Michael Avenatti sent this tweet Sunday, which is being characterized as cryptic.

Now if you consider what Avenatti said on Joy Reid’s show Saturday, it’s not quite so inscrutable.

“There’s another issue really hasn’t been touched on yet, and I think that this is going to be the next front of inquiry this next week.

So, shortly after the election, Michael Cohen goes and…forms a relationship with a very well–known law firm in Washington, DC, by the name of Patton Boggs. And Patton Boggs has a long history of lobbying and being involved between companies and the U.S. government. That’s a very unusual relationship to have been formed right after the election, because Michael Cohen is not your average Patton Boggs attorney.

I think some of us have experience with Patton Boggs. I know I do. It’s a very reputable law firm. Some of those people are highly educated usually, a lot of experience, exceptional attorneys. That’s a very unusual relationship. So, why did Patton Boggs and why did Michael Cohen come together, and what did Michael Cohen sell to Patton Boggs as it related to the idea that they were going to allow Michael Cohen to come to the law firm?

It’s pretty clear to me what he sold them. What he sold them was a book of clients. A book of corporations or individuals that had already retained him for access to the U.S. president.

That needs to be the next inquiry: What did Patton Boggs know, when did they know it, did they know that Michael Cohen was lobbying? Did they not know it? And if they knew about it, why didn’t they have Michael Cohen register as a lobbyist in connection with the work that he was doing? No one has really talked about that, but I think that needs to be inquired into.”

Lobbying 101

To meet the definition of a lobbyist, the law says a person must meet three criteria:

  • First, he or she must be getting paid by the client for their work.
  • Second, to be considered a lobbyist, he or she must make at least two contacts with government officials on behalf of the client. These contacts can be in the form of phone calls, emails or meetings, and they need not be to the same government official both times. So if one were to contact two different senators on behalf of a client, that would count as two contacts.
  • The third threshold is often the murkiest: In order to be acting as a lobbyist for a client, the act of contacting government officials must take up at least 20 percent of the overall work that person does for this particular client.

For example, if a lawyer were hired by a company to do a year’s worth of full-time legal work, and he or she happened to make two phone calls to lawmakers to discuss the client’s agenda during that year of work for the client, this would most likely not be considered lobbying, because it wouldn’t meet the 20 percent threshold.

What does make some kind of sense is that it was peculiar when Cohen was revealed to have only three clients, Trump, Broidy and Hannity. Now if he was lobbying for all these corporations, AT&T, Novartis, et al., they would be his clients. However, he isn’t a registered lobbyist and so what was Cohen’s role exactly? It seems like that’s what Robert Mueller and Michael Avenatti are both interested in knowing.

Additionally, Squire Patton Boggs has roots with yet another prominent Trump player, none other than Jared Kushner.

A Wall Street Journal report linked the lobbying firm with Jared Kushner’s family business and its efforts to seek wealthy Chinese investors through a government visa program and the Florida–based company U.S. Immigration Fund LLC, which was one of five clients Cohen brought to Squire Patton Boggs. U.S. Immigration Fund is the company that organized a trip to China where Kushner Co. officials could meet with wealthy investors desiring to immigrate, and in essence pay for a visa if they invested $500,000 in various real estate projects.

Clearly, Squire Patton Boggs is a key player. As Avenatti has promised, more will be revealed. Stay tuned.

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