of this individual are those of an intelligence officer

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OLSON - DIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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conducting espionage. I had no question about that at all.

MR. MANGAN: One moment, Your Honor.

THE COURT: Very well.

(Pause.)

MR. MANGAN: No further questions.

THE COURT: Very well.

Mr. McBride, do you want to launch now or do you have

another proposal?

MR. McBRIDE: Your Honor, this might be a great time

for a break, or do you want to break for the day, Your Honor?

THE COURT: You are not going to trap me.

MR. McBRIDE: No, sir.

THE COURT: But maybe. If it would help you for a

break, we'll break for 15 minutes and figure out where we are,

get the juice flowing in the jurors. They have had a long

day.

We are going to break for 15 minutes, send you upstairs,

and then we will ask you to come back. During the break, take

a break. Don't discuss the case among yourselves or with

anyone else. No independent research. Continue to keep an

open mind.

We will rise for you as you leave for 15 minutes.

THE COURTROOM DEPUTY: All rise for the jury.

(Jury out at 3:48 p.m.)

THE COURT: The jury's left the room. The door is

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OLSON - DIRECT (Mangan)

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closing. You may all be seated.

From my perspective, this is a natural break. We are

coming up on 4:30. But you all know better than I where you

are in the case.

Is the cross-examination likely to be extensive or not?

MR. McBRIDE: Your Honor, I think I can get it done

in a half an hour, 40 minutes at the most.

THE COURT: From the government's perspective, you'd

just as soon plunge ahead; is that right?

MR. MANGAN: We would, Your Honor.

THE COURT: Do you have more witnesses after this

one?

MR. MANGAN: We do not.

THE COURT: I'm sorry we took a break. We'll be

back at 4:05, and I am going to rely on you.

We are in recess until that time.

THE COURTROOM DEPUTY: All rise. The court is now

in recess.

(Recess from 3:49 p.m. until 4:04 p.m.)

THE COURT: Remain seated. Court's in session, back

in session.

Are we ready for the jury from the government's

perspective?

MR. MANGAN: Yes, Your Honor.

THE COURT: From the defense as well?

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OLSON - CROSS (McBride)

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MR. McBRIDE: Yes, Your Honor.

THE COURT: Let's get the jury.

THE COURTROOM DEPUTY: All rise for the jury.

(Jury in at 4:05 p.m.)

THE COURT: Please be seated.

15 jurors have rejoined us. Welcome back, jurors.

I want to push ahead. The defense has an opportunity to

ask questions of this witness, and perhaps the government a

few questions. I may have to keep you a little after 4:30,

and by that I mean a little.

Can anybody not abide with that?

(No response.)

THE COURT: Very well. Mr. McBride, you may

proceed.

The witness remains under oath.

MR. McBRIDE: Thank you, Your Honor.

CROSS-EXAMINATION

BY MR. McBRIDE:

Q. Good afternoon, Mr. Olson. My name is Bob McBride. I

represent Mr. Xu, along with my colleagues.

A. Good afternoon.

Q. Good afternoon. I want to ask you some questions about

your testimony, if I may.

When did you leave active service as a case officer?

A. In 1999.

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Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Q. And then I understand roughly you went to CIA

headquarters?

A. Yes.

Q. When did you leave CIA headquarters, sir?

A. I left in 1998.

Q. All right. I believe you told us that you felt you were

a case -- or you were a case officer beyond that date,

correct, sir?

A. Yes. I still had some operational responsibilities.

Q. When you became a professor at your current position, you

had to come out from undercover, correct?

A. Yes, sir.

Q. So you were undercover for approximately 32 years?

A. Yes, sir.

Q. You mentioned that your parents didn't know you were

undercover?

A. That's right.

Q. 32 years they didn't know?

A. They didn't know.

Q. And your children, they didn't know either?

A. They did not know.

Q. Except for the one time that your children and you became

under threat and you let your 17-year-old know, correct?

A. Yes. And we were in Vienna.

Q. What countries did you operate in?

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A. I operated in Russia and in Austria and in Mexico.

Q. And who was the primary enemy at that time?

A. Our number one adversary during the Cold War was

Russia.

Q. Would you agree with me that Russia culturally is much

more like the United States than is China?

A. I would probably agree with that, although the Russian

culture is distinctly different from ours.

Q. Understood. You testified today about your opinions

related to the evidence that you saw, correct, sir?

A. Yes.

Q. And those opinions were based only on the evidence that

was provided to you, sir, correct?

A. And on my training and experience, yes.

Q. You applied your training and experience only to the

evidence that was presented to you by the government, correct,

sir?

A. Yes.

Q. You didn't read any outside sources on China and China

espionage, did you?

A. I do that routinely in my duties as a professor.

Q. But not for this case, correct?

A. No, sir.

Q. I think you testified that -- and correct me if I'm

wrong -- that the evidence that you saw was consistent with

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the early phases of the development?

A. Yes.

Q. The recruitment cycle?

A. Yes.

Q. And tell me again what that was, sir. What was the --

what was that that you saw, sir, that made you think that?

A. I saw the classic recruitment cycle used by

intelligence services, including the MSS, to spot targets

and then to assess them, to develop them, and then to enter

into a productive relationship.

Q. Yes, sir, I understand that. What was it in the

development phase that you looked that made you think they

were developing this man as a spy?

A. I saw the case officer pushing for more and more

production. I saw him trying to build a personal and

professional relationship.

Q. Sir, you don't know that this man is a case officer, do

you? That's simply your opinion.

A. It is not my opinion. I saw his admissions in the

transcripts that he is an MSS officer.

Q. That doesn't mean he is a case officer, does it, sir?

A. He is a case officer. He is an operator.

Q. Sir, nowhere in the evidence it says he's a case officer,

does it?

A. The entire pattern of his behavior tells me, based on

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my experience, that he is an MSS case officer.

Q. Well, I want to talk about that pattern of behavior.

So I think you told us that spotting in this case

happened via LinkedIn, correct?

A. That was probably the initial spotting.

Q. So LinkedIn is used for a variety of other purposes, is

it not?

A. It can be.

Q. One of the purposes is to advertise your professional

credentials, correct?

A. Yes.

Q. Perhaps to get a new job, correct?

A. Yes.

Q. Perhaps to get -- build your network of people, correct?

A. It could be.

Q. You could also use it if you wanted to identify somebody

in your own profession, correct?

A. Yes.

Q. Or if you were looking for an expert in another field,

correct?

A. Could be.

Q. For example, an expert witness, correct?

A. Yes.

Q. Such as you are today, correct?

A. Yes.

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Q. And that would be a typical use of LinkedIn, would it

not?

A. Yes.

Q. And that's completely indistinguishable from the contact

that was made through LinkedIn in this case; is it not?

A. The use of LinkedIn in this case was for intelligence

spotting purposes.

Q. Sir, you don't know what it was for in this case. You

have an opinion, correct?

A. I have a professional opinion based on my knowledge of

how Chinese intelligence services operate, and LinkedIn is a

standard spotting mechanism for the MSS.

Q. But you don't really know what they were doing, do you?

A. It's transparent to me what was going on.

Q. So for all you know, Chen Feng is a legitimate professor

or -- correct, with NUAA?

A. Yes, I --

Q. And NUAA -- I'm sorry. I didn't mean to cut you off,

sir.

A. Yes, I believe he is.

Q. And so NUAA is, of course, a legitimate organization; is

it not?

A. Yes.

Q. A well-respected science and technology university in

China, correct?

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A. Correct.

Q. And there is -- we in America have well-respected science

and technology universities here, correct?

A. Yes.

Q. And those universities conduct exchanges with other

academics and professionals, do they not?

A. Yes. Quite often.

Q. So in all perspectives, the invite to China of Dr. Zheng

was in all respects exactly the same as any other exchange,

professional exchange?

A. No. It was different because it was an ulterior

motive. It was an intelligence operation to bring that

person to China for intelligence purposes.

Q. Sir, you don't know that there is an ulterior motive

here.

A. I know how the MSS operates, and this is a common

practice.

Q. How do you know -- well, let me talk about how you know

how the MSS operates. How many bureaus does the MSS have?

A. I cannot tell you.

Q. Do you know what JSSD is?

A. Yes.

Q. What is it?

A. It is the Jiangsu Science and Technology Association.

Q. Where is that located?

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A. I believe it's in Nanjing.

Q. Do you know how many people are employed by that

organization?

A. No, I do not.

Q. Do you know how many people are employed by MSS?

A. No, I do not.

Q. Do you know whether --

A. But I --

Q. I'm sorry. I thought there was an objection. My

apologies.

Do you know whether everybody that's employed by MSS is

an agent?

A. I do not know that.

Q. Do you know whether there are -- part of their mission is

to collect open-source information?

A. I know that all intelligence services do that.

Q. And intelligence is really a collection and analysis of

just information; is it not?

A. It's not a collection of just information. It's a

collection of secrets and controlled information.

Q. Sometimes, sir, correct?

A. Always, in my experience.

Q. Always, in you your experience, but not necessarily in

China, correct?

A. Chinese services also operate the way we do. They use

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their intelligence services, and particularly their case

officers, to collect not publicly available information.

Q. Sir, what kind of training do MSS officers have?

A. I don't know specifically because that's confidential,

but I assume it's very rigorous. Similar to ours, I would

guess.

Q. So you don't know what their initial training phase is?

A. No.

Q. And you don't know what kind of spycraft they are taught?

A. No, I do know what kind of spycraft they use, so I

assume that's what they were taught.

Q. My question was, you don't know how they're trained, do

you?

A. No.

Q. Okay. And you don't know who trains them, do you?

A. That's not publicly available.

Q. You know also that the PLA has a large intelligencegathering organization, correct?

A. Yes.

Q. You know also that China has significant institutes that

collect open-source information, correct?

A. Yes.

Q. And, in fact, China's evaluation of open-source

information is quite institutionalized; is it not?

A. I would assume so.

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Q. You don't know?

A. No.

Q. You would agree with me that China is behind us in

science and technology, correct?

A. Would you repeat that?

Q. Do you agree that China is behind us in science and

technology generally?

A. Generally behind us?

Q. Yes.

A. Yes.

Q. And also in aviation. Would you agree with that?

A. Yes.

Q. And that to catch up with aviation areas, they are using

American companies to provide products for them?

A. Yes.

Q. What are your concerns about technology transfers that

are perfectly legal?

A. I think that those are positive. It's commercial.

It's business. It's open. As long as the technology in

question is not trade secret or controlled technology.

Q. So it's okay to do an academic exchange where no secrets

are released; is that correct?

A. If there are no secrets, an academic exchange is

legitimate.

Q. Are you aware that in this case no secrets were released

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when Dr. Zheng went to China?

A. I don't know the substance of his lecture. I don't

know how much information he contributed. But I do know

that it was encouraging to the MSS because they followed up.

Q. So the government didn't tell you that no information --

no secrets were released at the NUAA lecture by Dr. Zheng?

A. No, I don't know what that information was.

Q. Did they tell you that Dr. Zheng took steps to make sure

he released no secret information?

A. No, I was not told that.

Q. I want to go back to this issue of information

development. So I believe you testified that operators -- I

want to make sure I get this wrong [sic], so if I get the

wrong terminology, please forgive me.

Case agents identify operators or agents to obtain

information their seniors want, correct?

A. Yes.

Q. And in our case, in the United States' case, it's the

President, correct?

A. We have a mechanism for consolidating requirements

through the national director of intelligence.

Q. But it comes from the top down, correct?

A. It comes from the executive branch primarily.

Q. All right. And in those cases, they are general requests

for information, correct?

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A. Not always. Some of them are very specific.

Q. How high up do they come from?

A. Any senior government official can solicit requirements

from the intelligence community, secret information that

that official believes would be useful for national

security.

Q. And in this case, there is no communications from any

national government that you have seen specifying information

to be asked for?

A. I know how the requirement process works, and it comes

from a lot of different bureaus and agencies of the United

States government. Many of them submit collection

requirements for the intelligence community.

Q. But in this case, there is no such evidence of that

coming from China, is there?

A. China operates differently.

Q. China operates differently. So does the MSS operate

differently or exactly the same way the CIA operates?

A. It operates differently. It lists its requirements

from experts in the different fields.

Q. Um-hmm. There are no names of experts in these fields

mentioned in any of the information you reviewed, was there?

A. No. They were just described as unidentified males.

Q. Um-hmm. You mention the use of multiple platforms for

communication as evidence of spycraft, correct?

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A. Yes.

Q. Do you have email?

A. Yes.

Q. Do you have text messages?

A. Yes.

Q. Do you use Instagram?

A. I do not.

Q. Do you have grandkids?

A. Yes.

Q. Do they use Instagram?

A. I don't know. I would guess they probably do.

Q. How about Twitter? Do you use Twitter?

A. I do not.

Q. I assume you don't use WeChat, correct?

A. I do not.

Q. All right. Do you have the same email address for work

as you do for home?

A. I have two email addresses.

Q. Are they the same?

A. No.

Q. So they have different names, correct?

A. Yes.

Q. Not just domain names, correct?

A. No.

Q. All right. Would you agree with me that it's not unusual

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in modern life for people to use more than one name on

platforms?

A. A name? You mean their personal name?

Q. Or identifier, sir. That was a bad question. Let me

rephrase it, if I may.

Is it not usual in modern life for people to use a

different identifier for themselves on different platforms?

A. Yes. Some email addresses are very creative and do not

have a name in it.

Q. So someone may use one identifier on an email address and

another one on an Instagram account, correct?

A. That could happen, yes.

Q. It could also happen that the one -- they would have a

different identifying -- identifier address on their Twitter

account than they would on their Instagram account, correct?

A. Yes.

Q. And does it stand to reason that the same thing could be

true for WeChat?

A. Yes.

Q. All right. And is it unusual today for people to use

email and text messages in communicating with each other?

A. No, it's not unusual.

Q. So that in and of itself is not indicative of spycraft,

is it?

A. That's right.

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Q. You talked about the photographs that were found during

the trip to Belgium. Do you remember that, sir?

A. Yes, I do.

Q. All right. Those photographs were on WeChat. Did you

know that?

A. Yes.

Q. And that -- did you know that Dr. Zheng had friended Chen

Feng and Qu Hui on WeChat?

A. Yes.

Q. You knew that?

A. Not specifically, but I assumed so.

Q. All right. And you know that people can download images

or photographs from WeChat, correct, sir?

A. Yes.

Q. That in and of itself is not indicative of tradecraft, is

it?

A. It's consistent of tradecraft for a case officer to

want to do that with the agent.

Q. But in and of itself it's not indicative of tradecraft,

is it?

A. Standing alone it might not be.

Q. Thank you. There was also $7,000 found in U.S. dollars

in Belgium; is that correct, sir?

A. Yes.

Q. And that money was never transferred to anybody, was it?

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A. No.

Q. It's not unusual for Chinese people to pay in U.S.

dollars, is it?

A. I don't know that.

Q. Okay. Does it stand to reason that one would spend

$7,000 to buy multimillion dollar technology?

A. No, it doesn't sound that that would be sufficient.

Q. Okay. You mentioned about the Safran incident. Do you

remember that, sir?

A. Yes, I do.

Q. China is a surveillance state, is it not?

A. Yes.

Q. All right. So if you're a company doing business in

China, it's likely that there's going to be some sort of

surveillance, correct?

A. It's almost certain.

Q. Almost certain.

Did you know that there is no evidence that the malware

searched for any files once it was in place?

A. I don't know how the malware was specifically used. I

just know it was implanted.

Q. All right. So the government didn't tell you that the

malware did not search for any particular files, correct?

MR. MANGAN: Objection.

THE COURT: Basis?

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Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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MR. MANGAN: Misleading, misstating the evidence.

THE COURT: Sustained as to form only.

BY MR. McBRIDE:

Q. Sir, did you know there was no evidence that the malware

extracted information from the computer?

MR. MANGAN: Objection. Same objection.

THE COURT: Sustained.

BY MR. McBRIDE:

Q. I want to go back one question for -- about MSS, sir.

You don't know what the Sixth Bureau does, do you?

A. No.

MR. McBRIDE: May I have a moment, Your Honor?

THE COURT: Yes.

MR. McBRIDE: I'm close to done.

(Pause.)

BY MR. McBRIDE:

Q. Sir, I've got your book Fair Play here.

A. Yes.

Q. I'd like to read you a couple of lines out of it if I

may, tell me if I read them correctly.

MR. MANGAN: Objection, Your Honor.

THE COURT: Basis?

MR. MANGAN: Hearsay, improper impeachment.

MR. McBRIDE: Your Honor, it's his book, his words.

Goes to his credibility.

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OLSON - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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THE COURT: I don't know how you are going to use

it. You may proceed.

BY MR. McBRIDE:

Q. Sir, you wrote this book Fair Play?

A. Yes, I did.

Q. And this is -- touches on the morality of spycraft?

A. Yes.

Q. All right. And in this book, don't you say that you

lied, cheated, and stole, misled people, et cetera, in service

of the United States?

A. Yes, I did.

Q. That was, in your mind, a noble cause?

A. Yes. I believed I was serving our country.

Q. Would a conviction here serve the intelligence

community's objectives?

MR. MANGAN: Objection.

THE COURT: Overruled.

You can answer the question.

THE WITNESS: It's hard for me to speculate on that.

I believe that Chinese espionage needs to be stopped. I

believe this would be a step in the right direction, because I

know spying when I see it, and this is spying. I believe that

a conviction would be -- in my opinion, it would be -- it

would be justice.

BY MR. McBRIDE:

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OLSON - REDIRECT (Mangan)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

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Q. So it's your testimony you know a spy when you see it?

A. Yes.

MR. McBRIDE: That's all I have, Your Honor. Thank

you.

THE COURT: Very well.

Redirect, if any.

REDIRECT EXAMINATION

BY MR. MANGAN:

Q. Mr. Olson, when you evaluated the information in this

case, did you rely on any one indicator or were you looking at

a collection of indicators to form your opinion?

A. In counterintelligence, we don't look at single

incidents, we look at the incidents in their totality, we

look at the context, we look at the patterns, and then we

draw our conclusions.

I looked at the totality of the evidence in this case.

Q. And regarding exchanges in the initial presentation, does

the content of that initial presentation affect your opinion

that it's part of the assessment phase?

A. No.

Q. All right. Lastly, Mr. McBride asked you about the

things that you did in your career --

A. Yes.

Q. -- on behalf of the United States.

A. Yes.

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Q. You were taking risks, right?

A. Yes.

Q. And if you had been caught in a foreign country, there

would have been consequences?

MR. McBRIDE: Objection.

THE COURT: Overruled.

BY MR. MANGAN:

Q. Would there have been consequences?

A. Yes. It would have been severe. It's better not to

get caught.

MR. MANGAN: That's all I have, Your Honor.

THE COURT: Recross, if any.

RECROSS-EXAMINATION

BY MR. McBRIDE:

Q. If you had been caught in a country with an extradition

treaty for another country --

A. Yes.

Q. -- all right, and arrested, you could have been

extradited and sent to the country and prosecuted, right?

A. If there were an extradition treaty that applied to my

case, yes.

Q. All right. Did you avoid those countries of which there

were such extradition treaties?

A. If I had a mission in a foreign country where I did not

have diplomatic immunity, I accepted the risk.

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MR. McBRIDE: Thank you.

THE COURT: Sir, you have completed your testimony.

You are welcome to step down and leave.

(Proceedings reported but not transcribed.)

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OLSON - RECROSS (McBride)

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CERTIFICATE OF REPORTER

I, Mary A. Schweinhagen, Federal Official Realtime

Court Reporter, in and for the United States District Court

for the Southern District of Ohio, do hereby certify that

pursuant to Section 753, Title 28, United States Code that the

foregoing is a true and correct transcript of the

stenographically reported proceedings held in the

above-entitled matter and that the transcript page format is

in conformance with the regulations of the Judicial Conference

of the United States.

s/Mary A. Schweinhagen

__________________________________ 31st of October, 2021

MARY A. SCHWEINHAGEN, RDR, CRR

FEDERAL OFFICIAL COURT REPORTER

Case: 1:18-cr-00043-TSB Doc #: 166-1 Filed: 11/01/21 Page: 95 of 95 PAGEID #: 2467