(May 31, 2022)

Durham has remained at work into the Biden administration. He has brought three cases so far, though the one against Sussmann is the only to have reached trial. A former FBI lawyer, Kevin Clinesmith, was given probation after pleading guilty in 2020 to altering an email related to the surveillance of an ex-Trump campaign aide, and a Russian analyst who contributed to a dossier of Democratic-funded research into ties between Russia and Trump awaits trial on charges of lying to the FBI about his sources of information.