Trump-indictment-Fulton-County-Georgia

READ: Trump indictment in Fulton County, Georgia.
The fourth indictment against former president Donald Trump was released Monday. Trump and 18 others were criminally charged in Georgia in connection with efforts to overturn Joe Biden’s 2020 victory in the state.
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Trump Georgia Indictment ACT Overt ACT GEORGIA DONALD JOHN TRUMP STATE day
READ: Trump indictment in Fulton County, Georgia.
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Newswire Expert is your daily connection to the wire. Covering U.S. and International business, entertainment, technology and financial news releases.
Trump Georgia Indictment ACT Overt ACT GEORGIA DONALD JOHN TRUMP STATE day
66
Fulton County Superior Court
INDICTMENT
£375Mozzfee
**F|LED** CA
,
Date: August 14, 2023
Che Alexander, Clerk of Court
Clerk No.wqé/7
FULTON SUPERIOR COURT
THE STATE OF GEORGIA
V.
DONALD JOHN TRUMP
Couhts 1,5, 9, 11, 13, 15, 17, 19,
2729, 38-39
RUDOLPHWILLIAM LOUIS
GIULIANI
Counts 1-3, 6-7, 9,11,13,15,17,19,
23-24
JOHN CI-MRLES EASTMAN
Counts 1-2, 9, 11,13, 15, 17, 19, 27
MARK RANDALLMEADOWS
Counts 1, 28
KENNETH JOHN CHESEBRO
Counts 1, 9,11,13,15,17,19
JEFFREY BOSSERT CLARK
Counts 1, 22
JENNA LYNN ELLIS
Counts 12
RAY STALLINGS SNIITH III
Counts 1-2, 4, 6, 9, 11, 13,15, 17,19,
23, 25
ROBERT DAVID CHEELEY
Counts 1, 9,11,13, 15, 17,19, 23, 26,
41
MICHAEL A. ROMAN
Counts 1, 9, 11,13,15,17, 19
DAVID JAMES SHAFER
Counts 1, 8,10,12,14,16,18, 40
l0
11
VIOLATION OF THE GEORGIA RICO
(RACKETEER INFLUENCED AND CORRUPT
ORGANIZATIONS) ACT
O.C.G.A. § 16144(c)
1
SOLICITATION OF VIOLATION OF OATH
BY PUBLIC OFFICER
O.C.G.A. §§ 164-7 & 1640-1
2
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-10-20
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 1610-20
4
SOLICITATION OF VIOLATION OF OATH
BY PUBLIC OFFICER
O.C.G.A. §§ 16-47 & 16101
5
SOLICITATION OF VIOLATION OF OATH
BY PUBLIC OFFICER
O.C.G.A. §§ 164-7 & 1610-1
FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16102'0
7
IMPERSONATING A PUBLIC OFFICER
O.C.G.A. § 16-1023
CONSPIRACY TO COMMIT
INIPERSONATING A PUBLIC OFFICER
O.C.G.A. §§ 164-8 & 16-10-23
FORGERY IN THE FIRST DEGREE
O.C.G.A. § 169-1(b)
CONSPIRACY To COMMIT
FORGERY 1N THE FIRST DEGREE
O.C.G.A. §§ 16-48 & 16-9-1(b)
SHAWNMCAH TRESHER STILL
12 FALSE STATEMENTS AND WRITINGS
Counts 1, 8, 10, 12, 14, 16, 18
O.C.G.A. § 16-1020
STEPHEN CLIFFGARD LEE
13 CONSPIRACY TO COMlWIT
Counts 1, 20-21, 30-31
FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 1648 & 161020
HARRISONWILLIAM PRESCOTT
FLOYD
14 CRWAL ATTEMPT To COMMIT
Counts 1, 3031
Emma FALSE DOCUMENTS
O.C.G.A. §§ 1641 & 16102o.1(b)(1)
TREVIAN C. KUTTI
Counts 1, 3031
15 CONSPIRACY TO COMMIT
Emma FALSE DOCUMENTS
SIDNEY KATHERINE POWELL
O.C.G.A. §§ 164-8 & 16102o.1(b)(1)
Counts 1, 32-37
16 FORGERY IN THE FIRST DEGREE
CATHLEEN ALSTON LATHAM
O.C.G.A. § 16-9-1(b)
Counts 1, 8, 10, 12, 14, 32-37
17 CONSPIRACY TO COMMIT
SCOTT GRAHAM HALL
.
FORGERYm THE FIRST DEGREE
Counts 1, 32-37
O.C.G.A. §§ 16-48 & 1691(b)
MISTYHAMPTON
18 FALSE STATEMENTS ANDWRITINGS
AKA EMILYMISTYHAYES
O_C_G_A. § 16_10_20
Counts 1, 32-37
19 CONSPIRACY TO COMlVIIT
FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-8 & 16-10-20
20 CRIMINAL ATTEMPT TO COMMIT
INFLUENCING WITNESSES
O.C.G.A. §§ 16-41 & 161093(b)(1)(A)
21 CRIMINAL ATTEMPT TO COMMIT
INFLUENCUYG WITNESSES
O.C.G.A. §§ 16-4-1& 16-10-93(b)(1)(A)
22 CRIMINAL ATTEMPT TO COMMIT
FALSE STATEMENTS ANDmums
O.C.G.A. §§ 16-41 & 161020
23 SOLICITATION OF VIOLATION OF OATH
BY PUBLIC OFFICER
O.C.G.A. §§ 16-47 & 16-10-1
24 FALSE STATENIENTS AND WRITINGS
O.C.G.A. § 16-1020
25 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 161020
'
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
FILING FALSE DOCUMENTS
O.C.G.A. § 16-1020.1(b)(1)
SOLICITATION OF VIOLATION OF OATH
BY PUBLIC OFFICER
O.C.G.A. §§ 164-7 & 16-10-1
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-10-20
CONSPIRACY TO COMlVIIT SOLICITATION OF
FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-8, 16-4-7 & 16-10-20
INFLUENcmGWITNESSES
O.C.G.A. § 161093(b)(1)(A)
CONSPIRACY TO COMMIT ELECTION FRAUD
O.C.G.A. §§ 21-2603 & 21-2-566
CONSPIRACY TO CONIMIT ELECTION FRAUD
O.C.G.A. §§ 21-2-603 & 21-2-574
CONSPIRACY To COMMIT
COMPUTER THEFT
O.C.G.A. §§ 1648 & 16993(a)
CONSPIRACY TO COMlVIIT
COMPUTER TRESPASS
O.C.G.A. §§ 16-4-8 & 16-9-93(b)
CONSPIRACY TO COMIVIIT
COMPUTER INVASION OF PRIVACY
O.C.G.A. §§ 16-4-8 & 169-93(c)
CONSPIRACY TO DEFRAUD TIE STATE
O.C.G.A. § 16-1021
SOLICITATION OF VIOLATION OF OATH
BY PUBLIC OFFICER
O.C.G.A. §§ 16-47 & 16101
FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-1020
FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 161020
41 PERJURY
o.c.G.A. § 161070(a)
'Z
BILL
2023
5%
Jury Foreperson
FANI T.WILLIS, District Attorney
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STATE OF GEORGIA, COUNTY OF FULTON
IN THE SUPERIOR COURT OF SAID COUNTY
THE GRAND JURORS, selected, chosen, and sworn for the County of Fulton, to wit:
1. ROBERTWELLS, Foreperson
14. GREGORY PETRALIA
2. ASHLEY MELVIN, Asst. FP
15. JENNIFER PRICE
16. GEORGE PRINGLE
4. JULIA DECREDICO, Asst. Sec.
17. PAVAN PULAVARTY
5. ERLE ARNOLD
18. FRANEEN SARIF
6. DANIELLE BROWN
19. EMMA ST. JOHN
7. CAROL DICK
20. VLADIMIR TCHAKAROV
8. KATHY GOLD
21. CEDRIC TRICE
9. WILLIS HARDY
22. ESTHER UDOJI
10. BRENDA HART
23. MARCUS WELBORN
11. ANTIONETI'E HUDSON
12. lLE LIN
25. KATHLEEN CHEN
13. MAX MORTENSEN
9
COUNT 1:
COUNT 2:
COUNT 3:
COUNT 4:
COUNT 5:
COUNT 6:
COUNT 7:
COUNT 8:
COUNT 9:
COUNT 10:
COUNT 11:
COUNT 12:
COUNT l3:
TABLE OF CONTENTS
VIOLATION OF THE GEORGIA RICO
(RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS) ACT
O.C.G.A. § 16-14-4(c)
13
Introduction
14
The Enterprise
15
Manner and Methods of the Enterprise
16
Acts ofRacketeering Activity and Overt Acts in Furtherance of the
Conspiracy
20
SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1
72
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-10-20
72
FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
73
SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER,
O.C.G.A. §§ 164-7 & 16101
74
SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1
74
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-10-20
75
IMPERSONATING A PUBLIC OFFICER
O.C.G.A. § 1610-23
76
CONSPIRACY TO COMMIT IMPERSONATING A PUBLIC OFFICER
O.C.G.A. §§ 16-4-8 & 16-10-23
76
FORGERY IN THE FIRST DEGREE
O.C.G.A. § 16-9-1(b)
77
CONSPIRACY To COMMIT FORGERY IN THE FIRST DEGREE
O.C.G.A. §§ 1648 & 16-91(b)
77
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-1020
78
CONSPIRACY TO COMMIT FALSE STATEMENTS ANDWRITINGS
O.C.G.A. §§ 16-4-8 & 16-1020
78
10
COUNle
COUNTli
COUNT1&
COUNT1%
COUNT1&
COUNT 19
COUNTZm
COUNTZh
COUNT 22:
C0UNT2$
COUNTzm
'COUNT2&
COUNT2&
COUNTzn
COUNT 28:
CRIMINALATTEMPT To COMMIT FILING FALSE DOCUMENTS
0.C.G.A. §§ 164-1 & 16-1020.1(b)(1)
79
CONSPIRACY TO COMMIT FILING FALSE DOCUMENTS
O.C.G.A. §§ 16-4-8 & 16-10-20.1(b)(1)
79
FORGERY IN THE FIRST DEGREE
O.C.G.A. § 16-9-1(b)
80
CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE
O.C.G.A. §§ 16-48 & 16-91(b)
80
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-10-20
81
CONSPIRACY TO COMMIT FALSE STATEMENTS ANDWRITINGS
O.C.G.A. §§ 164-8 & 16-1020
81
CRIMINALATTEMPT TO COMMIT INFLUENCINGWITNESSES
O.C.G.A. §§ 1641 & 16-1093(b)(1)(A)
82
CRIMINALATTEMPT TO COMMIT INFLUENCINGWITNESSES
O.C.G.A. §§ 16-4-1 &16-10-93(b)(1)(A)
82
CRIMINALATTEMPT TO COMMIT
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. §§ 1641 & 161020
83
SOLICITATION OF VIOLATION OF OATHBY PUBLIC OFFICER
O.C.G.A. §§ 1647 & 16101
84
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-10-20
84
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 161020
>
85
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-10-20
85
FILING FALSE DOCUMENTS
O.C.G.A. § 161020.1(b)(1)
86
SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-47 & 1610-1
87
11
COUNT 29:
COUNT 30:
COUNT 31:
COUNT 32:
COUNT 33:
COUNT 34:
COUNT 35:
COUNT 36:
COUNT 37:
COUNT 38:
COUNT 39:
COUNT 40:
COUNT 41:
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-1020
CONSPIRACY TO COMMIT SOLICITATION OF
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. §§ 16-4-8, 16-4-7, & 1610-20
INFLUENCINGWITNESSES
O.C.G.A. § 1610-93(b)(1)(A)
CONSPIRACY TO COMMIT ELECTION FRAUD
O.C.G.A. §§ '21-2-603 & 21-2566
CONSPIRACY TO COMMIT ELECTION FRAUD
O.C.G.A. §§ 212603 & 21-2574
CONSPIRACY To COMMIT COMPUTER THEFT
O.C.G.A. §§ 16-4-8 & 16993(a)
CONSPIRACY TO COMMIT COMPUTER TRESPASS
O.C.G.A. §§ 1648 & 16-9-93(b)
CONSPIRACY TO COMMIT COMPUTER INVASION OF PRIVACY
O.C.G.A. §§ 16-4-8 & 16-9-93(c)
CONSPIRACY TO DEFRAUD THE STATE
O.C.G.A. § 16-10-21
SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 1610-1
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-10-20
FALSE STATEMENTS ANDWRITINGS
O.C.G.A. § 16-10-20
PERJURY
O.C.G.A. § 16-10-70(a)
12
88
89
89
90
91
92
93
94
95
95
96
96
97
COUNT 1 of 41
The Grand Jurors aforesaid, in the name and behalf of the citizens ofGeorgia, do hereby
charge and accuse:
DONALD JOHN TRUMP,
RUDOLPHWILLIAM LOUIS GIULIANI,
JOHN CHARLES EASTMAN,
MARK RANDALLMEADOWS,
KENNETH JOHN CI-IESEBRO,
JEFFREY BOSSERT CLARK,
JENNA LYNN ELLIS,
RAY STALLINGS SMITH III,
ROBERT DAVID CHEELEY,
MICHAELA. ROMAN,
DAVID JAMES SHAFER,
SHAWNMICAH TRESI-IER STILL,
STEPHEN CLIFFGARD LEE,
HARRISONWILLIAM PRESCOTT FLOYD,
TREVIAN C. KUTTI,
SIDNEY KATHERINE POWELL,
CATHLEENALSTON LATHAM,
SCOTT GRAHAMHALL, and
MISTY HAMPTON
with the offense ofVIOLATION OF TI-IE GEORGIA RICO (RACKETEER
INFLUENCED AND CORRUPT ORGANIZATIONS) ACT, O.C.G.A. § 16-14-4(c), for the
said accused, individually and as persons concerned in the commission of a crime, and together
with unindicted co-conspirators, in the State ofGeorgia and County of Fulton, on and between
the 4th day ofNovember 2020 and the 15th day of September 2022, while associated with an
enterprise, unlawfully conspired and endeavored to conduct and participate in, directly and
indirectly, such enterprise through a pattern of racketeering activity in violation ofO.C.G.A. §
16-14-4(b), as described below and incorporated by reference as iffillly set forth herein, contrary
to the laws of said State, the good order, peace, and dignity thereof;
l3
INTRODUCTION
Defendant Donald John Trump lost the United States presidential election held on
November 3, 2020. One of the states he lost was Georgia. Trump and the other Defendants
charged in this Indictment refused to accept that Trump lost, and they knowingly and willfully
joined a conspiracy to unlawfully change the outcome of the election in favor of Trump. That
conspiracy contained a common plan and purpose to commit two or more acts of racketeering
activity in Fulton County, Georgia, elsewhere in the State ofGeorgia, and in other states.
14
THE ENTERPRISE
At all times relevant to this Count of the Indictment, the Defendants, as well as others not
named as defendants, unlawfully conspired and endeavored to conduct and participate in a
criminal enterprise in Fulton County, Georgia, and elsewhere. Defendants Donald John Trump,
RudolphWilliam Louis Giuliani, John Charles Eastman, Mark Randall Meadows, Kenneth John
Chesebro, Jeffrey Bossert Clark, Jenna Lynn Ellis, Ray Stallings Smith III, Robert David
Cheeley, Michael A. Roman, David James Shafer, ShawnMicah Tresher Still, Stephen Cliffgard
Lee, HarrisonWilliam Prescott Floyd, Trevian C. Kutti, Sidney Katherine Powell, Cathleen
Alston Latham, Scott Graham Hall, Misty Hampton, unindicted co-conspirators Individual l
through Individual 30, and others known and unknown to the Grand Jury, constituted a criminal
organization whose members and associates engaged in various related criminal activities
including, but not limited to, false statements and writings, impersonating a public officer,
forgery, filing false documents, influencing witnesses, computer theft, computer trespass,
computer invasion ofprivacy, conspiracy to defraud the state, acts involving theft, and perjury.
This criminal organization constituted an enterprise as that term is defined in O.C.G.A. §
l6-14-3(3), that is, a group of individuals associated in fact. The Defendants and other members
and associates of the enterprise had connections and relationships with one another and with the
enterprise. 'The enterprise constituted an ongoing organization whose members and associates
functioned as a continuing unit for a common purpose of achieving the objectives of the
enterprise. The enterprise operated in Fulton County, Georgia, elsewhere in the State ofGeorgia,
in other states, including, but not limited to, Arizona, Michigan, Nevada, New Mexico,
Pennsylvania, and Wisconsin, and in the District of Columbia. The enterprise operated for a
period of time sufficient to permit its members and associates to pursue its objectives.
15
MANNER AND METHODS OF THE ENTERPRISE
The manner and methods used by the Defendants and other members and associates of
the enterprise to further the goals of the enterprise and to achieve its purposes included, but were
not limited to, the following:
1. False Statements to and Solicitation of State Legislatures
Members of the enterprise, including several of the Defendants, appeared at hearings in
Fulton County, Georgia, before members of the Georgia General Assembly on December 3,
2020, December 10, 2020, and December 30, 2020. At these hearings, members of the enterprise
made false statements concerning fraud in the November 3, 2020, presidential election. The
purpose of these false statements was to persuade Georgia legislators to reject lawfill electoral
votes cast by the duly elected and qualified presidential electors from Georgia. Members of the
enterprise corruptly solicited Georgia legislators instead to unlawfillly appoint their own
presidential electors for the purpose of casting electoral votes for Donald Trump. Members of the
enterprise also made false statements to state legislators during hearings and meetings in
Arizona, Michigan, and Pennsylvania in November and December 2020 to persuade legislators
in those states to unlawfillly appoint their own presidential electors.
2. False Statements to and Solicitation ofHighRanking State Officials
Members of the enterprise, including several of the Defendants, made false statements in
Fulton County and elsewhere in the State ofGeorgia to Georgia officials, including the
Governor, the Secretary cf State, and the Speaker of the House of Representatives. Members of
the enterprise also corruptly solicited Georgia officials, including the Secretary of State and the
Speaker of the House of Representatives, to violate their oaths to the Georgia Constitution and to
the United States Constitution by unlawfully changing the outcome of the November 3, 2020,
16
presidential election in Georgia in favor ofDonald Trump. Members of the enterprise also made
false statements to and solicited state officials in Arizona, Michigan, and Pennsylvania.
3. Creation and Distribution of False Electoral College Documents
Members of the enterprise, including several of the Defendants, created false Electoral
College documents and recruited individuals to convene and cast false Electoral College votes at
the Georgia State Capitol, in Fulton County, on December 14, 2020. After the false Electoral
College votes were cast, members of the enterprise transmitted the votes to the President of the
United States Senate, the Archivist of the United States, the Georgia Secretary of State, and the
Chief Judge of the United States District Court for the Northern District of Georgia. The false
documents were intended to disrupt and delay the joint session of Congress on January 6, 2021,
in order to unlawfully change the outcome of the November 3, 2020, presidential election in
favor ofDonald Trump. Similar schemes were executed by members of the enterprise in Arizona,
Michigan, Nevada, New Mexico, Pennsylvania, and Wisconsin.
4. Harassment and Intimidation of Fulton Countv ElectionWorker Rubv Freeman
Members of the enterprise, including several of the Defendants, falsely accused Fulton
County election worker Ruby Freeman of committing election crimes in Fulton County, Georgia.
These false accusations were repeated to Georgia legislators and other.Georgia officials in an
effort to persuade them to unlawfully change the outcome of the November 3, 2020, presidential
election in favor ofDonald Trump. In furtherance of this scheme, members of the enterprise
traveled from out of state to harass Freeman, intimidate her, and solicit her to falsely confess to
election crimes that she did not commit.
l7
5. Solicitation ofHigh-Ranking United States Department of Justice Officials
Members of the enterprise, including several of the Defendants, corruptly solicited high-
ranking United States Department of Justice officials to make false statements to government
officials in Fulton County, Georgia, including the Governor, the Speaker of the House of
Representatives, and the President Pro Tempore of the Senate. In one instance, Donald Trump
stated to the Acting United States Attorney General, "Just say that the election was corrupt, and
leave the rest to me and the Republican congressmen."
-
6. Solicitation of the Vice President of the United States
Members of the enterprise, including several of the Defendants, corruptly solicited the
Vice President of the United States to violate the United States Constitution and federal law by
unlawfiilly rejecting Electoral College votes cast in Fulton County, Georgia, by the duly elected
and qualified presidential electors fiom Georgia. Members of the enterprise also corruptly
solicited the Vice President to reject votes cast by the duly elected and qualified presidential
electors fiom several other states.
7._ Unlawful Breach of Election Equipment in Georgia and Elsewhere
Members of the enterprise, including several of the Defendants, corruptly conspired in
Fulton County, Georgia, and elsewhere to unlawfillly access secure voting equipment and voter
data. In Georgia, members of the enterprise stole data, including ballot images, voting equipment
software, and personal voter information. The stolen data was then distributed to other members
of the enterprise, including members in other states.
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8. Obstructive Acts in Furtherance of the Conspiracy and the Cover Up
Members of the enterprise, including several of the Defendants, filed false documents,
made false statements to government investigators, and committed perjury in judicial
proceedings in Fulton County, Georgia, and elsewhere in furtherance of and to cover up the
conspiracy.
l9
ACTS OF RACKETEERING ACTIVITYAND
OVERT ACTS IN FURTHERANCE OF THE CONSPIRACY
As part of and on behalf of the crimin'al enterprise detailed above, the Defendants and
othermembers and associates of the enterprise committed overt acts to efiect the objectives of
the enterprise, including but not limited to:
Act 1.
On or about the 4th day ofNovember 2020, DONALD JOHN TRUMP made a
nationally televised speech falsely declaring victory in the 2020 presidential election.
Approximately four days earlier, on or about October 31, 2020, DONALD JOHN TRUMP
discussed a draft speech with unindicted coconspirator Individual l, whose identity is known to
the Grand Jury, that falsely declared victory and falsely claimed voter fraud. The speech was an
overt act in furtherance of the conspiracy.
On or about the 15th day ofNovember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI placed a telephone call to unindicted co-conspirator Individual 2, whose identity is
known to the Grand Jury, and left an approximately 83-second-long voicemail message for
unindicted coconspirator Individual 2 making statements concerning fraud in the November 3,
2020, election in Fulton County, Georgia. This telephone call was an overt act in furtherance of
the conspiracy.
On or about the 19th day ofNovember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI, JENNA LYNN ELLIS, SIDNEY KATHERINE POWELL, and unindicted co-
conspirator Individual 3, whose identity is known to the Grand Jury, appeared at a press
conference at the Republican National Committee Headquarters on behalfofDONALD JOHN
TRUMP and Donald J. Trump for President, Inc. (the "Trump Campaign") and made false
statements concerning fraud in the November 3', 2020, presidential election in Georgia and
elsewhere. These were overt acts in furtherance of the conspiracy.
On or about the 20th day ofNovember 2020, DAVID JAMES SHAFER sent an e-mail
to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, and other
individuals. In the email, DAVID JAMES SHAFER stated that SCOTT GRAHAM HALL, a
Georgia bail bondsman, "has been looking into the election on behalfof the President at the
request ofDavid Bossie" and asked unindicted co-conspirator Individual 4 to exchange contact
information with SCOTT GRAHAM HALL and to "help him as needed." This was an overt act
in furtherance of the conspiracy.
20
Act 5.
On or about the 20th day ofNovember 2020, DONALD JOHN TRUNIP andMARK
RANDALLMEADOWS met with Majority Leader of the Michigan Senate Michael Shirkey,
Speaker of the Michigan House of Representatives Lee Chatfield, and other Michigan legislators
in the Oval Office at the White House, and DONALD JOHN TRUMP made false statements
concerning fiaud in the November 3, 2020, presidential election in Michigan. RUDOLPH
WILLIAM LOUIS GIULIANI joined the meeting by telephone. This meeting was an overt act
in furtherance of the conspiracy.
Act 6.
On or about the 21st day ofNovember 2020, MARK RANDALLMEADOWS sent a
text message to United States Representative Scott Perry from Pennsylvania and stated, "Can
you send me the number for the speaker and the leader ofPA Legislature. POTUS wants to chat
with them." This was an overt act in furtherance of the conspiracy.
Act 7.
On or about the 22nd day ofNovember 2020, DONALD JOHN TRUMP and
RUDOLPHWILLIAM LOUIS GIULIANI placed a telephone call to Speaker of the Arizona
House ofRepresentatives Russell "Rusty" Bowers. During the telephone call, RUDOLPH
WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3,
2020, presidential election in Arizona and solicited, requested, and importuned Bowers t0
unlawfiJlly appoint presidential electors from Arizona. Bowers declined and later testified to the
United States House of Representatives Select Committee to Investigate the January 6th Attack
on the United States Capitol that he told DONALD JOHN TRUMP, "I would not break my
oath." The false statements and solicitations were overt acts in furtherance of the conspiracy.
Act 8.
On or about the 25th day ofNovember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses at a meeting
ofPennsylvania legislators in Gettysburg, Pennsylvania. During the meeting, RUDOLPH
WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3,
2020, presidential election in Pennsylvania and solicited, requested, and importuned the
Pennsylvania legislators present at the meeting to unlawfully appoint presidential electors from
Pennsylvania. During the meeting, JENNA LYNN ELLIS solicited, requested, and importuned
the Pennsylvania legislators present at the meeting to unlawfully appoint presidential electors
from Pennsylvania. DONALD JOHN TRUMP joined the meeting by telephone, made false
statements concerning fiaud in the November 3, 2020, presidential election in Pennsylvania, and
solicited, requested, and importuned the Pennsylvania legislators present at the meeting to
unlawfully appoint presidential electors from Pennsylvania. These were overt acts in furtherance
of the conspiracy.
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Act 9.
On or about the 25th day ofNovember 2020, immediately after the meeting of
Pennsylvania legislators in Gettysburg, Pennsylvania, where RUDOLPHWILLIAM LOUIS
GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses, DONALD
JOHN TRUMP invited a group of the Pennsylvania legislators and others to meet with him at
the White House. Later that day, DONALD JOHN TRUMP,MARK RANDALL
MEADOWS, RUDOLPHWILLIAM LOUIS GIULIANI, JENNA LYNN ELLIS and
unindicted co-conspirators Individual 5 and Individual 6, whose identities are known to the
Grand Jury, met with the group ofPennsylvania legislators at the White House and discussed
holding a special session of the Pennsylvania General Assembly. These were overt acts in
flirtherance of the conspiracy.
Act 10.
On or about the 26th day ofNovember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI and JENNA LYNN ELLIS placed a telephone call to Speaker of the Pennsylvania
House ofRepresentatives Bryan Cutler and left Cutler a voicemail message for the purpose of
soliciting, requesting, and importuning him to unlawfully appoint presidential electors from
Pennsylvania. This was an overt act in furtherance of the conspiracy.
Act 11.
On or about the 26th day ofNovember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI placed a telephone call to President Pro Tempore of the Pennsylvania Senate Jacob
"Jake" Corman for the purpose of soliciting, requesting, and importuning Corman to unlawfully
appoint presidential electors fiom Pennsylvania. This was an overt act in furtherance of the
conspiracy.
'
'
Act 12.
On or about the 27th day ofNovember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI and JENNA LYNN ELLIS placed a telephone call to Speaker of the Pennsylvania
House ofRepresentatives Bryan Cutler and left Cutler a voicemail message for the purpose of
soliciting, requesting, and importuning him to unlawfully appoint presidential electors from
Pennsylvania. This was an overt act in furtherance of the conspiracy.
Act 12.
On or about the 27th day ofNovember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI and JENNA LYNN ELLIS placed a telephone call to President Pro Tempore of the
Pennsylvania Senate Jake Corman for the purpose of soliciting, requesting, and importuning
Corman to unlawfiilly appoint presidential electors from Pennsylvania. This was an overt act in
turtherance of the conspiracy.
22
Act l4.
On or about the 27th day ofNovember 2020, DONALD JOHN TRUMP placed a
telephone call to President Pro Tempore of the Pennsylvania Senate Jake Corman for the purpose
of soliciting, requesting, and importuning Corman to unlawfully appoint presidential electors
from Pennsylvania. This was an overt act in furtherance of the conspiracy.
Act 15.
\
On or about the 28th day ofNovember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI placed a telephone call to Speaker of the Pennsylvania House ofRepresentatives
Bryan Cutler and left Cutler a voicemail message for the purpose of soliciting, requesting, and
importuning him to unlawfully appoint presidential electors from Pennsylvania. This was an
overt act in furtherance of the conspiracy.
Act 16.
On or about the 29th day ofNovember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI placed a telephone call to Speaker of the Pennsylvania House ofRepresentatives
Bryan Cutler and left Cutler a voicemail message for the'purpose of soliciting, requesting, and
importuning him to unlawfully appoint presidential electors from Pennsylvania. This was an
overt act in furtherance of the conspiracy.
Act 17.
'1 On or about the 30th day ofNovember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses at a meeting
ofArizona legislators in Phoenix, Arizona. Unindicted co-conspirators Individual 5 and
Individual 6, whose identities are known to the Grand Jury, were also present. During the
meeting, RUDOLPHWILLIAM LOUIS GIULIANI made false statements concerning fraud
in the November 3, 2020, presidential election in Arizona and solicited, requested, and
importuned the Arizona legislators present at the meeting to unlawfully appoint presidential
electors from Arizona. During the meeting, JENNA LYNN ELLIS solicited, requested, and
importuned the Arizona legislators present at the meeting to unlawfully appoint presidential
electors from Arizona. DONALD JOI-IN TRUMP joined the meeting by telephone and made
false statements concerning fraud in the November 3, 2020, presidential election in Arizona.
These were overt acts in furtherance of the conspiracy.
Act 18.
On or about the 30th day ofNovember 2020, MICHAELA. ROMAN instructed
unindicted co-conspirator Individual 7, whose identity is known to the Grand Jury, to coordinate
with individuals associated with the Trump Campaign to contact state legislators in Georgia and
elsewhere on'behalfofDONALD JOHN TRUMP and to encourage them to unlawfully appoint
presidential electors from their respective states. This was an overt act in furtherance of the
conspiracy.
23
Act 19.
On or between the 1st day ofDecember 2020 and the 31st day ofDecember 2020,
DONALD JOHN TRUMP andMARK RANDALLMEADOWS met with John McEntee and
requested that McEntee prepare a memorandum outlining a strategy for disrupting and delaying
the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes
cast by the duly elected and qualified presidential electors from Georgia and the other states. The
strategy included having Vice President Michael R. "Mike" Pence count only half of the electoral
votes from certain states and then return the remaining electoral votes to state legislatures. The
request was an overt act in furtherance of the conspiracy.
Act 20.
On or about the 1st day ofDecember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI and JENNA LYNN ELLIS met with Speaker of the Arizona House of
Representatives Rusty Bowers, President of the Arizona Senate Karen Fann, and other Arizona
legislators in Phoenix, Arizona. Unindicted co-conspirator Individual 5, whose identity is known
to the Grand Jury, was also present. During the meeting, RUDOLPHWILLIAM LOUIS
GIULIANI made false statements concerning fraud in the November 3, 2020, presidential
election in Arizona and solicited, requested, and importuned the legislators present to call a
special session of the Arizona State Legislature. These were overt acts in furtherance of the
conspiracy.
Act 21.
On or about the 2nd day ofDecember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses at a meeting
of the Michigan House ofRepresentatives Oversight Committee. During the meeting,
RUDOLPHWILLIAM LOUIS GIULIANI made false statements concerning fraud in the
November 3, 2020, presidential election inMichigan and solicited, requested, and importuned
the Michigan legislators present at the meeting to unlawfully appoint presidential electors from
Michigan. During the meeting, JENNA LYNN ELLIS solicited, requested, and importuned the
Michigan legislators present at the meeting to unlawfully appoint presidential electors from
Michigan. These were overt'acts in fiirtherance of the conspiracy.
Act 22
On or about the 3rd day ofDecember 2020, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account @RealDonaldTrump, "Georgia hearings now on @OANN.
Amazing!" This was an overt act in furtherance of the conspiracy.
24
LAC"i
On or about the 3rd day ofDecember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI, JOHN CHARLES EASTMAN, JENNA LYNN ELLIS, and RAY STALLINGS
SMITH III committed the felony offense of SOLICITATION OF VIOLATION OF OATH
BY PUBLIC OFFICER, in Violation ofO.C.G.A. §§ 16-47 & 16-10-1, in Fulton County,
Georgia, by unlawfully soliciting, requesting, and importuning certain public officers then
serving as elected members of the Georgia Senate and present at a Senate Judiciary
Subcommittee meeting, including unindicted co-conspirator Individual 8, Whose identity is
known to the Grand Jury, Senators Lee Anderson, Brandon Beach, Matt Brass, Greg Dolezal,
Steve Gooch, Tyler Harper, Bill Heath, Jen Jordan, John F. Kennedy, William Ligon, Elena
Parent, Michael Rhett, Carden Summers, and Blake Tillery, to engage in conduct constituting the
felony offense ofViolation ofOath by Public Officer, O.C.G.A. § 1610-1, by unlawfully
appointing presidential electors from Georgia, in willful and intentional Violation of the terms of
the oath of said persons as prescribed by law, with intent that said persons engage in said
conduct. This was an overt act in furtherance of the conspiracy.
Act 24.
On or about the 3rd day ofDecember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI committed the felony offense ofFALSE STATEMENTS ANDWRITINGS, in
violation ofO.C.G.A. § 16-10-20, in-Fulton County, Georgia, by knowingly, willfully, and
unlawfully making at least one of the following false statements and representations to members
of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:
1. That at least 96,600 mailin ballots were counted in the November 3, 2020, presidential
election in Georgia, despite there being no record of those ballots having been returned to
a county elections office;
2. That Dominion Voting Systems equipment used in the November 3, 2020, presidential
election in Antrim County, Michigan, mistakenly recorded 6,000 votes for Joseph R.
Biden when the votes were actually cast for Donald John Trump;
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and
the Georgia Bureau of Investigation, departments and agencies of state government, and county
and city law enforcement agencies. This was an act of racketeering activity under O.C.G.A. § 16-
14-3 (5)(A)(xxii) and an overt act in furtherance of the conspiracy.
25
Act 25.
On or about the 3rd day ofDecember 2020, RAY STALLINGS SMITH III committed
the felony offense of FALSE STATEMENTS ANDWRITINGS, in violation ofO.C.G.A. §
16-10-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least
one of the following false statements and representations to members of the Georgia Senate
present at a Senate Judiciary Subcommittee meeting:
l. That 2,506 felons voted illegally in the November 3, 2020, presidential election in
Georgia;
2. That 66,248 underage people illegally registered to vote before their seventeenth birthday
prior to the November 3, 2020, presidential election in Georgia;
3. That at least 2,423 people voted in the November 3, 2020, presidential election in
Georgia who were not listed as registered to vote;
4. That 1,043 people voted in the November 3, 2020, presidential election in Georgia who
had illegally registered to vote using a post office box;
5. That 10,315 or more dead people voted in the November 3, 2020, presidential election in
Georgia;
6. That Fulton County election workers at State Farm Arena ordered poll watchers and
members of the media to leave the tabulation area on the night ofNovember 3, 2020, and
continued to operate after ordering everyone to leave;
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and
the Georgia Bureau of Investigation, departments and agencies of state government, and county
and city law enforcement agencies. This was an act of racketeering activity under O.C.G.A. § l6-
l4-3 (5)(A)(xxii) and an overt act in furtherance of the conspiracy.
Act 26.
On or about the 3rd day 0fDecember 2020, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account @RealDonaldTrump, "Wow! Blockbuster testimony taking
place right now in Georgia. Ballot stuffing by Dems when Republicans were forced to leave the
large counting room. Plenty more coming, but this alone leads to an easy win of the State!" This
was an overt act in filrtherance of the conspiracy.
Act 27.
On or about the 3rd day 0fDecember 2020, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account @RealDonaldTrump, "People in Georgia got caught cold
bringing in massive numbers ofballots and putting them in 'voting' machines. Great job
@BrianKempGA!" This was an overt act in furtherance of the conspiracy.
26
Act 28.
On or about the 3rd day ofDecember 2020, DONALD JOHN TRUMP met with
Speaker of the Pennsylvania House of Representatives Bryan Cutler in the Oval Office at the
White House and discussed holding a special session of the Pennsylvania General Assembly.
This was an overt act in furtherance of the conspiracy.
Act 29.
On or between the 3rd day ofDecember 2020 and the 26th day ofDecember 2020,
RUDOLPHWILLIAM LOUIS GIULIANI placed a telephone call to President Pro Tempore
of the Georgia Senate Cecil Terrell "Butch" Miller for the purpose ofmaking false statements
concerning fraud in the November 3, 2020, presidential election in Georgia. This was an overt
act in furtherance of the conspiracy.
Act 30.
On or between the 3rd day ofDecember 2020 and the 26th day ofDecember 2020,
DONALD JOHN TRUMP placed a telephone call to President Pro Tempore of the Georgia
Senate Butch Miller. This was an overt act in furtherance of the conspiracy.
Act 31.
On or about the 5th day ofDecember 2020, DONALD JOHN TRUMP placed a
telephone call to Georgia Governor Brian Kemp and solicited, requested, and importuned Kemp
to call a special session of the Georgia General Assembly. This was an overt act in furtherance of
the conspiracy.
Act 32.
On or about the 6th day ofDecember 2020, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account @RealDonaldTrump, "Gee, what a surprise. Has anyone
informed the so-called (says he has no power to do anything!) Governor @BrianKempGA & his
puppet Lt. Governor @GeoffDuncanGA, that they could easily solve this mess, & WIN.
Signature verification & call a Special Session. So easy! 'https://t.co/5cb4QdepU." This was an
overt act in furtherance of the conspiracy.
Act 33.
On or about the 6th day ofDecember 2020, SIDNEY KATHERINE POWELL entered
into a written engagement agreement with SullivanStrickler LLC, a forensic data firm located in
Fulton County, Georgia, for the performance of computer forensic collections and analytics on
Dominion Voting Systems equipment in Michigan and elsewhere. The unlawful breach of
election equipment in Coffee County, Georgia, was subsequently performed under this
agreement. This was an overt act in furtherance of the conspiracy.
27
Act 34.
On or about the 6th day 0fDecember 2020, ROBERT DAVID CHEELEY sent an e-
mail to JOHN CHARLES EASTMAN, unindicted co-conspirator Individual 8, whose identity
is known to the Grand Jury, and Georgia Senator Brandon Beach that stated, "I am working on
setting up a call for you with the Speaker and the President Pro Tempore tomorrow. I am also
making the leadership aware of the importance for Trump electors to meet on December l4.
Please provide the citation to the requirements of the duties which they must comply with." This
was an overt act in furtherance of the conspiracy.
Act 35.
On or about the 6th day ofDecember 2020, JOHN CHARLES EASTMAN sent an e
mail to ROBERT DAVID CHEELEY, unindicted co-conspirator Individual 8, whose identity is
known to the Grand Jury, and Georgia Senator Brandon Beach that stated that the Trump
presidential elector nominees in Georgia needed to meet on December l4, 2020, sign six sets of
certificates of vote, and mail them "to the President of the Senate and to other officials." This
was an overt act in furtherance of the conspiracy.
Act 36.
On or about the 6th day 0fDecember 2020, ROBERT DAVID CHEELEY sent an e-
mail to unindicted co-conspirator Individual 2, whose identity is known to the Grand Jury, that
stated he had been speaking with JOHN CHARLES EASTMAN and was attempting to set up a
call with Speaker of the Georgia House of Representatives David Ralston and President Pro
Tempore of the Georgia Senate Butch Miller to encourage them to call a special session of the
Georgia General Assembly. In the email, ROBERT DAVID CHEELEY stated, "Professor
Eastman told me tonight that it is critical that the 16 Electors for President Trump meet next
Monday and vote in accordance with 3 U.S.C. § 7." In the e-mail, ROBERT DAVID
CHEELEY further stated, "I assume you can make sure this happens." This was an overt act in
furtherance of the conspiracy.
Act 37.
On or about the 7th day ofDecember 2020, unindicted coconspirator Individual 2,
Whose identity is known to the Grand Jury, sent an email to ROBERT DAVID CHEELEY and
DAVID JAMES SHAFER that stated, "Bob, can u get on a call with David Shafer, state GOP
chair and I later this morning to discuss. David has been on top of a lot of efi'orts in the state. I
get offof a board call around 10:30." This was an overt act in furtherance of the conspiracy.
28
Act 38.
On or about the 7th day ofDecember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI caused to be tweeted from the Twitter account @RudyGiuliani a retweet of
unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, that stated,
"Georgia Patriot Call to Action: today is the day we need you to call your state Senate & House
Reps & ask them t0 sign the petition for a special session. We must have free & fair elections in
GA & a this is our only path to ensuring every legal vote is counted. @realDonaldTrump." This
was an overt act in furtherance of the conspiracy.
Act 39.
On or about the 7th day 0fDecember 2020, JOHN CHARLES EASTMAN sent an e-
mail to RUDOLPHWILLIAM LOUIS GIULIANI with an attached memorandum titled "The
Real Deadline for Settling a State's Electoral Votes." The body of the e-mail stated, "Here's the
memo we discussed." The memorandum was written by KENNETH JOHN CHESEBRO to
James R. Troupis, an attomey associated with the Trump Campaign, and advocates for the
position that Trump presidential elector nominees in Wisconsin should meet and cast electoral
votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD
JOHN TRUMP lost the November 3, 2020, presidential election in Wisconsin. This e-mail was
an overt act in furtherance of the conspiracy.
Act 40.
On or about the 7th day 0fDecember 2020, DONALD JOHN TRUMP requested that
Bill White, an individual associated with the Trump Campaign then residing in Fulton County,
Georgia, provide him with certain information, including contact information for Majority
Leader of the Georgia Senate Mike Dugan and President Pro Tempore of the Georgia Senate
Butch Miller. The following day, White sent an email containing the requested information to
RUDOLPHWILLIAM LOUIS GIULIANI, unindicted co-conspirator Individual 5, whose
identity is known to the Grand Jury, and others. This request was an overt act in furtherance of
the conspiracy.
Act 41.
On or about the 7th day 0fDecember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI placed a telephone call to Speaker of the Georgia House of Representatives David
Ralston and discussed holding a special session of the Georgia General Assembly. This was an
overt act in fithherance of the conspiracy.
29
Act 42.
On or about the 7th day ofDecember 2020, DONALD JOHN TRUMP committed the
felony offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, in
Violation ofO.C.G.A. §§ 16-4-7 & 16-10-1, in Fulton County, Georgia, by unlawfully soliciting,
requesting, and importuning Speaker of the Georgia House of Representatives David Ralston, a
public officer, to engage in conduct constituting the felony offense ofViolation ofOath by
Public Officer, O.C.G.A. § 1610-1, by calling a special session of the Georgia General
Assembly for the purpose ofunlawfully appointing presidential electors from Georgia, in willful
and intentional Violation of the terms of the oath of said person as prescribed by law, with intent
that said person engage in said conduct. This was an overt act in furtherance of the conspiracy.
Act 43.
On or about the 8th day ofDecember 2020, DONALD JOHN TRUMP placed a
telephone call to Georgia Attorney General Chris Carr for the purpose ofmaking false statements
concerning fraud in the November 3, 2020, presidential election in-Georgia and elsewhere.
During the telephone call, DONALD JOHN TRUMP asked Carr not to discourage other state
attorneys general fiom joining a federal lawsuit filed by the State of Texas contesting the
administration of the November 3, 2020, presidential election in Georgia, Michigan,
Pennsylvania, and Wisconsin. This was an overt act in furtherance of the conspiracy.
Act 44.
On or about the 8th day ofDecember 2020, DONALD JOHN TRUMP and JOHN
CHARLES EASTMAN placed a telephone call to Republican National Committee
Chairwoman RonnaMcDaniel to request her assistance gathering certain individuals to meet and
cast electoral votes for DONALD JOHN TRUMP on December 14, 2020, in certain states
despite the fact that DONALD JOHN TRUMP' lost the November 3, 2020, presidential election
in those states. This was an overt act in furtherance of the conspiracy.
Act 45.
On or about the 8th day ofDecember 2020, MICHAELA. ROMAN sent a text
message to unindicted co-conspirator 1ndividual 4, whose identity is known to the Grand Jury,
stated that he had spoken to MISTYHAMPTON, and asked unindicted co-conspirator
Individual 4 to "get" MISTYHAMPTON to attend the hearing before the Georgia House of
Representatives Governmental Affairs Committee on December 10, 2020. This was an overt act
in furtherance of the conspiracy.
30
Act 46.
On or about the 9th day ofDecember 2020, KENNETH JOHN CHESEBRO wrote a
memorandum titled "Statutory Requirements for December 14 Electoral Votes" to James R.
Troupis, an attorney associated with the Trump Campaign. The memorandum provides detailed,
state-specific instructions for how Trurnp presidential elector nominees in Georgia, Arizona,
Michigan, Nevada, Pennsylvania, and Wisconsin would meet and cast electoral votes for
DONALD JOHN TRUMP on December l4, 2020, despite the fact that DONALD JOHN
TRUMP lost the November 3, 2020, presidential election in those states. This was an overt act
in flirtherance of the conspiracy.
Act 47.
On or about the 10th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail to Georgia Republican Party Chairman DAVID JAMES SHAFER and unindicted co-
conspirator Individual 9, whose identity is known to the Grand Jury. KENNETH JOHN
CHESEBRO stated in the e-mail that certain individuals associated with the Trump Campaign
asked him "to help coordinate with the other 5 contested States, to help With logistics of the
electors in other States hopefully joining in casting their votes on Monday." This was an overt
act in furtherance of the conspiracy.
Act 48.
On or about the 10th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail with attached documents to DAVID JAMES SHAFER and unindicted co-conspirators
Individual 9, Individual 10, and Individual 11, whose identities are known to the Grand Jury. The
documents were to be used by Trump presidential elector nominees in Georgia for the purpose of
casting electoral votes for DONALD JOHN TRUW on December 14, 2020, despite the fact
that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in Georgia.
This was an overt act in furtherance of the conspiracy.
Act 49.
On or about the 10th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
email with attached documents to Arizona Republican Party Executive Director Greg Safsten
and others. The documents were 'to be used by Trump presidential elector nominees in Arizona
for the purpose of casting electoral votes for DONALD JOHN TRUMP on December 14, 2020,
despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election
in Arizona. This was an over't act in flirtherance of the conspiracy.
3l
Act 50.
On or about the 10th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail to Republican Party ofWisconsin Chairman Brian Schimming with proposed language
for documents to be used by TruInp presidential elector nominees in Wisconsin for the purpose
of casting electoral votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact
'that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in Wisconsin.
This was an overt act in furtherance of the conspiracy.
Act51-
.
On or about the 10th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail to Nevada Republican Party Vice Chairman Jirn DeGraffenreid. KENNETH JOHN
CHESEBRO stated in the e-mail that RUDOLPHWILLIAM LOUIS GIULIANI and other
individuals associated With the Trump Campaign asked him "to reach out to you and the other
Nevada electors to run point on the plan to have all Trump-Pence electors in all six contested
States meet and transmit their votes to Congress on Monday, Dec. 14." This was an overt act in
furtherance of the conspiracy.
I
Act 52
On or about the 10th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
email with attached documents to Jim DeGraffenreid. The documents were to be used by Trump
presidential elector nominees in Nevada for the purpose of casting electoral votes for DONALD
JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN TRUMP lost
the November 3, 2020, presidential election in Nevada. This was an overt act in furtherance of
the conspiracy.
Act 52
On or about the 10th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail with attached documents to Republican Party of Pennsylvania General Counsel Thomas
W. King III. The documents were to be used by Trump presidential elector nominees in
Pennsylvania for the purpose of casting electoral votes for DONALD JOHN TRUMP on
December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020,
presidential election in Pennsylvania. This was an overt act in furtherance of the conspiracy.
Act 54.
On or between the 10th day ofDecember 2020 and the 14th day ofDecember 2020,
DAVID JAMES SHAFER contacted unindicted coconspirator Individual 2, whose identity is
known to the Grand Jury, by telephone and discussed unindicted co-conspirator Individual 2's
attendance at the December 14, 2020, meeting of Trump presidential elector nominees in Fulton
County, Georgia. This was an overt act in furtherance of the conspiracy.
32
Act 55.
On or about the 10th day ofDecember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI and RAY STALLINGS SMITH III committed the felony offense of
SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, in Violation of
O.C.G.A. §§ 16-4-7 & 16-10-1, in Fulton County, Georgia, by unlawfully soliciting, requesting,
and importuning certain public officers then serving as elected members of the Georgia House of
Representatives and present at a House Governmental Affairs Committee meeting, including
Representatives Shaw Blackmon, Jon Burns, Barry Fleming, Todd Jones, Bee Nguyen, Mary
Margaret Oliver, Alan Powell, Renitta Shannon, Robert Trammell, Scot Turner, and Bruce
Williamson, to engage in conduct constituting the felony offense ofViolation ofOath by Public
Officer, O.C.G.A. § 16-10-1, by unlawfully appointing presidential electors from Georgia, in
willful and intentional violation of the terms of the oath of said persons as prescribed by law,
with intent that said persons engage in said conduct. This was an overt act in furtherance of the
conspiracy.
33
Act 56.
On or about the 10th day ofDecember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI committed the felony offense ofFALSE STATEMENTS ANDWRITINGS, in
Violation ofO.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly, willfully, and
unlawfully making at least one of the following false statements and representations to members
of the Georgia House 0f Representatives present at a House Governmental Affairs Committee
meeting:
1. That it is quite clear from the State Farm Arena Video from November 3, 2020, that
Fulton County election workers were stealing votes and that Georgia officials were
covering up a crime in plain sight;
That at State Farm Arena on November 3, 2020, Democratic officials "got rid of all of the
reporters, all the observers, anyone that couldn't be trusted," used the excuse of a
watermain break, cleared out the voting area and then "went about their dirty, crooked
business";
2
That between 12,000 and 24,000 ballots were illegally counted by Fulton County election
workers at State Farm Arena on November 3, 2020;
3
That inMichigan, there were 700,000 more ballots counted than were sent out to voters
in the November 3, 2020, presidential election, which was accounted for by quadruple
counting ballots;
4
A
That Ruby Freeman, Shaye Moss, and an unidentified man were "quite obviously
surreptitiously passing around USB ports as if they're vials ofheroin or cocaine" at State
Farm Arena to be used to "infiltrate the crooked Dominion voting machines";
5
That 96,600 mail-in ballots were counted in the November 3, 2020, presidential election
in Georgia, despite there being no record of those ballots having been returned to a
county elections office;
6
said statements being Within the jurisdiction of the Office of the Georgia Secretary of State and
the Georgia Bureau of Investigation, departments and agencies of state government, and county
and city law enforcement agencies. This was an act of racketeering activity under O.C.G.A. § 16-
14-3 (5)(A)(xxii) and an overt act in furtherance of the conspiracy.
34
Act 57.
On or about the, 11th day ofDecember 2020, DAVID JAMES SHAFER reserved Room
216 at the Georgia State Capitol in Fulton County, Georgia, for the December 14, 2020, meeting
of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in
furtherance of the conspiracy.
Act 58.
On or about the 11th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail to Jim DeGraffenreid and stated that "the purpose ofhaving the electoral votes sent in to
Congress is to provide the opportunity to debate the election irregularities in Congress, and to
keep alive the possibility that the votes could be flipped to Trump." This was an overt act in
filrtherance of the conspiracy.
Act 59.
' On or about the 11th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail with attached documents to Greg Safsten and others. The documents were to be used by
Trump presidential elector nominees in Arizona for the purpose of casting electoral votes for
DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN
TRUMP lost the November 3, 2020, presidential election in Arizona. This was an overt act in
furtherance of the conspiracy.
Act 60.
On or about the 11th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail with attached documents to MICHAEL A. ROMAN and other individuals associated
with the Trump Campaign. The documents were to be used by Trump presidential elector
nominees in Nevada for the purpose of casting electoral votes for DONALD JOHN TRUMP on
December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020,
presidential election in Nevada. This was an overt act in furtherance of the conspiracy.
Act 61.
On or about the 11th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail with attached documents to MICHAEL A. ROMAN, unindicted co-conspirator
Individual 5, whose identity is known to the Grand Jury, and others. The documents were to be
used by Trump presidential elector nominees in Georgia for the purpose of casting electoral
votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD
JOHN TRUMP lost the November 3, 2020, presidential election in Georgia. This was an overt
act in furtherance of the conspiracy.
35
Act 62.
On or about the 12th day ofDecember 2020, DAVID JAMES SHAFER contacted
unindicted co-conspirator Individual 12, whose identity is known t0 the Grand Jury, and
discussed unindicted co-conspirator Individual 12's attendance at the December 14, 2020,
meeting ofTrump presidential elector nominees in Fulton County, Georgia. This was an overt act
in furtherance of the conspiracy.
Act 63.
On or about the 12th day ofDecember 2020, MICHAELA. ROMAN sent an e-mail to
unindicted co-conspirators Individual 4 and Individual 7, whose identities are known to the
Grand Jury, and other individuals associated with the Trump Campaign. In the e-mail,
MICHAELA. ROMAN stated, "I need a tracker for the electors," and instructed individuals
associated with the Trump Campaign to populate entries on a shared spreadsheet listing Trump
presidential elector nominees in Georgia, Arizona, Michigan, Nevada, Pennsylvania, and
Wisconsin. The entries on the spreadsheet included contact information for the Trump
presidential elector nominees, whether the Trump presidential elector nominees had been
contacted, and whether the Trump presidential elector nominees had confirmed that they would
attend the December l4, 2020, meetings of Trump presidential elector nominees in their
respective states, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020,
presidential election in those states. This was an overt act in furtherance of the conspiracy.
Act 64.
On or about the 12th day ofDecember 2020, KENNETH JOHN CHESEBRO met
with Brian Schimming and discussed the December l4, 2020, meeting of Trump presidential
elector nominees in Wisconsin. RUDOLPHWILLIAM LOUIS GIULIANI joined the meeting
by telephone and stated that the media should not be notified of the December 14, 2020, meeting
of Trump presidential elector nominees in Wisconsin. These were overt acts in furtherance of the
conspiracy.
AL65-
On or about the 12th day ofDecember 2020, MICHAELA. ROMAN instructed an
individual associated with the Trump Campaign to distribute certain information related to the
December 14, 2020, meetings ofTrump presidential elector nominees in Georgia, Arizona,
Michigan, Nevada, New Mexico, Pennsylvania, and Wisconsin to unindicted co-conspirator
Individual 4, whose identity is known to the Grand Jury, and to other individuals associated with
the Trump Campaign. This was an overt act in furtherance of the conspiracy.
36
AL"-
On or about the 12th day ofDecember 2020, unindicted co-conspirator Individual 4,
Whose identity is known to the Grand Jury, sent an e-mail to MICHAELA. ROMAN and
DAVID JAMES SHAFER with updates on the progress of organizing the December 14, 2020,
meeting of Trump presidential elector nominees in Fulton County, Georgia. The e-mail stated
which elector nominees had confirmed they would attend the meeting, that other individuals had
been secured in case some of the elector nominees refused to participate in the meeting, that
Georgia legislators had been contacted to ensure access to the Georgia Capitol, and that DAVID
JAMES SHAFER had reserved Room 216 for the meeting. This was an overt act in furtherance
of the conspiracy.
Act 67.
On or about the 12th day ofDecember 2020, DAVID JAMES SHAFER sent an e-mail
to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, advising
them to "touch base" with each of the Trump presidential elector nominees in Georgia in advance
of the December 14, 2020, meeting to confirm their attendance. This was an overt act in
furtherance of the conspiracy.
Act 68.
On or about the 12th day ofDecember 2020, unindicted co-conspirator Individual 4,
whose identity is known to the Grand Jury, sent a text message with contactlinformation for
unindicted coconspirator Individual 8, whose identity is known to the Grand Jury, and Georgia
Senator Brandon Beach to MICHAELA. ROMAN for the purpose ofproviding the contact
information to RUDOLPHWILLIAM LOUIS GIULIANI. This was an overt act in
furtherance of the conspiracy.
Act 69.
On or about the 13th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail with attached documents to MICHAEL A. ROMAN. The documents were to be used by
Trump presidential elector nominees in NewMexico for the purpose of casting electoral votes
for'DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN
TRUMP lost the November 3, 2020, presidential election in NewMexico. This was an overt act
in furtherance of the conspiracy.
37
Act 70.
On or about the 13th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail to RUDOLPHWILLIAM LOUIS GIULIANI with the subject "PRIVILEGED AND
CONFIDENTIAL  Brief notes on 'President of the Senate' strategy." In the email, KENNETH
JOHN CHESEBRO outlined multiple strategies for disrupting and delaying the joint session of
Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly
elected and qualified presidential electors from Georgia and the other states. In the e-mail,
KENNETH JOHN CHESEBRO stated that the strategies outlined by him were "preferable to
allowing the Electoral Count Act to operate by its terms." This was an overt act in furtherance of
the conspiracy.
AL71-
On or about the 13th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
email with attached documents to MICHAEL A. ROMAN and unindicted co-conspirator
Individual 4, whose identity is known to the Grand Jury. The documents were to be used by
Trump presidential elector nominees in Georgia for the purpose of casting electoral votes for
DONALD JOHN TRUMP on December l4, 2020, despite the fact that DONALD JOHN
TRUMP lost the November 3, 2020, presidential election in Georgia. This was an overt act in
filrtherance of the conspiracy.
Act 72.
On or about the 13th day ofDecember 2020, KENNETH JOHN CHESEBRO sent an
e-mail to MICHAEL A. ROMAN and unindicted co-conspirator Individual 4, whose identity is
known to the Grand Jury, and stated that RUDOLPHWILLIAM LOUIS GIULIANI "wants to
keep this quiet until after all the voting is done," in reference to the December 14, 2020, meeting
ofTrump presidential elector nominees in Fulton County, Georgia. This was an overt act in
furtherance of the conspiracy.
Act 73.
On or about the 13th day ofDecember 2020, DAVID JAMES SHAFER sent a text
message to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury,
and stated that unindicted co-conspirator Individual 8, whose identity is known to the Grand
Jury, would attend the December 14, 2020, meeting ofTrump presidential elector nominees in
Fulton County, Georgia, in the place of a Trump presidential elector nominee who refused to
participate in the meeting. This was an overt act in furtherance of the conspiracy.
38
Act 74.
On or about the 13th day ofDecember 2020, unindicted co-conspirator Individual 9,
whose identity is known to the Grand Jury, sent a text message to DAVID JAMES SHAFER
and confirmed that he and unindicted co-conspirator Individual 13, whose identity is known to
the Grand Jury, would attend the December 14, 2020, meeting of Trump presidential elector
nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.
Act 75.
On or about the 14th day 0fDecember 2020, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account @RealDonaldTrump, "What a fool Governor @BrianKempGA
ofGeorgia is. Could have been so easy, but now we have to do it the hard way. Demand this
clown call a Special Session and open up signature verification, NOW. Otherwise, could be a bad
day for two GREAT Senators on January 5th." This was an overt act in furtherance of the
conspiracy.
Act 76.
On 0r about the 14th day ofDecember 2020, DAVID JAMES SHAFER sent a text
message to unindicted coconspirator Individual 4, whose identity is known to the Grand Jury
that stated, "Listen. Tell them to go straight to Room 216 to avoid drawing attention to what we
are doing," in reference to the December 14, 2020, meeting of Trump presidential elector
nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.
Act 77.
On or about the 14th day 0fDecember 2020, MICHAELA. ROMAN sent an e-mail to
unindicted coconspirators Individual 4 and Individual 7, whose identities are known to the
Grand Jury, and stated, "Please send me an update as soon as the State Electoral College has
adjourned and all paperwork is secured." This was an overt act in furtherance of the conspiracy.
Act 78.
On 0r about the 14th day 0fDecember 2020, RAY STALLINGS SMITH III and
DAVID JAMES SHAFER encouraged certain individuals present at the December 14, 2020,
meeting of Trump presidential elector nominees in Fulton County, Georgia, to sign the document
titled "CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA." This
was an overt act in furtherance of the conspiracy.
39
Act 79.
On or about the 14th day ofDecember 2020, DAVID JAMES SHAFER, SHAWN
MICAH TRESHER STILL, CATHLEEN ALSTON LATHAM, and unindicted co-
conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual ll, Individual 12,
Individual 13, Individual l4, Individual 15, Individual 16, Individual l7, Individual 18, and
Individual 19, Whose identities are known to the Grand Jury, committed the felony offense of
IMPERSONATING A PUBLIC OFFICER, in violation ofO.C.G.A. § 16-10-23, in Fulton
County, Georgia, by unlawfully falsely holding themselves out as the duly elected and qualified
presidential electors fiom the State ofGeorgia, public officers, with intent to mislead the
President of the United States Senate, the Archivist of the United States, the Georgia Secretary of
State, and the Chief Judge of the United States District Court for the Northern District ofGeorgia
into believing that they actually were such officers by placing in the United States mail to said
persons a document titled "CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM
GEORGIA." This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xxiii) and
an overt act in furtherance of the conspiracy.
Act 80.
On or about the 14th day ofDecember 2020, DAVID JAMES SHAFER, SHAWN
MICAH TRESHER STILL, CATHLEENALSTON LATHAM, and unindicted co-
conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual ll, Individual 12,
Individual l3, Individual l4, Individual 15, Individual 16, Individual l7, Individual l8, and
Individual 19, whose identities are known to the Grand Jury, committed the felony offense of
FORGERY IN THE FIRST DEGREE, in violation ofO.C.G.A. § 16-9-1(b), in Fulton
_
County, Georgia, by, with the intent to defraud, knowingly making a document titled
"CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA," a writing
other than a check, in such manner that the writing as made purports to have been made by
authority of the duly elected and qualified presidential electors from the State ofGeorgia, who
did not give such authority, and uttered and delivered said document to the Archivist of the
United States. This was an act of racketeering activity under O.C.G.A. § 1614-3(5)(A)(xvi) and
an overt act in furtherance of the conspiracy.
40
Act 81.
On or about the 14th day ofDecember 2020, DAVID JAMES SHAFER, SHAWN
MICAH TRESHER STILL, CATHLEENALSTON LATHAM, and unindicted co-
conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual ll, Individual 12,
Individual 13, Individual 14, Individual 15, Individual l6, Individual 17, Individual 18, and
Individual 19, whose identities are known to the Grand Jury, committed the felony offense of
FALSE STATEMENTS ANDWRITINGS, in violation ofO.C.G.A. § 16-10-20, in Fulton
County, Georgia, by knowingly, willfully, and unlawfully making and using a false document
titled "CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA," with
knowledge that said document contained the false statement, "WE, THE UNDERSIGNED,
being the duly elected and qualified Electors for President and Vice President of the United
States ofAmerica from the State ofGeorgia, do hereby certify the following," said document
being within the jurisdiction of the Ofiice of the Georgia Secretary of State and the Office of the
Governor ofGeorgia, departments and agencies of state government. This was an act of
racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xxii) and an overt act in furtherance of the
conspiracy.
14le
On or about the 14th day ofDecember 2020, DAVID JAMES SHAFER, SHAWN
MICAH TRESHER STILL, CATHLEENALSTON LATHAM, and unindicted co-
conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual ll, Individual 12,
Individual 13, Individual 14, Individual 15, Individual l6, Individual l7, Individual 18, and
Individual l9, whose identities are known to the Grand Jury, attempted to commit the felony
offense ofFILING FALSE DOCUMENTS, in violation ofO.C.G.A. § 16-10-20.1(b)(1), in
Fulton Counw, Georgia, by placing in the United States mail a document titled "CERTIFICATE
OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA," addressed to Chief Judge,
U.S. District Court, Northern District ofGeorgia, 2188 Richard D. Russell Federal Ofiice
Building and U.S. Courthouse, 75 Ted Turner Drive, SW, Atlanta, GA 30303, with intent to
knowingly file, enter, and record said document in a court of the United States, having reason to
know that said document contained the materially false statement, "WE, THE UNDERSIGNED,
being the duly elected and qualified Electors for President and Vice President of the United
States ofAmerica from the State ofGeorgia, do hereby certify the following." This was an act of
racketeering activity under O.C.G.A. § 16-14-3 (5)(A)(xxii) and an overt act in furtherance of the
conspiracy.
41
Act 83.
On or about the 14th day ofDecember 2020, DAVID JAMES SHAFER and SHAWN
MICAH TRESHER STILL committed the felony offense ofFORGERY IN THE FIRST
DEGREE, in Violation ofO.C.G.A. § 1691(b), in Fulton County, Georgia, by, with the intent
to defraud, knowingly making a document titled "RE: Notice ofFilling ofElectoral College
Vacancy," a writing other than a check, in suchmanner that the writing as made purports to have
been made by the authority of the duly elected and qualified presidential electors from the State
ofGeorgia, who did not give such authority, and uttered and delivered said document to the
Archivist of the United States. This was an act of racketeering activity under O.C.G.A. § 16-14-
3(5)(A)(xvi) and an overt act in furtherance of the conspiracy.
Act 84.
On or about the 14th day ofDecember 2020, DAVID JAMES SHAFER and SHAWN
MICAH TRESHER STILL committed the felony offense of FALSE STATEMENTS AND
WRITINGS, in violation ofO.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly,
willfully, and unlawfully making and using a false document titled "RE: Notice ofFilling of
Electoral College Vacancy," with knowledge that said document contained the false statements
that DAVID JAMES SHAFER was Chairman of the 2020 Georgia Electoral College Meeting
and SHAWNMICAH TRESHER STILL was Secretary of the 2020 Georgia Electoral College
Meeting, said document being within the jurisdiction of the Office of the Georgia Secretary of
State and the Office of the Governor ofGeorgia, departments and agencies of state government.
This was an act of racketeering activity under O.C.G.A. § l6-l4-3(5)(A)(xxii) and an overt act in
furtherance of the conspiracy.
Act 85.
On or about the 14th day ofDecember 2020, DAVID JAMES SHAFER instructed
unindicted coconspirator Individual 15, whose identity is known to the Grand Jury, to deliver to
the Office of the Governor ofGeorgia a document signed by DAVID JAMES SHAFER and
SHAWNMICAH TRESHER STILL titled "RE: Notice ofFilling ofElectoral College
Vacancy." The document contained multiple false statements. This was an overt act in
furtherance of the conspiracy.
Act 86.
On or about the 14th day ofDecember 2020, unindicted co-conspirator Individual 4,
whose identity is known to the Grand Jury, sent an e-mail to MICHAELA. ROMAN,
unindicted co-conspirator Individual 7, whose identity is known to the Grand Jury, and others
that stated, "All votes cast, paperwork complete, being mailed now. Ran pretty smoothly," in
reference to the December 14, 2020, meeting of Trump presidential elector nominees in Fulton
County, Georgia. This was an overt act in furtherance of the conspiracy.
42
Act 87.
On or about the 14th day ofDecember 2020, STEPHEN CLIFFGARD LEE attempted
to commit the felony offense of INFLUENCINGWITNESSES, in Violation ofO.C.G.A. § 16-
10-93(b)(1)(A), in Fulton County, Georgia, by traveling to the home ofRuby Freeman, a Fulton
County, Georgia, election worker, and speaking to her neighbor, with intent to knowingly engage
in misleading conduct toward Ruby Freeman, by purporting to offer her help, and with intent to
influence her testimony in an official proceeding in Fulton County, Georgia, concerning events
at State Farm Arena in the November 3, 2020, presidential election in Georgia. This was an act
of racketeering activity pursuant to O.C.G.A. § 16143(5)(A)(xxvii) and an overt act in
furtherance of the conspiracy.
Act 88.
On or about the 15th day ofDecember 2020, STEPHEN CLIFFGARD LEE attempted
to commit the felony offense of INFLUENCINGWITNESSES, in violation ofO.C.G.A. § 16-
10-93(b)(1)(A), in Fulton County, Georgia, by traveling to the home ofRuby Freeman, a Fulton
County, Georgia, election worker, and knocking on her door, with intent to knowingly engage in
misleading conduct toward Ruby Freeman, by purporting to offer her help, and with intent t0
influence her testimony in an official proceeding in Fulton County, Georgia, concerning events
at State Farm Arena in the November 3, 2020, presidential election in Georgia. This was an act
of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xxvii) and an overt act in
furtherance of the conspiracy.
Act 89.
On or between the 15th day ofDecember 2020 and the 4th day of January 2021,
STEPHEN CLIFFGARD LEE solicited HARRISONWILLIAM PRESCOTT FLOYD, an
individual associated with the organization Black Voices for Trump, to assist with his effort t0
speak to Ruby Freeman, a Fulton County, Georgia, election worker. STEPHEN CLIFFGARD
LEE stated to HARRISONWILLIAM PRESCOTT FLOYD that Freeman was afraid to talk
to STEPHEN CLIFFGARD LEE because he was a white man. These were overt acts in
furtherance of the conspiracy.
Act 90.
. On or about the 18th day ofDecember 2020, DONALD JOHN TRUMP met with
RUDOLPHWILLIAM LOUIS GIULIANI, SIDNEY KATHERINE POWELL, unindicted
co-conspirator Individual 20, whose identity is known to the Grand Jury, and others at the White
House. The individuals present at the meeting discussed certain strategies and theories intended
to influence the outcome of the November 3, 2020, presidential election, including seizing voting
equipment and appointing SIDNEY KATHERINE POWELL as special counsel with broad
authority to investigate allegations of voter fraud in Georgia and elsewhere. This was an overt act
in furtherance of the conspiracy.
43
Act 91.
On or about the 21st day ofDecember 2020, SIDNEY KATHERINE POWELL sent
an email to the ChiefOperations Officer of SullivanStrickler LLC and instructed him that she
and unindicted co-conspirators Individual 6, Individual 21, and Individual 22, whose identities
are known to the Grand Jury, were to immediately "receive a copy of all data" obtained by
SullivanStrickler LLC from Dominion Voting Systems equipment in Michigan. This was an
overt act in furtherance of the conspiracy.
Act 92.
On or about the 22nd day ofDecember 2020, MARK RANDALLMEADOWS
traveled to the Cobb County Civic Center in Cobb County, Georgia, and attempted to observe the
signature match audit being performed there by law enforcement officers from the Georgia
Bureau of Investigation and the Ofiice of the Georgia Secretary of State, despite the fact that the
audit process was not open to the public. While present at the center, MARK RANDALL
MEADOWS spoke to Georgia Deputy Secretary of State Jordan Fuchs, Office of the Georgia
Secretary of State Chief Investigator Frances Watson, Georgia Bureau of Investigation Special
Agent in Charge Bahan Rich, and others, who prevented MARK RANDALLMEADOWS from
entering into the space where the audit was being conducted. This was an overt act in furtherance
of the conspiracy.
Act 93.
On or about the 23rd day ofDecember 2020, DONALD JOHN TRUMP placed a
telephone call to Office of the Georgia Secretary of State Chief Investigator Frances Watson that
had been previously arranged by MARK RANDALLMEADOWS. During the phone call,
DONALD JOHN TRUMP falsely stated that he had won the November 3, 2020, presidential
election in Georgia "by hundreds of thousands of votes" and stated to Watson that "when the
right answer comes out you'll be praised." This was an overt act in furtherance of the conspiracy.
Act 94.
On or about the 23rd day ofDecember 2020, JOHN CHARLES EASTMAN sent an e-
mail to KENNETH JOHN CHESEBRO and unindicted co-conspirator Individual 3, whose
identity is known to the Grand Jury, with the subject "FW: Draft 2, with edits'." In the e-mail,
JOHN CHARLES EASTMAN attached a memorandum titled "PRIVILEGED AND
CONFIDENTIAL -- Dec 23 memo on Jan 6 scenario.docx" and stated, "As for hearings, I think
both are unnecessary. The fact that we have multiple slates of electors demonstrates the
uncertainty of either. That should be enough. And I agree with Ken that Judiciary Committee
hearings on the constitutionality of the Electoral CountAct could invite counter views that we do
not believe should constrain Pence (or Grassley) in the exercise ofpower they have under the
12th Amendment. Better for them just to act boldly and be challenged, since the challenge would
likely lead to the Court denying review on nonjusticiable political question grounds." This was
an overt act in furtherance of the conspiracy.
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Act 95.
On or about the 25th day ofDecember 2020, DONALD JOHN TRUMP placed a
telephone call to Speaker of the Arizona House of Representatives Rusty Bowers for the purpose
of soliciting, requesting, and importuning Bowers to unlawfully appoint presidential electors
from Arizona. During the call, Bowers stated to Trump, "I voted for you. I worked for you. I
campaigned for you. I just won't d0 anything illegal for you." This telephone call was an overt
act in furtherance of the conspiracy.
Act 96.
On or about the 27th day ofDecember 2020, MARK RANDALLMEADOWS sent a
text message to Office of the Georgia Secretary of State Chief Investigator Frances Watson that
stated in part, "Is there a way to speed up Fulton county signature verification in order to have
results before Jan 6 if the trump campaign assist financially." This was an overt act in furtherance
of the conspiracy.
Act 97.
On or about the 27th day ofDecember 2020, DONALD JOHN TRUMP solicited
Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney
General Richard Donoghue to make a false statement by stating, "Just say that the election was
corrupt, and leave the rest to me and the Republican congressmen." This was an overt act in
furtherance of the conspiracy.
Act 98.
On or about the 28th day ofDecember 2020, JEFFREY BOSSERT CLARK attempted
to commit the felony ofiense of FALSE STATEMENTS ANDWRITINGS, in violation of
O.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly and willfully making a false
writing and document knowing the same to contain the false statement that the United States
Department of Justice had "identified significant concerns that may have impacted the outcome
of the election in multiple States, including the State ofGeorgia," said statement being within the
jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of
Investigation, departments and agencies of state government, and county and city law
enforcement agencies;
And on or about the 28th day ofDecember 2020, JEFFREY BOSSERT CLARK sent
an e-mail to Acting United States Attorney General Jeffrey Rosen and Acting United States
Deputy Attorney General Richard Donoghue and requested authorization to send said false
writing and document to Georgia Governor Brian Kemp, Speaker of the Georgia House of
Representatives David Ralston, and President Pro Tempore of the Georgia Senate Butch Miller,
which constitutes a substantial step toward the commission of False Statements and Writings,
O.C.G.A. § 16-1020. This was an act of racketeering activity under O.C.G.A. § 16-14-
3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.
45'
Act 99.
On or about the 28th day 0fDecember 2020, JEFFREY BOSSERT CLARK solicited
Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney
General Richard Donoghue to sign and send a document that falsely stated that the United States
Department of Justice had "identified significant concerns that may have impacted the outcome
of the election in multiple States, including the State ofGeorgia," to Georgia Governor Brian
Kemp, Speaker of the Georgia House of Representatives David Ralston, and President Pro
Tempore of the Georgia Senate Butch Miller. This was an overt act in furtherance of the
conspiracy.
Act 100.
On or about the 30th day ofDecember 2020, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account @RealDonaldTrump, "Hearings from Atlanta on the Georgia
Election overturn now being broadcast. Check it out. @OANN @newsmax and many more.
@BrianKempGA should resign from office. He is an obstructionist who refuses to admit that we
won Georgia, BIG! Also won the other Swing States." This was an overt act in furtherance of the
conspiracy.
Act 101.
On or about the 30th day ofDecember 2020, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account @RealDonaldTrump, "Hearings from Atlanta on the Georgia
Election overturn now being broadcast LIVE via @RSBNetwork! https://t.co/ogBvaKfqG."
This was an overt act in furtherance of the conspiracy.
Act 102
On or about the 30th day 0fDecember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI, RAY STALLINGS SMITH III, and ROBERT DAVID CHEELEY committed
the felony ofiense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER,
in violation ofO.C.G.A. §§ 16-4-7 & 16-10-1, in Fulton County, Georgia, by soliciting,
requesting, and importuning certain public officers then serving as elected members of the
Georgia Senate and present at a Senate Judiciary Subcommittee meeting, including unindicted
co-conspirator Individual 8, whose identity is known to the Grand Jury, Senators Brandon Beach,
Bill Heath, William Ligon, Michael Rhett, and Blake Tillery, to engage in conduct constituting
the felony ofiense ofViolation ofOath by Public Ofiicer, O.C.G.A. § l6-lO-l, by unlawfully
appointing presidential electors from the State ofGeorgia, in willful and intentional violation of
the terms of the oath of said persons as prescribed by law, with intent that said persons engage in
said conduct. This was an overt act in furtherance of the conspiracy.
46
Act 103.
On or about the 30th day ofDecember 2020, RUDOLPHWILLIAM LOUIS
GIULIANI committed the felony offense ofFALSE STATEMENTS ANDWRITINGS, in
Violation of 0.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly, willfully, and
unlawfully making at least one of the following false statements and representations to members
of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:
l. That Fulton County election workers fiaudulently counted certain ballots as many
as five times at State Farm Arena on November 3, 2020;
2. That 2,560 felons voted illegally in the November 3, 2020, presidential election in
Georgia;
3. That 10,315 dead people voted in the November 3, 2020, presidential election in
Georgia;
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and
the Georgia Bureau of Investigation, departments and agencies of state government, and county
and city law enforcement agencies. This was an act of racketeering activity under 0.C.G.A. § 16-
14-3 (5)(A)(xxii) and an overt aCt in furtherance of the conspiracy.
Act 104
On or about the 30th day ofDecember 2020, RAY STALLINGS SMITH III
committed the felony offense of FALSE STATEMENTS ANDWRITINGS, in violation of
0.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfillly
making at least one of thefollowing false statements and representations to members of the
Georgia Senate present at a Senate Judiciary Subcommittee meeting:
1. That Georgia Secretary of State General Counsel Ryan Germany stated that his
office had sent letters to 8,000 people who voted illegally in the November 3,
2020, presidential election and told them not to vote in the January 5, 2021, runofl'
election;
2. That the Georgia Secretary of State admitted "that they had a 90% accuracy rate"
in the November 3, 2020, presidential election and that "there's still a 10% margin
that's not accurate";
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and
the Georgia Bureau of Investigation, departments and agencies of state government, and county
and city law enforcement agencies. This was an act of racketeering activity under 0.C.G.A. § l6-
l43 (5)(A)(xxii) and an overt act in furtherance of the conspiracy.
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Act105-
On or about the 30th day ofDecember 2020, ROBERT DAVID CHEELEY committed
the felony offense of FALSE STATEMENTS ANDWRITINGS, in Violation ofO.C.G.A. §
16-10-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfillly making at least
one of the following false statements and representations to members of the Georgia Senate
present at a Senate Judiciary Subcommittee meeting:
1. That poll watchers and media at State Farm Arena were told late in the evening of
November 3, 2020, that the vote count was being suspended until the next
morning and to go home because of "a major watermain break";
2. That Fulton County election workers at State Farm Arena "voted" the same
ballots "over and over again" on November 3, 2020;
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and
the Georgia Bureau of Investigation, departments and agencies of state government, and county
and city law enforcement agencies. This was an act of racketeering activity under O.C.G.A. § l6
14-3 (5)(A)(xxii) and an overt act in furtherance of the conspiracy.
Act 106.
On or about the 30th day ofDecember 2020, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account @RealDonaldTrump, "We now have far more votes than
needed to flip Georgia in the Presidential race. Massive VOTER FRAUD took place. Thank you
to the Georgia Legislature for today's revealing meeting!" This was an overt act in furtherance of
the conspiracy.
Act107-
On or about the 3lst day ofDecember 2020, JENNA LYNN ELLIS wrote a
memorandum titled "Memorandum Re: Constitutional Analysis 0fVice President Authority for
January 6, 2021 Electoral College Vote Count" to DONALD JOHN TRUMP. The
memorandum outlined a strategy for disrupting and delaying the joint session of Congress on
January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and
qualified presidential electors from Georgia and the other states, and stated, "the Vice President
should therefore not open any of the votes" from six states, including Georgia, that were falsely
characterized as having "electoral delegates in dispute." This was an overt act in furtherance of
the conspiracy.
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Act 108.
On or about the 31st day ofDecember 2020, DONALD JOHN TRUNIP and JOHN
CHARLES EASTMAN committed the felony offense ofFILING FALSE DOCUMENTS, in
violation ofO.C.G.A. § 16-10-20.1(b)(1), in Fulton County, Georgia, by knowingly filing a
document titled "VERIFIED COMPLAINT FOR EMERGENCY INJUNCTIVE AND
DECLARATORY RELIEF" in the matter ofTrump V. Kemp, Case 1:20cv05310-MHC, in the
United States District Court for the Northern District ofGeorgia, a court of the United States
having reason to know that said document contained at least one of the following materially false
statements:
l. That "as many as 2,506 felons with an uncompleted sentence" voted illegally in the
November 3, 2020, presidential election in Georgia;
2. That "at least 66,247 underage" people voted illegally in the November 3, 2020,
presidential election in Georgia;
3. That "at least 2,423 individuals" voted illegally in the November 3, 2020, presidential
election in Georgia "who were not listed in the State's records as having been registered
to vote";
4. That "at least 1,043 individuals" voted illegally in the November 3, 2020, presidential
election "who had illegally registered to vote using a postal office box as their
habitation";
-
5. That "as many as 10,315 or more" dead people voted in the November 3, 2020,
presidential election in Georgia;
6. That "[d]eliberate misinformation was used to instruct Republican poll watchers and
members of the press to leave the premises for the night at approximately 10:00 p.m. on
November 3, 2020" at State Farm Arena in Fulton County, Georgia;
Earlier on the same day, JOHN CHARLES EASTMAN sent an email to attorneys associated
with the Trump Campaign admitting his knowledge that at least some of the allegations in the
verified complaint were not accurate. This filing was an act of racketeering activity under
O.C.G.A. § 16-14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.
Act 109.
On or about the lst day of January 2021, KENNETH JOHN CHESEBRO sent an e
mail to JOHN CHARLES EASTMAN and unindicted co-conspirator Individual 3, whose
identity is known to the Grand Jury. In the e-mail, KENNETH JOHN CHESEBRO outlined a
strategy for disrupting and delaying the joint session of Congress on January 6, 2021, the day
prescribed by law for counting votes cast by the duly elected and qualified presidential electors
from Georgia and the other states. This was an overt act in furtherance of the conspiracy.
49
Act 110.
On or about the 2nd day 0f January 2021, SCOTT GRAHAM HALL, a Georgia bail
bondsman, placed a telephone call to JEFFREY BOSSERT CLARK and discussed the
November 3, 2020, presidential election in Georgia. The telephone call was 63 minutes in
duration. This was an overt act in furtherance of the conspiracy.
Act 111.
On or about the 2nd day 0f January 2021, JEFFREY BOSSERT CLARK solicited
Acting United States Attorney General Jefi'rey Rosen andActing United States Deputy Attorney
General Richard Donoghue to sign and send a document that falsely stated that the United States
Department of Justice had "identified significant concerns that may have impacted the outcome
of the election in multiple States, including the State ofGeorgia," to Georgia Governor Brian
Kemp, Speaker of the Georgia House of Representatives David Ralston, and President Pro
Tempore of the Georgia Senate Butch Miller. This was an overt act in furtherance of the
conspiracy.
Act 112.
On or about the 2nd day 0f January 2021, DONALD JOHN TRUMP andMARK
RANDALLMEADOWS committed the felony offense of SOLICITATION OF VIOLATION
OF OATH BY PUBLIC OFFICER, in violation ofO.C.G.A. §§ 16-4-7 & 16-10-1, in Fulton
County, Georgia, by unlawfully soliciting, requesting, and importuning Georgia Secretary of
State Brad Raffensperger, a public officer, to engage in conduct constituting the felony offense of
Violation of Oath by Public Ofiicer, O.C.G.A. § 16-10-1, by unlawfully altering, unlawfully
adjusting, and otherwise unlawfully influencing the certified returns for presidential electors for
the November 3, 2020, presidential election in Georgia, in willful and intentional violation of the
terms of the oath of said person as prescribed by law, with intent that said person engage in said
conduct. This was an overt act in furtherance of the conspiracy.
50
Act 113.
On or about the 2nd day of January 2021, DONALD JOHN TRUMP committed the
felony offense ofFALSE STATEMENTS ANDWRITINGS, in violation ofO.C.G.A. § 16-
10-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of
the following false statements and representations to Georgia Secretary of State Brad
Raffensperger, Georgia Deputy Secretary of State Jordan Fuchs, and Georgia Secretary of State
General Counsel Ryan Germany:
l. That anywhere from 250,000 to 300,000 ballots were dropped mysteriously
into the rolls in the November 3, 2020, presidential election in Georgia;
2. That thousands ofpeople attempted to vote in the November 3, 2020,
presidential election in Georgia and were told they could not because a ballot
had already been cast in their name;
3. That 4,502 people voted in the November 3, 2020, presidential election in
Georgia who were not on the voter registration list;
4. That 904 people voted in the November 3, 2020, presidential election in
Georgia who were registered at an address that was a post office box;
5. That Ruby Freeman was a.professional vote scammer and a known political
operative;
6. That Ruby Freeman, her daughter, and others were responsible for
fraudulently awarding at least 18,000 ballots to Joseph R. Biden at State Farm
Arena in the November 3, 2020, presidential election in Georgia;
7. That close to 5,000 dead people voted in the November 3, 2020, presidential
election in Georgia;
8. That 139% ofpeople voted in the November 3, 2020, presidential election in
Detroit;
9. That 200,000 more votes were recorded than the number ofpeople who voted
in the November 3, 2020, presidential election in Pennsylvania;
10. That thousands of dead people voted in the November 3, 2020, presidential
election in Michigan;
l l. That Ruby Freeman stufi'ed the ballot boxes;
12. That hundreds of thousands of ballots had been "dumped" into Fulton County
and another county adjacent to Fulton County in the November 3, 2020,
presidential election in Georgia;
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13. That he won the November 3, 2020, presidential election in Georgia by
400,000 votes;
said statements being within the jurisdiction of the Ofiice of the Georgia Secretary of State and
the Georgia Bureau of Investigation, departments and agencies of state government. This was an
act of racketeering activity under O.C.G.A. § 16-14-3 (5)(A)(xxii) and an overt act in furtherance
of the conspiracy.
Act 114.
On or about the 3rd day of January 2021, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account @RealDonaldTrump, "I spoke to Secretary of State Brad
Rafiensperger yesterday about Fulton County and voter fraud in Georgia. He was unwilling, or
unable, to answer questions such as the 'ballots under table' scam, ballot destruction, out of state
'voters', dead voters, and more. He has no clue!" This was an overt act in furtherance of the
conspiracy.
52
ALIS.-
On or about the 3rd day of January 2021, STEPHEN CLIFFGARD LEE,
HARRISONWILLIAM PRESCOTT FLOYD, and TREVIAN C. KUTTI placedmultiple
telephone calls and sent text messages to each other and to other individuals involved in the
conspiracy. They include the following:
l. At 7:48 p.m., HARRISONWILLIAM PRESCOTT FLOYD placed a telephone
call to Ruby Freeman, a Fulton County, Georgia, election worker, that was
unsuccessful.
2. At 7:49 p.m., HARRISONWILLIAM PRESCOTT FLOYD placed a telephone
call to Ruby Freeman that was unsuccessful.
3. At 7:49 p.m., HARRISONWILLIAM PRESCOTT FLOYD placed a telephone
call to TREVIAN C. KUTTI.
4. At 7:53 p.m., HARRISONWILLIAM PRESCOTT FLOYD sent a text message to
Ruby Freeman.
5. At 8:03 p.m., TREVIAN C. KUTTI placed a telephone call to HARRISON
WILLIAM PRESCOTT FLOYD.
6. At 8:11 p.m., HARRISONWILLIAM PRESCOTT FLOYD placed a telephone
call to unindicted co-conspirator Individual 23, who'se identity is known to the Grand
Jury.
7. At 8:18 p.m., HARRISONWILLIAM PRESCOTT FLOYD placed a telephone
call to STEPHEN CLIFFGARD LEE.
8. At 8:48 p.m., HARRISONWILLIAM PRESCOTT FLOYD placed a telephone
call to TREVIAN C. KUTTI.
9. At 9:16 p.m., HARRISONWILLIAM PRESCOTT FLOYD placed a telephone
call to TREVIAN C. KUTTI.
'
10. At 9:33 p.m., HARRISONWILLIAM PRESCOTT FLOYD placed a telephone
call to TREVIAN C. KUTTI.
11. At 9:50 p.m., HARRISONWILLIAM PRESCOTT FLOYD placed a telephone
call to STEPHEN CLIFFGARD LEE.
These were overt acts in furtherance of the conspiracy.
53