PlainSite :: The State of Georgia v. Donald John Trump, Case No. 23SC188947 Document 1: Criminal Indictment

Page 1 Fulton
Fulton County
Superior
Colinty Superior Court
Court
wrlepech
CA
**F|LED**
INDICTMENT
INDICTMENT
oo
,
Date:
Date: August
14, August 14,
Che Alexander,
Clerk of
of Court
Court
Che
Alexander, Clerk

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£375Maker
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BISSMClerk No.
No.
COURT
FULTON
SUPERIOR COURT
FULTON SUPERIOR
THE STATE OF GEORGIA
‘THE

V.
v.
TRUMP
DONALD JOHN
JOHN TRUMP
DONALD
Couhts 1,5,
15, 17,
19,
Counts
1,5,9,9, 11,
11, 13,
13,15,
17,19,
38-2729,
21.29,WILLIAM LOUIS
RUDOLPH WILLIAM
RUDOLPH
LOUIS
GIULIANI
GIULIANI
Counts 1-3,
Counts
13, 67,9,
11, 13,15, 17, 19,
6-7, 9,11,13,15,17,19,
CI-MRLES EASTMAN
JOHN CHARLES
JOHN
EASTMAN
23-
VIOLATION OF THE GEORGIA RICO
CORRUPT
AND CORRUPT
INFLUENCED AND
(RACKETEER
(RACKETEER INFLUENCED
ORGANIZATIONS)
ACT
ACT
ORGANIZATIONS)
O.C.G.A.
O.CG.A. §§ 16144(c)
16-14-4(c)
2 SOLICITATION
SOLICITATION OF
OF OATH
VIOLATION OF
OF VIOLATION
OATH
BY
PUBLIC OFFICER
OFFICER
BY PUBLIC

O.C.G.A.
OCGA. §§
164-7 &
& 1640-16-10-§§ 164-
FALSE STATEMENTS AND WRITINGS
OCGA.
O.C.G.A.
§§ 16-10-16-
MARK
MARK RANDALL
RANDALL MEADOWS
MEADOWS
Counts 1,Counts
WRITINGS
4 FALSE
AND WRITINGS
FALSE STATEMENTS
STATEMENTS AND
OCGA
1610-O.C.G.A. §OF OATH
SOLICITATION OF
5 SOLICITATION
OF VIOLATION
VIOLATION OF
OATH
BY
PUBLIC OFFICER
BY PUBLIC
OFFICER
OCGA.
§§ 16-416-&16-10-& 1610O.C.G.A. §§
KENNETH JOHN CHESEBRO

Counts
Counts 1-2,
12,9,
11,13, 15,
17, 19,
19,15, 17,
9, 11,13,
1,
Counts 1,
Counts
1,9,9,11,13,15,17,11,13, 15, 17,
JEFFREY BOSSERT CLARK
JEFFREY
Counts 1,
Counts
1,
§
OF OATH
OF VIOLATION
SOLICITATION OF
SOLICITATION
VIOLATION OF
OATH
BY
PUBLIC OFFICER
OFFICER
BY PUBLIC
O.C.G.A. §§
OCGA.
164-7 && 1610-16-10-§§ 164-
WRITINGS
FALSE
STATEMENTS AND
FALSE STATEMENTS
AND WRITINGS
O.C.G.A. §§ 16102'O.CG.A.
16-10-
LYNN ELLIS
JENNA LYNN
JENNA
ELLIS
Counts 11-
SNIITH III
III
STALLINGS SMITH
RAY STALLINGS
RAY
Counts 12,4,6,9,
1-2, 4, 6, 9, 11,
13,15, 17,19,
Counts
11,13,15,17,19,
TO COMMIT
COMMIT
9 CONSPIRACY
CONSPIRACY TO
CHEELEY
DAVID CHEELEY
ROBERT DAVID
ROBERT
Counts 1,9,11,13,15,17,19,23,26,
Counts
9,11,13, 15, 17,19, 23, 26,
l0 FORGERY
IN THE FIRST
FORGERY
INTHE
FIRST DEGREE
DEGREE
23, 2,
a
1,

MICHAEL A. ROMAN
Counts 1, 9, 11,13,15,17,
Counts1,9,
11,13, 15,17,
DAVID JAMES
SHAFER
DAVID
JAMES SHAFER
Counts 1,8,10,
Counts
12, 14, 16, 18, 8,10,12,14,16,18,
1,
A PUBLIC OFFICER
IMPERSONATING
IMPERSONATING
A
O.C.G.A.
OCGA. §16-§ 16-10GA
A PUBLIC
INIPERSONATIN
IMPERSONATING
PUBLIC OFFICER
OFFICER
&
16-10-O.C.G.A.
164-OCGA. §§
§§ 16-4-8 & 16-10-
O.C.G.A. §169-1(b)
§ 169-1(b)
OCGA.

To COMMIT
CONSPIRACY TO
FORGERYINTHE FIRST DEGREE
DEGREE
FORGERY 1N THE FIRST
O.C.G.A. §§
OCGA.
§§ 16-4164-&& 16-9-1(b)
16-9-1(b)

Page 2 WRITINGS
FALSE STATEMENTS
SHAWN MCAH TRESHER STILL
A
—
STEPHEN CLIFFGARD LEE
CONSPIRACY TO
SEOENCUNGIDLE
15 CONSPIRACYTOCONMIT
WRITINGS
STATEMENTS
FALSE
BRERA
SE
mes
HARRISON
PRESCOTT
HARRISON WILLIAM
WILLIAMPRESCOTT
CRWAL ATTEMPT To COMMIT
FLOYD
Emma FALSE DOCUMENTS
Tear)
KUTTI
TREVIAN C.KUTTI
REvIAN
CONSPIRACY TO COMMIT
Emma
FALSE DOCUMENTS
Ea
socom
SIDNEY KATHERINE POWELL
AND

Counts 1,
Counts
1,8,
10, 12,
12, 14,
14,16,
8, 10,
16,
O.C.G.A. § 16-10OCGA.§
16-10-
COMlWIT
AND
& 1610O.C.G.A.
OCGA. §§
16-4-8 &
16-10-§§ 164
CRIMINAL ATTEMPT TO COMMIT
FILING FALSE DOCUMENTS
O.C.G.A. §§ 1641 & 16102o.1(b)(1)
Counts 1, 20-21, 30-
FLOYD
Counts 1,30-Counts
1, 30
C.
Counts 1, 30
SIDNEY KATHERINE POWELL
Counts 1,32:Counts
1, 32-
CATHLEEN ALSTON LATHAM
'CATHLEEN
Counts 1, 8, 10, 12, 14, 32-SCOTT GRAHAM
SCOTT
GRAHAM HALL
32-Counts 1,
Couns
1, 32:
O.C.G.A.
OCGA. §§
16-4-8 & 16-10-20.1(b)(1)
16102o.1(b)(1)
§§ 164-
FORGERY IN THE FIRST DEGREE
O.C.G.A.
0.CGA. §§16-9-1(b)
16-9-1(b)
CONSPIRACY TO COMMIT
ST—
THE FIRST
m THE
FORGERY IN
FORGERY
FIRST DEGREE
DEGREE
.
I—
TwiNMoNvaAYEs
Pane
MISTY HAMPTON
AKA EMILY MISTY HAYES
& 1691(b)
16-48 &
O.C.G.A. §§
OCGA.
§§ 164-16-9-1(b)
WRITINGS
STATEMENTS
18 FALSE
FALSESTATEMENTSANDWRITINGS
AND

O_C_G_A. § 16_10_
Counts 1, 32-
CONSPIRACY TO
iEB
neves
COMlVIIT
CONSPIRACY
TO COMMIT
FALSE STATEMENTS AND WRITINGS
& 16-10-O.C.G.A.
0.CG.A. §§
16-4-8 &
16-10-§§ 16-4-
CRIMINAL ATTEMPT TO COMMIT
INFLUENCING
INFLUENCING WITNESSES
WITNESSES
O.C.G.A.
OCGA. §§
164-1 & 161093(b)(1)(A)
16-10-93(b)(1XA)
§§ 16-4
TO COMMIT
CRIMINAL ATTEMPT
ATTEMPTTO
INFLUENCUYG WITNESSES
ms
O.C.G.A. §§
OCGA
16-41 & 16-10-93(b)(1)(A)
16-10-93BX1)A)
§§ 16-4-1&
FALSE STATEMENTS
me
BE
,mums
OF VIOLATION OFONE
OF OATH
SOLICITATIONCrVIOLATION
2 SOTTO
BY PUBLIC OFFICER
mE
DE
STATENIENTSANDWRITINGS
WRITINGS
24 FALSE
FALSE STATEMENTS
STATEMENTS AND WRITINGS
25 FALSE
FALSE
STATEMENTS
WRITINGS
ERATE
CRIMINAL ATTEMPT
ATTEMPT TO COMMIT
CRIMINAL
AND
O.C.G.A. §§
16-4
&
1610
O.C.G.A. §§ 16-47 & 16-10-
AND

O.C.G.A.
§ 16-10
AND

O.C.G.A.

'
§ 161020

Page 3 WRITINGS
STATEMENTS AND
26 FALSE
FALSE STATEMENTS
AND WRITINGS
16-10-O.C.G.A.
0CGA§§ 16-27 FILING
FILING FALSE
FALSE DOCUMENTS
DOCUMENTS
O.C.G.A.
0.CGA.§§ 16-1020.1(b)(1)
16-10-20.1(bX1)
OF VIOLATION
VIOLATION OF
OATH
28 SOLICITATION
SOLICITATION OF
OF OATH
OFFICER
BY
PUBLIC OFFICER
BY PUBLIC
O.C.G.A.
OCGA. §§
164-7 && 16-10-16-10-§§ 164-STATEMENTS AND
29 FALSE
FALSE STATEMENTS
AND WRITINGS
WRITINGS
16-10-OCGA.
O.C.G.A. §§ 16-COMlVIIT SOLICITATION
SOLICITATION OF
CONSPIRACY TO
30 CONSPIRACY
TO COMMIT
OF
AND
STATEMENTS
WRITINGS
FALSE
FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§
OCGA.
§§ 164-8,
16-4-&& 16-10-16-10-16-4-8, 16-4-WITNESSES
31 INFLUENcmG
INFLUENCING WITNESSES
O.C.G.A. §§ 161093(b)(1)(A)
OCGA.
16-10-93bX1)A)
TO COMMIT
COMMIT ELECTION
FRAUD
CONSPIRACY TO
32 CONSPIRACY
ELECTION FRAUD
21-2&
21-2-O.C.G.A. §§
OCGA.
§§212:603 & 212-TO CONIMIT ELECTION
CONSPIRACYTOCOMMIT
33 CONSPIRACY
ELECTION FRAUD
FRAUD
21-2-O.C.G.A. §§21-2:OCGA
& 212-§§ 21-2-603 &
COMMIT
CONSPIRACY TO
To COMMIT
34 CONSPIRACY
THEFT
COMPUTER
COMPUTER THEFT
O.C.G.A. §§
169-932)
164-8 && 16993(a)
OCGA
§§ 164TO COMlVIIT
CONSPIRACY TO
35 CONSPIRACY
COMMIT
COMPUTER TRESPASS
COMPUTER
TRESPASS
O.C.G.A.
O.CGA §§
164-8 && 16-9-93(b)
16:9-93(6)
§§ 16-4-TO COMIVIIT
36 CONSPIRACY
CONSPIRACY TO
COMMIT
PRIVACY
COMPUTER
COMPUTER INVASION
INVASION OF
OF PRIVACY
O.C.G.A. §§
OCGA.
164-&& 169-93(c)
16:9:93(c)
§§ 16-4-DEFRAUD THE
TIE STATE
STATE
37 CONSPIRACY
CONSPIRACY TO
TO DEFRAUD
O.C.G.A. §§ 16-10OCGA
16-OATH
38 SOLICITATION
SOLICITATION OF
OF VIOLATION
VIOLATION OF
OF OATH
BY
PUBLIC
OFFICER
BY PUBLIC OFFICER
& 1610O.C.G.A. §§
16-47 &
OCGA
§§ 16-16-10-39 FALSE
FALSE STATEMENTS
STATEMENTS AND
AND WRITINGS
WRITINGS
O.C.G.A. §§ 16-10OCGA.
16:10:STATEMENTS AND
40 FALSE
FALSE STATEMENTS
AND WRITINGS
WRITINGS
O.C.G.A. § 1610OCGA.§
16:10:

Page 4 si PERJURY
PERIURY
o.c.G.A. § 161070(a)
OCGA.
16-10-70)

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day of
,

Page 8 ‘The
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,

Page 9 OF FULTON
STATE
OF GEORGIA,
COUNTY OF
STATE OF
FULTON
GEORGIA, COUNTY
SAID COUNTY
IN THE
COURT OF
OF SAID
COUNTY
IN
THE SUPERIOR
SUPERIOR COURT
of Fulton,
sworn for the County
wit:
Fulton, toto wit:
THE GRAND
GRAND JURORS,
and swornforthe
chosen, and
THE
County of
JURORS, selected,
selected, chosen,
ROBERTWES, Foreperson
2 ASHUEYMEL StF
Ser
Fool
At.Sc.
JULIA
JOUDECRG,
5 ene ARioL.
sown
ome
&7.c0L00K
CAROL
810 Gow
vos wor
So BReNOA KARTHus0H
32ATONETTE
Leu
MAX oer
a wax
1. ROBERT WELLS, Foreperson
2. ASHLEY MELVIN, Asst. FP
4.
DECREDICO, Asst. Sec.
5. ERLE ARNOLD
6. DANIELLE BROWN
DICK
7.
8. KATHY GOLD
9. WILLIS HARDY
10. BRENDA HART
11. ANTIONETI'E HUDSON
12. lLE LIN
MORTENSEN
13.

GREGORYPETRA
10.GREGORY
JENIFERPRICE
15 JENNIFER
GEORGE PAGE
16 GroRSe
PULAVARTY
PAVAN PULAVATY
7 VAN
SARE
38 FRANEEN
JOHN
EMMA
JOHN
EAST
15. VLADIMIR
TCHAKAROV
20 VORTORO
21 coomCTRCE
esmuenuoon
= MARCUS
WeLsoRN
5 MARCUS WELBORN
“TESTO
25 amieen cen
SCASTORERSTTON.
PETRALIA
14.
PRICE
15.
PRINGLE
16.
17.
18. FRANEEN SARIF
ST.
19.
20.
21. CEDRIC TRICE
22. ESTHER UDOJI
23.
25. KATHLEEN CHEN

Page 10 TABLE OF
CONTENTS
TABLE
OF CONTENTS
THE GEORGIA
GEORGIA RICO
OF THE
COUNT 1: VIOLATION
COUNT:
VIOLATION OF
RICO
AND
CORRUPT
INFLUENCED
(RACKETEER
INFLUENCED
AND
CORRUPT ORGANIZATIONS)
ACT
ORGANIZATIONS) ACT
(RACKETEER
CEB
UMAR mmmmemmmmmmmmmmmmm——O.C.G.A. § 16-14-4(c)
Introduction
mm——————————"_—
JORG
The Enterprise
Ly
— Manner and Methods of the Enterprise
and Overt
Overt Acts
of the
Acts
of Racketeering
Racketeering Activity
Activity and
Acts inin Furtherance
Furtheranceofthe
Acts of
EE
A
—. Conspiracy
OFFICER
OF VIOLATION
PUBLIC OFFICER
COUNT 2: SOLICITATION
SOLICITATION OF
COUNT2:
VIOLATION OF
OF OATH
OATH BY
BY PUBLIC
16-10-&
OCGA.
&
16-sss
16-4-O.C.G.A. §§
§§
COUNT3:
FALSE STATEMENTS
STATEMENTS AND
AND WRITINGS
WRITINGS
COUNT 3: FALSE
OLA
O.C.G.A. SUNDrsmsmmmmmmammmmmmmmmmmnonsill
§ 16-10-COUNT
COUNT4:4: FALSE
FALSE STATEMENTS
STATEMENTS AND
AND WRITINGS
WRITINGS
OCGA §§ 16-10-20.
wll
16-10-O.C.G.A.
OATH BY
OF VIOLATION
COUNTS:5: SOLICITATION
SOLICITATION OF
VIOLATION OF
OF OATH
BY PUBLIC
PUBLIC OFFICER,
COUNT
OFFICER,
&
1610164-O.C.G.A.
OCGA. $16-&
16-WhLcressmmrmmensmemasssnsn
Th
§§
OFFICER
OF OATH
OATH BY
OF VIOLATION
COUNT
COUNTG:6: SOLICITATION
SOLICITATION OF
VIOLATION OF
BY PUBLIC
PUBLIC OFFICER
&
16-10-O.CG.A. §§
1647& 16-10-nm—
omni
O.C.G.A.
§§ 16-4-WRITINGS
FALSE STATEMENTS
STATEMENTS AND
COUNT
COUNT7:7: FALSE
AND WRITINGS
O.C.G.A.
O.C.GA§§ 16-10-16-10-20.
OFFICER
COUNT
COUNTS:8: IMPERSONATING
IMPERSONATING AA PUBLIC
PUBLIC OFFICER
1610-OLOA
mms
O.C.G.A. §SAND
OFFICER
TO COMMIT
PUBLIC OFFICER
IMPERSONATING AA PUBLIC
COUNT 9: CONSPIRACY
CONSPIRACY TO
COMMIT IMPERSONATING
COUNT:
O.C.G.A. §§
OCOA.
$8 16-4-16-48 && 16-10-16-10-THE FIRST
COUNT 10:
COUNT
10: FORGERY
FORGERY IN
IN THE
FIRST DEGREE
DEGREE
O.C.G.A. § 16-9-1(b)
OCBAL
ULB mmmmmmminmimmimmmimmmssmisisiTl
FORGERY IN
THE FIRST
To COMMIT
COUNT 11:
1: CONSPIRACY
COMMIT FORGERY
IN THE
FIRST DEGREE
DEGREE
COUNT
CONSPIRACY TO
O.C.G.A. SSL
CORA
HB UB mmmmmmmmmsmmmmmmmmnintT]
§§ 1648 & 16-91(b)
AND WRITINGS
STATEMENTS AND
COUNT 12:
COUNT
12: FALSE
FALSE STATEMENTS
WRITINGS
O.C.G.A.
ORAL§ 16-101A arms TE
COMMIT FALSE
TO COMMIT
STATEMENTS AND
CONSPIRACY TO
COUNT l3:
COUNT
13: CONSPIRACY
FALSE STATEMENTS
AND WRITINGS
WRITINGS
& 16-1020 mmm
O.C.G.A. SSIES
OLBA
ds
§§ 16-4-8 LI6I0B

Page 11 FILING FALSE
To COMMIT
ATTEMPT TO
DOCUMENTS
FALSE DOCUMENTS
CRIMINAL ATTEMPT
COMMIT FILING
COUNle
14: CRIMINAL
COUNT
&
164-A.
0.C.G.A.
16-1020.1b)(1)
&
§§ 164-1 16-1020.1(b)(1)
OCGA. §§
DOCUMENTS
TO COMMIT
COMMIT FILING
FALSE DOCUMENTS
CONSPIRACYTO
FILING FALSE
COUNTli
15: CONSPIRACY
COUNT
&
16-4-O.C.G.A.
1(b)(1) crn
& 16-10-20.
§§ 164-O.C.G.A. §§
16-10-20.1(b)(1)
IN THE
COUNT
16: FORGERY
FORGERY IN
THE FIRST
FIRST DEGREE
DEGREE
COUNT1&
O.C.G.A.
169-1(b) rrr
OCGA. §§ 16-9-1(b)
DEGREE
THE FIRST
TO COMMIT
FIRST DEGREE
IN THE
FORGERY IN
COUNT1%
COMMIT FORGERY
TO
CONSPIRACY
17: CONSPIRACY
COUNT
sss
16-48 &
& 16-910)
O.C.G.A. §§
§§ 16-OCGA.
16-91(b)
WRITINGS
STATEMENTS AND
COUNT1&
AND WRITINGS
FALSE STATEMENTS
18: FALSE
COUNT
16-10-O.C.G.A. §§ 16-10-OCGA
AND WRITINGS
WRITINGS
FALSE STATEMENTS
STATEMENTS AND
CONSPIRACY TO
COUNT 19:
19 CONSPIRACY
COMMIT FALSE
TO COMMIT
COUNT
O.C.G.A. §§
16-10-20...
164-8 && 16-10§§ 164-OCGA.
TO COMMIT
INFLUENCING WITNESSES
WITNESSES
CRIMINAL ATTEMPT TO
COMMIT INFLUENCING
COUNTZm
20: CRIMINALATTEMPT
COUNT
&
164O.C.G.A. §§
rrr
16-10-93BYINAY
&
164-O.C.G.A.
16-1093(b)(1)(A)
§§
WITNESSES
COMMIT INFLUENCING
TO COMMIT
CRIMINAL ATTEMPT
COUNTZh
INFLUENCING WITNESSES
ATTEMPT TO
21: CRIMINAL
COUNT
16-4-rrr
O.C.G.A. §§
16-10:93D)1NA)
OCGA.
&16-10-93(b)(1)(A)
§§ 16-41 &
TO COMMIT
COMMIT
CRIMINAL ATTEMPT
COUNT22:
ATTEMPT TO
COUNT 22: CRIMINAL
FALSE
FALSE STATEMENTS
STATEMENTS AND
AND WRITINGS
WRITINGS
&
1610164OCGA.
164-&
16-10-20.
ami}
O.C.G.A. §§
§§
OFFICER
PUBLIC OFFICER
OF VIOLATION
BY PUBLIC
OATH BY
OF OATH
VIOLATION OF
C0UNT2$
SOLICITATION OF
23: SOLICITATION
COUNT
&
1610O.C.G.A.
& 16-10-OCGA. §§
§§ 164STATEMENTS AND
WRITINGS
AND WRITINGS
COUNTzm
FALSE STATEMENTS
24: FALSE
COUNT
nh
——————————
O.C.G.A.
16-10-20...
OCGA. §§ 16-10-WRITINGS
STATEMENTS AND
COUNT25: FALSE
FALSE STATEMENTS
AND WRITINGS
'COUNT2&
O.C.GA§§ 161016-1020.
O.C.G.A.
WRITINGS
FALSE STATEMENTSAND
STATEMENTS AND WRITINGS
26: FALSE
COUNT
COUNT2&
JOC NT
————— 16-10-O.C.G.A.
§
>
FALSE DOCUMENTS
DOCUMENTS
COUNTzn
FILING FALSE
27: FILING
COUNT
OCGA BIGADMIN
O.C.G.A.
§ 161020.1(b)(1) ssn
OFFICER
OF OATH
SOLICITATION OF
PUBLIC OFFICER
BY PUBLIC
OATH BY
COUNT 28:
VIOLATION OF
OF VIOLATION
28: SOLICITATION
COUNT
O.C.GA. §§
1647 && 1610-§§ 16-416-10-L
msm
O.C.G.A.
i

Page 12 WRITINGS
STATEMENTS AND
29: FALSE
COUNT
COUNT29:
FALSE STATEMENTS
AND WRITINGS
VSL nummer
OF
COMMIT SOLICITATION
CONSPIRACY TO
SOLICITATION OF
COUNT 30:
TO COMMIT
30: CONSPIRACY
COUNT
WRITINGS
FALSE STATEMENTS
STATEMENTS AND
FALSE
AND WRITINGS
O.C.G.A.
16-10-20 cosnssnsnn 164-7, && 1610-§§ 164-8,
O.C.GA. §§
16-4-8, 16-4-7,
WITNESSES
COUNT 31: INFLUENCING
COUNT31:
INFLUENCING WITNESSES
sss
O.C.G.A.
16-10-93B)(1)(A)....
0.C.G.A. §§ 1610-93(b)(1)(A)
O.C.G.A.
CORA
§ 16-10
COMMIT ELECTION
ELECTION FRAUD
CONSPIRACY TO
COUNT
TO COMMIT
FRAUD
32: CONSPIRACY
COUNT 32:
O.C.G.A. §§
§§ '21-2-21-2603 && 21-2566.rrsnsnsssnsssnsn
21-2O.C.G.A.
ELECTION FRAUD
CONSPIRACY TO
FRAUD
33: CONSPIRACY
COUNT 33:
COMMIT ELECTION
TO COMMIT
COUNT
————— O.C.G.A.
TEXPIER & 21-2IN §§ 212PY
THEFT
COMPUTER THEFT
CONSPIRACY To
COUNT
TO COMMIT
COMMIT COMPUTER
34: CONSPIRACY
COUNT 34:
&
9D
16-4-O.C.G.A. §§
corr
16-993(@)
&
164-OCGA.
16993(a)
§§
TRESPASS
COMPUTER TRESPASS
CONSPIRACY TO
35: CONSPIRACY
COUNT 35:
COMMIT COMPUTER
TO COMMIT
COUNT
164&
OCGA.
§§
164-&
16-9936)...
rmm—————
O.C.G.A. §§
16-9-93(b)
PRIVACY
TO COMMIT
COMPUTER INVASION
OF PRIVACY
INVASION OF
CONSPIRACY TO
36: CONSPIRACY
COMMIT COMPUTER
COUNT 36:
COUNT
Ih
O.C.G.A. §§
16-993(€) corr
16-48 && 16-9-93(c)
OCGA
§§ 16-4-TO DEFRAUD
THE STATE
STATE
COUNT
DEFRAUD THE
CONSPIRACY TO
37: CONSPIRACY
COUNT 37:
16-10-BLRA
O.C.G.A. SUASNm
§
OFFICER
OATH BY
OF VIOLATION
PUBLIC OFFICER
BY PUBLIC
SOLICITATION OF
OF OATH
38: SOLICITATION
COUNT 38:
VIOLATION OF
COUNT
&
OCGA.
&
16-10-16-4-1610-O.C.G.A. §§
§§
.
STATEMENTS AND
COUNT 39: FALSE
COUNT39:
FALSE STATEMENTS
AND WRITINGS
WRITINGS
O.C.G.A. §§ 16-10-1610-20...
OCGA
STATEMENTS AND
40: FALSE
COUNT 40:
FALSE STATEMENTS
AND WRITINGS
WRITINGS
COUNT
CELA LUA
ED smmmermmmmmmmssssmsssssassommnnnIl
O.C.G.A.
§ 16-10-41: PERJURY
COUNT41:
PERJURY
COUNT
O.C.G.A.
10-10TUErrsmmmsssessssssssmssmmmmmmmsmmnel
OLBAS§ 16-10-70(a)
2

Page 13 COUNT
of COUNT 11of
‘The Grand Jurors aforesaid, in the name and behalf
ofthe citizens of Georgia, do hereby
and accuse:
accuse:
charge and
charge
DONALD
JOHN TRUMP,
DONALD JOHN
TRUMP,
RUDOLPH
LOUIS
RUDOLPH WILLIAM
GIULIANI,
WILLIAM LOUIS GIULIANI,
JOHN CHARLES
JOHN
CHARLES EASTMAN,
EASTMAN,
MARK
MARK RANDALL
RANDALL MEADOWS,
MEADOWS,
KENNETH JOHN
KENNETH
JOHN CHESEBRO,
CI-IESEBRO,
JEFFREY
JEFFREY BOSSERT
BOSSERT CLARK,
CLARK,
JENNA
LYNN
JENNA LYNN ELLIS,
ELLIS,
RAY STALLINGS
STALLINGS SMITH
SMITH III,
RAY
III,
ROBERT
DAVID
ROBERT DAVID CHEELEY,
CHEELEY,
MICHAEL
MICHAEL A.
A. ROMAN,
ROMAN,
DAVID
DAVID JAMES
JAMES SHAFER,
SHAFER,
SHAWN MICAH
TRESI-IER STILL,
SHAWN
MICAH TRESHER
STILL,
STEPHEN
CLIFFGARD LEE,
STEPHEN CLIFFGARD
LEE,
HARRISON
HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD,
FLOYD,
TREVIAN C.
TREVIAN
C. KUTTI,
KUTTI,
SIDNEY
KATHERINE POWELL,
SIDNEY KATHERINE
POWELL,
CATHLEEN
CATHLEEN ALSTON
ALSTON LATHAM,
LATHAM,
SCOTT GRAHAM
and
GRAHAM HALL,
SCOTT
HALL, and
MISTY
MISTY HAMPTON
HAMPTON
the offense
offense ofVIOLATION
of VIOLATION OF
with
OF THE
TI-IE GEORGIA
RICO (RACKETEER
with the
GEORGIA RICO
(RACKETEER
AND CORRUPT
INFLUENCED
CORRUPT ORGANIZATIONS)
O.C.G.A. §§ 16-14-4(c),
the
INFLUENCED AND
ACT,
16-14-4(c), for
for the
ORGANIZATIONS) ACT, O.C.G.A.
said accused,
and as
as persons
of aa crime,
concerned in
the commission
said
individually and
persons concerned
in the
commission of
and together
together
accused, individually
crime, and
with
in
the
State
of
and
of
on
and
between
with unindicted
unindicted co-conspirators,
in
the
State
of
Georgia
and
Countyof
Fulton,
on
and
between
Fulton,
co-conspirators,
Georgia
County
the
the 15th
of September 2022,
an
the 4th
4th dayofNovember
2020 and
and the
15th day
while associated
associated with
with an
2022, while
day of November day ofSeptember
and endeavored
conduct and
and
enterprise, unlawfully
unlawfully conspired
endeavored toto conduct
and participate
participate in,
in, directly
enterprise,
conspired and
directly and
such
a
of
in
violation
of
O.C.G.A.
indirectly, such enterprise
enterprise through
through a pattern
patternofracketeering
indirectly,
racketeering activity
activity in violation of 0.C.G.A. §§
as described below
and incorporated
if ﬁllly set
set forth
16-14-4(b),asdescribed
below and
incorporated by
by reference
referenceasas iffully
16-14-4(b),
forth herein,
herein, contrary
contrary
to
of said State,
and
to the
the laws
lawsofsaid
the good
good order,
peace,
and
dignity
thereof;
State, the
thereof;
order, peace,
dignity
The Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do hereby
l3

Page 14 INTRODUCTION
INTRODUCTION
Defendant Donald John Tramp lost the United States presidential election held on
and the
Defendants
other Defendants
he lost
November 3,3, 2020.
the states
lost was
was Georgia.
Georgia. Trump
the other
2020. One
One of
of the
states he
November
Trump and
Indictment refused
charged inin this
this Indictment
refused toto accept
that Trump
and they
knowingly and
and willfully
willfully
lost, and
they knowingly
Trump lost,
accept that
charged
of Trump. That
election in
joined
conspiracy toto unlawfully
change the
the outcome
outcomeofof the
the election
in favor
favorofTrump.
That
unlawfully change
joined aa conspiracy
or more
acts of racketeering
commit two
conspiracy
common plan
plan and
purpose toto comnit
two or
more actsofracketeeting
contained aa common
and purpose
conspiracy contained
states.
of Georgia,
State of
activity
in Fulton
Fulton County,
elsewhere inin the
the State
and inin other
other states.
Georgia, and
activity in
County, Georgia,
Georgia, elsewhere
Defendant Donald John Trump lost the United States presidential election held on

Page 15 THE ENTERPRISE
THE
ENTERPRISE
as others
others not
as well as
not
the Defendants,
aswell
Defendants,
of the Indictment,
Indictment, the
Count ofthe
this Count
relevant to
to this
At
all times
times relevant
Atall
named as defendants, unlawfully conspired and endeavored to conduct and participate in a
and elsewhere.
Trump,
John Trump,
Donald John
Defendants Donald
elsewhere. Defendants
criminal enterprise
Fulton County,
in Fulton
criminal
Georgia, and
County, Georgia,
enterprise in
Kenneth John
John
Randall Meadows,
Charles Eastman,
Mark Randall
Meadows, Kenneth
Eastman, Mark
John Charles
Lous Giuliani,
William Louis
Giuliani, John
Rudolph William
Rudolph
David
Robert David
Smith III,
Ray Stallings
Ellis, Ray
Lynn Ellis,
Jenna Lynn
III, Robert
Clark, Jenna
Bossert Clark,
Jeffrey Bossert
Chescbro, Jeffrey
Stallings Smith
Chesebro,
Tresher Still,
Micah Tresher
Cliffgard
Still, Stephen
James Shafer,
Shawn Micah
Shafer, Shawn
Michael A.
David James
Stephen Cliffgard
Roman, David
A. Roman,
Cheeley, Michael
Cheeley,
Cathleen
C. Kutti,
Trevian C.
Powell, Cathleen
Katherine Powell,
Kutt, Sidney
Floyd, Trevian
Prescott Floyd,
Sidney Katherine
William Prescott
Harrison William
Lee, Harrison
Lee,
Individual l|
unindicted co-conspirators
Hampton, unindicted
Scott Graham
Hell, Misty
Alston
Graham Hall,
Latham, Scott
Alston Latham,
co-conspirators Individual
Misty Hampton,
criminal
constituted aa criminal
to the
and unknown
unknown to
Grand Jury,
the Grand
others known
known and
Individual 30,
and others
Jury, constituted
through Individual
30, and
through
activities
criminal activities
in various
related criminal
and associates
associates engaged
various related
members and
whose members
organization
engaged in
organization whose
and writings,
ofﬁcer,
statements and
impersonating aa public
limited to,
writings, impersonating
false statements
to, false
public officer,
not limited
but not
including, but
including,
theft, computer
witnesses, computer
documents, influencing
false documents,
trespass,
filing false
forgery, ﬁling
computer trespass,
computer theft,
inﬂuencing witnesses,
forgery,
and perjury.
acts involving
perjury.
to defraud
defraud the
involving theft,
the state,
of privacy, conspiracy
theft, and
state, acts
invasionofprivacy,
computer invasion
conspiracy to
computer
in O.C.G.A.
O.C.G.A. §§
deﬁned in
that term
term is
an enterprise
is defined
constituted an
as that
This
criminal organization
enterprise as
“This criminal
organization constituted
named as defendants, unlawfully conspired and endeavored to conduct and participate in a
other members
and other
The Defendants
members
of individuals
Defendants and
fact. The
associated inin fact.
individuals associated
16-14-3(3), that is, aa group
group of
and with
another and
with one
one another
and relationships
connections and
the
with the
and
associates of the enterprise
relationships with
had connections
enterprise had
and associatesofthe
and associates
whose members
associates
members and
constituted an
an ongoing
enterprise constituted
The enterprise
enterprise.
ongoing organization
organization whose
enterprise. 'The
of the
common purposeofachieving
objectivesofthe
the objectives
functioned
for aa common
unit for
continuing unit
functioned asas aa continuing
purpose of achieving the
State of
of Georgia,
elsewhere in
Georgia,
the State
in the
The enterprise
Fulton County,
in Fulton
enterprise operated
enterprise.
County, Georgia,
Georgia, elsewhere
operated in
enterprise. The
Mexico,
New Mexico,
Nevada, New
Arizona, Michigan,
to, Arizona,
limited to,
in
not limited
but not
including, but
other states,
in other
Michigan, Nevada,
states, including,
The enterprise
of Columbia.
Columbia. The
for aa
and in
enterprise operated
and Wisconsin,
Districtof
the District
in the
Wisconsin, and
Pennsylvania, and
operated for
Pennsylvania,
l6-14-3(3), that is,
and associates
associates to
its objectives.
to pursue
to permit
members and
sufﬁcient to
its members
permit its
objectives.
periodoftime
pursue its
period of time sufficient

Page 16 OF THE
ENTERPRISE
MANNER AND
AND METHODS
METHODS OF
THE ENTERPRISE
MANNER
of
associates of
and othermembersand
methods used
other members and associates
“The
used by
by the
the Defendants
Defendants and
The manner
manner and
and methods
were
and to
but were
achieve its
purposes included,
its purposes
the
to further
to achieve
the enterprise
of the
the goals
included, but
further the
enterprise to
the enterprise
enterprise and
goals of
not limited
limited to,
not
the following:
following:
to, the
and Solicitation
1.
1. False
False Statements
Statements toto and
Solicitationofof State
State Legislatures
Legislatures
several ofthe
of the Defendants,
Membersofthe
including several
Defendants, appeared
at hearings
in
Members of the enterprise,
hearings in
appeared at
enterprise, including
members of the Georgia
on December
Fulton County,
before membersofthe
General Assembly
December 3,3,
Fulton
Georgia General
Assembly on
Georgia, before
County, Georgia,
of the enterprise
2020. At
At these
2020, December
December 10,
10, 2020,
2020, and
December 30,
30, 2020.
these hearings,
hearings, members
membersofthe
and December
enterprise
2020,
election. The
made false
false statements
statements concerning
fraud inin the
the November
November 3,3, 2020,
2020, presidential
presidential election.
The
made
concerning fraud
electoral
statements was
of these
purposeof
these false
false statements
was toto persuade
persuade Georgia
to reject
reject lawﬁll
lawful electoral
Georgia legislators
legislators to
purpose
of the
electors from
votes
cast by
the duly
elected and
Votes cast
by the
and qualified
from Georgia.
Membersofthe
Georgia. Members
qualiﬁed presidential
presidential electors
duly elected
own
solicited Georgia
enterprise corruptly
corruptly solicited
legislators instead
instead toto unlawﬁllly
unlawfully appoint
their own
Georgia legislators
appoint their
enterprise
Members of the
presidential electors
for the
the purpose
purposeofcasting
for Donald
Donald Trump.
of casting electoral
electoral votes
votes for
electors for
Trump. Membersofthe
presidential
state legislators
statements to
enterprise
made false
false statements
to state
legislators during
during hearings
hearings and
and meetings
meetings inin
also made
enterprise also
November and
and December
December and Pennsylvania
Arizona, Michigan,
Michigan, and
Pennsylvania inin November
2020 toto persuade
persuade legislators
legislators
Arizona,
their own presidential
electors.
in
to unlawfully
those states
states to
in those
appointtheirown
presidential electors.
unlawﬁllly appoint
Officials
State Ofﬁcials
and Solicitation
Solicitation of
High-Ranking State
to and
of HighRanking
2.
False Statements
Statements to
2. False
statements in
several ofthe
of the Defendants,
made false
of the enterprise,
Members
Membersofthe
enterprise, including
including several
Defendants, made
false statements
in
State of Georgia to
Fulton
elsewhere in
Fulton County
and elsewhere
in the
the StateofGeorgia
to Georgia
the
officials, including
including the
County and
Georgia officials,
of
and the
of the House
of Representatives. Members
Members of
Govemor, the
the Speaker
Speakerofthe
HouseofRepresentatives.
the SecretaryofState,
Governor,
Secretary cf State, and
and the
solicited Georgia
the enterprise
the
also corruptly
including the
the SecretaryofState
the
officials, including
Georgia officials,
Secretary of State and
enterprise also
corruptly solicited
and to
to
the Georgia
Constitution and
of Representatives, to
oaths to
Speakerofthe
HouseofRepresentatives,
to violate
violate their
their oaths
to the
Georgia Constitution
Speaker of the House
outcome of the November
the
States Constitution
Constitution by
the United
United States
by unlawfully
unlawfully changing
the outcomeofthe
November 3,3, 2020,
2020,
changing the

Page 17 also made
of the enterprise
made
in favor
of Donald
in Georgia
Membersofthe
election in
Donald Trump.
favor of
presidential
enterprise also
Georgia in
Trump. Members
presidential election
ofﬁcials in
and solicited
solicited state
state officials
Pennsylvania.
and Pennsylvania.
Michigan, and
Arizona, Michigan,
in Arizona,
to and
false
false statements
statements to
of False
False Electoral
Documents
Electoral College
Distributionof
and Distribution
3. Creation
3.
Creation and
College Documents
created false
Electoral
false Electoral
several of the Defendants,
Members
including severalofthe
the enterprise,
of the
Members of
Defendants, created
enterprise, including
cast false
votes atat
and recruited
to convene
convene and
and cast
Electoral College
false Electoral
documents and
individuals to
recruited individuals
College votes
College documents
College
After the
2020. After
on December
Electoral
false Electoral
the false
14, 2020.
December 14,
Fulton County,
in Fulton
Georgia State
the Georgia
the
State Capitol,
County, on
Capitol, in
of the enterprise
the
of the
President of
the President
votes toto the
the votes
transmitted the
enterprise transmitted
membersofthe
cast, members
were cast,
College
votes were
College votes
and the
the
of the United
the Archivist
States Senate,
the Georgia
United
States, the
United States,
Archivistofthe
United States
Senate, the
Secretary of State, and
Georgia SecretaryofState,
The false
of Georgia.
Court for
States District
false
Georgia. The
District of
of the United
United States
Northern District
the Northern
for the
District Court
Judgeofthe
Chief
Chief Judge
on January
and delay
of Congress on
2021,
to disrupt
session ofCongress
January 6,6, 2021,
intended to
documents were
thejoint
delay the
were intended
documents
disrupt and
joint session
outcome of the November
clection inin
November 3,3, 2020,
the outcomeofthe
inorderto
in order to unlawfully
2020, presidential
change the
presidential election
unlawfully change
of the enterprise
schemes were
executed by
favor
of Donald Trump.
Arizona,
in Arizona,
membersofthe
were executed
Similar schemes
Trump. Similar
favor ofDonald
enterprise in
by members
and Wisconsin.
Wisconsin.
New Mexico,
Pennsylvania, and
Mexico, Pennsylvania,
Nevada, New
Michigan, Nevada,
Michigan,
of Fulton
4.
Freeman
Ruby Freeman
Worker Rubv
Election Worker
Fulton County
Intimidation of
and Intimidation
Harassment and
4. Harassment
Countv Election
accused Fulton
of the Defendants,
Members
Fulton
falsely accused
severalofthe
including several
enterprise, including
the enterprise,
of the
Members of
Defendants, falsely
of committing
crimes in
Georgia.
County, Georgia.
Fulton County,
in Fulton
election crimes
committing election
Freeman of
Ruby Freeman
worker Ruby
election worker
‘County
County election
other. Georgia
an
officials inin an
and other
legislators and
repeated toto Georgia
were repeated
accusations were
false accusations
‘These
These false
Georgia ofﬁcials
Georgia legislators
presidential
November 3,3, 2020,
outcomeofthe
unlawfullychangethe
them toto unlawfully
persuade them
to persuade
effort
of the November
effort to
2020, presidential
change the outcome
In furtherance
of this scheme,
members of the enterprise
in favor
of Donald
election in
furtherance ofthis
Donald Trump.
favor of
election
scheme, membersofthe
enterprise
Trump. In
confess to
of state to
traveled
to
falsely confess
her toto falsely
solicit her
and solicit
her, and
intimidate her,
harass Freeman,
to harass
outofstate
from out
traveled from
Freeman, intimidate
did not
commit.
not commit.
she did
that she
crimes that
election crimes
election
l

Page 18 5. SolicitationofHigh-Ranking United States DepartmentofJustice Officials
solicited highMembersofthe
Defendants, corruptly
highseveral of the Defendants,
of the enterprise,
Members
corruptly solicited
enterprise, including
including severalofthe
goverment
ofﬁcials to
statements toto government
false statements
States Departmentof
make false
to make
Justice officials
United States
ranking United
Department of Justice
ranking
of
House of
the Speakerofthe
the Governor,
ofﬁcials in
Georgia, including
County, Georgia,
Fulton County,
in Fulton
Governor, the
officials
Speaker of the House
including the
one instance,
Pro Temporeofthe
Senate. In
and the
Representatives, and
the President
President Pro
In one
Donald Trump
Trump
instance, Donald
Tempore of the Senate.
Representatives,
and
election was
was corrupt,
States Attorney
the election
that the
“Just say
to the
stated to
Attorney General,
United States
Acting United
the Acting
stated
corrupt, and
General, "Just
say that
5. Solicitation of High-Ranking United States Department of Justice Ofﬁcials
-
leave the rest to me and the Republican congressmen.”
States
Vice President
Solicitation of the Vice
6.6. Solicitationofthe
President of
of the
the United
United States
solicited the
Membersofthe
severalofthe
Defendants, corruptly
corruptly solicited
the
of the Defendants,
Members of the enterprise,
enterprise, including
including several
lawby
States Constitution
Vice President
Presidentofthe
States toto violate
the United
United States
Constitution and
and federal
federal law
of the United
United States
violate the
Vice
by
elected
the duly
in Fulton
votes cast
unlawfully rejecting
rejecting Electoral
Electoral College
College votes
cast in
Fulton County,
by the
Georgia, by
duly elected
County, Georgia,
unlawﬁilly
also corruptly
ﬁom Georgia.
of the enterprise
electors from
enterprise also
and
Membersofthe
presidential electors
and qualified
corruptly
Georgia. Members
qualiﬁed presidential
Vice President
cast by
solicited
the Vice
President toto reject
reject votes
votes cast
by the
the duly
duly elected
elected and
and qualified
presidential
solicited the
qualiﬁed presidential
leave the rest to me and the Republican congressmen."
electors from several other states
Elsewhere
in Georgia
7. Unlawful
Unlawful Breach
Breach of
of Election
Election Equipment
Equipment in
and Elsewhere
Georgia and
of the enterprise,
several of the Defendants,
Members
Membersofthe
including severalofthe
Defendants, corruptly
in
conspired in
corruptly conspired
enterprise, including
and voter
access secure
and elsewhere
Fulton
County, Georgia,
elsewhere toto unlawfully
secure voting
voting equipment
voter
Fulton County,
equipment and
unlawﬁllly access
Georgia, and
members of the enterprise
stole data,
data. In
data.
In Georgia,
enterprise stole
ballot images,
voting equipment
equipment
data, including
images, voting
including ballot
Georgia, membersofthe
other members
distributed to
The stolen
data was
and personal
stolen data
software,
personal voter
voter information.
information. The
was then
then distributed
to other
members
software, and
other states.
states.
of the enterprise,
ofthe
including members
members inin other
enterprise, including
electors ﬁom several other states.
7._

Page 19 Cover Up
and the
in Furtherance
8.8. Obstructive
Obstructive Acts
Acts in
Furtherance of
of the
the Conspiracy
the Cover
Up
Conspiracy and
Members
of the enterprise,
several of the Defendants,
Membersofthe
including severalofthe
Defendants, ﬁled
filed false
false documents,
documents,
enterprise, including
committed perjury
made false
false statements
statements toto government
government investigators,
and committed
in judicial
judicial
made
perjury in
investigators, and
the
furtherance of and to
and elsewhere
elsewhere in
proceedings
in Fulton
Fulton County,
in furtheranceofand
to cover
cover up
up the
County, Georgia,
Georgia, and
proceedings in
conspiracy.
conspiracy.
l

Page 20 AND
RACKETEERING ACTIVITY
ACTS
OF RACKETEERING
ACTS OF
ACTIVITY AND
OF THE
CONSPIRACY
OVERT
URTHERANCE OF
OVERT ACTS
ACTS IN
IN FFURTHERANCE
THE CONSPIRACY.
detailed above,
the Defendants
and
As part
of and onbehalfof
on behalf of the
crimin'al enterprise
As
part ofand
the criminal
Defendants and
above, the
enterprise detailed
of
acts to
other
members and
and associatesofthe
committed overt
overt acts
to eﬁect
effect the
the objectives
objectives of
other members
associates of the enterprise
enterprise committed
to:
the enterprise,
but not
the
enterprise, including
including but
not limited
limited to:
Act 1.
Act
DONALD JOHN
TRUMP made
On
about the
4th day
On or
or about
the 4th
dayofof November
November 2020,
2020, DONALD
JOHN TRUMP
made aa
televised specch
nationally
falsely declaring
victory inin the
the 2020 presidential
presidential election.
election.
nationally televised
declaring victory
speech falsely
October
DONALD
JOHN
TRUMP
four
or
about
on
Approximately
four
days
earlier,
on
or
about
October
31,
2020,
DONALD
JOHN
TRUMP
31, 2020,
Approximately
days earlier,
Individual l,
whose identity
known to
discussed aa draft
draft speech
unindicted co-conspirator
discussed
speech with
with unindicted
1, whose
identity isis known
to
coconspirator Individual
claimed
voter
was
an
Grand Jury,
and
fraud.
The
the
that
declared
the Grand
that
falsely
declared
victory
and
falsely
claimed
voter
fraud.
The
speech
was
an
falsely
Jury,
victory
falsely
speech
overt act
act in
of the conspiracy.
overt
in furtherance
furtheranceofthe
conspiracy.
Act2,
WILLIAM LOUIS
On or
or about
the 15th
15th dayof
November 2020,
On
about the
2020, RUDOLPH
RUDOLPH WILLIAM
LOUIS
day of November
GIULIANI placed
Individual 2,
whose identity
GIULIANI
placed aa telephone
telephone call
call toto unindicted
unindicted co-conspirator
2, whose
identity isis
co-conspirator Individual
known
the Grand
voicemail
and
left
an
known toto the
Grand Jury,
and
left
an
approximately
83-second-long
voicemail
message
for
message for
Jury,
approximately 83-second-long
statements concerning
unindicted
unindicted coconspirator
co-conspirator Individual
Individual 22 making
making statements
fraud inin the
the November
November 3,3,
concerning fraud
call
was
an
in
This
overt
act
in
furtherance
of
election
Fulton
2020,
election
in
Fulton
County,
Georgia.
This
telephone
call
was
an
overt
act
in
furtherance
of
2020,
telephone
County, Georgia.
the
the conspiracy.
conspiracy.
Act2,
WILLIAM LOUIS
On
or about
about the
of November
On or
the 19th
19th day
November 2020,
2020, RUDOLPH
RUDOLPH WILLIAM
LOUIS
day of
counindicted coPOWELL, and
JENNA LYNN
SIDNEY KATHERINE
and unindicted
KATHERINE POWELL,
ELLIS, SIDNEY
LYNN ELLIS,
GIULIANI,
GIULIANI, JENNA
known to
a press
whose identity
conspirator
Individual 3,3, whose
identity isis known
to the
the Grand
Grand Jury,
Jury, appeared
atapress
conspirator Individual
appeared at
conference
at
the
Committee
on
behalf
of
conference at the Republican
Republican National
National Committee Headquarters
DONALD JOHN
JOHN
Headquarters onbehalf of DONALD
TRUMP and
and Donald
and made
for President,
TRUMP
Donald J.J. Trump
President, Inc.
Inc. (the
(the “Trump
Campaign”) and
made false
false:
"Trump Campaign")
Trump for
statements concerning
November 3',
election in
in Georgia
statements
concerning fraud
fraud inin the
the November
3, 2020,
presidential election
and
2020, presidential
Georgia and
elsewhere.
of the conspiracy.
These were overt
overt acts
elsewhere. Thesewere
acts inin furtherance
furtheranceofthe
conspiracy.
Acta.
On
of November
SHAFER sent
sent an
an e-mail
about the
20th day
On or
or about
the 20th
day of
November 2020,
DAVID JAMES
JAMES SHAFER
e-mail
2020, DAVID
known to
whose identity
Grand Jury,
to unindicted
to
unindicted co-conspirator
co-conspirator Individual
Individual 4,4, whose
identity isis known
to the
the Grand
and other
other
Jury, and
stated that
SCOTT GRAHAM
In the
SHAF ER stated
individuals.
individuals. In
the email,
e-mail, DAVID
DAVID JAMES
JAMES SHAFER
that SCOTT
GRAHAM HALL,
HALL, aa
election on
bail bondsman,
of the President
"has been
been looking
‘Georgia
bondsman, “has
into the
the election
on behalf
behalf
ofthe
President atat the
the
Georgia bail
looking into
Individual
to
contact
of
David
Bossie"
and
asked
unindicted
request
of
David
Bossie”
and
asked
unindicted
co-conspirator
Individual
to
exchange
contact
co-conspirator
exchange
request
and to
to “help
as needed." This
information
with SCOTT
SCOTT GRAHAM
This was
overt act
information with
GRAHAM HALL
HALL and
himasneeded.”
was an
an overt
act
"help him
furtherance of the conspiracy.
inin furtheranceofthe
conspiracy.

Page 21 Act
Acts.5.
and MARK
JOHN TRUNIP
On
the 20th
20th day
November 2020,
DONALD JOHN
TRUMP and
MARK
of November
On or
or about
about the
2020, DONALD
day of
Shirkey,
of the
Michael Shirkey,
with Majority
Senate Michael
Michigan Senate
met with
the Michigan
RANDALL MEADOWS
Leaderof
Majority Leader
MEADOWS met
RANDALL
Lee
and
other
of
legislators
Michigan
other
and
the
House
Chatfield,
Lee
of
ofRepresentatives
House
Michigan
t
he
Chatﬁeld,
of
Speaker
Michigan legislators
Representatives
Speaker
Michigan
false
statements
DONALD
JOHN
TRUMP
made
and
at the
Oval Office
Ofﬁce at
House, and DONALD JOHN TRUMP made false statements
White House,
the White
the Oval
inin the
election in
in Michigan.
concerning
fraud
in
the
November
3, 2020,
presidential election
Michigan. RUDOLPH
RUDOLPH
ﬁaud
in
the
November
2020, presidential
3,
concerning
act
was an overt act
This
the
WILLIAM
LOUIS
GIULIANI
joined
the
meeting
by
telephone.
Thismeeting
LOUIS
GIULIANI
WILLIAM
meeting wasanovert
meeting by telephone.
joined
of the conspiracy.
inin furtherance
furtheranceofthe
conspiracy.
Act 6.
Act6.
sent a
a
RANDALL MEADOWS
November 2020,
On or
or about
about the
the 21st
dayofof November
MARK RANDALL
MEADOWS sent
21st day
On
2020, MARK
text message
message toto United
Representative Scott
Scott Perry
Perry from
from Pennsylvania
Pennsylvania and
and stated,
“Can
text
United States
States Representative
stated, "Can
wants
the
PA
POTUS
and
leader
of
‘you
me the
the number
number for
for the
the speaker
Legislature. POTUS wants toto chat
chat
send me
speaker and the leader ofPA Legislature.
you send
furtherance of the conspiracy.
with
was an
overt act
them." This
This was
with them.”
an overt
act inin furtheranceofthe
conspiracy.
Act
Act.7.
and
JOHN TRUMP
TRUMP and
November 2020,
22nd dayof
On
or about
about the
On or
the 22nd
DONALD JOHN
2020, DONALD
day of November
the Arizona
a
call
of
to
Arizona
LOUIS
GIULIANI
Speakerofthe
to
call
RUDOLPH
WILLIAM
telephone
a
placed
GIULIANI
LOUIS
WILLIAM
RUDOLPH
placed telephone
Speaker
Bowers. During
House
of Representatives Russell
HouseofRepresentatives
Russell “Rusty”
During the
the telephone
telephone call,
RUDOLPH
call, RUDOLPH
"Rusty" Bowers.
statements concerning
fraud
in
the
November
WILLIAM LOUIS
GIULIANI made
LOUIS GIULIANI
WILLIAM
made false
false statements
fraud
in
the
November 3,3,
concerning
tand
Bowers
and
2020,
presidential election
election inin Arizona
Arizona and solicited,
solicited, requested,
requested, and importuned
2020, presidential
importuned Bowers to
the
testiﬁed to
declined and
unlawfully appoint
presidential electors
electors from
from Arizona.
Arizona. Bowers
Bowers declined
and later
later testified
to the
unlawﬁJlly
appoint presidential
Attack
6th
Select
Committee
the
Attack
to
6th
January
the
Investigate
United
States
House
of
to
United States HouseofRepresentatives
January
Representatives Select Committee Investigate
break my
not break
would not
on the
the United
States Capitol
TRUMP, "I“I would
JOHN TRUMP,
DONALD JOHN
told DONALD
he told
that he
United States
on
my
Capitol that
acts in
oath.”
false statements
solicitations were
were overt
overt acts
in furtherance
furtherance of
of the
the conspiracy.
The false
statements and
and solicitations
oath." The
conspiracy.
Act
Act8.8.
of November
On or
or about
about the
On
the 25th
25th day
November 2020,
2020, RUDOLPH
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS
day of
GIULIANI
and JENNA LYNN
at aa meeting
and
witnesses
GIULIANI
andJENNA
LYNN ELLIS
ELLIS appeared,
spoke,
and
presented
witnessesat
meeting
appeared, spoke,
presented
of
of Pennsylvania
Pennsylvania legislators
legislators inin Gettysburg,
Gettysburg, Pennsylvania.
Pennsylvania. During
During the
the meeting,
meeting, RUDOLPH
RUDOLPH
false statements
WILLIAM
GIULIANI made
WILLIAM LOUIS
LOUIS GIULIANI
made false
statements concerning
concerning fraud
fraud inin the
the November
November 3,3,
and
and
election in
2020, presidential
presidential election
in Pennsylvania
Pennsylvania and solicited,
requested, and importuned
importuned the
the
solicited, requested,
2020,
from
at
the
to
electors
Pennsylvania
legislators
present
at
the
meeting
to
unlawfully
appoint
presidential
electors
from
meeting
unlawfully appoint presidential
Pennsylvania legislators present
LYNN
ELLIS
and
JENNA
the
Pennsylvania.
During
the
meeting,
JENNA
LYNN
ELLIS
solicited,
requested,
and
importuned.
solicited, requested,
importuned
meeting,
Pennsylvania. During
the meeting
electors
at the
the
the Pennsylvania
Pennsylvania legislators
meeting toto unlawfully
unlawfully appoint
presidential electors
appoint presidential
legislators present
present at
false
made
TRUMP joined
from Pennsylvania.
Pennsylvania. DONALD
JOHN TRUMP
joined the
the meeting
meeting
by
telephone,
made
false
DONALD JOHN
from
by telephone,
election in
statements
concerning ﬁaud
fraud inin the
the November
November 3,3, 2020,
presidential election
in Pennsylvania,
Pennsylvania, and
and
statements concerning
2020, presidential
to
the
at
the
and
solicited,
requested,
and
importuned
the
Pennsylvania
legislators
present
at
the
meeting
to
meeting
Pennsylvania legislators present
solicited, requested,
importuned
from Pennsylvania.
These were
overt acts
electors from
unlawfully appoint
presidential electors
Pennsylvania. These
were overt
acts inin furtherance
furtherance
unlawfully
appoint presidential
of
the
ofthe conspiracy.
conspiracy.

Page 22 Act
Act.9.
the meeting
after the
of
meeting of
25th dayof
On or
about the
immediately after
2020, immediately
November 2020,
the 25th
or about
On
day of November
LOUIS
WILLIAM LOUIS
RUDOLPH WILLIAM
where RUDOLPH
Pennsylvania, where
Gettysburg, Pennsylvania,
legislators inin Gettysburg,
Pennsylvania legislators
Pennsylvania
and presented
DONALD
witnesses, DONALD
presented witnesses,
spoke, and
JENNA LYNN
ELLIS appeared,
GIULIANI and
and JENNA
LYNN ELLIS
GIULIANI
appeared, spoke,
with
to
meet
and
others
him atat
legislators and others to meet with him
JOHN TRUMP
invited aa groupofthe
TRUMP invited
JOHN
Pennsylvania legislators
group of the Pennsylvania
JOHN TRUMP,
RANDALL
that day,
MARK RANDALL
Later that
DONALD JOHN
the
House. Later
White House.
the White
TRUMP, MARK
day, DONALD
LYNN
LOUIS
JENNA
WILLIAM
and
ELLIS and
RUDOLPH WILLIAM LOUIS GIULIANI,
GIULIANI, JENNA LYNN ELLIS
MEADOWS, RUDOLPH
MEADOWS,
the
are known
and Individual
identities are
Individual 55 and
known toto the
unindicted
whose identities
Individual 6,6, whose
co-conspirators Individual
unindicted co-conspirators
and
discussed
House
at
the
White
of
the
with
discussed
and
Grand
met with the groupof
legislators at the White House
Pennsylvania legislators
Jury, met
Grand Jury,
Pennsylvania
group
in
acts in
overt acts
General
These were
were overt
the
of
session
holding
a
special
sessionofthe
Pennsylvania
General
Assembly. These
a
Pennsylvania
Assembly.
holding special
ﬂirtherance of the conspiracy.
furtheranceofthe
conspiracy.
Act
Act 10.
10.
of November 2020,
RUDOLPH WILLIAM
LOUIS
26th day
WILLIAM LOUIS
or about
On or
about the
2020, RUDOLPH
day ofNovember
the 26th
On
the
of
a
to
LYNN
ELLIS
call
Pennsylvania
Speakerofthe
to
and JENNA
JENNA LYNN ELLIS placed
telephone call Speaker
GIULIANI and
placed a telephone
Pennsylvania
GIULIANI
of
and left
Cutler aa voicemail
Cutler and
the purpose
for the
message for
House
of Representatives Bryan
voicemail message
left Cutler
HouseofRepresentatives
purpose of
Bryan Cutler
from
electors
him
to
soliciting,
requesting,
and
importuning
him
to
unlawfully
appoint
presidential
electors
from
and
unlawfully appoint presidential
importuning
soliciting, requesting,
furtherance of the conspiracy.
an overt
Pennsylvania. This
This was
was an
overt act
act inin furtheranceoftheconspiracy.
Pennsylvania.
Act 11.
Actll
November 2020,
LOUIS
On or
or about
about the
WILLIAM LOUIS
RUDOLPH WILLIAM
2020, RUDOLPH
26th dayof
the 26th
On
day of November
Senate
Pro Temporeofthe
of
the
Jacob
Senate Jacob
GIULIANI
Pennsylvania
President Pro
call toto President
telephone call
placed aa telephone
GIULIANI placed
Pennsylvania
Tempore
Corman
to
of
and
for
the
“Jake”
Corman
for
the
purposeofsoliciting,
requesting,
and
importuning
Corman
to
unlawfully
"Jake" Corman
unlawfully
soliciting, requesting,
importuning
purpose
of the
act
in
furtherance
ﬁom
This
was
an
overt
electors
appoint
presidential
electors
from
Pennsylvania.
This
was
an
overt
act
in
furtheranceofthe
Pennsylvania.
appoint presidential
conspiracy.
conspiracy.
Act
12.
Act12,
LOUIS
WILLIAM LOUIS
the 27th
27th dayof
On or
or about
On
about the
November 2020,
RUDOLPH WILLIAM
2020, RUDOLPH
day of November
the
a
of
and JENNA
call
to
GIULIANI
LYNN ELLIS
ELLIS placed
telephone
call
to
Speakerofthe
Pennsylvania
GIULIANI and
JENNA LYNN
Pennsylvania
placed telephone
Speaker
House
of Representatives Bryan
HouseofRepresentatives
Bryan Cutler
Cutler and
and left
left Cutler
Cutleraa voicemail
voicemail message
message for
for the
the purpose
purpose of
of
from
him
to
electors
soliciting,
requesting,
and
importuning
him
to
unlawfully
appoint
presidential
electors
from
and
importuning
unlawfully appoint presidential
soliciting, requesting,
of the conspiracy.
act in
This was
an overt
Pennsylvania. This
was an
overt act
in furtherance
furtheranceofthe
conspiracy.
Pennsylvania.
Act
12.
Act 12.
LOUIS
of November
RUDOLPH WILLIAM
WILLIAM LOUIS
On
or about
about the
On or
the 27th
27th day
day of
November 2020,
2020, RUDOLPH
to President
call to
Pro Temporeofthe
JENNA LYNN
President Pro
and JENNA
telephone call
GIULIANI and
placed aa telephone
ELLIS placed
LYNN ELLIS
GIULIANI
Tempore of the
and
for
the
of
importuning
Corman
and
Jake
requesting,
Senate
soliciting,
purposeof
the
for
Corman
Jake
Senate
Pennsylvania
importuning
purpose
soliciting, requesting,
Pennsylvania
overt act
act in
in
This was
was an
an overt
Pennsylvania. This
from Pennsylvania.
Corman to
electors from
presidential electors
unlawfully appoint
to unlawﬁilly
Corman
appoint presidential
the conspiracy.
turtherance
furtheranceofof the
conspiracy.
'
'

Page 23 Act
l4.
Act14,
On or about the 27th day ofNovember 2020, DONALD JOHN TRUMP placed a
telephone call to President Pro Temporeofthe Pennsylvania Senate Jake Corman for the purpose
ofsoliciting, requesting, and importuning Corman to unlawfully appoint presidential electors
from Pennsylvania. This was an overt act in furtheranceofthe conspiracy.
On or about the 27th day of November 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.
Act1s,
LOUIS
of November
WILLIAM LOUIS
the 28th
28th day
RUDOLPH WILLIAM
On or
November 2020,
or about
about the
On
2020, RUDOLPH
day of
of
of the Pennsylvania
call to
Representatives
House of Representatives
Pennsylvania House
GIULIANI placed
to Speaker
telephone call
placed aa telephone
Speaker ofthe
GIULIANI
and
of
a
voicemail
the
left
Cutler
for
and
purposeofsoliciting,
the
Cutler
for
message
voicemail
a
Cutler
left
and
Cutler
soliciting, requesting,
requesting, and
Bryan
message
purpose
Bryan
was
an
This
from Pennsylvania.
electors from
presidential electors
unlawfully appoint
him toto unlawfully
Pennsylvania. This was an
importuning
appoint presidential
importuning him
of the
act in
overt act
overt
in furtherance
furtheranceof
the conspiracy.
conspiracy.
Act 16.
Act16.
LOUIS
of November
November 2020,
WILLIAM LOUIS
29th day
On
or about
RUDOLPH WILLIAM
dayof
the 29th
about the
On or
2020, RUDOLPH
of
House
call
to
of
the
a
Representatives
of
House
Pennsylvania
GIULIANI
Speakerofthe
to
telephone call Speaker
placed a telephone
Representatives
GIULIANI placed
Pennsylvania
and
the' purpose of
left Cutler
and left
of soliciting,
forthepurpose
message for
voicemail message
Cutler aa voicemail
soliciting, requesting,
requesting, and
Cutler and
Bryan Cutler
Bryan
This was
from Pennsylvania.
electors from
importuninghimto
unlawfully appoint
Pennsylvania. This
was an
an
him to unlawfully
appoint presidential
presidential electors
importuning
overt actin
conspiracy.
furtherance of the conspiracy.
overt
act in furtheranceofthe
Act
17.
Act17.
of November 2020,
30th day
* On
On or
or about
the 30th
dayofNovember
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS
about the
2020, RUDOLPH
witnesses at
and presented
LYNN ELLIS
and JENNA
JENNA LYNN
GIULIANI and
ELLIS appeared,
appeared, spoke,
spoke, and
presented witnesses
at aa mecing
GIULIANI
meeting
and
Individual
and
Individual
in
Arizona.
Unindicted
co-conspirators
Unindicted
Arizona.
of
Arizona
Phoenix,
in
legislators
ofArizona legislators Phoenix,
co-conspirators
also present.
the
known to
Grand Jury,
During the
were also
the Grand
to the
Individual
are known
identities are
whose identities
Individual 6,6, whose
present. During
Jury, were
fraud
statements
GIULIANI
made
false
fraud
WILLIAM
LOUIS
concerning
statements
RUDOLPH
false
made
GIULIANT
LOUIS
WILLIAM
concerning
RUDOLPH
‘meeting,
meeting,
and
election
in
Arizona
and
requested, and
solicited, requested,
the November
November 3,3, 2020,
inin the
2020, presidential
presidential election in Arizona and solicited,
at
the
to
the
Arizona
presidential
appoint
unlawfully
to
meeting
the
at
present
legislators
presidential
Arizona
the
unlawfully
appoint
importuned
legislators present
meeting
importuned
ELLIS
JENNA
LYNN
electors
electors from
from Arizona.
Arizona. During
During the
the meeting,
JENNA
LYNN
ELLIS
solicited,
requested,
and
solicited, requested, and
meeting,
the meeting
to unlawfully
importuned the
Arizona legislators
legislators present
present atat the
meeting to
the Arizona
unlawfully appoint
appoint presidential
presidential
importuned
JOI-IN TRUMPjoined
TRUMP joined the
electors
Arizona. DONALD
DONALD JOHN
the meeting
by
telephone
and made
made
from Arizona.
electors from
meeting by telephone and
in
election
Arizona.
fraud
in
the
presidential election in Arizona.
false
statements concerning
2020, presidential
November 3,3, 2020,
false statements
concerning fraud in the November
furtherance of the conspiracy.
overt acts
These
‘These were
were overt
acts inin furtheranceofthe
conspiracy.
Act 18.
Act18.
30th day
of November
On
or about
about the
November 2020,
MICHAEL A.
A. ROMAN
ROMAN instructed
instructed
the 30th
On or
2020, MICHAEL
day of
to coordinate
coordinate
Grand
to
the
Individual
whose
is
known
Jury,
Grand
the
to
known
is
unindicted
identity
whose
7,
Individual
co-conspirator
7,
Jury, to
unindicted co-conspirator
identity
in
and
to contact
state legislators
contact state
with the
Georgia and
associated with
with
the Trump
individuals associated
with individuals
legislators in Georgia
Campaignto
Trump Campaign
TRUMP and
and to
appoint
of DONALD JOHN
to encourage
unlawfully appoint
them toto unlawfully
encourage them
elsewhere on'behalf
JOHN TRUMP
ofDONALD
on behalf
elsewhere
the
in
furtherance
of
act
states. This
an overt
overt actin furtheranceofthe
was an
This was
their respective
from their
electors from
presidential
respective states.
presidential electors
conspiracy.
conspiracy.
\
'
2

Page 24 Act
19.
Act19.
of December
31st day
and the
the 31st
the 1st
2020 and
December 2020,
day of
or between
of December
On or
December 2020,
1st day
between the
On
day of
McEntee and
with
MEADOWS met
and
TRUMP and
and MARK
JOHN TRUMP
John McEntee
met with John
DONALD
RANDALL MEADOWS
MARK RANDALL
DONALD JOHN
for
and
a
requested
that
McEntee
prepare
a
memorandum
outlining
a
strategy
for
disrupting
and
delaying
McEntee
a
memorandum
that
delaying
disrupting
outlining strategy
prepare
requested
law for
on January
thejoint
Congress on
2021, the
the day
prescribed by
for counting
counting votes
votes
session of Congress
the
by law
6, 2021,
day prescribed
January 6,
joint sessionof
the
other
states.
The
and
from
electors
elected
and
cast by
the
duly
elected
and
qualified
presidential
electors
from
Georgia
and
the
other
states.
The
the
cast
Georgia
duly
qualiﬁed presidential
by
half
of
the
electoral
count
Pence
"Mike"
President Michael
included having
strategy included
having Vice
Vice President
Michael R.
R. “Mike” Pence count onlyhalfofthe
electoral
only
strategy
The
state
votes
to
The
electoral
legislatures.
state
to
states and
and then
return the
votes
certain states
electoral
the remaining
votes
then return
from certain
Votes from
legislatures.
remaining
furtherance
of
the
an
overt
act
in
was an overt act in furtheranceofthe conspiracy.
request was
conspiracy.
request
20.
Act
Act20.
RUDOLPH WILLIAM
LOUIS
of December
WILLIAM LOUIS
about the
On or
December 2020,
dayof
1st day
the 1st
or about
On
2020, RUDOLPH
House
of
the
Arizona
of
met with
with Speaker
and JENNA
JENNA LYNN
Arizona House of
GIULIANI
ELLIS met
LYNN ELLIS
GIULIANI and
Speaker ofthe
and other
other Arizona
Arizona Senate
Senate Karen
Arizona
Karer Fann,
the Arizona
Fann, and
Presidentofof the
Bowers, President
Representatives Rusty
Rusty Bowers,
Representatives
whose
Individual
legislators inin Phoenix,
Phoenix, Arizona.
Arizona. Unindicted
5, whose identity
identity isis known
known
Unindicted co-conspirator
co-conspirator Individual 5,
legislators
LOUIS
WILLIAM
RUDOLPH
also present.
the
toto the
the Grand
Grand Jury,
Jury, was
was also
During
the
meeting,
RUDOLPH
WILLIAM
LOUIS
meeting,
present. During
statements concerning
GIULIANT
made false
false statements
concerning fraud
fraud inin the
the November
November 3,3, 2020,
presidential
GIULIANI made
2020, presidential
call aa
the legislators
and importuned
and solicited,
election
in Arizona
Arizona and
solicited, requested,
requested, and
legislators present
present toto call
election in
importuned the
in
furtherance
of
the
acts
were
overt
the
Arizona
State
These
furtheranceofthe
in
session
of
wereovertacts
These
Legislature.
special
special session ofthe Arizona State Legislature.
conspiracy.
conspiracy.
Act 21.
Act21.
of December
about the
On or
or about
On
the 2nd
2nd day
dayof
December 2020,
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS
2020, RUDOLPH
witnesses
at
and
and JENNA
GIULIANI and
JENNA LYNN
LYNN ELLIS
ELLIS appeared,
spoke,
and
presented
witnesses
at aa meeting
GIULIANI
meeting
presented
appeared, spoke,
the
Committee.
of
meeting,
the
House
During
of the Michigan
Oversight Committee. During meeting,
Michigan HouseofRepresentatives
ofthe
Representatives Oversight
statements concerning
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS GIULIANI
GIULIANT made
made false
false statements
concerning fraud
fraud inin the
the
RUDOLPH
and
and
election
in
November 3,3, 2020,
presidential
election
in
Michigan
and
solicited,
requested,
and
importuned
November
solicited, requested,
importuned
2020, presidential
Michigan
electors from
from
the Michigan
legislators present
present atat the
the meeting
to unlawfully
unlawfully appoint
appoint presidential
presidential electors
the
meeting to
Michigan legislators
and
the
ELLIS
the
JENNA
LYNN
Michigan.
During
the
meeting,
JENNA
LYNN
ELLIS
solicited,
requested,
and
importuned
solicited,
importuned the
requested,
meeting,
Michigan. During
electors
from
Michigan legislators
legislators present
present atat the
the meeting
meeting toto unlawfully
unlawfully appoint
appoint presidential
presidential electors from
Michigan
overt'acts
in
ﬁirtherance
of
the
These
were
Michigan.
These
were
overt
acts
in
furtheranceofthe
conspiracy.
conspiracy.
Michigan.
Act
Act22,
TRUMP caused
JOHN TRUMP
3rd day
of December 2020,
On
about the
the 3rd
day ofDecember
DONALD JOHN
caused toto be
be
On or
or about
2020, DONALD
now on
on @OANN.
Twitter account@RealDonaldTrump,
account @RealDonaldTrump, “Georgia
the Twitter
tweeted from
from the
hearings now
@OANN.
tweeted
"Georgia hearings
an overt
furtherance of the conspiracy.
This was
Amazing!” This
was an
overt act
act inin furtheranceofthe
conspiracy.
Amazing!"
u

Page 25 Act23.
LAC"i
RUDOLPH WILLIAM
LOUIS
WILLIAM LOUIS
about the
3rd day
of December
On
or about
2020, RUDOLPH
December 2020,
the 3rd
On or
day of
STALLINGS
JENNA LYNN
GIULIANI,
EASTMAN, JENNA
LYNN ELLIS,
ELLIS, and
and RAY
RAY STALLINGS
JOHN CHARLES
CHARLES EASTMAN,
GIULIANI, JOHN
OF OATH
OF VIOLATION
OATH
of SOLICITATION
SOLICITATION OF
VIOLATION OF
offense of
felony offense
the felony
SMITH III
committed the
III committed
SMITH
&
in
Fulton
16-4County,
of O.C.G.A. §§
16-101, in Fulton County,
BY
violationofO.C.G.A.
OFFICER, inin Violation
PUBLIC OFFICER,
BY PUBLIC
§§ 164-7 & 16-10-1,
ofﬁcers
then
certain
then
and
officers
public
certain
importuning
and
requesting,
soliciting,
unlawfully
by
public
Georgia,
importuning
Georgia, by unlawfully soliciting, requesting,
at
a
Senate
and
Senate
of the Georgia Senate and present
present ata Senate Judiciary
as elected
Judiciary
membersoftheGeorgia
elected members
serving
serving as
Whose identity
Individual 8,
unindicted co-conspirator
identity isis
Subcommittee meeting,
8, whose
including unindicted
meeting, including
‘Subcommittee
co-conspirator Individual
Matt
Dolezal,
Brandon
Greg
Brass,
Matt
Beach,
Lee
Brandon
Grand Jury,
Senators Lee Anderson,
Anderson,
known
Brass, Greg Dolezal,
Beach,
the Grand
known toto the
Jury, Senators
Elena
John F.
F. Kennedy,
William Ligon,
Jen Jordan,
Kennedy, William
Bill Heath,
Heath, Jen
Steve Gooch,
Ligon, Elena
Steve
Jordan, John
Gooch, Tyler
Tyler Harper,
Harper, Bill
the
in
conduct
to
and
Blake
constituting
conduct
in
engage
Michael
Carden
to
Tillery,
Blake
and
constituting the
Parent, Michael Rhett,
Summers,
Tillery, engage
Rhett, Carden Summers,
Parent,
10- 1, by
O. C. G. A. §§ 16
unlawfully
by unlawfully
of Oath
Oath by
16-10-1,
of Violation
Public Officer,
by Public
Violationof
Ofﬁcer, O.C.G.A.
offenseof
felony offense
felony
of
of the terms
intentional
Violation
and
willful
in
terms of
ofthe
electors
from
violation
intentional
and
willful
in
Georgia,
appointing presidential
presidential electors from Georgia,
appointing
in
said
said
with intent
engage in said
of said persons
as prescribed
that said persons
intent that
the
law, with
prescribed by
persons engage
oathofsaid
the oath
by law,
persons as
of the conspiracy.
conduct. This
was an
overt act
act inin furtherance
furtheranceofthe
an overt
This was
conduct.
conspiracy.
Act 24.
Act24,
WILLIAM LOUIS
RUDOLPH WILLIAM
On or
the 3rd
December 2020,
2020, RUDOLPH
LOUIS
or about
about the
3rd dayof
On
day of December
AND
in
STATEMENTS
WRITINGS,
AND
of
FALSE
STATEMENTS
committed
the
offense
FALSE
of
offense
felony
GIULIANI committed the felony
WRITINGS, in
GIULIANI
and
knowingly, wilfully,
by knowingly,
Georgia, by
County, Georgia,
in Fulton County,
violation
of O.C.G.A. §§ 16-10-20,
violationof0.C.G.A.
willfully, and
16-10-20, in-Fulton
members
to
and
statements
false
members
to
representations
at
least
one
of
the
falsestatementsand
following
oneofthe
at least
making
unlawfully making
representations
following
unlawfully
Subcommittee meeting:
meeting:
ataa Senate
Senate Judiciary
of the Georgia
present at
Senate present
Georgia Senate
ofthe
Judiciary Subcommittee
in the November
presidential
2020, presidential
November 3,3, 2020,
least 96,mailin ballots
countedinthe
were counted
That at
at least
ballots were
1.
96,600 mail-in
1. That
of those ballots
retumed toto
been returned
having been
ballots having
recordofthose
no record
election
election inin Georgia,
Georgia, despitetherebeing
despite there being no
a
a county
elections office;
ofﬁce;
county elections
November 3,
2.2. That
Dominion Voting
equipment used
used inin the
the November
2020, presidential
That Dominion
3, 2020,
presidential
Voting Systems
Systems equipment
recorded 6,Antrim County,
election
in Antrim
Michigan, mistakenly
mistakenly recorded
votes for
for Joseph
R.
election in
6,000 votes
Joseph R.
County, Michigan,
John
Donald
cast
for
when the
the votes
Biden when
votes were
were actually
cast
for
Donald
John
Trump;
Biden
Trump;
actually
and
Ofﬁce of the Georgia
State and
of State
Georgia Secretary
statements being
within the
said statements
thejurisdictionofthe
being within
said
Secretary of
jurisdiction of the Officeofthe
and
of
state
and
county
and
govemment,
state government, county
Bureau of
ofInvestigation,
the
the Georgia
agencies
departments and agenciesof
Investigation, departments
Georgia Bureau
O.C.G.A. §§ 16under O.C.G.A.
of
an
act
This
was
and city
city law
law enforcement
This
was
an
act
ofracketeering
activity under
16enforcement agencies.
and
activity
racketeering
agencies.
of
the
act
in
furtherance
and
an
overt
14-3(5)(A)(xif)
and
an
overt
act
in
furtheranceofthe
conspiracy.
14-conspiracy.
(5)(A)(xxii)
2

Page 26 25.
Act
Act25,
committed
RAY STALLINGS
STALLINGS SMITH
SMITH III
or about
of December
On
about the
the 3rd
3rd day
December 2020,
2020, RAY
III commited
On or
day of
in violation
of 0.C.G.A.
O.C.G.A. §§
the
offense of
STATEMENTS AND
the felony
felony offense
of FALSE
FALSE STATEMENTS
AND WRITINGS,
violation of
WRITINGS, in
at least
and
16-10-20,
in
Fulton
County,
Georgia,
by
knowingly,
willfully,
and
unlawfully
making
least
in
Fulton
unlawfully making at
16-10-20,
County, Georgia, by knowingly, willfully,
of the Georgia
oneofthe
following false
fale statements
and representations
representations toto members
membersofthe
Senate
one
of the following
statements and
Georgia Senate
Subcommittee
present
at
a
Senate
Judiciary
Subcommittee
meeting:
at
a
Senate
meeting:
Judiciary
present
in the
the November
l.
That 2,1. That
felons voted
voted illegally
November 3,3, 2020,
2020, presidential
presidential election
election inin
2,506 felons
illegally in
Georgia;
Georgia;
seventeenth birthday
2.2. That
That 66,underage people
illegally registered
registered toto vote
vote before
before their
their seventeenth
birthday
66,248 underage
people illegally
election in
prior toto the
the November
November 3,3, 2020,
2020, presidential
presidential election
in Georgia;
Georgia;
prior
election in
November 3,
That atleast
at least 2,3.3. That
2,423 people
people voted
voted inin the
the November
3, 2020,
presidential election
in
2020, presidential
to
listed
as
Georgia who
who were
were not
not lsted as registered
vote;
registered to vote;
Georgia
in Georgia
election in
who
Georgia who
presidential election
November 3,3, 2020,
the November
voted inin the
2020, presidential
people voted
1,043 people
That 1,4.4. That
ofﬁce box;
vote using
had
had illegally
illegally registered
registered toto vote
using aa post
post office
box;
election in
in the
voted in
5.5. That
10,315 or
more dead
people voted
the November
November 3,3, 2020,
2020, presidential
presidential election
in
That 10,or more
dead people
Georgia;
Georgia;
and
State Farm
Arena ordered
watchers and
election workers
That Fulton
6.6. That
Fulton County
workers atat State
Farm Arena
ordered poll
poll watchers
County election
on the
of November 3,
members
of the
membersof
the media
media toto leave
leave the
the tabulation
tabulation area
area on
the night
nightofNovember
2020, and
and
3, 2020,
to
after
continued
to
leave;
continued to operate
operate after ordering
ordering everyone
everyone to leave;
and
of State
State and
Ofﬁce of the
said statements
being within
within the
thejurisdictionofthe
the Georgia
Secretaryof
said
statements being
Georgia Secretary
jurisdiction of the Officeof
and
and
of
state
the
of Investigation, departments
the Georgia
BureauofInvestigation,
government,
county
agencies
government, and county
departments and agenciesofstate
Georgia Bureau
an
act
of
under
O.C.G.A.
This
was
and city
enforcement agencies.
‘and
city law
law enforcement
Thiswas
an
act
of
racketeering
activity
under
0.C.G.A.
§§ l616racketeering
activity
agencies.
the
of
in
furtherance
and
an
overt
act
l4-14-3(5)(A)(xii)
conspiracy.
(5)(A)(xxii) and an overt act in furtheranceofthe conspiracy.
Act 26.
Act26,
be
December 2020,
or about
On
the 3rd
3rd dayof
2020, DONALD
DONALD JOHN
JOHN TRUMP
TRUMP caused
caused toto be
On or
about the
day 0f December
"Wow!
Blockbuster
tweeted
Twitter account@RealDonaldTrump,
account @RealDonaldTrump, “Wow! Blockbuster testimony
tweeted from
from the
the Twitter
testimony taking
taking
the
to
leave
Dems
when
were
forced
place
right
now
in
Georgia.
Ballot
stuffing
by
Dems
when
Republicans
were
forced
to
leave
the
Ballot
now
in
stufﬁng
by
Republicans
Georgia.
place right
alone
leads
to
an
win
the
This
but
this
of
State!"
room.
more
large
counting
room.
Plenty
more
coming,
but
this
alone
leads
to
an
easy
winof
the
State!”
This
easy
coming,
large counting
Plenty
of the conspiracy.
was
an overt
act in
was an
overt act
in ﬁlrtherance
furtheranceofthe
conspiracy.
Act
27.
Act27.
JOHN TRUMP
TRUMP caused
caused to
On
about the
the 3rd
3rd day
dayof
December 2020,
DONALD JOHN
to be
be:
0f December
On or
or about
2020, DONALD
in
cold
tweeted
Twitter account
account @RealDonaldTrump,
tweeted from
from the
the Twitter
“People
in
Georgia
got
caught
cold
@RealDonaldTrump, "People Georgia got caught
machines. Great
of ballots and
bringing inin massive
massive numbers
numbersofballots
and putting
putting them
them inin ‘voting’
Greatjob.
'voting' machines.
job
bringing
of
the
in
furtherance
act
This
was
an
overt
@BrianKempGA!”
This
was
an
overt
act
in
furtheranceofthe
conspiracy.
conspiracy.
@BrianKempGA!"

Page 27 Act
28.
Act28.
with
met with
of December
December 2020,
3rd day
On
about the
day of
DONALD JOHN
JOHN TRUMP
TRUMP met
On or
or about
the 3rd
2020, DONALD
at the
Ofﬁce at
the Oval
the.
of Representatives Bryan
Oval Office
Cutler inin the
Bryan Cutler
HouseofRepresentatives
Speakerofthe
Pennsylvania House
Speaker of the Pennsylvania
session
of
the
General
a
Assembly.
General
White
House
and
discussed
Pennsylvania
sessionofthe
special
a
holding special
Assembly.
‘White House and discussed holding
Pennsylvania
of the conspiracy.
was an
an overt
furtheranceofthe
This was
overt act
‘This
act inin furtherance
conspiracy.
Act 29.
Act29.
December 2020,
On
the 3rd
December 2020 and
and the
the 26th
26th day
dayofof December
of December
3rd day
On or
or between
between the
2020,
day of
a telephone call
call to
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS GIULIANI
GIULIANI placed
placed atelephone
to President
President Pro
Pro Tempore
Tempore.
RUDOLPH
statements
Terrell "Butch"
ofthe
Senate Cecil
“Butch” Miller
Miller for
for the
the purpose
purposeofof making
making false
false statements
Cecil Terrell
of the Georgia
Georgia Senate
an overt
overt
election in
in Georgia.
This was an
concerning fraud
in the
the November
3, 2020,
presidential election
fraud in
November 3,
2020, presidential
Georgia. Thiswas
concerning
act
in
furtherance
of
the
act in furtheranceof the conspiracy.
conspiracy.
Act
30.
Act30.
and the
On
or between
between the
the 3rd
3rd day
of December
December 2020 and
the 26th
26th dayof
December 2020,
2020,
On or
day of December
day of
call
to
of
the
DONALD JOHN
JOHN TRUMP
TRUMP placed
DONALD
placed aa telephone
telephone call to President
President Pro
Pro Tempore
Tempore of the Georgia
Georgia
act in furtherance
of the conspiracy.
was an
an overt
overt actin
Senate Butch
‘Senate
Butch Miller.
Miller. This
This was
furtheranceofthe
conspiracy.
Act
31.
Act31.
TRUMP placed
of December
JOHN TRUMP
On or
On
or about
about the
the 5th
5th day
December 2020,
2020, DONALD
DONALD JOHN
placed aa
day of
and
Brian
and
Governor
telephone
call
to
Georgia
Governor
Brian
Kemp
and
solicited,
requested,
and
importuned
Kemp
call
to
solicited, requested,
Kemp
importuned Kemp
telephone
Georgia
furtherance of
of
This was
an overt
overt actin
act in furtherance
session of the
the Georgia
to call
call aa special
General Assembly.
Assembly. This
was an
to
Georgia General
special sessionof
the
the conspiracy.
conspiracy.
Act
32.
Act32.
JOHN TRUMP
TRUMP caused
caused to
6th day
of December 2020,
On or
about the
On
the 6th
dayofDecember
2020, DONALD
DONALD JOHN
to be
be
or about
what
a
Has
account @RealDonaldTrump, “Gee,
tweeted
from the
tweeted from
the Twitter
Twitter account@RealDonaldTrump,
what
a
surprise.
Has
anyone
"Gee,
anyone
surprise.
do anything!)
& his
informed
Governor @BrianKempGA
informed the
the so-called
so-called (says
he has
has no
no power
power toto do
his
anything!) Governor
(says he
@BrianKempGA &
that
could
&
WIN.
solve
this
Lt.
Governor
puppet
Lt.
Govemor
@GeoffDuncanGA,
that
they
could
easily
solve
this
mess,
&
WIN.
mess,
they
easily
puppet
@GeoffDuncanGA,
an
This was
was an
Session. So
So easy!
call aa Special
hitps:/t.co/Scb4QdYzpU.” This
verification && call
Signature
easy! 'https://t.co/5cb4QdepU."
Special Session.
Signature verification
overt
act in
of the conspiracy.
overt act
in furtherance
furtheranceofthe
conspiracy.
Act
33.
Act33.
entered
SIDNEY KATHERINE
the 6th
6th day
On
or about
about the
of December
December 2020,
2020, SIDNEY
KATHERINE POWELL
POWELL entered
On or
day of
SullivanStrickler LLC,
ﬁrm located
located in
in
into
into aa written
written engagement
with SullivanStrickler
LLC, aa forensic
forensic data
data firm
agreement with
engagement agreement
of
on
the
forensic
and
Fulton County,
Fulton
County, Georgia,
Georgia, for
for the performance
performanceof computer
collections and analytics
analytics on
computer forensic collections
and
of
in
elsewhere.
The
unlawful
breach
Dominion Voting
Dominion
Voting Systems
equipment
in
Michigan
and
elsewhere.
The
unlawful
breach
of
Systems equipment Michigan
was
under
this
Coffee County,
election equipment
election
equipment inin Coffee
County, Georgia,
performed under this
Georgia, was subsequently
subsequently performed
furtherance
of
the
act
in
This
was
an
overt
agreement.
This
was
an
overt
actin
furtheranceofthe
conspiracy.
conspiracy.
agreement.

Page 28 Act
34.
Act34.
sent an
CHEELEY sent
an e-¢0f December
DAVID CHEELEY
6th day
ROBERT DAVID
about the
On or
December 2020,
the 6th
or about
On
2020, ROBERT
day of
whose
Individual
identity
CHARLES EASTMAN,
unindicted co-conspirator
mail
8, whose identity
EASTMAN, unindicted
JOHN CHARLES
mail toto JOHN
co-conspirator Individual 8,
on
"I
am
that
Senator
Brandon
Beach
on
and
working
am
“I
stated,
that
Grand Jury,
Beach
Brandon
is
known to
Senator
stated,
working
Georgia
and
the Grand
to the
is known
Georgia
Jury,
also
I
am
tomorrow.
and
the
President
Pro
the
call for
with the Speaker
for you
up aa call
setting
Tempore tomorrow. I am also
Speaker and the President Pro Tempore
you with
setting up
meet on
on December
to meet
of
the
for
electors
aware
14.
December l4.
to
the
electors
Trump
for
importance
the
awareof
leadership
the
making
importance
Trump
leadership
making
This
with."
must
This
of
the
duties
which
with.”
to
the
comply
must
they
the
citation
which
Please
requirementsof the duties
comply
provide the cifation to the requirements
they
Please provide
of the conspiracy.
in furtherance
was an
furtheranceofthe
conspiracy.
act in
was
an overt
overt act
Act
35.
Act35.
an e
sent an
December 2020,
JOHN CHARLES
CHARLES EASTMAN
6th day
¢about the
EASTMAN sent
On
2020, JOHN
dayofof December
the 6th
or about
On or
is
whose
is
identity
unindicted
Individual
whose
8,
DAVID
Individual
ROBERT
co-conspirator
mail
to
unindicted
8,
identity
CHEELEY,
DAVID
CHEELEY,
mail to ROBERT
co-conspirator
the
that
stated
Senator
Brandon
Beach
that
and Georgia
known
Trump
Jury, and
Grand Jury,
the Grand
known toto the
Georgia Senator Brandon Beach that stated that the Trump
six
sets of
of
needed
to
meet
on
December
six sets
sign
in
2020,
14,
nominees
December
on
elector
meet
to
needed
Georgia
in
2020,
nominees
l4,
elector
presidential
sign
Georgia
presidential
This
other
ofﬁcials."
the
and
to
them
"to
the
President
of
Senate
This
officials.”
mail
other
to
and
and mail them “to the President of the Senate
certiﬁcates of
vote, and
of vote,
certificates
of the
the conspiracy.
act in
in furtherance
an overt
overt act
was an
‘was
furtheranceof
conspiracy.
Act
36.
Act 36,
DAVID CHEELEY
an e-c0f December
ROBERT DAVID
sent an
6th day
CHEELEY sent
On
about the
December 2020,
day of
the 6th
or about
On or
2020, ROBERT
Grand Jury,
that
Individual 2,
the Grand
known toto the
is known
mail
unindicted co-conspirator
whose identity
2, whose
Jury, that
mail toto unindicted
identity is
co-conspirator Individual
to
set
and
was
up aa
to set up
attempting
EASTMAN and was attempting
stated
CHARLES EASTMAN
JOHN CHARLES
with JOHN
been speaking
had been
he had
stated he
speaking with
Pro
President Pro
and President
House ofRepresentatives
of Representatives David
of the Georgia
Ralston and
David Ralston
call with
Speakerofthe
with Speaker
call
Georgia House
of
the
session
a
Butch
Miller
to
them
to
call
Senate Butch Miller to encourage
Temporeofthe
special sessionofthe
encourage them to call a special
Georgia Senate
Tempore of the Georgia
"Professor
CHEELEY stated,
DAVID CHEELEY
stated, “Professor
ROBERT DAVID
e-mail, ROBERT
the email,
In the
Assembly. In
General Assembly.
Georgia General
Georgia
next
critical
that
the
Electors
for
President
that
it
is
Eastman
told
me
tonight
that
it
is
critical
that
the
Electors
for
President
Trump
meet next
told
me
Eastman
Trump meet
tonight
ROBERT DAVID
DAVID
accordance with
e-mail, ROBERT
the e-mail,
In the
vote in
7.” In
and vote
U.S.C. §§ 7."
with 3 U.S.C.
in accordance
Monday and
Monday
an overt
act in
was
This
assume
can
make
sure
this
in
"I
overt act
an
Thiswas
happens.”
CHEELEY
further
this
sure
make
can
you
CHEELEY further sated,
stated, “I assume you
happens."
of the
furtherance of
furtherance
the conspiracy.
conspiracy.
Act
37.
Act37,
of December
Individual 2,2,
the 7th
unindicted co-conspirator
On or
or about
2020, unindicted
December 2020,
7th day
abou the
On
day of
coconspirator Individual
CHEELEY and
sent an
email to
to ROBERT
ROBERT DAVID
and
the Grand
is known
DAVID CHEELEY
Whose
an e-mail
Jury, sent
Grand Jury,
known toto the
whose identity
identity is
state
GOP
David
can
u
a
call
with
on
DAVID JAMES
that stated,
“Bob,
can
u
get
on
acall
with
David
Shafer,
state
GOP
DAVID
SHAFER that
JAMES SHAFER
Shafer,
"Bob,
stated,
get
state. II
of efforts
eﬁ'orts in
David has
has been
on top
ofaa lot
discuss. David
‘chair
and II later
later this
this morning
to discuss.
been on
top of
lot of
in the
the state.
chair and
morning to
This was
an overt
furtherance of the conspiracy.
around 10:30."
overt act
call around
off of aa board
board call
act inin furtheranceofthe
was an
10:30.” This
conspiracy.
getoffof
get
.
2

Page 29 Act
38.
Act38,
of December
On
about the
the 7th
7¢h day
December 2020,
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS
or about
On or
2020, RUDOLPH
day of
of
a
retweet
tweeted from
GIULIANI caused
caused toto be
be tweeted
from the
the Twitter
Twitter account
account@RudyGiulianiaretweet
of
GIULIANI
@RudyGiuliani
that
to
the
Grand
known to the Grand Jury,
whose identity
unindictedco-conspirator
Individual 8,8, whose
identity isis known
unindicted
stated,
Jury, that stated,
co-conspirator Individual
&
state
Senate
House
call
to
Call
to
Action:
is
the
we
need
Patriot
“Georgia
Patriot
Call
to
Action:
today
is
the
day
we
need
you
to
call
your
state
Senate
&
House
your
today
day
you
"Georgia
&
fair
elections
in
have
free
must
in
tthe
for
a
session.
We
elections
fair
&
them
free
ask them to sign
special session. We must have
petition fora special
Reps && ask
sign the petition
Reps
This
to ensuring
vote is
counted. @realDonaldTrump.”
is counted.
GA
every legal
our only
this isis our
GA && aa this
only path
ensuring every
legal vote
@realDonaldTrump." This
path to
the
in
furtherance
of
act
was
an
overt
was an overt act in furtheranceofthe conspiracy.
conspiracy.
Act
39.
Act39.
sent an
On or
or about
the 7th
dayof0f December
December 2020,
JOHN CHARLES
EASTMAN sent
an e-e7th day
CHARLES EASTMAN
about the
On
2020, JOHN
titled
"The
memorandum
an
attached
mail toto RUDOLPH
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS GIULIANI
GIULIANI with
with
anattached memorandum titled “The
mail
"Here's the
e-mail stated,
State's Electoral
Votes." The
The body
of the e-mail
Real Deadline
Deadline for
for Settling
Electoral Votes.”
bodyofthe
stated, “Here's
the
Real
Settling aa State’s
CHESEBRO
to
JOHN
The
memorandum
was
written
KENNETH
discussed."
‘memo
we discussed.” The memorandum was written by
by KENNETH JOHN CHESEBRO to
memo we
the
advocates for
with the
an attomey
associated with
James
R. Troupis,
Troupis, an
the Trump
for the
James R.
attomey associated
Campaign, and advocates
Trump Campaign,and
cast
meet
and
electoral
should
elector
nominees
in
Wisconsin
that
position
that
Trump
presidential
elector
nominees
in
Wisconsin
should
meet
and
cast
electoral
Trump presidential
position
JOHN TRUMP
TRUMP on
on December
votes
votes for
for DONALD
DONALD JOHN
December 14,
14, 2020,
2020, despite
despite the
the fact
fact that
that DONALD
DONALD
This e-mail
e-mail was
was
in Wisconsin.
Wisconsin. This
the November
election in
JOHN TRUMP
TRUMP lost
JOHN
lost the
November 3,3, 2020,
2020, presidential
presidential election
of the conspiracy.
overt act
an overt
an
act inin furtherance
furtheranceofthe
conspiracy.
Act
40.
Actdo,
TRUMP requested
that
0f December
or about
On or
On
about the
the 7th
7th day
December 2020,
2020, DONALD
DONALD JOHN
JOHN TRUMP
requested that
day of
with the
then residing
an individual
Bill White,
Bill
White, an
individual associated
associated with
the Trump
Trump Campaign
in Fulton
Fulton County,
residing in
County,
Campaign then
for
information
him
with
certain
contact
Majority
for
information
information, including
provide him with certain information,
Majority
Georgia,
including contact
Georgia, provide
Senate
Senate Mike
Leaderofthe
Mike Dugan
and President
President Pro
Pro Temporeof
the Georgia
Leader of the Georgia
Georgia Senate
Tempore of the
Georgia Senate
Dugan and
information
to
the
an e-mail
email containing
Butch Miller.
Miller. The
The following
following day,
day, White
White sent
sent an
the
requested
information
to
Butch
requested
containing
WILLIAM LOUIS
RUDOLPH
LOUIS GIULIANI,
unindicted co-conspirator
Individual 5,5, whose
whose
RUDOLPH WILLIAM
GIULIANI, unindicted
co-conspirator Individual
in
furtherance
of
an
overt
act
Grand
and
others.
This
was
known
to
the
is
identity
is
known
to
the
Grand
Jury,
and
others.
This
request
wasan
overt
act
in
furtherance
of
Jury,
request
identity
the
the conspiracy.
conspiracy.
Act 41.
Actdl.
7th day
0f December
On
about the
On or
or about
the 7th
December 2020,
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS
2020, RUDOLPH
day of
of
David
call
of
the
House
GIULIANI placed
GIULIANI
placed aa telephone
to Speaker
Georgia House ofRepresentatives
Representatives David
Speaker of the Georgia
telephone call to
This was
was an
an
of the Georgia
General Assembly.
discussed holding
Ralston and
and discussed
holding aa special
special session
sessionofthe
Assembly. This
Ralston
Georgia General
the conspiracy.
in furtherance
ﬁthheranceoof
overt act
act in
overt
fthe
conspiracy.

Page 30 Act
42.
Actd2,
TRUMP committed
JOHN TRUMP
DONALD JOHN
7th day
of December 2020,
On or
or about
about the
On
the 7th
dayofDecember
2020, DONALD
committed the
the
OATH BY
in
offense of
of SOLICITATION
SOLICITATION OF
PUBLIC OFFICER,
BY PUBLIC
OF OATH
VIOLATION OF
OF VIOLATION
OFFICER, in
felony offense
felony
16-4-in
Fulton
violation
164-&
16-10-1,
in
Fulton
County,
Georgia,
by
unlawfully
soliciting,
of O.C.G.A.
O.C.G.A. §§
&
Violation of
16-10-1,
County, Georgia, by unlawfully soliciting,
§§
of Representatives David
and importuning
of the Georgia
requesting, and
Speakerofthe
Georgia House
HouseofRepresentatives
David Ralston,
Ralston, aa
importuning Speaker
requesting,
of Oath by
of Violation ofOath
offense ofViolation
conduct constituting
public ofﬁcer,
officer, toto engage
in conduct
consituting the
the felony
felony offense
by
engage in
public
the
General
of
session
O.C.G.A. §§ 1610-1,
Public
Officer, 0.C.G.A.
16-10-1, by
by calling
calling aa special
Georgia General
Public Ofﬁcer,
special session ofthe Georgia
from
electors
for
the
of
Assemblyforthe
purpose
of
unlawfully
appointing
presidential
electors
from Georgia,
Georgia, inin willful
willful
unlawfully appointing presidential
Assembly
purpose
with
as
of
said
Violation
of
the
terms
of
the
oath
and
intentional
‘and intentional violation ofthe termsofthe oath of said person
person as prescribed
prescribed by
by law,
law, with intent
intent
the conspiracy.
act in
an overt
conduct. This
furtheranceofoftheconspiracy.
that
said person
in furtherance
overt act
was an
This was
said conduct.
in said
person engage
that said
engage in
Act 43.
Actd3.
JOHN TRUMP
8th dayofDecember
On or
or about
about the
On
the 8th
DONALD JOHN
TRUMP placed
placed aa
2020, DONALD
day of December 2020,
of
false
statements
the
Carr
for
call
to
General
Chris
telephone
call
to
Georgia
Attorney
General
Chris
Car
for
the
purpose
of
making
making false statements
purpose
Georgia Attorney
telephone
and
elsewhere.
election
concerning
fraud inin the
the November
November 3,3, 2020,
presidential election in-Georgia
in Georgia and elsewhere.
2020, presidential
concerning fraud
not
other state
asked
Carr
TRUMP
During
the
telephone
call,
DONALD
JOHN
TRUMP
asked
Carr
not toto discourage
state
the
DONALD
JOHN
discourage other
call,
During
telephone
Texas
the
State
of
filed
the
ﬁom
a
federal
lawsuit
attorneys
general
fromjoining
a
federal
lawsuit
filed
by
the
StateofTexas
contesting
the
contesting
by
joining
attorneys general
election in
administrationofthe
November 3,3, 2020,
2020, presidential
presidential election
in Georgia,
Georgia, Michigan,
Michigan,
administration of the November
of the conspiracy.
act in
and Wisconsin.
This was an overt
Pennsylvania, and
Wisconsin. Thiswasan
overt act
in furtherance
furtheranceofthe
conspiracy.
Pennsylvania,
Act
44.
Actdd,
TRUMP and
and JOHN
JOHN
JOHN TRUMP
On
about the
8th dayof
2020, DONALD
DONALD JOHN
On or
or about
the 8th
December 2020,
day of December
Committee
National
call to
to Republican
CHARLES
placed aa telephone
telephone call
Republican National Committee
EASTMAN placed
CHARLES EASTMAN
certain individuals
her assistance
assistance gathering
to request
Chairwoman
Ronna McDaniel
McDaniel to
request her
individuals toto meet
meet and
and
Chairwoman Ronna
gathering certain
in
certain
December
states
on
for
DONALD
JOHN
TRUMP
electoral votes
votes for DONALD JOHN TRUMP on December 14,
cast electoral
14, 2020,
cast
2020, in certain states
election
lost
the
November
the
fact
that
DONALD
JOHN
TRUMP'
despite
the
fact
that
DONALD
JOHN
TRUMP
lost
the
November
3,
2020,
presidential election
3,
2020, presidential
despite
of
the
This
was
an
act
in
furtherance
those
states.
overt
in
in those states. This was an overt act in furtheranceofthe conspiracy.
conspiracy.
Act
45.
Actds.
A. ROMAN sent aa text
On
or about
8th day
On or
the 8th
dayofof December
December 2020,
MICHAEL
A.ROMANsent
text
about the
2020, MICHAEL
to
the
is
known
Grand
whose
unindicted
1ndividual
to
‘message
to
unindicted
co-conspirator
Individual
4,
whose
identity
is
known
to
the
Grand
Jury,
4,
identity
Jury,
co-conspirator
message
and asked
asked unindicted
stated that
stated
that he
he had
had spoken
to MISTY
MISTY HAMPTON,
HAMPTON, and
unindicted co-conspirator
co-conspirator
spoken to
the
before
of
to
attend
the
Individual 44 toto “get”
MISTY
HAMPTON
to
attend
the
hearing
before
the
Georgia House
House of
MISTY
HAMPTON
Individual
Georgia
hearing
"get"
This
an
act
Governmental Affairs
Representatives Governmental
Affairs Committee
Committee on
on December
December 10,
10, 2020.
2020. This was
was an overt
overt act
Representatives
furtherance of the conspiracy.
inin furtheranceofthe
conspiracy.

Page 31 46.
Act
Act 46.
JOHN CHESEBRO
CHESEBRO wrote
On or
about the
9th dayofDecember
On
or about
the 9th
KENNETH JOHN
wrote aa
2020, KENNETH
day of December 2020,
Electoral Votes”
Votes" to
to James
James R.
memorandum
‘memorandum titled
titled “Statutory
Requirements for
for December
December 14 Electoral
R.
"Statutory Requirements
The
memorandum
an
associated
with
the
‘Troupis,
an
attorney
associated
with
the
Trump
Campaign.
The
memorandum
provides
detailed,
provides detailed,
Trump Campaign.
Troupis,
attorney
for how
how Trump
state-specific instructions
instructions for
presidential elector
elector nominees
nominees inin Georgia,
Arizona,
Georgia, Arizona,
state-speciﬁc
Trurnp presidential
meet
and
would
cast
electoral
votes
for
Wisconsin
and
Michigan,
Nevada,
Pennsylvania,
and
Wisconsin
would
meet
and
cast
electoral
votes
for
Michigan, Nevada, Pennsylvania,
the fact
JOHN
DONALD
TRUMP on
DONALD JOHN
JOHN TRUMP
on December
December l4,
14, 2020,
despite the
fact that
that DONALD
DONALD JOHN
2020, despite
in those
act
election in
This was
TRUMP lost
TRUMP
lost the
the November
November 3,3, 2020,
2020, presidential
presidential election
those states.
states. This
was an
an overt
overt act
of the conspiracy.
in
in ﬂirtherance
furtheranceofthe
conspiracy.
Act
47.
Actd7.
On or
or about
the 10th
10th day
of December
On
about the
December 2020,
2020, KENNETH
KENNETH JOHN
JOHN CHESEBRO
CHESEBRO sent
sent an
an
day of
JAMES SHAFER
SHAFER and
e-mail
e-mail toto Georgia
Republican Party
Chairman DAVID
DAVID JAMES
and unindicted
unindicted cocoGeorgia Republican
Party Chairman
to
the
Grand
KENNETH
JOHN
is
known
Individual
whose
conspirator
Individual
9,
whose
identity
is
known
to
the
Grand
Jury.
KENNETH
JOHN
9,
Jury.
identity
conspirator
individuals associated
with the
CHESEBRO stated
stated in
e-mail that
CHESEBRO
in the
the e-mail
that certain
certain individuals
associated with
the Trump
Trump Campaign
Campaign
to
With
asked
asked him
him "to
“10 help
help coordinate
coordinate with
with the
the other
other 55 contested
contested States,
to
help
with
logisticsofthe
States,
help
logistics of the
on Monday."
This was
an overt
overt
other States
electors
States hopefully
electors inin other
hopefullyjoining
in casting
casting their
their votes
votes on
Monday.” This
was an
joining in
act
furtherance of the conspiracy.
actinin furtheranceofthe
conspiracy.
Act
48.
Actas,
KENNETH JOHN
sent an
an
On
or about
about the
of December
On or
the 10th
10th day
December 2020,
2020, KENNETH
JOHN CHESEBRO
CHESEBRO sent
day of
and
e-mail
with
attached
DAVID
JAMES
SHAFER
unindicted
documents
to
e-mail with attached documents to DAVID JAMES SHAFER and unindicted co-conspirators
co-conspirators
are known
known to
Grand Jury.
Individual
Individual 10,
and Individual
Individual 9,9, Individual
10, and
Individual 11,
11, whose
whose identities
identities are
to the
the Grand
The
Jury. The
in
elector
nominees
for
the
documents
documents were
were toto be
be used
used by
by Trump
presidential
elector
nominees
in
Georgia
for
the
purpose
of
Georgia
purpose of
Trump presidential
on December
December 14,
electoral votes
JOHN TRUMP
TRUW on
fact
casting electoral
votes for
for DONALD
DONALD JOHN
2020, despite
despite the
the fact
14, 2020,
casting
DONALD JOHN
JOHN TRUMP
election
in
that DONALD
that
TRUMP lost
lost the
the November
November 3,3, 2020,
presidential
election
in
Georgia.
2020, presidential
Georgia.
This was
an overt
furtherance of the conspiracy.
‘This
was an
overt act
actinin furtheranceofthe
conspiracy.
Act
49.
Actd9.
On or
or about
JOHN CHESEBRO
CHESEBRO sent
about the
December 2020,
On
the 10th
10th dayof
KENNETH JOHN
sent an
an
2020, KENNETH
day of December
email
Director Greg
Safsten
attached documents
documents to
e-mail with
with attached
to Arizona
Arizona Republican
Party Executive
Executive Director
Republican Party
Greg Safsten
and
The documents
used by
elector
nominees
in
Arizona
documents were
and others.
others. The
were 'toto be
be used
Trump
presidential
elector
nominees
in
Arizona
by Trump presidential
TRUMP on
on December
for
of casting electoral
electoral votes
for the
the purpose
purposeofcasting
votes for
for DONALD
DONALD JOHN
JOHN TRUMP
December 14,
14, 2020,
2020,
lost the
election
that DONALD
TRUMP lost
despite
the fact
fact that
DONALD JOHN
JOHN TRUMP
the November
November 3,3, 2020,
2020, presidential
presidential election
despite the
This was
of the conspiracy.
in
an over't act in ﬂirtherance
in Arizona.
Arizona. This
was anovertactin
furtherance ofthe
conspiracy.
3l

Page 32 Act
Act 50.
50.
On or about the 10th dayof December 2020, KENNETH JOHN CHESEBRO sent an
‘e-mail to Republican PartyofWisconsin Chairman Brian Schimming with proposed language
for documents to be used by Trump presidential elector nominees in Wisconsin for the purpose
ofcasting 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 furtheranceofthe conspiracy.
On or about the 10th day of December 2020, KENNETH JOHN CHESEBRO sent an
e-mail to Republican Party of Wisconsin 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,
Act51an
KENNETH JOHN
sent an
JOHN CHESEBRO
CHESEBRO sent
On
or about
about the
On or
the 10th
10th dayof
December 2020,
2020, KENNETH
day of December
JOHN
Chairman Jirn
DeGraffenreid. KENNETH
e-mail to
‘e-mail
to Nevada
Nevada Republican
Republican Party
Party Vice
Vice Chairman
Jim DeGraffenreid.
KENNETH JOHN
and other
other
RUDOLPH
WILLIAM
LOUIS
GIULIANI
that
CHESEBRO
in
the
e-mail
stated in the e-mail that RUDOLPH WILLIAM LOUIS GIULIANT and
CHESEBRO stated
other
asked him
"to reach
out tto
individuals associated
with the
the Trump
him “to
reach out
o youandthe
individuals
associated With
you and the other
Campaign asked
Trump Campaign
to
have
all
electors
in
all
six
contested
on
Nevada
electors to
the
Nevada electors
to run
run point
on
the
plan
to
have
all
Trump-Pence
electors
in
all
six
contested
Trump-Pence
plan
point
an overt
overt act
Dec. 14.”
14." This
This was
States meet
States
meet and
and transmit
transmit their
their votes
votes toto Congress
on Monday,
Monday, Dec.
wasan
actinin
Congress on
furtherance
of
the
furtheranceofthe conspiracy.
conspiracy.
Act
ActS2.
JOHN CHESEBRO
CHESEBRO sent
On or
or about
about the
10th day
On
the 10th
of December
December 2020,
KENNETH JOHN
sent an
an
2020, KENNETH
day of
The
to
DeGraffenreid.
documents
were
be
used
with
documents
to
Jim
email
e-mail with attached
attached documentsto Jim DeGraffenreid. The documents were to beusedby
by Trump
Trump
of
for
the
electoral
votes
for
DONALD
in
Nevada
elector
nominees
presidential
elector
nominees
in
Nevada
for
the
purpose
of
casting
electoral
votes
for
DONALD.
purpose
casting
presidential
the fect
that DONALD
TRUMP lost
lost
fact that
JOHN TRUMP
JOHN TRUMP
TRUMP on
on December
JOHN
December 14,
14, 2020,
DONALD JOHN
2020, despite
despite the
overt actin
act in furtherance
the
the November
November 3,3, 2020,
presidential election
election inin Nevada.
Nevada. This
This was
was an
an overt
furtherance of
of
2020, presidential
the
the conspiracy.
conspiracy.
Act Act52.
KENNETH JOHN
sent an
On or
or about
about the
On
the 10th
10th dayof
December 2020,
2020, KENNETH
JOHN CHESEBRO
CHESEBRO sent
an
day of December
of
Thomas
Counsel Thomas
e-mail with
documents to
attached documents
‘e-mail
with attached
to Republican
Republican Partyof
Pennsylvania
General Counsel
Party
Pennsylvania General
W.
The documents
in
documents were
be used by Trump
elector nominees
nominees in
W. King
Ill. The
were totobeusedby
presidential lector
King III.
Trump presidential
electoral
votes
for
DONALD
TRUMP
on
for
of
JOHN
the
Pennsylvania
for
the
purposeofcasting
electoral
votes
for
DONALD
JOHN
TRUMP
on
casting
Pennsylvania
purpose
JOHN TRUMP
TRUMP lost
lost the
December 14,
the fact
December
14, 2020,
2020, despite
fact that
that DONALD
DONALD JOHN
the November
November 3,3, 2020,
2020,
despite the
an
in
This
was
overt
act
furtherance
of
the
in
election
presidential
election
in
Pennsylvania.
This
was
an
overt
actin
furtheranceofthe
conspiracy.
Pennsylvania.
conspiracy.
presidential
Act
54.
Act54,
and the
14th day
of December 2020,
On or
between the 10th
On
orbetweenthe
10th dayofDecember
2020 and
the 14th
dayofDecember
2020,
day of December Individual
whose
DAVID
JAMES SHAFER
SHAFER contacted
contacted unindicted
DAVID JAMES
unindicted co-conspirator
Individual
2,
whose
identity
is
2,
coconspirator
identity is
discussed nindicted
unindicted co-conspirator
Individual 2's
known
the Grand
Grand Jury,
Known toto the
Jury, by
telephone and
and discussed
co-conspirator Individual
2's
by telephone
of Trump presidential
elector nominees
Fulton
attendance at
at the
the December
attendance
December 14,
14, 2020,
2020, meeting
meetingofTrump
presidential elector
nominees inin Fulton
of the conspiracy.
act in
an overt
overt act
‘County,
This was
wasan
in furtherance
furtheranceofthe
conspiracy.
County, Georgia.
Georgia. This
I

Page 33 Act
55.
Act 55,
On or about the 10th dayof December 2020, RUDOLPH WILLIAM LOUIS
GIULIANI and RAY STALLINGS SMITH III committed the felony offense of
SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, in violation of
0.C.G.A. §§ 164-7 & 16-10-1, in Fulton County, Georgia, by unlawfully soliciting, requesting,
and importuning certain public officers then serving as elected membersofthe 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 offenseofViolationofOath by Public
Officer, 0.C.G:A. § 16-10-1, by unlawfully appointing presidential electors from Georgia, in
willful and intentional violationofthe termsofthe oath of saidpersonsas prescribed
by law,
furtheranceofthe
in
act
with intent that said persons engagein said conduct. This wasanovert
conspiracy.
On or about the 10th day of December 2020, RUDOLPH WILLIAM 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 of Violation of Oath 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.

Page 34 Act
56.
Act 56.
On or about the 10th day of December 2020, RUDOLPH WILLIAM LOUIS
GIULIANI committed the felony offense of FALSE STATEMENTS AND WRITINGS, in
violation of 0.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly, willfully, and
unlawfully making at least oneof the following false statements and representations to members
ofthe Georgia HouseofRepresentatives present at a House Govemmental Affairs Committee:
‘meeting:
meeting:
State Farm
from November
that
2020, that
clear from
November 3,3, 2020,
That it is
video from
Arena Video
1.
Farm Arena
the State
from the
is quite
1. Thatit
quite clear
were
ofﬁcials
workers
were
votes
and
that
election workers were stealing
Fulton
stealing votes and that Georgia
County election
Fulton County
Georgia officials were
in
a
crime
covering
up
acrime
in
plain
sight;
plain sight;
covering up
rid of all
the
of the
ll of
ofﬁcials “got
on November
Democratic officials
That at
State Farm
November 3,3, 2020,
Arena on
Farm Arena
at State
2. That
2020, Democratic
"got ridof
of
a
excuse
used
the
a
of
be
excuse
the
used
that
couldn't
trusted,”
be
all
the
couldn’t
that
anyone
reporters, all the observers,
trusted,"
observers, anyone
reporters,
crooked
their dirty,
"went about
cleared out
out the
area and
and then
then “went
dirty, crooked
about their
watermain
voting area
the voting
break, cleared
‘watermain break,
business”;
business";
election
counted by
and 24,ballots were
were illegally
Fulton County
by Fulton
illegally counted
12,000 and
between 12,24,000 ballots
County election
That between
3. That
on November
Farm Arena
State Farm
workers
‘workers atat State
Arena on
November 3,3, 2020;
2020;
out to
counted than
ballots counted
4.4 That
That inin Michigan,
Michigan, there
there were
were 700,700,000 more
more ballots
than were
were sent
sent out
10 voters
voters
for
was
accounted
quadruple
by
which
for
accounted
election, which was
in
presidential election,
2020, presidential
November 3,3, 2020,
the November
in the
by quadruple
counting
ballots;
ballots;
counting
On or about the 10th day of December 2020, RUDOLPH WILLIAM LOUIS
GIULIANI committed the felony offense of FALSE STATEMENTS AND WRITINGS, in
Violation of O.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
A
an unidentified
unidentiﬁed man
“quite obviously
were "quite
man were
andan
Moss, and
Freeman, Shaye
obviously
Ruby Freeman,
That Ruby
5. That
Shaye Moss,
State
heroin
or
if
vials
of
around
USB
as
surreptitiously
passing around USB ports
ports as iftheyre
ofheroin or cocaine"
cocaine” atat State
they're vials
surreptitiously passing
crooked Dominion
"inﬁltrate the
Farm Arena
Arena toto be
be used
used toto “infiltrate
the crooked
Dominion voting
voting machines";
machines”;
Farm

election
in the
counted in
November 3,3, 2020,
the November
mail-in ballots
were counted
ballots were
2020, presidential
That 96,6.6 That
presidential election
96,600 mail-in
returned
to
been
to
of those ballots
having been returned aa
ballots having
in
recordofthose
no record
there being
despite there
in Georgia,
being no
Georgia, despite
elections office;
county elections
ofﬁce;
county
and
of the Ofﬁce
of the Georgia
said statements
statements being
Officeofthe
jurisdictionofthe
the jurisdiction
within the
being Within
said
Secretary of State and
Georgia SecretaryofState
and
state
and
of
of
county
and
Bureau
govemment,
the
state
agenciesof
and
departments
county
Georgia BureauofInvestigation,
the Georgia
government,
Investigation, departments
agencies
O.C.G.A. §§ 16under O.C.G.A.
16an act of racketeering activity
enforcement agencies.
and city
wasanactofracketeering
This was
law enforcement
‘and
activity under
agencies. This
city law
furtherance of
an overt
act in
and an
14-14-3(5)(A)(xxii)
overt act
in furtherance
of the
the conspiracy.
conspiracy.
(5)(A)(xxii) and

Page 35 Act 57.
Act57.
SHAFER reserved
On
about the,
of December 2020,
On or
or about
the 11th
11th day
dayofDecember
DAVID JAMES
JAMES SHAFER
reserved Room
Room
2020, DAVID
State
in
for
the
December
216 at the
Fulton
216at
the Georgia
State
Capitol
in
Fulton
County,
Georgia,
for
the
December
14,
2020,
meeting
14, 2020, meeting
Georgia
Capitol
County, Georgia,
This was
overt act
of Trump presidential
ofTrump
presidential elector
elector nominees
nominees inin Fulton
Fulton County,
was an
an overt
act inin
Georgia. This
County, Georgia.
furtherance
of the conspiracy.
furtheranceofthe
conspiracy.
Act
Act 58.
58,
CHESEBRO sent
or about
On or
On
about the
the 11th
11th day
of December
December 2020,
KENNETH JOHN
JOHN CHESEBRO
sent an
an
2020, KENNETH
day of
and stated
the electoral votes
sent in
Jim DeGraffenreid
"the purpose
of having
e-mail
mail toto Jim
DeGraffenreid and
stated that
that “the
purposeof
havingtheelectoral
votes sent
in toto
and to
to
the opportunity
Congress isis toto provide
to debate
debate the
the election
election irregularities
irregularities inin Congress,
Congress, and
Congress
provide the
opportunity to
This
an
act
in
the
that
the
votes
be
to
was
overt
alive
could
keep
alive
the
possibility
that
the
votes
could
be
flipped
toTrump.”This
was
an
overt
act
in
possibility
ﬂipped Trump."
keep
of the
ﬁlrtherance
furtheranceof
the conspiracy.
conspiracy.
Act 59.
59.
Act
CHESEBRO sent
sent an
On or
or about
about the
JOHN CHESEBRO
an
On
the 11th
11th dayof
December 2020,
2020, KENNETH
KENNETH JOHN
day of December
The
documents
were
to
be
used
attached documents
Safsten
and
others.
e-mail with
e-mail
with attached
documents toto Greg
Safsten
and
others.
The
documents
were
to
be
used
by
by
Greg
votes for
electoral votes
‘Trump presidential
presidential elector
elector nominees
nominees inin Arizona
Arizona for
for the
the purposeofcasting
for
Trump
purpose of casting electoral
on December
JOHN
DONALD
JOHN TRUMP
DONALD JOHN
TRUMP on
December 14,
the fact
fact that
that DONALD
DONALD JOHN
14, 2020,
2020, despite
despite the
was
an
lost
the
November
Arizona.
This
overt
TRUMP
election
in
TRUMP lost the November 3,3, 2020,
act inin
2020, presidential
presidential election in Arizona. This was an overt act
furtherance of the conspiracy.
furtheranceofthe
conspiracy.
Act
60.
Act 60.
CHESEBRO sent
or about
of December
JOHN CHESEBRO
sent an
an
On or
On
about the
the 11th
11th day
day of
December 2020,
KENNETH JOHN
2020, KENNETH
attached documents
with attached
documents to
ROMAN and
associated
e-mail
e-mail with
to MICHAEL
MICHAEL A.
A. ROMAN
and other
other individuals
individuals associated
The documents
the Trump
documents were
with
with the
were toto be
be used
used by
by Trump
presidential elector
elector
Trump Campaign.
Campaign. The
Trump presidential
for the purposeofcasting
TRUMP on
on
nominees in
electoral votes
votes for
‘nominees
in Nevada
Nevadaforthe
for DONALD
DONALD JOHN
JOHN TRUMP
purpose of casting electoral
the
TRUMP
lost
the
November
fact
that
DONALD
JOHN
December
December 14,
2020,
despite
the
fact
that
DONALD
JOHN
TRUMP
lost
the
November
3,
2020,
14, 2020, despite
3, 2020,
of the conspiracy.
election in
This was
overt act
act in
presidential
in Nevada.
Nevada. This
was an
an overt
in furtherance
furtheranceofthe
conspiracy.
presidential election
Act
61.
Act6l,
On or
or about
KENNETH JOHN
CHESEBROsentan
sent an
On
about the
the 11th
11th day
of December
December 2020,
2020, KENNETH
JOHN CHESEBRO
day of
e-mail with
documents to
to MICHAEL
‘e-mail
with attached
attached documents
MICHAEL A.
A. ROMAN,
unindicted co-conspirator
co-conspirator
ROMAN, unindicted
The
were
Individual
known to the
the Grand
and
others.
documents
be
Individual 5,5, whose
whose identity
identity isisknownto
Grand Jury,
and
others.
The
documents
were toto be
Jury,
of casting electoral
used by
elector nominees
nominees in
used
by Trump
presidential elector
in Georgia
for the
the purpose
purposeofcasting
electoral
Trump presidential
Georgia for
DONALD JOHN
JOHN TRUMP
fact
votes for
TRUMP on
the
that
DONALD
votes
for DONALD
on December
December 14,
14, 2020,
2020, despite
the
fact
that
DONALD
despite
TRUMP lost
lost the
the November
This was
an overt
JOHN
overt
JOHN TRUMP
November 3,3, 2020,
election inin Georgia.
Georgia. This
was an
2020, presidential
presidential election
of the conspiracy.
act in furtherance
actin
furtheranceofthe
conspiracy.
'

Page 36 Act
62.
Act62.
contacted
JAMES SHAFER
SHAFER contacted
On
the 12th
12th day
December 2020,
2020, DAVID
DAVID JAMES
On or
or about
about the
of December
day of
Grand Jury,
and
known twhose identity
unindicted co-conspirator
Individual 12,
12, whose
identity isis known
to the
the Grand
unindicted
Jury, and
co-conspirator Individual
discussed unindicted
discussed
unindicted co-conspirator
co-conspirator Individual
Individual 12's
12's attendance
attendance atat the
the December
December 14,
14, 2020,
2020,
act
an overt
overt act
‘meetingofTrump
presidential elector
nominees inin Fulton
Fulton County,
Georgia. This
This was
was an
of Trump presidential
elector nominees
County, Georgia.
meeting
of the conspiracy.
inin furtherance
furtheranceofthe
conspiracy.
63.
Act
Act63.
On or about the 12th day of December 2020, MICHAEL A. ROMAN sent an e-mail to
unindicted co-conspirators Individual 4 and Individual 7, whose idenitcs are known to the
Grand Jury, and other individuals associated with the Trump Campaign. In the e-mail,
MICHAEL
A. ROMAN stated, “I need a tracker for the electors,” and instructed individuals
associated with the Tramp 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 electornomineeshad confirmed that they would
attend the December 14, 2020, meetingsof Trump presidential lector 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.
On or about the 12th day of December 2020, MICHAEL A. 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,
MICHAEL A. 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.
Act6d.
On or about the 12th day of December 2020, KENNETH JOHN CHESEBRO met
with Brian Schimming and discussed the December 14, 2020, meetingofTrump presidential
elector nominees in Wisconsin. RUDOLPH WILLIAM LOUIS GIULIANI joined the meeting
by telephone and stated that the media should not be notifiedofthe December 14, 2020, meeting
of Trump presidential elector nominees in Wisconsin. These were overtacts in furtheranceofthe
On or about the 12th day of December 2020, KENNETH JOHN CHESEBRO met
with Brian Schimming and discussed the December l4, 2020, meeting of Trump presidential
elector nominees in Wisconsin. RUDOLPH WILLIAM 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.
conspiracy.
Act6s.
AL65On or about the 12th dayofDecember 2020, MICHAEL A. ROMAN instructed an
individual associated withthe Trump Campaign to distribute certain information relatedto the
December 14, 2020, meetingsof Trump 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 furtheranceofthe conspiracy.
On or about the 12th day of December 2020, MICHAEL A. ROMAN instructed an
individual associated with the Trump Campaign to distribute certain information related to the
December 14, 2020, meetings of Trump 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.

Page 37 AL"Act 66.
Individual 4,
On
about the
unindicted co-conspirator
4,
December 2020,
12th dayof
2020, unindicted
the 12th
or about
co-conspirator Individual
On or
day of December
A.
ROMAN
and
e-mail
to
MICHAEL
sent
an
the Grand Jury,sentan
whose identity
identity is
is known
known to
totheGrand
e-mail
to
MICHAEL
A.ROMAN
and
Whose
Jury,
the progress
on the
DAVID JAMES SHAFER with
with updates
updates on
of organizing
the December 14,
14, 2020,
2020,
organizing the
progress of
meeting of Trump presidential elector nominees in Fulton County, Georgia. The e-mail stated
individuals had
had
other individuals
that other
elector nominees
meeting, that
the meeting,
which
attend the
would attend
they would
confirmed they
had conﬁrmed
nominees had
‘which elector
refused to
in the
nominees refused
that
meeting, that
of the elector
the meeting,
in case
case some
someofthe
participate in
to participate
been
elector nominees
secured in
been secured
that
DAVID
to
the
and
access
to
ensure
Georgia
legislators
hadbeencontacted
to
ensure
access
to
the
Georgia
Capitol,
and
that
had
contacted
been
Georgia Capitol,
Georgia legislators
in furtherance
furtherance
This was
an overt act
216 for
had reserved
reserved Room
JAMES SHAFER
SHAFERhad
Room for the
the meeting.
meeting. This
wasanovert
act in
JAMES
meeting ofTrump presidential elector nominees in Fulton County, Georgia. The e-mail stated
of the conspiracy.
ofthe
conspiracy.
67.
Act 67.
sent an
an e-mail
JAMES SHAFER
SHAFER sent
On
or about
of December
On or
the 12th
12th day
day of
December 2020,
2020, DAVID JAMES
e-mail
about the
known
to
the
Grand
is
advising
Jury,
whose
Grand
the
to
Individual
known
is
unindicted
identity
whose
4,
to
Individual
to unindicted co-conspirator
4,
Jury, advising
identity
co-conspirator
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.
them to “touch base” with each ofthe Trump presidential elector nominees in Georgia in advance
ofthe December 14, 2020, meeting to confirm their attendance. This was an overtact in
furtheranceofthe conspiracy.
Act 68.
68.
of December
On or
or about
the 12th
On
about the
12th day
December 2020,
2020, unindicted
unindicted co-conspirator
co-conspirator Individual
Individual 4,
4,
day of
whose identity is knownto the Grand Jury, senta text message with contact information for
whose identity is known to the Grand Jury, sent a text message with contactlinformation for
and Georgia
Grand Jury,
whose identity
Jury, and
Individual 8,
the Grand
to the
unindicted
known to
is known
identity is
Georgia
unindicted co-conspirator
8, whose
coconspirator Individual
of providing the
contact
A. ROMAN
Senator Brandon
Brandon Beach
Beach to
to MICHAEL
MICHAEL
A.
ROMAN for
for the
the purpose
purposeofproviding
the contact
Senator
an overt
overt act
act in
in
GIULIANI. This
This was
information to
to RUDOLPH
WILLIAM LOUIS
LOUIS GIULIANI.
was an
information
RUDOLPH WILLIAM
of the conspiracy.
furtherance
furtheranceofthe
conspiracy.
Act 69.
69.
an
sent an
CHESEBRO sent
of December 2020,
On or
or about
13th day
dayofDecember
the 13th
about the
2020, KENNETH JOHN CHESEBRO
On
The
were
to
be
used
A.
documents
ROMAN.
to
MICHAEL
‘e-mail
with
attached
documents
to
MICHAEL
ROMAN.
Thedocumentswere
to
be
used
by
attached
documents
e-mail with
by
of casting electoral
electoral votes
votes
elector nominees
purposeofcasting
the purpose
for the
Mexico for
in New Mexico
nominees in
presidential elector
Trump
Trump presidential
fact
that
DONALD
JOHN
the
for DONALD JOHN
TRUMP on
December 14,
14, 2020,
despite
the
fact
that
JOHN
JOHN TRUMP
on December
for'DONALD
2020, despite
was an
overt act
election in New Mexico.
TRUMP
lost the
‘TRUMP lost
the November
November 3,
3, 2020,
presidential electionin
Mexico. This was
an overt
act
2020, presidential
in furtherance of the conspiracy.
in furtherance ofthe conspiracy.

Page 38 Act
Act 70.
70.
On or about the 13th day of December 2020, KENNETH JOHN CHESEBRO sent an
e-mail to RUDOLPH WILLIAM LOUIS GIULIANI with the subject “PRIVILEGED AND
CONFIDENTIAL - Brief notes on ‘Presidentofthe Senate’ strategy.” In the e-mail, KENNETH
JOHN CHESEBRO outlined multiple strategies for disrupting and delaying thejoint 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.” Thiswas an overt act in furtherance of
the conspiracy.
On or about the 13th day of December 2020, KENNETH JOHN CHESEBRO sent an
e-mail to RUDOLPH WILLIAM 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.

AL71Act71.
an
sent an
CHESEBRO sent
On
the 13th
13th dayof
December 2020,
2020, KENNETH
KENNETH JOHN
JOHN CHESEBRO
On or
or about
about the
day of December
and unindicted
unindicted co-conspirator
mail
to MICHAEL
MICHAEL A.
A. ROMAN
ROMAN and
email with
with attached
attached documents
documents to
co-conspirator
Grand Jury.
The documentswereto
documents were to be
Individual 4,4, whose
identity isis known
known toto the
the Grand
be used
used by
Individual
whose identity
by
Jury. The
the
votes
for
in
for
of
electoral
elector
nominees
“Trump
presidential
elector
nominees
in
Georgia
for
the
purposeofcasting
electoral
votes
for
Georgia
purpose
casting
Trump presidential
fact
that
JOHN
December
the
DONALD
on December l4,
DONALD JOHN
JOHN TRUMP
DONALD
TRUMP on
14, 2020,
2020, despite
despite the fact that DONALD JOHN
act in
an overt
overt act
was an
TRUMP lost
the November
November 3,
TRUMP
lost the
2020, presidential
presidential election
election inin Georgia.
This was
in
3, 2020,
Georgia. This
ﬁlrtherance
of
the
furtheranceofthe conspiracy.
conspiracy.
Act
72.
Act72.
an
CHESEBRO sent
On or
or about
the 13th
On
about the
13th day
of December
December 2020,
KENNETH JOHN
JOHN CHESEBRO
sent an
2020, KENNETH
day of
is
Individual
whose
and unindicted
A. ROMAN
e-mail
to MICHAEL
MICHAEL A.
ROMAN and
unindicted co-conspirator
Individual
4,
whose
identity
e-mail to
4,
identity is
co-conspirator
to
"wants
that RUDOLPH
WILLIAM LOUIS
LOUIS GIULIANT
GIULIANI “wants to
and stated
known
Grand Jury,
known toto the
the Grand
stated that
RUDOLPH WILLIAM
Jury, and
December 14,
after all
keep this
this quiet
quiet until
until after
al the
the voting
voting isis done,”
in reference
reference toto the
the December
14, 2020,
2020, meeting
done," in
meeting
keep
an
overt
act in
in
Fulton
This
was
of Trump
elector nominees
of
presidential elector
nominees in Fulton County,
County, Georgia.
in
Georgia. This was an overt act
Trump presidential
furtherance
of the conspiracy.
furtheranceofthe
conspiracy.
Act 73.
Act73.
December 2020,
DAVID JAMES
JAMES SHAFER
SHAFER sent
On or
or about
about the
On
the 13th
13th dayof
2020, DAVID
sent aa text
text
day of December
Grand
Individual
whose
is
known
to
the
‘message
to
unindicted
co-conspirator
Individual
4,
whose
identity
is
known
to
the
Grand
Jury,
to
unindicted
4,
Jury,
identity
message
co-conspirator
is known
and stated
stated that
that unindicted
and
unindicted co-conspirator
Individual 8,8, whose
whose identity
known toto the
the Grand
Grand
identity is
co-conspirator Individual
in
nominees
of
elector
December
would
attend
the
Jury,
would
attend
the
December
14,
2020,
meetingof
Trump
presidential
elector
nominees
in
14,
2020,
meeting
Trump presidential
Jury,
to
a
refused
the
of
elector
nominee
who
Fulton County,
in the place
place ofa Trump
presidential elector nominee who refused to
Fulton
Trump presidential
County, Georgia,
Georgia, in
an
overt
act
in
furtherance
This
was
of the conspiracy.
in
the
participate
in
the
meeting.
This
was
an
overt
act
in
furtheranceofthe
conspiracy.
meeting.
participate

Page 39 Act
Act 74.
74.
13th dayof
On
or about
the 13th
December 2020,
2020, unindicted
unindicted co-conspirator
Individual 9,9,
On or
about the
co-conspirator Individual
day of December
SHAFER
JAMES SHAFER
sent aa text
DAVID JAMES
Grand Jury,
‘whose
identity isis known
known toto the
the Grand
text message
message toto DAVID
whose identity
Jury, sent
known to
is
to
and
unindicted
Individual
whose
is
identity
he
whose
13,
and
conﬁrmed
that
Individual
co-conspirator
‘and confirmed that he and unindicted co-conspirator
13,
identity known
elector
December 14,
attend the
the December
presidential elector
Trump presidential
the Grand
Grand Jury,
meetingofof Trump
2020, meeting
14, 2020,
would attend
Jury, would
the
of
the
This
was
an
overt
act
in
furtherance
nominees inin Fulton
Fulton County,
Georgia.
This
was
an
overt
act
in
furtheranceofthe
conspiracy.
nominees
conspiracy.
County, Georgia.
Act 75.
75.
Act
TRUMP caused
DONALD JOHN
On or
or about
about the
On
the 14th
14th day
dayof0f December
December 2020,
2020, DONALD
JOHN TRUMP
caused toto be
be
a
fool
Governor
account
"What
@BrianKempGA
tweeted
from the
Twitter account @RealDonaldTrump,
the Twitter
tweeted from
@RealDonaldTrump, “What a fool Governor @BrianKempGA
it the
so
do it
of
is.
Could
have
been
so
easy, but
but now
now we
we have
have toto do
the hard
hard way.
way. Demand
Demand this
this
have
been
is.
Could
of Georgia
easy,
Georgia
could
beaa bad
and open up
NOW.
clown
Special Session
signature
verification,
NOW.
Otherwise,
couldbe
bad
call aa Special
Sessionandopen
clown call
Otherwise,
up signature veriﬁcation,
the
5th." This
an overt act
on January
act in
dayfortwo
Senators on
This was
wasanovert
in furtherance
furtheranceofof the
GREAT Senators
January Sth.”
day for two GREAT
conspiracy.
conspiracy.
Act
Act 76.
76.
sent a text
December 2020,
JAMES SHAFER
SHAFER senta
the 14th
On 0r
On
or about
about the
14th dayof
DAVID JAMES
text
2020, DAVID
day of December
the
Grand
known
to
Individual
whose
is
to
unindicted
message
to
unindicted
co-conspirator
Individual
4,
whose
identity
is
known
to
the
Grand
Jury
4,
Jury
identity
coconspirator
message
to what we
attention towhatwe
216 to
avoid drawing
them to
to avoid
"Listen. Tell
that
that stated,
stated, “Listen.
Tell them
to go
to Room
Room drawing attention
go straight
straight to
elector
the December
December 14,
of Trump presidential
are
are doing,"
doing,” inin reference
reference toto the
14, 2020,
2020, meeting
meetingofTrump
presidential elector
the conspiracy.
This wasanovert
was an overt actin
of the
nominees inin Fulton
Fulton County,
County, Georgia.
furtheranceof
conspiracy.
act in furtherance
nominees
Georgia. This
Act
77.
Act 71.
On or about the 14th day of December 2020, MICHAEL
A.ROMAN sent an e-mail to
unindicted co-conspirators 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 ofthe conspiracy.
On or about the 14th day 0f December 2020, MICHAEL A. 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.
Act78.
and
SMITH III
STALLINGS SMITH
On
about the
the 14th
14th day
of December
December 2020,
RAY STALLINGS
III and
On or
0r about
2020, RAY
day 0f
certain individuals
SHAFER encouraged
DAVID JAMES
individuals present
present atat the
the December
December 14,
14, 2020,
2020,
DAVID
JAMES SHAFER
encouraged certain
the
document
nominees
in
to
document
the
elector
Fulton
sign
to
Georgia,
County,
of
Fulton
in
nominees
presidential elector
Trump presidential
meetingof Trump
sign
County, Georgia,
meeting
This
OF THE
THE GEORGIA." This
titled “CERTIFICATE
VOTES OF
2020 ELECTORS
ELECTORS FROM
FROM GEORGIA.”
OF THE
THE VOTES
"CERTIFICATE OF
titled
of the conspiracy.
act in
an overt
overt act
was an
in furtherance
furtheranceofthe
was
conspiracy.

Page 40 Act
Act 79.
79.
SHAWN
On or about the 14th dayof December 2020, DAVID
DAVID JAMES
JAMES SHAFER,
SHAFER, SHAWN
unindicted
coand
CATHLEEN
TRESHER STILL,
MICAH TRESHER
ALSTON LATHAM,
LATHAM, and unindicted coMICAH
STILL, CATHLEEN ALSTON
Individual 11,
conspirators Individual
Individual 2,2, Individual
Individual 8,8, Individual
Individual 9,9, Individual
Individual 10,
10, Individual
Individual 12,
12,
ll, Individual
conspirators
Individual
and
Individual
Individual
Individual
and
18,
Individual
Individual
17,
Individual
18,
14, Individual 15,
Individual 13,
15, Individual 16,
16, Individual l7,
13, Individual l4,
offense of
of
are known
committed the
Grand Jury,
Individual 19,
whose identities
identities are
known toto the
the Grand
the felony
felony offense
Individual
19, Whose
Jury, committed
in
Fulton
PUBLIC OFFICER,
violation
of
O.C.G.A.
in
IMPERSONATING AA PUBLIC
in
violation
of
0.C.G.A.
§
16-10-23,
in
Fulton
IMPERSONATING
OFFICER,
§ 16-10-23,
and qualified
elected and
as the duly elected
County, Georgia,
falsely holding
holding themselves
themselves out
outastheduly
qualiﬁed
by unlawfully
unlawfully falsely
Georgia, by
County,
to
mislead
the
intent
ﬁom
the
State
of
with
electors
presidential
electors
from
the
Stateof
Georgia,
public
officers,
with
intent
to
mislead
the
Georgia, public ofﬁcers,
presidential
of
States Senate,
Archivist of the United
President of the United
Presidentofthe
United States
the Archivistofthe
United States,
States, the
the Georgia
Secretary of
Senate, the
Georgia Secretary
of Georgia
for the
the Northern
States District
District of
and theChief
the Chief Judgeofthe
Northern District
Court fo
District Court
United States
State, and
Georgia
State,
Judge of the United
States
mail
United
such officers
into believing
they actually
were such
by placing
in the
the United States mail toto said
said
that they
ofﬁcers by
into
actually were
believing that
placing in
FROM
ELECTORS
THE
titled
"CERTIFICATE
OF
THE
VOTES
OF
persons
a
document
titled
“CERTIFICATE
OF
THE
VOTES
OF
THE
ELECTORS
FROM
a
document
persons
and
act ofracketeering
of racketeering activity
This was
GEORGIA.”
was an
an act
activity under
under O.C.G.A.
O.C.G.A. §§ 16-14-3(5)(A)(xxiii)
16-14-3(5)(A)(xxiii) and
GEORGIA." This
anovert
act inin furtherance
furtherance of
of the
the conspiracy.
conspiracy.
an overt act
On or about the 14th day of December 2020,
Act 80.
Act80.
SHAWN
JAMES SHAFER,
about the
December 2020,
On
the 14th
14th dayof
DAVID JAMES
On or
or about
SHAFER, SHAWN
2020, DAVID
day of December
coCATHLEEN ALSTON
TRESHER STILL,
MICAH
ALSTON LATHAM,
LATHAM, and
and unindicted
unindicted coMICAH TRESHER
STILL, CATHLEEN
Individual
Individual
Individual
Individual
Individual
conspirators
Individual 2,2, Individual 8,8, Individual 9,9, Individual 10,
10, Tndividual 11,
12,
ll, Individual 12,
conspirators Individual
Individual
Individual l3,
13, Individual
Individual l4,
14, Individual
Individual 15,
15, Individual
Individual 16,
16, Individual
Individual l7,
17, Individual
Individual l8,
18, and
and
offense of
are known
committed the
Grand Jury,
Individual
Individual 19,
19, whose
whose identities
identities are
known toto the
the Grand
the felony
felony offense
of
Jury, committed
Fulton
THE FIRST
violation of .C.G.A.
O.C.G.A. §§ 16-9-1(b),
FORGERY IN
IN THE
FIRST DEGREE,
DEGREE, inin violationof
16-9-1(b), inin Fulton
FORGERY
document titled
with the
intent to defraud,
County,
by, with
the intentto
knowingly making
making aa document
tiled
defraud, knowingly
Georgia, by,
County, Georgia,
“CERTIFICATE OF
OF THE
THE VOTES
VOTES OF
OF THE
THE 2020 ELECTORS
ELECTORS FROM
FROM GEORGIA,”
"CERTIFICATE
GEORGIA," aa writing
writing
to
have
been
made
in
such
manner
that
the
as
made
other than
than aa check,
in
such
manner
that
the
writing
as
made
purports
to
have
been
made
by
other
check,
by
writing
purports
State
of
who
electors from
of the duly
authorityofthe
elected and
and qualiﬁed
qualified presidential
from the
the Stateof Georgia,
Georgia, who
duly elected
presidential electors
authority
Archivist of the
and uttered
delivered said
said document
document to
not give
such authority,
did not
did
uttered and
and delivered
to the
the Archivistofthe
authority, and
give such
and
was
an
act
of
under
O.C.G.A.
United States.
activity under O.C.G.A. §§ 1614-3(5)(A)(xvi)
16-14-3(5)A)xvi) and
This was an act ofracketeering
United
States. This
racketeering activity
of the conspiracy.
act in furtherance
an overt
an
overt actin
furtheranceofthe
conspiracy.
_

Page 41 Act
81.
Act8L.
SHAF ER, SHAWN
SHAWN
On
or about
the 14th
December 2020,
DAVID JAMES
JAMES SHAFER,
about the
14th dayof
On or
2020, DAVID
day of December
and
unindicted
coTRESHER STILL,
CATHLEEN
ALSTON
MICAH TRESHER
CATHLEEN
ALSTON
LATHAM,
and
unindicted
coMICAH
LATHAM,
STILL,
conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual 11, Individual 12,
Individual 13, Individual 14, Individual 15, Individual 16, Individual 17, Individual 18, and
Individual 19, whose identities are known to the Grand Jury, committed the felony offense of
FALSE STATEMENTS AND WRITINGS, in violationof0.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 Presidentofthe United
States ofAmerica from the StateofGeorgia, do hereby certify the following,” said document
being within thejurisdictionofthe Officeofthe Georgia SecretaryofState and the Officeofthe
‘Govemorof Georgia, departments and agenciesofstate government. This was an act of
racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xxii) and an overt act in furtheranceofthe
conspiracy.
conspiracy.
14le
Act82.
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 AND WRITINGS, in violation of O.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 of America from the State of Georgia, 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 of Georgia, 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
JAMES SHAFER,
On or
or about
about the
On
the 14th
14th dayofDecember
2020, DAVID
DAVID JAMES
SHAWN
SHAFER, SHAWN
day of December 2020,
and
unindicted
coALSTON
TRESHER STILL,
CATHLEEN
MICAH
MICAH TRESHER
CATHLEEN
ALSTON
LATHAM,
and
unindicted
coLATHAM,
STILL,
12,
Individual 12,
11, Individual
conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual ll,
Individual 13,
13, Individual
Individual 14,
14, Individual
Individual 15,
15, Individual
Individual l6,
16, Individual
Individual l7,
17, Individual
Individual 18,
18, and
and
Individual
Individual l9,
19, whose
whose identities
idenities are
are known
known toto the
the Grand
Grand Jury,
Jury, attempted
to commit
commit the
the felony
felony
Individual
attempted to
O.C.G.A. §§ 16-10-20.1(b)(1),
violation of 0.C.G.A.
offenseof
FILING FALSE
FALSE DOCUMENTS,
DOCUMENTS, inin violationof
16-10-20.1(b)(1), inin
offense of FILING
a
document
titled
"CERTIFICATE
in
the
States
mail
United
Fulton
Fulton County,
Georgia,
by
placing
in
the
United
States
mail
a
document
titled
“CERTIFICATE
Counw, Georgia, by placing
to Chief Judge,
addressed toChief
OF THE
OF THE
THE VOTES
‘OF
VOTES OF
THE 2020 ELECTORS
ELECTORS FROM
FROM GEORGIA,”
GEORGIA," addressed
Judge,
D.
Russell
Federal
Oﬁice
Richard
Northern
District
of
U.S.
U.S. District
District Court,
Northern
District
ofGeorgia,
Richard
D.
Russell
Federal
Office:
Court,
Georgia,
GA 30303,
with intent
intent to
to
Building
and U.S.
U.S. Courthouse,
Courthouse, 75 Ted
Ted Turner
Drive, SW,
SW, Atlanta,
Atlanta, GA
Turner Drive,
30303, with
Building and
the
United
reason
and
record
in
a
court
of
said
document
knowingly
file,
enter,
and
record
said
document
inacourt
of
the
United
States,
having
reason
toto
States,
having
knowingly ﬁle, enter,
THE
false
said document
document contained
contained the
know
know that
that said
the materially
statement, “WE,
"WE, THE UNDERSIGNED,
UNDERSIGNED,
materially false statement,
Vice
President
of
the United
and
elected
and
Electors
for
President
the
being
the
duly
elected
and
qualified
Electors
for
President
and
Vice
Presidentofthe
United
being
duly
qualiﬁed
was
an
act of
of
the
This
State of Georgia,
do
States of America
Statesof
America from
from the
the Stateof
do
hereby
certify
the
following.”
This
was
an act
following."
hereby certify
Georgia,
overt act
of the
the
under O.C.G.A.
O.C.G.A. §§ 16-14-3(5)(A)(xxii)
16-14-3 (5)(A)(xxii) and
racketeering activity
activity under
and an
an overt
act inin furtherance
furtheranceof
racketeering
conspiracy.
conspiracy.
conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual
a

Page 42 Act 83.
Act83.
SHAWN
On or
about the
On
or about
the 14th
14th dayof
December 2020,
DAVID JAMES
JAMES SHAFER
SHAFER and
and SHAWN
2020, DAVID
day of December
FORGERY
IN
THE
FIRST
of
the
offense
TRESHER
committed
MICAH
MICAH TRESHER STILL
STILL committed the felony
felony offense ofFORGERY IN THE FIRST
in Fulton
Fulton County,
of O.C.G.A. §§ 1691(b),
DEGREE, inin Violation
violationof0.C.G.A.
16-9-1(b), in
Georgia, by,
by, with
with the
the intent
intent
DEGREE,
County, Georgia,
of
of
Electoral
Notice
titled
"RE:
a
document
to
to defraud,
knowingly making
College
Filling of Electoral College
defraud, knowingly
making a document titled “RE: NoticeofFilling
such manner
Vacancy,” aa writing
writing other
other than
than aa check,
check, inin such
manner that
that the
the writing
writing as
as made
made purports
t0 have
have
purports to
Vacancy,"
electors
from
the
State
and
elected
been
the
of
the
been made
made by
the
authority
ofthe
duly
elected
and
qualified
presidential
electors
from
the
State:
qualiﬁed presidential
by
duly
authority
delivered said
said document
document to
and delivered
who did
did not
such authority,
of Georgia, who
not give
ofGeorgia,
and uttered
uttered and
to the
the
authority, and
give such
under
O.C.G.A.
of racketeering activity
of the United
This was
an act
Archivist
Archivistofthe
United States.
States. This
was an
actofracketeering
under
O.C.G.A.
§
16-14activity
§ 16-14the
of
overt act
act in
3(5)(A)(xvi) and
and an
an overt
in furtherance
furtheranceofthe
conspiracy.
conspiracy.
3(5)(A)(xvi)
84.
Act
Act84,
On or about the 14th dayofDecember 2020, DAVID JAMES SHAFER and SHAWN
MICAH TRESHER STILL committed the felony offense of FALSE STATEMENTS AND
WRITINGS, in violationof 0.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly,
willfully, and unlawfully making and using a false document titled “RE: NoticeofFilling of
Electoral College Vacancy,” with knowledge that said document contained the false statements
that DAVID JAMES SHAFER was Chairman ofthe 2020 Georgia Electoral College Meeting
and SHAWN MICAH TRESHER STILL was Secretaryofthe 2020 Georgia Electoral College
Meeting, said document being within thejurisdictionofthe Officeofthe Georgia Secretary of
State and the Officeofthe GovemorofGeorgia, departments and agenciesofstate government.
‘This was an actofracketeering activity under 0.C.G.A. § 16-14-3(5)(A)(xxii) and an overt act in
furtheranceof the conspiracy.
On or about the 14th day of December 2020, DAVID JAMES SHAFER and SHAWN
MICAH TRESHER STILL committed the felony offense of FALSE STATEMENTS AND
WRITINGS, in violation of O.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly,
willfully, and unlawfully making and using a false document titled "RE: Notice of Filling 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 SHAWN MICAH 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 of Georgia, 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.
Acts.
of December
On or
or about
about the
On
the 14th
14th day
December 2020,
2020, DAVID
DAVID JAMES
JAMES SHAFER
SHAFER instructed
instructed
day of
the Grand
deliver to
whose identity
unindicted co-conspirator
15, whose
identity isis known
known to10 the
Grand Jury,
Jury, toto deliver
to
unindicted
Individual 15,
coconspirator Individual
DAVID
and
JAMES
SHAFER
a
document
theOfficeofthe
of Georgia
a
document
signed
by
DAVID
JAMES
SHAFER
and
the Ofﬁce of the Governor
Governor of
signed by
Georgia
Electoral College
"RE: Notice
SHAWN
STILL titled
titled “RE:
Notice of
of Filling
Filling of
ofElectoral
SHAWN MICAH
MICAH TRESHER
TRESHER STILL
College
This
was
an
overt
act
in
statements.
The
false
Vacancy.”
The
document
contained
multiple
false
statements.
Thiswasan
overt
act
in
document
contained
multiple
Vacancy."
of
the
furtherance
furtheranceofthe conspiracy.
conspiracy.
Act
86.
Act 86.
On
14th day
On or
or about
about the
the 14th
of December
December 2020,
unindicted co-conspirator
Individual 4,4,
2020, unindicted
co-conspirator Individual
day of
to
sent
an
e-mail
MICHAEL
A.
whose identity
‘whose
identity isis known
known toto the
the Grand
Grand Jury,
Jury, sent an e-mail to MICHAEL
A.ROMAN,
ROMAN,
to
the
Grand
is
known
and others
others
whose
Individual
unindicted co-conspirator
‘unindicted
Individual
7,
whose
identity
is
known
to
the
Grand
Jury,
7,
identity
Jury, and
co-conspirator
mailed
now.
Ran
that stated,
that
“All votes
votes cast,
paperwork complete,
being mailed now. Ran pretty
in
stated, "All
cast, paperwork
pretty smoothly,”
smoothly," in
complete, being
elector nominees
in Fulton
Fulton
of Trump
reference
reference toto the
the December
December 14,
14, 2020,
2020, meeting
meetingof
Trump presidential
presidential elector
nominees in
of the conspiracy.
an overt
act in
overt act
County,
Georgia. This
This was
was an
in furtherance
furtheranceofthe
conspiracy.
County, Georgia.

Page 43 Act
87.
Act87,
STEPHEN CLIFFGARD
CLIFFGARD LEE
On or
or about
On
about the
14th dayofDecember
LEE attempted
attempted
the 14th
2020, STEPHEN
day of December 2020,
O.C.G.A.
in
Violation
of
commit the
offense of
toto commit
the felony
of INFLUENCING
INFLUENCING WITNESSES,
WITNESSES, in violation of 0.C.G.A. §§ 1616felony offense
a
Fulton
to
the
home
of
in
Fulton
10-93(b)(1)(A),
in
Fulton
County,
Georgia,
by
traveling
to
the
home
ofRuby
Freeman,a
Fulton
Freeman,
traveling
Ruby
County, Georgia, by
10-93(b)(1)(A),
intent to knowingly
County,
worker, and
and speaking
speaking
toto her
her neighbor,
neighbor, with
with intentto
knowingly engage
election worker,
engage
County, Georgia,
Georgia, election
offer her
intent to
and with
with intent
inin misleading
misleading conduct
toward Ruby
Ruby Freeman,
Freeman, by
by purporting
to offer
her help,
help, and
to
conduct toward
purporting to
events
influence
her testimony
testimony inin an
proceeding inin Fulton
Fulton County,
Georgia,
concerning
events
inﬂuence her
an official
ofﬁcial proceeding
County, Georgia, concerning
in Georgia.
was an act
election in
at
at State
Farm Arena
Arena inin the
the November
3, 2020,
presidential election
Thiswasan
act
State Farm
November 3,
2020, presidential
Georgia. This
act
in
and
an
overt
to
O.C.G.A.
of racketeering activity
ofracketeering
pursuant
to
0.C.G.A.
§
16-14-3(S)(A)(xxvii)
andan
overt
act
in
§ 16143(5)(A)(xxvii)
activity pursuant
furtherance
of the conspiracy.
furtheranceofthe
conspiracy.
Act 88.
Act88,
On or about the 15th day of December 2020, STEPHEN CLIFFGARD LEE attempted
to commit the felony offense of INFLUENCING WITNESSES, in violation of 0.C.G.A. § 1610-93(b)(1)(A), in Fulton County, Georgia, by traveling to the home of Ruby 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 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
ofracketeering activity pursuant to 0.C.G.A. § 16-14-3(S)(A)(xxvii) and an overt act in
furtheranceofthe conspiracy.
On or about the 15th day of December 2020, STEPHEN CLIFFGARD LEE attempted
to commit the felony offense of INFLUENCING WITNESSES, in violation of O.C.G.A. § 1610-93(b)(1)(A), in Fulton County, Georgia, by traveling to the home of Ruby 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 tinﬂuence 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.
Act89.
2020 and
and the
December 4th day
of January 2021,
On or
15th dayof
or between
On
betwween the
the 15th
the 4th
dayofJanuary
2021,
day of December
an
PRESCOTT FLOYD,
STEPHEN CLIFFGARD
CLIFFGARD LEE
LEE solicited
solicited HARRISON
STEPHEN
HARRISON WILLIAM
WILLIAM PRESCOTT
FLOYD, an
tfor Trump,
his effort
individual
associated with
individual associated
with the
the organization
organization Black
Black Voices
Voices for
to assist
assist with
with his
effort to
Trump, to
election
worker.
STEPHEN
CLIFFGARD
to
a
Fulton
speak
to
Ruby
Freeman,
a
Fulton
County,
Georgia,
election
worker.
STEPHEN
CLIFFGARD
County, Georgia,
speak Ruby Freeman,
FLOYD that
afraid to
LEE
WILLIAM PRESCOTT
LEE stated
stated toto HARRISON
HARRISON WILLIAM
PRESCOTT FLOYD
that Freeman
Freeman was
was afraid
to talk
talk
to
man. These
These were
overt acts
acts in
were overt
LEE because
to STEPHEN
STEPHEN CLIFFGARD
CLIFFGARD LEE
because he
he was
was aa white
white man.
in
furtherance
of the conspiracy.
furtheranceofthe
conspiracy.
Act
90.
Act90.
On or
JOHN TRUMP
TRUMP met
with
or about
the 18th
On
about the
18th dayofDecember
DONALD JOHN
met with
2020, DONALD
day of December 2020,
unindicted
RUDOLPH
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS GIULIANI,
SIDNEY KATHERINE
KATHERINE POWELL,
POWELL, unindicted
GIULIANI, SIDNEY
.
known to the
the Grand
and others
Individual 20,
whose identity
co-conspirator
20, whose
identity isis knownto
Grand Jury,
Jury, and
others atat the
the White
White
co-conspiratorIndividual
certain strategies
and theories
House.
The individuals
House. The
individuals present
present atat the
the meeting
meeting discussed
discussed certain
strategies and
theories intended
intended
to
inﬂuence the
of the November
to influence
the outcome
outcomeofthe
November 3,3, 2020,
2020, presidential
presidential election,
including seizing
election, including
voting
seizing voting
broad
POWELL
as
counsel
with
KATHERINE
and
SIDNEY
equipment
and
appointing
SIDNEY
KATHERINE
POWELL
as
special
counsel
with
broad
special
equipment
appointing
This was
an overt
act
of voter
voter fraud
to investigate
‘authority
investigate allegations
allegationsof
fraud inin Georgia
and elsewhere.
elsewhere. This
was an
overt act
Georgia and
authority to
in
of the conspiracy.
in furtherance
furtheranceofthe
conspiracy.

Page 44 Act
91.
Actor.
sent
On or
21st dayof
or about
about the
On
the 21st
December 2020,
2020, SIDNEY
SIDNEY KATHERINE
KATHERINE POWELL
POWELL sent
day of December
Ofﬁcer of
she
that she
him that
an e-mail
Chief Operations
instructed him
and instructed
LLC and
email to
SullivanStrickler LLC
of SullivanStrickler
theChief
o the
an
Operations Officer
identities
and
whose
Individual
Individual
Individual
and unindicted
unindicted co-conspirators
Individual
6,
Individual
21,
and
Individual
22,
whose
identities
and
6,
22,
21,
co-conspirators
obtained by
"receive a
a copyofall
data" obtained
were to
are
to the
the Grand
Jury, were
to immediately
are known
known to
Grand Jury,
by
immediately “receive
copy of all data”
was
an
This
in
SullivanStrickler
LLC from
from Dominion
Dominion Voting
Voting Systems
in
Michigan.
This
was
an
SullivanStrickler LLC
Systems equipment
Michigan.
equipment
the
act
in
furtherance
of
overt
overt act in furtherance of the conspiracy.
conspiracy.
Act
92.
Act92.
MARK RANDALL
MEADOWS
of December
On or
about the
the 22nd
On
22nd day
December 2020,
2020, MARK
RANDALL MEADOWS
or about
day of
in
Cobb
Center
and
Civic
traveled
traveled toto the
the Cobb
Cobb County
attempted toto observe
observe the
the
County, Georgia,
Georgia, and attempted
County Civic Center in Cobb County,
law
the
there
enforcement
ofﬁcers
from
match
audit
signature
match
audit
being
performed
there
by
law
enforcement
officers
from
the
Georgia
Georgia
by
being performed
signature
fact that
of the Georgia
the fact
and the
of State,
the Oﬁice
Bureau
of Investigation
Bureau of
Investigation and
Officeofthe
State, despite
that the
the
Georgia Secretary
despite the
Secretary of
RANDALL
While present
MARK RANDALL
to the
the public.
audit
audit process
process was
was not
not open
open to
present atat the
the center,
center, MARK
public. While
of the Georgia
State Jordan
Jordan Fuchs,
Georgia
to Georgia
Officeofthe
MEADOWS
Fuchs, Ofﬁce
MEADOWS spoke
Secretary of State
Georgia Deputy
Deputy Secretaryof
spoke to
of Investigation
Special
Investigation Special
Chief Investigator
Bureau of
Watson, Georgia
Frances Watson,
Investigator Frances
StateChief
of State
Secretary
Georgia Bureau
Secretary of
from
MARK
RANDALL
MEADOWS
and
who
‘Agent
in
Charge
Bahan
Rich,
and
others,
who
prevented
MARK
RANDALL
MEADOWS
from
Bahan
in
others,
Rich,
prevented
Agent Charge
act in
in furtherance
audit was
conducted. This
This was
an overt
overt act
where the
entering into
into the
space where
the audit
was being
being conducted.
was an
furtherance
the space
entering
of
of the
the conspiracy.
conspiracy.
Act 93.
Act93.
DONALD JOHN
JOHN TRUMP
or about
about the
On
On or
the 23rd
23rd dayofDecember
2020, DONALD
TRUMP placed
placed aa
day of December 2020,
Watson
that
of
State
Chief
Frances
of
the
telephone
call
to
Officeofthe
Georgia
SecretaryofState
Chief
Investigator
Frances
Watson that
call
to
Ofﬁce
Georgia Secretary
Investigator
telephone
MARK RANDALL
been previously
had been
previously amranged
by MARK
RANDALL MEADOWS.
MEADOWS. During
During the
the phone
phone call,
call,
had
arranged by
DONALD
JOHN TRUMP
DONALD JOHN
TRUMP falsely
falsely stated
stated that
that he
he had
had won
won the
the November
November 3,3, 2020,
presidential
2020, presidential
and stated
of thousands of votes" and
election in
election
in Georgia
“by hundreds
hundredsofthousandsofvotes”
stated toto Watson
Watson that
that "when
“when the
the
Georgia "by
This
was
of
the
be
an
overt
act
furtherance
in
answer
comes
out
right
answer
comes
out
you'll
be
praised.”
This
was
an
overt
act
in
furtheranceofthe
conspiracy.
conspiracy.
you'll praised."
right
Act
94.
Act 94,
sent an
an eeJOHN CHARLES
CHARLES EASTMAN
the 23rd
On
about the
23rd dayof
December 2020,
EASTMAN sent
On or
or about
2020, JOHN
day of December
and unindicted
whose
unindicted co-conspirator
mail
JOHN CHESEBRO
mail toto KENNETH
KENNETH JOHN
CHESEBRO and
Individual 3,3, whose
co-conspirator Individual
with
the
"FW:
Draft
edits'."
In
the
known
to
the
Grand
with
is
identity is known to the Grand Jury,
e-mail,
2, with edits.” In the e-mail,
subject “FW: Draft 2,
Jury, with the subject
identity
a memorandum
attached a
memorandum titled
"PRIVILEGED AND
JOHN CHARLES
CHARLES EASTMAN
JOHN
EASTMAN attached
titled “PRIVILEGED
AND
CONFIDENTIAL
Dec on Jan
Jan 66 scenario.docx"
scenario docx” and
for hearings,
think
23 memo
memo on
and stated,
"As for
CONFIDENTIAL — Dec
stated, “As
hearings, II think
we
the
of electors demonstrates
demonstrates the
both
are unnecessary.
both are
unnecessary. The
The fact
fact that
that we have
have multiple
slatesofelectors
multiple slates
I
And
Committee
be
Ken
that
That
should
with
of
either.
uncertainty
ofeither.
That
should
be
enough.
AndT
agree
with
Ken
that
Judiciary Committee
enough.
Judiciary
agree
uncertainty
we do
Electoral
that we
of
the
Count
Act
invite
counter
views
could invite counter views that
on the
hearings on
the constitutionalityofthe
Electoral Count Act could
do
constitutionality
hearings
in
the
the
exercise
have
under
of
should constrain
not
not believe
believe should
constrain Pence
Pence (or
Grassley)
inthe
exercise
ofpower
they
have
under
the
(or Grassley)
power they
act boldly
12% Amendment.
Amendment. Better
Better for
for them
themjust
o act
boldly and
and be
be challenged,
challenged, since
the challenge
challenge would
would
since the
12th
just to
This was
was
on nonjusticiable
Court denying
likely lead
lead toto the
the Court
review on
question grounds."
grounds.” This
nonjusticiable political
denying review
political question
likely
of the conspiracy.
an
overt act
an overt
act inin furtherance
furtheranceofthe
conspiracy.
--
“

Page 45 Act
Act 95.
95.
TRUMP placed
JOHN TRUMP
25th day
of December
On
or about
the 25th
December 2020,
DONALD JOHN
placed aa
about the
On or
2020, DONALD
day of
the purpose
for the
Bowers for
call to
to Speaker
telephone call
Speaker of
of the
the Arizona
Arizona House
House of
of Representatives
Representatives Rusty
Rusty Bowers
purpose
telephone
electors
and
Bowers
to
of
soliciting, requesting,
and
importuning
Bowers
to
unlawfully
appoint
presidential
electors
of soliciting,
importuning
unlawfully appoint presidential
requesting,
stated to
to Trump,
voted for
you. II
for you.
worked for
for you.
“I voted
from
Bowers stated
the call,
Arizona. During
from Arizona.
call, Bowers
Trump, "I
you. II worked
During the
an
overt
call
was
won't
dfor
This
overt
I
callwasan
for
telephone
This
you.”
for
illegal
anything
do
won't
you.I just
campaigned for you.
telephone
anything illegal
you."
just
campaigned
of the conspiracy.
act in furtherance
actin
furtheranceofthe
conspiracy.
Act
96.
Act96.
a
sent a
27th day
of December
MARK RANDALL
On
the 27th
December 2020,
2020, MARK
RANDALL MEADOWS
MEADOWS sent
about the
On or
or about
day of
that
Watson
Frances
the
of
of
State
Chief
text message
message toto Ofﬁce
Office of the Georgia
Georgia Secretary
Investigator Frances Watson that
text
Secretary of StateChief Investigator
order to
a
to
Fulton
"Is
there
stated
in part,
“Is
there
a
way
to
speed
up
Fulton
county
signature
verification in
in order
to have
have
stated in
way speed up
county signature veriﬁcation
part,
act
in
furtherance
an
overt
assist
was
if
the
This
Jan
results
before
Jan
6ifthe
tramp
campaign
assist
financially.”
This
was
an
overt
act
in
furtherance
results before
trump campaign
ﬁnancially."
of the conspiracy.
ofthe
conspiracy.
Act 97.
Act97.
solicited
TRUMP solicited
December 2020,
On
the 27th
DONALD JOHN
JOHN TRUMP
27th dayof
or about
about the
On or
2020, DONALD
day of December
States Deputy
General Jeffrey
and Acting
Acting United
United States
Jeffrey Rosen
Rosen and
United States
Deputy Attorney
Attorney
States Attorney
Acting United
Attorney General
Acting
the
election
was
that
"Just say
statement by
General
Donoghue toto make
make aa false
false statement
by stating,
stating, “Just
that
the
election
was
Richard Donoghue
General Richard
say
in
an
overt
act
the
This
was
to
me
and
leave the
corrupt, and
the rest
rest
tomeand the Republican
Republican congressmen.”
and leave
congressmen."This Wasan overt act in
corrupt,
furtherance
furtheranceofof the
the conspiracy.
conspiracy.
Act
98.
Act 98.
CLARK attempted
of December
BOSSERT CLARK
about the
JEFFREY BOSSERT
On or
On
or about
the 28th
28th day
day of
December 2020,
2020, JEFFREY
attempted
of
oﬁense of FALSE
STATEMENTS AND
toto commit
commit the
the felony
felony offenseof
FALSE STATEMENTS
AND WRITINGS,
WRITINGS, inin violation
violation of
0.C.G.A.
16-10-20, inin Fulton
Fulton County,
by knowingly
and willfully
willfully making
making
aa false
false:
O.C.G.A. §§ 16-10-20,
County, Georgia,
Georgia, by
knowingly and
States
that
the
United
the
same
to
contain
the
false
statement
and
document
writing
and
document
knowing
the
same
to
contain
the
false
statement
that
the
United
States
knowing
writing
outcome
had
"identiﬁed significant
concerns that
Justice
of
Departmentof
Justice
had
“identified
that may
may have
have impacted
impacted the
the outcome
signiﬁcant concerns
Department
within the
statement
the
State
of
said
ofthe
in multiple
multiple States,
including
the
State
of
Georgia,”
said
statement
being
the
election in
of the election
States, including
being within
Georgia,"
of
Bureau
of the Georgia Secretary
the Georgia
of the Ofﬁce
and the
jurisdictionofthe
OfficeoftheGeorgia
Secretary of
of State
State and
Georgia Bureau of
jurisdiction
and city
and
of
state
and
Investigation,
departments
and
agencies
of
state
govemment,
and
county
and
law
city law
agencies
government,
county
Investigation, departments
enforcement
enforcement agencies;
agencies;
CLARK sent
sent
28th dayofDecember
or about
And
And on
on or
about the
the 28th
JEFFREY BOSSERT
BOSSERT CLARK
2020, JEFFREY
day of December 2020,
United
States
States Attorney
General Jeffrey
and Acting
United States
an e-mail
Acting United
Attorney General
Rosen and
Acting United States
an
e-mail to
to Acting
Jeffrey Rosen
send said
said false
Richard
and
to
General
authorization
Deputy
Attorney
General
Richard
Donoghue
and
requested
authorization
to send
false
Donoghue
requested
Deputy Attorney
House
Governor Brian
writing and
to Georgia
Brian Kemp,
Kemp, Speakerofthe
of
and document
document to
Georgia Governor
Georgia House of
Speaker of the Georgia
writing
Butch
and
Senate
David
President
Pro
of
the
Representatives
David
Ralston,
and
President
Pro
Tempore
of
the
Georgia
Senate
Butch
Miller,
Miller,
Ralston,
Georgia
Tempore
Representatives
and
commission of False Statements
Statements and Writings,
substantial step
‘which
toward the
the commissionofFalse
which constitutes
constitutes aa substantial
Writings,
step toward
an actofracketeering
act of racketeering activity
0.C.G.A.
16-10-20. This
This was
was an
activity under
under O.C.G.A.
.C.G.A. §§ 16-1416-14O.C.G.A. §§ 16-1020.
furtherance of
of the
overt act
and an
an overt
3(5)(A)(xxii)
act inin furtherance
the conspiracy.
conspiracy.
3(5)(A)(xxii) and

45'

Page 46 Act
99.
Act99.
On or about the 28th day of December 2020, JEFFREY BOSSERT CLARK solicited
Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Atiormey
General Richard Donoghue to sign and send a document that falsely stated that the United States
Departmentof Justice had “identified significant concerns that may have impacted the outcome
ofthe election in multiple States, including the State ofGeorgia,” to Georgia Governor Brian
Kemp, Speakerofthe Georgia House of Representatives David Ralston, and President Pro
:
Temporeofthe Georgia Senate Butch Miller. This was an overt act in furtheranceofthe
conspiracy.
Act
Act 100.
100.
caused to
TRUMP caused
JOHN TRUMP
of December
December 2020,
be
to be
30th day
On
or about
about the
DONALD JOHN
dayof
the 30th
2020, DONALD
On or
on the
the Georgia
from Atlanta
Georgia
the Twitter
Twitter account
Atlanta on
tweeted from
account@RealDonaldTrump,
from the
"Hearings from
tweeted
@RealDonaldTrump, “Hearings
more.
and
it
out.
broadcast.
Check
more.
now
many
and
overturn
@newsmax
Election
many
being broadcast. Check it out. @OANN
Election overturn now being
@OANN @newsmax
to admit
who
refuses
ofﬁce.
He
is
an
obstructionist
should
from
we.
that we
admit that
to
refuses
who
obstructionist
an
is
He
office.
from
resign
should
@BrianKempGA
resign
@BrianKempGA
of
the
in
furtherance
an
overt
act
was
furtheranceofthe
won
the
other
States."
This
actin
overt
BIG!
Also
an
was
This
States.”
Swing
won
other
Georgia, BIG! Also won the
won Georgia,
Swing
conspiracy.
conspiracy.
Act
Act 101.
101.
caused to
TRUMP caused
JOHN TRUMP
be
to be
about the
On
DONALD JOHN
December 2020,
30th dayof
the 30th
2020, DONALD
On oror about
day of December
on the
the Georgia
Georgia
the Twitter
Atlanta on
from Atlanta
tweeted
account @RealDonaldTrump,
Twitter account
from the
"Hearings from
tweeted from
@RealDonaldTrump, “Hearings
broadcast
LIVE
via
now
overturn now being
htpsy/t.cologBvLbKfqG.”
Election
being broadcast LIVE via @RSBNetwork!
Election overturn
@RSBNetwork! https://t.co/ogBvaKfqG."
act in
‘This
was an
an overt
overt act
in furtherance
furtherance ofoftthe
he conspiracy.
This was
conspiracy.
Act
Act102.
0f December
On
the 30th
30th day
December 2020,
2020, RUDOLPH
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS
about the
or about
On or
day of
committed
CHEELEY
DAVID
and
ROBERT
STALLINGS
SMITH
RAY
committed
CHEELEY
DAVID
ROBERT
and
II,
SMITH
STALLINGS
III,
GIULIANI,
GIULIANI, RAY
BY
PUBLIC
OATH
OF
OF VIOLATION
of SOLICITATION OF
oﬁense ofSOLICITATION
the felony
the
felony offense
VIOLATION OF OATH BY PUBLIC OFFICER,
OFFICER,
in Fulton
Fulton County,
by soliciting,
Georgia, by
O.C.G.A. §§
in
violation of 0.C.G.A.
164-7 && 16-10-1,
16-10-1, in
soliciting,
in violationof
County, Georgia,
§§ 16-4-of the
the
elected members
ofﬁcers then
requesting, and
and importuning
certain public
public officers
then serving
as elected
membersof
serving as
importuning certain
requesting,
unindicted
at a Senate
Senate Judiciary
Subcommittee meeting,
and present
including unindicted
meeting, including
Senate and
present ata
Georgia
Judiciary Subcommittee
Georgia Senate
Brandon
Senators
to
the
Grand
whose
is
known
Individual
Beach,
Brandon Beach,
Senators
Jury,
Grand
the
to
known
is
identity
whose
8,
Individual
8,
Jury,
co-conspirator
identity
co-conspirator
in
conduct
to
Michael
Blake
Bill
William Ligon,
Ligon, Michael Rhett,
Rhett, and
and Blake Tillery,
Tillery, to engage
engage in conduct constituting
Bill Heath,
constituting
Heath, William
Oath
O.C.G.A.
unlawfully
of
Violation
of
Public
by
16-10-1,
§
oﬁense
0.C.G.A.
Officer,
Public
the
by
l6-lO-l,
ViolationofOath
of
Oﬁicer,
offense
by
unlawfully
the felony
§
by
felony
of
intentional violation
the State
of Georgia,
appointing
presidential electors
electors from
from the
State of
Georgia, inin willful
willful and
and intentional
violation of
appointing presidential
that said
said persons
of said persons
as prescribed
engage inin
of the oath
the
intent that
with intent
by law;
prescribed by
law, with
persons as
persons engage
oathofsaid
termsofthe
the terms
of
the
an
overt
act
in
furtherance
This
was
conspiracy.
t
he
conduct.
of
said
said conduct. This was an overt act in furtherance
conspiracy.
On or about the 28th day 0f December 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 of Georgia," 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.

Page 47 Act 103.
Act
103.
WILLIAM LOUIS
RUDOLPH WILLIAM
LOUIS
or about
about the
On or
2020, RUDOLPH
December 2020,
dayofof December
30th day
the 30th
On
in
STATEMENTS AND
of FALSE
WRITINGS, in
committed the
offense of
AND WRITINGS,
GIULIANI committed
FALSE STATEMENTS
felony offense
the felony
GIULIANI
and
willfully, and
knowingly, willfully,
0.C.G.A. §§ 16-10-20,
Fulton County,
of 0.C.G.A.
Violation
in Fulton
by knowingly,
violationof
16-10-20, in
Georgia, by
County, Georgia,
members
and
to
unlawfully making
making atat least
least one
one ofthe
following false
false statements
statements and representations
representations to members
of the following
unlawfully
Subcommittee
Senate
at
a
Senate
ofthe
Senate
present
at
a
Senate
Judiciary
Subcommitice
meeting:
of the Georgia
meeting:
Judiciary
Georgia
present
certain ballots
counted certain
election workers
That Fulton
1. That
Fulton County
County election
workers ﬁaudulently
fraudulently counted
ballots asas many
l.
many
November
times at
at State
State Farm
as ﬁve
as
five times
Farm Arena
Arena on
on November 3,3, 2020;
2020;
in
election in
voted illegally
That 2,presidential election
2.
November 3,3, 2020,
the November
illegally inin the
2020, presidential
felons voted
2. That
2,560 felons
Georgia
Georgia;
election in
in *
That 10,dead people
voted in the November
3. That
10,315 dead
people votedinthe
November 3,3, 2020,
presidential election
3.
2020, presidential
Georgia;
Georgia;
and
the Georgia
Office of the
within the
said statements
statements being
thejurisdictionofthe
said
Secretary of State and.
Georgia SecretaryofState
being within
jurisdiction of the Officeof
and
of
state
and agenciesofstate
of Investigation, departments
government, and county
the
BureauofInvestigation,
the Georgia
government,
county
agencies
departments and
Georgia Bureau
under
0.C.G.A.
16an
act
of
§§ 16This
was
0.C.G.A.
under
activity
and city
racketeering
actof
an
was
This
enforcement agencies.
activity
law enforcement
city law
and
racketeering
agencies.
the
in
furtherance
of
and
an
overt
aCt
14-14-3(5)(A)(xxi)
conspiracy.
(5)(A)(xxii) and an overt actin furtheranceofthe conspiracy.
Act
Act 104,
SMITH III
the 30th dayofDecember
On or
or about
On
aboutthe30th
2020, RAY
RAY STALLINGS
STALLINGS SMITH
ITI
day of December 2020,
violation of
offense of
of FALSE
STATEMENTS AND
committed
the felony
felony offense
FALSE STATEMENTS
AND WRITINGS,
WRITINGS, inin violation
of
committed the
and
in
0.C.G.A.
16-10-20, in Fulton
Fulton County,
by knowingly,
willfully, and unlawﬁllly
unlawfully
0.C.G.A. §§ 16-10-20,
knowingly, willfully,
County, Georgia,
Georgia, by
members
to
of the
and
membersofthe
one
of
statements
to
at
least
false
representations
and
statements
faise
following
oneofthe
least
at
making
representations
thefollowing
making
a
Subcommittee
Senate
at
Senate
Georgia
present at a Senate Judiciary
meeting:
Judiciary Subcommittee meeting:
Georgia Senate present
General Counsel
1. That
Counsel Ryan
Ryan Germany
Germany stated
stated that
that his
his
1.
That Georgia
State General
Georgia Secretaryof
Secretary of State
ofﬁce had sent
officehad
sent letters
letters toto 8,people who
who voted
voted illegally
illegally inin the
the November
November 3,3,
8,000 people
in
to
vote
the
and
them
not
election
told
2020, presidential
election
and
told
them
not
to
vote
in
the
January
5,5, 2021,
2021, runoﬂ'
runoff
January
2020,
presidential
election;
election;
2. That
the Georgia
admitted "that
“that they
they had
hadaa 90%
90% accuracy
rate”
That the
2.
accuracy rate"
Georgia SecretaryofState
Secretary of State admitted
a
10%
"there's still
still a 10% margin
and that
election and
in
the November
in the
November 3,3, 2020,
presidential election
that “there’s
2020, presidential
margin
not aceurate”;
that's not
that’s
accurate";
of the Georgia
and
said
statements being
being within
thejurisdictionofthe
Office ofthe
Georgia SecretaryofState
within the
said statements
Secretary of State and
jurisdiction of the Ofﬁce
of
state
and
and
the
Georgia
Bureauof
Investigation,
departments
and
agenciesofstate
government,
and
county
Bureau
of
the Georgia
government,
county
agencies
Investigation, departments
under
0.C.G.A.
act
of
was
an
and city
city law
This
was
an
actofracketeering
activity
under
O.C.G.A.
§§ l616enforcement agencies.
This
law enforcement
and
racketeering
activity
agencies.
of
the
and
an
overt
act
in
furtherance
l414-3(5)(A)(xxii)
conspiracy.
(5)(A)(xxii) and an overt act in furtheranceofthe conspiracy.
a

Page 48 Act 105.
committed
CHEELEY committed
of December
On or
or about
about the
30th day
On
the 30th
December 2020,
2020, ROBERT
ROBERT DAVID
DAVID CHEELEY
day of
Violation of
AND WRITINGS,
of 0.C.G.A.
O.C.G.A. §§
the
offense of
STATEMENTS AND
the felony
felony offense
of FALSE
FALSE STATEMENTS
WRITINGS, inin violation
and unlawﬁllly
16-10-20, inin Fulton
Fulton County,
Georgia, by
by knowingly,
knowingly, willfully,
willfully, and
unlawfully making
making atat least
least
16-10-20,
County, Georgia,
of the Georgia
Senate
oneofthe
following false
false statements
statements and
and representations
representations toto members
membersofthe
Senate
of the following
one
Georgia
Subcommittee meeting:
present atat aa Senate
Senate Judiciary
meeting:
present
Judiciary Subcommittee
of
Arena were
State Farm
1.
1. That
That poll
poll watchers
watchers and
and media
mediaatat State
Farm Arena
were told
told late
late inin the
the evening
evening of
the next
was being
November
count was
that the
November 3,3, 2020,
the vote
vote count
being suspended
suspended until
until the
next
2020, that
"a
watermain
of
and
to
home
because
morning and to go
go home because of
“a major
break”;
major watermain break";
morning
Arena “voted”
"voted" the
same
State Farm
2.2. That
workers atat State
Farm Arena
the same.
That Fulton
Fulton County
election workers
County election
ballots
"over and
and over
on November
over again”
ballots “over
November 3,3, 2020;
2020;
again" on
of the Georgia
of State and
said
statements being
the jurisdiction of the Office
said statements
within thejurisdictionofthe
Officeofthe
Georgia Secretary
Secretary ofStateand
being within
and county
the
of Investigation,
the Georgia
Georgia Bureau
Bureau of
Investigation, departments
departments and
and agenciesofstate
county
agencies of state goverment,
government, and
under
O.C.G.A.
an
act
of
and city
enforcement agencies.
This was
‘and
law enforcement
was an actofracketeering
16+
racketeering activity
activity under 0.C.G.A. §§ l6
city law
agencies. This
of
the
in
furtherance
14-and
an
overt
act
14-3(5)(A)(xxii)
and
an
overt
act
in
furtherance
ofthe
conspiracy.
conspiracy.
(5)(A)(xxii)
Act
Act 106.
106.
caused to
JOHN TRUMP
TRUMP caused
or about
December 2020,
On
the 30th
30th dayof
DONALD JOHN
to be
be
On or
about the
2020, DONALD
day of December
"We
now
have
far
more
votes
than
from the
tweeted from
the Twitter
Twitter account
account @RealDonaldTrump,
“We
now
have
far
more
votes
than
tweeted
@RealDonaldTrump,
needed
needed toto ﬂip
flip Georgia
Georgia inin the
the Presidential
Presidential race.
race. Massive
Massive VOTER
VOTER FRAUD
FRAUD took
took place.
Thank you
place. Thank
you
an
act
of
This
was
overt
in
furtherance
to
for
to the
the Georgia
Legislature
for
today’s
revealingmeeting!”
This
was
an
overt
act
in
furtherance
of
Georgia Legislature
today's revealing meeting!"
the
the conspiracy.
conspiracy.
Act107.
Act107wrote aa
On or
or about
3lst day
the 31st
On
about the
day of
of December
December 2020,
JENNA LYNN
LYNN ELLIS
ELLIS wrote
2020, JENNA
0f Vice
for
President Authority
Constitutional Analysis
memorandum
‘memorandum titled
titled "Memorandum
“Memorandum Re:
Re: Constitutional
Analysis of
Vice President
Authority for
TRUMP.
The
to
DONALD
JOHN
Count"
Vote
Electoral
January
6,
Electoral
College
Vote
Count”
toDONALD
JOHN
TRUMP.
The
College
January 6,
on
and delaying
of Congress
memorandum
outlined aa strategy
memorandum outlined
for disrupting
disrupting and
delaying the
the joint
joint session
session of
Congress on
strategy for
cast by
for counting
January
6, 2021,
2021, the
the day
prescribed by
by law
law for
votes cast
by the
the duly
elected and
and
counting votes
duly elected
January 6,
day prescribed
the
other
and
"the
Vice
President
and
electors
from
qualified
presidential
electors
from
Georgia
and
the
other
states,
and
stated,
“the
Vice
President
states,
stated,
Georgia
qualiﬁed presidential
six states,
should therefore
therefore not
should
not open
the votes"
votes” from
from six
including Georgia,
that were
were falsely
falsely
states, including
Georgia, that
any of the
open anyof
This
an
overt
act
in
furtherance
of
in
was
characterized as
"electoral
characterized
as having
“electoral
delegates
in
dispute.”
This
was
an
overt
act
in
furtherance
of
delegates
dispute."
having
the conspiracy.
the
conspiracy.
Act105-

Page 49 Act
Act 108.
108.
JOHN
and JOHN
TRUMP and
JOHN TRUNIP
of December
DONALD JOHN
31st day
2020, DONALD
On or
or about
about the
December 2020,
day of
the 31st
On
in
of
FILING
FALSE
offense
in
the
DOCUMENTS,
FALSE
committed
CHARLES
EASTMAN
DOCUMENTS,
offenseofFILING
felony
the
(CHARLES EASTMAN committed felony
Fulton County,
filing aa
knowingly ﬁling
by knowingly
violation of
of O.C.G.A.
Georgia, by
16-10-20.1(b)(1), inin Fulton
0.C.G.A. §§ 16-10-20.1(b)(1),
violation
County, Georgia,
INJUNCTIVE AND
AND
COMPLAINT FOR
document titled
"VERIFIED COMPLAINT
EMERGENCY INJUNCTIVE
FOR EMERGENCY
itled “VERIFIED
document
Case 1:20cv05310-MHC,
the matter
the
DECLARATORY RELIEF"
1:20-cv-05310-MHC, inin the
Kemp, Case
Trump v.V. Kemp,
matterofof Trump
RELIEF” inin the
DECLARATORY
of Georgia, aa courtofthe
court of the United
for the
United States
the Northern
Northern District
DistrictofGeorgia,
United States
States
Court for
United
States District
District Court
false
contained at
at least
one of the following
materially false
following materially
document contained
least oneofthe
said document
reason to
know that
that said
to know
having reason
having
statements:
statements:
sentence" voted illegally
the
in the
l.1. That
That "as
as 2,506 felons
uncompletedsentence”voted
an uncompleted
with an
felons with
manyas2,“as many
illegally in
in
election
November 3,
November
3, 2020,
presidential election in Georgia;
Georgia;
2020, presidential
November 3,3, 2020,
the November
2.
That "at
in the
voted illegally
2020,
people voted
underage” people
6,247 underage"
least 66,“at least
2. That
illegally in
in
election
presidential
election
in
Georgia;
Georgia;
presidential
in the November
presidential
2020, presidential
November 3,3, 2020,
illegallyinthe
voted illegally
That "at
individuals” voted
2,423 individuals"
least 2,“at least
3.3. That
been
as
in
the
State's
records
registered
been
not
listed
having
as
were
records
"who
State’s
the
in
election in
in Georgia
listed
not
were
“who
election
registered
having
Georgia
to
to vote";
vote”;
presidential
2020, presidential
4.
November 3,3, 2020,
the November
That "at
least 1,illegally inin the
voted illegally
individuals” voted
1,043 individuals"
“at least
4. That
as
their
to
vote
a
ofﬁce
box
their
as
box
office
postal
a
election "who
using
vote
to
registered
had illegally
“who had
election
using
postal
illegally registered
habitation";
habitation";
November 3,
dead people
or more"
5. That
“as many
many asas 10,10,315 or
more” dead
people voted
voted inin the
the November
5.
That "as
2020,
3, 2020,
in
election
presidential
election
in
Georgia;
Georgia;
presidential
and
watchers and
Republican poll
6.
instruct Republican
used toto instruct
That “[djeliberate
was used
misinformation was
6. That
poll watchers
"[d]eliberate misinformation
at
10:for
the
the
on.
p.m.
to
leave
10:approximately
at
members
of
the
night
the
for
premises
the
leave
to
press
p.m. on
‘membersofthe press
night approximately
premises
State Farm
November
November 3,3, 2020"
2020” atat State
Farm Arena
Arena inin Fulton
Fulton County,
County, Georgia;
Georgia;
associated
an e-mail
email to
attorneys associated
to attorneys
CHARLES EASTMAN
sent an
EASTMAN sent
Earlier on
on the
JOHN CHARLES
same day,
the same
Earlier
day, JOHN
some of the allegations
the
in the
with
least someofthe
thataat least
knowledge that
his knowledge
Campaign admitting
allegations in
the Trump
with the
admitting his
Trump Campaign
under
of
was
an
act
This
not
accurate.
verified complaint
were
not
accurate.
This
filing
was
an
actofracketeering
activity
under
veriﬁed
were
ﬁling
racketeering activity
complaint
act in
furtherance of the conspiracy.
overt act
O.C.G.A. §§ 16-14-3(5)(A)(xxii)
O.C.G.A.
16-14-3(S)(A)(xxii) and
and an
an overt
in furtheranceofthe
conspiracy.
Act 109.
Act
109.
an esent an
On or
oraboutthe
Ist dayof
January 2021,
2021, KENNETH
KENNETH JOHN
JOHN CHESEBRO
CHESEBRO sent
On
about the lst
day of January
whose
and unindicted
mail toto JOHN
unindicted co-conspirator
Individual 3,3, whose
mail
CHARLES EASTMAN
EASTMAN and
JOHN CHARLES
co-conspirator Individual
outlined
JOHN
CHESEBRO
In
the
KENNETH
identity
is
known
to
the
Grand
Jury.
In
the
e-mail,
KENNETH
JOHN
CHESEBRO
outlined aa
is
known
to
the
Grand
e-mail,
Jury.
identity
on January
session of Congress
the day
and delaying
6, 2021,
for disrupting
thejoint
2021, the
day
strategy
Congress on
January 6,
joint sessionof
delaying the
strategy for
disrupting and
electors
the
elected
and
votes
cast
clectors
presidential
law
for
qualified
and
elected
by the duly
counting votes cast by
by law for counting
prescribed by
duly
qualiﬁed presidential
prescribed
an overt
act in furtherance
of the conspiracy.
states. This
This was
from
from Georgia
Georgia and
and the
the other
other sates.
was an
overt actin
furtheranceofthe
conspiracy.
-
e
9

Page 50 Act
Act
110.
bail
0f January 2021,
SCOTT GRAHAM
GRAHAM HALL,
Georgia bail
HALL, aa Georgia
On oraboutthe
or about the 2nd
2021, SCOTT
dayofJanuary
2nd day
On
and discussed
call to
JEFFREY BOSSERT
the
a telephone call
discussed the
CLARK and
BOSSERT CLARK
to JEFFREY
placed atelephone
bondsman, placed
bondsman,
minutes
The telephone
election in
was 63 minutes inin
November
call was
telephone call
in Georgia.
3,3, 2020,
November
2020, presidential
Georgia. The
presidential election
act in
duration.
overt act
in furtherance
furtherance of
of the
the conspiracy.
conspiracy.
This was an overt
duration. Thiswasan
Act
111.
Act111,
CLARK solicited
JEFFREY BOSSERT
BOSSERT CLARK
solicited
On or
or about
2nd dayofJanuary
the 2nd
about the
2021, JEFFREY
On
day 0f January 2021,
J
Rosen
United
States
General
and
Atiomey
Deputy
States
United
States
United
Acting
Acting United States Attorney
Deputy Attorney
eﬁ'rey Rosen and Acting
Attorney General Jeffrey
Acting
States
stated that
and send
send aa document
document that
General
Richard Donoghue
Donoghue toto sign
that falsely
falsely stated
that the
the United
United States
General Richard
sign and
outcome
the
concerns
that
have
had
"identiﬁed
Departmentof
Justice
had
“identified
significant
conces
that
may
have
impacted
the
outcome
of
Justice
signiﬁcant
may
impacted
Department
Brian
Governor Brian
of Georgia,”
ofthe
election inin multiple
States, including
including the
the State
Stateof
to Georgia
Georgia Governor
of the election
Georgia," to
multiple States,
and President
House of Representatives David
Kemp, Speakerof
the Georgia
David Ralston,
Ralston, and
President Pro
Pro
Georgia HouseofRepresentatives
Kemp,
Speaker of the
the
of
Miller.
This
was
an
act
in
furtherance
Butch Miller. This was an overt
overt act in furtherance ofthe
Senate Butch
of the Georgia
‘Temporeofthe
Georgia Senate
Tempore
conspiracy.
conspiracy.
Act 112.
Act
112.
MARK
and MARK
JOHN TRUMP
TRUMP and
2nd day
On or
or about
the 2nd
dayof0f January
2021, DONALD
DONALD JOHN
On
about the
January 2021,
OF VIOLATION
of SOLICITATION OF
RANDALL MEADOWS
MEADOWS committed
committed the
the felony
felony offense
offenseofSOLICITATION
VIOLATION
RANDALL
Fulton
in Fulton
of 0.C.G.A.
O.C.G.A. §§
164-7 && 16-10-1,
OF
OATH BY
violation of
OFFICER, inin violation
PUBLIC OFFICER,
16-10-1, in
BY PUBLIC
OF OATH
§§ 16-4-of
and
Secretary
Georgia
importuning
and
requesting,
soliciting,
unlawfully soliciting, requesting, importuning Georgia Secretary of
by unlawfully
County, Georgia,
County,
Georgia, by
offense of
of
conduct constituting
felony offense
the felony
State Brad
Brad Raffensperger,
in conduct
to engage
ofﬁcer, to
Raffensperger, aa public
State
engage in
constituting the
public officer,
O.C.G.A.
unlawfully
Public
altering,
of
Oath
unlawfully
by
Violation
16-10-1,
§
0.C.G.A.
Officer,
by Public Oﬁicer,
ViolationofOath by
§ 16-10-1, by unlawfully altering, unlawfully
for
the certiﬁed
adjusting,
unlawfully influencing
certified returns
returns for
for presidential
presidential electors
electors for
and otherwise
otherwise unlawfully
inﬂuencingthe
adjusting, and
of the
in willful
election in
and intentional
the November
November 3,3, 2020,
2020, presidential
presidential election
in Georgia,
willful and
intentional violation
violation of
the
the
Georgia, in
in
said
with
intent
that
said
termsofthe
oathofsaid
person asas prescribed
prescribed by
by law,
law, with intent that said person
person engage
engage in said
terms
of the oath
of said person
of the
an overt
overt act
conduct. This
was an
conduct.
This was
act inin furtherance
furtherance of
the conspiracy.
conspiracy.
110.

Page 51 Act
113.
Act113.
On or about the 2nd dayof January2021, DONALD JOHN TRUMP committed the
felony offense ofFALSE STATEMENTS AND WRITINGS, in violation of 0.C.G.A. § 1610-20, 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 SecretaryofState Jordan Fuchs, and Georgia SecretaryofState
General Counsel Ryan Germany:
from 250,were dropped
anywhere from
250,000 toto 300,ballots were
mysteriously
l.1. That
That anywhere
300,000 ballots
dropped mysteriously
in
November 3,
election
into the
the rolls
rolls inin the
the November
3, 2020,
presidential
election
in
Georgia;
into
2020, presidential
Georgia;
to vote
thousands of people attempted
2. That
That thousandsofpeople
vote inin the
the November
November 3,3, 2020,
2020,
2.
attempted to
not
because
ballot
election
in
and
were
told
could
aa ballot
because
not
they could
Georgia and were told they
presidential election in Georgia
presidential
had
had already
been cast
cast inin their
their name;
name;
already been
election in
3. That
That 4,people voted
voted inin the
the November
November 3,3, 2020,
2020, presidential
presidential election
in
3.
4,502 people
were
not
on
the
voter
who
Georgia who were not on the voter registration
registration list;
list;
Georgia
November 3,
904 people
4.4. That
That people voted
voted inin the
the November
3, 2020,
presidential election
election inin
2020, presidential
an address
ofﬁce box;
address that
was aa post
Georgia who
who were
were registered
registered atat an
thatwas
post office
box;
Georgia
vote scammer
scammer and
5.5. That
Freeman was
was a.aprofessional
and aa known
known political
political
That Ruby
Ruby Freeman
professional vote
operative;
operative;
and others
others were
were responsible
6.6. That
That Ruby
Freeman, her
her daughter,
responsible for
for
daughter, and
Ruby Freeman,
State Farm
Biden
at
least
ballots
to
R.
fraudulently
awarding
at
least
18,ballots
to
Joseph
R.
Biden
atat State
Farm
18,Joseph
fraudulently awarding
in Georgio;
election in
Arena
Arena inin the
the November
November 3,3, 2020,
2020, presidential
presidential election
Georgia;
dead people
November 3,
7.7. That
close toto 5,people voted
voted inin the
the November
2020, presidential
presidential
That close
5,000 dead
3, 2020,
election in
election
in Georgia;
Georgia;
election in
in the
8.8. That
139%ofpeople
the November
November 3,3, 2020,
2020, presidential
presidential election
in
of people voted
voted in
That 139%
Detroit;
Detroit;
votes were
of people who
the number
9. That
That 200,more votes
were recorded
recorded than
than the
numberofpeople
who voted
voted
9.
200,000 more
in
November3,
inin the
the November
presidential election
election in Pennsylvania;
Pennsylvania;
3, 2020,
2020, presidential
the November 3,
10.
thousands of dead people
10. That
That thousandsofdead
people voted
voted inintheNovember
3, 2020,
2020, presidential
presidential
election
Michigan;
election inin Michigan;
Freeman stuffed
stuﬁ'ed the
l11.
l. That
That Ruby
Ruby Freeman
the ballot
ballot boxes;
boxes;
hundreds of thousands
of ballots had
That hundredsof
12.
thousandsofballots
had been
been "dumped"
“dumped into
into Fulton
Fulton County
County
12. That
to
Fulton
in
the
November
‘and
another county
county adjacent
to
Fulton
County
in
the
November
3,
2020,
and another
3, 2020,
County
adjacent
election in
presidential
Georgia;
in Georgia;
presidential election
On or about the 2nd day of January 2021, DONALD JOHN TRUMP committed the
felony offense of FALSE STATEMENTS AND WRITINGS, in violation of O.C.G.A. § 1610-20, 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:
s1

Page 52 13. That he won the November 3, 2020, presidential lection in Georgia by
400,votes;
400,000 votes;
of State and
and
of the Georgia
SecretaryofState
Office ofthe
the Oﬁice
of the
statements being
jurisdiction of
said
the jurisdiction
within the
being within
Georgia Secretary
said statements
an
This
was
of
state
an
was
Bureau of Investigation,
agenciesofstate goverment.
the
and agencies
government. This
Investigation, departments
the Georgia
departments and
Georgia Bureauof
overt act
furtherance
an overt
act inin furtherance
and an
act of
16-14-3(S)(A)(xxii)
0.C.G.A. §§ 16-14-under O.C.G.A.
racketeering activity
of racketeering
act
activity under
(5)(A)(xxii) and
of the conspiracy.
ofthe
conspiracy.
Act 114.
Act
114,
caused to
TRUMP caused
JOHN TRUMP
be
to be
about the
On
DONALD JOHN
3rd dayofJanuary
the 3rd
or about
On or
2021, DONALD
day of January 2021,
of
State
Brad
to
account @RealDonaldTrump, "I
from the
“I spoke
tweeted
Twitter account@RealDonaldTrump,
the Twitter
Secretary of State Brad
tweeted from
spoke to Secretary
or
He
was unwilling,
in
voter
fraud
about
and
Fulton
unwilling, or
He was
Georgia.
in
fraud
voter
and
County
Fulton
Georgia.
about
yesterday
Raffensperger yesterday
County
Raﬁensperger
out
of
state
ballot
under
table'
'ballots under table” sca,
unable, toto answer
answer questions
questions such
such asas the
the “ballots
destruction, outofstate
scam, ballot destruction,
unable,
of the
furtherance
act
in
an
overt
was
furtheranceofthe
in
and
more.
He
no
clue!"
This
act
overt
an
has
was
This
dead
clue!”
no
has
He
more.
and
voters,
dead
voters’,
voters,
'voters',
conspiracy.
conspiracy.
13. That he won the November 3, 2020, presidential election in Georgia by

Page 53 Act 115.
ALIS.CLIFFGARD LEE,
STEPHEN CLIFFGARD
LEE,
the 3rd
3rd dayof
On or
about the
or about
2021, STEPHEN
On
January 2021,
day of January
C.
KUTTI
TREVIAN
and
multiple
WILLIAM
PRESCOTT
placed multiple
KUTTI
C.
HARRISON
TREVIAN
and
FLOYD,
PRESCOTT
FLOYD,
placed
HARRISON WILLIAM
telephone calls and sent text messages to each other and to other individuals involved in the
conspiracy. They include the following:
a telephone
FLOYD placed
WILLIAM PRESCOTT
1.l. At7:pm, HARRISON
HARRISON WILLIAM
PRESCOTT FLOYD
telephone
At 7:48 p.m.,
placeda
election
that
was
to
a
Fulton
call
call to Ruby
Ruby Freeman,
Freeman, a Fulton County,
worker,
Georgia, election worker,thatwas
County, Georgia,
unsuccessful.
unsuccessful.
2. At
At7:p.m., HARRISON
HARRISON WILLIAM
PRESCOTT FLOYD
FLOYD placed
telephone
WILLIAM PRESCOTT
2.
7:49 p.m.,
placed aa telephone
call to
call
to Ruby
Ruby Freeman
Freeman that
that was
was unsuccessful.
unsuccessful.
FLOYD placed
7:49 p.m.,
WILLIAM PRESCOTT
3.3. At
At7:p.m, HARRISON
HARRISON WILLIAM
PRESCOTT FLOYD
placed
aa telephone
telephone
call to
to TREVIAN
TREVIAN C.
C. KUTTI.
call
KUTTI.
a text message
to
sent atext
7:53 p.m.,
FLOYD sent
PRESCOTT FLOYD
WILLIAM PRESCOTT
HARRISON WILLIAM
pm, HARRISON
At7:4.4. At
message to
Freeman.
Ruby Freeman.
Ruby
8:03 p.m.,
TREVIAN C.
C. KUTTI
5. At
At8:pm, TREVIAN
KUTTI placed
placed aatelephone
call toto HARRISON
HARRISON
5.
telephone call
WILLIAM
PRESCOTT
FLOYD.
WILLIAM PRESCOTT FLOYD.
8:11 p.m.,
HARRISON WILLIAM
6.
6. At
At8:p.m, HARRISON
WILLIAM PRESCOTT
PRESCOTT FLOYD
FLOYD placeda
telephone
placed a telephone
to
Grand
who'se identity
call to
call
to unindicted
unindicted co-conspirator
Individual 23,
23, whose
identity isis known
known to the
the Grand
co-conspirator Individual
Jury.
Jury.
7. At
At8:pm, HARRISON
WILLIAM PRESCOTT
PRESCOTT FLOYD
FLOYD placed
telephone
HARRISON WILLIAM
7.
8:18 p.m.,
placed aa telephone
LEE.
call
to
STEPHEN
CLIFFGARD
call to STEPHEN CLIFFGARD LEE.
8.
8:48 pm,
8. At
At8:HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD
FLOYD placed
placed aa telephone
telephone
p.m., HARRISON
C. KUTTI.
call
call toto TREVIAN
TREVIAN C.
KUTTL.
telephone
placed aa telephone
9:16 p.m.,
FLOYD placed
PRESCOTT FLOYD
WILLIAM PRESCOTT
HARRISON WILLIAM
At9:9.9. At
p.m., HARRISON
call to
C. KUTTI.
TREVIAN C.
call
to TREVIAN
KUTTL.
10.
9:33 p.m.,
10. At
At9:p.m., HARRISON
HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD
FLOYD placed
placedaa telephone
telephone
call to
TREVIAN C.
C. KUTTI.
call
to TREVIAN
KUTTL.
FLOYD placed
a telephone
PRESCOTT FLOYD
9:50 p.m.,
11.11. At
At9:p.m, HARRISON
HARRISON WILLIAM
WILLIAM PRESCOTT
placed atelephone
LEE.
call
to
STEPHEN
CLIFFGARD
call to STEPHEN CLIFFGARD LEE.
overt acts
of the
were overt
acts in
These were
‘These
in furtherance
furtherance of
the conspiracy.
conspiracy.
telephone calls and sent text messages to each other and to other individuals involved in the
conspiracy. They include the following:
'

Page 54 Act 116.
ALILQC. KUTTI,
recruited
On
the 4th
TREVIAN C.
KUTT, having
having been
been recruited
On or
or about
about the
4th dayof
2021, TREVIAN
January 2021,
day of January
from
to
traveled
PRESCOTT
HARRISON
WILLIAM
by
HARRISON
WILLIAM
PRESCOTT
FLOYD,
traveled
from
Chicago,
Illinois,
to
Atlanta,
FLOYD,
Chicago, Illinois, Atlanta,
by
known to
Grand Jury,
her
pick her
to pick
the Grand
and caused
a certain individual,
to the
is known
whose identity
individual, Whose
caused acertain
Georgia,
identity is
Jury, to
Georgia, and
for
the
of
to
contact
up
from
a
train
station
in
Fulton
County,
Georgia,
for
the
purposeofattempting
to
contact
Ruby
ﬁom
a
train
station
in
Fulton
Ruby
purpose
attempting
County, Georgia,
up
an overt
act in
of the
worker. This
Freeman,aa Fulton
Fulton County,
County, Georgia,
election worker.
This was
was an
overt act
in furtherance
furtheranceofthe
Freeman,
Georgia, election
conspiracy.
conspiracy.
Act
117.
Act117.
TREVIAN C.
On or about
about the
4th dayofJanuary
Onor
the 4th
C. KUTTI
KUTTI traveled
traveled toto Ruby
Ruby
2021, TREVIAN
day of January 2021,
to
contact
her
unsuccessful.
and
but
was
Freeman's
Cobb County,
Freeman's home
home inin Cobb
Georgia,
and
attempted
to
contact
her
but
was
unsuccessful.
attempted
County, Georgia,
stated that
she was
crisis
Freeman's neighbor
TREVIAN C.
TREVIAN
C. KUTTI
KUTTI spoke
with Freeman's
neighbor and
and falsely
falsely stated
that she
was aa crisis
spoke with
act in
Freeman's
home.
This
was
an
overt
before
‘manager
attempting
to
“help”
Freeman
before
leaving
Freeman's
home.
This
was
an
overt
act
in
to
Freeman
leaving
manager attempting
"help"
furtherance
of the conspiracy.
furtheranceofthe
conspiracy.
118.
Act 118,
Act
TREVIAN C.
while in Fulton
Fulton
On or
of January 2021,
or about
about the
4th day
On
the 4th
dayofJanuary
2021, TREVIAN
C. KUTT,
KUTTI, whilein
and stated
Freeman and
stated that
call to
County,
placed aa telephone
telephone call
to Ruby
that Freeman
Freeman was
was inin
Ruby Freeman
County, Georgia,
Georgia, placed
Freeman
and
she
could
danger.
TREVIAN
C.
KUTTI
stated
that
she
could
“help”
Freeman
and
requested
that
Freeman
stated
that
TREVIAN
C.
KUTTI
"help"
requested that Freeman
danger.
in Cobb
Cobb
Cobb County
meet with
with and
to her
that night
night atat aa Cobb
County Police
Police Department
Department precinct
meet
and speak
her that
precinct in
speak to
of
the
in
furtherance
an
overt
act
County,
Georgia.
This
was
an
overt
act
in
furtheranceofthe
conspiracy.
This
was
conspiracy.
County, Georgia.
Act 119,
ActC. KUTTI
to aa Cobb
Cobb
On
about the
4th dayofJanuary
On or
or about
the 4th
TREVIAN C.
KUTTI traveled
traveled to
2021, TREVIAN
day of January 2021,
and
to
met
with
and
in
Cobb
County
Police
Department
precinct
in
Cobb
County,
Georgia,
and
met
with
and
spoke
to
Ruby
Police
Ruby
County, Georgia,
spoke
County
Department precinct
FLOYD joined
Freeman
for approximately
hour. HARRISON
HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD
Freeman for
one hour.
joined
approximately one
and HARRISON
HARRISON WILLIAM
WILLIAM PRESCOTT
C. KUTTI
the
TREVIAN C.
the meeting
meeting by
by telephone.
telephone. TREVIAN
KUTTIand
PRESCOTT
and purported
to offer
offer her
FLOYD
stated to
that she
she needed
FLOYD stated
to Freeman
Freeman that
needed protection
protection and
purported to
her help.
help. This
This was
was
an
overt act
act in
of the conspiracy.
an overt
in ﬁthherance
furtheranceofthe
conspiracy.

Page 55 Act
120.
Act 120,
On
or about
the 4th
2021 STEPHEN
STEPHEN CLIFFGARD
CLIFFGARD LEE,
LEE,
about the
4th dayof
On or
January day of January
and
committed
TREVIAN
C.
KUTTI
HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD,andTREVIAN
C.
KUTTI
committed the
the
HARRISON
FLOYD,
offense of
of SOLICITATION
SOLICITATION OF
felony
OF FALSE
FALSE STATEMENTS
STATEMENTS AND
AND WRITINGS,
WRITINGS, inin
felony offense
violation of 0.C.G.A. §§ 16-4-7 & 16-10-20, in Cobb County, Georgia, by soliciting, requesting,
and importuning Ruby Freeman, a Fulton County, Georgia, election worker, to engage in
conduct constituting the felony offenseof False Statements and Writings, 0.C.G.A. § 16-10-20,
by knowingly and willfully making a false statement and representation conceming events at
State Farm Arena in the November 3, 2020, presidential election in Georgia, said statement and
representation being within thejurisdictionofthe Officeofthe Georgia SecretaryofState and
the Georgia Bureauof Investigation, departments and agenciesof state goverment, and county
and city law enforcement agencies, with intent that said person engage in said conduct, This was
an actofracketeering activity under O.C.G.A. § 16-14-3(5)(A)xxii) and an overt act in
furtheranceofthe conspiracy.
Act 121.
Act
121.
STEPHEN CLIFFGARD
CLIFFGARD LEE,
On or
the 4th
On
or about
about the
4th dayof
2021 STEPHEN
LEE,
January day of January
and
the
C. KUTTI
HARRISON
HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD,
TREVIAN C.
KUTTI committed
committed the
FLOYD, and TREVIAN
offense of
of INFLUENCING
felony offense
INFLUENCING WITNESSES,
in violation
violation of
of O.C.G.A.
0.C.G.A. §§ 16-1016-10WITNESSES, in
felony
and
93(b)(1)(A),
in Fulton
Fulton County,
engaging inin misleading
misleading
Georgia, by
by knowingly
knowingly and unlawfully
unlawfully engaging
County, Georgia,
93(b)(1)(A), in
she
election worker,
conduct toward
conduct
Ruby Freeman,
Freeman, aa Fulton
Fulton County,
County, Georgia,
Georgia, election
worker, by
by stating
stating that
that she
toward Ruby
her
with
her
to
offer
intent
to
inﬂuence
needed
and
needed protection
protection and by
purporting to offer her help,
help, with intent o influence her testimony
in
testimony in
by purporting
Arena
in
the
events
at
State
Farm
an official
in
Fulton
ofﬁcial proceeding
an
in
Fulton
County,
Georgia,
concerningeventsat
State
Farm
Arena
inthe
Georgia,
County,
concerning
proceeding
in Georgia.
This was
election in
act ofracketeering
of racketeering activity
November
November 3,3, 2020,
2020, presidential
presidential election
was an
an act
activity
Georgia. This
an overt
act in
furtherance of the conspiracy.
under
O.C.G.A. §§ 16-14-under 0.C.G.A.
16-14-3(5)(A)xxvii)
and an
overt act
in furtheranceofthe
conspiracy.
(5)(A)(xxvii) and
Violation of O.C.G.A. §§ 16-4-7 & 16-10-20, in Cobb County, Georgia, by soliciting, requesting,
and importuning Ruby Freeman, a Fulton County, Georgia, election worker, to engage in
conduct constituting the felony offense of False Statements and Writings, O.C.G.A. § 16-10-20,
by knowingly and willfully making a false statement and representation concerning events at
State Farm Arena in the November 3, 2020, presidential election in Georgia, said statement and
representation 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, with intent that said person engage in said conduct. This was
an act of racketeering activity under O.C.G.A. § l614-3(5)(A)(xxii) and an overt act in
furtherance of the conspiracy.

Page 56 Act122.
Act 122.
CLIFFGARD LEE,
On
or about
the 4th
4th dayofJanuary
STEPHEN CLIFFGARD
about the
On or
LEE,
2021, STEPHEN
day of January 2021,
HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD,
and
TREVIAN
C.
KUTTI
placed
multiple
and
C.
KUTTI
TREVIAN
HARRISON
FLOYD,
placed multiple
telephone
calls and
and sent
text messages
messages toto each
to other
involved inin the
the
each other
other and
and to
other individuals
individuals involved
sent text
telephone calls
conspiracy.
They
include
the
following:
the
include
following:
conspiracy. They
HARRISON
call to HARRISON
telephonecallto
placed aa telephone
CLIFFGARD LEE
LEE placed
STEPHEN CLIFFGARD
l.1. At
9:41 am,
At9:a.m., STEPHEN
WILLIAM PRESCOTT
PRESCOTT FLOYD.
FLOYD.
WILLIAM
2. At
At11:HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD
FLOYD placed
placed
aa telephone
telephone call
call
11:24 am.
a.m., HARRISON
to DAVID
DAVID JAMES
JAMES SHAFER.
SHAFER.
to
3. Atpm, STEPHEN
LEE placed
call toto HARRISON
HARRISON
CLIFF GARD LEE
STEPHEN CLIFFGARD
At 12:25 p.m.,
placed aa telephone
telephone call
.
FLOYD.
PRESCOTT
FLOYD.
PRESCOTT
WILLIAM
WILLIAM
HARRISON
4.4 At
At12:p.m., STEPHEN
LEE sent
sent aa text
text message
message toto HARRISON
CLIFFGARD LEE
STEPHEN CLIFFGARD
12:32 p.m.,
FLOYD.
WILLIAM PRESCOTT
PRESCOTT FLOYD.
WILLIAM
5. At
At8:p.m, HARRISON
HARRISON WILLIAM
PRESCOTT FLOYD
FLOYD placed
placedaa telephone
telephone call
to
call to
WILLIAM PRESCOTT
8:10 p.m.,
SHAFER.
DAVID JAMES
DAVID
JAMES SHAFER.
call
6.6 At
At10:HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD
FLOYD placed
placed
aa telephone
telephone call
10:00 p.m,
p.m., HARRISON
toto STEPHEN
CLIFFGARD
LEE,
CLIFFGARD
LEE.
STEPHEN
call
At10:pm, HARRISON
HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD
FLOYD placed
telephone call
77. At
10:19 p.m.,
placed aa telephone
to TREVIAN
KUTTL.
C. KUTTI.
TREVIAN C.
to
TREVIAN C.
8. At
AUpm, TREVIAN
C. KUTTI
KUTTI placed
placed aa telephone
call toto HARRISON
HARRISON
10:43 p.m.,
telephone call
PRESCOTT FLOYD.
WILLIAM PRESCOTT
FLOYD.
WILLIAM
C. KUTTI
call to
11:10 p.m.,
TREVIAN C.
9.9 At
At11:pm, TREVIAN
KUTTI placed
placed aa telephone
telephone call
to HARRISON
HARRISON
WILLIAM
PRESCOTT
FLOYD.
WILLIAM PRESCOTT FLOYD.
to
10. At
At 12:12:12 a.m.
a.m. on
on January
January 5,5, 2021',
2021, TREVIAN
KUTTI placed
telephone call
TREVIAN C.
C. KUTTI
call to
10.
placed aa telephone
HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD.
FLOYD.
HARRISON
‘These
were overt
in furtheranceofthe
furtherance of the conspiracy.
overt acts
acts in
These were
conspiracy.
~

Page 57 Act
123.
Act 123.
CHARLES EASTMAN
4th day
of January 2020,
EASTMAN placed
or about
about the
On or
JOHN CHARLES
dayofJanuary
the dth
On
2020, JOHN
placedaa
telephone call
to Speakerofthe
Arizona House
House of
of Representatives
Representatives Rusty
Bowers and
and solicited,
solicited,
call to
Rusty Bowers
Speaker of the Arizona
telephone
from
Arizona.
electors
Bowers
to
requested,
and
importuned
Bowers
to
unlawfully
appoint
presidential
electors
from
Arizona.
and
importuned
unlawﬁilly appoint presidential
requested,
that he
and stated
stated that
Bowers
declined
to
with Eastman’s
Eastman's request
During
the
telephone
call,
Bowers
declined
to comply
request and
he
the
call,
comply with
telephone
During
the
act in
oath of oﬁice. The
The request
an overt
would not
no risk
risk Violating
violating his
his oathofoffice.
request was
was an
overt act
in furtherance
furtherance of
ofthe
would
conspiracy.
conspiracy.
Act 124.
Act124,
sent an
CHESEBRO sent
the 4th
4th dayof
JOHN CHESEBRO
On
about the
KENNETH JOHN
an e-eOn or
or about
2021, KENNETH
day 0f January
January 2021,
edits" and
included
Draft 2,
EASTMAN with
with the
‘mail toto JOHN
JOHN CHARLES
the subject
subject "Fwd:
“Fw: Draft
2, with
with edits”
and included
CHARLES EASTMAN
mail
CHESEBRO
the
e-mail
another
e-mail
JOHN
of
that
KENNETH
within the
bodyofthe e-mail another e-mail that KENNETH JOHN CHESEBRO previously
within
the body
previously
"PRIVILEGED AND
with the
sentto
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS GIULIANI
GIULIANI with
the subject
sent to RUDOLPH
subject “PRIVILEGEDAND
the e-mail,
on ‘Presidentofthe
Brief notes on
'President of the Senate’
Senate' strategy.”
CONFIDENTIAL
CONFIDENTIAL -Briefnotes
In the
KENNETH
email, KENNETH
strategy." In
session of
of
outlined multiple
and delaying
CHESEBRO outlined
JOHN
JOHN CHESEBRO
for disrupting
thejoint
joint session
delaying the
multiple strategies
strategies for
disrupting and
cast
the
votes
on
the
law
for
Congress
on
January
6,
2021,theday
prescribed
by
law
for
counting
votes
cast
by
the
duly
by
duly
counting
January 6, 2021,
day prescribed by
Congress
and stated
that the
and the
the other
elected
qualified presidential
electors from
from Georgia
other states,
stated that
the
and qualiﬁed
elected and
states, and
presidential electors
Georgia and
Act
Count
to
the
Electoral
to
outcomes of any of these strategies were “preferable
outcomesofanyofthesestrategieswere
to
allowing
the
Electoral
Count
Act
to
"preferable allowing
This was
an overt
act in
its terms."
of the conspiracy.
operate
by its
terms.” This
was an
overt act
in furtherance
furtheranceofthe
conspiracy.
operate by
'

Act 123.
Act123,
JOHN
and JOHN
JOHN TRUMP
On or
or about
about the
On
the 4th
4th dayofJanuary
DONALD JOHN
TRUMP and
2021, DONALD
day of January 2021,
Chiefof
of Staﬂ'
CHARLES EASTMAN
CHARLES
EASTMAN met
met with
with Vice
Vice President
President Mike
Mike Pence,
Pence, Chief
Staff
toto the
the Vice
Vice
in
the
Oval
Ofﬁce
and
Counsel
to
the
Vice
President
Jacob
President
Marc
PresidentMare Short,
Short, and Counsel to the Vice President Greg
Greg Jacob in the Oval Office atat the
the
TRUMP and
and JOHN
White
House. During
White House.
the meeting,
meeting, DONALD
DONALD JOHN
JOHN TRUMP
JOHN CHARLES
CHARLES
During the
states or
could either
electoral votes
votes from
EASTMAN
EASTMANarguedto
Pence that
that he
he could
either reject
reject electoral
from certain
certain sates
or
argued to Pence
on January
session of Congress
the day
delay
thejoint
6, 2021,
day prescribed
prescribed
by
law for
for counting
counting
2021, the
Congress on
January 6,
by law
joint sessionof
delay the
the other
elected and
and qualified
votes
cast by
Votes cast
by the
the duly
duly elected
presidential electors
electors from
from Georgia
Georgia and
and the
other
qualiﬁed presidential
of allowing certain
state legislatures
states,
for the
the purpose
purposeofallowing
certain state
legislatures toto unlawfully
states, for
presidential
unlawfully appoint
appoint presidential
CHARLES
DONALD JOHN
the meeting,
JOHN CHARLES
TRUMP. During
electors
electors inin favor
favor of
ofDONALD
JOHN TRUMP.
meeting, JOHN
During the
act in
This was
admitted both
Count Act.
EASTMAN
EASTMAN admitted
both options
violated the
the Electoral
Electoral Count
Act. This
was an
an overt
overt act
in
options violated
furtherance of the conspiracy.
furtheranceofthe
conspiracy.

Page 58 Act
126.
Act126On
5th dayof
JENNA LYNN
LYNN ELLIS
ELLIS wrote
wroteaa memorandum
memorandum
or about the 5th
On oraboutthe
January 2021, JENNA
day 0f January2021,
and to
U.S.
Constitution
and
Constitution
Electors
U.S.
to
in
pursuant
Electors
Counting
in
"Re: Vice
titled
President Authority
Vice President
titled “Re:
pursuant
Authority Counting
TRUMP.
The
JOHN
DONALD
The
with
TRUMP.
to an
an attorney
and 15"
associated with DONALD JOHN
U.S.
attomey associated
15”to
Code §§
U.S. Code
§§ 55 and
of Congress on
on
for
sessionofCongress
joint session
the joint
outlinedaa strategy
delaying the
and delaying
memorandum
disrupting
for
‘memorandum outlined
strategy
disrupting and
elected
and
the
votes
cast
and
law
for
elected
duly
the
the
by
counting votes cast by duly
by law for counting
prescribed by
6, 2021,
January
2021, the day
day prescribed
January 6,
"the Vice
and
the
other states,
electors
from
President
Vice President
stated, “the
and stated,
states, and
the other
and
Georgia
from
electors
presidential
qualified
Georgia
qualiﬁed presidential
not
the
to
ﬁrst
and
order
of
the
in
open
not
Arizona,
to
firs
should begin
Arizona,
open the
states, and coming
begin alphabetically
should
coming
alphabetically in orderofthe states,
was an overt
overt act
act in
in
purported certification,
but simply
stop the
the count
count atat that
thatjuncture.”
Thiswasan
certiﬁcation, but
juncture." This
simply stop
purported
of
the
furtherance
furtheranceof the conspiracy.
conspiracy.

Page 59 Act
Act127,
STEPHEN
DAVID CHEELEY,
CHEELEY, STEPHEN
ROBERT DAVID
On or about the Sth dayof January 2021, ROBERT
TREVIAN C.
C. KUTTI,
CLIFFGARD
LEE, HARRISON
HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD,
FLOYD, TREVIAN
KUTTI,
CLIFFGARD LEE,
each
other
and
to
other
calls
to
and
SCOTT
GRAHAM
HALL
placed
multiple
telephone
calls
to
cach
other
and
to
other
GRAHAM
HALL
and SCOTT
placed multiple telephone
individuals
involved in
the conspiracy.
They include
include the
the following:
following:
in the
individuals involved
conspiracy. They
TREVIAN
call toto TREVIAN
CLIFFGARD LEE
telephone call
11:32 am,
placed aa telephone
LEE placed
l.
STEPHEN CLIFFGARD
At11:1. At
a.m., STEPHEN
C.
KUTTI.
C.KUTTL
C.
TREVIAN C.
2.2 At
At12:p.m, HARRISON
HARRISON WILLIAM
WILLIAM PRESCOTT
PRESCOTT FLOYD,
FLOYD, TREVIAN
12:14 p.m.,
Individual
and
unindicted
KUTTI, STEPHEN
CLIFFGARD LEE,
LEE, and unindicted co-conspirator
STEPHEN CLIFFGARD
coconspirator Individual
KUTTI,
in
four-way telephone:
to
the
Grand
in aa four-way
known
participated
Jury,
whose
is
Grand
the
to
known
is
identity
whose
23,
telephone
Jury,
participated
23,
identity
call.
call.
GRAHAM HALL
ROBERT
call toto ROBERT
12:19 p.m.,
placed aatelephone
HALL placed
SCOTT GRAHAM
pm, SCOTT
At12:3. At
telephone call
DAVID
DAVID CHEELEY.
CHEELEY.
GRAHAM HALL
4.4 At
At12:SCOTT GRAHAM
HALL placed
placed aatelephone
call toto ROBERT
ROBERT
12:34 pm.
telephone call
p.m., SCOTT
DAVID
CHEELEY.
DAVID CHEELEY.
call to
a telephone call
SCOTT
to SCOTT
1:07 p.m.,
placedatelephone
CHEELEY placed
DAVID CHEELEY
ROBERT DAVID
pm, ROBERT
At1:5. At
GRAHAM HALL.
GRAHAM
HALL.
call to
SCOTT
to SCOTT
1:09 p.m.,
telephone call
placed aa telephone
CHEELEY placed
DAVID CHEELEY
ROBERT DAVID
pm, ROBERT
At1:6. At
GRAHAM HALL.
GRAHAM
HALL.
HARRISON
call to
2:30 p.m.,
DAVID CHEELEY
7.7 At
At2:pm, ROBERT
ROBERT DAVID
CHEELEY placed
placed aa telephone
to HARRISON
telephone call
FLOYD.
WILLIAM
PRESCOTT
WILLIAM PRESCOTT FLOYD.
PRESCOTT FLOYD
placed aatelephone
2:45 pm,
FLOYD placed
WILLIAM PRESCOTT
HARRISON WILLIAM
At2:8. At
telephone
p.m., HARRISON
call to
call
to ROBERT
ROBERT DAVID
DAVID CHEELEY.
CHEELEY.
call to
CHEELEY placedatelephone
9.9 At
At3:ROBERT DAVID
to SCOTT
SCOTT
DAVID CHEELEY
3:5 9 pm.
placed a telephone call
p.m., ROBERT
GRAHAM
GRAHAM HALL.
HALL.
call to
to ROBERT
CLIFFGARD LEE
10. At
At 4:4:42 p.m.,
p.m., STEPHEN
LEE placed
placed aa telephone
telephone call
ROBERT
10.
STEPHEN CLIFFGARD
DAVID
DAVID CHEELEY.
CHEELEY.
call to
to
LEE placed
11.
p.m, STEPHEN
STEPHEN CLIFFGARD
CLIFFGARD LEE
placed aa telephone
telephone call
ll. At4:At 4:50 p.m.,
FLOYD.
PRESCOTT
HARRISON
WILLIAM
HARRISON WILLIAM PRESCOTT FLOYD.
call to
12. At5:pm, STEPHEN
CLIFFGARD LEE
LEE placed
placed aatelephone
to
12.
At 5:05 p.m.,
STEPHEN CLIFFGARD
telephone call
FLOYD.
HARRISON WILLIAM
WILLIAM PRESCOTT
HARRISON
PRESCOTT FLOYD.
On or about the 5th day of January 2021,
o

\

Page 60 call to
13. At
At 7:pm, TREVIAN
TREVIAN C.
C. KUTTI
KUTTI placed
placed aa telephone
telephone call
to ROBERT
ROBERT DAVID
DAVID
7:19 p.m.,
CIIEELEY.
CHEELEY.
a telephone call
call to
TREVIAN
to TREVIAN
14.
At 7:placed atelephone
CHEELEY placed
DAVID CHEELEY
ROBERT DAVID
p.m, ROBERT
7:48 p.m.,
14. At
C.
KUTTI.
C.KUTTL
TREVIAN
CHEELEY placed
DAVID CHEELEY
15. At
pm., ROBERT
ROBERT DAVID
placed aa telephone
call toto TREVIAN
15.
At 8:8:27 p.m.,
telephone call
C.
KUTTI.
C.KUTTL
CHEELEY placed
call to
STEPHEN
DAVID CHEELEY
16. At
At 8:16.
8:49 p.m.,
p.m, ROBERT
ROBERT DAVID
to STEPHEN
placed aa telephone
telephone call
LEE.
CLIFFGARD
CLIFFGARD LEE.
call to
to ROBERT
GRAHAM HALL
l7.
9:18 p.m.,
17. At
At9:p.m, SCOTT
SCOTT GRAHAM
HALL placed
placed aa telephone
telephone call
ROBERT
DAVID
DAVID CHEELEY.
CHEELEY.
call tC. KUTTI
TREVIAN C.
18.
9:31 p.m.,
18. At
At9:pm, TREVIAN
KUTTI placed
placed aatelephone
to ROBERT
ROBERT DAVID
DAVID
telephone call
CHEELEY.
CHEELEY.
call to
to STEPHEN
19. At
At10:DAVID CHEELEY
CHEELEY placed
placed
aa telephone
telephone call
STEPHEN
19.
10:14 p.m,
ROBERT DAVID
p.m., ROBERT
LEE.
CLIFFGARD LEE.
CLIFFGARD
20.
At11:p.m.,
ROBERT DAVID
DAVID CHEELEY
CHEELEY placed
placed
aa telephone
telephone call
call toto TREVIAN
TREVIAN
20. At
11:p.m., ROBERT
C. KUTTI.
C.KUTTL
call to
ROBERT
SCOTT GRAHAM
GRAHAM HALL
21.
At HALL placed
placed aatelephone
to ROBERT
21. At
11:25 p.m,
telephone call
p.m., SCOTT
DAVID
CHEELEY.
DAVID CHEELEY.
TREVIAN C.
SCOTT
22. At
11:35 p.m.,
22.
At11:ROBERT DAVID
DAVID CHEELEY,
C. KUTTI,
KUTTI, and
and SCOTT
CHEELEY, TREVIAN
p.m., ROBERT
call.
GRAHAM
GRAHAM HALL
HALL participated
participated inin aa three-way
threeway telephone
telephone call.
call to
TREVIAN C.
23.
12:09 am.
afm. on
on January
23. At
At12:2021, TREVIAN
C. KUTTI
KUTT placed
placed aa telephone
telephone call
to
6, 2021,
January 6,
DAVID CHEELEY.
CHEELEY.
ROBERT
ROBERT DAVID
of the
These were
acts in
‘These
were overt
overt acts
in furtherance
furtherance of
the conspiracy.
conspiracy.
Act
Act 128.
128.
caused to
to be
be
JOHN TRUMP
TRUMP caused
about the
5th dayof
On
or about
the 5th
DONALD JOHN
On or
2021, DONALD
January 2021,
day of January
"The Vice
the power
President has
Twitter account
account @RealDonaldTrump,
tweeted from
the Twitter
tweeted
from the
Vice President
has the
to
power to
@RealDonaldTrump, “The
was
an
overt
act
in
of
the
This
furtherance
chosen
electors."
reject
fraudulently
chosen
electors.”
This
was
an
overt
act
in
furtheranceofthe
conspiracy.
conspiracy.
reject fraudulently
13.
'

Page 61 Act 129.
Act
129,
with
met with
EASTMAN met
JOHN CHARLES
CHARLES EASTMAN
the 5th
2021, JOHN
On or
or about
about the
5th dayof
On
January 2021,
day of January
Jacob for
for
Vice President
and Counsel
Counsel to
to the
the Vice
President Greg
Chief of Staffto
Staff to the
Short and
Marc Short
President Marc
Vice President
Greg Jacob
the Vice
Chiefof
electors
electors
slates
of
Mike
Pence
ofpresidential
sates
Vice
President
reject
Pence
that
Mike
the
of requesting that Vice President
purposeofrequesting
the purpose
reject
presidential
on
the
session
of
January 6,6, 2021,
on January
Congress
of
other
states
session
certain
2021,
thejoint
during
from
and
states
other
certain
and
from Georgia
Congress
during
joint
Georgia
elected
and
votes
cast
the
presidential
qualified
and
law
for
elected
duly
the
the
by
cast
votes
counting
prescribed by
the day
by
qualiﬁed presidential
duly
by law for counting
day prescribed
of the conspiracy.
an overt
overt act
act in
in furtherance
furtherance ofthe
states. This
other states.
electors from
was an
This was
the other
and the
conspiracy.
from Georgia
electors
Georgia and
Act
Act 130.
130,
met with
Vice
JOHN TRUMP
with Vice
TRUMP met
5th dayof
the 5th
DONALD JOHN
2021, DONALD
On or
about the
or about
On
January 2021,
day of January
the meeting,
at the
DONALD
Ofﬁce at
in the
Oval Office
House. During
Pence in
White House.
the White
President
the Oval
Mike Pence
President Mike
meeting, DONALD
During the
to
the
November
had
the
presidential
2020,
that
Pence
3,
stated that Pence had the power
decertify the November 3, 2020, presidential
JOHN
power to decertify
TRUMP stated
JOHN TRUMP
of Queensberry
and that
wanted to
Marquess of
to “play
election results,
Pence wanted
that Pence
people cheated,
that people
Queensberry
results, that
cheated, and
election
by Marquess
"play by
and that
to
and
defend
the
Constitution
it
was
his
that
that
and
stated
Constitution
the
rules."
When
Pence
supportand defend
rules.” When Pence stated that it was his duty
duty to support
JOHN
of presidential electors,
decide to
only Congress
had the
the power
power toto decide
to reject
slates ofpresidential
DONALD JOHN
electors, DONALD
reject slates
Congress had
only
was
Pence
that
was
that
he
lacked
and
stated
Pence
that
stated
and
was
courage,
lacked
he
that
Pence
that
implied
TRUMP
stated
naive,
was
Pence
that
TRUMP stated
naive, implied
courage,
act in furtherance
of the
the conspiracy.
This was
"a great disservice." This
doing “agreatdisservice.”
was an
an overt
overt actin
furtheranceof
conspiracy.
doing
Act
131.
Act 131.
JOHN TRUMP
TRUMP placed
5th day
placed aa
On
or about
about the
DONALD JOHN
January 2021,
dayofof January
2021, DONALD
the Sth
On or
JOHN
telephone call
call toto Vice
Vice President
President Mike
Mike Pence.
Pence. During
During the
the telephone
telephone call,
DONALD JOHN
call, DONALD
telephone
of
slates of
Pence
to
to
EASTMAN
CHARLES EASTMAN attempted
TRUMP
persuade Pence to reject
reject slates
and JOHN
JOHN CHARLES
TRUMP and
attempted to persuade
an
This was
was an
slates of presidential electors
electors or
or return
presidential electors
return the
the slatesofpresidential
electors toto state
state legislatures.
legislatures. This
presidential
the
of
act
in
furtherance
overt
act
in
furtheranceofthe
conspiracy.
overt
conspiracy.
Act
132.
Act132.
second
JOHN TRUMP
TRUMP placed
placed aa second
or about
about the
the 5th
DONALD JOHN
On or
5th dayof
On
2021, DONALD
January 2021,
day of January
JOHN
the
DONALD
Pence. During
Mike Pence.
call to
Vice President
telephone call
to Vice
President Mike
During the telephone
telephone call,
call, DONALD JOHN
telephone
of Pennsylvania
Pennsylvania
of a letter
from aa group
received aa copy
letter from
copyofa
if he had
TRUMP
asked Pence
had received
Pence ifhe
group of
TRUMP asked
"You
to
stated
the
electoral
votes
and
return
state's
Pence, “You
to Pence,
stated
to
and
votes
college
electoral
urging Congress
legislators urging
college
Congress to return the state’s
legislators
an overt
overt act
the conspiracy.
tomorrow." This
gotta
be tough
tough tomorrow.”
This was
was an
act inin furtherance
furtheranceofof the
conspiracy.
gotta be
Act 133.
Act
133,
issuedaa
TRUMP issued
or about
On
about the
the 5th
5th dayof
2021, DONALD
DONALD JOHN
JOHN TRUMP
On or
January 2021,
day of January
and I| are
are in
that falsely
total
in total
President and
Vice President
“The Vice
statement
falsely stated,
the Trump
statement through
stated, "The
Trump Campaign
Campaign that
through the
several
to
act.
has
has
the
Our
Vice
President
Vice
President
that
the
‘agreement
that
the
Vice
President
has
the
power
to
act...
Our
Vice
President
has
several
options
options
power
agreement
states for
send them
Constitution. He can decertify
under
under the
the U.S.
U.S. Constitution.Hecan
decertify the
the results
results or
or send
them back
back toto the
the states
for
and send
send them
the illegal
can also
also decertify
certiﬁcation. He
change
and certification.
He can
decertify the
illegal and
and cormupt
results and
them toto
corrupt results
change and
an overt
act in
one state
state tabulation.”
one vote
tabulation." This
of Representatives
the
Representatives for
for the
the one
vote for
for one
This was
was an
overt act
in
the House
House of
furtheranceof
the conspiracy.
furtherance
of the
conspiracy.

Page 62 Act
134.
Act134,
LATHAM placed
placed aa
6th dayof
ALSTON LATHAM
about the
CATHLEEN ALSTON
2021, CATI-ILEEN
On or
the 6th
or about
On
day of January
January 2021,
GRAHAM HALL
SCOTT GRAHAM
HALL. Several
Several hours
GRAHAM HALL.
HALL
to SCOTT
SCOTT GRAHAM
later, SCOTT
hours later,
callto
telephone
telephone call
one
of
the
least
at
ALSTON
LATHAM.
to
CATHLEEN
placed
a
telephone
call
to
CATHLEEN
ALSTON
LATHAM.
During
at
least
oneofthe
phone
call
phone
During
placed a telephone
with the
of
breach of
assist with
unlawful breach
the unlawﬁJl
GRAHAM HALL's
SCOTT GRAHAM
request toto assist
HALL’ request
calls,theydiscussed
calls, they discussed SCOTT
in
Coffee
Ofﬁce
Coffee
in
Board
of
Elections
&
Office
at
the
Coffee
Registration
&
election
BoardofElections
County
election equipment
Registration
equipment at the Coffee County
acts in
were overt
overt acts
furtherance of the
County, Georgia.
These were
in furtheranceof
the conspiracy.
conspiracy.
County,
Georgia. These
Act 135.
Act
135.
and
TRUMP appeared
6th day
Onoraboutthe
dayofof January
January 2021,
2021, DONALD
DONALD JOHN
JOHN TRUMP
appeared and
or about the 6th
On
TRUMP
JOHN TRUMP
at the
spoke
a rally
the Ellipse
Ellipse inin Washington,
Washington, D.C.
D.C. During
During the
the rally,
DONALD JOHN
at a
rally, DONALD
rally at
spoke at
election
fraud
in
the
November
‘made
statements concerning
concerning fraud in the November 3,3, 2020,
2020, presidential
presidential election inin
made false
false statements
session
and delay
solicited Vice
to disrupt
thejoint
disrupt and
and elsewhere,
Pence to
Mike Pence
President Mike
Vice President
Georgia
delay the
joint session
elsewhere, solicited
Georgia and
the
cast
votes
the
law
for
duly
the
by
cast
votes
on
counting
for
of
by law counting
prescribed by
2021,the day
duly
by
ofCongress
6, 2021,
day prescribed
January 6,
Congress on January
and
from
and
the
other
electors
encouraged
and
states,
elected and
and qualified
other
the
and
Georgia
from
electors
states,
presidential
encouraged
elected
Georgia
presidential
qualiﬁed
act in
an overt
This was
march to
to the
States Capitol.
the rally
those inin attendance
attendance atat the
rally toto march
the United
United States
Capitol. This
was an
overt act
in
those
of the conspiracy.
furtherance
furtheranceofthe
conspiracy.
Act
136.
Act 136.
GIULIANI
On
the 6th
2021, RUDOLPH
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS GIULIANI
6th dayofJanuary
about the
On or
or about
day of January 2021,
ataa rally
appeared
and spoke
rally atat the
the Ellipse
Ellipse inin Washington,
Washington, D.C.
D.C. During
During the
the rally,
rally, RUDOLPH
RUDOLPH
spoke at
appeared and
in
the
November
fraud
made
false
statements
GIULIANI
LOUIS
WILLIAM
LOUIS
GIULIANI
made
false
statements
concerning
fraud
in
the
November
3,3,
WILLIAM
concerning
Vice President
Pence toto
Mike Pence
and elsewhere
elsewhere and
and solicited
solicited Vice
President Mike
election in
in Georgia
2020, presidential
Georgia and
2020,
presidential election
law for
the
for
of
on
by
the
session
prescribed
day
the
and
2021,
6,
January
on
disrupt
day prescribed by law
Congress
January 6, 2021,
delay thejoint
joint sessionofCongress
disrupt and delay
the
electors from
fromGeorgiaand
votes cast by
presidential electors
qualified presidential
and qualiﬁed
elected and
the duly
by the
countingvotescast
Georgia and the
duly elected
counting
overt act
act in
of the conspiracy.
This was
other
states. This
other states.
was an
an overt
in furtherance
furtheranceofthe
conspiracy.
Act
137.
Act137,
JOHN CHARLES
the 6th
6th dayof
EASTMANappearedand.
CHARLES EASTMAN
On
2021, JOHN
appeared and
abouthe
or about
On or
January 2021,
day of January
CHARLES
JOHN
in
D.C.
the
the
at
spoke
at
a
rally
at
the
Ellipse
in
Washington,
D.C.
During
the
rally,
JOHN
CHARLES
at
a
During
rally,
Ellipse Washington,
rally
spoke
statements concerning
presidential
made false
false statements
2020, presidential
November 3,3, 2020,
the November
EASTMAN made
fraud inin the
EASTMAN
concerning fraud
of
the
session
and
President Mike
Mike Pence
to disrupt
election
Vice President
Pence to
and
delay
thejoint
session
of
solicited Vice
election and
and solicited
delay
joint
disrupt
cast
the
votes
for
‘Congress
on January
January 6,6, 2021,
the day
by law
law for counting
by the duly
duly
2021, the
counting votes cast by
day prescribed
prescribed by
Congress on
was
an
overt
states.
This
electors
from
and
the
other
wasanovert
This
states.
other
elected and
the
and
Georgia
from
electors
qualified presidential
and qualiﬁed
elected
Georgia
presidential
the
of
furtherance
act
in
actin furtheranceofthe conspiracy.
conspiracy.

Page 63 Act
Act 138.
On or about the 6th dayof January 2021, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account@RealDonaldTrump, “IfVice President @Mfike_Pence comes
through for us, we will win the Presidency. Many States want to decertify the mistake they made
in certifying incorrect & even fraudulent numbers ina process NOT approved by their State
Legislatures (which it must be). Mike can send it back!” This was an overt act in furtherance of
the conspiracy.
the
conspiracy.
Act
139.
Act139.
caused to
be
JOHN TRUMP
about the
On or
or about
On
the 6th
6th dayofJanuary
DONALD JOHN
TRUMP caused
to be
2021, DONALD
day of January 2021,
account @RealDonaldTrump, "States
tweeted
tweeted from
from the
the Twitter
Twitter account@RealDonaldTrump,
“States want
want toto correct
correct their
their votes,
votes, which
which
never
received
on
know
were
based
and
now
they now know were based on irregularities
plus corrupt
process never received
fraud, plus
irregularities and fraud,
corrupt process
they
WIN.
All Mike
Mike Pence
Pence has
has to
send them
legislative approval.
to do
do isis send
them back
back toto the
the States,
AND WE
WE WIN.
States, AND
legislative
approval. All
furtherance
of
the
act
in
This
was
an
overt
Dotit Mike,
Mike, this
this iss aa time
time for
for extreme
extreme courage!”
This
was
an
overt
act
in
furtherance
ofthe
Do
courage!"
conspiracy.
conspiracy.
Act 140.
Act
140.
TRUMP placed
about the
6th day
On or
or about
the 6th
dayofof January
2021, DONALD
DONALD JOHN
JOHN TRUMP
placed aa
On
January 2021,
and delay
President Mike
and solicited
solicited him
Pence and
telephone call
call t0to Vice
Vice President
Mike Pence
him toto disrupt
delay the
thejoint
joint
disrupt and
telephone
for
votes
cast
the
on
law
the
session of
of Congress
session
on
January
6,
2021,
the
day
prescribed
by
law
for
counting
votes
cast
by the
by
counting
Congress
January 6, 2021,
day prescribed by
When Pence
the other
other states.
states. When
and qualified
and the
elected and
electors from
duly elected
presidential electors
from Georgia
Pence
Georgia and
duly
qualiﬁed presidential
down
as
a
and
that
JOHN
TRUMP
stated
that
Pence
would
DONALD
refused,
DONALD
JOHN
TRUMP
stated
that
Pence
would
“go
down
as
a
wimp"
and
that
refused,
wimp"
"go
of the
the United
This was
overt act
act in
States. This
Pence
was not
Pence was
not protecting
protecting the
United States.
was an
an overt
in furtherance
furtheranceofthe
conspiracy.
conspiracy.
On or about the 6th day of January 2021, DONALD JOHN TRUMP caused to be
tweeted from the Twitter account @RealDonaldTrump, "If Vice President @Mike_Pence comes
through for us, we will Win the Presidency. Many States want to decertify the mistake they made
in certifying incorrect & even fraudulent numbers in a process NOT approved by their State
Legislatures (which it must be). Mike can send it back!" This was an overt act in furtherance of
6

Page 64 Act 141.
Act141,
CHARLES EASTMAN
sent an eOn
about the
6th dayof
On or
or abou
the 6th
JOHN CHARLES
EASTMAN scatan
¢2021, JOHN
day of January
January 2021,
that
stated:
to Counsel
Jacob
mail
mail to
Counsel toto the
the Vice
Vice President
President Greg
Jacob
that
sated:
Greg
Act this
violated the
the Electoral
“The Senate
House have
have both
both violated
Electoral Count
Count Act
ths evening
evening —
"The
Senate and
and House
Violation
of
hours.
more
than
debated
the
Arizona
for
they
debated
the
Arizona
objections
for
more
than
hous.
Violation
of
33 USC
USC
they
objections
after the
debate or
or statements
l7.
17. And
And the
the VP
VP allowed
allowed fmther
further debate
statements by
leadership after
the
by leadership
And
had
that
debate
USC
17.
had
been
Violation
of
voted
question
had
been
voted
upon.
Violation
of
3USC
17.”
Andtheyhad
that
debate
they
question
upon.
in
USC
the
that
motion approved
of
the VP,
‘upon
bythe
VP, inin violation
violationofthe
requirement
15 that
requirement in 3 USC upon motion
approved by
meet.'
afterthe
the vote
shall immediately
after
vote inin the
the separate
separate houses,
houses, 'they
‘they shall
immediately again
again meet.
Act is
So now
been set
set that
the Electoral
So
now that
that the
the precedent
precedent has
hasbeen
that the
Electoral Count
Count Act
is not
not quite
so
quite so
consider
one
more
to
as was
was previously
I
sacrosanctas
sacrosanct
previously claimed,
I
implore
you
to
consider
one
more
claimed, implore you
allow the
violation and
and adjourn
relatively
minor violation
for 1010 days
to allow
the legislatures
legislatures toto
relatively minor
days to
adjourn for
audit
of the
the massive
a
full
forensic
ﬁnish their
their investigations,
as
well
as
to
allow
finish
as
well
as
to
allow
a
full
forensic
auditof
massive
investigations,
If none of that moves
amount of illegal activity
amountofillegal
activity that
that has
has occurred
here. Ifnoneofthat
moves the
the
occurred here.
who
President
million
at
least
a
of
the
needle,
atleast
a
good
portionofthe
million
people
who
supported
President.
needle,
supported
people
good portion
be aired.
aired.
seen aa process
that allowed
allowed the
“Tramp will
will have
have seen
process that
the illegality
illegality toto be
Trump
John"
John”
an overt
overt act
This was
furtherance of the conspiracy.
‘This
was an
actinin furtheranceofthe
conspiracy.
Act 142.
Act142.
LATHAM sent
sent aa
On
or about
about the
7th day
On or
the 7th
dayofof January
January 2021,
CATHLEEN ALSTON
ALSTON LATHAM
2021, CATI-ILEEN
LLC
the
with
address
for
to
the
of
SullivanStrickler
text message
Chief Operations
Ofﬁcer of SullivanStrickler LLC with the address for the
text
the
message to the Chief
Operations Officer
to
coordinate
SCOTT
in
Coffee
Douglas
Municipal
Airport
in
Coffee
County,
Georgia,
to
coordinate
picking
up
SCOTT
picking
up
County,
Georgia,
Douglas Municipal Airport
&
HALL from
him to
of Elections &
GRAHAM
and driving
GRAHAM HALL
from the
the airport
airport and
driving him
to the
the Coffee
Coffee County
BoardofElections
County Board
of election equipment
at
Ofﬁce for
the unlawﬁll
of assisting with
Registration
for the
the purpose
purposeofassisting
with the
unlawful breach
breachofelection
equipment at
Registration Office
an
Ofﬁce.
was
act
of
&
This
the Coffee County
Board
of
Elections
theCoffee
Board
of
Elections
&
Registration
Office,Thiswas
an
actofracketeering
racketeering
County
Registration
of the
in furtherance
furtherance of
an overt
overt act
act in
O.C.G.A. §§ 16-14-3(5)(B)
and an
activity
under O.C.G.A.
16-14-3(5)(B) and
the conspiracy.
conspiracy.
activity under
Act
143.
Act143,
and unindicted
SCOTT GRAHAM
On
abou the
7th dayof
GRAHAM HALL
HALL and
unindicted
On or
or about
the 7th
2021, SCOTT
day of January
January 2021,
Grand Jury,
from DeKalbknown to
co-conspirator Individual
Individual 24,
24, whose
whose identity
identity isis known
to the
the Grand
Jury, ﬂew
flew from
DeKalbco-conspirator
in
Coffee
in
to
Peachtree
DeKalb
Peachtree Airport
in
DeKalb
County,
Georgia,
to
Douglas
Municipal
Airport
in
Coffee
County,
County,
Airport
County, Georgia, Douglas Municipal Airport
of
election
with
unlawful
breach
at
the
for the
the purposeofassisting
the unlawful breachofelection equipment
Georgia, for
equipment at the
Georgia,
purpose of assisting with the
This was
act of racketeering activity
Ofﬁce. This
Coffee County
of Elections&& Registration
Coffee
County Board
BoardofElections
Registration Office.
was an
an actofracketeering
activity
in
furtherance
of
the
under
O.C.G.A.
and
an
overt
act
under 0.C.G.A. §§ 16-14-3(5)(B)
conspiracy.
l6-l4-3(5)(B) andanovert act in furtheranceofthe conspiracy.

Page 65 Act
Act 144.
144.
SIDNEY KATHERINE
POWELL,
KATHERINE POWELL,
On or
7th dayof
the 7th
about the
or about
On
2021, SIDNEY
January 2021,
day of January
and MISTY
SCOTT GRAHAM
HAMPTON
MISTY HAMPTON
HALL, and
CATHLEEN ALSTON
GRAHAM HALL,
LATHAM, SCOTT
ALSTON LATHAM,
CATHLEEN
PRIMARIES
AND
WITH
ELECTIONS,
AND
INTERFERENCE
PRIMARIES
of INTERFERENCE WITH
ELECTIONS,
offense of
committed the
felony offense
the felony
committed
and unlawfully
unlawfully
Coffee County,
Georgia, by
County, Georgia,
212-566, inin Coffee
of O.C.G.A. §§ 21-2-566,
violationof0.C.G.A.
inin Violation
willfully and
by wilfully
in
Coffee
machines
County,
and
Coffee
in
markers
machines
ballot
tabulating
and
with
electronic
markers
tampering with electronic ballot
Georgia.
County, Georgia.
tabulating
tampering
of the conspiracy.
an overt
overt act
‘This
was an
act inin furtherance
furtheranceofthe
conspiracy.
This was
145.
Act Act
SIDNEY KATHERINE
On
about the
the 7th
7th dayof
KATHERINE POWELL,
POWELL,
On or
or about
2021, SIDNEY
January 2021,
day of January
and MISTY
HAMPTON
MISTY HAMPTON
HALL, and
SCOTT GRAHAM
GRAHAM HALL,
ALST ON LAT
CATHLEEN ALSTON
LATHAM,
CATHLEEN
HAM, SCOTT
of
Violation of
OF
POSSESSION
in violation
UNLAWFUL
BALLOTS,
of UNLAWFUL POSSESSION OF BALLOTS, in
offense of
committed the
felony offense
the felony
committed
certain members
of the
the conspiracy,
Coffee County,
membersof
by causing
O.C.G.A. §§ 21-2-Georgia, by
County, Georgia,
212-574,4, inin Coffee
conspiracy,
0.C.G.A.
causing certain
not
ballots
and
who
were
care
of
with
the
persons
law
not
were
were
ofﬁcers
who
and
who were not
by law with the care of ballots
not officers charged
persons
who
charged by
to
a
for
of
ballots
the
care
possess
with
to possess
law,
by
entrusted by
such
officer
required
purpose
a
for
law,
officerwiththecareofballots
by
such
by any
required
entrusted
purpose
any
act in
This
an
overt
was
Coffee County,
official
polling place
place inin Coffee
Georgia.
This
was
an
overt
act
in
outside of the polling
ofﬁcial ballots
ballots outsideofthe
County, Georgia.
furtherance of the conspiracy.
furtheranceofthe
conspiracy.
Act 146.
Act
146.
SIDNEY KATHERINE
POWELL,
On or
or about
KATHERINE POWELL,
2021, SIDNEY
7th dayof
the 7th
about the
On
January 2021,
day 0f January
HAMPTON
and MISTY
SCOTT GRAHAM
MISTY HAMPTON
CATHLEEN ALSTON
ALSTON LATHAM,
HALL, and
GRAHAM HALL,
LATHAM, SCOTT
CATHLEEN
in
Violation
of
O.C.G.A.
of
COMPUTER
committed the
committed
the felony
felony offense
offense of COMPUTER THEFT,
THEFT, in violation of 0.C.G.A. §§ 16-9-93(a),
169-93(a),
without
that
such
use
was
with
without
was
use
such
that
a
knowledge
with
computer
Coffee County,
a
using
by
Georgia,
inin Coffee
knowledge
computer
by
using
County, Georgia,
and software,
the
software, the
of taking and
information, data,
and with
with the
appropriating information,
and appropriating
data, and
intentionoftaking
the intention
authority
authority and
act
of
was an
This was
an act of
of Dominion Voting
County, Georgia.
Coffee County,
Corporation inin Coffee
Systems Corporation
propertyofDominion
Georgia. This
Voting Systems
property
of the
act in
and an
overt act
furtheranceofthe
in furtherance
an overt
16-14-3(5)(A)(xix)
O.C.G.A. §§ 1614-under O.C.G.A.
activity under
racketeering activity
(5)(A)(Xix) and
racketeering
conspiracy.
conspiracy.
Act 147.
Act
147.
POWELL,
KATHERINE POWELL,
On or
about the
7th day
SIDNEY KATHERINE
2021, SIDNEY
dayofof January
the 7th
or about
On
January 2021,
GRAHAM HALL,
and MISTY
SCOTT GRAHAM
HAMPTON
MISTY HAMPTON
CATHLEEN ALSTON
HALL, and
LATHAM, SCOTT
ALSTON LATHAM,
CATHLEEN
of 0.C.G.A.
16-9O.C.G.A. §§ 169COMPUTER TRESPASS,
‘committed
the felony
felony offense
offense of
ofCOMPUTER
TRESPASS, inin Violation
violation of
committed the
with
that
such
use
was
a
was
use
such
knowledge that
Coffee County,
using a computer
by using
in Coffee
93(b),
computer with knowledge
Georgia, by
93(b), in
County, Georgia,
data and
and Dominion
without
authority and
with the
the intentionofremoving
voter data
Dominion Voting
intention of removing voter
and with
without authority
Voting Systems
Systems
of
This
was
an
act
racketeering
of
act
an
in
Coffee
was
This
Georgia.
County,
data
from
said
Coffee
in
computer
Corporation
racketeering
County, Georgia.
Corporation data from said computer
act in furtherance
of the conspiracy.
and an
conspiracy.
furtheranceofthe
O.C.G.A. §§ 16-14-overt actin
an overt
16-14-3(5)(A)(xix)
under O.C.G.A.
activity
(5)(A)(xix) and
activity under

Page 66 Act
Act 148.
148,
SIDNEY KATHERINE
of January 2021,
7th day
On or
or about
about the
KATHERINE POWELL,
POWELL,
2021, SIDNEY
dayofJanuary
the 7th
On
HAMPTON
GRAHAM HALL,
CATHLEEN
ALSTON LATHAM,
LATHAM, SCOTT
SCOTT GRAHAM
and MISTY
MISTY HAMPTON
CATHLEEN ALSTON
HALL, and
of
in
Violation
OF
INVASION
COMPUTER INVASION OF PRIVACY,
offense of
committed
the felony
felony offense
of COMPUTER
PRIVACY, in violation of
committed the
of
the intention
with the
intention of
Coffee County,
using aa computer
by using
O.C.G.A. §§ 169-93(c),
in Coffee
0.C.G.A.
County, Georgia,
Georgia, by
computer with
16-9-93(c), in
that
such
examination
was
without
This
authority.
data
with
without
was
voter
personal voter data with knowledge
authority. This
examining
knowledge that such examination
examining personal
act in
and an
an overt
O.C.G.A. §§ 16-14-in
overt act
was an
of racketeering activity
16-14-3(S)(A)(xix)
under O.C.G.A.
actofracketeering
an act
‘was
(5)(A)(xix) and
activity under
the
furtheranCe
of
furtheranceofthe conspiracy.
conspiracy.
Act
149.
Act 149,
and the
the 7th
7th day
of January
6th day
On
between the
the 6th
of December
December 2020 and
dayof
On and
and between
2021,
January 2021,
day 0f
GRAHAM
ALSTON
SCOTT
CATHLEEN ALSTON LATHAM,
SIDNEY KATHERINE
SIDNEY
KATHERINE POWELL,
POWELL, CATHLEEN
LATHAM, SCOTT GRAHAM
TO
the
oﬁense
of
CONSPIRACY TO
committed
of CONSPIRACY
HAMPTON
offense
and
MISTY
felony
the
committed
HAMPTON
MISTY
and
HALL,
felony
HALL,
in
of
O.C.G.A.
Coﬁee
by
Georgia,
County, Georgia, by
DEFRAUD THE
16-10-21, in Coffee County,
violation of0.C.G.A. §§ 16-10-21,
in Violation
THE STATE,
DEFRAUD
STATE, in
commit theft
of voter
voter data,
which was
the
under the
was under
theftof
agreeing toto commit
and agreeing
data, property
unlawfully
property which
unlawfully conspiring
conspiring and
a
in
his
ofﬁcial
Brad
state
of
State
capacity.
of
official
his
in
control
officer,
Brad Raffensperger,a
capacity.
controlofGeorgia
Raﬁensperger, state ofﬁcer,
Secretary
Georgia SecretaryofState
act in
and an
an overt
“This was
was an
under O.C.G.A.
O.C.G.A. §§ 16-14-16-14-3(5)(B)
overt act
in
This
an actofracketeering
act of racketeering activity
(5)(B) and
activity under
furtherance
of
the
furtheranceofthe conspiracy.
conspiracy.
Act
Act 150.
150.
10th dayof
11th day
the 11th
On or
about the 9th
9th dayof
January 2021,
the 10th
2021, the
day
oraboutthe
On
January 2021, the
day of January
day of January2021,
Individual
of
unindicted
of
2021, and
the 13th
13th dayofJanuary
25,
0f January
and the
2021, unindicted co-conspirator
co-conspirator Individual 25,
day January 2021,
January 2021,
accessed certain
certain data
Grand Jury,
whose
whose identity
identity isis known
known toto the
the Grand
data copied
from
Jury, unlawfully
unlawfully accessed
copied from
& Registration
Coﬁee County
of Elections &
Dominion Voting
Voting Systems
equipment atat the
the Coffee
County Board
BoardofElections
Registration
Dominion
Systems equipment
said data
data ﬁom
Office inin Coffee
by downloading
from aa server
server maintained
maintained by
by
Ofﬁce
Coﬁee County,
downloading said
Georgia, by
County, Georgia,
an actofracketeering
act of racketeering activity
under
O.C.G.A.
SullivanStrickler
LLC. This
SullivanSitrickler LLC.
This was
was an
under
0.C.G.A.
§
16-14-3(5)(B)
§ l6-l43(5)(B)
activity
of the conspiracy.
and an
an overt
overt act
act in
and
in furtherance
furtheranceofthe
conspiracy.
Act 151.
Act
151.
the 10th
of January 2021,
On or
9th day
or about
On
about the
the 9th
dayofJanuary
2021, the
10th dayofJanuary
2021, the
the 11th
11th day
day
day of January 2021,
and the
the 18th
of
2021, the
18th dayofJanuary
the 19th
19th dayof
January 2021,
2021,
0f January
2021, and
day of January
day of January 2021,
January 2021,
the Grand
unindicted
unindicted co-conspirator
co-conspirator Individual
Individual 26,
whose identity
identity isis unknown
unknown toto the
Grand Jury,
Jury,
26, whose
at the
unlawfully accessed
copied from
from Dominion
Dominion Voting
Voting Systems
the Coffee
Coffee
data copied
accessed certain
certain data
Systems equipment
equipment at
unlawfully
Oﬁice
in
Coffee
&
County
Board
ofElections&
Registration
Office
in
Coffee
County,
Georgia,
by
downloading
of
Elections
Board
downloading
Registration
County, Georgia, by
County
SullivanStrickler LLC.
This was
was an
an act
act of
of racketeering
said
data from
from aa server
server maintained
said data
maintained by
by SullivanStrickler
LLC. This
racketeering
and
an
overt
act
in
furtherance
of
the
under
O.C.G.A.
16-14-activity
under
O.C.G.A.
§
16-14-3(5)(B)
and
an
overt
actin
furtherance
of
the
conspiracy.
conspiracy.
(5)(B)
§
activity

Page 67 Act
152.
Act152.
of January
13th
the 13th
2021, the
0f January 2021,
January 2021,
dayof
12th day
the 12th
or about
about the
On or
dayofJanuary
2021, the
10th day
the 10th
On
of
and
the
26th
2021,
of
February
of
day
the
25th
26th
the
and
2021,
2021,
February
dayof
of
25th
the
2021,
February
January
dayof
2021,
day
day February
day January 2021,
Grand Jury,
to the
Whose identity
unknown to
Jury,
the Grand
identity isis unknown
unindicted co-conspirator
Individual 27,
co-conspirator Individual
unindicted
27, whose
Coffee
at the
Dominion Voting
the Coffee
data copied
accessed certain
Voting Systems
from Dominion
copied from
certain data
unlawfully accessed
equipment at
Systems equipment
unlawfully
Oﬁice
in
Coffee
&
downloading
by downloading
of Elections & Registration
County, Georgia,
Registration Office in Coffee County,
BoardofElections
Georgia, by
County Board
County
of racketeering
an act
SullivanStrickler LLC.
actofracketeering.
was an
This was
said data
LLC, This
maintained by
server maintained
from aa server
data from
said
by SullivanStrickler
the
of
and
an
overt
act
in
furtherance
conspiracy.
the
of
O.C.G.A. §§ 16-14-3(5)(B)
conspiracy.
16-14-3(5)(B) and an overt act in furtherance
under O.C.G.A.
activity
activity under
Act
153.
Act 153.
Individual 28,
about the
co-conspirator Individual
On or
or about
28,
unindicted co-conspirator
2021, unindicted
13th dayof
the 13th
On
January 2021,
day 0f January
from
data
certain
accessed certain data copied
Grand Jury,
known to
whose
Jury, unlawfully
the Grand
to the
identity isis known
copied from
‘whose identity
unlawfully accessed
&
at
the
Coffee
Board
of
Elections
Registration
& Registration
Elections
Boardof
Dominion
County
Coffee
the
at
equipment
Systems
Voting
Dominion Voting Systems equipment
County
maintained
a
server
said
data
from
by
Oﬁice in
Coffee County,
Georgia, by
County, Georgia,
in Coffee
Office
by downloading
downloading said data from a server maintained by
O.C.G.A. §§ l614-3(5)(B)
16-14-3(5)(B)
was an
act of racketeering
LLC. This
This was
under O.C.G.A.
activity under
racketeering activity
an actof
SullivanStrickler
SullivanStrickler LLC.
furtherance of the conspiracy.
an overt
overt act
and
act inin furtheranceofthe
and an
conspiracy.
Act
154.
Actise,
counindicted cothe 18th
18th dayof
On
MISTY HAMPTON
HAMPTON allowed
allowed unindicted
or about
about the
On or
2021, MISTY
January 2021,
day of January
to
Grand Jury,
are known
conspirators
Individual 25 and
and Individual
Individual 29,
whose identities
identitiesare
known toto the
the Grand
Jury, to
29, whose
conspirators Individual
in
Oﬁice
&
Coffee
in Coﬂee
Coffee
Board
of
Elections
Office
Registration
of
the
&
areas
ofElections
Board
access non-public
County
Coffee
the
areasof
access
Registration
County
non-public
This
access to
was
Voting Systems
Dominion Voting
to Dominion
their access
facilitated their
and facilitated
Georgia, and
County,
equipment This was
Systems equipment.
County, Georgia,
of the conspiracy.
an
overt act
an overt
act inin furtherance
furtheranceofthe
conspiracy.
Act
Act 155.
155.
Individual 28,
whose
28, whose
22nd dayof
unindicted co-conspirator
On or
or about
the 22nd
about the
On
2021, unindicted
co-conspirator Individual
day of April
April 2021,
of
Oﬁicer
sent
an
email
to
the
Chief
Grand
to
the
is
known
identity
is
known
to
the
Grand
Jury,
sent
an
e-mail
to
theChief
Operations
Officer
of
Jury,
Operations
identity
all data
data copied
from Dominion
Systems
Voting Systems
Dominion Voting
SullivanStrickler LLC
transmit all
him toto transmit
directing him
LLC directing
SullivanStrickler
copied from
Coffee
in
Ofﬁce
County,
&
Coffee
in
of
Elections
Office
Board
Registration
&
at
the
Coffee
County,
BoardofElections
County
Coffee
Registration
equipment at the
County
equipment
Grand Jury,
known to
Individual 30,
whose identity
the Grand
to the
identity isis known
unindicted co-conspirator
30, whose
Jury,
Georgia, toto unindicted
co-conspirator Individual
Georgia,
This
and the
SIDNEY KATHERINE
with SIDNEY
associated with
the Trump
an attorney
POWELL and
KATHERINE POWELL
Campaign. This
Trump Campaign.
attomey associated
an
in
overt
act
and
an
under
O.C.G.A.
of
was
an
act
of
racketeering
activity
under
0.C.G.A.
§
16-14-3(5)(B)
and
an
overt
act
in
an
act
was
§ 16-14-3(5)(B)
racketeering activity
furtherance
of the conspiracy.
furtheranceofthe
conspiracy.

Page 68 Act
156.
Act 156.
committed
JOHN TRUMP
TRUMP committed
On or
DONALD JOHN
September 2021,
of September
17¢h day
the 17th
about the
2021, DONALD
or about
On
day of
OF VIOLATION
offense of
the
OFFICER,
the felony
felony offense
of SOLICITATION
SOLICITATION OF
VIOLATION OF
OF OATH
OATH BY
BY PUBLIC
PUBLIC OFFICER,
unlawfully
by unlawfully
and 16-10-1,
Fulton County,
of O.C.G.A. §§
16-10-1, inin Fulton
164-7 and
violationof0.C.G.A.
inin Violation
Georgia, by
County, Georgia,
§§ 16-4-Brad
of
State
public
aa public
and
Raffensperger,
Brad
SecretaryofState
Georgia
importuning
and
requesting,
soliciting,
Raffensperger,
importuning Georgia Secretary
soliciting, requesting,
Public
Oath
of
of
Violation
the
oﬁ'ense
Public
by
Oath
in
conduct
to engage
by
officer,
ofﬁcer, to
constituting the felony
felony offenseof Violationof
engage in conduct constituting
correct
or Whatever
the correct
whatever the
O.C.G.A. §§ 16-10-1,
Election, or
the Election,
“decertifying the
unlawfully "decertifying
16-10-1, by
Officer,
Ofﬁcer, 0.C.G.A.
by unlawfully
of
the
terms
Violation
and
intentional
the
true
in
willful
and
announce
terms
the
violationof
winner,” in willful and intentional
remedy is,
legal
is, and announce the true Winner,"
legal remedy
said
said person
ofthe
person asas prescribed
by law,
law, with
with intent
intent that
that said
person engage
engage inin said
oath of said person
of the oathofsaid
prescribed by
act
in
furtherance
of
the
an
overt
This
was
conduct.
conduct. This was an overt act in furtheranceofthe conspiracy.
conspiracy.
Act 157.
Act
157,
committed the
of September 2021,
the
about the
TRUMP committed
On
JOHN TRUMP
DONALD JOHN
17th day
the 17th
On oror about
2021, DONALD
day ofSeptember
of
Violation
O.C.G.A.
in
16oﬁ'ense of FALSE
AND WRITINGS,
STATEMENTS AND
FALSE STATEMENTS
WRITINGS, in violation of 0.C.G.A. §§ 16felony
felony offenseof
the
and
10-20,
in
Fulton
County,
Georgia,
by
knowingly,
willfully,
and
unlawfully
making
the
following
in
Fulton
making
following
unlawfully
10-20,
County, Georgia, by knowingly, willfully,
Brad Raffensperger
of State
falsestatementand
representation toto Georgia
Georgia Secretary
State Brad
false
statement and representation
Raffensperger:
Secretary of
than
of false and/or
and/or irregular
greater than
far greater
votes sis far
irregular votes
stated to
numberoffalse
the number
previously, the
to you
“As stated
1.l. "As
you previously,
needed
needed toto change
change the
the Georgia
election result”;
result";
Georgia election
State and
and
within thejurisdictionof
the jurisdiction of the
Office of the Georgia
said statement
statement being
the Officeofthe
Secretary of Sate
being within
said
Georgia Secretaryof
and county
of state government,
of Investigation,
and agencies
the Georgia
Bureauof
agenciesofstate
the
county
government, and
Investigation, departments
departments and
Georgia Bureau
under
O.C.G.A.
This was an act of
enforcement agencies.
‘and
city law
law enforcement
of racketeering
racketeering activity
16+
and city
activity under 0.C.G.A. §§ l6agencies. Thiswasanact
act
in
the
an
overt
furtherance
of
and
l4-14-3(5)(A)(xii)
and
an
overt
act
in
furtheranceofthe
conspiracy.
conspiracy.
(5)(A)(xxii)

Page 69 Act
Act 158.
158.
On or about the 25th dayof April 2022, DAVID JAMES SHAFER commited the
felony offense of FALSE STATEMENTS AND WRITINGS, in violationof 0.C.G.A. § 1610-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of
the following false statements and representations in the presence of Fulton County District
Attorney’s Office investigators:
of Trump presidential
and convened"
the December
That he
1.1. That
he "attended
“attended and
convened the
December 14,
14, 2020,
2020, meeting
meetingofTrump
presidential
each
of
the
he
did
not
"call
that
but
eachofthe
“call
not
elector nominees
Georgia, but that he did
County, Georgia,
Fulton County,
nominees inin Fulton
elector
other preparations
or make
make anyofthe
individual members
members and
notify them
themofthe
meeting or
and notify
of the meeting
individual
any of the other
preparations
for
the
necessary
meeting”;
necessary for the meeting";
Thataa court
2.2. That
court reporter
reporter was
was not
not present
present atat the
the December
December 14,
14, 2020,
Trump
2020, meetingof
meeting of Trump
elector nominees
presidential elector
nominees inin Fulton
Fulton County,
County, Georgia;
Georgia;
presidential
the jurisdiction of the Fulton
said
being within
within thejurisdictionofthe
Fulton County
District Attomey's
Attorney's Office,
said statements
statements being
Ofﬁce, aa
County District
an act
act of
was an
state. This
of the
of a countyofthis
department and
and agency
agency of
the government
government of
This was
of
county of this state.
department
act
in
overt
furtherance
of the
and
an
furtheranceofthe
in
act
under
O.C.G.A.
overt
an
and
16-14-3(S)(A)(xxii)
activity underO.C.G.A. §§ 16-14-3(5)(A)(xxii)
racketeering activity
racketeering
conspiracy.
conspiracy.
Act 159.
Act159.
POWELL made
least
KATHERINE POWELL
7th dayofMay
SIDNEY KATHERINE
On or
about the
On
or about
the 7th
made atat least
2022, SIDNEY
day of May 2022,
with the
sworn deposition
false statements
United
the United
statements and
and representations
deposition with
of the following
in aa sworn
one
following false
oneofthe
representations in
the
6th
Attack
on
to
States
HouseofRepresentatives
Select
Committee
to
Investigate
the
January
6th
Attack
on the
the
of
Select
Committee
States House
January
Investigate
Representatives
United
United States
States Capitol:
Capitol:
machines in
in
"didn't have
voting machines
That she
she “didn’t
have any
access voting
1.
efforts toto access
up” efforts
setting up"
really setting
role inin really
1. That
any role
or Antrim County,
Coffee
Coffee County,
County, Georgia,
Georgia,orAntrim
Michigan;
County, Michigan;
access to
some people" to get
That she
she was
an "effort by
2.2. That
was aware
aware there
there was
was
an“effort
by somepeople”to
get access
to voting
voting
that"
and
did not
with
what
machines inin Georgia
but
that
she
did
not
“know
what
happened
with
that”
and did
not
but
did
not
"know
machines
that
she
happened
Georgia
or other
"remember whether
that was
was Rudy
“remember
whether that
Rudy or
other folks."
folks.”
overt act
act in
of the conspiracy.
This was
‘This
was an
an overt
in furtherance
furtheranceofthe
conspiracy.
On or about the 25th day of April 2022, DAVID JAMES SHAF ER committed the
felony offense of FALSE STATEMENTS AND WRITINGS, in Violation of O.C.G.A. § 1610-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of
the following false statements and representations in the presence of Fulton County District
Attorney's Ofﬁce investigators:
'

Page 70 Act 160.
Act
160.
CATHLEEN ALSTON
ALSTON LATHAM
On
or about
about the
LATHAM
of September
On or
the 1st
It day
September 2022,
2022, CATHLEEN
day of
of O.C.G.A.
committed the
offense of PERJURY, in
commited
the felony
felony offenseofPERJURY,
in Violation
violationof
0.C.G.A. §§ 16-1070(a),
16-10-70(a), inin Houston
Houston
one of the following
and unlawfully
‘County,
by knowingly,
knowingly, willfully,
making atat least
least oneofthe
following
unlawfully making
County, Georgia,
Georgia, by
willfully, and
Case 1:17-cv-02989
false statements
statements ina
in a deposition
of Curling V.
in the matter
false
depositioninthe
matterofCurling
v. Raffensperger,
Raffensperger, Case
1:17-cv-02989a judicial proceeding,
AT in the
States District
Court for
ATin
the United
United States
District Court
for the
the Northern
Northern District
District of
of Georgia,
Georgia, ajudicial
proceeding,
been
after having
administered
a
lawful
oath:
after
been
administered
a
lawful
oath:
having
of Elections &
& Registration
l.
she was
Office
1. That
That she
was only
presentaat the
the Coffee
Coffee County
County Board
BoardofElections
Registration Office
only present
on
in
Coffee County,
few
minutes"
for
a
in Coffee
Georgia,
for
“justa
few
minutes”on
January
7,
2021;
January 7, 2021;
County, Georgia,
"just
of Elections&&
she only
of the Coffee
"walked into
front part" ofthe
2.2 That
That she
only “walked
into the
the frontpart”
Coffee County
BoardofElections
County Board
the office";
Oﬁice on
on January
Registration Office
January 7,7, 2021,
2021, and
and "didn't
“didn’t go
go into
into the
office”;
Registration
Eric Chaney
That shehad
she had “no
at the
Coffee
"no idea"
of SullivanStrickler
SullivanStrickler met
3.3 That
idea” ifif employees
employeesof
met Eric
the Coffee
Chaney at
Board
of
&
Oﬁice
on
Elections
County
BoardofElections
&
Registration
Office
on
January
7,
2021;
7,
January
County
Registration
That she
of Elections&
&
did not
see Misty
at the
4. That
she did
not see
Misty Hampton
the Coffee
Coffee County
BoardofElections
County Board
Hampton at
Oﬁice
on
Registration
7, 2021;
2021;
Registration Office on January
January 7,
Coffee County
Board of Elections &
&
That her
Scott Hall
5.5 That
her only
interaction with
with Scott
Hall atat the
the Coffee
County BoardofElections
only interaction
him outside
of the
Ofﬁce on
on January
Registration
January 7,7, 2021,
2021, was
was meeting
him, speaking
to him
outsideofthe
meeting him,
Registration Office
speaking to
and then
then leaving
office,
leaving the
the office;
office, and
office;
other thanherselfat
than herself at the
the Coffee
she did
Scott Hall
6.6 That
That she
did not
not see
see Scott
Hall speak
to anyone
Coffee County
anyone other
County
speak to
Board
of
Elections
on
&
Ofﬁce
Board of Elections & Registration
Registration Office on January
7, January 7,
statements being
said
accused's own
said statements
being material
material toto the
the accused’s
own involvement
involvement inin the
the January
7, 2021,
2021,
January 7,
of Elections &
& Registration
unlawful
breach of election equipment
Coffee County
unlawful breachofelection
at the
the Coffee
BoardofElections
County Board
Registration
equipment at
Oﬂice
and to
to the
the accused's
with others
communications with
Office and
accused's communications
others involved,
involved, the
the issues
issues inin question.
question. This
This
was an
act ofracketeering
of racketeering activity
and an
act in
O.C.G.A. §§ l6-l4-3(5)(A)(xxv)
‘was
an act
under O.C.G.A.
16-14-3(S)(A)(xxv) and
an overt
overt act
in
activity under
furtherance
of the conspiracy.
furtheranceofthe
conspiracy.
;
;
0

Page 71 Act
161.
Act161DAVID CHEELEY
CHEELEY
ROBERT DAVID
On or
or about
about the
2022, ROBERT
dayofof September
15th day
the 15th
On
September 2022,
Fulton
in Fulton
Violation of 0.C.G.A.
O.C.G.A. §§ 16-10-70(a),
committed
the felony
felony offense
offense of
PERJURY, inin violationof
16-10-70(w), in
of PERJURY,
committed the
one of the following
‘County,
Georgia, by
by knowingly,
willfully, and
and unlawfully
unlawfully making
making atat least
least oneofthe
following
County, Georgia,
knowingly, willfully,
Grand
a
proceeding,
false
statements before
Fulton County
the Fulton
before the
false statements
Jury, ajudicial
judicial proceeding,
Purpose Grand Jury,
County Special
Special Purpose
oath:
after having
after
having been
been administered
administered aa lawful
lawful oath:
elector
1.1. That
he was
unawareofthe
December 14,
14, 2020,
Trump presidential
presidential elector
That he
was unaware
of the December
2020, meetingof
meeting of Trump
the
had
taken
until
after
‘nominces
in Fulton
Georgia,
until
after
the
meeting
had
already
taken
place;
Fulton County,
nominees in
meeting
already
place;
County, Georgia,
December 14,
14,
the December
conversations with
concerning the
2.
That he
substantive conversations
with anyone
no substantive
had no
he had
2. That
anyone concerning
until
Georgia, until
elector nominees
Fulton County,
nominees inin Fulton
of Trump presidential
presidential elector
meetingofTrump
2020,
County, Georgia,
2020, meeting
after the
had already
after
the meeting
meeting had
taken place;
place;
already taken
elector nominees
3.
That he
3. That
he never
never suggested
suggested toto anyone
that the
the Trump
presidential elector
nominees inin
Trump presidential
anyone that
on
December
should meet
Georgia
meet on December 14,
2020;
14, 2020;
Georgia should
4.4. That
the only
only communication
he had
had with
with John
John Eastman
Eastman concerning
the November
November 3,3,
That the
communication he
concerning the
Senator
of connecting Eastman
Eastman toto Georgia
election was
purposeofconnecting
the purpose
for the
was for
2020,
Georgia Senator
2020, presidential
presidential election
to
known
Individual
whose
is
and unindicted
Brandon Beach
unindicted co-conspirator
Brandon
Beach and
Individual
8,
whose
identity
is
known
to
8,
identity
coconspirator
the
Grand Jury,
the Grand
Jury, for
for possible
possible legal
legal representation;
representation;
other than
with any
John Eastman
5.5. That
he never
never wo'rked
worked toto connect
Eastman with
legislators other
than
connect John
That he
any Georgia
Georgia legislators
Individual
whose
unindicted
and
Beach
Georgia
Senator
Brandon
Beach
and
unindicted
co-conspirator
Individual
8,
whose
Senator
Brandon
8,
co-conspirator
Georgia
the Grand
identity
is known
known toto the
Grand Jury;
Jury;
identity is
2020,
accused's own
14, 2020,
December 14,
the December
said statements
involvement inin the
own involvement
the accuseds
material toto the
statements being
said
being material
the accused's
accused's
in Fulton
and to
nominees in
10 the
of Trump
Fulton County,
elector nominees
presidential elector
County, Georgia,
meeting
Georgia, and
meeting of
Trump presidential
of
an
act of
the
issues
in
This
was
communications
with others
involved inin the
the meeting,
the
issues
in
question.
This
was
an
act
communications with
others involved
meeting,
question.
the
of
and
an
overt
act
in
furtherance
16-14-3(5)(A)(xxv)
O.C.G.A. §§ 1614-under O.C.G.A.
racketeering activity
(5)(A)(xxv) and an overt act in furtherance ofthe
racketeering
activity under
conspiracy.
conspiracy.
furtherance of the
committed in
“The
forth above
above were
were committed
in furtheranceof
the conspiracy
alleged above
above
The acts
acts set
set forth
conspiracy alleged
and methods
of commission
commission
methodsof
and had
had the
same and similar
accomplices, victims,
similar intents,
victims, and
thesameand
results, accomplices,
and
intents, results,
and were
acts
were interrelated
isolated acts.
not isolated
were not
and otherwise
otherwise were
interrelated by
characteristics and
distinguishing characteristics
by distinguishing
and

Page 72 COUNT 22 of
of COUNT
do
in the
and behalf
of the citizensofGeorgia,
citizens of Georgia, do
And the
the Grand
the name
name and
behalf
ofthe
And
Grand Jurors
Jurors aforesaid,
aforesaid, in
and accuse
accuse RUDOLPH
charge
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS GIULIANI,
GIULIANI, JOHN
JOHN CHARLES
CHARLES
charge and
of
and
RAY
with the
STALLINGS
SMITH
III
offense of
the offense
LYNN
IIT
JENNA LYNN ELLIS,
ELLIS, and RAY STALLINGS SMITH with
EASTMAN, JENNA
EASTMAN,
O.C.G.A. §§
OF OATH
SOLICITATION OF
VIOLATION OF
OATH BY
BY PUBLIC
PUBLIC OFFICER,
16-OF VIOLATION
SOLICITATION
OFFICER, O.C.G.A.
§§ 16-4-ofaa
in
commission
and
as
concerned
the
& 16-10-1,
for
the
said
accused,
individually
and
as
persons
concerned
in
the
commission
of
&
for
the
said
accused, individually
16-10-1,
persons
of
and State
crime,
and together
together with
with unindicted
unindicted co-conspirators,
co-conspirators, inin the
the CountyofFulton
State of
crime, and
County of Fulton and
and
importuned
December
and
0f
requested,
solicited,
on
the
3rd
unlawfully
2020,
dayofDecember
3rd
the
on
2020,
Georgia,
importuned
unlawfully solicited, requested,
day
Georgia,
of the Georgia
elected members
Senate andpresent
and present atat aa
certain
Georgia Senate
membersofthe
serving asas elected
then serving
officers then
public oﬂicers
certain public
Senate
unindicted co-conspirator
Individual 8,8,
Senate Judiciary
Subcommittee meeting,
including unindicted
meeting, including
co-conspirator Individual
Judiciary Subcommittee
Grand
Senators
Lee
Brandon
to
the
whose
is known
whose identity
known to the Grand Jury,
Jury, Senators Lee Anderson,
Anderson, Brandon Beach,
Beach, Matt
Matt Brass,
Brass,
identity is
William
Bill
Jen
F.
John
Steve
Greg
Dolezal,
Steve
Gooch,
Tyler
Harper,
Bill
Heath,
Jen
Jordan,
John
F.
Kennedy,
William
Heath,
Jordan,
Gooch,
Dolezal,
Kennedy,
Tyler
Harper,
Greg
Carden Summers,
Blake Tillery,
Ligon, Elena
Elena Parent,
Parent, Michael
Michael Rhett,
Rhett, Carden
Summers, and
and Blake
to engage
engage inin conduct
conduct
Tillery, to
Ligon,
O.C.G.A. §§ 16-10-1,
of Violation of Oath by
the felony
constituting
felony oﬂ'ense
offenseofViolationofOath
Public Officer,
16-10-1, by
Oﬂicer, 0.C.G.A.
by
by Public
constitutingthe
intentional
from
the
of
in
and
electors
State
willful
unlawfully
appointing
presidential
electors
from
the
State
ofGeorgia,
in
willful
and
intentional
Georgia,
unlawfully appointing presidential
said
of the termsofthe
terms of the oath
violation ofthe
violation
oath of
of said
said persons
persons asas prescribed
prescribed by
by law,
with intent
intent that
that said
law, with
to the
the
date
a
the
said
material
element
of
in
persons
engage
in
said
conduct,
said
date
being
a
material
elementofthe
offense,
contrary
said
oﬂ'ense,
conduct,
contrary to
being
persons engage
and dignity
laws
of said State,
lawsofsaid
the good
peace and
thereof;
order, peace
State, the
dignity thereof;
good order,
3 of COUNT 3of
COUNT
in the
name and
and behalf
of the citizensofGeorgia,
citizens of Georgia, do
Grand Jurors
Jurors aforesaid,
And the
theGrand
the name
behalf
ofthe
do
And
aforesaid, in
of
FALSE
LOUIS
GIULIANI
with
the
offense
WILLIAM
and
accuse
RUDOLPH
charge
and
accuse
RUDOLPH
WILLIAM
LOUIS
GIULIANI
with
the
offense
of
FALSE.
charge
O.C.G.A. §§ 16-10-20,
STATEMENTS AND
STATEMENTS
AND WRITINGS,
WRITINGS, 0.C.G.A.
16-10-20, for
for the
the said
said accused,
in the
the County
accused, in
County
willfully,
knowingly,
2020,
or about
about the
the 3rd
3rd day
of
December
of
on or
December
of Fulton
and StateofGeorgia,
State of Georgia, on
Fulton and
of
2020,
knowingly, willfully,
day
to
the
false
statements
one
of
and
and unlawfully
and
made atat least
least oneofthe following
following false statements and representations
representations to
unlawfully made
Senate
at
a
Subcommittee
Senate
‘membersofthe
Senate
present
at
a
Senate
Judiciary
Subcommittee
meeting:
members
of the Georgia
meeting:
present
Judiciary
Georgia
ballots were counted
counted in
in the
November 3,
1.
1. That
That atat least
least 96,mail-inballotswere
the November
3, 2020,
2020, presidential
presidential
96,600 mail-in
been
returned
no
record
of
those
there
ballots
election inin Georgia,
Georgia, despite
there
being
no
recordofthose
ballots
having
been
returned toto
election
being
having
despite
a
a county
elections ofﬁce;
office;
county elections
the November
2.2. That
That aa Dominion
Voting Systems
machine used
used inin the
November 3,3, 2020,
presidential
Dominion Voting
2020, presidential
Systems machine
in Antrim
Antrim County,
election
Michigan, mistakenly
mistakenly recorded
recorded 6,votes for
for Joseph
R.
election in
6,000 votes
Joseph R.
County, Michigan,
cast for
Donald Trump;
Biden
Biden when
when the
the votes
votes were
were actually
actually cast
for Donald
Trump;
of the Oﬂice
and
of the Georgia
within the
said
being within
the jurisdiction
jurisdictionofthe
Officeofthe
Georgia SecretaryofState
said statements
statements being
Secretary of State and
and
and
of
state
of Investigation,
the
the Georgia
Bureauof
Investigation, departments
agenciesofstate government,
county
departments and agencies
government, and county
Georgia Bureau
and
to
the
laws
of
said
the
and city
law
enforcement
and
law
enforcement
agencies,
contrary
to
the
lawsofsaid
State,
the
good
order,
peace
and
order,
State,
contrary
peace
good
agencies,
city
dignity
thereof;
dignity thereof;

Page 73 COUNT
0f COUNT 44 of
citizens of Georgia, do
in the
of the citizensofGeorgia,
do
And the Grand
ofthe
behalf
and behalf
name and
the name
aforesaid, in
Jurors aforesaid,
Grand Jurors
Andthe
STATEMENTS
of
FALSE
STATEMENTS
SMITH
III
with
the
offense
FALSE
of
RAY
STALLINGS
offense
the
with
accuse
III
SMITH
and
STALLINGS
RAY
accuse
and
charge
charge
of Fulton and
the County
said accused,
AND WRITINGS,
WRITINGS, O.C.G.A.
0.C.G.A. §§ 16-10-20,
16-10-20, for
for the
the said
in the
CountyofFulton
and
AND
accused, in
and
3rd day
about the
on or
2020, knowingly,
State of Georgia, on
December 2020,
of December
the 3rd
or about
willfully, and
StateofGeorgia,
knowingly, willfully,
day of
members
to
the
false
and
one
of
statements
of
members of
at
least
to
made
representations
and
statements
false
following
unlawfully made at least oneofthe following
representations
unlawfully
at aa Senate
Senate Judiciary
Subcommittee meeting:
Senate present
the
the Georgia
meeting:
Judiciary Subcommittee
present at
Georgia Senate
election in
the November
voted illegally
2,506 felons
felons voted
in the
November 3,3, 2020,
presidential election
in
l.1. That
That 2,2020, presidential
illegally in
Georgia;
Georgia;
seventeenth birthday
birthday
That 66,their seventeenth
before their
vote before
registered toto vote
illegally registered
people illegally
underage people
2. That
66,248 underage
election
in
November
priorto
the November 3,3, 2020,
2020, presidential
Georgia;
presidential election in Georgia;
prior to the
voted in
3.3 That
at least
least 2,people voted
in the
the November
November 3,3, 2020,
presidential election
election inin
That at
2020, presidential
2,423 people
listed as registered to
wh'o were
were not
‘Georgia
not listedasregistered
to vote;
vote;
Georgia who
who.
Georgia who
election inin Georgia
That 1,November 3,3, 2020,
the November
voted inin the
1,043 people
4. That
2020, presidential
presidential election
people voted
a
to
vote
ofﬁce
had
had illegally
registered
to
vote
using
a
post
office
box;
box;
using post
illegally registered
or more dead people
5. That
10,315 ormoredead
voted inin the
the November
November 3,3, 2020,
2020, presidential
presidential election
lection inin
That 10,people voted
Georgia;
Georgia;
and
watchers and
workers at
at State
6.6 That
State Farm
FarmArena
ordered poll
poll watchers
election workers
Arena ordered
Fulton County
That Fulton
County election
and
tabulation area
on the
of November 3,
‘membersofthe
media toto leave
leave the
the tabulation
area on
the night
nightofNovember
2020, and
of the media
members
3, 2020,
after
to
to
continued
continued to operate
operate afer ordering
everyone to leave;
leave;
ordering everyone
and
of State and
Office of the Georgia
said
statements being
said statements
being within
within the
thejurisdictionofthe
SecretaryofState
jurisdiction of the Officeofthe
Georgia Secretary
and agenciesofstate
of Investigation,
the Georgia
the
Georgia Bureau
Bureauof
Investigation, departments
and county
county
departments and
agencies of state goverment,
government, and
the
to
the
laws
of
said
and city
law
enforcement
‘and
law
enforcement
agencies,
contrary
to
the
lawsofsaid
State,
the
good
order,
peace
and
order,
State,
peace and
good
agencies, contrary
city
dignity
thereof;
dignity thereof;
'
7

Page 74 COUNT 5 of COUNTSof
Jurors aforesaid,
citizens of Georgia, do
And
Grand Jurors
in the
name and
and behalf
behalfofthe
of the citizensofGeorgia,
And the
the Grand
the name
do
aforesaid, in
OF
accuse
DONALD
JOHN
TRUMP
with
the
offense
of
SOLICITATION
and
charge
and
accuse
DONALD
JOHN
TRUMP
with
the
offense
ofSOLICITATION
OF
charge
OF OATH
OATH BY
for the
O.C.G.A. §§
VIOLATION
VIOLATION OF
BY PUBLIC
PUBLIC OFFICER,
OFFICER, 0.C.G.A.
164-7 && 16-10-1,
16-10-1,forthe
§§ 16-4-0f
in
the
of
Fulton
or
the
7th
and
State
of
on
about
said accused,
said
inthe
County
of
Fulton
and
State
of
Georgia,
on
or
about
the
7th
day
of
accused,
day
County
Georgia,
and importuned
December
December 2020,
unlawfully solicited,
requested, and
importuned Speakerof
the Georgia
Georgia House
House
2020, unlawfully
solicited, requested,
Speaker of the
the
in
conduct
David Ralston,
of Representatives David
ofRepresentatives
Ralston,aa public
public ofﬁcer,
officer, toto engage
in
conduct
constituting
the
felony
constituting
felony
engage
of Oath by
of Violation
O.C.G.A. §§ 16-10-1,
offense of
offense
ViolationofOath
Public Officer,
16-10-1, by
for aa special
Oﬁicer, 0.C.G.A.
by Public
by calling
calling for
special
General Assembly
for the
the purpose
of unlawfully appointing
session of the Georgia
sessionofthe
Georgia General
Assembly for
purposeofunlawfully
appointing presidential
presidential
of the oath
oath of
the
State
of
in
of
the terms
from
willful
and
intentional
Violation
electors
electors from the Stateof Georgia,
Georgia, in willful and intentional violationofthe
termsofthe
of
intent that
said
said person
person asas prescribed
by law,
law, with
with intent
that said
said person
person engage
engage inin said
said conduct,
to
conduct, contrary
contrary to
prescribed by
the
laws
of
said
and
the
the lawsofsaid State,
peace and dignity
dignity thereof;
thereof;
State, the good
order, peace
good order,
COUNT 66of
of COUNT
And
the Grand
Grand Jurors
Jurors aforesaid,
in the
of the citizensofGeorgia,
citizens of Georgia, do
do
name and
and behalf
behalfofthe
And the
the name
aforesaid, in
RAY
STALLINGS
and
accuse
RUDOLPH
WILLIAM
and
LOUIS
GIULIANI
charge
and
accuse
RUDOLPH
WILLIAM
LOUIS
GIULIANI
and
RAY
STALLINGS
charge
offense of
of SOLICITATION
OATH BY
SMITH
SOLICITATION OF
SMITH III
IIT with
with the
the offense
OF VIOLATION
VIOLATION OF
OF OATH
BY PUBLIC
PUBLIC
and
as
O.C.G.A.
16-4-&
for
the
said
OFFICER,
0.C.G.A.
§§
164-&
16-10-1,
for
the
said
accused,
individually
andaspersons
OFFICER,
16-10-1,
accused, individually
§§
persons
in the
commission of
concerned
with unindicted
concerned inin the
the commission
ofaa crime,
and together
together with
unindicted co-conspirators,
the.
crime, and
co-conspirators, in
and
State
of
of
Fulton
on
the
10th
0f
December
Countyof
Fultonand
StateofGeorgia,
on
the
10th
day
of
December
2020,
unlawfully
solicited,
2020,
solicited,
unlawfully
County
Georgia,
day
certain public
of the
oﬁicers then
as elected
elected members
requested, and
and importuned
public officers
then serving
membersof
the Georgia
Georgia
importuned certain
serving as
requested,
and present
Affairs Committee
Committee meeting,
of Representatives and
House
HouseofRepresentatives
present atat aa House
House Governmental
Governmental Affairs
meeting,
Shaw Blackmon,
including Representatives
Representatives Shaw
Blackmon, Jon
Jon Burns,
Barry Fleming,
Todd Jones,
Jones, Bee
Bee Nguyen,
Burns, Barry
Fleming, Todd
Nguyen,
including
and Bruce
Bruce
Scot Tumer,
Mary Margaret
Oliver, Alan
Alan Powell,
Powell, Renitta
Renitta Shannon,
Shannon, Robert
Robert Trammell,
Turner, and
Trammell, Scot
Margaret Oliver,
Mary
of
in
conduct
of
Violation
Oath
Public
to
the
offense
Williamson,
to
engage
in
conduct
constituting
the
felony
offenseof
Violation
of
Oath
by
Public
Williamson, engage
by
constituting
felony
the State
of
electors from
O.C.G.A. §§ 16101,
Officer, 0.C.G.A.
16-10-1, by
by unlawfully
unlawfully appointing
from the
State of
Oﬁicer,
appointing presidential
presidential electors
and
of
as
in
willful
intentional
violation
of
the
terms
of
the
oath
said
Georgia,
in
willful
and
intentional
violation
ofthe
termsofthe
oathofsaid
persons
as
prescribed
persons
prescribed
Georgia,
said date
date being
element of
of
with intent
said conduct,
by law,
law, with
intent that
that said
said persons
persons engage
in said
beingaa material
material element
conduct, said
by
engage in
and
to
the
laws
of
said
the
the offense,
the
contrary
to
the
lawsofsaid
State,
the
good
order,
peace
and
dignity
thereof;
thereof;
order,
offense, contrary
State,
dignity
good
peace

Page 75 7 of COUNT
COUNT 7of
And the Grand Jurors aforesaid, in the name and behalf
ofthe citizensofGeorgia, do
charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI with the offense of FALSE
said accused,
AND WRITINGS,
STATEMENTS
0.C.G.A. §§ 16-10-20,
16-10-20, for
for the
the said
in the
the County
STATEMENTS AND
accused, in
WRITINGS, O.C.G.A.
County
and StateofGeorgia,
State of Georgia, on
the 10th
10th day
of Fulton
Fulton and
on or
or about
of December
December 2020,
knowingly,
of
about the
2020, knowingly,
day of
at least one
made atleast
of the following
willfully,
and unlawfully
unlawfully made
oneofthe
following false
false statements
statements and
and representations
representations
willfully, and
at
a
House
Governmental
the
of
House of Representatives present
to
to members
membersofthe
Georgia HouseofRepresentatives
present at a House Governmental Affairs
Affairs
Georgia
Committee
Committee meeting:
meeting:
November 3,
l.
That it is quite
clear from
State Farm
Arena Video
1. Thatitis
from the
the State
Farm Arena
video from
from November
that
3, 2020,
2020, that
quite clear
ofﬁcials
and
that
were
Fulton County
election
votes
workers
were
Fulton
election
workers
were
stealing
votes
and
that
Georgia
officials
were
Georgia
County
stealing
covering
up aa crime
crime inin plain
covering up
sight;
plain sight;
ofﬁcials “got
rid of all of the
Democratic officials
the
That at
at State
State Farm
Farm Arena
2. That
Arena on
on November
November 3,3, 2020,
2020, Democratic
"got ridofallof
used
the
excuse
of
a
all
that
couldn't
be
the
reporters,
all
the
observers,
anyone
that
couldn’t
be
trusted,”
used
the
excuse
of
a
trusted,"
observers, anyone
reporters,
about their
"went about
crooked
cleared out
area and
and then
‘watermain break,
break, cleared
out the
the voting
voting area
then “went
their dirty,
watermain
dirty, crooked
business”;
business";
counted by
election
and 24,ballots were
were illegally
3.3 That
That between
between 12,12,000 and
by Fulton
Fulton County
24,000 ballots
County election
illegally counted
workers
Farm
Arena
on
November
workers atat State
State Farm Arena on November 3,3, 2020;
2020;
than were sent
sent out
out to
counted thanwere
there were
4.4 That
That inin Michigan,
Michigan, there
were 700,700,000 more
more ballots
ballots counted
to voters
voters
accounted for
in the November
which was
inthe
November 3,3, 2020,
was accounted
for by
by quadruple
election, which
2020, presidential
quadruple
presidential election,
counting
ballots;
counting ballots;
were “quite
That Ruby
5.5 That
Ruby Freeman,
Freeman, Shaye
Shaye Moss,
and an
an unidentified
unidentified man
man were
Moss, and
"quite obviously
obviously
of
or
vials
heroin
cocaine"
USB
as
if
surreptitiously
passing
around
USB
ports
as
if
t
heyre
vials
of
heroin
or
cocaine” atat State
State
around
surreptitiously passing
ports
they're
Farm
"inﬁltrate the
Farm Arena
Arena toto be
be used
used toto “infiltrate
the crooked
crooked Dominion
Dominion voting
machines";
voting machines”;
in the
election
That 96,mailin ballots
were counted
counted in
6.6 That
ballots were
the November
November 3,3, 2020,
2020, presidential
96,600 mail-in
presidential election
been
ballots
returned
to
in
there
no
record
of
those
in Georgia,
despite
there
being
no
record
of
those
ballots
having
been
returned
to
aa
having
Georgia, despite
being
elections office;
county
office;
county elections
Office of the Georgia
the jurisdiction of the Officeofthe
said
statements being
being within
within thejurisdictionofthe
Georgia SecretaryofState
and
said statements
Secretary of State and
and county
of Investigation,
and agenciesofstate
the
the Georgia
Bureau of
Investigation, departments
goverment, and
agencies of state government,
county
Georgia Bureau
departments and
the
to
the
laws
of
said
and
law
enforcement
and
and city
law
enforcement
agencies,
contrary
to
the
lawsof
said
State,
the
good
order,
peace
State,
good order, peace and
agencies, contrary
city
dignity
thereof;
dignity thereof;
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI with the offense of FALSE

Page 76 COUNT 8 of COUNTSofof the citizensofGeorgia,
citizens of Georgia, do
and behalf
do
And
the Grand
ofthe
behalf
name and
the name
in the
Jurors aforesaid,
Grand Jurors
And the
aforesaid, in
TRESHER STILL,
SHAWN MICAH
and accuse
accuse DAVID
SHAFER, SHAWN
charge
MICAH TRESHER
and
DAVID JAMES
JAMES SHAFER,
STILL, and
charge and
PUBLIC
of IMPERSONATING A
offense ofIMPERSONATING
LATHAM with
CATHLEEN ALSTON
ALSTON LATHAM
with the
the offense
A PUBLIC
CATHLEEN
and as
concerned in
as persons
the said
O.C.G.A. §§ 16-10-23,
OFFICER, 0.C.G.A.
16-10-23, for
for the
said accused,
individually and
persons concerned
in
accused, individually
OFFICER,
Fulton
in
the
of
with
unindicted
CountyofFulton
a
the
in
the
commission
of
and
co-conspirators,
unindicted
with
together
and
crime,
the commission of a crime, together
County
co-conspirators,
of December
held
falsely held
and StateofGeorgia,
State of Georgia, on
on or
or about
unlawfully falsely
2020, unlawfully
December 2020,
14th day
the 14th
about the
‘and
day of
electors
from
the
State
of
themselves out
the duly
elected
and
qualified
presidential
electors
from
the
Stateof
Georgia,
as the
elected
and
themselves
out as
Georgia,
duly
qualiﬁed presidential
of
the United
‘public
with intent
intent toto mislead
mislead the
the President
President of
ofthe
United States
States Senate,
Senate, the
the Archivist
Archivist of
ofﬁcers, with
public officers,
Chief Judgeofthe
United States
States
the Georgia
the
Georgia SecretaryofState,
and the
theChief
the United
United States,
Judge of the United
States, the
Secretary of State, and
that
were
such
into
District
of
District Court
for the
the Norther
Northern DistrictofGeorgia
District
Court for
they actually
believing that they
actually were such
Georgia into believing
document titled
titled “CERTIFICATE
"CERTIFICATE
mail to
ofﬁcers
officers by
by placing
placing inin the
the United
United States
States mail
to said
said persons
persons aadocument
to
laws of said
FROM
THE
VOTES
OF
THE
ELECTORS
OF
OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,”
the lawsofsaid
GEORGIA," contrary
contrary to the
and dignity
State, the
the good
peace and
thereof;
State,
order, peace
good order,
dignity thereof;
of COUNT 99of
COUNT
do
of the citizensofGeorgia,
citizens of Georgia, do
and behalf
And
Grand Jurors
Jurors aforesaid,
ofthe
behalf
name and
the name
aforesaid, inin the
the Grand
And the
WILLIAM
LOUIS
RUDOLPH
charge
and
accuse
DONALD
JOHN
TRUMP,
RUDOLPH
WILLIAM
LOUIS
GIULIANI,
GIULIANI,
charge and accuse DONALD JOHN TRUMP,
RAY STALLINGS
STALLINGS
JOHN CHARLES
CHARLES EASTMAN,
EASTMAN, KENNETH
KENNETH JOHN
JOHN CHESEBRO,
JOHN
CHESEBRO, RAY
of
with the
the offense
and MICHAEL
DAVID CHEELEY,
SMITH
III, ROBERT
ROBERT DAVID
MICHAEL A.
A. ROMAN
ROMAN with
offense of
SMITH III,
CHEELEY, and
O.C.G.A. §§
A PUBLIC
IMPERSONATING A
TO COMMIT
CONSPIRACY
COMMIT IMPERSONATING
PUBLIC OFFICER,
§§
CONSPIRACY TO
OFFICER, 0.C.G.A.
as
concerned
in
the
and
for
the
said
16-4-16-4-8 && 16-10-23,
for
the
said
accused,
individually
and
as
persons
concemed
in
the
accused, individually
16-10-23,
persons
and unindicted
commission of
ofaa crime,
and together
commission
crime, and
together with
with indicted
indicted and
unindicted co-conspirators,
in the
the County
County
co-conspirators, in
December
and
the
14th
the 6th
of
of
Fulton and
between the
6th day
of
December
and
the
14th
and StateofGeorgie,
State of Georgia, on
on and
and between
of Fulton
day
cause certain
certain individuals
hold
dayofDecember
unlawfully conspired
to cause
individuals toto falsely
falsely hold
2020, unlawfully
conspired to
day of December 2020,
electors from
of Georgia,
themselves out
out asas the
and qualified
presidential electors
from the
the State
Stateof
the duly
elected and
themselves
Georgia,
qualiﬁed presidential
duly elected
the
Archivist
of
of
the
United
States
President
public officers,
with intent
intent toto mislead
mislead the
the Presidentofthe United States Senate,
Senate, the Archivist of
ofﬁcers, with
public
Chief Judge
of the United
United States
States
and the
of State, and
the
the United
United States,
States, the
the Georgia
SecretaryofState,
theChief
Judgeofthe
Georgia Secretary
that
were
into
of
Court
for
the
Northern
District
District
District Court for the Norther Districtof Georgia
believing that they
they actually
such
actually were such
Georgia into believing
officers;
ofﬁcers;
as co-conspirators,
as described
described above
above and
and
the Defendants
Count 8,
And the
And
Defendants named
named inin Count
actingas
8, acting
co-conspirators, as
held themselves
out as
said public
set forth
incorporated by
by reference
reference as
if fully
fully set
forth herein,
falsely held
themselves out
as said
public
as if
herein, falsely
incorporated
a
document
titled
"CERTIFICATE
mail
to
said
in
States
ofﬁcers by
the
United
officers
by placing
in
the
United
States
mail
to
said
persons
a
document
titled
“CERTIFICATE
persons
placing
GEORGIA" in
Georgia,
2020 ELECTORS
OF THE
THE VOTES
THE Fulton County,
in Fulton
FROM GEORGIA”
ELECTORS FROM
OF THE
VOTES OF
OF
County, Georgia,
to
the
laws
of
said
of the conspiracy,
overt act
act to
the object
‘which
was an
an overt
to effect
effect the
objectofthe
contrary
to
the
lawsofsaid
State,
which was
State,
conspiracy, contrary
and dignity
the
the good
peace and
thereof;
order, peace
good order,
dignity thereof;

Page 77 COUNT
COUNT
of 10 ofdo
of the citizens
citizens of
Georgia, do
of Georgia,
Jurors aforesaid,
ofthe
behalf
and behalf
And the
the Grand
name and
the name
in the
Grand Jurors
And
aforesaid, in
and
SHAWN MICAH
chargeandaccuse
DAVID JAMES
MICAH TRESHER
TRESHER STILL,
SHAFER, SHAWN
JAMES SHAFER,
STILL, and
charge and accuse DAVID
FIRST
of.
FORGERY
IN
THE
the
offense
with
CATHLEEN
ALSTON
LATHAM
with
the
offense
of
FORGERY
IN
THE
FIRST
LATHAM
CATHLEEN ALSTON
DEGREE, 0.C.G.A.
for the
the said
said accused,
and asas persons
concerned inin
O.C.G.A. §§ 16-9-1(b),
accused, individually
individually and
persons concerned
DEGREE,
16-9-1(b), for
unindicted
in
the
Fulton
with
Countyof
the
in
a
and
co-conspirators,
unindicted
the
commission
of
with
together
and
the commissionofa crime,
County of Fulton
crime,
co-conspirators,
together
with the
and with
of December
the
about the
unlawfully and
2020, unlawfully
and
State of Georgia,
on or
or about
December 2020,
14th day
the 14th
and Stateof
day of
Georgia, on
OF
THE
THE
VOTES
titled
"CERTIFICATE
OF
document
OF THE
made
a
VOTES
to
THE
OF
intent
“CERTIFICATE
titled
document
a
knowinglymade
intentto defraud,
defraud, knowingly
the
that
such manner
manner that the
a writing other
other than
2020 ELECTORS
in such
than aa check,
check, in
FROM GEORGIA,”
GEORGIA," awriting
ELECTORS FROM
and
of
the
elected
made
have
been
writingas
made
purports
tohavebeen
made
by
authorityofthe
duly
elected
and
qualified
as
to
made
qualiﬁed
by authority
duly
writing
purports
and
and
did
not
who
such
State of Georgia, who did not give
presidential
from the
the StateofGeorgia,
authority, and uttered
uttered and
electors from
give such authority,
presidential electors
of said State,
United States,
of the United
delivered
to the
State,
States, contrary
delivered said
said document
document to
the Archivist
Archivistofthe
contrary toto the
the laws
lawsofsaid
and
the good
the
good order,
thereof;
order, peace
dignity thereof;
peace and dignity
0f COUNT COUNT
11 of
do
of the citizensof
name and
and behalf
citizens of Georgia,
And
Grand Jurors
Jurors aforesaid,
And the
the Grand
aforesaid, inin the
the name
behalf
ofthe
Georgia, do
LOUIS GIULIANI,
and accuse
accuse DONALD
charge
DONALD JOHN
JOHN TRUMP,
TRUMP, RUDOLPH
RUDOLPH WILLIAM
WILLIAM LOUIS
GIULIANI,
charge and
RAY
STALLINGS
JOHN
JOHN CHESEBRO,
KENNETH JOHN
CHESEBRO, RAY STALLINGS
CHARLES EASTMAN,
JOHN CHARLES
EASTMAN, KENNETH
offense of
of
the offense
with the
SMITH III,
ROMAN with
A. ROMAN
MICHAEL A.
and MICHAEL
DAVID CHEELEY,
ROBERT DAVID
III, ROBERT
CHEELEY, and
SMITH
16-4-IN
THE
FIRST
O.C.G.A.
CONSPIRACY
TO
COMMIT
FORGERY
IN
THE
FIRST
DEGREE,
0.C.G.A.
§§
164-CONSPIRACY TO COMMIT FORGERY
DEGREE,
§§
commission ofa a
and as
as persons
concerned in
&& 16-91(b),
16-9-1(b), for
for the
the said
accused, individually
individually and
persons concerned
in the
the commissionof
said accused,
and unindicted
and together
with indicted
crime,
together with
indicted and
unindicted co-conspirators,
in the
the County
County of
of Fulton
Fulton and
and
crime, and
co-conspirators, in
of
and the
and between
State
of Georgia, on
on and
StateofGeorgia,
between the
the 6th
6th dayofDecember
2020 and
the 14th
14th day
day of
day of December make
the
intent
to
to
aa
with
make
knowingly
to
December
defraud,
to
intent
the
with
conspired,
unlawfully conspired,
2020, unlawfully
defraud,
December 2020,
knowingly
THE 2020 ELECTORS
document
titled "CERTIFICATE
“CERTIFICATE OF
OF THE
VOTES OF
OF THE
ELECTORS FROM
FROM
THE VOTES
document titled
the
as
made
in
such
manner
that
a
a
other
than
purports toto
made
as
writing
the
that
manner
such
in
check,
a
than
writing other
check,
GEORGIA,”
writing
purports
GEORGIA," a writing
State
electors
from
have been
been made
made by
by authorityofthe
elected and
and qualified
presidential electors from the
the State
have
qualiﬁed presidential
duly elected
authority of the duly
to utter
and deliver
deliver said
document to
such authority,
of Georgia,
did not
of
who did
not give
and to
utter and
said document
to the
the
authority, and
Georgia, who
give such
Archivist
Archivist of
of the
the United
United States;
States;
above
as co-conspirators,
as described
described above
named in
And
the Defendants
Defendants named
And the
in Count
Count 10,
10, acting
acting as
co-conspirators, as
set forth
document in
‘and
incorporated by
by reference
reference
asiffully
forth herein,
made said
said document
in Fulton
Fulton County,
as if ﬁilly set
and incorporated
herein, made
County,
in
Fulton
to
the
Archivist
of
the
United
States
document
said
Georgia,
and
uttered
and
delivered
said
document
to
the
Archivist
of
the
United
States
in
Fulton
uttered
and
delivered
and
Georgia,
the
to
the
of
the
the
to
to
effect
contrary
overt acts effect the object
conspiracy, contrary
objectofthe conspiracy,
were overtactsto
which were
Georgia, which
‘County,
County, Georgia,
and
laws
of said State,
lawsofsaid
the good
order,
peace
and
dignity
thereof;
thereof;
order,
State, the
dignity
good
peace
kd

Page 78 COUNT
12 of
0f COUNT the name
name and
and behalf
citizens of Georgia, do
of the citizensofGeorgia,
Grand Jurors
And the
the Grand
Jurors aforesaid,
aforesaid, inin the
behalf
ofthe
do
And
and
SHAF
SHAWN
TRESHER
MICAH
JAMES
and
accuse
DAVID
charge
and
accuse
DAVID
JAMES
SHAFER,
SHAWN
MICAH
TRESHER
STILL,
and
STILL,
ER,
charge
the offense
of FALSE
offense of
FALSE STATEMENTS
STATEMENTS AND
AND
CATHLEEN
with the
LATHAM with
ALSTON LATHAM
CATHLEEN ALSTON
concerned
for
the
said
and
as
WRITINGS,
0.C.G.A.
§
16-10-20,forthe
said
accused,
individually
and
as
persons
O.C.G.A.
16-10-20,
accused,
WRITINGS,
individually
persons concerned
§
in
With
the
and
unindicted
in the
the commission
commission of
ofaa crime,
crime, and together
together with unindicted co-conspirators,
co-conspirators, in the County
of
in
County of
about the
or about
State of Georgia, on
Fulton and
and StateofGeorgia,
on or
the 14th
14th dayofDecember
knowingly, willfully,
willfully,
Fulton
2020, knowingly,
day of December 2020,
THE VOTES
"CERTIFICATE OF
OF THE
and
made and
and unlawfully
unlawfully made
and used
used aa false
false document
document titled
titled “CERTIFICATE
VOTES OF
OF
contained the
that said
said document
THE 2020 ELECTORS
THE
ELECTORS FROM
FROM GEORGIA,”
with knowledge
document contained
the
GEORGIA," with
knowledge that
Electors
for
the
elected
and
THE
false
false statement,
statement, “WE,
THE
UNDERSIGNED,
being
the
duly
elected
and
qualified
Electors
for
UNDERSIGNED, being
"WE,
duly
qualiﬁed
do
States of
of America
of the United
United States
from the
State of Georgia,
President
and Vice
President and
Vice President
Presidentofthe
America from
the Stateof
Georgia, do
the
of
document
within
of
the
Ofﬁce
said
the
the
hereby
certify
the
following,”
said
document
being
within
the
jurisdictionofthe
Officeof
the
being
following,"
jurisdiction
hereby certify
and agencies
Ofﬁce of
Governor of
of Georgia,
Georgia SecretaryofState
and the
the Office
of the
the Governor
Georgia, departments
agencies
departments and
Georgia
Secretary of State and
the
laws
of
said
the
and
to
ofof state
contrary
to
the
lawsofsaid
State,
the
good
order,
peace
and
dignity
thereof;
state government,
State,
dignity thereof;
good order, peace
government, contrary
COUNT 0f COUNT
13of
do
the name
citizens of Georgia,
of the citizensof
And
the Grand
Grand Jurors
Andthe
Jurors aforesaid,
inthe
name and
and behalf
behalf
ofthe
aforesaid, in
Georgia, do
RUDOLPH WILLIAM
and accuse
accuse DONALD
charge
DONALD JOHN
JOHN TRUMP,
TRUMP, RUDOLPH
WILLIAM LOUIS
LOUIS GIULIANI,
GIULIANI,
charge and
GS
JOHN
RAY
STALLIN
KENNETH
JOHN
CHARLES
JOHN CHARLES EASTMAN,
EASTMAN, KENNETH JOHN CHESEBRO,
CHESEBRO, RAY STALLINGS
offense of
of
SMITH III,
ROBERT DAVID
SMITH
III, ROBERT
DAVID CHEELEY,
and MICHAEL
MICHAEL A.
A. ROMAN
ROMAN with
with the
the offense
CHEELEY, and
O.C.G.A. §§
COMMIT FALSE
STATEMENTS AND
TO COMMIT
CONSPIRACY
FALSE STATEMENTS
AND WRITINGS,
WRITINGS, O.C.G.A.
16CONSPIRACY TO
§§ 16
and as
in the
as persons
concerned in
said accused,
4-8 &
& 16-10-20,
16-10-20, for
for the
the said
individually and
the commission
commission
accused, individually
persons concermed
indicted
and
unindicted
in
the
ofaa crime,
and
with
of
and
together
with
indictedand
unindicted
co-conspirators,
in
the
CountyofFulton
crime,
County of Fulton
together
co-conspirators,
of
the
6th
of
14th day
and the
and State
State of
of Georgia,
and
on and
and between
between the 6th day
December 2020 and
the 14th
day of
day of December
Georgia, on
December
December 2020,
2020, unlawfully
unlawfully conspired
conspired toto knowingly
knowingly and
and willfully
willfully make
make and
and use
use aa false
false
THE
FROM
OF
VOTES
OF
THE
ELECTORS
"CERTIFICATE
document
document titled
titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM
THE
said document
document contained
with knowledge
GEORGIA,”
knowledge that
that said
contained the
the false
false statement,
"WE, THE
statement, “WE,
GEORGIA," with
and
Vice
President
elected
Electors
for
President
and
the
UNDERSIGNED,
being
the
duly
elected
and
qualified
Electors
for
President
and
Vice
President
UNDERSIGNED, being
duly
qualiﬁed
said
from the State
States of
of America
ofthe
United States
Americafromthe
Stateofof Georgia,
do hereby
hereby certify
the following,"
following,” said
of the United
Georgia, do
certify the
the
State
and
of
the
the
Ofﬁce
of
the
and
State
of
of
Secretary
the
Georgia
t
he
of
document
Office
within
jurisdictionofthe
the
being within jurisdiction
document being
Georgia Secretary
and agencies
state government;
of Georgia,
Ofﬁce of the Governor
Officeofthe
Governor of
Georgia, departments
of state
agencies of
departments and
government;
above
Count 12,
as co-conspirators,
as described
described above
And the
And
the Defendants
Defendants named
named inin Count
co-conspirators, as
12, acting
acting as
in Fulton
document in
if fully set
and used
said document
and
by reference
reference asas iffully
set forth
forth herein,
made and
used said
Fulton
and incorporated
herein, made
incorporated by
to
the
to
effect
the
were
overt
acts
of
the
which
County,
Georgia,
which
were
overt
acts
to
effect
the
objectofthe
conspiracy,
contrary
to
the
object
conspiracy, contrary
County, Georgia,
and dignity
laws of said State,
lawsofsaid
the good
dignity thereof;
thereof;
order, peace
State, the
good order,
peace and

Page 79 COUNT 14 of
of COUNT
do
citizens of Georgia, do
of the citizensofGeorgia,
the name
And the
the Grand
aforesaid, inin the
name and
and behalf
behalf
ofthe
Jurors aforesaid,
Grand Jurors
And
and
TRESHER STILL,
JAMES SHAFER,
MICAH TRESHER
SHAWN MICAH
and accuse
DAVID JAMES
STILL, and
accuse DAVID
charge and
SHAFER, SHAWN
charge
TO
ATTEMPT
with the
offense ofCRIMINAL
of CRIMINAL ATTEMPT TO
CATHLEEN ALSTON
ALSTON LATHAM
LATHAM with
the offense
CATHLEEN
the
for the
O.C.G.A. §§
16-10-20.1(B)(1), for
164-1 && 16-10-20.1(b)(1),
§§ 164-COMMIT
DOCUMENTS, 0.C.G.A.
FALSE DOCUMENTS,
FILING FALSE
COMMIT FILING
and
a
of
as
concerned
in
the
commission
together
and as persons
said
persons concerned in the commission ofa crime,
crime, and together
said accused,
accused; individually
individually and
on
about the
of
the
in
the
of
Fulton
and
State
or about
on or
StateofGeorgia,
and
with
Fulton
of
County
the
in
unindicted co-conspirators,
with unindicted
Georgia,
County
co-conspirators,
False
of
the
crime
with
intent
to
commit
False
14th day
unlawfully, with intent to commit the crimeofFiling
December 2020,
of December
Filing
14th
2020, unlawfully,
day of
document titled
in the
United States
States mail
Documents, 0.C.G.A.
16-10-20.1(b)(1, placed
placed in
the United
mailaa document
titled
O.C.G.A. §§ 16-10-20.l(b)(1),
Documents,
addressed
FROM
VOTES
OF
THE
ELECTORS
OF
THE
addressed
"CERTIFICATE
GEORGIA,"
“CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,”
2188 Richard
Northern District
District ofGeorgia,
of Georgia, toChiefJudge,
U.S. District
District Court,
Court, Northern
Richard D.
D. Russell
Russell
to
Chief Judge, U.S.
GA
30303,
GA
and
U.S.
Ted
Turner
Atlanta,
SW,
Drive,
Turner
Ofﬁce
Ted
Federal
Courthouse,
U.S.
30303, aa
and
Federal Office Building
Drive, SW, Atlanta,
Courthouse,
Building
O.C.G.A. §§ 16-10-20.1()(1),
of Filing False
Documents, 0.C.G.A.
False Documents,
substantial
commissionofFiling
the commission
toward the
step toward
substantial step
1610-20.1(b)(1),
the
United
a
court
of
and
record
said
document
in
to
intent
with
States,
‘with intent to knowingly
knowingly ﬁle,
file, enter,andrecord
said document ina courtofthe United States,
enter,
THE
that said
false statement,
the materially
contained the
statement, “WE,
"WE, THE
document contained
said document
know that
reason toto know
having reason
materially false
having
and Vice
and qualified
the duly
elected and
President
Vice President
President and
for President
Electors for
duly elected
being the
UNDERSIGNED, being
UNDERSIGNED,
qualiﬁed Electors
the
State of Georgia,
States of America from
following,”
certify the following,"
United StatesofAmerica
hereby certify
do hereby
of the United
the Stateof
from the
ofthe
Georgia, do
the
of
said
and
to
the
laws
contrary
to
the
lawsofsaid
State,
the
good
order,
peace
and
dignity
thereof;
thereof;
State,
order,
good
peace
dignity
contrary
COUNT of COUNT
15of
do
of the citizensofGeorgia,
citizens of Georgia, do
Jurors aforesaid,
Grand Jurors
And
And the
the Grand
in the
the name
name and
and behalf
behalfofthe
aforesaid, in
JOHN TRUMP,
RUDOLPH WILLIAM
LOUIS GIULIANI,
accuse DONALD
WILLIAM LOUIS
GIULIANI,
DONALD JOHN
and accuse
charge and
TRUMP, RUDOLPH
charge
RAY
STALLINGS
JOHN
KENNETH
STALLINGS
CHARLES
RAY
JOHN
CHESEBRO,
JOHN
EASTMAN, KENNETH
CHESEBRO,
JOHN CHARLES EASTMAN,
of
offense of
and MICHAEL
A. ROMAN
the offense
with the
ROMAN with
SMITH III,
MICHAEL A.
DAVID CHEELEY,
ROBERT DAVID
CHEELEY, and
III, ROBERT
SMITH
16O.C.G.A. §§
FILING FALSE
CONSPIRACY
COMMIT FILING
FALSE DOCUMENTS,
DOCUMENTS, O.C.G.A.
§§ 16-416-4-8 && 16T0 COMMIT
CONSPIRACYTO
of
and as
as persons
concerned in
said accused,
10-20.1(b)(1), for
for the
the said
individually and
persons concerned
in the
the commission
commission of
accused, individually
10-20.1(b)(1),
of Fulton
and
the County
and unindicted
indicted and
unindicted co-conspirators,
together with
with indicted
in the
Fulton and
aa crime,
and together
County of
crime, and
co-conspirators, in
14th
of
and
the
between the
6th day
of December 2020 and the 1th day
and between
State of Georgia, on
StateofGeorgia,
on and
the 6th
dayofDecember
day of
titled
document
a
to
and
record
titled
document
a
record
and
enter,
file,
December
knowingly
to
conspired
enter,
December 2020,
ﬁle,
2020, unlawfully
unlawfully conspired knowingly
in
FROM
THE
ELECTORS
OF
of
OF
THE
VOTES
court of
GEORGIA,” in aa court
"CERTIFICATE
“CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,"
that said
said document
contained the
false
materially false
the materially
the
document contained
know that
reason toto know
having reason
United States,
the United
States, having
Electors
for
the
elected
and
THE
statement,
“WE,
THE
UNDERSIGNED,
being
the
duly
elected
and
qualified
Electors
for
UNDERSIGNED, being
statement, "WE,
duly
qualiﬁed
State of Georgia,
of the United
of America from
Vice President
President and
and Vice
Presidentofthe
United States
States ofAmerica
from the
the Stateof
do
President
Georgia, do
the
hereby
certify
the
following”;
following";
hereby certify
as described
described above
Count 14,
the Defendants
Defendants named
And
And the
named inin Count
14, acting
acting asas co-conspirators,
above
co-conspirators, as
States mail
said
as if fully set
and incorporated
‘and
incorporated by
by reference
reference
asiffully
set forth
forth herein,
herein, placed
placed inin the
the United
United States
mail said
of Georgia, Chief Judge, U.S.
U.S. District
District Court,
addressed to
document,
toChiefJudge,
Court, Northern
Northern District
District ofGeorgia,
document, addressed
Ted
Turner
Ofﬁce Building
Federal Office
Richard D.
Richard
D. Russell
Russell Federal
Building and
and U.S.
U.S. Courthouse,
Ted
Turner
Drive,
SW,
Drive, SW,
Courthouse,
of the
to effect
effect the
act o
Fulton County,
an overt act
Atlanta, GA
GA 30303,
30303, inin Fulton
Georgia, which
which was
wasanovert
the object
objectofthe
Atlanta,
County, Georgia,
of
said
the
and
to
the
laws
conspiracy,
contrary
to
the
lawsofsaid
State,
the
good
order,
peace
and
dignity
thereof;
State,
dignity thereof;
good order, peace
conspiracy, contrary

Page 80 COUNT
of COUNT l16 of
ofthe citizensofGeorgia, do
And the Grand Jurors aforesaid, in the name and behalf
TRESHER STILL with
MICAH
SHAWN
and
SHAFER
charge and accuse DAVID JAMES
the offense of FORGERY IN THE FIRST DEGREE, 0.C.G.A. § 16-9-1(b), for the said
accused, individually and as persons concerned in the commission ofa crime, and together with
unindicted co-conspirators, in the Countyof Fulton and StateofGeorgia, on or about the 14th
dayofDecember 2020, unlawfully and with the intent to defraud, knowingly made adocument
titled “RE: NoticeofFillingof Electoral College Vacancy,” a writing other than a check, in such
manner that the writing as made purports to have been made by the authorityofthe duly elected
and qualified presidential electors from the StateofGeorgia, who did not give such authority,
and uttered and delivered said document to the Archivistofthe United States and the Office of
the Governorof Georgia, contrary to the lawsofsaid State, the good order, peace and dignity
thereof;
thereof;
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
accuse DAVID JAMES SHAFER and SHAWN MICAH TRESHER STILL with
and
charge
the offense of FORGERY IN THE FIRST DEGREE, O.C.G.A. § 16-9-1(b), for the said
accused, individually and as persons concerned in the commission of a crime, and together with
unindicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 14th
day of December 2020, unlawfully and with the intent to defraud, knowingly made a document
titled "RE: Notice of Filling of Electoral College Vacancy," a writing other than a check, in such
manner that the writing as made purports to have been made by the authority of the duly elected
and qualified presidential electors from the State of Georgia, who did not give such authority,
and uttered and delivered said document to the Archivist of the United States and the Ofﬁce of
the Governor of Georgia, contrary to the laws of said State, the good order, peace and dignity
COUNT
of COUNT 17of
And the Grand Jurors aforesaid, in the name and behalf
ofthe citizensofGeorgia, do
and accuse
accuse DONALD
charge
DONALD JOHN
JOHN TRUMP,
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS GIULIANI,
GIULIANI,
TRUMP, RUDOLPH
charge and
STALLINGS
JOHN CHESEBRO,
CHARLES EASTMAN,
JOHN CHARLES
JOHN
EASTMAN, KENNETH
KENNETH JOHN
CHESEBRO, RAY
RAY STALLINGS
with the
offense of
A. ROMAN
of
the offense
ROMAN with
SMITH III,
MICHAEL A.
and MICHAEL
DAVID CHEELEY,
ROBERT DAVID
III, ROBERT
SMITH
CHEELEY, and
O.C.G.A. §§
TO COMMIT
IN THE
THE FIRST
16-4-CONSPIRACY
DEGREE, 0.C.G.A.
FIRST DEGREE,
FORGERY IN
COMMIT FORGERY
§§ 16-4-CONSPIRACY TO
commission of
of aa
concerned in
and as
as persons
said accused,
& 16-9-1(b),
169-1(b), for
for the
the said
accused, individually
individually and
persons concemed
in the
the commission
&
Fulton and
and
indicted and
and nindicted
unindicted co-conspirators,
with indicted
crime,
co-conspirators, inin the
the County
County ofof Fulton
and together
crime, and
together with
14th
of
and
the
on and
and between
the 6th
of
December
StateofGeorgia,
between the
6th day
of
December
and
the
14th
day
of
State
of Georgia, on
day
day
intent to
with the
December
unlawfully conspired,
conspired, with
the intent
to defraud,
defraud, toto knowingly
make aa
December 2020,
knowingly make
2020, unlawfully
a
other than
of Filling of
titled "RE:
document titled
document
“RE: Notice
NoticeofFilling
of Electoral
Electoral College
College Vacancy,”
a
writing
than aa
Vacancy," writing other
the authority
been made by the
have beenmadeby
that the
such manner
check,
in such
manner that
the writing
writing asas made
made purports
purports toto have
authority of
of
check, in
did
not
who
State
of
electors
from
the
the duly
elected
and
qualified
presidential
electors
from
the
StateofGeorgia,
who
did
not
give
elected
and
the
Georgia,
give
qualiﬁed presidential
duly
States and
and
the Archivistofthe
Archivist of the United
utter and
and deliver
deliver said
said document
United States
such authority,
document toto the
and toto utter
authority, and
such
Governor "of
the
Ofﬁce of the
the Officeof
the Govemor
of Georgia;
Georgia;
as described
described above
above
named in
in Count
And the
the Defendants
Defendants named
And
Count 16,actingas
l6, acting as co-conspirators,
coconspirators, as
document in
if fully set
set forth
and
incorporated by
by reference
reference
asas iffully
forth herein,
herein, made
made said
said document
in Fulton
Fulton County,
and incorporated
County,
States and
and the
United States
Archivist of
delivered said
said document
document to
and uttered
the
the United
of the
the Archivist
to the
and delivered
uttered and
Georgia,
Georgia, and
acts
to
effect
the
were
overt
in
Fulton
which
Governor of Georgia
of the Governorof
Ofﬁce
Officeofthe
in
Fulton
County,
Georgia,
which
were
overt
acts
to
effect
the
Georgia
County, Georgia,
and
the
objectofthe
to the
the laws
laws of
of said
said State,
peace and dignity
order, peace
State, the good
dignity
good order,
contrary to
conspiracy, contrary
object of the conspiracy,
thereof;
thereof;
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do

Page 81 of COUNT
COUNT 18of
And the Grand Jurors aforesaid, in the name and behalf
ofthe citizensofGeorgia, do
charge and accuse DAVID JAMES SHAFER andSHAWN MICAH TRESHER STILL with
said
the said
for the
of FALSE
STATEMENTS AND
O.C.G.A. §§ 16-10-20,
offense of
AND WRITINGS,
the
16-1020, for
FALSE STATEMENTS
WRITINGS, O.C.G.A.
the offense
in the commission
commission of
With
together with
and together
crime, and
ofaa crime,
as persons
concernedinthe
persons concerned
and as
accused,
accused, individually
individually and
on
14th
of
or
about
the
State
and
14th
the
about
of
Fulton
or
on
in the
and StateofGeorgia,
unindicted
the CountyofFulton
unindicted co-conspirators,
Georgia,
County
co-conspirators, in
and used
document
made
and
false docunent
used aa false
and
December
made
of
unlawfully
and
willfully,
knowingly,
2020,
December
of
day
2020,
unlawﬁllly
willfully,
knowingly,
day
that
said
document
with
document
said
Notice
of
of
Electoral
that
"RE:
knowledge
titled
College
titled “RE: NoticeofFillingofElectoral
Vacancy," with knowledge
College Vacancy,”
Filling
of the SHAFER was
JAMES SHAFER
statements that
Chairmanofthe
was Chairman
contained the
DAVID JAMES
that DAVID
false statements
the false
contained
of
STILL
was
TRESHER
MICAH
‘Georgia
Electoral
College
Meeting
and
SHAWN
MICAH
TRESHER
STILL
was
Secretary
and
SHAWN
Electoral
Secretary of
College Meeting
Georgia
within the
said document
the Georgia Electoral
Meeting, said
document being
being within
thejurisdictionof
the
Electoral College
2020 Georgia
the
jurisdiction of the
College Meeting,
Governor
of
of
the
Ofﬁce
of
State
and
the
Officeof
the Georgia
Secretary
of
State
and
the
Officeofthe
GovemorofGeorgia,
departments
Office of the
Georgia, departments
Georgia Secretary
and
the good
of said State,
and agenciesofstate
‘and
goverment, contrary
contrary toto the
the laws
lawsofsaid
State, the
peace and
order, peace
good order,
agencies of state government,
dignity
thereof;
dignity thereof;
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
charge and accuse DAVID JAMES SHAFER and SHAWN MICAH TRESHER STILL with
COUNT
COUNT
19 of citizens of Georgia,
behalfofthe
of the citizensof
and behalf
in the
do
And the
the Grand
Grand Jurors
the name
name and
And
Jurors aforesaid,
Georgia, do
aforesaid, in
charge
accuse DONALD
RUDOLPH WILLIAM
WILLIAM LOUIS
LOUIS GIULIANI,
GIULIANI,
and accuse
DONALD JOHN
JOHN TRUMP,
TRUMP, RUDOLPH
charge and
RAY
STALLIN
GS
JOHN CHARLES
EASTMAN, KENNETH
KENNETH JOHN
JOHN CHESEBRO,
RAY
STALLINGS
CHARLES EASTMAN,
JOHN
CHESEBRO,
with the
CHEELEY and
SMITH
IIT, ROBERT
ROBERT DAVID
DAVID CHEELEY
and MICHAEL
MICHAEL A.
A. ROMAN
ROMAN with
the offense
offense of
of
SMITH III,
O.C.G.A. §§
16STATEMENTS AND
TO COMMIT
CONSPIRACY
COMMIT FALSE
FALSE STATEMENTS
AND WRITINGS,
WRITINGS, O.C.G.A.
§§ 16CONSPIRACY TO
concerned in
commission
and as
as persons
for the
& 16-10-20,
said accused,
4-16-10-20, for
the said
accused, individually
persons concerned
in the
the commission
4-8 &
individually and
in
the
unindicted
CountyofFulton
the
and
with
indicted
and
in
of
a
co-conspirators,
unindicted
and
indicted
with
together
of a crime,
County of Fulton
crime, and together
co-conspirators,
and
the
14th day
of
day of
and between
on and
2020 and the 14th
and Stateof
State of Georgia,
December 6th dayof
the 6th
between the
and
day 0f December
Georgia, on
make
and
a
false
and
use
false
a
to
use
and
make
willfully
December
and
knowingly
to
conspired
unlawfully
2020,
December 2020, unlawfully conspired knowingly willfully
said
document
tiled “RE:
NoticeofFillingof
Electoral College
Vacancy,” with
with knowledge
that said
"RE: Notice
of Filling of Electoral
document titled
knowledge that
College Vacancy,"
the
Chairman of
SHAF ER was
contained the
false statements
document contained
the false
statements that
that DAVID
DAVID JAMES
JAMES SHAFER
was Chairman
ofthe
document
TRESHER
STILL
was
SHAWN
MICAH
Electoral
and
2020 Georgia
Georgia Electoral College
Meeting and SHAWN MICAH TRESHER STILL was
College Meeting
document being
said document
of
the
Electoral
Secretaryofthe
Georgia
Electoral
College
Meeting, said
being within
within the
the
College Meeting,
Secretary
Georgia
the
Governor
of
the
Ofﬁce
of
and
of
State
of
Governor
of
of
the
Ofﬁce
the
Officeofthe
the
and
State
Officeof the Georgia
jurisdictionofthe
Secretary
Georgia Secretaryof
jurisdiction
and agencies
Georgia, departments
of state
state government;
government;
agencies of
Georgia,
departments and
described above
above
And
the Defendants
named inin Count
Count 18,
as co-conspirators,
co-conspirators, asas described
And the
Defendants named
l8, acting
acting as
said document
made and
and used
used said
document in
if fully set
and incorporated
‘and
incorporated by
by reference
reference asasiffully
set forth
forth herein,
herein, made
in Fulton
Fulton
to
of
the
the
to
eﬁect
the
which
were
overt
acts
County,
Georgia,
which
were
overt
acts
to
effect
the
objectofthe
conspiracy,
contrary
to
the
object
conspiracy, contrary
County, Georgia,
of said State,
laws
lawsofsaid
the good
order, peace
peace and
and dignity
thereof;
State, the
dignity thereof;
good order,

19 0f
'

Page 82 0f COUNT COUNT
20of
do
of the citizensofGeorgia,
citizens of Georgia, do
And the
the Grand
Jurors aforesaid,
in the
the name
name and
and behalf
behalf
ofthe
And
Grand Jurors
aforesaid, in
the
offense
of
CRIMINAL
LEE
with
charge
and
accuse
STEPHEN
CLIFFGARD
LEE
with
the
offense
of
CRIMINAL
and
accuse
STEPHEN
CLIFFGARD
charge
16-10ATTEMPT TO
TO COMMIT
INFLUENCING WITNESSES,
0.C.G.A. §§
§§ 16-4-16-4-1 && 16-10ATTEMPT
COMMIT INFLUENCING
WITNESSES, O.C.G.A.
93(b)(1)(A),
for
the
said
accused,
in
the
CountyofFulton
and
State
of
Georgia,
on
the
14th day
day
of
on
the
14th
of
Fulton
and
State
the
said
in
the
for
accused,
County
Georgia,
93(b)(1)(A),
of
December
2020,
unlawfully,
vith
intent
to
commit
the
crimeof
Influencing
Witnesses,
crime
of
0f December 2020, unlawfully, with intent to commit the
Inﬂuencing'Witnesses,
0.C.G.A.
16-10-93(b)(1)(A), traveled
traveled
toto the
the home
homeofof Ruby
Ruby Freeman,
Freeman, 2a Fulton
Fulton County,
O.C.G.A. §§ l6-lO-93(b)(l)(A),
County,
Georgia,
election
worker,
and
spoke
to
her
neighbor,
a
substantial
step
toward
the commission
commission of
of
a
substantial
toward
the
step
Georgia, election worker, and spoke to her neighbor,
with intent
intent to
Influencing Witnesses,
Witnesses, O.C.G.A.
16-10-93(b)(1)(A),
to knowingly
knowingly engage
in
O.C.G.A. §§ 16-10-engage in
(b)(l)(A), with
Inﬂuencing
and
with
intent
to
to
offer
her
misleading
conduct
toward
Ruby
Freeman,
by
purporting
to
offer
her
help,
and
with
intent
to
conduct
toward
help,
misleading
Ruby Freeman, by purporting
events
influence her
testimony inin an
an official
proceeding inin Fulton
Fulton County,
concerning events
inﬂuence
her testimony
ofﬁcial proceeding
Counw, Georgia,
Georgia, concerning
election
in
said
date
atat State
in the
November 3,3, 2020,
presidential
election
in
Georgia,
said
date
being aa
State Farm
Farm Arena
Arena in
the November
2020, presidential
being
Georgia,
of said State,
‘material elementofthe
offense, contrary
to the
the laws
lawsofsaid
the good
peace and
and
material
element of the offense,
State, the
order, peace
good order,
contrary to
dignity
thereof,
dignity thereof;
21 of
0f COUNT
COUNT
‘And the Grand Jurors aforesaid, in the name and behalf
ofthe citizens of Georgia, do
charge and accuse STEPHEN CLIFFGARD LEE with the offense of CRIMINAL
ATTEMPT TO COMMIT INFLUENCING WITNESSES, 0.C.G.A. §§ 16-4-1 & 16-1093(b)(1)(A), for the said accused, in the CountyofFulton and Stateof Georgia, on the 15th day
of December 2020, unlawfully, with intent to commit the crime of Influencing Witnesses,
O.C.GA. § 16-10-93(b)(1)(A), traveled to the homeofRuby Freeman, a Fulton County,
Georgia,
worker, and
and knocked
knocked on
her door,
substantial step
step toward
toward the
of
a substantial
the commission
commission of
on her
election worker,
door, a
Georgia, election
Influencing Witnesses,
Witnesses, 0.C.G.A.
16-10-93(b)(1)(A),
with intent
intent toto knowingly
in
O.C.G.A. §§ 16-10-knowingly engage
engage in
(b)(l)(A), with
Inﬂuencing
misleading
conduct
toward
Ruby
Freeman,
by
purporting
to
offer
her
help,
and
with
intent
toto
offer
with
to
her
and
intent
conduct
toward
help,
misleading
Ruby Freeman, by purporting
influence her
her testimony
in an
proceeding inin Fulton
Georgia, concerning
Fulton County,
events
inﬂuence
an official
ofﬁcial proceeding
County, Georgia,
concerning events
testimony in
election
in
said
date
at State
Farm Arena
Arena inin the
3, 2020,
presidential
election
in
Georgia,
said
date
being aa
at
State Farm
the November
November 3,
2020, presidential
being
Georgia,
and
material elementofthe
offense, contrary
to the
the lawsofsaid
the good
peace and
laws of said State,
element of the offense,
material
State, the
order, peace
good order,
contrary to
dignity
thereof;
dignity thereof;
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
charge and accuse STEPHEN CLIFFGARD LEE with the offense of CRIMINAL
ATTEMPT TO COMMIT INFLUENCING WITNESSES, O.C.G.A. §§ 16-4-1 & 161093(b)(1)(A), for the said accused, in the County of Fulton and State of Georgia, on the 15th day
of December 2020, unlawfully, with intent to commit the crime of Inﬂuencing Witnesses,
O.C.G.A. § l6-lO-93(b)(l)(A), traveled to the home of Ruby Freeman, a Fulton County,

Page 83 0f COUNT
COUNT and behalf of the
of Georgia, do
And the
the Grand
name andbehalfof
the citizens
citizensofGeorgia,
do
in the
the name
And
Grand Jurors
Jurors aforesaid,
aforesaid, in
ATTEMPT
CRIMINALATTEMPT
with
the
offense
of
CRIMINAL
of
offense
the
CLARK
with
BOSSERT
CLARK
BOSSERT
and
accuse
JEFFREY
JEFFREY
accuse
and
charge
Charge
16-10-20,
& 16-10-20,
16-4-1 &
AND WRITINGS,
O.C.G.A. §§
WRITINGS, O.C.G.A.
STATEMENTS AND
TO COMMIT
FALSE STATEMENTS
COMMIT FALSE
TO
§§ 16-4-and
a
for the
the said
individually
and
as
a
person
concerned
in
the
commission
of
a
crime,
and
in
of
as
a
concerned
the
commission
and
for
said accused,
crime,
accused, individually
person
and
on
together
with
unindicted
co-conspirators,
in
the
County
of
Fultonand
Stateof
Georgia,
on
and
of
and
State
of
Fulton
Georgia,
together with unindicted co-conspirators, in the County
between the
the 28th
28th day
of
December
and
the
2nd
dayofJanuary
2021,
unlawfully, With
with
and
the
2nd
of
of
December
between
2021,
unlawfully,
day January
day
intent
to
commit
the
crimeofFalse
Statements
and
Writings,
0.C.G.A.
§
16-10-20,
knowingly
Statements
and
O.C.G.A.
False
intent to commit the crime of
Writings,
§ 16-1020, knowingly
and willfully
willfullymadea
false writing
writing and
knowing the
the same
to contain
contain the
the false
false statement
statement
and document
document knowing
same to
and
made a false
concerns
that
that
the
United
States
Department
of
Justicehad
“identified
significant
concerns
that
may
have
of
Justice
had
"identiﬁed
that the United States Department
may have
signiﬁcant
said
the Stateof
State of Georgia,"
impacted the
the outcome
of the
the election
in multiple
including the
Georgia,” said
election in
outcome of
State's, including
multiple States,
impacted
and
the
the
of
State
of
the
Ofﬁce
of
statement being
within
thejurisdictionof
the
Office
of
the
Georgia
Secretaryof
State
and
the
statement
within
the
Georgia Secretary
jurisdiction
being
and
county and
of state government,
and county
agenciesofstate
and agencies
departments and
of Investigation,
Investigation, departments
Bureau of
Georgia Bureau
government, and
Georgia
city
law
enforcement
agencies;
law
enforcement
city
agencies;
And,
on or
or about
about the
28th day
December 2020,
the said
e-mail t0to
of December
said accusedsentan
accused sent an e-mail
the 28th
2020, the
And, on
day of
and Acting
States Deputy
Acting
United States
Attomey General
Rosen and
Acting United
United States
Deputy Attomey
General Jeffrey
States Attorney
Attorney
Jeffrey Rosen
Acting United
and
document
authorization to
send said
‘General
Richard Donoghue
Donoghue and
and requested
requested authorization
to send
false writing
and
document
said false
General Richard
writing
House of
toto Georgia
Kemp, Speakerofthe
of Representatives
Representatives David
David
Brian Kemp,
Governor Brian
Georgia House
Speaker of the Georgia
Georgia Governor
Ralston,
and President
President Pro
the Georgia
Senate Butch
Butch Miller;
Pro Temporeof
Miller;
Georgia Senate
Ralston, and
Tempore of the
the said
2nd dayof
accused met
And,
on oror about
the 2nd
said accused
met with
with Acting
Acting United
United
about the
2021, the
And, on
January 2021,
day of January
and
United
States
General
Rosen
States
Attomey
General
Jeffrey
Rosen
and
Acting
United
States
Deputy
Attomey
General
General
States Attorney
Acting
Jeffrey
Deputy Attorney
send said
and document
document to
Richard
Donoghue and
requested authorization
authorization toto send
said false
false writing
writing and
to
and requested
Richard Donoghue
Georgia
Govemor
Brian
Kemp,
Speaker
ofthe
Georgia
House
of
Representatives
David
Ralston,
the
David
of
House
of
Brian
Governor
Ralston,
Georgia
Representatives
Georgia
Kemp, Speaker
and
Senate Butch
Butch Miller;
Miller;
and President
Pro Temporeofthe
President Pro
Georgia Senate
Tempore of the Georgia
Statements
And said
said acts
constituted substantial
toward the
the commissionofFalse
substantial steps
commission of False Statements
acts constituted
And
steps toward
and
said
conduct
committed
outside
the
state
of
and
0.C.G.A.
§
16-10-20,
and
said
conduct
committed
outside
the
stateof
Georgia.
and Writings,
O.C.G.A.
Georgia
§ 16-10-20,
Writings,
constitutedanattempt
to
commitacrime
within
the
state
o
fGeorgia,
pursuant
to
O.C.G.A.
17constituted an attempt to commit a crime within the state of Georgia, pursuant to O.C.G.A. §§ l7the good
of said State,
2-1(b)(2), contrary
to the
the laws
lawsofsaid
peace and
and dignity
dignity thereof;
thereof;
order, peace
State, the
good order,
contrary to
2-1(b)(2),

Page 84 COUNT of COUNT
23of
do
of Georgia, do
citizensofGeorgia,
behalfofthe
and behalf
of the citizens
name and
the name
in the
Jurors aforesaid,
Grand Jurors
the Grand
And the
And
aforesaid, in
SMITH
RAY STALLINGS
STALLINGS SMITH
LOUIS GIULIANI,
WILLIAM LOUIS
accuse RUDOLPH
RUDOLPH WILLIAM
and accuse
charge
GIULIANI, RAY
charge and
OF
VIOLATION
the offense
offense of
SOLICITATION OF VIOLATION
of SOLICITATION
with the
CHEELEY with
and ROBERT
DAVID CHEELEY
ROBERT DAVID
III, and
III,
said accused,
the said
for the
O.C.G.A. §§
16-10-1, for
16-4-7 && 16101,
§§ 16-4-PUBLIC OFFICER,
OF
OATH BY
BY PUBLIC
accused,
OF OATH
OFFICER, O.C.G.A.
with
individually
and
as
persons
concemed
in
the
commission
of
a
crime,
and
together
with
in
the
commission
of
a
and
crime,
together
individually and as persons concerned
0f
the 30th
unindicted co-conspirators,
in
the
County
ofFulton
and
StateofGeorgia,
30th day
on the
the
of
Fulton
and
State
of
in
unindicted
day of
Georgia, on
County
co-conspirators,
then
ofﬁcers
December
2020,
unlawfully
solicited,
requested,
and
importuned
certain
public
officers
then
and
certain
December 2020, unlawfully solicited, requested,
public
importuned
serving
as
elected
membersofthe
Georgia
Senate
and
present
at
a
Senate
Judiciary
the
Senate
and
at
a
Senate
of
members
as
elected
Judiciary
Georgia
present
serving
identity isis
whose identity
8,
Individual
co-conspirator
unindicted
Individual
unindicted
including
meeting,
Subcommittee
Subcommittee meeting, including
8, whose
co-conspirator
Rhett,
Michael Rhett,
Ligon, Michael
Bill Heath,William
Beach, Bill
Brandon Beach,
Senators Brandon
Grand Jury,
the Grand
to the
known to
known
Heath, William Ligon,
Jury, Senators
by
Oath
of
Oath
of
Violation
ofViolation
offense
the
offense
of
felony
the
in
conduct
constituting
to
conduct
in
engage
Blake
to
Tillery,
and
Blake
and
by
constituting
felony
Tillery, engage
State
the State:
from the
electors from
presidential electors
appointing presidential
O.C.G.A. §§ 16-10-1,
16-10-1, by
Public
Officer, 0.C.G.A.
Public Officer,
by unlawfully
unlawfully appointing
as
of
said
intentional
violation
of
the
terms
of
the
oath
of
in
willful
and
intentional
violationofthe
termsofthe
oath
of
said
persons
as
and
in
willful
of Georgia,
persons
Georgia,
material
being aamaterial
date being
said persons
said conduct,
said date
in said
persons engage
with intent
that said
intent that
law, with
by law,
prescribed by
conduct, said
engage in
prescribed
dignity
and
and
peace
laws
of
order,
good
to
the
said
the
the
Stat,
said
of
laws
the
element
to
contrary
the offense,
of the
element of
dignity
State,
offense, contrary
good order, peace
thereof;
thereof;
COUNT 24 ofCOUNT
0f do
of Georgia, do
and behalf
of the citizens
And the
the Grand
in the
the name
name and
behalf
ofthe
citizensofGeorgia,
Grand Jurors
Jurors aforesaid,
And
aforesaid, in
of
FALSE
with
the
oﬁense
WILLIAM
LOUIS
GIULIANI
charge
and
accuse
RUDOLPH
WILLIAM
LOUIS
GIULIANI
with
the
offense
of
FALSE
and
accuse
RUDOLPH
charge
County
the County
in the
said accused,
the said
for the
O.C.G.A. §§ 16-10-20,
16-10-20, for
AND WRITINGS,
WRITINGS, O.C.G.A.
STATEMENTS AND
STATEMENTS
accused, in
on or
December
of
of Fulton
Fulton and
or about
about the
the 30th
30th day
of
December
2020,
knowingly,
and StateofGeorgia,
State of Georgia, on
of
2020, knowingly,
day
willfully, and
unlawfully made
made atat least
least oneofthe
following false
false statements
and representations
one of the following
statements and
and unlawfully
representations
willfully,
to members
membersofthe
Senate
present
at
a
Senate
Judiciary
Subcommittee
meeting:
at
a
Senate
Subcommittee
Senate
of the Georgia
to
meeting:
Judiciary
Georgia
present
election workers
workers fraudulently
fraudulently counted
certain ballots
as five
five
ballots as
as many
counted certain
l.1. That
That Fulton
Fulton County
many as
County election
times atat State
Farm Arena
Arena on
November 3,3, 2020;
2020;
on November
State Farm
times
in
election in
presidential election
November 3,3, 2020,
the November
illegally inin the
voted illegally
felons voted
2,560 felons
That 2,2.2. That
2020, presidential
Georgia;
Georgia;
3.3. That
10,315 dead
dead people
people voted
voted inintheNovember
3, 2020,
presidential election
election inin Georgia;
Georgia;
the November 3,
That 10,2020, presidential
and
State and
said
being within
within the
thejurisdictionofthe
of State
Office of the
the Georgia
statements being
said statements
Secretary of
Georgia Secretary
jurisdiction of the Officeof
and county
and agenciesofstate
of Investigation,
the
Bureauof
the Georgia
county
agencies of state government,
government, and
Investigation, departments
departments and
Georgia Bureau
and city
law
enforcement
agencies,
contrary
to
the
lawsofsaid
State,
the
good
order,
peace
and
the
to
laws
of
said
the
law
enforcement
and
State,
agencies, contrary
good order, peace and
city
dignity thereof;
thereof;
dignity

Page 85 25 of
0f COUNT COUNT
citizens of Georgia, do
of the citizensofGeorgia,
the name
and behalf
And the
Grand Jurors
Jurors aforesaid,
in the
name and
behalf
ofthe
do
the Grand
And
aforesaid, in
STATEMENTS
of
FALSE
offense
SMITH
III
with
the
RAY
STALLINGS
charge
and
accuse
RAY
STALLINGS
SMITH
IIT
with
the
offense
ofFALSE
STATEMENTS
and
accuse
charge
of Fulton and
said accused,
AND WRITINGS,
O.C.G.A. §§ 16-10-20,
for the
the said
in the
the County
CountyofFulton
and
AND
accused, in
16-10-20, for
WRITINGS, O.C.G.A.
and
the 30th
30th day
of December 2020,
about the
StateofGeorgia,
on or
or about
day ofDecember
2020, knowingly,
willfully, and
State of Georgia, on
knowingly, willfully,
of
and representations
of the following
false statements
statements and
members of
representations toto members
following false
oneofthe
least one
made atat least
unlawfully made
unlawfully
Senate Judiciary
Subcommittee meeting:
Senate present
the Georgia
present atat aa Senate
the
meeting:
Judiciary Subcommittee
Georgia Senate
office had
had
General Counsel
Counsel Ryan
Germany stated
stated that
that his
his office
l.1. That
That Georgia
Ryan Germany
Georgia SecretaryofState
Secretary of State General
November
who
voted
in
the
sent
to 8,people
who
voted
illegally
in
the
November
3,
2020,
presidential
letters to
sent letters
3, 2020, presidential
8,000 people
illegally
them not
not to
to vote
and told
election
told them
vote inin the
the January
January $,5, 2021,
runoffelection;
election and
election;
2021, runoff
90% accuracy
of State
admitted “that
"that they
That the
2. That
the Georgia
State admitted
they had
had aa 90%
rate” inin the
the
2.
accuracy rate"
Secretary of
Georgia Secretary
that's
not
a
10%
that
"there's
still
not
that's
election
and
margin
10%
stila
November
“there’s
that
and
election
presidential
2020,
3,
November 3, 2020, presidential
margin
accurate”;
accurate";
within the
of the
Office of
said
being within
thejurisdiction
the Office
of the
the Georgia
Georgia Secretary
of State
State and
and
said statements
statements being
Secretary of
jurisdiction of
and
of
state
of
and
Bureau
the Georgia
Bureauof
Investigation,
departments
and
agenciesofstate
government,
and
county
the
county
government,
agencies
Investigation, departments
Georgia
and
of said State,
enforcement agencies,
and
law enforcement
agencies, contrary
to the
the laws
lawsofsaid
the good
order, peace
peace and
and city
State, the
good order,
contrary to
city law
dignity
thereof;
dignity thereof;
26 of COUNT 26of
COUNT
do
citizens of Georgia, do
the name
of the citizensofGeorgia,
Grand Jurors
Jurors aforesaid,in
And the
the Grand
name and
and behalf
behalf
ofthe
And
aforesaid, in the
STATEMENTS
of FALSE STATEMENTS
ROBERT DAVID
with the
accuse ROBERT
CHEELEY with
charge
DAVID CHEELEY
the offense
offenseofFALSE
and accuse
charge and
and
in
the
O.C.G.A.
for
the
said
AND WRITINGS,
0.C.G.A.
§
16-10-20,
for
the
said
accused,
in
the
Countyofof Fulton
Fulton and
AND
accused,
WRITINGS,
County
§ 16-10-20,
and
on or
about the
30th day
of December 2020,
State of Georgia, on
StateofGeorgia,
or about
the 30th
knowingly, willfully,
willfully, and
2020, knowingly,
day ofDecember
to members
at
least
one
of
the
false
statements
and
made
unlawfully
made
at
least
one
ofthe
following
false
statements
and
representations
members of
of
following
representationsto
unlawfully
at
a
Senate
Senate
Subcommittee
the
the Georgia
meeting:
Judiciary Subcommittee meeting;
Georgia Senate present
present at a Senate Judiciary
late in
in the
at State
were told
and media
media at
State Farm
Arenawere
1. That
poll watchers
watchers and
FarmArena
told lat
the evening
of
That poll
l.
evening of
next
and to
until the
to
morning and
November
the next morning
being suspended
was being
count was
vote count
the vote
that the
2020, that
November 3,3, 2020,
suspended until
of
"a
watermain
because
home
home
because
of“a
major
watermain
break’;
break";
major
go
same ballots
Arena “voted”
"voted" the
"over
election workers
State Farm
2.
That Fulton
2. That
Fulton County
workers atat State
Farm Arena
the same
ballots “over
County election
on
November
and
over
and over again”
3,3, 2020;
2020;
again" on November
of State
and
within the
the jurisdiction
Office of
said statements
statements being
said
being within
jurisdiction of
of the
the Office
of the
the Georgia
Georgia Secretary
State and
Secretary of
and county
and agencies
of state government,
of Investigation,
the
the Georgia
Bureauof
Investigation, departments
departments and
agenciesofstate
county
government, and
Georgia Bureau
the
and
to
the
laws
of
said
law
enforcement
and
and city
law
enforcement
agencies,
contrary
to
the
lawsofsaid
State,
the
good
order,
peace
State,
good order, peace and.
agencies, contrary
city
dignity thereof;
thereof;
dignity

Page 86 COUNT
27of
COUNT of do
‘And
the Grand
Grand Jurors
Jurors aforesaid,
aforesaid, inin the
name and
and behalf
behalf
ofthe
of the citizensofGeorgia,
citizens of Georgia, do
And the
the name
the
CHARLES
EASTMAN
with
charge
and
accuse
DONALD
JOHN
TRUMP
and
JOHN
CHARLES
EASTMAN
with
the
and
accuse
DONALD
J
OIﬂ'I
TRUMP
and
JOHN
charge
for the
said accused,
offenseofFILING
FALSE DOCUMENTS,
16-10-20.1(b)(1), for
the said
O.C.G.A. §§ 16-10-20.1(b)(1),
offense of FILING FALSE
accused,
DOCUMENTS, 0.C.G.A.
a
and
with
and
as
of
individually
and
as
persons
concerned
in
the
commission
of
a
crime,
and
together
with
concerned
in
the
commission
crime,
together
individually
persons
about the
of Fulton and
State of
unindicted co-conspirators,
in the
the County
CountyofFulton
and State
of Georgia,
on or
or about
the 3lst
31st
unindicted
Georgia, on
co-conspirators, in
dayof
December
2020,
knowingly
and
unlawfully
filed
a
document
tiled
“VERIFIED
titled
"VERIFIED
a
document
December
and
ﬁled
of
2020, knowingly
unlawfully
day
COMPLAINT
EMERGENCY INJUNCTIVE
INJUNCTIVE AND
AND DECLARATORY
DECLARATORY RELIEF”
the
RELIEF" in
in the
FOR EMERGENCY
COMPLAINT FOR
States District
Court for
for the
matterof
Kemp, Case
1:20-cv-05310-MHC, inin the
the United
United States
District Court
the
of Trump
v. Kemp,
Case 1:20-cv05310MHC,
matter
Trump v.
to
know
that
said
Northen District
District ofGeorgia,
United States,
having
reason
to
know
that
said
of Georgia, aa courtofthe
reason
Northern
court of the United
States, having
statements:
document contained
following materially
materially false
false statements:
at least
least oneofthe
document
contained at
one of the following
"as many
as 2,an uncompleted
1l.. That
many as
2,506 felons
felons with
with an
uncompleted sentence"
sentence” voted
voted illegally
illegally inin the
the
That “as
in
November 3,3, 2020,
2020, presidential
election
in
Georgia;
November
election
Georgia;
presidential
2.2 That
That “at
least 66,underage” people
people voted
November 3,3, 2020,
the November
in the
"at least
voted illegally
2020,
66,247 underage"
illegally in
election in
presidential election
in Georgia;
Georgia;
presidential
3.3 That
That “at
least 2,2,423 individuals”
the November
November 3,3, 2020,
2020, presidential
presidential
in the
"at least
voted illegally
individuals" voted
illegally in
election inin Georgia
not listed
in the
the State's
havingbeenregistered
records as
as having
been registered
State's records
election
"who were
were not
listed in
Georgia “who
to
to vote";
vote”;
4.4 That
least 1,1,043 individuals"
individuals” voted
voted illegally
illegally inin the
the N0vember
November
3,3, 2020,
2020, presidential
presidential
"at least
That “at
ofﬁce box
as their
election “who
had illegally
registered toto vote
vote using
using
aa postal
postal office
boxastheir
election
"who had
illegally registered
habitation”;
habitation";
5. That
“as many
many asas 10,10,315 or
or more"
more” dead
in the
the November
November 3,3, 2020,
2020,
That "as
dead people
voted in
people voted
election in
presidential election
in Georgia;
Georgia;
presidential
watchers and
and
6. That
misinformation was
wasusedto
instruct Republican
poll watchers
That “[d]eliberate
used to instruct
Republican poll
"[d]eliberate misinformation
on
‘membersofof the
the press
press toto leave
leave the
the premises
premises for
night atat approximately
approximately 10:10:00 pm.
p.m. on
members
for the
the night
Fulton
2020"
at
State
Farm
Arena
in
November 3,3, 2020” at State Farm Arena in Fulton County,
Georgia;
November
County, Georgia;
of said State,
and dignity
contrarytoto the
the laws
lawsofsaid
the good
thereof;
State, the
order, peace
dignity thereof;
contrary
good order,
peace and
o

Page 87 of 28 ofCOUNT
COUNT
of Georgia, do
do
behalfofthe
of the citizens
and behalf
in the
And the
Grand Jurors
And
the Grand
the name
name and
citizensofGeorgia,
Jurors aforesaid,
aforesaid, in
the
TRUMP and MARK RANDALL
with the
MEADOWS with
RANDALL MEADOWS
JOHN TRUMPandMARK
DONALD JOHN
accuse DONALD
and accuse
charge
charge and
O.C.G.A.
OATH
BY
PUBLIC
OF
O.C.G.A.
of
OF
VIOLATION
OFFICER,
PUBLIC
offense
SOLICITATION
BY
OATH
OF
OFFICER,
offense ofSOLICITATION OF VIOLATION
concerned in
in the
and as
the
said accused,
persons concemed
as persons
individually and
accused, individually
the said
for the
16-10-1, for
164-7 && 16-10-1,
§§
§§ 16-4-Fulton
in
the
of
with
unindicted
of
a
and
CountyofFulton
the
in
commission
co-conspirators,
unindicted
with
together
crime, and together
County
commission ofa crime,
co-conspirators,
2nd dayof
requested,
and
State of Georgia, on
on or
or about
unlawfully solicited,
2021, unlawfully
solicited, requested,
the 2nd
about the
January 2021,
and StateofGeorgia,
day of January
to
a
Brad
and importuned
Georgia
SecretaryofState
Brad
Raffensperger,
public
officer,
to
engage
in
of
State
and
ofﬁcer,
engage in
Raffensperger, public
importuned Georgia Secretary
l6Public
O.C.G.A.
conduct constituting
of Oath
Oath by
by Public Officer,
the felony
offense of Violation of
conduct
Officer, 0.C.G.A. §§ 16constituting the
felony offenseofViolation
otherwise unlawfully
and otherwise
10-1, by
by unlawfully
unlawfully altering,
unlawfully adjusting,
unlawfully inﬂuencing
influencing the
the
10-1,
adjusting, and
altering, unlawfully
in
election
November
for the
electors for
certiﬁed
for presidential
certified returns
returns for
presidential electors
the November 3,3, 2020,
2020, presidential
presidential election in
of said person
as prescribed
of
the
oath
the
terms
prescribed
of
in
willful
and
intentional
violation
oathofsaid
the
termsof
violationofthe
intentional
and
willful
in
Georgia,
person as
Georgia,
to
the
laws
of
said
the
in
said
State, the
intent
lawsofsaid
said person
person engage
State,
that said
conduct, contrary
with intent that
law, with
by
contrary to the
engage in said conduct,
by law,
and dignity
‘200d
dignity thereof;
thereof;
order, peace
good order,
peace and

Page 88 COUNT 29 of
of COUNT
ofthe citizensofGeorgia, do
And the Grand Jurors aforesaid, in the name and behalf
charge and accuse DONALD JOHN TRUMP with the offense of FALSE STATEMENTS
AND WRITINGS, 0.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and
Stateof Georgia, on or about the 2nd day of January 2021, knowingly, willfully, and unlawfully
made at leastoneofthe following false statements and representations
to Georgia Secretary of
State Brad Raffensperger, Georgia Deputy Secretaryof State Jordan Fuchs, and Georgia
Secretary of State General Counsel Ryan Germany:
rolls
the rolls
into the
mysteriously into
dropped mysteriously
were dropped
ballots were
300,000 ballots
to 300,to
250,1.
from 250,That anywhere
1. That
anywhere from
election in
inin the
the November
November 3,3, 2020,
presidential election
in Georgia;
2020, presidential
Georgia;
2.2. That
thousandsofpeople
attempted toto vote
vote inin the
the November
November3,3, 2020,
presidential
That thousands
of people attempted
2020, presidential
in
cast in
election
and
were
told
they
could
not
because
a
ballot
had
already
been cast
could
not
because
a
ballot
had
told
in Georgia
and
were
election in
already been
they
Georgia
their name;
their
name;
3.3. That
4,502 people
people voted
voted inin the
the November
November 3,3, 2020,
election inin Georgia
who
That 4,2020, presidential
Georgia who
presidential election
‘were
not on
the voter
voter registration
registration list;
list;
were not
on the
who
in Georgia
4. That
904 people
people voted
in the
the November
November 3,3, 2020,
presidential election
election in
4.
That voted in
2020, presidential
Georgia who
a
oﬁice
were
registered
at
an
address
that
was
a
post
office
box;
that
was
address
were registered at an
box;
post
5. That
Ruby Freeman
Freemanwas
professional vote
vote scammer
scammer and
and aa known
known political
operative;
5.
That Ruby
was aa professional
political operative;
6. That
“That Ruby
Ruby Freeman,
her daughter,
were responsible
responsible for
for fraudulently
fraudulently awarding
and others
others were
6.
awarding
Freeman, her
daughter, and
atat least
least 18,18,000 ballots
ballots
toJoseph
Biden atat State
Arena inin the
the November
3, 2020,
State Farm
Farm Arena
R. Biden
November 3,
to Joseph R.
2020,
election
in
presidential
election
in
Georgia;
Georgia;
presidential
November 3,
7. That
That elose
people voted
voted inin the
the November
2020, presidential
presidential election
election inin
close to
to 5,dead people
7.
3, 2020,
5,000 dead
Georgia;
Georgia;
Detroit;
election inin Detroit;
November 3,
presidential election
the November
8.
That 139%
of people voted
voted inin the
139%ofpeople
3, 2020,
2020, presidential
8. That
in the
the numberof
number of people
9.9. That
more votes
votes were
were recorded
recorded than
thanthe
people who
who voted
votedinthe
That 200,200,000 more
‘November
3, 2020,
in Pennsylvania;
Pennsylvania;
election in
November 3,
2020, presidential
presidential election
in
election in
presidential election
November 3,
the November
of dead people
voted inin the
10.
That thousands
people voted
thousandsofdead
10. That
3, 2020,
2020, presidential
Michigan;
Michigan;
11.
Freeman stuffed
the ballot
boxes;
ballot boxes;
ll. That
That Ruby
stuffed the
Ruby Freeman
12.
hundredsof
thousandsofballots
had been
been “dumped”
Fulton County
and
into Fulton
of ballots had
That hundreds
of thousands
12. That
"dumped" into
County and
another
county adjacent
to
Fulton
County
in
the
November
3,
2020,
presidential
in
the
election
November
Fulton
to
another county
3, 2020, presidential election
County
adjacent
in Georgia;
Georgia;
in
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
charge and accuse DONALD JOHN TRUMP with the offense of FALSE STATEMENTS
AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and
State of Georgia, on or about the 2nd day of January 2021, knowingly, willfully, and unlawfully
made 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:

Page 89 votes;
400,000 votes;
by 400,in Georgia
presidential election
election in
2020, presidential
the November
November 3,3, 2020,
13. That
That he
won the
he won
13.
Georgia by
and
SecretaryofState
of State and
thejurisdictionofthe
Ofﬁce of the Georgia
within the
being within
said
said statements
statements being
Georgia Secretary
jurisdiction of the Officeofthe
to
and agenciesofstate
Investigation, departments
the
Bureau of Investigation,
the Georgia
contrary to
agencies of state government,
government, contrary
departments and
Georgia Bureauof
and
the
lawsofsaid
State,
the
good
order,
peace
and
dignity
thereof;
the laws of said State, the good order, peace
dignity thereof;
COUNT
of COUNT 30 of
do
of Georgia,
Georgia, do
citizens of
and behalfof
of the
the citizens
name andbehalf
Jurors aforesaid,
the name
in the
And
Grand Jurors
the Grand
And the
aforesaid, in
PRESCOTT
PRESCOTT
CLIFFGARD
HARRISON
WILLIAM
WILLIAM
HARRISON
LEE,
STEPHEN
CLIFFGARD
and
accuse
STEPHEN
accuse
and
charge
LEE,
charge
FLOYD, and
and TREVIAN
KUTTI with
with the
the offense
COMMIT
ofCONSPIRACY
offense of
TO COMMIT
CONSPIRACY TO
C. KUTTI
TREVIAN C.
FLOYD,
SOLICITATION
FALSE STATEMENTS
O.C.G.A. §§
AND WRITINGS,
WRITINGS, 0.C.G.A.
16-4-8, 16-416-4STATEMENTS AND
SOLICITATION OF
OF FALSE
§§ 16-4-8,
of
of
commission
the
in
concerned
commission
as persons
and as
individually and
said accused,
the said
for the
16-10-20, for
7,7, && 16-10-20,
accused, individually
persons concerned in the
State of
a crime,
together with
unindicted co-conspirators,
in the
the Countyof
Fulton and
and State
of
with unindicted
a
and together
coconspirators, in
County of Fulton
crime, and
and
request,
solicit,
to
conspired
to
unlawfully
4th dayof
the 4th
or about
on or
about the
Georgia, on
2021, unlawfully conspired solicit, request, and
January 2021,
day of January
Georgia,
in conduct
conduct
worker,toto engage
election worker,
County, Georgia,
Fulton County,
Freeman, aa Fulton
importune Ruby
engage in
Georgia, election
Ruby Freeman,
importune
by.
16-10-20,
§
0.C.G.A.
Statements
and
O.C.G.A.
Writings,
and
of
False
Statements
offense of False
felony offense
the felony
constituting
§ 16-10-20, by
Writings,
constituting the
State
events atat State
and representation
false statement
statement and
representation concerning
and willfully
making aa false
willfully making
knowingly and
concerning events
knowingly
and
and
statement
statement
said
election
in
said
Georgia,
in
election
presidential
Arena
in
the
November
2020,
3,
Farm
Farm Arena in the November 3, 2020, presidential
Georgia,
and
representation
being
within
thejurisdictionof
the
Officeofthe
Georgia
Secretary of
of State
State and
the
of
Ofﬁce
of
the
within
the
Georgia Secretary
jurisdiction
representation being
and
the Georgia
Georgia Bureau
BureauofInvestigation,
departments and
goverment,
and
county
and agenciesofstate
of
state
the
of Investigation, departments
county
agencies
government,
and
and
law enforcement
with intent
intent that
that said
said person
person engage
in said
said conduct;
and city
enforcement agencies,
conduct; and
engage in
agencies, with
city law
a telephone call
TREVIAN
C. KUTTI
KUTTItraveledto
Fulton County,
County, Georgia,
Georgia, and
placedatelephone
call toto Ruby
Ruby
and placed
traveled to Fulton
TREVIAN C.
of the
which were
were overt
effect the
Freeman while
in Fulton
Fulton County,
overt acts
to effect
the object
objectofthe
acts to
while in
Freeman
Georgia, which
County, Georgia,
said
the
and
‘conspiracy,
contrary
to
the
laws
of
said
State,
the
good
order,
peace
and
dignity
thereof;
laws
of
to
the
thereof;
State,
dignity
good order, peace
conspiracy, contrary
COUNT 31of
31 of COUNT
do
And
the Grand
Jurors aforesaid,
the name
behalf
ofthe
in the
name and
of the citizensofGeorgia,
citizens of Georgia, do
and behalf
And the
Grand Jurors
aforesaid, in
charge
and accuse
accuse STEPHEN
LEE, HARRISON
HARRISON WILLIAM
PRESCOTT
WILLIAM PRESCOTT
CLIFFGARD LEE,
STEPHEN CLIFFGARD
charge and
with the
offense of
C. KUTTI
FLOYD and
KUTTI with
the offense
of INFLUENCING
INFLUENCING WITNESSES,
FLOYD
and TREVIAN
TREVIAN C.
WITNESSES,
and as
concerned inin
said accused,
as persons
individually and
the said
for the
O.C.G.A. §§ 1610-93(b)(1)(A),
16-10-93(b)(1)(A), for
0.C.G.A.
accused, individually
persons concerned
in the
the commission
crime, and
and together
together with
with unindicted
unindicted co-conspirators,
the Countyof
Fulton
the
commission of
of aa crime,
County of Fulton
co-conspirators, in
of
and
the
4th
and
State
of
Georgia,
onor
about
the
4th
dayofJanuary
2021,
knowingly
and
unlawfully
and State of Georgia, on or about
unlawfully
day January 2021, knowingly
engaged
in
misleading
conduct
toward
Ruby
Freeman,
a
Fulton
County,
Georgia,
election
election
a
Fulton
conduct
toward
in
Freeman,
Georgia,
Ruby
County,
engaged misleading
intent to
and
with
worker,
by
stating
that
she
neededprotectionand
by
purporting
to
offer
her
help,
with
intent
to
to
her
needed
offer
she
that
by purporting
help,
worker, by stating
protection
events
Georgia, concerning
County, Georgia,
Fulton County,
in Fulton
an official
official proceeding
testimony inin an
her testimony
inﬂuence
influence her
concerning events
proceeding in
the
election
in
atat State
Farm Arena
Arena inin the
the November
2020,
presidential
election
in
Georgia,
to the
November 3,
State Farm
3, 2020, presidential
contrary to
Georgia, contrary
and dignity
lawsofsaid
State, the
peace and
thereof;
the good
laws
of said State,
order, peace
dignity thereof;
good order,

Page 90 COUNT of COUNT
32 of
do
Georgia, do
of Georgia,
citizens of
the citizens
and behalf of the
name andbehalfof
the name
in the
Jurors aforesaid,
the Grand
Grand Jurors
And
And the
aforesaid, in
LATHAM,
ALSTON LATHAM,
CATHLEEN ALSTON
SIDNEY KATHERINE
KATHERINE POWELL,
and accuse
accuse SIDNEY
charge
POWELL, CATHLEEN
charge and
TO
of
CONSPIRACY
TO
with
the
offense
offenseofCONSPIRACY
the
and
MISTY
HANIPTON
with
HAMPTON
HALL, and MISTY
GRAHAM HALL,
SCOTT GRAHAM
SCOTT
said accused,
the said
for the
O.C.G.A. §§
21-2-603 && 21-2-566,
accused,
ELECTION FRAUD,
COMMIT ELECTION
COMMIT
21-2-566, for
FRAUD, 0.C.G.A.
§§ 21-2-with
with
and
andtogether
in
the
commission
of
a
crime,
a
of
concerned
commission
as
the
in
and
concemed
persons
individually and as persons
crime,
together
individually
Ist
the 1st
between the
and between
on and
of Georgia,
Stateof
of Fulton and
and State
CountyofFulton
the County
unindicted co-conspirators,
co-conspirators, inin the
unindicted
Georgia, on
to
and agreed
conspired and
unlawfully conspired
2020 and
and the
7th dayof
the 7th
December dayof
agreed to
2021, unlawfully
day of January
January 2021,
day of December
of Georgia;
the State
machines in
StateofGeorgia;
ballot markers
and tabulating
in the
with electronic
electronic ballot
tabulating machines
markers and
tamper with
willfully
willfully tamper
SullivanStrickler
with SullivanStrickler
into aa contract
contract with
entered into
POWELL entered
KATHERINE POWELL
SIDNEY KATHERINE
And
And SIDNEY
County,
Fulton County,
in Fulton
LLC in
to SullivanStrickler
delivered aa payment
SullivanStrickler LLC
Fulton County,
in Fulton
LLC
LLC in
payment to
Georgia, delivered
County, Georgia,
Fulton
Georgia,
County, Georgia,
from Fulton County,
caused employees
travel from
LLC toto travel
and caused
SullivanStrickler LLC
of SullivanStrickler
Georgia,
employees of
Georgia, and
ballot
ballot
electronic
electronic
said
with
said
tampering
with
the
of
purposeofwillfully
the
for
for
Georgia,
to Coffee
to
Coffee County,
purpose
willfully tampering
County, Georgia,
the conspiracy;
of the
the object
to effect
effect the
were overt
overt acts
acts to
which were
machines, which
tabulating machines,
markers
and tabulating
‘markers and
conspiracy;
object of
MISTY
and MISTY
HALL, and
GRAHAM HALL,
SCOTT GRAHAM
LATHAM, SCOTT
ALSTON LATHAM,
And CATHLEEN
CATHLEEN ALSTON
And
willfully
LLC inin willfully
SullivanStrickler LLC
of SullivanStrickler
and encouraged
HAMPTON
HAMPTON aided,
abetted, and
aided, abetted,
encouraged employees
employees of
Coffee
the
County
inside
Coffee
the
inside
machines
while
while
ballot
markers
and
machines
tabulating
and
electronic ballot markers tabulating
with electronic
tampering with
County
tampering
to effect
effect the
the
overt acts
acts to
Coffee County,
were overt
which were
County, Georgia,
Office inin Coffee
Elections
Registration Ofﬁce
Elections && Registration
Georgia, which
and
dignity
and
peace
tthe
laws
of
said
the
order,
good
the
State,
lawsofsaid
the
to
contrary
objectofthe
dignity
State,
good order, peace
conspiracy, contrary
object of the conspiracy,
thereof;
thereof;
9O

Page 91 COUNT 33 of
COUNT
of of Georgia, do
And
the Grand
in the
name and
behalf
ofthe
citizensofGeorgia,
do
of the citizens
Jurors aforesaid,
the name
and behalf
Grand Jurors
And the
aforesaid, in
ALSTON
CATHLEEN
KATHERINE
SIDNEY
and
accuse
charge
and
accuse
SIDNEY
KATHERINE
POWELL,
CATHLEEN
ALSTON
LATHAM,
LATHAM,
POWELL,
charge
TO
CONSPIRACY TO
of CONSPIRACY
the offense
offense of
with the
HAMPTON with
MISTY HAMPTON
and MISTY
HALL, and
GRAHAM HALL,
SCOTT
SCOTT GRAHAM
accused,
said accused,
the said
for the
& 21-2-574,
21-2-603 &
0.C.G.A. §§
FRAUD, O.C.G.A.
ELECTION FRAUD,
COMMIT ELECTION
COMMIT
21-2-574, for
§§ 21-2-with
with
and
together
and
a
crime,
a
of
of
commission
concerned
in
the
commission
the
persons concerned in
and asas persons
individually and
crime,
together
individually
the 1st
on and
and between
between the
Ist
of
on
in
the
Fulton
and
State
StateofGeorgia,
and
of
Fulton
Countyof
the
in
unindicted
unindicted co-conspirators,
Georgia,
co-conspirators,
County
and
to
day
of
December
and
the
7th
dayof
January
2021,
unlawfully
conspired
andagreedto
and
the
7th
of
December
agreed
day January 2021, unlawfully conspired
day of
care of
of
cause
conspiracy, who
law with
with the
the care
not officers
ofﬁcers charged
members of the conspiracy,
who were
were not
cause certain
certain membersofthe
by law
charged by
a
for
for
a
careofballots
the
care
of
ballots
the
with
with
officer
such
any
ofﬁcer
by
entrusted
entrusted
such
not persons
were not
who were
and who
ballots and
ballots
by any
persons
State of
of
the State
place inin the
polling place
ballots outsideofthe
official
to
ofﬁcial
ballots
outside of the polling
possess
to
law,
by
required
‘purpose
law,
by
posSess
required
purpose
Georgia;
Georgia;
with SullivanStrickler
SullivanStrickler
And
POWELL entered
entered into
into aa contract
contract with
KATHERINE POWELL
And SIDNEY
SIDNEY KATHERINE
LLC
LLC
in
Fulton
County,
Georgia,
delivered
a
payment
to
SullivanStrickler
LLC
inin Fulton
Fulton County,
LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler
County,
Fulton
from
Georgia,
and
caused
employeesofSullivanStrickler
LLC
to
travel
from
Fulton
County,
Georgia,
to
travel
of
LLC
caused
SullivanStrickler
and
Georgia,
County,
employees
Georgia,
who
members of the conspiracy,
to Coffee
for the
purpose of
of causing
causing certain
certain membersofthe
conspiracy, who
the purpose
Coffee County,
to
County, Georgia,
Georgia, for
entrusted by
not persons
were not
not ofﬁcers
officers charged
by law
the careofballots
and who
who were
were not
by
law with
with the
care of ballots and
were
persons entrusted
charged by
ballots
official
ofﬁcial
ballots
possess
to
to
law,
by
required
purpose
a
for
the
a
with
care
of
ballots
for
ofﬁcer withthecareofballots
such officer
any
possess
purpose required by law,
any such
of
the
the
which
acts
to
effect
were
overt
outside of the polling
outsideofthe
polling place,
which
were
overt
acts
to
effect
the
object
of
the
conspiracy;
conspiracy;
object
place,
MISTY
and MISTY
HALL, and
GRAHAM HALL,
SCOTT GRAHAM
LATHAM, SCOTT
And
ALSTON LATHAM,
CATHLEEN ALSTON
And CATHLEEN
LLC
in
accessing
in
LLC
SullivanStrickler
and
of
SullivanStrickler
employeesof
encouraged
and
abetted,
HAMPTON
aided,
HAMPTON aided, abetted, encouraged employees
accessing
Ofﬁce in
in Coffee
Coffee
election equipment
while inside
inside the
the Coffee
Elections && Registration
Coffee County
election
Registration Office
County Elections
equipment while
who
were
not
the
County,
Georgia,
for
the
purposeofcausing
certain
members
of
the
conspiracy,
who
were
not
of
the
of
certain
members
for
conspiracy,
causing
purpose
County, Georgia,
such
entrusted
not persons
officers charged
charged by
with the
the careofballots
who were
by any
any such
care of ballots and
and who
were not
law with
ofﬁcers
persons entrusted by
by law
outside of
of
ballots outside
official ballots
to possess
law, to
by law,
required by
care of ballots for
foraa purpose
with the
the careofballots
ofﬁcer
officer with
possess ofﬁcial
purpose required
to
the
the
to
contrary
the
conspiracy,
the
of
overt acts
acts to
effect the objectofthe
to effect
were overt
the
which were
place, which
polling place,
the polling
conspiracy, contrary
object
and
lawsofsaid
the good
order,
peace
and
dignity
thereof;
of said State,
laws
thereof;
State, the
order,
dignity
good
peace

Page 92 +
of COUNT COUNT
34ofof the citizensof
citizens of Georgia,
do
and behalf
Grand Jurors
And the
Jurors aforesaid,
And
the Grand
in the
the name
name and
behalf
ofthe
Georgia, do
aforesaid, in
ALSTON LATHAM,
and accuse
accuse SIDNEY
SIDNEY KATHERINE
CATHLEEN ALSTON
POWELL, CATHLEEN
KATHERINE POWELL,
LATHAM,
charge
charge and
of
TO
with
the
offense
CONSPIRACY
HAMPTON
GRAHAM HALL,
and MISTY
MISTY HAMPTON with the offense of CONSPIRACY TO
SCOTT
SCOTT GRAHAM
HALL, and
said accused,
& 16-9-93(a),
16-4-8 &
COMMIT COMPUTER
THEFT, 0.C.G.A.
§§ 16-4-16-9-93(a), for
or the
the said
COMPUTER THEFT,
O.C.G.A. §§
COMMIT
accused,
a
and
with
of
commission
and
as
concerned
in
the
individually
and
as
persons
concerned
in
the
commission
of
a
crime,
and
together
with
crime,
together
individually
persons
and between
1st
on and
and
State
of
Fulton
in
the
of
unindicted co-conspirators,
in
the
CountyofFulton
and
StateofGeorgia,
on
between the
the 1st
unindicted
Georgia,
co-conspirators,
County
a
to
use
of
of
December
and
the
7th
dayofDecember
and
the
7th
dayofJanuary
2021,
unlawfully
conspired
to
use
a
day January 2021, unlawfully conspired
day
the intention
and with
of taking
that such
was without
with knowledge
such use
computer with
knowledge that
use was
without authority
with the
intentionoftaking
authority and
computer
of
Dominion
the
and
and
and appropriating
information,
data,
and
software,
the
property
of
Dominion
Voting
Systems
software,
Voting Systems
property
appropriating information, data,
Corporation,
Corporation,
SullivanStrickler
contract with
entered into
SIDNEY KATHERINE
And
And SIDNEY
KATHERINE POWELL
POWELL entered
into aa contract
with SullivanStrickler
SullivanStrickler LLC
delivered aa payment
LLC
LLC inin Fulton
Fulton County,
Georgia, delivered
payment toto SullivanStrickler
LLC inin Fulton
Fulton County,
County,
County, Georgia,
Fulton
to
travel
from
LLC to travel from Fulton County,
caused employeesofSullivanSirickler
Georgia, and
and caused
County, Georgia,
Georgia,
employees of SullivanStrickler LLC
Georgia,
with
that
such
use
a
of
for
the
to Coffee
Coffee County,
Georgia,
for
the
purpose
of
using
a
computer
with
knowledge
that
such
use
to
knowledge
using computer
County, Georgia,
purpose
and
and
with
the
of
‘was
without authority
authority and with the intention
intentionoftaking
appropriating information,
information, data,
and
was without
data, and
taking and appropriating
which were
acts to
effect
of Dominion
software,
the property
property of
Dominion Voting
Voting Systems
Corporation, which
were overt
overt acts
to effect
software, the
Systems Corporation,
the
the objectofthe
object of the conspiracy;
conspiracy;
and MISTY
SCOTT GRAHAM
And
And CATHLEEN
CATHLEEN ALSTON
ALSTON LATHAM,
LATHAM, SCOTT
GRAHAM HALL,
HALL, and
MISTY
of SullivanStrickler LLC
HAMPTON aided,
abetted, and
employeesofSullivanStrickler
LLC inin using
and encouraged
HAMPTON
aided, abetted,
using aa
encouraged employees
the
of taking
and
with
intention
with
that
such
use
was
without
computer
with
knowledge
that
such
use
was
without
authority
and
with
the
intentionoftaking
authority
knowledge
computer
of Dominion
and appropriating
and
information, data,
and software,
software, the
the property
propertyof
Dominion Voting
Voting Systems
data, and
Systems
appropriating information,
Ofﬁce
in
Coffee
&
inside
the
Elections
while
Coffee
Corporation,
while
inside
the
Coffee
County
Elections
&
Registration
Office
in
Coffee
County,
Registration
County,
County
Corporation,
to
the
laws
of said
which were
were overt
overt acts
effect the
Georgia,
acts toto effect
the objectofthe
conspiracy, contrary
contrary to the lawsofsaid
object of the conspiracy,
Georgia, which
State,
the good
good order,
peace and
and dignity
dignity thereof;
thereof;
order, peace
State, the

Page 93 .
35 of
of COUNT COUNT
of the citizensofGeorgia,
citizens of Georgia, do
and behalf
in the
And
the Grand
Jurors aforesaid,
And the
Grand Jurors
the name
name and
behalf
ofthe
do
aforesaid, in
CATHLEEN
ALSTON
and
accuse
KATHERINE
SIDNEY
charge
and
accuse
SIDNEY
KATHERINE
POWELL,
CATHLEEN
ALSTON
LATHAM,
POWELL,
LATI-IAM,
charge
with the
offense of
of CONSPIRACY
HAMPTON with
and MISTY
SCOTT
GRAHAM HALL,
SCOTT GRAHAM
HALL, and
MISTY HAMPTON
the offense
CONSPIRACY TO
TO
said accused,
O.C.G.A. §§
COMMIT COMPUTER
COMPUTER TRESPASS,
TRESPASS, 0.C.G.A.
16-4-8 && 16-9-93(b),
16-9-93(b), for
for the
the said
COMMIT
accused,
§§ 16-4-and together
ofaa crime,
with
and as
as persons
concerned in
individually and
persons concerned
in the
the commission
commission of
together with
crime, and
individually
and State
State of
of Georgia,
on and
and between
of Fulton
unindicted co-conspirators,
‘unindicted
in the
the County
Fulton and
Georgia, on
between the
the lst
Ist
County of
co-conspirators, in
a
to
use
of
of
December
and
the
7th
day
of
December
and
the
7th
dayof
January
2021,
unlawfully
conspired
to
use
a
day January 2021, unlawfully conspired
day
the intention
of removing
with knowledge
that such
‘computer
knowledge that
such use
use was
was without
without authority
and with
with the
authority and
intentionofremoving
computer with
data
from
said
voter
Voter data
data and
and Dominion
Dominion Voting
Voting Systems
Corporation
data
from
said
computer;
computer;
Systems Corporation
entered into
SullivanStrickler
And
SIDNEY KATHERINE
KATHERINE POWELL
And SIDNEY
POWELL entered
intoaa contract
contract with
with SullivanStrickler
a
to
SullivanStrickler
LLC
LLC
Fulton County,
delivered a payment
LLC inin Fulton
County, Georgia,
payment to SullivanStrickler LLC inin Fulton
Fulton County,
County,
Georgia, delivered
from
LLC
to
travel
Fulton
and
SullivanStrickler
caused
of
Georgia,
and
caused
employees
of
SullivanStrickler
LLC
to
travel
from
Fulton
County,
Georgia,
Georgia,
County,
Georgia,
employees
of using
to
Coffee County,
to Coffee
County, Georgia,
for the
the purpose
purpose of
using aa computer
computer with
with knowledge
that such
such use
use
knowledge that
Georgia, for
of removing voter
data and
and Dominion
was
the intention
was without
without authority
authority and
and with
with the
intentionofremoving
voter data
Dominion Voting
Voting
overt acts
acts to
effect the
of the
data from
Systems
from said
said computer,
computer, which
which were
were overt
to effect
the object
objectofthe
Systems Corporation
Corporation data
conspiracy;
conspiracy;
SCOTT GRAHAM
GRAHAM HALL,
and MISTY
And
CATHLEEN ALSTON
And CATHLEEN
ALSTON LATHAM,
LATHAM, SCOTT
HALL, and
MISTY
of
SullivanStrickler
LLC
in
HAMPTON
and
HAMPTON aided,
abetted,
and
encouraged
employeesof
SullivanStrickler
LLC
in
using
aided, abetted,
using aa
encouraged employees
and with
with the
without authority
of removing
use was
computer with
with knowledge
that such
such use
was without
the intention
intentionofremoving
authority and
computer
knowledge that
data
from
said
while
inside
voter
data and
and Dominion
voter data
Dominion Voting
Systems
Corporation
data
from
said
computer,
while
inside the
the
computer,
Voting Systems Corporation
which were
Coffee
Ofﬁce in
Coffee County
Elections && Registration
in Coffee
Coffee County,
were overt
overt
County, Georgia,
Georgia, which
County Elections
Registration Office
to
the
laws
of
said
the
effect the
acts
of the conspiracy,
acts toto effect
the object
objectofthe
contrary
to
the
lawsofsaid
State,
the
good
order,
State,
order,
good
conspiracy, contrary
and dignity
peace and
thereof;
peace
dignity thereof;
9%

Page 94 36 of
of COUNT COUNT
do
‘And
the Grand
Jurors aforesaid,
aforesaid, inintthe
hename
behalf
ofthe
name and
and behalf
of the citizensofGeorgia,
citizens of Georgia, do
And the
Grand Jurors
LATHAM,
ALSTON
CAT HLEEN ALST
ON LATHAM,
POWELL, CATHLEEN
KATHERINE POWELL,
accuse SIDNEY
SIDNEY KATHERINE
and accuse
charge
charge and
TO
TO
CONSPIRACY
ofCONSPIRACY
offense
HAMPTON
withythe
offense
of
the
with
HAMPTON
MISTY
and MISTY
HALL, and
GRAHAM HALL,
SCOTT GRAHAM
SCOTT
for
16-9-93(c), for
O.C.G.A. §§
164-8 && 16-9-93(c),
OF PRIVACY,
PRIVACY, O.C.G.A.
INVASION OF
COMMIT COMPUTER
COMPUTER INVASION
COMMIT
§§ 16-4-and
the
accused, individually
individually and
persons concerned
in the
the commission
commission of
and
concerned in
ofaa crime,
and as
as persons
the said
said accused,
crime,
together
with
unindicted
co-conspirators,
in
the
County
of
Fulton
and
Stateof
Georgia,
on and
and
on
in
of
Fulton
and
State
of
the
unindicted
with
Georgia,
County
together
co-conspirators,
between
the lst
Ist dayof
December
and
the
7th
dayofJanuary
2021,
unlawfully
conspired
and
the
7th
of
December
between the
of
day January 2021, unlawfully conspired
day
that such
10to use
use acomputer
with the
the intention
intentionof
examining personal
personal voter
data with
with knowledge
knowledge that
such
voter data
of examining
a computer with
examination
examination was
was without
without authority;
authority;
And SIDNEY
KATHERINE POWELL
POWELL entered
contract with
with SullivanStrickler
entered into
into aa contract
SullivanStrickler
And
SIDNEY KATHERINE
delivered aa payment
LLC in
Fulton County,
LLC
in Fulton
County, Georgia,
payment toto SullivanStrickler
SullivanStrickler LLC
LLC inin Fulton
Fulton County,
County,
Georgia, delivered
Georgia,
County,
Fulton
from
to
from
travel
to
LLC
LLC
travel
Fulton
SullivanStrickler
of
SullivanStrickler
of
employees
caused
and
and
caused
Georgia,
Georgia,
County,
Georgia,
employees
with the
the intentionofexamining
intention of examining
to Coffee
County, Georgia,
Georgia, for
for the
the purposeof
using aa computer
to
Coffee County,
computer with
purpose of using
were
which were
such examination
examination was
without authority,
was without
that such
knowledge that
with knowledge
data with
voter data
personal voter
authority, which
personal
of the conspiracy;
overt
to effect
the object
objectofthe
overt acts
acts to
effect the
conspiracy;
And CATHLEEN
LATHAM, SCOTT
HALL, and
MISTY
GRAHAM HALL,
and MISTY
SCOTT GRAHAM
ALSTON LATHAM,
And
CAT HLEEN ALSTON
HAMPTON aided,
abetted, and
LLC inin using
using aa
SullivanStrickler LLC
and encouraged
HAMPTON
aided, abetted,
encouraged employeesof
employees of SullivanStrickler
that
such
computer
with
the
intention
of
examining
personal
voter
data
with
knowledge
that
such
voter
data
with
of
the
intention
with
knowledge
examining personal
computer
examination was
was without
inside the
the Coffee
County Elections
Elections && Registration
Registration
Coffee County
while inside
examination
without authority,
authority, while
conspiracy,
objectofthe
the
effect
overt
acts
to
effect
the
of
the
to
acts
overt
which
were
were
which
Georgia,
Ofﬁce in
in Coffee
Coffee County,
Office
conspiracy,
object
County, Georgia,
and dignity
contrary toto the
lawsofsaid
peace and
thereof;
the good
the laws
of said State,
order, peace
State, the
dignity thereof;
good order,
contrary
9%

Page 95 COUNT
37 of COUNT 37of
do
the name
name and
and behalf
And the
the Grand
Grand Jurors
of the citizensofGeorgia,
citizens of Georgia, do
And
Jurors aforesaid,
aforesaid, inin the
behalf
ofthe
SIDNEY KATHERINE
CATHLEEN ALSTON
charge
and accuse
accuse SIDNEY
KATHERINE POWELL,
ALSTON LATHAM,
LATHAM,
POWELL, CATHLEEN
charge and
TO
of CONSPIRACY TO
SCOTT GRAHAM
the offense
SCOTT
GRAHAM HALL,
HALL, and
and MISTY
MISTY HAMPTON
HAMPTON with
with the
offense ofCONSPIRACY
O.C.G.A. §§ 16-10-21,
DEFRAUD THE
THE STATE,
said accused,
DEFRAUD
STATE, O.C.G.A.
16-10-21, for
for the
the said
individually and
and asas
accused, individually
of
a
and
in
the
commission
with
unindicted
concerned
persons
concerned
in
the
commission
of
a
crime,
and
together
with
unindicted
co-conspirators,
in
crime,
co-conspirators, in
together
persons
on
and
and
and State
State of
of Georgia,
the
1st day
the County
of Fulton
Fulton and
between the
the 1st
of December
December 2020 and
Georgia, on and between
County of
day of
and
to
theft
of voter data,
the 7th
of
commit
the
7th dayofJanuary
2021,
unlawfully
conspired
and
agreed
to
commit
theft ofvoter
data,
2021,
unlawfully conspired
agreed
day January
a
state
the
control
of
was under
State Brad
property which
which was
under the control of Georgia
Brad Raffensperger,
Raffensperger,a state:
Georgia Secretaryof
Secretary of State
property
ofﬁcial capacity;
officer, inin his
his official
officer,
capacity;
entered into
with SullivanStrickler
SullivanStrickler
And SIDNEY
contract with
And
SIDNEY KATHERINE
KATHERINE POWELL
POWELL entered
intoaa contract
a
delivered
to
SullivanStrickler
LLC
LLC
LLC inin Fulton
Fulton County,
Georgia,
delivered
a
payment
to
SullivanStrickler
LLC
inin Fulton
Fulton County,
payment
County,
County, Georgia,
from Fulton
and caused
caused employees
Georgia, and
of SullivanStrickler
SullivanStrickler LLC
LLC toto travel
travel from
Fulton County,
Georgia,
County, Georgia,
Georgia,
employees of
of committing theft
was
to
of voter
voter data,
to Coffee
Coffee County,
for the
the purpose
purpose ofcommitting
theft of
data, property
property which
which was
Georgia, for
County, Georgia,
ofﬁcial
under
state office,
under the
the control
control of
of Georgia
of State
State Brad
Brad Raffensperger,
Raffenspenger,aa sate
in his
his official
officer, in
Georgia Secretary
Secretary of
the
overt
acts
to
effect
of
the
which
were
capacity,
objectofthe conspiracy;
capacity, which were overt acts to effect the object
conspiracy;
SCOTT GRAHAM
and MISTY
ALSTON LATHAM,
And
CATHLEEN ALSTON
And CATHLEEN
LATHAM, SCOTT
GRAHAM HALL,
HALL, and
MISTY
and encouraged
HAMPTON
SullivanStrickler LLC
HAMPTON aided,
aided, abetted,
abetted, and
LLC inin accessing
accessing
encouraged employeesof
employees of SullivanStrickler
the
while
inside
Coffee
Ofﬁce
in
election equipment
Elections
&
election
while
inside
the
Coffee
County
Elections
&
Registration
Office
in
Douglas,
Douglas,
County
Registration
equipment
theft
of
the
the
of
voter
was
under
Georgia,
for the purpose
purposeofcommitting
property which
which was under the control
control
data, property
committing theft ofvoter data,
Georgia, for
State
Brad
a
which
of
of
state
in
his
ofﬁcial
of Georgia
Georgia Secretaryof
State
Brad
Raffensperger,a
state
officer,
in
his
official
capacity,
which
officer,
Raffensperger,
Secretary
capacity,
were
overt acts
acts to
to effect
of said Stat,
were overt
effect the
the objectofthe
conspiracy, contrary
contrary toto the
the laws
lawsofsaid
the good
good
State, the
object of the conspiracy,
and dignity
order, peace
peace and
dignity thereof;
thereof
order,
COUNT
38 of
of COUNT
‘And the Grand Jurors aforeseid, in the name and behalf
ofthe citizensofGeorgia, do
charge and accuse DONALD JOHN TRUMP with the offenseofSOLICITATION OF
VIOLATION OF OATH BY PUBLIC OFFICER, 0.C.G.A. §§ 164-7 and 16-10-1, for the
said accused, in the CountyofFulton and StateofGeorgia, on or about the 17th day of
September 2021, unlawfully solicited, requested, and importuned Georgia Secretary of State.
Brad Raffenspenger,a public officer, to engage in conduct constituting the felony offense of
ViolationofOathby Public Officer, 0.C.G.A. § 16-10-1, by unlawfully “decertifying the
Election, or whatever the correct legal remedy is, and announce the true winner,” in willful and
intentional violationofthe termsofthe oathofsaid person as prescribed by law; with intent that
said person engage in said conduct, contrary to the lawsofsaid State, the good order, peace and
dignity thereof;
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
charge and accuse DONALD JOHN TRUMP with the offense of SOLICITATION OF
VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 and 16-10-1, for the
said accused, in the County of Fulton and State of Georgia, on or about the 17th day of
September 2021, unlawfully solicited, requested, and importuned 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. § 16-101, by unlawfully "decertifying the
Election, or whatever the correct legal remedy is, and announce the true winner," 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, contrary to the laws of said State, the good order, peace and
dignity thereof;

Page 96 COUNT
39 of
0f COUNT
And the Grand Jurors aforesaid, in the name and behalf
ofthe citizensofGeorgia, do
charge and accuse DONALD JOHN TRUMP with the offense of FALSE STATEMENTS
AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the CountyofFulton and
StateofGeorgia, on or about the 17th day of September 2021, knowingly, willfully, and
unlawfully made the following fase statement and representation to Georgia Secretary of State
Brad
Brad Raffensperger:
Raffensperger:
than
number of false and/or
and/or irregular
far greater
"As stated
stated to
votes isis far
l.1. “As
regular votes
the numberoffalse
greater than
previously, the
to you
you previously,
the
election
to
needed
needed to change
result”;
Georgia election result";
change the Georgia
of State and
within thejurisdictionofthe
the jurisdiction of the Officeofthe
Oﬁice of the Georgia
and
statement being
SecretaryofState
said statement
being within
said
Georgia Secretary
and
of state government,
and agencies
of Investigation,
county
the
agenciesofsate
departments and
Investigation, departments
Bureau of
government, and county
the Georgia
Georgia Bureau
and
the
to
the
laws
of
said
enforcement
and city
law
enforcement
agencies,
contrary
to
the
lawsofsaid
State,
the
good
order,
peace
and.
and
law
order,
State,
peace
good
agencies, contrary
city
dignity thereof;
thereof;
dignity
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
charge and accuse DONALD JOHN TRUMP with the offense of FALSE STATEMENTS
AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and
State of Georgia, on or about the 17th day of September 2021, knowingly, willfully, and
unlawfully made the following false statement and representation to Georgia Secretary of State
COUNT 40of
40 of COUNT
do
the citizensofGeorgia,
citizens of Georgia, do
the name
Grand Jurors
And the
the Grand
Jurors aforesaid,
aforesaid, inin the
name and
and behalf
behalf
ofofthe
And
STATEMENTS
of
FALSE
JANIES
SHAFER
with
the
offense
DAVID
charge
and
accuse
DAVID
JAMES
SHAFER
with
the
offense
of
FALSE
STATEMENTS
and
accuse
charge
and
in the
O.C.G.A. §§ 16-10-20,
said accused,
AND WRITINGS,
16-10-20, for
for the
the said
the County
of Fulton
Fulton and
AND
accused, in
WRITINGS, 0.C.G.A.
County of
and
the
25th
of
on
or
about
Stateof
on
or
about
the
25th
dayof
April
2022,
knowingly,
willfully,
and
unlawfully
State of Georgia,
unlawfully
day April 2022, knowingly, willfully,
Georgia,
Fulton
made
least oneofthe
one of the following
made atat least
following false
false statements
statements and
and representations
representations inin the
the presence
presenceofof Fulton
Office
District
County
Attorney's Office investigators:
investigators:
County District Attorney's
of Trump presidential
and convened”
convened" the
the December
presidential
meetingofTrump
That he
2020, meeting
1.
December 14,
“attended and
he "attended
1. That
14, 2020,
the
each
of
not
"call
in
Fulton
but
that
he
did
elector nominees
Georgia, but that he did not “call eachofthe
nominees in Fulton County,
elector
County, Georgia,
the other
other preparations
make anyof
and notify
them
of the meeting
or make
individual
members and
themofthe
meeting or
preparations
individual members
any ofthe
notify
the
necessary for
for the meeting”;
meeting";
necessary
at the
the December
2.2. That
Thataa court
court reporter
reporter was
was not
not present
December 14,
14, 2020,
2020, meeting
meetingofof Trump.
Trump
present at
nominees in
Fulton County,
presidential elector
elector nominees
in Fulton
Georgia;
County, Georgia;
presidential
of the Fulton
District Attorneys
said
statements being
said statements
being within
within the
the jurisdiction
jurisdictionofthe
Fulton County
Ofﬁce, aa
Attorney's Office,
County District
said
ofaa countyofthis
department
to the
the laws
lawsofof said
and agencyofthe
state, contrary
contrary to
government of
county of this state,
agency of the government
department and
and
State,
the
good
order,peaceand
dignity
thereof;
the
State,
dignity thereof;
good order, peace
'
9%

Page 97 of COUNT
41 of
COUNT do
of the citizens
Grand Jurors
Jurors aforesaid,
in the
the name
And
the Grand
aforesaid, in
name and
and behalf
behalf
ofthe
citizensofof Georgia,
And the
Georgia, do
of PERJURY, O.C.G.A.
with the
accuse ROBERT
CHEELEY with
and accuse
charge and
ROBERT DAVID
DAVID CHEELEY
the offense
offenseofPERJURY,
0.C.G.A. §§
charge
on
or
about the
of
and
State
Fulton
for
the
said
in
the
of
16-10-70(a),
for
the
said
accused,
in
the
County
of
Fulton
and
StateofGeorgia,
on
or
about
the
Georgia,
accused,
County
16-10-70(a),
least oneofthe
one of the
made at
at least
and unlawfully
15th dayof
2022, knowingly,
knowingly, willfully,
willfully, and
unlawfully made
15th
September 2022,
day of September
a
Grand
false
statements
before
the
Fulton
following
false
statements
before
the
Futon
County
Special
Purpose
Grand
Jury,
ajudicial
Jury, judicial
County Special Purpose
following
been
administered
a
lawﬁll
oath:
after
proceeding,after
having
been
administered
a
lawful
oath:
having
proceeding,
elector
unaware of the December
he was
was unawareofthe
December l4,
14, 2020,
2020, meeting
meetingofof Trump
presidential elector
l.1. That
That he
Trump presidential
after the
until after
‘nominees
in Fulton
Fulton County,
the meeting
meeting had
had already
already taken
taken place;
place;
nominees in
County, Georgia,
Georgia, until
December l4,
substantive conversations
had no
2. That
he had
no substantive
conversations with
with anyone
anyone concerning
the December
14,
That he
concerning the
Fulton
in
elector
nominees
2020, meetingof
presidential elector nominees in Fulton County,
until
County, Georgia,
Georgia, until
2020,
meeting of Trump
Trump presidential
after the
the meeting
after
meeting had
had already
already taken
taken place;
place;
nominces inin
elector nominees
he never suggested
presidential elector
the Trump
that the
anyone that
to anyone
henever
That
3. That
suggested to
Trump presidential
meet
should
on
December
Georgia should meet on December l4,
14, 2020;
2020;
Georgia
the November
November 3,
with John
Eastman concerning
4.4 That
That the
the only
communication he
he had
had with
John Eastman
3,
concerning the
only communication
Senator
Eastman to
was for
of connecting
2020,
presidential election
election was
for the
the purpose
purposeof
connecting Eastman
to Georgia
Georgia Senator
2020, presidential
whose
is
known
to
Individual
Beach and
and unindicted
Brandon Beach
unindicted co-conspirator
Individual
8,
whose
identity
is
known
to
Brandon
8,
identity
co-conspirator
the Grand
the
Grand Jury,
Jury, for
for possible
possible legal
legal representation;
representation;
other than
than
with any
connect John
Eastman with
That he
5.5 That
he never
never worked
worked toto connect
John Eastman
legislators other
Georgia legislators
any Georgia
Individual 8,
and unindicted
whose
Senator Brandon
Beach and
co-conspirator Individual
unindicted coconspirator
8, whose
Brandon Beach
Georgia
Georgia Senator
identity isis known
known toto the
the Grand
Grand Jury;
Jury;
identity
material to
to the
the accused’s
accused's own
own involvement
said
involvement inin the
the December
December 14,
said statements
statements being
l4, 2020,
2020,
being material
and
to
the
accused's
in
Fulton
elector
nominees
‘meetingof
Trump
presidential
elector
nominees
in
Fulton
County,
Georgia,
and
to
the
acused’s
of
Georgia,
County,
Trump presidential
meeting
to
the
others involved
involved in
in said
said meeting,
communications with
communications
with others
meeting, the
the issues
issues inin question,
contrary
to
the laws
laws
question, contrary
the good
and dignity
of said State,
ofsaid
State, the
thereof.
order, peace
good order,
peace and
dignity thereof.
FANI T. WILLIS,
FANIT.
WILLIS, District
District Attorney
Attorney

Page 98 WITNESS LIST
WITNESS
LIST
Asst.Chief Inv.M. Hill ~ FCDA
FCDA DADA
Asst. Chief Inv. M. Hill

FCDA DASt.
Swanson-Lucas - FCDA
DATT. Swanson-Lucas
Sr. Inv.
Inv. T.

9%
i

PDF Page 1	PlainSite Cover Page

PDF Page 2	Fulton Fulton County Superior Colinty Superior Court Court wrlepech CA F\|LED INDICTMENT INDICTMENT oo , 2023 Date: Date: August 14, 2023 August 14, Che Alexander, Clerk of of Court Court Che Alexander, Clerk 66 =. Mozzfee EO £375Maker wqé/7 Clerk BISSM7 Clerk No. No. COURT FULTON SUPERIOR COURT FULTON SUPERIOR THE STATE OF GEORGIA ‘THE 1 1 V. v. TRUMP DONALD JOHN JOHN TRUMP DONALD Couhts 1,5, 15, 17, 19, Counts 1,5,9,9, 11, 11, 13, 13,15, 17,19, 38-39 2729, 21.29,3839 WILLIAM LOUIS RUDOLPH WILLIAM RUDOLPH LOUIS GIULIANI GIULIANI Counts 1-3, Counts 13, 67,9, 11, 13,15, 17, 19, 6-7, 9,11,13,15,17,19, 52 CI-MRLES EASTMAN JOHN CHARLES JOHN EASTMAN 23-24 VIOLATION OF THE GEORGIA RICO CORRUPT AND CORRUPT INFLUENCED AND (RACKETEER (RACKETEER INFLUENCED ORGANIZATIONS) ACT ACT ORGANIZATIONS) O.C.G.A. O.CG.A. §§ 16144(c) 16-14-4(c) 2 SOLICITATION SOLICITATION OF OF OATH VIOLATION OF OF VIOLATION OATH BY PUBLIC OFFICER OFFICER BY PUBLIC 2 O.C.G.A. OCGA. §§ 164-7 & & 1640-1 16-10-1 §§ 164-7 3 FALSE STATEMENTS AND WRITINGS OCGA. O.C.G.A. §§ 16-10-20 16-1020 MARK MARK RANDALL RANDALL MEADOWS MEADOWS 28 Counts 1,28 Counts WRITINGS 4 FALSE AND WRITINGS FALSE STATEMENTS STATEMENTS AND OCGA 1610-20 O.C.G.A. §161020 OF OATH 5 SOLICITATION OF 5 SOLICITATION OF VIOLATION VIOLATION OF OATH BY PUBLIC OFFICER BY PUBLIC OFFICER OCGA. §§ 16-47 16-47 &16-10-1 & 16101 O.C.G.A. §§ KENNETH JOHN CHESEBRO 6 27 Counts Counts 1-2, 12,9, 11,13, 15, 17, 19, 19,27 15, 17, 9, 11,13, 1, Counts 1, Counts 1,9,9,11,13,15,17,19 11,13, 15, 17,19 JEFFREY BOSSERT CLARK JEFFREY 22 Counts 1, Counts 1,22 4 § OF OATH OF VIOLATION SOLICITATION OF SOLICITATION VIOLATION OF OATH BY PUBLIC OFFICER OFFICER BY PUBLIC O.C.G.A. §§ OCGA. 164-7 && 1610-1 16-10-1 §§ 164-7 77 WRITINGS FALSE STATEMENTS AND FALSE STATEMENTS AND WRITINGS O.C.G.A. §§ 16102'0 O.CG.A. 16-10-20 LYNN ELLIS JENNA LYNN JENNA ELLIS Counts 12 1-2 8 SNIITH III III STALLINGS SMITH RAY STALLINGS RAY Counts 12,4,6,9, 1-2, 4, 6, 9, 11, 13,15, 17,19, Counts 11,13,15,17,19, TO COMMIT COMMIT 9 CONSPIRACY CONSPIRACY TO CHEELEY DAVID CHEELEY ROBERT DAVID ROBERT Counts 1,9,11,13,15,17,19,23,26, Counts 9,11,13, 15, 17,19, 23, 26, 10 l0 FORGERY IN THE FIRST FORGERY INTHE FIRST DEGREE DEGREE 23, 25 2,25 a 1, 41 MICHAEL A. ROMAN Counts 1, 9, 11,13,15,17, Counts1,9, 11,13, 15,17, 19 19 DAVID JAMES SHAFER DAVID JAMES SHAFER Counts 1,8,10, Counts 12, 14, 16, 18, 40 40 8,10,12,14,16,18, 1, A PUBLIC OFFICER IMPERSONATING IMPERSONATING A O.C.G.A. OCGA. §16-1023 § 16-1023 GA A PUBLIC INIPERSONATIN IMPERSONATING PUBLIC OFFICER OFFICER & 16-10-23 O.C.G.A. 164-8 OCGA. §§ §§ 16-4-8 & 16-10-23 O.C.G.A. §169-1(b) § 169-1(b) OCGA. 11 11 To COMMIT CONSPIRACY TO FORGERYINTHE FIRST DEGREE DEGREE FORGERY 1N THE FIRST O.C.G.A. §§ OCGA. §§ 16-48 164-8 && 16-9-1(b) 16-9-1(b)

PDF Page 3	WRITINGS FALSE STATEMENTS SHAWN MCAH TRESHER STILL A — STEPHEN CLIFFGARD LEE CONSPIRACY TO SEOENCUNGIDLE 15 CONSPIRACYTOCONMIT WRITINGS STATEMENTS FALSE BRERA SE mes HARRISON PRESCOTT HARRISON WILLIAM WILLIAMPRESCOTT CRWAL ATTEMPT To COMMIT FLOYD Emma FALSE DOCUMENTS Tear) KUTTI TREVIAN C.KUTTI REvIAN CONSPIRACY TO COMMIT Emma FALSE DOCUMENTS Ea socom SIDNEY KATHERINE POWELL AND 12 Counts 1, Counts 1,8, 10, 12, 12, 14, 14,16, 18 8, 10, 16, 18 O.C.G.A. § 16-1020 OCGA.§ 16-10-20 13 COMlWIT AND & 161020 O.C.G.A. OCGA. §§ 16-4-8 & 16-10-20 §§ 1648 14 14 CRIMINAL ATTEMPT TO COMMIT FILING FALSE DOCUMENTS O.C.G.A. §§ 1641 & 16102o.1(b)(1) Counts 1, 20-21, 30-31 FLOYD Counts 1,30-31 Counts 1, 3031 C. Counts 1, 3031 15 SIDNEY KATHERINE POWELL Counts 1,32:37 Counts 1, 32-37 CATHLEEN ALSTON LATHAM 'CATHLEEN Counts 1, 8, 10, 12, 14, 32-37 SCOTT GRAHAM SCOTT GRAHAM HALL 32-37 Counts 1, Couns 1, 32:37 O.C.G.A. OCGA. §§ 16-4-8 & 16-10-20.1(b)(1) 16102o.1(b)(1) §§ 164-8 16 16 FORGERY IN THE FIRST DEGREE O.C.G.A. 0.CGA. §§16-9-1(b) 16-9-1(b) CONSPIRACY TO COMMIT ST— THE FIRST m THE FORGERY IN FORGERY FIRST DEGREE DEGREE 17 . I— TwiNMoNvaAYEs Pane MISTY HAMPTON AKA EMILY MISTY HAYES & 1691(b) 16-48 & O.C.G.A. §§ OCGA. §§ 164-8 16-9-1(b) WRITINGS STATEMENTS 18 FALSE FALSESTATEMENTSANDWRITINGS AND 18 O_C_G_A. § 16_10_20 Counts 1, 32-37 19 19 CONSPIRACY TO iEB neves COMlVIIT CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS & 16-10-20 O.C.G.A. 0.CG.A. §§ 16-4-8 & 16-10-20 §§ 16-4-8 20 20 CRIMINAL ATTEMPT TO COMMIT INFLUENCING INFLUENCING WITNESSES WITNESSES O.C.G.A. OCGA. §§ 164-1 & 161093(b)(1)(A) 16-10-93(b)(1XA) §§ 16-41 21 21 TO COMMIT CRIMINAL ATTEMPT ATTEMPTTO INFLUENCUYG WITNESSES ms O.C.G.A. §§ OCGA 16-41 & 16-10-93(b)(1)(A) 16-10-93BX1)A) §§ 16-4-1& FALSE STATEMENTS me BE ,mums OF VIOLATION OFONE OF OATH SOLICITATIONCrVIOLATION 2 SOTTO BY PUBLIC OFFICER mE DE STATENIENTSANDWRITINGS WRITINGS 24 FALSE FALSE STATEMENTS STATEMENTS AND WRITINGS 25 FALSE FALSE STATEMENTS WRITINGS ERATE 22 22 CRIMINAL ATTEMPT ATTEMPT TO COMMIT CRIMINAL AND O.C.G.A. §§ 16-41 & 161020 23 O.C.G.A. §§ 16-47 & 16-10-1 AND 24 O.C.G.A. § 16-1020 AND 25 O.C.G.A. 2 ' § 161020

PDF Page 4	WRITINGS STATEMENTS AND 26 FALSE 26 FALSE STATEMENTS AND WRITINGS 16-10-20 O.C.G.A. 0CGA§§ 16-1020 27 FILING 27 FILING FALSE FALSE DOCUMENTS DOCUMENTS O.C.G.A. 0.CGA.§§ 16-1020.1(b)(1) 16-10-20.1(bX1) OF VIOLATION VIOLATION OF OATH 28 SOLICITATION 28 SOLICITATION OF OF OATH OFFICER BY PUBLIC OFFICER BY PUBLIC O.C.G.A. OCGA. §§ 164-7 && 16-10-1 16-10-1 §§ 164-7 STATEMENTS AND 29 29 FALSE FALSE STATEMENTS AND WRITINGS WRITINGS 16-10-20 OCGA. O.C.G.A. §§ 16-1020 COMlVIIT SOLICITATION SOLICITATION OF 30 CONSPIRACY TO 30 CONSPIRACY TO COMMIT OF AND STATEMENTS WRITINGS FALSE FALSE STATEMENTS AND WRITINGS O.C.G.A. §§ OCGA. §§ 164-8, 16-4-7 && 16-10-20 16-10-20 16-4-8, 16-4-7 WITNESSES 31 31 INFLUENcmG INFLUENCING WITNESSES O.C.G.A. §§ 161093(b)(1)(A) OCGA. 16-10-93bX1)A) TO COMMIT COMMIT ELECTION FRAUD CONSPIRACY TO 32 CONSPIRACY 32 ELECTION FRAUD 21-2603 & 21-2-566 O.C.G.A. §§ OCGA. §§212:603 & 212-566 TO CONIMIT ELECTION CONSPIRACYTOCOMMIT 33 CONSPIRACY 33 ELECTION FRAUD FRAUD 21-2-574 O.C.G.A. §§21-2:603 OCGA & 212-574 §§ 21-2-603 & COMMIT CONSPIRACY TO To COMMIT 34 CONSPIRACY 34 THEFT COMPUTER COMPUTER THEFT O.C.G.A. §§ 169-932) 164-8 && 16993(a) OCGA §§ 1648 TO COMlVIIT CONSPIRACY TO 35 CONSPIRACY 35 COMMIT COMPUTER TRESPASS COMPUTER TRESPASS O.C.G.A. O.CGA §§ 164-8 && 16-9-93(b) 16:9-93(6) §§ 16-4-8 TO COMIVIIT 36 36 CONSPIRACY CONSPIRACY TO COMMIT PRIVACY COMPUTER COMPUTER INVASION INVASION OF OF PRIVACY O.C.G.A. §§ OCGA. 164-8 && 169-93(c) 16:9:93(c) §§ 16-4-8 DEFRAUD THE TIE STATE STATE 37 37 CONSPIRACY CONSPIRACY TO TO DEFRAUD O.C.G.A. §§ 16-1021 OCGA 16-1021 OATH 38 SOLICITATION SOLICITATION OF 38 OF VIOLATION VIOLATION OF OF OATH BY PUBLIC OFFICER BY PUBLIC OFFICER & 16101 O.C.G.A. §§ 16-47 & OCGA §§ 16-47 16-10-1 39 FALSE 39 FALSE STATEMENTS STATEMENTS AND AND WRITINGS WRITINGS O.C.G.A. §§ 16-1020 OCGA. 16:10:20 STATEMENTS AND 40 FALSE 40 FALSE STATEMENTS AND WRITINGS WRITINGS O.C.G.A. § 161020 OCGA.§ 16:10:20 3

PDF Page 5	si PERJURY PERIURY o.c.G.A. § 161070(a) OCGA. 16-10-70) 41 Ts, § 'Z BILL 2023 prsI — 2ToT Jury Torspersn Foreperson 5% FANIT. WILLIS Distict Atorney FANI T. WILLIS, District Attorney The of copy ofof The Defendant waives copy Defendant waives The Defendant The Defendant Defendant waives waives copy Defendant waives of The waives copy “The copy of copy of of witnesses, list ofwilneses, of witnesses, of witnesses, indictment list lsofwitesses, indictment, st indictment, ist ofwitnesses, indictment, list indictment, indictment, and pleads and pleads formal arraignment and formal arraignment formal and pleads formalaraignment pleads formal armsignment and pleads formalarraignment pleads arraignment and Guity. Guy. Guy. Guilty. Guilty. Guilty. a Defendant Defendant Defendant for Defendant Aormey or Defendant Aireyfor Defendant Aiomey Defendant or Defendant Attorney Attorney for Attorney for Defendant AsnDieAomey Assistant District Attorney This This__dayof day of Avian DictAdorey of This Ths_day day of Assistant District Attorney , , 44 Assistant District Attorney AssanDiverAomey This of This__day day of ,

PDF Page 6	waives copy The Defendant waives of ‘The Defendant waives copy of TheDefendant copy of list of indictment, indictment, listofwitnesses, witnesses, indictment, listofwitnesses, formal and pleads pleads and pleads formal formal arraignment arraignment and araignment and formal arraignment pleads Guilty. Guy. Guilty. Guilty. The Defendant waives copy of indictment, list of witnesses, The Defendant waives copy of indictment, lst ofwitnesses, and pleads formal arraignment and formal arraignment pleads Gui. Guilty. The Defendant waives copy of indictment list of witnesses, Defedm Defendant Defendant Defendant Defends Defendant forDefendanty Atorme for Defendant ey Ritom AttorneyforDefendant Attorney for Defendant Attorney for Defendant Assistant District Aorney \| DistrictAttorney Assan of This “This_day day of Reson Disvict Alormey of “This__day This day of Assistant District Attorney , of waives copy Defendant waives ‘The The Defendant copy of list of ofwitnesses, list indictment, witnesses, indictment, pleads formal and pleads formal arraignment arraignment and Guilty. Guilty. The Defendant of copy of waives copy Defendant waives The list of ofwitnesses, lst indictment, indictment, witnesses, and pleads formal arraignment pleads formal arraignment and Guilty. Guilty. ant Defendant Defend Defendant for Defendant ey Ritom AttorneyforDefendant Attorney for Defendant AssisantDirct Atorney of This “This_day day of Assistant District Attorney , The Defendant waives copy of indictment, fst ofwitnesses, formal pleads and pleads formal amaignment arraignment and Guilty. Guilty. The Defendant waives copy of indictment, list of witnesses, TT Defendant Deda AtomeyforDefendant for Defendanty Atame AttorneyforDefendant Defendant AssistantDisinctAorney This of This_day day of Assistant District Attorney AssistantDistAtiorney of This_day This day of. Defendant Atomeyfor Assistant District Attorney , of TheDefendant The Defendant waives of The Defendant waives copy copy of waives copy Defendant waives ‘The copy of indictmentlistof listofwitnesses, indictment, list of witnesses, witnesses, indictment, list of witnesses, indictment, and pleads pleads and pleads formal formal arraignment pleads formal arraignment and formal arraignment arraignment and Guilty. Guy. Guilty. Guilty. Assistant District Attorney Aomey AssistantDisrict This of “This_day day of of waives copy The Defendant Defendant waives The copy of ofwitnesses, fst of indictment, list witnesses, indictment, and pleads pleads formal arraignment and arraignment formal Guy. Guilty. ____ Defendant Defndat Defendant Deda Defendant for Defendant y Rtome AttorneyforDefendant Attorney for Defendant AtomeyforDefendant Attorney for Defendant Assistant District Attorney AssistantDistAtiomey This This_dayof day of Assistant Disirct Aliorney This “This_dayof , day of Assistant District Attorney , 5 5 Deeds forDefendantey Attom District Attorney ant AssistantDistrictAomey Assist of This “This__day dayof ,

PDF Page 7	The Defendant of waives copy Defendant waives The copy of of witnesses, indictment,list indictment, list ofwitnesses, formal pleads and pleads formal arraignment arraignment and Guilty. Guilty. of The Defendant waives copy Defendant waives The copy of list of indictment, indictment, lst ofwitnesses, witnesses, and pleads formal arraignment pleads arraignment and formal Guile. Guilty. waives copy The Defendant of Defendant waives The copy of of list ofwitnesses, lst indictment, witnesses, indictment, and pleads pleads formal formal arraignment arraignment and Guilty. Guilty. Defendant Defendant Defendant Defendant Defendant Defendam for Defendant forDefendant Attomey Attorney for Defendant Atomey AttorneyforDefendant Defendant Auomeyfor Attorney for Defendant Assistant District Attorney ney Assistant District Attorney \|AsssuntDistrictAtor Assiun(DiswctAtomey This This dayof day of ‘The Defendantwaivescopyof indictment listofwitnesses, and pleads formal pleads araignment and formal arraignment Guilty. Guilty. The Defendant waives copy of indictment, list of witnesses, Defendant Defendant forDefendant ‘Attomey Attorney for Defendant Assistant District Attorney Atormey AssistantDisiet of ‘This_day This day of. This dof Ths day of , AssistantDistrict District Atiomey Assistant Attorney This _dwol Ths day of , of The Defendant waives The Defendant of waivescopy TheDefendant copy of waives copy Defendant waives The copy of list of list ofwitnesses, of witnesses, ofwitnesscs, indictment, lst indictment, list witnesses, indictment, indictment, and pleads formal formal and pleads pleads formal arraignment formal arraignment arraignment and arraignment and pleads Guilty. Gily. Guilty. Guilty. Defendant Defendant Defendant Defendant ‘AttomeyforDefendant Attorney for Defendant Assistant District Attorney ResistDistAtomey This of “This__day day of , RitomeyforDefendant Attorney for Defendant Assistant District Aorey This of “This__day day of Assistant District Attorney , The Defendant waives copy of indictment, list ofwitnesses, formal arraignment and pleads Guilty. The Defendant of waives copy Defendant waives The copy of ofwitnesses, lst of indictment, list indictment, witnesses, formal and pleads pleads arraignment and formal arraignment Guilty. Guilty. The Defendant waives copy of indictment, list of witnesses, formal arraignment and pleads Guilty. Defendant Defdam Defendant Dean for Defendant ‘Ritormey AttorneyforDefendant for Defendant Ritormey AttorneyforDefendant Defendant efendant Atomeyfor Attorney forD AssistantDist Atorey of “This_day This day of AssistantDistrict Atiomey of This This_day day of Assistant District Attorney ResisiantDisc Attorney of This This_day day of, ‘The Defendant waives copy of indictment list ofwitnesses, pleads and pleads formal arraignment formal arraignment and Guilty. Guilty. The Defendant waives copy of indictment, list of witnesses, Defendant Deed Assistant District Attorney Assistant District Attorney , 6 6 ,

PDF Page 8	of The Defendant copy of waives copy Defendant waives The list of witnesses, indictment, listofwitnesses, indictment, arraignment and formal arraignment and pleads formal pleads Guilty. Guilty. The Defendant waives copy of Defendant waives The copy of of witnesses, lisofwitnesses, indictment, list indictment, pleads and pleads formal arraignment formal arraignment and Guilty. Guilty. waives copy The Defendant of Defendant waives The copy of list of witnesses, indictment, indictment listofwitnesses, and pleads formal pleads formal amaignment arraignment and Guilty. Guilty. Defendant Defendant Defendant Defendant Defendant Defendant for Defendant Riomey AttorneyforDefendant for Defendant Defendant Riomey Attorney for for Defendant Defendant Aomey Attorneyfor AssistantDistrict Atormey of ‘This_day This day of Assistant District Attorney ‘The Defendant waives copy of indictment, listofwitnesses, and pleads formal pleads formal araignment arraignment and Guilty. Guilty. The Defendant waives copy of indictment, list of witnesses, District Assistant Dist Attorney Atomey DistictAtiomey \|Assistant Resistant This of This of “This_day day This_ day of, day of Assistant District Attorney , , The Defendant waives copy of indictment, lst ofwitnesses, formal and pleads formal araignment arraignment and pleads Guily. Guilty. The Defendant waives copy of indictment, list of witnesses, of The Defendant waives copy Defendant waives The copy of of list ofwitnesses, list indictment, indictment, witnesses, and pleads formal araignment formal arraignment and pleads Guily. Guilty. Defendamt Defendant Defend Defendant Defendant Defendant Defendant Atomeyfor Attorney for Defendant for Defendant Atomey AttomeyforDefendant for Defendant Defendant Atomeyfor Attorney Assistant District Attorney AssistantDistrictAttorney Assistant DisrictAttomey District Attorney Assistant Assistant DistrictAttorney District Attorney Assistant Ths This dayof day of This__dayof This day of , This dof, Ths day of , The Defendant waives copy of indictment, list of witnesses, formal arraignment and pleads Guilty. The Defendant waives copy of indictment, list of witnesses, The Defendant waives copy of indictment, lst ofwitnesses, formal and pleads formal araignment arraignment and pleads Guilty. Guilty. Defendant waives The Defendant of waives copy The copy of ofwitnesses, lst of indictment, list indictment, witnesses, and pleads formal pleads formal arraignment arraignmentand Guilty. Guilty. Defendant Defendant Defendant Defesdam Defendant forDefendant Ritomey for Defendant Ritomey AttorneyforDefendant for Defendant Atomey AttorneyforDefendant ‘The Defendant waives copy of indictment, list ofwitnesses, and pleads formal arraignment Guilty. Attorney for Defendant AssismntDiuciAomey \| This of This__day day of Assistant District Attorney , Defends Assistant District Attorney Assistant District Attorney Aomey \|AsssantDistAlorey AwisaniDist of This This This__day of This_day , day of, day of , 7 7

PDF Page 9	‘The Defendant waives copy ofof waives copy The Defendant list of indictment, indictment, listofwitnesses, witnesses, and pleads formal arraignment pleads formal arraignment and Guily. Guilty. of The Defendant The Defendant waives waives copy copy of list of indictment list ofwitnesses, witnesses, indictment, and pleads formal arraignment formal armaignment and pleads Guilty. Guilty. Defedant Deda Defendant Defendant The Defendant Defendant waives waives copy The of copy of ist of listofwitnesses, indictment, indictment, witnesses, and pleads formal formal arraignment pleads arraignment and Guy. Guilty. Defendant Deena for for Defendant Defendant Atomey Defendant Romneyfor Attorney for Defendant Attorney for Defendant Atorey AttorneyforDefendant Assistant District Attorney Aesbani \| Asda District Aomey AssistantDictAtorney District Attorney \|AssistantDistAtomey AssistantDis Attorney This dyer This This This dayof Ths dayef Ths day of__, day of day of , The Defendant of The Defendant waives waives copy copy of indictment list list ofwitnesses, of witnesses, indictment, and pleads formal arraignment and formal arraignment pleads Guy. Guilty. of The Defendant waives copy The Defendant waives copy of of witnesses, indictment, lst ofwitnesses, indictment, list formal formal arraignment and pleads arraignment and pleads Guily. Guilty. The Defendant of The Defendant waives waives copy copy of list ofwitnesses, of witnesses, indictment, list indictment, formal arraignment and pleads formal pleads arraignment and Guilty. Guilty. Defendant Defendant Defendant Defendant Defdw Delma for Defendant Romy AttorneyTrDefendant for Defendant Aomey Adore Defendant or Defendant Attorney for Attorney forDefendant Assistant District Asean DictAtomey \|Aswan DiveAforey Attorney This of This This__day This__day of day of day of Assis Dist Atlorney This of “This_day day of “The Defendant waives copy of indictment, listofwitnesses, and pleads formal formal araignment pleads arraignment and Guily. Guilty. of The Defendant The Defendant waives waives copy copy of of witnesses, indictment list list ofwitesses, indictment, and pleads formal arraignment formal arraignment and pleads Guily. Guilty. The Defendant Defendant waives waives copy of The copy of list of indictment, istofwitnesses, indictment, witnesses, and pleads: formal formal arraignment arraignment and pleads Guily. Guilty. Defendant Defendant Defendant Demadw Defendant Daw toryTor Defendant Attorney for Defendant Assistant District Attorney , , The Defendant waives copy of indictment, list of witnesses, Attorney for Defendant for Defendant Amey AttorneyforDefendant Assistant District Attorney , __ Atorey forDefendant Assistant District Assistant District Attorney AnD Alomey \| Assan Dist Atomey \|Aesiant DietAtorey Attorney This of This of This This __day “This__day This_day of. day of day of day of, Assistant District Attorney , ,' 8 ,

PDF Page 10	OF FULTON STATE OF GEORGIA, COUNTY OF STATE OF FULTON GEORGIA, COUNTY SAID COUNTY IN THE COURT OF OF SAID COUNTY IN THE SUPERIOR SUPERIOR COURT of Fulton, sworn for the County wit: Fulton, toto wit: THE GRAND GRAND JURORS, and swornforthe chosen, and THE County of JURORS, selected, selected, chosen, ROBERTWES, Foreperson 2 ASHUEYMEL StF Ser Fool At.Sc. JULIA JOUDECRG, 5 ene ARioL. sown ome &7.c0L00K CAROL 810 Gow vos wor So BReNOA KARTHus0H 32ATONETTE Leu MAX oer a wax 1. ROBERT WELLS, Foreperson 2. ASHLEY MELVIN, Asst. FP 4. DECREDICO, Asst. Sec. 5. ERLE ARNOLD 6. DANIELLE BROWN DICK 7. 8. KATHY GOLD 9. WILLIS HARDY 10. BRENDA HART 11. ANTIONETI'E HUDSON 12. lLE LIN MORTENSEN 13. 99 GREGORYPETRA 10.GREGORY JENIFERPRICE 15 JENNIFER GEORGE PAGE 16 GroRSe PULAVARTY PAVAN PULAVATY 7 VAN SARE 38 FRANEEN JOHN EMMA JOHN EAST 15. VLADIMIR TCHAKAROV 20 VORTORO 21 coomCTRCE esmuenuoon = MARCUS WeLsoRN 5 MARCUS WELBORN “TESTO 25 amieen cen SCASTORERSTTON. PETRALIA 14. PRICE 15. PRINGLE 16. 17. 18. FRANEEN SARIF ST. 19. 20. 21. CEDRIC TRICE 22. ESTHER UDOJI 23. 25. KATHLEEN CHEN

PDF Page 11	TABLE OF CONTENTS TABLE OF CONTENTS THE GEORGIA GEORGIA RICO OF THE COUNT 1: VIOLATION COUNT: VIOLATION OF RICO AND CORRUPT INFLUENCED (RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS) ACT ORGANIZATIONS) ACT (RACKETEER 13 CEB UMAR mmmmemmmmmmmmmmmmm——5 O.C.G.A. § 16-14-4(c) 14 Introduction mm——————————"_— JORG 15 The Enterprise Ly — 16 Manner and Methods of the Enterprise and Overt Overt Acts of the Acts of Racketeering Racketeering Activity Activity and Acts inin Furtherance Furtheranceofthe Acts of EE A —. 20 Conspiracy OFFICER OF VIOLATION PUBLIC OFFICER COUNT 2: SOLICITATION SOLICITATION OF COUNT2: VIOLATION OF OF OATH OATH BY BY PUBLIC 72 16-10-1 & OCGA. 1647 & 16-10 sss 2 16-4-7 O.C.G.A. §§ §§ COUNT3: FALSE STATEMENTS STATEMENTS AND AND WRITINGS WRITINGS COUNT 3: FALSE 72 OLA O.C.G.A. SUNDrsmsmmmmmmammmmmmmmmmmnonsill § 16-10-20 COUNT COUNT4:4: FALSE FALSE STATEMENTS STATEMENTS AND AND WRITINGS WRITINGS 73 OCGA §§ 16-10-20. wll 16-10-20 O.C.G.A. OATH BY OF VIOLATION COUNTS:5: SOLICITATION SOLICITATION OF VIOLATION OF OF OATH BY PUBLIC PUBLIC OFFICER, COUNT OFFICER, 74 & 16101 164-7 O.C.G.A. OCGA. $5 16-47 & 16-WhLcressmmrmmensmemasssnsn Th §§ OFFICER OF OATH OATH BY OF VIOLATION COUNT COUNTG:6: SOLICITATION SOLICITATION OF VIOLATION OF BY PUBLIC PUBLIC OFFICER 74 & 16-10-1 O.CG.A. §§ 1647& 16-10-1 nm— omni O.C.G.A. §§ 16-4-7 WRITINGS FALSE STATEMENTS STATEMENTS AND COUNT COUNT7:7: FALSE AND WRITINGS 75 O.C.G.A. O.C.GA§§ 16-10-20 16-10-20. 15 OFFICER COUNT COUNTS:8: IMPERSONATING IMPERSONATING AA PUBLIC PUBLIC OFFICER 76 1610-23 OLOA mms O.C.G.A. §SAND OFFICER TO COMMIT PUBLIC OFFICER IMPERSONATING AA PUBLIC COUNT 9: CONSPIRACY CONSPIRACY TO COMMIT IMPERSONATING COUNT: 76 O.C.G.A. §§ OCOA. $8 16-4-8 16-48 && 16-10-23 16-10-23 6 THE FIRST COUNT 10: COUNT 10: FORGERY FORGERY IN IN THE FIRST DEGREE DEGREE 77 O.C.G.A. § 16-9-1(b) OCBAL ULB mmmmmmminmimmimmmimmmssmisisiTl FORGERY IN THE FIRST To COMMIT COUNT 11: 1: CONSPIRACY COMMIT FORGERY IN THE FIRST DEGREE DEGREE COUNT CONSPIRACY TO 77 O.C.G.A. SSL CORA HB UB mmmmmmmmmsmmmmmmmmnintT] §§ 1648 & 16-91(b) AND WRITINGS STATEMENTS AND COUNT 12: COUNT 12: FALSE FALSE STATEMENTS WRITINGS 78 O.C.G.A. ORAL§ 16-1020 1A arms TE COMMIT FALSE TO COMMIT STATEMENTS AND CONSPIRACY TO COUNT l3: COUNT 13: CONSPIRACY FALSE STATEMENTS AND WRITINGS WRITINGS 78 & 16-1020 mmm O.C.G.A. SSIES OLBA ds §§ 16-4-8 LI6I0B 10 10

PDF Page 12	FILING FALSE To COMMIT ATTEMPT TO DOCUMENTS FALSE DOCUMENTS CRIMINAL ATTEMPT COMMIT FILING COUNle 14: CRIMINAL COUNT 79 & 164-1 A. 0.C.G.A. 16-1020.1b)(1) & §§ 164-1 16-1020.1(b)(1) OCGA. §§ DOCUMENTS TO COMMIT COMMIT FILING FALSE DOCUMENTS CONSPIRACYTO FILING FALSE COUNTli 15: CONSPIRACY COUNT 79 19 & 16-4-8 O.C.G.A. 1(b)(1) crn & 16-10-20. §§ 164-8 O.C.G.A. §§ 16-10-20.1(b)(1) IN THE COUNT 16: FORGERY FORGERY IN THE FIRST FIRST DEGREE DEGREE COUNT1& 80 80 O.C.G.A. 169-1(b) rrr OCGA. §§ 16-9-1(b) DEGREE THE FIRST TO COMMIT FIRST DEGREE IN THE FORGERY IN COUNT1% COMMIT FORGERY TO CONSPIRACY 17: CONSPIRACY COUNT 80 80 sss 16-48 & & 16-910) O.C.G.A. §§ §§ 16-48 OCGA. 16-91(b) WRITINGS STATEMENTS AND COUNT1& AND WRITINGS FALSE STATEMENTS 18: FALSE COUNT 81 16-10-20 O.C.G.A. §§ 16-10-01 OCGA AND WRITINGS WRITINGS FALSE STATEMENTS STATEMENTS AND CONSPIRACY TO COUNT 19: 19 CONSPIRACY COMMIT FALSE TO COMMIT COUNT 81 81 O.C.G.A. §§ 16-10-20... 164-8 && 16-1020 §§ 164-8 OCGA. TO COMMIT INFLUENCING WITNESSES WITNESSES CRIMINAL ATTEMPT TO COMMIT INFLUENCING COUNTZm 20: CRIMINALATTEMPT COUNT 82 & 82 1641 O.C.G.A. §§ rrr 16-10-93BYINAY & 164-1 O.C.G.A. 16-1093(b)(1)(A) §§ WITNESSES COMMIT INFLUENCING TO COMMIT CRIMINAL ATTEMPT COUNTZh INFLUENCING WITNESSES ATTEMPT TO 21: CRIMINAL COUNT 82 82 16-4-1 rrr O.C.G.A. §§ 16-10:93D)1NA) OCGA. &16-10-93(b)(1)(A) §§ 16-41 & TO COMMIT COMMIT CRIMINAL ATTEMPT COUNT22: ATTEMPT TO COUNT 22: CRIMINAL FALSE FALSE STATEMENTS STATEMENTS AND AND WRITINGS WRITINGS 83 & 161020 1641 OCGA. 164-1 & 16-10-20. ami} O.C.G.A. §§ §§ OFFICER PUBLIC OFFICER OF VIOLATION BY PUBLIC OATH BY OF OATH VIOLATION OF C0UNT2$ SOLICITATION OF 23: SOLICITATION COUNT 84 & 16101 O.C.G.A. & 16-10-84 1647 OCGA. §§ §§ 1647 STATEMENTS AND WRITINGS AND WRITINGS COUNTzm FALSE STATEMENTS 24: FALSE COUNT 84 nh —————————— O.C.G.A. 16-10-20... OCGA. §§ 16-10-20 WRITINGS STATEMENTS AND COUNT25: FALSE FALSE STATEMENTS AND WRITINGS 'COUNT2& 85 O.C.GA§§ 161020 16-1020. 8 O.C.G.A. WRITINGS FALSE STATEMENTSAND STATEMENTS AND WRITINGS 26: FALSE COUNT COUNT2& JOC NT ————— 85 16-10-20 O.C.G.A. § > FALSE DOCUMENTS DOCUMENTS COUNTzn FILING FALSE 27: FILING COUNT 86 OCGA BIGADMIN O.C.G.A. § 161020.1(b)(1) ssn OFFICER OF OATH SOLICITATION OF PUBLIC OFFICER BY PUBLIC OATH BY COUNT 28: VIOLATION OF OF VIOLATION 28: SOLICITATION COUNT 87 O.C.GA. §§ 1647 && 1610-1 §§ 16-47 16-10-L msm 81 O.C.G.A. i 11

PDF Page 13	WRITINGS STATEMENTS AND 29: FALSE COUNT COUNT29: FALSE STATEMENTS AND WRITINGS 88 VSL nummer OF COMMIT SOLICITATION CONSPIRACY TO SOLICITATION OF COUNT 30: TO COMMIT 30: CONSPIRACY COUNT WRITINGS FALSE STATEMENTS STATEMENTS AND FALSE AND WRITINGS 89 O.C.G.A. 16-10-20 cosnssnsnn 89 164-7, && 1610-20 §§ 164-8, O.C.GA. §§ 16-4-8, 16-4-7, WITNESSES COUNT 31: INFLUENCING COUNT31: INFLUENCING WITNESSES 89 3 sss O.C.G.A. 16-10-93B)(1)(A).... 0.C.G.A. §§ 1610-93(b)(1)(A) O.C.G.A. CORA § 16-1020 COMMIT ELECTION ELECTION FRAUD CONSPIRACY TO COUNT TO COMMIT FRAUD 32: CONSPIRACY COUNT 32: 90 O.C.G.A. §§ §§ '21-2-603 21-2603 && 21-2566.rrsnsnsssnsssnsn 90 21-2566 O.C.G.A. ELECTION FRAUD CONSPIRACY TO FRAUD 33: CONSPIRACY COUNT 33: COMMIT ELECTION TO COMMIT COUNT ————— 91 O.C.G.A. TEX7 PIER & 21-2574 IN §§ 212603 PY THEFT COMPUTER THEFT CONSPIRACY To COUNT TO COMMIT COMMIT COMPUTER 34: CONSPIRACY COUNT 34: 92 & 9D 16-4-8 O.C.G.A. §§ corr 16-993(@) & 164-8 OCGA. 16993(a) §§ TRESPASS COMPUTER TRESPASS CONSPIRACY TO 35: CONSPIRACY COUNT 35: COMMIT COMPUTER TO COMMIT COUNT 93 1648 & OCGA. §§ 164-8 & 16-9936)... rmm————— O.C.G.A. §§ 16-9-93(b) PRIVACY TO COMMIT COMPUTER INVASION OF PRIVACY INVASION OF CONSPIRACY TO 36: CONSPIRACY COMMIT COMPUTER COUNT 36: COUNT 94 Ih O.C.G.A. §§ 16-993(€) corr 16-48 && 16-9-93(c) OCGA §§ 16-4-8 TO DEFRAUD THE STATE STATE COUNT DEFRAUD THE CONSPIRACY TO 37: CONSPIRACY COUNT 37: 95 16-10-21 BLRA O.C.G.A. SUASNm § OFFICER OATH BY OF VIOLATION PUBLIC OFFICER BY PUBLIC SOLICITATION OF OF OATH 38: SOLICITATION COUNT 38: VIOLATION OF COUNT 95 & OCGA. 1647 & 16-10-95 16-4-7 1610-1 O.C.G.A. §§ §§ . STATEMENTS AND COUNT 39: FALSE COUNT39: FALSE STATEMENTS AND WRITINGS WRITINGS 96 9 O.C.G.A. §§ 16-10-20 1610-20... OCGA STATEMENTS AND 40: FALSE COUNT 40: FALSE STATEMENTS AND WRITINGS WRITINGS COUNT 96 CELA LUA ED smmmermmmmmmmssssmsssssassommnnnIl O.C.G.A. § 16-10-20 41: PERJURY COUNT41: PERJURY COUNT 97 O.C.G.A. 10-10TUErrsmmmsssessssssssmssmmmmmmmsmmnel OLBAS§ 16-10-70(a) 12 2

PDF Page 14	COUNT of 41 COUNT 11of41 ‘The Grand Jurors aforesaid, in the name and behalf ofthe citizens of Georgia, do hereby and accuse: accuse: charge and charge DONALD JOHN TRUMP, DONALD JOHN TRUMP, RUDOLPH LOUIS RUDOLPH WILLIAM GIULIANI, WILLIAM LOUIS GIULIANI, JOHN CHARLES JOHN CHARLES EASTMAN, EASTMAN, MARK MARK RANDALL RANDALL MEADOWS, MEADOWS, KENNETH JOHN KENNETH JOHN CHESEBRO, CI-IESEBRO, JEFFREY JEFFREY BOSSERT BOSSERT CLARK, CLARK, JENNA LYNN JENNA LYNN ELLIS, ELLIS, RAY STALLINGS STALLINGS SMITH SMITH III, RAY III, ROBERT DAVID ROBERT DAVID CHEELEY, CHEELEY, MICHAEL MICHAEL A. A. ROMAN, ROMAN, DAVID DAVID JAMES JAMES SHAFER, SHAFER, SHAWN MICAH TRESI-IER STILL, SHAWN MICAH TRESHER STILL, STEPHEN CLIFFGARD LEE, STEPHEN CLIFFGARD LEE, HARRISON HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD, FLOYD, TREVIAN C. TREVIAN C. KUTTI, KUTTI, SIDNEY KATHERINE POWELL, SIDNEY KATHERINE POWELL, CATHLEEN CATHLEEN ALSTON ALSTON LATHAM, LATHAM, SCOTT GRAHAM and GRAHAM HALL, SCOTT HALL, and MISTY MISTY HAMPTON HAMPTON the offense offense ofVIOLATION of VIOLATION OF with OF THE TI-IE GEORGIA RICO (RACKETEER with the GEORGIA RICO (RACKETEER AND CORRUPT INFLUENCED CORRUPT ORGANIZATIONS) O.C.G.A. §§ 16-14-4(c), the INFLUENCED AND ACT, 16-14-4(c), for for the ORGANIZATIONS) ACT, O.C.G.A. said accused, and as as persons of aa crime, concerned in the commission said individually and persons concerned in the commission of and together together accused, individually crime, and with in the State of and of on and between with unindicted unindicted co-conspirators, in the State of Georgia and Countyof Fulton, on and between Fulton, co-conspirators, Georgia County the the 15th of September 2022, an the 4th 4th dayofNovember 2020 and and the 15th day while associated associated with with an 2022, while day of November 2020 day ofSeptember and endeavored conduct and and enterprise, unlawfully unlawfully conspired endeavored toto conduct and participate participate in, in, directly enterprise, conspired and directly and such a of in violation of O.C.G.A. indirectly, such enterprise enterprise through through a pattern patternofracketeering indirectly, racketeering activity activity in violation of 0.C.G.A. §§ as described below and incorporated if ﬁllly set set forth 16-14-4(b),asdescribed below and incorporated by by reference referenceasas iffully 16-14-4(b), forth herein, herein, contrary contrary to of said State, and to the the laws lawsofsaid the good good order, peace, and dignity thereof; State, the thereof; order, peace, dignity The Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do hereby l3 3

PDF Page 15	INTRODUCTION INTRODUCTION Defendant Donald John Tramp lost the United States presidential election held on and the Defendants other Defendants he lost November 3,3, 2020. the states lost was was Georgia. Georgia. Trump the other 2020. One One of of the states he November Trump and Indictment refused charged inin this this Indictment refused toto accept that Trump and they knowingly and and willfully willfully lost, and they knowingly Trump lost, accept that charged of Trump. That election in joined conspiracy toto unlawfully change the the outcome outcomeofof the the election in favor favorofTrump. That unlawfully change joined aa conspiracy or more acts of racketeering commit two conspiracy common plan plan and purpose toto comnit two or more actsofracketeeting contained aa common and purpose conspiracy contained states. of Georgia, State of activity in Fulton Fulton County, elsewhere inin the the State and inin other other states. Georgia, and activity in County, Georgia, Georgia, elsewhere Defendant Donald John Trump lost the United States presidential election held on 14 14

PDF Page 16	THE ENTERPRISE THE ENTERPRISE as others others not as well as not the Defendants, aswell Defendants, of the Indictment, Indictment, the Count ofthe this Count relevant to to this At all times times relevant Atall named as defendants, unlawfully conspired and endeavored to conduct and participate in a and elsewhere. Trump, John Trump, Donald John Defendants Donald elsewhere. Defendants criminal enterprise Fulton County, in Fulton criminal Georgia, and County, Georgia, enterprise in Kenneth John John Randall Meadows, Charles Eastman, Mark Randall Meadows, Kenneth Eastman, Mark John Charles Lous Giuliani, William Louis Giuliani, John Rudolph William Rudolph David Robert David Smith III, Ray Stallings Ellis, Ray Lynn Ellis, Jenna Lynn III, Robert Clark, Jenna Bossert Clark, Jeffrey Bossert Chescbro, Jeffrey Stallings Smith Chesebro, Tresher Still, Micah Tresher Cliffgard Still, Stephen James Shafer, Shawn Micah Shafer, Shawn Michael A. David James Stephen Cliffgard Roman, David A. Roman, Cheeley, Michael Cheeley, Cathleen C. Kutti, Trevian C. Powell, Cathleen Katherine Powell, Kutt, Sidney Floyd, Trevian Prescott Floyd, Sidney Katherine William Prescott Harrison William Lee, Harrison Lee, Individual l\| unindicted co-conspirators Hampton, unindicted Scott Graham Hell, Misty Alston Graham Hall, Latham, Scott Alston Latham, co-conspirators Individual Misty Hampton, criminal constituted aa criminal to the and unknown unknown to Grand Jury, the Grand others known known and Individual 30, and others Jury, constituted through Individual 30, and through activities criminal activities in various related criminal and associates associates engaged various related members and whose members organization engaged in organization whose and writings, ofﬁcer, statements and impersonating aa public limited to, writings, impersonating false statements to, false public officer, not limited but not including, but including, theft, computer witnesses, computer documents, influencing false documents, trespass, filing false forgery, ﬁling computer trespass, computer theft, inﬂuencing witnesses, forgery, and perjury. acts involving perjury. to defraud defraud the involving theft, the state, of privacy, conspiracy theft, and state, acts invasionofprivacy, computer invasion conspiracy to computer in O.C.G.A. O.C.G.A. §§ deﬁned in that term term is an enterprise is defined constituted an as that This criminal organization enterprise as “This criminal organization constituted named as defendants, unlawfully conspired and endeavored to conduct and participate in a other members and other The Defendants members of individuals Defendants and fact. The associated inin fact. individuals associated 16-14-3(3), that is, aa group group of and with another and with one one another and relationships connections and the with the and associates of the enterprise relationships with had connections enterprise had and associatesofthe and associates whose members associates members and constituted an an ongoing enterprise constituted The enterprise enterprise. ongoing organization organization whose enterprise. 'The of the common purposeofachieving objectivesofthe the objectives functioned for aa common unit for continuing unit functioned asas aa continuing purpose of achieving the State of of Georgia, elsewhere in Georgia, the State in the The enterprise Fulton County, in Fulton enterprise operated enterprise. County, Georgia, Georgia, elsewhere operated in enterprise. The Mexico, New Mexico, Nevada, New Arizona, Michigan, to, Arizona, limited to, in not limited but not including, but other states, in other Michigan, Nevada, states, including, The enterprise of Columbia. Columbia. The for aa and in enterprise operated and Wisconsin, Districtof the District in the Wisconsin, and Pennsylvania, and operated for Pennsylvania, l6-14-3(3), that is, and associates associates to its objectives. to pursue to permit members and sufﬁcient to its members permit its objectives. periodoftime pursue its period of time sufficient 15 15

PDF Page 17	OF THE ENTERPRISE MANNER AND AND METHODS METHODS OF THE ENTERPRISE MANNER of associates of and othermembersand methods used other members and associates “The used by by the the Defendants Defendants and The manner manner and and methods were and to but were achieve its purposes included, its purposes the to further to achieve the enterprise of the the goals included, but further the enterprise to the enterprise enterprise and goals of not limited limited to, not the following: following: to, the and Solicitation 1. 1. False False Statements Statements toto and Solicitationofof State State Legislatures Legislatures several ofthe of the Defendants, Membersofthe including several Defendants, appeared at hearings in Members of the enterprise, hearings in appeared at enterprise, including members of the Georgia on December Fulton County, before membersofthe General Assembly December 3,3, Fulton Georgia General Assembly on Georgia, before County, Georgia, of the enterprise 2020. At At these 2020, December December 10, 10, 2020, 2020, and December 30, 30, 2020. these hearings, hearings, members membersofthe and December enterprise 2020, election. The made false false statements statements concerning fraud inin the the November November 3,3, 2020, 2020, presidential presidential election. The made concerning fraud electoral statements was of these purposeof these false false statements was toto persuade persuade Georgia to reject reject lawﬁll lawful electoral Georgia legislators legislators to purpose of the electors from votes cast by the duly elected and Votes cast by the and qualified from Georgia. Membersofthe Georgia. Members qualiﬁed presidential presidential electors duly elected own solicited Georgia enterprise corruptly corruptly solicited legislators instead instead toto unlawﬁllly unlawfully appoint their own Georgia legislators appoint their enterprise Members of the presidential electors for the the purpose purposeofcasting for Donald Donald Trump. of casting electoral electoral votes votes for electors for Trump. Membersofthe presidential state legislators statements to enterprise made false false statements to state legislators during during hearings hearings and and meetings meetings inin also made enterprise also November and and December December 2020 and Pennsylvania Arizona, Michigan, Michigan, and Pennsylvania inin November 2020 toto persuade persuade legislators legislators Arizona, their own presidential electors. in to unlawfully those states states to in those appointtheirown presidential electors. unlawﬁllly appoint Officials State Ofﬁcials and Solicitation Solicitation of High-Ranking State to and of HighRanking 2. False Statements Statements to 2. False statements in several ofthe of the Defendants, made false of the enterprise, Members Membersofthe enterprise, including including several Defendants, made false statements in State of Georgia to Fulton elsewhere in Fulton County and elsewhere in the the StateofGeorgia to Georgia the officials, including including the County and Georgia officials, of and the of the House of Representatives. Members Members of Govemor, the the Speaker Speakerofthe HouseofRepresentatives. the SecretaryofState, Governor, Secretary cf State, and and the solicited Georgia the enterprise the also corruptly including the the SecretaryofState the officials, including Georgia officials, Secretary of State and enterprise also corruptly solicited and to to the Georgia Constitution and of Representatives, to oaths to Speakerofthe HouseofRepresentatives, to violate violate their their oaths to the Georgia Constitution Speaker of the House outcome of the November the States Constitution Constitution by the United United States by unlawfully unlawfully changing the outcomeofthe November 3,3, 2020, 2020, changing the 16 16

PDF Page 18	also made of the enterprise made in favor of Donald in Georgia Membersofthe election in Donald Trump. favor of presidential enterprise also Georgia in Trump. Members presidential election ofﬁcials in and solicited solicited state state officials Pennsylvania. and Pennsylvania. Michigan, and Arizona, Michigan, in Arizona, to and false false statements statements to of False False Electoral Documents Electoral College Distributionof and Distribution 3. Creation 3. Creation and College Documents created false Electoral false Electoral several of the Defendants, Members including severalofthe the enterprise, of the Members of Defendants, created enterprise, including cast false votes atat and recruited to convene convene and and cast Electoral College false Electoral documents and individuals to recruited individuals College votes College documents College After the 2020. After on December Electoral false Electoral the false 14, 2020. December 14, Fulton County, in Fulton Georgia State the Georgia the State Capitol, County, on Capitol, in of the enterprise the of the President of the President votes toto the the votes transmitted the enterprise transmitted membersofthe cast, members were cast, College votes were College votes and the the of the United the Archivist States Senate, the Georgia United States, the United States, Archivistofthe United States Senate, the Secretary of State, and Georgia SecretaryofState, The false of Georgia. Court for States District false Georgia. The District of of the United United States Northern District the Northern for the District Court Judgeofthe Chief Chief Judge on January and delay of Congress on 2021, to disrupt session ofCongress January 6,6, 2021, intended to documents were thejoint delay the were intended documents disrupt and joint session outcome of the November clection inin November 3,3, 2020, the outcomeofthe inorderto in order to unlawfully 2020, presidential change the presidential election unlawfully change of the enterprise schemes were executed by favor of Donald Trump. Arizona, in Arizona, membersofthe were executed Similar schemes Trump. Similar favor ofDonald enterprise in by members and Wisconsin. Wisconsin. New Mexico, Pennsylvania, and Mexico, Pennsylvania, Nevada, New Michigan, Nevada, Michigan, of Fulton 4. Freeman Ruby Freeman Worker Rubv Election Worker Fulton County Intimidation of and Intimidation Harassment and 4. Harassment Countv Election accused Fulton of the Defendants, Members Fulton falsely accused severalofthe including several enterprise, including the enterprise, of the Members of Defendants, falsely of committing crimes in Georgia. County, Georgia. Fulton County, in Fulton election crimes committing election Freeman of Ruby Freeman worker Ruby election worker ‘County County election other. Georgia an officials inin an and other legislators and repeated toto Georgia were repeated accusations were false accusations ‘These These false Georgia ofﬁcials Georgia legislators presidential November 3,3, 2020, outcomeofthe unlawfullychangethe them toto unlawfully persuade them to persuade effort of the November effort to 2020, presidential change the outcome In furtherance of this scheme, members of the enterprise in favor of Donald election in furtherance ofthis Donald Trump. favor of election scheme, membersofthe enterprise Trump. In confess to of state to traveled to falsely confess her toto falsely solicit her and solicit her, and intimidate her, harass Freeman, to harass outofstate from out traveled from Freeman, intimidate did not commit. not commit. she did that she crimes that election crimes election l7 17

PDF Page 19	5. SolicitationofHigh-Ranking United States DepartmentofJustice Officials solicited highMembersofthe Defendants, corruptly highseveral of the Defendants, of the enterprise, Members corruptly solicited enterprise, including including severalofthe goverment ofﬁcials to statements toto government false statements States Departmentof make false to make Justice officials United States ranking United Department of Justice ranking of House of the Speakerofthe the Governor, ofﬁcials in Georgia, including County, Georgia, Fulton County, in Fulton Governor, the officials Speaker of the House including the one instance, Pro Temporeofthe Senate. In and the Representatives, and the President President Pro In one Donald Trump Trump instance, Donald Tempore of the Senate. Representatives, and election was was corrupt, States Attorney the election that the “Just say to the stated to Attorney General, United States Acting United the Acting stated corrupt, and General, "Just say that 5. Solicitation of High-Ranking United States Department of Justice Ofﬁcials - leave the rest to me and the Republican congressmen.” States Vice President Solicitation of the Vice 6.6. Solicitationofthe President of of the the United United States solicited the Membersofthe severalofthe Defendants, corruptly corruptly solicited the of the Defendants, Members of the enterprise, enterprise, including including several lawby States Constitution Vice President Presidentofthe States toto violate the United United States Constitution and and federal federal law of the United United States violate the Vice by elected the duly in Fulton votes cast unlawfully rejecting rejecting Electoral Electoral College College votes cast in Fulton County, by the Georgia, by duly elected County, Georgia, unlawﬁilly also corruptly ﬁom Georgia. of the enterprise electors from enterprise also and Membersofthe presidential electors and qualified corruptly Georgia. Members qualiﬁed presidential Vice President cast by solicited the Vice President toto reject reject votes votes cast by the the duly duly elected elected and and qualified presidential solicited the qualiﬁed presidential leave the rest to me and the Republican congressmen." electors from several other states Elsewhere in Georgia 7. Unlawful Unlawful Breach Breach of of Election Election Equipment Equipment in and Elsewhere Georgia and of the enterprise, several of the Defendants, Members Membersofthe including severalofthe Defendants, corruptly in conspired in corruptly conspired enterprise, including and voter access secure and elsewhere Fulton County, Georgia, elsewhere toto unlawfully secure voting voting equipment voter Fulton County, equipment and unlawﬁllly access Georgia, and members of the enterprise stole data, data. In data. In Georgia, enterprise stole ballot images, voting equipment equipment data, including images, voting including ballot Georgia, membersofthe other members distributed to The stolen data was and personal stolen data software, personal voter voter information. information. The was then then distributed to other members software, and other states. states. of the enterprise, ofthe including members members inin other enterprise, including electors ﬁom several other states. 7._ 18 18

PDF Page 20	Cover Up and the in Furtherance 8.8. Obstructive Obstructive Acts Acts in Furtherance of of the the Conspiracy the Cover Up Conspiracy and Members of the enterprise, several of the Defendants, Membersofthe including severalofthe Defendants, ﬁled filed false false documents, documents, enterprise, including committed perjury made false false statements statements toto government government investigators, and committed in judicial judicial made perjury in investigators, and the furtherance of and to and elsewhere elsewhere in proceedings in Fulton Fulton County, in furtheranceofand to cover cover up up the County, Georgia, Georgia, and proceedings in conspiracy. conspiracy. l9 19

PDF Page 21	AND RACKETEERING ACTIVITY ACTS OF RACKETEERING ACTS OF ACTIVITY AND OF THE CONSPIRACY OVERT URTHERANCE OF OVERT ACTS ACTS IN IN FFURTHERANCE THE CONSPIRACY. detailed above, the Defendants and As part of and onbehalfof on behalf of the crimin'al enterprise As part ofand the criminal Defendants and above, the enterprise detailed of acts to other members and and associatesofthe committed overt overt acts to eﬁect effect the the objectives objectives of other members associates of the enterprise enterprise committed to: the enterprise, but not the enterprise, including including but not limited limited to: Act 1. Act DONALD JOHN TRUMP made On about the 4th day On or or about the 4th dayofof November November 2020, 2020, DONALD JOHN TRUMP made aa televised specch nationally falsely declaring victory inin the the 2020 2020 presidential presidential election. election. nationally televised declaring victory speech falsely October DONALD JOHN TRUMP four or about on Approximately four days earlier, on or about October 31, 2020, DONALD JOHN TRUMP 31, 2020, Approximately days earlier, Individual l, whose identity known to discussed aa draft draft speech unindicted co-conspirator discussed speech with with unindicted 1, whose identity isis known to coconspirator Individual claimed voter was an Grand Jury, and fraud. The the that declared the Grand that falsely declared victory and falsely claimed voter fraud. The speech was an falsely Jury, victory falsely speech overt act act in of the conspiracy. overt in furtherance furtheranceofthe conspiracy. Act2, WILLIAM LOUIS On or or about the 15th 15th dayof November 2020, On about the 2020, RUDOLPH RUDOLPH WILLIAM LOUIS day of November GIULIANI placed Individual 2, whose identity GIULIANI placed aa telephone telephone call call toto unindicted unindicted co-conspirator 2, whose identity isis co-conspirator Individual known the Grand voicemail and left an known toto the Grand Jury, and left an approximately 83-second-long voicemail message for message for Jury, approximately 83-second-long statements concerning unindicted unindicted coconspirator co-conspirator Individual Individual 22 making making statements fraud inin the the November November 3,3, concerning fraud call was an in This overt act in furtherance of election Fulton 2020, election in Fulton County, Georgia. This telephone call was an overt act in furtherance of 2020, telephone County, Georgia. the the conspiracy. conspiracy. Act2, WILLIAM LOUIS On or about about the of November On or the 19th 19th day November 2020, 2020, RUDOLPH RUDOLPH WILLIAM LOUIS day of counindicted coPOWELL, and JENNA LYNN SIDNEY KATHERINE and unindicted KATHERINE POWELL, ELLIS, SIDNEY LYNN ELLIS, GIULIANI, GIULIANI, JENNA known to a press whose identity conspirator Individual 3,3, whose identity isis known to the the Grand Grand Jury, Jury, appeared atapress conspirator Individual appeared at conference at the Committee on behalf of conference at the Republican Republican National National Committee Headquarters DONALD JOHN JOHN Headquarters onbehalf of DONALD TRUMP and and Donald and made for President, TRUMP Donald J.J. Trump President, Inc. Inc. (the (the “Trump Campaign”) and made false false: "Trump Campaign") Trump for statements concerning November 3', election in in Georgia statements concerning fraud fraud inin the the November 3, 2020, presidential election and 2020, presidential Georgia and elsewhere. of the conspiracy. These were overt overt acts elsewhere. Thesewere acts inin furtherance furtheranceofthe conspiracy. Acta. On of November SHAFER sent sent an an e-mail about the 20th day On or or about the 20th day of November 2020, DAVID JAMES JAMES SHAFER e-mail 2020, DAVID known to whose identity Grand Jury, to unindicted to unindicted co-conspirator co-conspirator Individual Individual 4,4, whose identity isis known to the the Grand and other other Jury, and stated that SCOTT GRAHAM In the SHAF ER stated individuals. individuals. In the email, e-mail, DAVID DAVID JAMES JAMES SHAFER that SCOTT GRAHAM HALL, HALL, aa election on bail bondsman, of the President "has been been looking ‘Georgia bondsman, “has into the the election on behalf behalf ofthe President atat the the Georgia bail looking into Individual 4 to contact of David Bossie" and asked unindicted request of David Bossie” and asked unindicted co-conspirator Individual 4 to exchange contact co-conspirator exchange request and to to “help as needed." This information with SCOTT SCOTT GRAHAM This was overt act information with GRAHAM HALL HALL and himasneeded.” was an an overt act "help him furtherance of the conspiracy. inin furtheranceofthe conspiracy. 20 20

PDF Page 22	Act Acts.5. and MARK JOHN TRUNIP On the 20th 20th day November 2020, DONALD JOHN TRUMP and MARK of November On or or about about the 2020, DONALD day of Shirkey, of the Michael Shirkey, with Majority Senate Michael Michigan Senate met with the Michigan RANDALL MEADOWS Leaderof Majority Leader MEADOWS met RANDALL Lee and other of legislators Michigan other and the House Chatfield, Lee of ofRepresentatives House Michigan t he Chatﬁeld, of Speaker Michigan legislators Representatives Speaker Michigan false statements DONALD JOHN TRUMP made and at the Oval Office Ofﬁce at House, and DONALD JOHN TRUMP made false statements White House, the White the Oval inin the election in in Michigan. concerning fraud in the November 3, 2020, presidential election Michigan. RUDOLPH RUDOLPH ﬁaud in the November 2020, presidential 3, concerning act was an overt act This the WILLIAM LOUIS GIULIANI joined the meeting by telephone. Thismeeting LOUIS GIULIANI WILLIAM meeting wasanovert meeting by telephone. joined of the conspiracy. inin furtherance furtheranceofthe conspiracy. Act 6. Act6. sent a a RANDALL MEADOWS November 2020, On or or about about the the 21st dayofof November MARK RANDALL MEADOWS sent 21st day On 2020, MARK text message message toto United Representative Scott Scott Perry Perry from from Pennsylvania Pennsylvania and and stated, “Can text United States States Representative stated, "Can wants the PA POTUS and leader of ‘you me the the number number for for the the speaker Legislature. POTUS wants toto chat chat send me speaker and the leader ofPA Legislature. you send furtherance of the conspiracy. with was an overt act them." This This was with them.” an overt act inin furtheranceofthe conspiracy. Act Act.7. and JOHN TRUMP TRUMP and November 2020, 22nd dayof On or about about the On or the 22nd DONALD JOHN 2020, DONALD day of November the Arizona a call of to Arizona LOUIS GIULIANI Speakerofthe to call RUDOLPH WILLIAM telephone a placed GIULIANI LOUIS WILLIAM RUDOLPH placed telephone Speaker Bowers. During House of Representatives Russell HouseofRepresentatives Russell “Rusty” During the the telephone telephone call, RUDOLPH call, RUDOLPH "Rusty" Bowers. statements concerning fraud in the November WILLIAM LOUIS GIULIANI made LOUIS GIULIANI WILLIAM made false false statements fraud in the November 3,3, concerning t0 and Bowers and 2020, presidential election election inin Arizona Arizona and solicited, solicited, requested, requested, and importuned 2020, presidential importuned Bowers to the testiﬁed to declined and unlawfully appoint presidential electors electors from from Arizona. Arizona. Bowers Bowers declined and later later testified to the unlawﬁJlly appoint presidential Attack 6th Select Committee the Attack to 6th January the Investigate United States House of to United States HouseofRepresentatives January Representatives Select Committee Investigate break my not break would not on the the United States Capitol TRUMP, "I“I would JOHN TRUMP, DONALD JOHN told DONALD he told that he United States on my Capitol that acts in oath.” false statements solicitations were were overt overt acts in furtherance furtherance of of the the conspiracy. The false statements and and solicitations oath." The conspiracy. Act Act8.8. of November On or or about about the On the 25th 25th day November 2020, 2020, RUDOLPH RUDOLPH WILLIAM WILLIAM LOUIS LOUIS day of GIULIANI and JENNA LYNN at aa meeting and witnesses GIULIANI andJENNA LYNN ELLIS ELLIS appeared, spoke, and presented witnessesat meeting appeared, spoke, presented of of Pennsylvania Pennsylvania legislators legislators inin Gettysburg, Gettysburg, Pennsylvania. Pennsylvania. During During the the meeting, meeting, RUDOLPH RUDOLPH false statements WILLIAM GIULIANI made WILLIAM LOUIS LOUIS GIULIANI made false statements concerning concerning fraud fraud inin the the November November 3,3, and and election in 2020, presidential presidential election in Pennsylvania Pennsylvania and solicited, requested, and importuned importuned the the solicited, requested, 2020, from at the to electors Pennsylvania legislators present at the meeting to unlawfully appoint presidential electors from meeting unlawfully appoint presidential Pennsylvania legislators present LYNN ELLIS and JENNA the Pennsylvania. During the meeting, JENNA LYNN ELLIS solicited, requested, and importuned. solicited, requested, importuned meeting, Pennsylvania. During the meeting electors at the the the Pennsylvania Pennsylvania legislators meeting toto unlawfully unlawfully appoint presidential electors appoint presidential legislators present present at false made TRUMP joined from Pennsylvania. Pennsylvania. DONALD JOHN TRUMP joined the the meeting meeting by telephone, made false DONALD JOHN from by telephone, election in statements concerning ﬁaud fraud inin the the November November 3,3, 2020, presidential election in Pennsylvania, Pennsylvania, and and statements concerning 2020, presidential to the at the and solicited, requested, and importuned the Pennsylvania legislators present at the meeting to meeting Pennsylvania legislators present solicited, requested, importuned from Pennsylvania. These were overt acts electors from unlawfully appoint presidential electors Pennsylvania. These were overt acts inin furtherance furtherance unlawfully appoint presidential of the ofthe conspiracy. conspiracy. 21 21

PDF Page 23	Act Act.9. the meeting after the of meeting of 25th dayof On or about the immediately after 2020, immediately November 2020, the 25th or about On day of November LOUIS WILLIAM LOUIS RUDOLPH WILLIAM where RUDOLPH Pennsylvania, where Gettysburg, Pennsylvania, legislators inin Gettysburg, Pennsylvania legislators Pennsylvania and presented DONALD witnesses, DONALD presented witnesses, spoke, and JENNA LYNN ELLIS appeared, GIULIANI and and JENNA LYNN ELLIS GIULIANI appeared, spoke, with to meet and others him atat legislators and others to meet with him JOHN TRUMP invited aa groupofthe TRUMP invited JOHN Pennsylvania legislators group of the Pennsylvania JOHN TRUMP, RANDALL that day, MARK RANDALL Later that DONALD JOHN the House. Later White House. the White TRUMP, MARK day, DONALD LYNN LOUIS JENNA WILLIAM and ELLIS and RUDOLPH WILLIAM LOUIS GIULIANI, GIULIANI, JENNA LYNN ELLIS MEADOWS, RUDOLPH MEADOWS, the are known and Individual identities are Individual 55 and known toto the unindicted whose identities Individual 6,6, whose co-conspirators Individual unindicted co-conspirators and discussed House at the White of the with discussed and Grand met with the groupof legislators at the White House Pennsylvania legislators Jury, met Grand Jury, Pennsylvania group in acts in overt acts General These were were overt the of session holding a special sessionofthe Pennsylvania General Assembly. These a Pennsylvania Assembly. holding special ﬂirtherance of the conspiracy. furtheranceofthe conspiracy. Act Act 10. 10. of November 2020, RUDOLPH WILLIAM LOUIS 26th day WILLIAM LOUIS or about On or about the 2020, RUDOLPH day ofNovember the 26th On the of a to LYNN ELLIS call Pennsylvania Speakerofthe to and JENNA JENNA LYNN ELLIS placed telephone call Speaker GIULIANI and placed a telephone Pennsylvania GIULIANI of and left Cutler aa voicemail Cutler and the purpose for the message for House of Representatives Bryan voicemail message left Cutler HouseofRepresentatives purpose of Bryan Cutler from electors him to soliciting, requesting, and importuning him to unlawfully appoint presidential electors from and unlawfully appoint presidential importuning soliciting, requesting, furtherance of the conspiracy. an overt Pennsylvania. This This was was an overt act act inin furtheranceoftheconspiracy. Pennsylvania. Act 11. Actll November 2020, LOUIS On or or about about the WILLIAM LOUIS RUDOLPH WILLIAM 2020, RUDOLPH 26th dayof the 26th On day of November Senate Pro Temporeofthe of the Jacob Senate Jacob GIULIANI Pennsylvania President Pro call toto President telephone call placed aa telephone GIULIANI placed Pennsylvania Tempore Corman to of and for the “Jake” Corman for the purposeofsoliciting, requesting, and importuning Corman to unlawfully "Jake" Corman unlawfully soliciting, requesting, importuning purpose of the act in furtherance ﬁom This was an overt electors appoint presidential electors from Pennsylvania. This was an overt act in furtheranceofthe Pennsylvania. appoint presidential conspiracy. conspiracy. Act 12. Act12, LOUIS WILLIAM LOUIS the 27th 27th dayof On or or about On about the November 2020, RUDOLPH WILLIAM 2020, RUDOLPH day of November the a of and JENNA call to GIULIANI LYNN ELLIS ELLIS placed 2 telephone call to Speakerofthe Pennsylvania GIULIANI and JENNA LYNN Pennsylvania placed telephone Speaker House of Representatives Bryan HouseofRepresentatives Bryan Cutler Cutler and and left left Cutler Cutleraa voicemail voicemail message message for for the the purpose purpose of of from him to electors soliciting, requesting, and importuning him to unlawfully appoint presidential electors from and importuning unlawfully appoint presidential soliciting, requesting, of the conspiracy. act in This was an overt Pennsylvania. This was an overt act in furtherance furtheranceofthe conspiracy. Pennsylvania. Act 12. Act 12. LOUIS of November RUDOLPH WILLIAM WILLIAM LOUIS On or about about the On or the 27th 27th day day of November 2020, 2020, RUDOLPH to President call to Pro Temporeofthe JENNA LYNN President Pro and JENNA telephone call GIULIANI and placed aa telephone ELLIS placed LYNN ELLIS GIULIANI Tempore of the and for the of importuning Corman and Jake requesting, Senate soliciting, purposeof the for Corman Jake Senate Pennsylvania importuning purpose soliciting, requesting, Pennsylvania overt act act in in This was was an an overt Pennsylvania. This from Pennsylvania. Corman to electors from presidential electors unlawfully appoint to unlawﬁilly Corman appoint presidential the conspiracy. turtherance furtheranceofof the conspiracy. ' ' 2 22

PDF Page 24	Act l4. Act14, On or about the 27th day ofNovember 2020, DONALD JOHN TRUMP placed a telephone call to President Pro Temporeofthe Pennsylvania Senate Jake Corman for the purpose ofsoliciting, requesting, and importuning Corman to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtheranceofthe conspiracy. On or about the 27th day of November 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. Act1s, LOUIS of November WILLIAM LOUIS the 28th 28th day RUDOLPH WILLIAM On or November 2020, or about about the On 2020, RUDOLPH day of of of the Pennsylvania call to Representatives House of Representatives Pennsylvania House GIULIANI placed to Speaker telephone call placed aa telephone Speaker ofthe GIULIANI and of a voicemail the left Cutler for and purposeofsoliciting, the Cutler for message voicemail a Cutler left and Cutler soliciting, requesting, requesting, and Bryan message purpose Bryan was an This from Pennsylvania. electors from presidential electors unlawfully appoint him toto unlawfully Pennsylvania. This was an importuning appoint presidential importuning him of the act in overt act overt in furtherance furtheranceof the conspiracy. conspiracy. Act 16. Act16. LOUIS of November November 2020, WILLIAM LOUIS 29th day On or about RUDOLPH WILLIAM dayof the 29th about the On or 2020, RUDOLPH of House call to of the a Representatives of House Pennsylvania GIULIANI Speakerofthe to telephone call Speaker placed a telephone Representatives GIULIANI placed Pennsylvania and the' purpose of left Cutler and left of soliciting, forthepurpose message for voicemail message Cutler aa voicemail soliciting, requesting, requesting, and Cutler and Bryan Cutler Bryan This was from Pennsylvania. electors from importuninghimto unlawfully appoint Pennsylvania. This was an an him to unlawfully appoint presidential presidential electors importuning overt actin conspiracy. furtherance of the conspiracy. overt act in furtheranceofthe Act 17. Act17. of November 2020, 30th day * On On or or about the 30th dayofNovember RUDOLPH WILLIAM WILLIAM LOUIS LOUIS about the 2020, RUDOLPH witnesses at and presented LYNN ELLIS and JENNA JENNA LYNN GIULIANI and ELLIS appeared, appeared, spoke, spoke, and presented witnesses at aa mecing GIULIANI meeting and 5 Individual and 5 Individual in Arizona. Unindicted co-conspirators Unindicted Arizona. of Arizona Phoenix, in legislators ofArizona legislators Phoenix, co-conspirators also present. the known to Grand Jury, During the were also the Grand to the Individual are known identities are whose identities Individual 6,6, whose present. During Jury, were fraud statements GIULIANI made false fraud WILLIAM LOUIS concerning statements RUDOLPH false made GIULIANT LOUIS WILLIAM concerning RUDOLPH ‘meeting, meeting, and election in Arizona and requested, and solicited, requested, the November November 3,3, 2020, inin the 2020, presidential presidential election in Arizona and solicited, at the to the Arizona presidential appoint unlawfully to meeting the at present legislators presidential Arizona the unlawfully appoint importuned legislators present meeting importuned ELLIS JENNA LYNN electors electors from from Arizona. Arizona. During During the the meeting, JENNA LYNN ELLIS solicited, requested, and solicited, requested, and meeting, the meeting to unlawfully importuned the Arizona legislators legislators present present atat the meeting to the Arizona unlawfully appoint appoint presidential presidential importuned JOI-IN TRUMPjoined TRUMP joined the electors Arizona. DONALD DONALD JOHN the meeting by telephone and made made from Arizona. electors from meeting by telephone and in election Arizona. fraud in the presidential election in Arizona. false statements concerning 2020, presidential November 3,3, 2020, false statements concerning fraud in the November furtherance of the conspiracy. overt acts These ‘These were were overt acts inin furtheranceofthe conspiracy. Act 18. Act18. 30th day of November On or about about the November 2020, MICHAEL A. A. ROMAN ROMAN instructed instructed the 30th On or 2020, MICHAEL day of to coordinate coordinate Grand to the Individual whose is known Jury, Grand the to known is unindicted identity whose 7, Individual co-conspirator 7, Jury, to unindicted co-conspirator identity in and to contact state legislators contact state with the Georgia and associated with with the Trump individuals associated with individuals legislators in Georgia Campaignto Trump Campaign TRUMP and and to appoint of DONALD JOHN to encourage unlawfully appoint them toto unlawfully encourage them elsewhere on'behalf JOHN TRUMP ofDONALD on behalf elsewhere the in furtherance of act states. This an overt overt actin furtheranceofthe was an This was their respective from their electors from presidential respective states. presidential electors conspiracy. conspiracy. \ '1 23 2

PDF Page 25	Act 19. Act19. of December 31st day and the the 31st the 1st 2020 and December 2020, day of or between of December On or December 2020 2020, 1st day between the On day of McEntee and with MEADOWS met and TRUMP and and MARK JOHN TRUMP John McEntee met with John DONALD RANDALL MEADOWS MARK RANDALL DONALD JOHN for and a requested that McEntee prepare a memorandum outlining a strategy for disrupting and delaying McEntee a memorandum that delaying disrupting outlining strategy prepare requested law for on January thejoint Congress on 2021, the the day prescribed by for counting counting votes votes session of Congress the by law 6, 2021, day prescribed January 6, joint sessionof the other states. The and from electors elected and cast by the duly elected and qualified presidential electors from Georgia and the other states. The the cast Georgia duly qualiﬁed presidential by half of the electoral count Pence "Mike" President Michael included having strategy included having Vice Vice President Michael R. R. “Mike” Pence count onlyhalfofthe electoral only strategy The state votes to The electoral legislatures. state to states and and then return the votes certain states electoral the remaining votes then return from certain Votes from legislatures. remaining furtherance of the an overt act in was an overt act in furtheranceofthe conspiracy. request was conspiracy. request 20. Act Act20. RUDOLPH WILLIAM LOUIS of December WILLIAM LOUIS about the On or December 2020, dayof 1st day the 1st or about On 2020, RUDOLPH House of the Arizona of met with with Speaker and JENNA JENNA LYNN Arizona House of GIULIANI ELLIS met LYNN ELLIS GIULIANI and Speaker ofthe and other other Arizona Arizona Senate Senate Karen Arizona Karer Fann, the Arizona Fann, and Presidentofof the Bowers, President Representatives Rusty Rusty Bowers, Representatives whose Individual legislators inin Phoenix, Phoenix, Arizona. Arizona. Unindicted 5, whose identity identity isis known known Unindicted co-conspirator co-conspirator Individual 5, legislators LOUIS WILLIAM RUDOLPH also present. the toto the the Grand Grand Jury, Jury, was was also During the meeting, RUDOLPH WILLIAM LOUIS meeting, present. During statements concerning GIULIANT made false false statements concerning fraud fraud inin the the November November 3,3, 2020, presidential GIULIANI made 2020, presidential call aa the legislators and importuned and solicited, election in Arizona Arizona and solicited, requested, requested, and legislators present present toto call election in importuned the in furtherance of the acts were overt the Arizona State These furtheranceofthe in session of wereovertacts These Legislature. special special session ofthe Arizona State Legislature. conspiracy. conspiracy. Act 21. Act21. of December about the On or or about On the 2nd 2nd day dayof December 2020, RUDOLPH WILLIAM WILLIAM LOUIS LOUIS 2020, RUDOLPH witnesses at and and JENNA GIULIANI and JENNA LYNN LYNN ELLIS ELLIS appeared, spoke, and presented witnesses at aa meeting GIULIANI meeting presented appeared, spoke, the Committee. of meeting, the House During of the Michigan Oversight Committee. During meeting, Michigan HouseofRepresentatives ofthe Representatives Oversight statements concerning RUDOLPH WILLIAM WILLIAM LOUIS LOUIS GIULIANI GIULIANT made made false false statements concerning fraud fraud inin the the RUDOLPH and and election in November 3,3, 2020, presidential election in Michigan and solicited, requested, and importuned November solicited, requested, importuned 2020, presidential Michigan electors from from the Michigan legislators present present atat the the meeting to unlawfully unlawfully appoint appoint presidential presidential electors the meeting to Michigan legislators and the ELLIS the JENNA LYNN Michigan. During the meeting, JENNA LYNN ELLIS solicited, requested, and importuned solicited, importuned the requested, meeting, Michigan. During electors from Michigan legislators legislators present present atat the the meeting meeting toto unlawfully unlawfully appoint appoint presidential presidential electors from Michigan overt'acts in ﬁirtherance of the These were Michigan. These were overt acts in furtheranceofthe conspiracy. conspiracy. Michigan. 22 Act Act22, TRUMP caused JOHN TRUMP 3rd day of December 2020, On about the the 3rd day ofDecember DONALD JOHN caused toto be be On or or about 2020, DONALD now on on @OANN. Twitter account@RealDonaldTrump, account @RealDonaldTrump, “Georgia the Twitter tweeted from from the hearings now @OANN. tweeted "Georgia hearings an overt furtherance of the conspiracy. This was Amazing!” This was an overt act act inin furtheranceofthe conspiracy. Amazing!" 24 u

PDF Page 26	Act23. LAC"i RUDOLPH WILLIAM LOUIS WILLIAM LOUIS about the 3rd day of December On or about 2020, RUDOLPH December 2020, the 3rd On or day of STALLINGS JENNA LYNN GIULIANI, EASTMAN, JENNA LYNN ELLIS, ELLIS, and and RAY RAY STALLINGS JOHN CHARLES CHARLES EASTMAN, GIULIANI, JOHN OF OATH OF VIOLATION OATH of SOLICITATION SOLICITATION OF VIOLATION OF offense of felony offense the felony SMITH III committed the III committed SMITH & in Fulton 16-47 County, of O.C.G.A. §§ 16-101, in Fulton County, BY violationofO.C.G.A. OFFICER, inin Violation PUBLIC OFFICER, BY PUBLIC §§ 164-7 & 16-10-1, ofﬁcers then certain then and officers public certain importuning and requesting, soliciting, unlawfully by public Georgia, importuning Georgia, by unlawfully soliciting, requesting, at a Senate and Senate of the Georgia Senate and present present ata Senate Judiciary as elected Judiciary membersoftheGeorgia elected members serving serving as Whose identity Individual 8, unindicted co-conspirator identity isis Subcommittee meeting, 8, whose including unindicted meeting, including ‘Subcommittee co-conspirator Individual Matt Dolezal, Brandon Greg Brass, Matt Beach, Lee Brandon Grand Jury, Senators Lee Anderson, Anderson, known Brass, Greg Dolezal, Beach, the Grand known toto the Jury, Senators Elena John F. F. Kennedy, William Ligon, Jen Jordan, Kennedy, William Bill Heath, Heath, Jen Steve Gooch, Ligon, Elena Steve Jordan, John Gooch, Tyler Tyler Harper, Harper, Bill the in conduct to and Blake constituting conduct in engage Michael Carden to Tillery, Blake and constituting the Parent, Michael Rhett, Summers, Tillery, engage Rhett, Carden Summers, Parent, 10- 1, by O. C. G. A. §§ 16 unlawfully by unlawfully of Oath Oath by 16-10-1, of Violation Public Officer, by Public Violationof Ofﬁcer, O.C.G.A. offenseof felony offense felony of of the terms intentional Violation and willful in terms of ofthe electors from violation intentional and willful in Georgia, appointing presidential presidential electors from Georgia, appointing in said said with intent engage in said of said persons as prescribed that said persons intent that the law, with prescribed by persons engage oathofsaid the oath by law, persons as of the conspiracy. conduct. This was an overt act act inin furtherance furtheranceofthe an overt This was conduct. conspiracy. Act 24. Act24, WILLIAM LOUIS RUDOLPH WILLIAM On or the 3rd December 2020, 2020, RUDOLPH LOUIS or about about the 3rd dayof On day of December AND in STATEMENTS WRITINGS, AND of FALSE STATEMENTS committed the offense FALSE of offense felony GIULIANI committed the felony WRITINGS, in GIULIANI and knowingly, wilfully, by knowingly, Georgia, by County, Georgia, in Fulton County, violation of O.C.G.A. §§ 16-10-20, violationof0.C.G.A. willfully, and 16-10-20, in-Fulton members to and statements false members to representations at least one of the falsestatementsand following oneofthe at least making unlawfully making representations following unlawfully Subcommittee meeting: meeting: ataa Senate Senate Judiciary of the Georgia present at Senate present Georgia Senate ofthe Judiciary Subcommittee in the November presidential 2020, presidential November 3,3, 2020, least 96,600 mailin ballots countedinthe were counted That at at least ballots were 1. 96,600 mail-in 1. That of those ballots retumed toto been returned having been ballots having recordofthose no record election election inin Georgia, Georgia, despitetherebeing despite there being no a a county elections office; ofﬁce; county elections November 3, 2.2. That Dominion Voting equipment used used inin the the November 2020, presidential That Dominion 3, 2020, presidential Voting Systems Systems equipment recorded 6,000 Antrim County, election in Antrim Michigan, mistakenly mistakenly recorded votes for for Joseph R. election in 6,000 votes Joseph R. County, Michigan, John Donald cast for when the the votes Biden when votes were were actually cast for Donald John Trump; Biden Trump; actually and Ofﬁce of the Georgia State and of State Georgia Secretary statements being within the said statements thejurisdictionofthe being within said Secretary of jurisdiction of the Officeofthe and of state and county and govemment, state government, county Bureau of ofInvestigation, the the Georgia agencies departments and agenciesof Investigation, departments Georgia Bureau O.C.G.A. §§ 16under O.C.G.A. of an act This was and city city law law enforcement This was an act ofracketeering activity under 16enforcement agencies. and activity racketeering agencies. of the act in furtherance and an overt 14-3(5)(A)(xif) and an overt act in furtheranceofthe conspiracy. 14-3 conspiracy. (5)(A)(xxii) 25 2

PDF Page 27	25. Act Act25, committed RAY STALLINGS STALLINGS SMITH SMITH III or about of December On about the the 3rd 3rd day December 2020, 2020, RAY III commited On or day of in violation of 0.C.G.A. O.C.G.A. §§ the offense of STATEMENTS AND the felony felony offense of FALSE FALSE STATEMENTS AND WRITINGS, violation of WRITINGS, in at least and 16-10-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making least in Fulton unlawfully making at 16-10-20, County, Georgia, by knowingly, willfully, of the Georgia oneofthe following false fale statements and representations representations toto members membersofthe Senate one of the following statements and Georgia Senate Subcommittee present at a Senate Judiciary Subcommittee meeting: at a Senate meeting: Judiciary present in the the November l. That 2,506 1. That felons voted voted illegally November 3,3, 2020, 2020, presidential presidential election election inin 2,506 felons illegally in Georgia; Georgia; seventeenth birthday 2.2. That That 66,248 underage people illegally registered registered toto vote vote before before their their seventeenth birthday 66,248 underage people illegally election in prior toto the the November November 3,3, 2020, 2020, presidential presidential election in Georgia; Georgia; prior election in November 3, That atleast at least 2,423 3.3. That 2,423 people people voted voted inin the the November 3, 2020, presidential election in 2020, presidential to listed as Georgia who who were were not not lsted as registered vote; registered to vote; Georgia in Georgia election in who Georgia who presidential election November 3,3, 2020, the November voted inin the 2020, presidential people voted 1,043 people That 1,043 4.4. That ofﬁce box; vote using had had illegally illegally registered registered toto vote using aa post post office box; election in in the voted in 5.5. That 10,315 or more dead people voted the November November 3,3, 2020, 2020, presidential presidential election in That 10,315 or more dead people Georgia; Georgia; and State Farm Arena ordered watchers and election workers That Fulton 6.6. That Fulton County workers atat State Farm Arena ordered poll poll watchers County election on the of November 3, members of the membersof the media media toto leave leave the the tabulation tabulation area area on the night nightofNovember 2020, and and 3, 2020, to after continued to leave; continued to operate operate after ordering ordering everyone everyone to leave; and of State State and Ofﬁce of the said statements being within within the thejurisdictionofthe the Georgia Secretaryof said statements being Georgia Secretary jurisdiction of the Officeof and and of state the of Investigation, departments the Georgia BureauofInvestigation, government, county agencies government, and county departments and agenciesofstate Georgia Bureau an act of under O.C.G.A. This was and city enforcement agencies. ‘and city law law enforcement Thiswas an act of racketeering activity under 0.C.G.A. §§ l616racketeering activity agencies. the of in furtherance and an overt act l4-3 14-3(5)(A)(xii) conspiracy. (5)(A)(xxii) and an overt act in furtheranceofthe conspiracy. Act 26. Act26, be December 2020, or about On the 3rd 3rd dayof 2020, DONALD DONALD JOHN JOHN TRUMP TRUMP caused caused toto be On or about the day 0f December "Wow! Blockbuster tweeted Twitter account@RealDonaldTrump, account @RealDonaldTrump, “Wow! Blockbuster testimony tweeted from from the the Twitter testimony taking taking the to leave Dems when were forced place right now in Georgia. Ballot stuffing by Dems when Republicans were forced to leave the Ballot now in stufﬁng by Republicans Georgia. place right alone leads to an win the This but this of State!" room. more large counting room. Plenty more coming, but this alone leads to an easy winof the State!” This easy coming, large counting Plenty of the conspiracy. was an overt act in was an overt act in ﬁlrtherance furtheranceofthe conspiracy. Act 27. Act27. JOHN TRUMP TRUMP caused caused to On about the the 3rd 3rd day dayof December 2020, DONALD JOHN to be be: 0f December On or or about 2020, DONALD in cold tweeted Twitter account account @RealDonaldTrump, tweeted from from the the Twitter “People in Georgia got caught cold @RealDonaldTrump, "People Georgia got caught machines. Great of ballots and bringing inin massive massive numbers numbersofballots and putting putting them them inin ‘voting’ Greatjob. 'voting' machines. job bringing of the in furtherance act This was an overt @BrianKempGA!” This was an overt act in furtheranceofthe conspiracy. conspiracy. @BrianKempGA!" 26 26

PDF Page 28	Act 28. Act28. with met with of December December 2020, 3rd day On about the day of DONALD JOHN JOHN TRUMP TRUMP met On or or about the 3rd 2020, DONALD at the Ofﬁce at the Oval the. of Representatives Bryan Oval Office Cutler inin the Bryan Cutler HouseofRepresentatives Speakerofthe Pennsylvania House Speaker of the Pennsylvania session of the General a Assembly. General White House and discussed Pennsylvania sessionofthe special a holding special Assembly. ‘White House and discussed holding Pennsylvania of the conspiracy. was an an overt furtheranceofthe This was overt act ‘This act inin furtherance conspiracy. Act 29. Act29. December 2020, On the 3rd December 2020 2020 and and the the 26th 26th day dayofof December of December 3rd day On or or between between the 2020, day of a telephone call call to RUDOLPH WILLIAM WILLIAM LOUIS LOUIS GIULIANI GIULIANI placed placed atelephone to President President Pro Pro Tempore Tempore. RUDOLPH statements Terrell "Butch" ofthe Senate Cecil “Butch” Miller Miller for for the the purpose purposeofof making making false false statements Cecil Terrell of the Georgia Georgia Senate an overt overt election in in Georgia. This was an concerning fraud in the the November 3, 2020, presidential election fraud in November 3, 2020, presidential Georgia. Thiswas concerning act in furtherance of the act in furtheranceof the conspiracy. conspiracy. Act 30. Act30. and the On or between between the the 3rd 3rd day of December December 2020 2020 and the 26th 26th dayof December 2020, 2020, On or day of December day of call to of the DONALD JOHN JOHN TRUMP TRUMP placed DONALD placed aa telephone telephone call to President President Pro Pro Tempore Tempore of the Georgia Georgia act in furtherance of the conspiracy. was an an overt overt actin Senate Butch ‘Senate Butch Miller. Miller. This This was furtheranceofthe conspiracy. Act 31. Act31. TRUMP placed of December JOHN TRUMP On or On or about about the the 5th 5th day December 2020, 2020, DONALD DONALD JOHN placed aa day of and Brian and Governor telephone call to Georgia Governor Brian Kemp and solicited, requested, and importuned Kemp call to solicited, requested, Kemp importuned Kemp telephone Georgia furtherance of of This was an overt overt actin act in furtherance session of the the Georgia to call call aa special General Assembly. Assembly. This was an to Georgia General special sessionof the the conspiracy. conspiracy. Act 32. Act32. JOHN TRUMP TRUMP caused caused to 6th day of December 2020, On or about the On the 6th dayofDecember 2020, DONALD DONALD JOHN to be be or about what a Has account @RealDonaldTrump, “Gee, tweeted from the tweeted from the Twitter Twitter account@RealDonaldTrump, what a surprise. Has anyone "Gee, anyone surprise. do anything!) & his informed Governor @BrianKempGA informed the the so-called so-called (says he has has no no power power toto do his anything!) Governor (says he @BrianKempGA & that could & WIN. solve this Lt. Governor puppet Lt. Govemor @GeoffDuncanGA, that they could easily solve this mess, & WIN. mess, they easily puppet @GeoffDuncanGA, an This was was an Session. So So easy! call aa Special hitps:/t.co/Scb4QdYzpU.” This verification && call Signature easy! 'https://t.co/5cb4QdepU." Special Session. Signature verification overt act in of the conspiracy. overt act in furtherance furtheranceofthe conspiracy. Act 33. Act33. entered SIDNEY KATHERINE the 6th 6th day On or about about the of December December 2020, 2020, SIDNEY KATHERINE POWELL POWELL entered On or day of SullivanStrickler LLC, ﬁrm located located in in into into aa written written engagement with SullivanStrickler LLC, aa forensic forensic data data firm agreement with engagement agreement of on the forensic and Fulton County, Fulton County, Georgia, Georgia, for for the performance performanceof computer collections and analytics analytics on computer forensic collections and of in elsewhere. The unlawful breach Dominion Voting Dominion Voting Systems equipment in Michigan and elsewhere. The unlawful breach of Systems equipment Michigan was under this Coffee County, election equipment election equipment inin Coffee County, Georgia, performed under this Georgia, was subsequently subsequently performed furtherance of the act in This was an overt agreement. This was an overt actin furtheranceofthe conspiracy. conspiracy. agreement. 27 27

PDF Page 29	Act 34. Act34. sent an CHEELEY sent an e-¢0f December DAVID CHEELEY 6th day ROBERT DAVID about the On or December 2020, the 6th or about On 2020, ROBERT day of whose Individual identity CHARLES EASTMAN, unindicted co-conspirator mail 8, whose identity EASTMAN, unindicted JOHN CHARLES mail toto JOHN co-conspirator Individual 8, on "I am that Senator Brandon Beach on and working am “I stated, that Grand Jury, Beach Brandon is known to Senator stated, working Georgia and the Grand to the is known Georgia Jury, also I am tomorrow. and the President Pro the call for with the Speaker for you up aa call setting Tempore tomorrow. I am also Speaker and the President Pro Tempore you with setting up meet on on December to meet of the for electors aware 14. December l4. to the electors Trump for importance the awareof leadership the making importance Trump leadership making This with." must This of the duties which with.” to the comply must they the citation which Please requirementsof the duties comply provide the cifation to the requirements they Please provide of the conspiracy. in furtherance was an furtheranceofthe conspiracy. act in was an overt overt act Act 35. Act35. an e sent an December 2020, JOHN CHARLES CHARLES EASTMAN 6th day ¢about the EASTMAN sent On 2020, JOHN dayofof December the 6th or about On or is whose is identity unindicted Individual whose 8, DAVID Individual ROBERT co-conspirator mail to unindicted 8, identity CHEELEY, DAVID CHEELEY, mail to ROBERT co-conspirator the that stated Senator Brandon Beach that and Georgia known Trump Jury, and Grand Jury, the Grand known toto the Georgia Senator Brandon Beach that stated that the Trump six sets of of needed to meet on December six sets sign in 2020, 14, nominees December on elector meet to needed Georgia in 2020, nominees l4, elector presidential sign Georgia presidential This other ofﬁcials." the and to them "to the President of Senate This officials.” mail other to and and mail them “to the President of the Senate certiﬁcates of vote, and of vote, certificates of the the conspiracy. act in in furtherance an overt overt act was an ‘was furtheranceof conspiracy. Act 36. Act 36, DAVID CHEELEY an e-c0f December ROBERT DAVID sent an 6th day CHEELEY sent On about the December 2020, day of the 6th or about On or 2020, ROBERT Grand Jury, that Individual 2, the Grand known toto the is known mail unindicted co-conspirator whose identity 2, whose Jury, that mail toto unindicted identity is co-conspirator Individual to set and was up aa to set up attempting EASTMAN and was attempting stated CHARLES EASTMAN JOHN CHARLES with JOHN been speaking had been he had stated he speaking with Pro President Pro and President House ofRepresentatives of Representatives David of the Georgia Ralston and David Ralston call with Speakerofthe with Speaker call Georgia House of the session a Butch Miller to them to call Senate Butch Miller to encourage Temporeofthe special sessionofthe encourage them to call a special Georgia Senate Tempore of the Georgia "Professor CHEELEY stated, DAVID CHEELEY stated, “Professor ROBERT DAVID e-mail, ROBERT the email, In the Assembly. In General Assembly. Georgia General Georgia next critical that the 16 Electors for President that it is Eastman told me tonight that it is critical that the 16 Electors for President Trump meet next told me Eastman Trump meet tonight ROBERT DAVID DAVID accordance with e-mail, ROBERT the e-mail, In the vote in 7.” In and vote U.S.C. §§ 7." with 3 U.S.C. in accordance Monday and Monday an overt act in was This assume can make sure this in "I overt act an Thiswas happens.” CHEELEY further this sure make can you CHEELEY further sated, stated, “I assume you happens." of the furtherance of furtherance the conspiracy. conspiracy. Act 37. Act37, of December Individual 2,2, the 7th unindicted co-conspirator On or or about 2020, unindicted December 2020, 7th day abou the On day of coconspirator Individual CHEELEY and sent an email to to ROBERT ROBERT DAVID and the Grand is known DAVID CHEELEY Whose an e-mail Jury, sent Grand Jury, known toto the whose identity identity is state GOP David can u a call with on DAVID JAMES that stated, “Bob, can u get on acall with David Shafer, state GOP DAVID SHAFER that JAMES SHAFER Shafer, "Bob, stated, get state. II of efforts eﬁ'orts in David has has been on top ofaa lot discuss. David ‘chair and II later later this this morning to discuss. been on top of lot of in the the state. chair and morning to This was an overt furtherance of the conspiracy. around 10:30." overt act call around off of aa board board call act inin furtheranceofthe was an 10:30.” This conspiracy. getoffof get 3 . 28 2

PDF Page 30	Act 38. Act38, of December On about the the 7th 7¢h day December 2020, RUDOLPH WILLIAM WILLIAM LOUIS LOUIS or about On or 2020, RUDOLPH day of of a retweet tweeted from GIULIANI caused caused toto be be tweeted from the the Twitter Twitter account account@RudyGiulianiaretweet of GIULIANI @RudyGiuliani that to the Grand known to the Grand Jury, whose identity unindictedco-conspirator Individual 8,8, whose identity isis known unindicted stated, Jury, that stated, co-conspirator Individual & state Senate House call to Call to Action: is the we need Patriot “Georgia Patriot Call to Action: today is the day we need you to call your state Senate & House your today day you "Georgia & fair elections in have free must in t0 the for a session. We elections fair & them free ask them to sign special session. We must have petition fora special Reps && ask sign the petition Reps This to ensuring vote is counted. @realDonaldTrump.” is counted. GA every legal our only this isis our GA && aa this only path ensuring every legal vote @realDonaldTrump." This path to the in furtherance of act was an overt was an overt act in furtheranceofthe conspiracy. conspiracy. Act 39. Act39. sent an On or or about the 7th dayof0f December December 2020, JOHN CHARLES EASTMAN sent an e-e7th day CHARLES EASTMAN about the On 2020, JOHN titled "The memorandum an attached mail toto RUDOLPH RUDOLPH WILLIAM WILLIAM LOUIS LOUIS GIULIANI GIULIANI with with anattached memorandum titled “The mail "Here's the e-mail stated, State's Electoral Votes." The The body of the e-mail Real Deadline Deadline for for Settling Electoral Votes.” bodyofthe stated, “Here's the Real Settling aa State’s CHESEBRO to JOHN The memorandum was written KENNETH discussed." ‘memo we discussed.” The memorandum was written by by KENNETH JOHN CHESEBRO to memo we the advocates for with the an attomey associated with James R. Troupis, Troupis, an the Trump for the James R. attomey associated Campaign, and advocates Trump Campaign,and cast meet and electoral should elector nominees in Wisconsin that position that Trump presidential elector nominees in Wisconsin should meet and cast electoral Trump presidential position JOHN TRUMP TRUMP on on December votes votes for for DONALD DONALD JOHN December 14, 14, 2020, 2020, despite despite the the fact fact that that DONALD DONALD This e-mail e-mail was was in Wisconsin. Wisconsin. This the November election in JOHN TRUMP TRUMP lost JOHN lost the November 3,3, 2020, 2020, presidential presidential election of the conspiracy. overt act an overt an act inin furtherance furtheranceofthe conspiracy. Act 40. Actdo, TRUMP requested that 0f December or about On or On about the the 7th 7th day December 2020, 2020, DONALD DONALD JOHN JOHN TRUMP requested that day of with the then residing an individual Bill White, Bill White, an individual associated associated with the Trump Trump Campaign in Fulton Fulton County, residing in County, Campaign then for information him with certain contact Majority for information information, including provide him with certain information, Majority Georgia, including contact Georgia, provide Senate Senate Mike Leaderofthe Mike Dugan and President President Pro Pro Temporeof the Georgia Leader of the Georgia Georgia Senate Tempore of the Georgia Senate Dugan and information to the an e-mail email containing Butch Miller. Miller. The The following following day, day, White White sent sent an the requested information to Butch requested containing WILLIAM LOUIS RUDOLPH LOUIS GIULIANI, unindicted co-conspirator Individual 5,5, whose whose RUDOLPH WILLIAM GIULIANI, unindicted co-conspirator Individual in furtherance of an overt act Grand and others. This was known to the is identity is known to the Grand Jury, and others. This request wasan overt act in furtherance of Jury, request identity the the conspiracy. conspiracy. Act 41. Actdl. 7th day 0f December On about the On or or about the 7th December 2020, RUDOLPH WILLIAM WILLIAM LOUIS LOUIS 2020, RUDOLPH day of of David call of the House GIULIANI placed GIULIANI placed aa telephone to Speaker Georgia House ofRepresentatives Representatives David Speaker of the Georgia telephone call to This was was an an of the Georgia General Assembly. discussed holding Ralston and and discussed holding aa special special session sessionofthe Assembly. This Ralston Georgia General the conspiracy. in furtherance ﬁthheranceoof overt act act in overt fthe conspiracy. 29 29

PDF Page 31	Act 42. Actd2, TRUMP committed JOHN TRUMP DONALD JOHN 7th day of December 2020, On or or about about the On the 7th dayofDecember 2020, DONALD committed the the OATH BY in offense of of SOLICITATION SOLICITATION OF PUBLIC OFFICER, BY PUBLIC OF OATH VIOLATION OF OF VIOLATION OFFICER, in felony offense felony 16-4-7 in Fulton violation 164-7 & 16-10-1, in Fulton County, Georgia, by unlawfully soliciting, of O.C.G.A. O.C.G.A. §§ & Violation of 16-10-1, County, Georgia, by unlawfully soliciting, §§ of Representatives David and importuning of the Georgia requesting, and Speakerofthe Georgia House HouseofRepresentatives David Ralston, Ralston, aa importuning Speaker requesting, of Oath by of Violation ofOath offense ofViolation conduct constituting public ofﬁcer, officer, toto engage in conduct consituting the the felony felony offense by engage in public the General of session O.C.G.A. §§ 1610-1, Public Officer, 0.C.G.A. 16-10-1, by by calling calling aa special Georgia General Public Ofﬁcer, special session ofthe Georgia from electors for the of Assemblyforthe purpose of unlawfully appointing presidential electors from Georgia, Georgia, inin willful willful unlawfully appointing presidential Assembly purpose with as of said Violation of the terms of the oath and intentional ‘and intentional violation ofthe termsofthe oath of said person person as prescribed prescribed by by law, law, with intent intent the conspiracy. act in an overt conduct. This furtheranceofoftheconspiracy. that said person in furtherance overt act was an This was said conduct. in said person engage that said engage in Act 43. Actd3. JOHN TRUMP 8th dayofDecember On or or about about the On the 8th DONALD JOHN TRUMP placed placed aa 2020, DONALD day of December 2020, of false statements the Carr for call to General Chris telephone call to Georgia Attorney General Chris Car for the purpose of making making false statements purpose Georgia Attorney telephone and elsewhere. election concerning fraud inin the the November November 3,3, 2020, presidential election in-Georgia in Georgia and elsewhere. 2020, presidential concerning fraud not other state asked Carr TRUMP During the telephone call, DONALD JOHN TRUMP asked Carr not toto discourage state the DONALD JOHN discourage other call, During telephone Texas the State of filed the ﬁom a federal lawsuit attorneys general fromjoining a federal lawsuit filed by the StateofTexas contesting the contesting by joining attorneys general election in administrationofthe November 3,3, 2020, 2020, presidential presidential election in Georgia, Georgia, Michigan, Michigan, administration of the November of the conspiracy. act in and Wisconsin. This was an overt Pennsylvania, and Wisconsin. Thiswasan overt act in furtherance furtheranceofthe conspiracy. Pennsylvania, Act 44. Actdd, TRUMP and and JOHN JOHN JOHN TRUMP On about the 8th dayof 2020, DONALD DONALD JOHN On or or about the 8th December 2020, day of December Committee National call to to Republican CHARLES placed aa telephone telephone call Republican National Committee EASTMAN placed CHARLES EASTMAN certain individuals her assistance assistance gathering to request Chairwoman Ronna McDaniel McDaniel to request her individuals toto meet meet and and Chairwoman Ronna gathering certain in certain December states on for DONALD JOHN TRUMP electoral votes votes for DONALD JOHN TRUMP on December 14, cast electoral 14, 2020, cast 2020, in certain states election lost the November the fact that DONALD JOHN TRUMP' despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election 3, 2020, presidential despite of the This was an act in furtherance those states. overt in in those states. This was an overt act in furtheranceofthe conspiracy. conspiracy. Act 45. Actds. A. ROMAN sent aa text On or about 8th day On or the 8th dayofof December December 2020, MICHAEL A.ROMANsent text about the 2020, MICHAEL to the is known Grand whose unindicted 1ndividual to ‘message to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, 4, identity Jury, co-conspirator message and asked asked unindicted stated that stated that he he had had spoken to MISTY MISTY HAMPTON, HAMPTON, and unindicted co-conspirator co-conspirator spoken to the before of to attend the Individual 44 toto “get” MISTY HAMPTON to attend the hearing before the Georgia House House of MISTY HAMPTON Individual Georgia hearing "get" This an act Governmental Affairs Representatives Governmental Affairs Committee Committee on on December December 10, 10, 2020. 2020. This was was an overt overt act Representatives furtherance of the conspiracy. inin furtheranceofthe conspiracy. 30 30

PDF Page 32	46. Act Act 46. JOHN CHESEBRO CHESEBRO wrote On or about the 9th dayofDecember On or about the 9th KENNETH JOHN wrote aa 2020, KENNETH day of December 2020, Electoral Votes” Votes" to to James James R. memorandum ‘memorandum titled titled “Statutory Requirements for for December December 14 14 Electoral R. "Statutory Requirements The memorandum an associated with the ‘Troupis, an attorney associated with the Trump Campaign. The memorandum provides detailed, provides detailed, Trump Campaign. Troupis, attorney for how how Trump state-specific instructions instructions for presidential elector elector nominees nominees inin Georgia, Arizona, Georgia, Arizona, state-speciﬁc Trurnp presidential meet and would cast electoral votes for Wisconsin and Michigan, Nevada, Pennsylvania, and Wisconsin would meet and cast electoral votes for Michigan, Nevada, Pennsylvania, the fact JOHN DONALD TRUMP on DONALD JOHN JOHN TRUMP on December December l4, 14, 2020, despite the fact that that DONALD DONALD JOHN 2020, despite in those act election in This was TRUMP lost TRUMP lost the the November November 3,3, 2020, 2020, presidential presidential election those states. states. This was an an overt overt act of the conspiracy. in in ﬂirtherance furtheranceofthe conspiracy. Act 47. Actd7. On or or about the 10th 10th day of December On about the December 2020, 2020, KENNETH KENNETH JOHN JOHN CHESEBRO CHESEBRO sent sent an an day of JAMES SHAFER SHAFER and e-mail e-mail toto Georgia Republican Party Chairman DAVID DAVID JAMES and unindicted unindicted cocoGeorgia Republican Party Chairman to the Grand KENNETH JOHN is known Individual whose conspirator Individual 9, whose identity is known to the Grand Jury. KENNETH JOHN 9, Jury. identity conspirator individuals associated with the CHESEBRO stated stated in e-mail that CHESEBRO in the the e-mail that certain certain individuals associated with the Trump Trump Campaign Campaign to With asked asked him him "to “10 help help coordinate coordinate with with the the other other 55 contested contested States, to help with logisticsofthe States, help logistics of the on Monday." This was an overt overt other States electors States hopefully electors inin other hopefullyjoining in casting casting their their votes votes on Monday.” This was an joining in act furtherance of the conspiracy. actinin furtheranceofthe conspiracy. Act 48. Actas, KENNETH JOHN sent an an On or about about the of December On or the 10th 10th day December 2020, 2020, KENNETH JOHN CHESEBRO CHESEBRO sent day of and e-mail with attached DAVID JAMES SHAFER unindicted documents to e-mail with attached documents to DAVID JAMES SHAFER and unindicted co-conspirators co-conspirators are known known to Grand Jury. Individual Individual 10, and Individual Individual 9,9, Individual 10, and Individual 11, 11, whose whose identities identities are to the the Grand The Jury. The in elector nominees for the documents documents were were toto be be used used by by Trump presidential elector nominees in Georgia for the purpose of Georgia purpose of Trump presidential on December December 14, electoral votes JOHN TRUMP TRUW on fact casting electoral votes for for DONALD DONALD JOHN 2020, despite despite the the fact 14, 2020, casting DONALD JOHN JOHN TRUMP election in that DONALD that TRUMP lost lost the the November November 3,3, 2020, presidential election in Georgia. 2020, presidential Georgia. This was an overt furtherance of the conspiracy. ‘This was an overt act actinin furtheranceofthe conspiracy. Act 49. Actd9. On or or about JOHN CHESEBRO CHESEBRO sent about the December 2020, On the 10th 10th dayof KENNETH JOHN sent an an 2020, KENNETH day of December email Director Greg Safsten attached documents documents to e-mail with with attached to Arizona Arizona Republican Party Executive Executive Director Republican Party Greg Safsten and The documents used by elector nominees in Arizona documents were and others. others. The were 'toto be be used Trump presidential elector nominees in Arizona by Trump presidential TRUMP on on December for of casting electoral electoral votes for the the purpose purposeofcasting votes for for DONALD DONALD JOHN JOHN TRUMP December 14, 14, 2020, 2020, lost the election that DONALD TRUMP lost despite the fact fact that DONALD JOHN JOHN TRUMP the November November 3,3, 2020, 2020, presidential presidential election despite the This was of the conspiracy. in an over't act in ﬂirtherance in Arizona. Arizona. This was anovertactin furtherance ofthe conspiracy. 3l 31

PDF Page 33	Act Act 50. 50. On or about the 10th dayof December 2020, KENNETH JOHN CHESEBRO sent an ‘e-mail to Republican PartyofWisconsin Chairman Brian Schimming with proposed language for documents to be used by Trump presidential elector nominees in Wisconsin for the purpose ofcasting 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 furtheranceofthe conspiracy. On or about the 10th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail to Republican Party of Wisconsin 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, Act51an KENNETH JOHN sent an JOHN CHESEBRO CHESEBRO sent On or about about the On or the 10th 10th dayof December 2020, 2020, KENNETH day of December JOHN Chairman Jirn DeGraffenreid. KENNETH e-mail to ‘e-mail to Nevada Nevada Republican Republican Party Party Vice Vice Chairman Jim DeGraffenreid. KENNETH JOHN and other other RUDOLPH WILLIAM LOUIS GIULIANI that CHESEBRO in the e-mail stated in the e-mail that RUDOLPH WILLIAM LOUIS GIULIANT and CHESEBRO stated other asked him "to reach out tto individuals associated with the the Trump him “to reach out o youandthe individuals associated With you and the other Campaign asked Trump Campaign to have all electors in all six contested on Nevada electors to the Nevada electors to run run point on the plan to have all Trump-Pence electors in all six contested Trump-Pence plan point an overt overt act Dec. 14.” 14." This This was States meet States meet and and transmit transmit their their votes votes toto Congress on Monday, Monday, Dec. wasan actinin Congress on furtherance of the furtheranceofthe conspiracy. conspiracy. Act 52 ActS2. JOHN CHESEBRO CHESEBRO sent On or or about about the 10th day On the 10th of December December 2020, KENNETH JOHN sent an an 2020, KENNETH day of The to DeGraffenreid. documents were be used with documents to Jim email e-mail with attached attached documentsto Jim DeGraffenreid. The documents were to beusedby by Trump Trump of for the electoral votes for DONALD in Nevada elector nominees presidential elector nominees in Nevada for the purpose of casting electoral votes for DONALD. purpose casting presidential the fect that DONALD TRUMP lost lost fact that JOHN TRUMP JOHN TRUMP TRUMP on on December JOHN December 14, 14, 2020, DONALD JOHN 2020, despite despite the overt actin act in furtherance the the November November 3,3, 2020, presidential election election inin Nevada. Nevada. This This was was an an overt furtherance of of 2020, presidential the the conspiracy. conspiracy. Act 52 Act52. KENNETH JOHN sent an On or or about about the On the 10th 10th dayof December 2020, 2020, KENNETH JOHN CHESEBRO CHESEBRO sent an day of December of Thomas Counsel Thomas e-mail with documents to attached documents ‘e-mail with attached to Republican Republican Partyof Pennsylvania General Counsel Party Pennsylvania General W. The documents in documents were be used by Trump elector nominees nominees in W. King Ill. The were totobeusedby presidential lector King III. Trump presidential electoral votes for DONALD TRUMP on for of JOHN the Pennsylvania for the purposeofcasting electoral votes for DONALD JOHN TRUMP on casting Pennsylvania purpose JOHN TRUMP TRUMP lost lost the December 14, the fact December 14, 2020, 2020, despite fact that that DONALD DONALD JOHN the November November 3,3, 2020, 2020, despite the an in This was overt act furtherance of the in election presidential election in Pennsylvania. This was an overt actin furtheranceofthe conspiracy. Pennsylvania. conspiracy. presidential Act 54. Act54, and the 14th day of December 2020, On or between the 10th On orbetweenthe 10th dayofDecember 2020 and the 14th dayofDecember 2020, day of December 2020 Individual whose DAVID JAMES SHAFER SHAFER contacted contacted unindicted DAVID JAMES unindicted co-conspirator Individual 2, whose identity is 2, coconspirator identity is discussed nindicted unindicted co-conspirator Individual 2's known the Grand Grand Jury, Known toto the Jury, by telephone and and discussed co-conspirator Individual 2's by telephone of Trump presidential elector nominees Fulton attendance at at the the December attendance December 14, 14, 2020, 2020, meeting meetingofTrump presidential elector nominees inin Fulton of the conspiracy. act in an overt overt act ‘County, This was wasan in furtherance furtheranceofthe conspiracy. County, Georgia. Georgia. This I 32 32

PDF Page 34	Act 55. Act 55, On or about the 10th dayof December 2020, RUDOLPH WILLIAM LOUIS GIULIANI and RAY STALLINGS SMITH III committed the felony offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, in violation of 0.C.G.A. §§ 164-7 & 16-10-1, in Fulton County, Georgia, by unlawfully soliciting, requesting, and importuning certain public officers then serving as elected membersofthe 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 offenseofViolationofOath by Public Officer, 0.C.G:A. § 16-10-1, by unlawfully appointing presidential electors from Georgia, in willful and intentional violationofthe termsofthe oath of saidpersonsas prescribed by law, furtheranceofthe in act with intent that said persons engagein said conduct. This wasanovert conspiracy. On or about the 10th day of December 2020, RUDOLPH WILLIAM 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 of Violation of Oath 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 33

PDF Page 35	Act 56. Act 56. On or about the 10th day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI committed the felony offense of FALSE STATEMENTS AND WRITINGS, in violation of 0.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least oneof the following false statements and representations to members ofthe Georgia HouseofRepresentatives present at a House Govemmental Affairs Committee: ‘meeting: meeting: State Farm from November that 2020, that clear from November 3,3, 2020, That it is video from Arena Video 1. Farm Arena the State from the is quite 1. Thatit quite clear were ofﬁcials workers were votes and that election workers were stealing Fulton stealing votes and that Georgia County election Fulton County Georgia officials were in a crime covering up acrime in plain sight; plain sight; covering up rid of all the of the ll of ofﬁcials “got on November Democratic officials That at State Farm November 3,3, 2020, 2 Arena on Farm Arena at State 2. That 2020, Democratic "got ridof of a excuse used the a of be excuse the used that couldn't trusted,” be all the couldn’t that anyone reporters, all the observers, trusted," observers, anyone reporters, crooked their dirty, "went about cleared out out the area and and then then “went dirty, crooked about their watermain voting area the voting break, cleared ‘watermain break, business”; business"; election counted by and 24,000 ballots were were illegally Fulton County by Fulton 3 illegally counted 12,000 and between 12,000 24,000 ballots County election That between 3. That on November Farm Arena State Farm workers ‘workers atat State Arena on November 3,3, 2020; 2020; out to counted than ballots counted 4.4 That That inin Michigan, Michigan, there there were were 700,000 700,000 more more ballots than were were sent sent out 10 voters voters for was accounted quadruple by which for accounted election, which was in presidential election, 2020, presidential November 3,3, 2020, the November in the by quadruple counting ballots; ballots; counting On or about the 10th day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI committed the felony offense of FALSE STATEMENTS AND WRITINGS, in Violation of O.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 A an unidentified unidentiﬁed man “quite obviously were "quite man were andan Moss, and Freeman, Shaye obviously Ruby Freeman, That Ruby 5. That Shaye Moss, State heroin or if vials of around USB as surreptitiously passing around USB ports ports as iftheyre ofheroin or cocaine" cocaine” atat State they're vials surreptitiously passing crooked Dominion "inﬁltrate the Farm Arena Arena toto be be used used toto “infiltrate the crooked Dominion voting voting machines"; machines”; Farm 5 election in the counted in November 3,3, 2020, the November mail-in ballots were counted ballots were 2020, presidential That 96,600 6.6 That presidential election 96,600 mail-in returned to been to of those ballots having been returned aa ballots having in recordofthose no record there being despite there in Georgia, being no Georgia, despite elections office; county elections ofﬁce; county and of the Ofﬁce of the Georgia said statements statements being Officeofthe jurisdictionofthe the jurisdiction within the being Within said Secretary of State and Georgia SecretaryofState and state and of of county and Bureau govemment, the state agenciesof and departments county Georgia BureauofInvestigation, the Georgia government, Investigation, departments agencies O.C.G.A. §§ 16under O.C.G.A. 16an act of racketeering activity enforcement agencies. and city wasanactofracketeering This was law enforcement ‘and activity under agencies. This city law furtherance of an overt act in and an 14-3 14-3(5)(A)(xxii) overt act in furtherance of the the conspiracy. conspiracy. (5)(A)(xxii) and 34 34

PDF Page 36	Act 57. Act57. SHAFER reserved On about the, of December 2020, On or or about the 11th 11th day dayofDecember DAVID JAMES JAMES SHAFER reserved Room Room 2020, DAVID State in for the December 216 at the Fulton 216at the Georgia State Capitol in Fulton County, Georgia, for the December 14, 2020, meeting 14, 2020, meeting Georgia Capitol County, Georgia, This was overt act of Trump presidential ofTrump presidential elector elector nominees nominees inin Fulton Fulton County, was an an overt act inin Georgia. This County, Georgia. furtherance of the conspiracy. furtheranceofthe conspiracy. Act Act 58. 58, CHESEBRO sent or about On or On about the the 11th 11th day of December December 2020, KENNETH JOHN JOHN CHESEBRO sent an an 2020, KENNETH day of and stated the electoral votes sent in Jim DeGraffenreid "the purpose of having e-mail mail toto Jim DeGraffenreid and stated that that “the purposeof havingtheelectoral votes sent in toto and to to the opportunity Congress isis toto provide to debate debate the the election election irregularities irregularities inin Congress, Congress, and Congress provide the opportunity to This an act in the that the votes be to was overt alive could keep alive the possibility that the votes could be flipped toTrump.”This was an overt act in possibility ﬂipped Trump." keep of the ﬁlrtherance furtheranceof the conspiracy. conspiracy. Act 59. 59. Act CHESEBRO sent sent an On or or about about the JOHN CHESEBRO an On the 11th 11th dayof December 2020, 2020, KENNETH KENNETH JOHN day of December The documents were to be used attached documents Safsten and others. e-mail with e-mail with attached documents toto Greg Safsten and others. The documents were to be used by by Greg votes for electoral votes ‘Trump presidential presidential elector elector nominees nominees inin Arizona Arizona for for the the purposeofcasting for Trump purpose of casting electoral on December JOHN DONALD JOHN TRUMP DONALD JOHN TRUMP on December 14, the fact fact that that DONALD DONALD JOHN 14, 2020, 2020, despite despite the was an lost the November Arizona. This overt TRUMP election in TRUMP lost the November 3,3, 2020, act inin 2020, presidential presidential election in Arizona. This was an overt act furtherance of the conspiracy. furtheranceofthe conspiracy. Act 60. Act 60. CHESEBRO sent or about of December JOHN CHESEBRO sent an an On or On about the the 11th 11th day day of December 2020, KENNETH JOHN 2020, KENNETH attached documents with attached documents to ROMAN and associated e-mail e-mail with to MICHAEL MICHAEL A. A. ROMAN and other other individuals individuals associated The documents the Trump documents were with with the were toto be be used used by by Trump presidential elector elector Trump Campaign. Campaign. The Trump presidential for the purposeofcasting TRUMP on on nominees in electoral votes votes for ‘nominees in Nevada Nevadaforthe for DONALD DONALD JOHN JOHN TRUMP purpose of casting electoral the TRUMP lost the November fact that DONALD JOHN December December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, 14, 2020, despite 3, 2020, of the conspiracy. election in This was overt act act in presidential in Nevada. Nevada. This was an an overt in furtherance furtheranceofthe conspiracy. presidential election Act 61. Act6l, On or or about KENNETH JOHN CHESEBROsentan sent an On about the the 11th 11th day of December December 2020, 2020, KENNETH JOHN CHESEBRO day of e-mail with documents to to MICHAEL ‘e-mail with attached attached documents MICHAEL A. A. ROMAN, unindicted co-conspirator co-conspirator ROMAN, unindicted The were Individual known to the the Grand and others. documents be Individual 5,5, whose whose identity identity isisknownto Grand Jury, and others. The documents were toto be Jury, of casting electoral used by elector nominees nominees in used by Trump presidential elector in Georgia for the the purpose purposeofcasting electoral Trump presidential Georgia for DONALD JOHN JOHN TRUMP fact votes for TRUMP on the that DONALD votes for DONALD on December December 14, 14, 2020, 2020, despite the fact that DONALD despite TRUMP lost lost the the November This was an overt JOHN overt JOHN TRUMP November 3,3, 2020, election inin Georgia. Georgia. This was an 2020, presidential presidential election of the conspiracy. act in furtherance actin furtheranceofthe conspiracy. ' 35 35

PDF Page 37	Act 62. Act62. contacted JAMES SHAFER SHAFER contacted On the 12th 12th day December 2020, 2020, DAVID DAVID JAMES On or or about about the of December day of Grand Jury, and known t0 whose identity unindicted co-conspirator Individual 12, 12, whose identity isis known to the the Grand unindicted Jury, and co-conspirator Individual discussed unindicted discussed unindicted co-conspirator co-conspirator Individual Individual 12's 12's attendance attendance atat the the December December 14, 14, 2020, 2020, act an overt overt act ‘meetingofTrump presidential elector nominees inin Fulton Fulton County, Georgia. This This was was an of Trump presidential elector nominees County, Georgia. meeting of the conspiracy. inin furtherance furtheranceofthe conspiracy. 63. Act Act63. On or about the 12th day of December 2020, MICHAEL A. ROMAN sent an e-mail to unindicted co-conspirators Individual 4 and Individual 7, whose idenitcs are known to the Grand Jury, and other individuals associated with the Trump Campaign. In the e-mail, MICHAEL A. ROMAN stated, “I need a tracker for the electors,” and instructed individuals associated with the Tramp 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 electornomineeshad confirmed that they would attend the December 14, 2020, meetingsof Trump presidential lector 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. On or about the 12th day of December 2020, MICHAEL A. 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, MICHAEL A. 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. Act6d. On or about the 12th day of December 2020, KENNETH JOHN CHESEBRO met with Brian Schimming and discussed the December 14, 2020, meetingofTrump presidential elector nominees in Wisconsin. RUDOLPH WILLIAM LOUIS GIULIANI joined the meeting by telephone and stated that the media should not be notifiedofthe December 14, 2020, meeting of Trump presidential elector nominees in Wisconsin. These were overtacts in furtheranceofthe On or about the 12th day of December 2020, KENNETH JOHN CHESEBRO met with Brian Schimming and discussed the December l4, 2020, meeting of Trump presidential elector nominees in Wisconsin. RUDOLPH WILLIAM 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. conspiracy. Act6s. AL65On or about the 12th dayofDecember 2020, MICHAEL A. ROMAN instructed an individual associated withthe Trump Campaign to distribute certain information relatedto the December 14, 2020, meetingsof Trump 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 furtheranceofthe conspiracy. On or about the 12th day of December 2020, MICHAEL A. ROMAN instructed an individual associated with the Trump Campaign to distribute certain information related to the December 14, 2020, meetings of Trump 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 36

PDF Page 38	AL"Act 66. Individual 4, On about the unindicted co-conspirator 4, December 2020, 12th dayof 2020, unindicted the 12th or about co-conspirator Individual On or day of December A. ROMAN and e-mail to MICHAEL sent an the Grand Jury,sentan whose identity identity is is known known to totheGrand e-mail to MICHAEL A.ROMAN and Whose Jury, the progress on the DAVID JAMES SHAFER with with updates updates on of organizing the December 14, 14, 2020, 2020, organizing the progress of meeting of Trump presidential elector nominees in Fulton County, Georgia. The e-mail stated individuals had had other individuals that other elector nominees meeting, that the meeting, which attend the would attend they would confirmed they had conﬁrmed nominees had ‘which elector refused to in the nominees refused that meeting, that of the elector the meeting, in case case some someofthe participate in to participate been elector nominees secured in been secured that DAVID to the and access to ensure Georgia legislators hadbeencontacted to ensure access to the Georgia Capitol, and that had contacted been Georgia Capitol, Georgia legislators in furtherance furtherance This was an overt act 216 for had reserved reserved Room JAMES SHAFER SHAFERhad Room 216 for the the meeting. meeting. This wasanovert act in JAMES meeting ofTrump presidential elector nominees in Fulton County, Georgia. The e-mail stated of the conspiracy. ofthe conspiracy. 67. Act 67. sent an an e-mail JAMES SHAFER SHAFER sent On or about of December On or the 12th 12th day day of December 2020, 2020, DAVID JAMES e-mail about the known to the Grand is advising Jury, whose Grand the to Individual known is unindicted identity whose 4, to Individual to unindicted co-conspirator 4, Jury, advising identity co-conspirator 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. them to “touch base” with each ofthe Trump presidential elector nominees in Georgia in advance ofthe December 14, 2020, meeting to confirm their attendance. This was an overtact in furtheranceofthe conspiracy. Act 68. 68. of December On or or about the 12th On about the 12th day December 2020, 2020, unindicted unindicted co-conspirator co-conspirator Individual Individual 4, 4, day of whose identity is knownto the Grand Jury, senta text message with contact information for whose identity is known to the Grand Jury, sent a text message with contactlinformation for and Georgia Grand Jury, whose identity Jury, and Individual 8, the Grand to the unindicted known to is known identity is Georgia unindicted co-conspirator 8, whose coconspirator Individual of providing the contact A. ROMAN Senator Brandon Brandon Beach Beach to to MICHAEL MICHAEL A. ROMAN for for the the purpose purposeofproviding the contact Senator an overt overt act act in in GIULIANI. This This was information to to RUDOLPH WILLIAM LOUIS LOUIS GIULIANI. was an information RUDOLPH WILLIAM of the conspiracy. furtherance furtheranceofthe conspiracy. Act 69. 69. an sent an CHESEBRO sent of December 2020, On or or about 13th day dayofDecember the 13th about the 2020, KENNETH JOHN CHESEBRO On The were to be used A. documents ROMAN. to MICHAEL ‘e-mail with attached documents to MICHAEL ROMAN. Thedocumentswere to be used by attached documents e-mail with by of casting electoral electoral votes votes elector nominees purposeofcasting the purpose for the Mexico for in New Mexico nominees in presidential elector Trump Trump presidential fact that DONALD JOHN the for DONALD JOHN TRUMP on December 14, 14, 2020, despite the fact that JOHN JOHN TRUMP on December for'DONALD 2020, despite was an overt act election in New Mexico. TRUMP lost the ‘TRUMP lost the November November 3, 3, 2020, presidential electionin Mexico. This was an overt act 2020, presidential in furtherance of the conspiracy. in furtherance ofthe conspiracy. 37 37

PDF Page 39	Act Act 70. 70. On or about the 13th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail to RUDOLPH WILLIAM LOUIS GIULIANI with the subject “PRIVILEGED AND CONFIDENTIAL - Brief notes on ‘Presidentofthe Senate’ strategy.” In the e-mail, KENNETH JOHN CHESEBRO outlined multiple strategies for disrupting and delaying thejoint 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.” Thiswas an overt act in furtherance of the conspiracy. On or about the 13th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail to RUDOLPH WILLIAM 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. AL71Act71. an sent an CHESEBRO sent On the 13th 13th dayof December 2020, 2020, KENNETH KENNETH JOHN JOHN CHESEBRO On or or about about the day of December and unindicted unindicted co-conspirator mail to MICHAEL MICHAEL A. A. ROMAN ROMAN and email with with attached attached documents documents to co-conspirator Grand Jury. The documentswereto documents were to be Individual 4,4, whose identity isis known known toto the the Grand be used used by Individual whose identity by Jury. The the votes for in for of electoral elector nominees “Trump presidential elector nominees in Georgia for the purposeofcasting electoral votes for Georgia purpose casting Trump presidential fact that JOHN December the DONALD on December l4, DONALD JOHN JOHN TRUMP DONALD TRUMP on 14, 2020, 2020, despite despite the fact that DONALD JOHN act in an overt overt act was an TRUMP lost the November November 3, TRUMP lost the 2020, presidential presidential election election inin Georgia. This was in 3, 2020, Georgia. This ﬁlrtherance of the furtheranceofthe conspiracy. conspiracy. Act 72. Act72. an CHESEBRO sent On or or about the 13th On about the 13th day of December December 2020, KENNETH JOHN JOHN CHESEBRO sent an 2020, KENNETH day of is Individual whose and unindicted A. ROMAN e-mail to MICHAEL MICHAEL A. ROMAN and unindicted co-conspirator Individual 4, whose identity e-mail to 4, identity is co-conspirator to "wants that RUDOLPH WILLIAM LOUIS LOUIS GIULIANT GIULIANI “wants to and stated known Grand Jury, known toto the the Grand stated that RUDOLPH WILLIAM Jury, and December 14, after all keep this this quiet quiet until until after al the the voting voting isis done,” in reference reference toto the the December 14, 2020, 2020, meeting done," in meeting keep an overt act in in Fulton This was of Trump elector nominees of presidential elector nominees in Fulton County, County, Georgia. in Georgia. This was an overt act Trump presidential furtherance of the conspiracy. furtheranceofthe conspiracy. Act 73. Act73. December 2020, DAVID JAMES JAMES SHAFER SHAFER sent On or or about about the On the 13th 13th dayof 2020, DAVID sent aa text text day of December Grand Individual whose is known to the ‘message to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, to unindicted 4, Jury, identity message co-conspirator is known and stated stated that that unindicted and unindicted co-conspirator Individual 8,8, whose whose identity known toto the the Grand Grand identity is co-conspirator Individual in nominees of elector December would attend the Jury, would attend the December 14, 2020, meetingof Trump presidential elector nominees in 14, 2020, meeting Trump presidential Jury, to a refused the of elector nominee who Fulton County, in the place place ofa Trump presidential elector nominee who refused to Fulton Trump presidential County, Georgia, Georgia, in an overt act in furtherance This was of the conspiracy. in the participate in the meeting. This was an overt act in furtheranceofthe conspiracy. meeting. participate 38 38

PDF Page 40	Act Act 74. 74. 13th dayof On or about the 13th December 2020, 2020, unindicted unindicted co-conspirator Individual 9,9, On or about the co-conspirator Individual day of December SHAFER JAMES SHAFER sent aa text DAVID JAMES Grand Jury, ‘whose identity isis known known toto the the Grand text message message toto DAVID whose identity Jury, sent known to is to and unindicted Individual whose is identity he whose 13, and conﬁrmed that Individual co-conspirator ‘and confirmed that he and unindicted co-conspirator 13, identity known elector December 14, attend the the December presidential elector Trump presidential the Grand Grand Jury, meetingofof Trump 2020, meeting 14, 2020, would attend Jury, would the of the This was an overt act in furtherance nominees inin Fulton Fulton County, Georgia. This was an overt act in furtheranceofthe conspiracy. nominees conspiracy. County, Georgia. Act 75. 75. Act TRUMP caused DONALD JOHN On or or about about the On the 14th 14th day dayof0f December December 2020, 2020, DONALD JOHN TRUMP caused toto be be a fool Governor account "What @BrianKempGA tweeted from the Twitter account @RealDonaldTrump, the Twitter tweeted from @RealDonaldTrump, “What a fool Governor @BrianKempGA it the so do it of is. Could have been so easy, but but now now we we have have toto do the hard hard way. way. Demand Demand this this have been is. Could of Georgia easy, Georgia could beaa bad and open up NOW. clown Special Session signature verification, NOW. Otherwise, couldbe bad call aa Special Sessionandopen clown call Otherwise, up signature veriﬁcation, the 5th." This an overt act on January act in dayfortwo Senators on This was wasanovert in furtherance furtheranceofof the GREAT Senators January Sth.” day for two GREAT conspiracy. conspiracy. Act Act 76. 76. sent a text December 2020, JAMES SHAFER SHAFER senta the 14th On 0r On or about about the 14th dayof DAVID JAMES text 2020, DAVID day of December the Grand known to Individual whose is to unindicted message to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury 4, Jury identity coconspirator message to what we attention towhatwe 216 to avoid drawing them to to avoid "Listen. Tell that that stated, stated, “Listen. Tell them to go to Room Room 216 drawing attention go straight straight to elector the December December 14, of Trump presidential are are doing," doing,” inin reference reference toto the 14, 2020, 2020, meeting meetingofTrump presidential elector the conspiracy. This wasanovert was an overt actin of the nominees inin Fulton Fulton County, County, Georgia. furtheranceof conspiracy. act in furtherance nominees Georgia. This Act 77. Act 71. On or about the 14th day of December 2020, MICHAEL A.ROMAN sent an e-mail to unindicted co-conspirators 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 ofthe conspiracy. On or about the 14th day 0f December 2020, MICHAEL A. 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. Act78. and SMITH III STALLINGS SMITH On about the the 14th 14th day of December December 2020, RAY STALLINGS III and On or 0r about 2020, RAY day 0f certain individuals SHAFER encouraged DAVID JAMES individuals present present atat the the December December 14, 14, 2020, 2020, DAVID JAMES SHAFER encouraged certain the document nominees in to document the elector Fulton sign to Georgia, County, of Fulton in nominees presidential elector Trump presidential meetingof Trump sign County, Georgia, meeting This OF THE THE 2020 GEORGIA." This titled “CERTIFICATE VOTES OF 2020 ELECTORS ELECTORS FROM FROM GEORGIA.” OF THE THE VOTES "CERTIFICATE OF titled of the conspiracy. act in an overt overt act was an in furtherance furtheranceofthe was conspiracy. 39 39

PDF Page 41	Act Act 79. 79. SHAWN On or about the 14th dayof December 2020, DAVID DAVID JAMES JAMES SHAFER, SHAFER, SHAWN unindicted coand CATHLEEN TRESHER STILL, MICAH TRESHER ALSTON LATHAM, LATHAM, and unindicted coMICAH STILL, CATHLEEN ALSTON Individual 11, conspirators Individual Individual 2,2, Individual Individual 8,8, Individual Individual 9,9, Individual Individual 10, 10, Individual Individual 12, 12, ll, Individual conspirators Individual and Individual Individual Individual and 18, Individual Individual 17, Individual 18, 14, Individual 15, Individual 13, 15, Individual 16, 16, Individual l7, 13, Individual l4, offense of of are known committed the Grand Jury, Individual 19, whose identities identities are known toto the the Grand the felony felony offense Individual 19, Whose Jury, committed in Fulton PUBLIC OFFICER, violation of O.C.G.A. in IMPERSONATING AA PUBLIC in violation of 0.C.G.A. § 16-10-23, in Fulton IMPERSONATING OFFICER, § 16-10-23, and qualified elected and as the duly elected County, Georgia, falsely holding holding themselves themselves out outastheduly qualiﬁed by unlawfully unlawfully falsely Georgia, by County, to mislead the intent ﬁom the State of with electors presidential electors from the Stateof Georgia, public officers, with intent to mislead the Georgia, public ofﬁcers, presidential of States Senate, Archivist of the United President of the United Presidentofthe United States the Archivistofthe United States, States, the the Georgia Secretary of Senate, the Georgia Secretary of Georgia for the the Northern States District District of and theChief the Chief Judgeofthe Northern District Court fo District Court United States State, and Georgia State, Judge of the United States mail United such officers into believing they actually were such by placing in the the United States mail toto said said that they ofﬁcers by into actually were believing that placing in FROM 2020 ELECTORS THE titled "CERTIFICATE OF THE VOTES OF persons a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM a document persons and act ofracketeering of racketeering activity This was GEORGIA.” was an an act activity under under O.C.G.A. O.C.G.A. §§ 16-14-3(5)(A)(xxiii) 16-14-3(5)(A)(xxiii) and GEORGIA." This anovert act inin furtherance furtherance of of the the conspiracy. conspiracy. an overt act On or about the 14th day of December 2020, Act 80. Act80. SHAWN JAMES SHAFER, about the December 2020, On the 14th 14th dayof DAVID JAMES On or or about SHAFER, SHAWN 2020, DAVID day of December coCATHLEEN ALSTON TRESHER STILL, MICAH ALSTON LATHAM, LATHAM, and and unindicted unindicted coMICAH TRESHER STILL, CATHLEEN Individual Individual Individual Individual Individual conspirators Individual 2,2, Individual 8,8, Individual 9,9, Individual 10, 10, Tndividual 11, 12, ll, Individual 12, conspirators Individual Individual Individual l3, 13, Individual Individual l4, 14, Individual Individual 15, 15, Individual Individual 16, 16, Individual Individual l7, 17, Individual Individual l8, 18, and and offense of are known committed the Grand Jury, Individual Individual 19, 19, whose whose identities identities are known toto the the Grand the felony felony offense of Jury, committed Fulton THE FIRST violation of .C.G.A. O.C.G.A. §§ 16-9-1(b), FORGERY IN IN THE FIRST DEGREE, DEGREE, inin violationof 16-9-1(b), inin Fulton FORGERY document titled with the intent to defraud, County, by, with the intentto knowingly making making aa document tiled defraud, knowingly Georgia, by, County, Georgia, “CERTIFICATE OF OF THE THE VOTES VOTES OF OF THE THE 2020 2020 ELECTORS ELECTORS FROM FROM GEORGIA,” "CERTIFICATE GEORGIA," aa writing writing to have been made in such manner that the as made other than than aa check, in such manner that the writing as made purports to have been made by other check, by writing purports State of who electors from of the duly authorityofthe elected and and qualiﬁed qualified presidential from the the Stateof Georgia, Georgia, who duly elected presidential electors authority Archivist of the and uttered delivered said said document document to not give such authority, did not did uttered and and delivered to the the Archivistofthe authority, and give such and was an act of under O.C.G.A. United States. activity under O.C.G.A. §§ 1614-3(5)(A)(xvi) 16-14-3(5)A)xvi) and This was an act ofracketeering United States. This racketeering activity of the conspiracy. act in furtherance an overt an overt actin furtheranceofthe conspiracy. _ 40 40

PDF Page 42	Act 81. Act8L. SHAF ER, SHAWN SHAWN On or about the 14th December 2020, DAVID JAMES JAMES SHAFER, about the 14th dayof On or 2020, DAVID day of December and unindicted coTRESHER STILL, CATHLEEN ALSTON MICAH TRESHER CATHLEEN ALSTON LATHAM, and unindicted coMICAH LATHAM, STILL, conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual 11, Individual 12, Individual 13, Individual 14, Individual 15, Individual 16, Individual 17, Individual 18, and Individual 19, whose identities are known to the Grand Jury, committed the felony offense of FALSE STATEMENTS AND WRITINGS, in violationof0.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 Presidentofthe United States ofAmerica from the StateofGeorgia, do hereby certify the following,” said document being within thejurisdictionofthe Officeofthe Georgia SecretaryofState and the Officeofthe ‘Govemorof Georgia, departments and agenciesofstate government. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xxii) and an overt act in furtheranceofthe conspiracy. conspiracy. 14le Act82. 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 AND WRITINGS, in violation of O.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 of America from the State of Georgia, 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 of Georgia, 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 JAMES SHAFER, On or or about about the On the 14th 14th dayofDecember 2020, DAVID DAVID JAMES SHAWN SHAFER, SHAWN day of December 2020, and unindicted coALSTON TRESHER STILL, CATHLEEN MICAH MICAH TRESHER CATHLEEN ALSTON LATHAM, and unindicted coLATHAM, STILL, 12, Individual 12, 11, Individual conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual ll, Individual 13, 13, Individual Individual 14, 14, Individual Individual 15, 15, Individual Individual l6, 16, Individual Individual l7, 17, Individual Individual 18, 18, and and Individual Individual l9, 19, whose whose identities idenities are are known known toto the the Grand Grand Jury, Jury, attempted to commit commit the the felony felony Individual attempted to O.C.G.A. §§ 16-10-20.1(b)(1), violation of 0.C.G.A. offenseof FILING FALSE FALSE DOCUMENTS, DOCUMENTS, inin violationof 16-10-20.1(b)(1), inin offense of FILING a document titled "CERTIFICATE in the States mail United Fulton Fulton County, Georgia, by placing in the United States mail a document titled “CERTIFICATE Counw, Georgia, by placing to Chief Judge, addressed toChief OF THE OF THE THE VOTES ‘OF VOTES OF THE 2020 2020 ELECTORS ELECTORS FROM FROM GEORGIA,” GEORGIA," addressed Judge, D. Russell Federal Oﬁice Richard Northern District of 2188 U.S. U.S. District District Court, Northern District ofGeorgia, 2188 Richard D. Russell Federal Office: Court, Georgia, GA 30303, with intent intent to to Building and U.S. U.S. Courthouse, Courthouse, 75 75 Ted Ted Turner Drive, SW, SW, Atlanta, Atlanta, GA Turner Drive, 30303, with Building and the United reason and record in a court of said document knowingly file, enter, and record said document inacourt of the United States, having reason toto States, having knowingly ﬁle, enter, THE false said document document contained contained the know know that that said the materially statement, “WE, "WE, THE UNDERSIGNED, UNDERSIGNED, materially false statement, Vice President of the United and elected and Electors for President the being the duly elected and qualified Electors for President and Vice Presidentofthe United being duly qualiﬁed was an act of of the This State of Georgia, do States of America Statesof America from from the the Stateof do hereby certify the following.” This was an act following." hereby certify Georgia, overt act of the the under O.C.G.A. O.C.G.A. §§ 16-14-3(5)(A)(xxii) 16-14-3 (5)(A)(xxii) and racketeering activity activity under and an an overt act inin furtherance furtheranceof racketeering conspiracy. conspiracy. conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual a 41

PDF Page 43	Act 83. Act83. SHAWN On or about the On or about the 14th 14th dayof December 2020, DAVID JAMES JAMES SHAFER SHAFER and and SHAWN 2020, DAVID day of December FORGERY IN THE FIRST of the offense TRESHER committed MICAH MICAH TRESHER STILL STILL committed the felony felony offense ofFORGERY IN THE FIRST in Fulton Fulton County, of O.C.G.A. §§ 1691(b), DEGREE, inin Violation violationof0.C.G.A. 16-9-1(b), in Georgia, by, by, with with the the intent intent DEGREE, County, Georgia, of of Electoral Notice titled "RE: a document to to defraud, knowingly making College Filling of Electoral College defraud, knowingly making a document titled “RE: NoticeofFilling such manner Vacancy,” aa writing writing other other than than aa check, check, inin such manner that that the the writing writing as as made made purports t0 have have purports to Vacancy," electors from the State and elected been the of the been made made by the authority ofthe duly elected and qualified presidential electors from the State: qualiﬁed presidential by duly authority delivered said said document document to and delivered who did did not such authority, of Georgia, who not give ofGeorgia, and uttered uttered and to the the authority, and give such under O.C.G.A. of racketeering activity of the United This was an act Archivist Archivistofthe United States. States. This was an actofracketeering under O.C.G.A. § 16-14activity § 16-14the of overt act act in 3(5)(A)(xvi) and and an an overt in furtherance furtheranceofthe conspiracy. conspiracy. 3(5)(A)(xvi) 84. Act Act84, On or about the 14th dayofDecember 2020, DAVID JAMES SHAFER and SHAWN MICAH TRESHER STILL committed the felony offense of FALSE STATEMENTS AND WRITINGS, in violationof 0.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making and using a false document titled “RE: NoticeofFilling of Electoral College Vacancy,” with knowledge that said document contained the false statements that DAVID JAMES SHAFER was Chairman ofthe 2020 Georgia Electoral College Meeting and SHAWN MICAH TRESHER STILL was Secretaryofthe 2020 Georgia Electoral College Meeting, said document being within thejurisdictionofthe Officeofthe Georgia Secretary of State and the Officeofthe GovemorofGeorgia, departments and agenciesofstate government. ‘This was an actofracketeering activity under 0.C.G.A. § 16-14-3(5)(A)(xxii) and an overt act in furtheranceof the conspiracy. On or about the 14th day of December 2020, DAVID JAMES SHAFER and SHAWN MICAH TRESHER STILL committed the felony offense of FALSE STATEMENTS AND WRITINGS, in violation of O.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making and using a false document titled "RE: Notice of Filling 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 SHAWN MICAH 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 of Georgia, 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. Acts. of December On or or about about the On the 14th 14th day December 2020, 2020, DAVID DAVID JAMES JAMES SHAFER SHAFER instructed instructed day of the Grand deliver to whose identity unindicted co-conspirator 15, whose identity isis known known to10 the Grand Jury, Jury, toto deliver to unindicted Individual 15, coconspirator Individual DAVID and JAMES SHAFER a document theOfficeofthe of Georgia a document signed by DAVID JAMES SHAFER and the Ofﬁce of the Governor Governor of signed by Georgia Electoral College "RE: Notice SHAWN STILL titled titled “RE: Notice of of Filling Filling of ofElectoral SHAWN MICAH MICAH TRESHER TRESHER STILL College This was an overt act in statements. The false Vacancy.” The document contained multiple false statements. Thiswasan overt act in document contained multiple Vacancy." of the furtherance furtheranceofthe conspiracy. conspiracy. Act 86. Act 86. On 14th day On or or about about the the 14th of December December 2020, unindicted co-conspirator Individual 4,4, 2020, unindicted co-conspirator Individual day of to sent an e-mail MICHAEL A. whose identity ‘whose identity isis known known toto the the Grand Grand Jury, Jury, sent an e-mail to MICHAEL A.ROMAN, ROMAN, to the Grand is known and others others whose Individual unindicted co-conspirator ‘unindicted Individual 7, whose identity is known to the Grand Jury, 7, identity Jury, and co-conspirator mailed now. Ran that stated, that “All votes votes cast, paperwork complete, being mailed now. Ran pretty in stated, "All cast, paperwork pretty smoothly,” smoothly," in complete, being elector nominees in Fulton Fulton of Trump reference reference toto the the December December 14, 14, 2020, 2020, meeting meetingof Trump presidential presidential elector nominees in of the conspiracy. an overt act in overt act County, Georgia. This This was was an in furtherance furtheranceofthe conspiracy. County, Georgia. 2 42

PDF Page 44	Act 87. Act87, STEPHEN CLIFFGARD CLIFFGARD LEE On or or about On about the 14th dayofDecember LEE attempted attempted the 14th 2020, STEPHEN day of December 2020, O.C.G.A. in Violation of commit the offense of toto commit the felony of INFLUENCING INFLUENCING WITNESSES, WITNESSES, in violation of 0.C.G.A. §§ 1616felony offense a Fulton to the home of in Fulton 10-93(b)(1)(A), in Fulton County, Georgia, by traveling to the home ofRuby Freeman,a Fulton Freeman, traveling Ruby County, Georgia, by 10-93(b)(1)(A), intent to knowingly County, worker, and and speaking speaking toto her her neighbor, neighbor, with with intentto knowingly engage election worker, engage County, Georgia, Georgia, election offer her intent to and with with intent inin misleading misleading conduct toward Ruby Ruby Freeman, Freeman, by by purporting to offer her help, help, and to conduct toward purporting to events influence her testimony testimony inin an proceeding inin Fulton Fulton County, Georgia, concerning events inﬂuence her an official ofﬁcial proceeding County, Georgia, concerning in Georgia. was an act election in at at State Farm Arena Arena inin the the November 3, 2020, presidential election Thiswasan act State Farm November 3, 2020, presidential Georgia. This act in and an overt to O.C.G.A. of racketeering activity ofracketeering pursuant to 0.C.G.A. § 16-14-3(S)(A)(xxvii) andan overt act in § 16143(5)(A)(xxvii) activity pursuant furtherance of the conspiracy. furtheranceofthe conspiracy. Act 88. Act88, On or about the 15th day of December 2020, STEPHEN CLIFFGARD LEE attempted to commit the felony offense of INFLUENCING WITNESSES, in violation of 0.C.G.A. § 1610-93(b)(1)(A), in Fulton County, Georgia, by traveling to the home of Ruby 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 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 ofracketeering activity pursuant to 0.C.G.A. § 16-14-3(S)(A)(xxvii) and an overt act in furtheranceofthe conspiracy. On or about the 15th day of December 2020, STEPHEN CLIFFGARD LEE attempted to commit the felony offense of INFLUENCING WITNESSES, in violation of O.C.G.A. § 1610-93(b)(1)(A), in Fulton County, Georgia, by traveling to the home of Ruby 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. Act89. 2020 and and the December 2020 4th day of January 2021, On or 15th dayof or between On betwween the the 15th the 4th dayofJanuary 2021, day of December an PRESCOTT FLOYD, STEPHEN CLIFFGARD CLIFFGARD LEE LEE solicited solicited HARRISON STEPHEN HARRISON WILLIAM WILLIAM PRESCOTT FLOYD, an t0 for Trump, his effort individual associated with individual associated with the the organization organization Black Black Voices Voices for to assist assist with with his effort to Trump, to election worker. STEPHEN CLIFFGARD to a Fulton speak to Ruby Freeman, a Fulton County, Georgia, election worker. STEPHEN CLIFFGARD County, Georgia, speak Ruby Freeman, FLOYD that afraid to LEE WILLIAM PRESCOTT LEE stated stated toto HARRISON HARRISON WILLIAM PRESCOTT FLOYD that Freeman Freeman was was afraid to talk talk to man. These These were overt acts acts in were overt LEE because to STEPHEN STEPHEN CLIFFGARD CLIFFGARD LEE because he he was was aa white white man. in furtherance of the conspiracy. furtheranceofthe conspiracy. Act 90. Act90. On or JOHN TRUMP TRUMP met with or about the 18th On about the 18th dayofDecember DONALD JOHN met with 2020, DONALD day of December 2020, unindicted RUDOLPH RUDOLPH WILLIAM WILLIAM LOUIS LOUIS GIULIANI, SIDNEY KATHERINE KATHERINE POWELL, POWELL, unindicted GIULIANI, SIDNEY . known to the the Grand and others Individual 20, whose identity co-conspirator 20, whose identity isis knownto Grand Jury, Jury, and others atat the the White White co-conspiratorIndividual certain strategies and theories House. The individuals House. The individuals present present atat the the meeting meeting discussed discussed certain strategies and theories intended intended to inﬂuence the of the November to influence the outcome outcomeofthe November 3,3, 2020, 2020, presidential presidential election, including seizing election, including voting seizing voting broad POWELL as counsel with KATHERINE and SIDNEY equipment and appointing SIDNEY KATHERINE POWELL as special counsel with broad special equipment appointing This was an overt act of voter voter fraud to investigate ‘authority investigate allegations allegationsof fraud inin Georgia and elsewhere. elsewhere. This was an overt act Georgia and authority to in of the conspiracy. in furtherance furtheranceofthe conspiracy. 3 43

PDF Page 45	Act 91. Actor. sent On or 21st dayof or about about the On the 21st December 2020, 2020, SIDNEY SIDNEY KATHERINE KATHERINE POWELL POWELL sent day of December Ofﬁcer of she that she him that an e-mail Chief Operations instructed him and instructed LLC and email to SullivanStrickler LLC of SullivanStrickler theChief o the an Operations Officer identities and whose Individual Individual Individual and unindicted unindicted co-conspirators Individual 6, Individual 21, and Individual 22, whose identities and 6, 22, 21, co-conspirators obtained by "receive a a copyofall data" obtained were to are to the the Grand Jury, were to immediately are known known to Grand Jury, by immediately “receive copy of all data” was an This in SullivanStrickler LLC from from Dominion Dominion Voting Voting Systems in Michigan. This was an SullivanStrickler LLC Systems equipment Michigan. equipment the act in furtherance of overt overt act in furtherance of the conspiracy. conspiracy. Act 92. Act92. MARK RANDALL MEADOWS of December On or about the the 22nd On 22nd day December 2020, 2020, MARK RANDALL MEADOWS or about day of in Cobb Center and Civic traveled traveled toto the the Cobb Cobb County attempted toto observe observe the the County, Georgia, Georgia, and attempted County Civic Center in Cobb County, law the there enforcement ofﬁcers from match audit signature match audit being performed there by law enforcement officers from the Georgia Georgia by being performed signature fact that of the Georgia the fact and the of State, the Oﬁice Bureau of Investigation Bureau of Investigation and Officeofthe State, despite that the the Georgia Secretary despite the Secretary of RANDALL While present MARK RANDALL to the the public. audit audit process process was was not not open open to present atat the the center, center, MARK public. While of the Georgia State Jordan Jordan Fuchs, Georgia to Georgia Officeofthe MEADOWS Fuchs, Ofﬁce MEADOWS spoke Secretary of State Georgia Deputy Deputy Secretaryof spoke to of Investigation Special Investigation Special Chief Investigator Bureau of Watson, Georgia Frances Watson, Investigator Frances StateChief of State Secretary Georgia Bureau Secretary of from MARK RANDALL MEADOWS and who ‘Agent in Charge Bahan Rich, and others, who prevented MARK RANDALL MEADOWS from Bahan in others, Rich, prevented Agent Charge act in in furtherance audit was conducted. This This was an overt overt act where the entering into into the space where the audit was being being conducted. was an furtherance the space entering of of the the conspiracy. conspiracy. Act 93. Act93. DONALD JOHN JOHN TRUMP or about about the On On or the 23rd 23rd dayofDecember 2020, DONALD TRUMP placed placed aa day of December 2020, Watson that of State Chief Frances of the telephone call to Officeofthe Georgia SecretaryofState Chief Investigator Frances Watson that call to Ofﬁce Georgia Secretary Investigator telephone MARK RANDALL been previously had been previously amranged by MARK RANDALL MEADOWS. MEADOWS. During During the the phone phone call, call, had arranged by DONALD JOHN TRUMP DONALD JOHN TRUMP falsely falsely stated stated that that he he had had won won the the November November 3,3, 2020, presidential 2020, presidential and stated of thousands of votes" and election in election in Georgia “by hundreds hundredsofthousandsofvotes” stated toto Watson Watson that that "when “when the the Georgia "by This was of the be an overt act furtherance in answer comes out right answer comes out you'll be praised.” This was an overt act in furtheranceofthe conspiracy. conspiracy. you'll praised." right Act 94. Act 94, sent an an eeJOHN CHARLES CHARLES EASTMAN the 23rd On about the 23rd dayof December 2020, EASTMAN sent On or or about 2020, JOHN day of December and unindicted whose unindicted co-conspirator mail JOHN CHESEBRO mail toto KENNETH KENNETH JOHN CHESEBRO and Individual 3,3, whose co-conspirator Individual with the "FW: Draft edits'." In the known to the Grand with is identity is known to the Grand Jury, e-mail, 2, with edits.” In the e-mail, subject “FW: Draft 2, Jury, with the subject identity a memorandum attached a memorandum titled "PRIVILEGED AND JOHN CHARLES CHARLES EASTMAN JOHN EASTMAN attached titled “PRIVILEGED AND CONFIDENTIAL Dec 23 on Jan Jan 66 scenario.docx" scenario docx” and for hearings, think 23 memo memo on and stated, "As for CONFIDENTIAL — Dec stated, “As hearings, II think we the of electors demonstrates demonstrates the both are unnecessary. both are unnecessary. The The fact fact that that we have have multiple slatesofelectors multiple slates I And Committee be Ken that That should with of either. uncertainty ofeither. That should be enough. AndT agree with Ken that Judiciary Committee enough. Judiciary agree uncertainty we do Electoral that we of the Count Act invite counter views could invite counter views that on the hearings on the constitutionalityofthe Electoral Count Act could do constitutionality hearings in the the exercise have under of should constrain not not believe believe should constrain Pence Pence (or Grassley) inthe exercise ofpower they have under the (or Grassley) power they act boldly 12% Amendment. Amendment. Better Better for for them themjust o act boldly and and be be challenged, challenged, since the challenge challenge would would since the 12th just to This was was on nonjusticiable Court denying likely lead lead toto the the Court review on question grounds." grounds.” This nonjusticiable political denying review political question likely of the conspiracy. an overt act an overt act inin furtherance furtheranceofthe conspiracy. -- 44 “

PDF Page 46	Act Act 95. 95. TRUMP placed JOHN TRUMP 25th day of December On or about the 25th December 2020, DONALD JOHN placed aa about the On or 2020, DONALD day of the purpose for the Bowers for call to to Speaker telephone call Speaker of of the the Arizona Arizona House House of of Representatives Representatives Rusty Rusty Bowers purpose telephone electors and Bowers to of soliciting, requesting, and importuning Bowers to unlawfully appoint presidential electors of soliciting, importuning unlawfully appoint presidential requesting, stated to to Trump, voted for you. II for you. worked for for you. “I voted from Bowers stated the call, Arizona. During from Arizona. call, Bowers Trump, "I you. II worked During the an overt call was won't d0 for This overt I callwasan for telephone This you.” for illegal anything do won't you.I just campaigned for you. telephone anything illegal you." just campaigned of the conspiracy. act in furtherance actin furtheranceofthe conspiracy. Act 96. Act96. a sent a 27th day of December MARK RANDALL On the 27th December 2020, 2020, MARK RANDALL MEADOWS MEADOWS sent about the On or or about day of that Watson Frances the of of State Chief text message message toto Ofﬁce Office of the Georgia Georgia Secretary Investigator Frances Watson that text Secretary of StateChief Investigator order to a to Fulton "Is there stated in part, “Is there a way to speed up Fulton county signature verification in in order to have have stated in way speed up county signature veriﬁcation part, act in furtherance an overt assist was if the This Jan 6 results before Jan 6ifthe tramp campaign assist financially.” This was an overt act in furtherance results before trump campaign ﬁnancially." of the conspiracy. ofthe conspiracy. Act 97. Act97. solicited TRUMP solicited December 2020, On the 27th DONALD JOHN JOHN TRUMP 27th dayof or about about the On or 2020, DONALD day of December States Deputy General Jeffrey and Acting Acting United United States Jeffrey Rosen Rosen and United States Deputy Attorney Attorney States Attorney Acting United Attorney General Acting the election was that "Just say statement by General Donoghue toto make make aa false false statement by stating, stating, “Just that the election was Richard Donoghue General Richard say in an overt act the This was to me and leave the corrupt, and the rest rest tomeand the Republican Republican congressmen.” and leave congressmen."This Wasan overt act in corrupt, furtherance furtheranceofof the the conspiracy. conspiracy. Act 98. Act 98. CLARK attempted of December BOSSERT CLARK about the JEFFREY BOSSERT On or On or about the 28th 28th day day of December 2020, 2020, JEFFREY attempted of oﬁense of FALSE STATEMENTS AND toto commit commit the the felony felony offenseof FALSE STATEMENTS AND WRITINGS, WRITINGS, inin violation violation of 0.C.G.A. 16-10-20, inin Fulton Fulton County, by knowingly and willfully willfully making making aa false false: O.C.G.A. §§ 16-10-20, County, Georgia, Georgia, by knowingly and States that the United the same to contain the false statement and document writing and document knowing the same to contain the false statement that the United States knowing writing outcome had "identiﬁed significant concerns that Justice of Departmentof Justice had “identified that may may have have impacted impacted the the outcome signiﬁcant concerns Department within the statement the State of said ofthe in multiple multiple States, including the State of Georgia,” said statement being the election in of the election States, including being within Georgia," of Bureau of the Georgia Secretary the Georgia of the Ofﬁce and the jurisdictionofthe OfficeoftheGeorgia Secretary of of State State and Georgia Bureau of jurisdiction and city and of state and Investigation, departments and agencies of state govemment, and county and law city law agencies government, county Investigation, departments enforcement enforcement agencies; agencies; CLARK sent sent 28th dayofDecember or about And And on on or about the the 28th JEFFREY BOSSERT BOSSERT CLARK 2020, JEFFREY day of December 2020, United States States Attorney General Jeffrey and Acting United States an e-mail Acting United Attorney General Rosen and Acting United States an e-mail to to Acting Jeffrey Rosen send said said false Richard and to General authorization Deputy Attorney General Richard Donoghue and requested authorization to send false Donoghue requested Deputy Attorney House Governor Brian writing and to Georgia Brian Kemp, Kemp, Speakerofthe of and document document to Georgia Governor Georgia House of Speaker of the Georgia writing Butch and Senate David President Pro of the Representatives David Ralston, and President Pro Tempore of the Georgia Senate Butch Miller, Miller, Ralston, Georgia Tempore Representatives and commission of False Statements Statements and Writings, substantial step ‘which toward the the commissionofFalse which constitutes constitutes aa substantial Writings, step toward an actofracketeering act of racketeering activity 0.C.G.A. 16-10-20. This This was was an activity under under O.C.G.A. .C.G.A. §§ 16-1416-14O.C.G.A. §§ 16-1020. furtherance of of the overt act and an an overt 3(5)(A)(xxii) act inin furtherance the conspiracy. conspiracy. 3(5)(A)(xxii) and 4 45'

PDF Page 47	Act 99. Act99. On or about the 28th day of December 2020, JEFFREY BOSSERT CLARK solicited Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Atiormey General Richard Donoghue to sign and send a document that falsely stated that the United States Departmentof Justice had “identified significant concerns that may have impacted the outcome ofthe election in multiple States, including the State ofGeorgia,” to Georgia Governor Brian Kemp, Speakerofthe Georgia House of Representatives David Ralston, and President Pro : Temporeofthe Georgia Senate Butch Miller. This was an overt act in furtheranceofthe conspiracy. Act Act 100. 100. caused to TRUMP caused JOHN TRUMP of December December 2020, be to be 30th day On or about about the DONALD JOHN dayof the 30th 2020, DONALD On or on the the Georgia from Atlanta Georgia the Twitter Twitter account Atlanta on tweeted from account@RealDonaldTrump, from the "Hearings from tweeted @RealDonaldTrump, “Hearings more. and it out. broadcast. Check more. now many and overturn @newsmax Election many being broadcast. Check it out. @OANN Election overturn now being @OANN @newsmax to admit who refuses ofﬁce. He is an obstructionist should from we. that we admit that to refuses who obstructionist an is He office. from resign should @BrianKempGA resign @BrianKempGA of the in furtherance an overt act was furtheranceofthe won the other States." This actin overt BIG! Also an was This States.” Swing won other Georgia, BIG! Also won the won Georgia, Swing conspiracy. conspiracy. Act Act 101. 101. caused to TRUMP caused JOHN TRUMP be to be about the On DONALD JOHN December 2020, 30th dayof the 30th 2020, DONALD On oror about day of December on the the Georgia Georgia the Twitter Atlanta on from Atlanta tweeted account @RealDonaldTrump, Twitter account from the "Hearings from tweeted from @RealDonaldTrump, “Hearings broadcast LIVE via now overturn now being htpsy/t.cologBvLbKfqG.” Election being broadcast LIVE via @RSBNetwork! Election overturn @RSBNetwork! https://t.co/ogBvaKfqG." act in ‘This was an an overt overt act in furtherance furtherance ofoftthe he conspiracy. This was conspiracy. 102 Act Act102. 0f December On the 30th 30th day December 2020, 2020, RUDOLPH RUDOLPH WILLIAM WILLIAM LOUIS LOUIS about the or about On or day of committed CHEELEY DAVID and ROBERT STALLINGS SMITH RAY committed CHEELEY DAVID ROBERT and II, SMITH STALLINGS III, GIULIANI, GIULIANI, RAY BY PUBLIC OATH OF OF VIOLATION of SOLICITATION OF oﬁense ofSOLICITATION the felony the felony offense VIOLATION OF OATH BY PUBLIC OFFICER, OFFICER, in Fulton Fulton County, by soliciting, Georgia, by O.C.G.A. §§ in violation of 0.C.G.A. 164-7 && 16-10-1, 16-10-1, in soliciting, in violationof County, Georgia, §§ 16-4-7 of the the elected members ofﬁcers then requesting, and and importuning certain public public officers then serving as elected membersof serving as importuning certain requesting, unindicted at a Senate Senate Judiciary Subcommittee meeting, and present including unindicted meeting, including Senate and present ata Georgia Judiciary Subcommittee Georgia Senate Brandon Senators to the Grand whose is known Individual Beach, Brandon Beach, Senators Jury, Grand the to known is identity whose 8, Individual 8, Jury, co-conspirator identity co-conspirator in conduct to Michael Blake Bill William Ligon, Ligon, Michael Rhett, Rhett, and and Blake Tillery, Tillery, to engage engage in conduct constituting Bill Heath, constituting Heath, William Oath O.C.G.A. unlawfully of Violation of Public by 16-10-1, § oﬁense 0.C.G.A. Officer, Public the by l6-lO-l, ViolationofOath of Oﬁicer, offense by unlawfully the felony § by felony of intentional violation the State of Georgia, appointing presidential electors electors from from the State of Georgia, inin willful willful and and intentional violation of appointing presidential that said said persons of said persons as prescribed engage inin of the oath the intent that with intent by law; prescribed by law, with persons as persons engage oathofsaid termsofthe the terms of the an overt act in furtherance This was conspiracy. t he conduct. of said said conduct. This was an overt act in furtherance conspiracy. On or about the 28th day 0f December 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 of Georgia," 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. 46 46

PDF Page 48	Act 103. Act 103. WILLIAM LOUIS RUDOLPH WILLIAM LOUIS or about about the On or 2020, RUDOLPH December 2020, dayofof December 30th day the 30th On in STATEMENTS AND of FALSE WRITINGS, in committed the offense of AND WRITINGS, GIULIANI committed FALSE STATEMENTS felony offense the felony GIULIANI and willfully, and knowingly, willfully, 0.C.G.A. §§ 16-10-20, Fulton County, of 0.C.G.A. Violation in Fulton by knowingly, violationof 16-10-20, in Georgia, by County, Georgia, members and to unlawfully making making atat least least one one ofthe following false false statements statements and representations representations to members of the following unlawfully Subcommittee Senate at a Senate ofthe Senate present at a Senate Judiciary Subcommitice meeting: of the Georgia meeting: Judiciary Georgia present certain ballots counted certain election workers That Fulton 1. That Fulton County County election workers ﬁaudulently fraudulently counted ballots asas many l. many November times at at State State Farm as ﬁve as five times Farm Arena Arena on on November 3,3, 2020; 2020; in election in voted illegally That 2,560 presidential election 2. November 3,3, 2020, the November illegally inin the 2020, presidential felons voted 2. That 2,560 felons Georgia Georgia; election in in * That 10,315 dead people voted in the November 3. That 10,315 dead people votedinthe November 3,3, 2020, presidential election 3. 2020, presidential Georgia; Georgia; and the Georgia Office of the within the said statements statements being thejurisdictionofthe said Secretary of State and. Georgia SecretaryofState being within jurisdiction of the Officeof and of state and agenciesofstate of Investigation, departments government, and county the BureauofInvestigation, the Georgia government, county agencies departments and Georgia Bureau under 0.C.G.A. 16an act of §§ 16This was 0.C.G.A. under activity and city racketeering actof an was This enforcement agencies. activity law enforcement city law and racketeering agencies. the in furtherance of and an overt aCt 14-3 14-3(5)(A)(xxi) conspiracy. (5)(A)(xxii) and an overt actin furtheranceofthe conspiracy. 104 Act Act 104, SMITH III the 30th dayofDecember On or or about On aboutthe30th 2020, RAY RAY STALLINGS STALLINGS SMITH ITI day of December 2020, violation of offense of of FALSE STATEMENTS AND committed the felony felony offense FALSE STATEMENTS AND WRITINGS, WRITINGS, inin violation of committed the and in 0.C.G.A. 16-10-20, in Fulton Fulton County, by knowingly, willfully, and unlawﬁllly unlawfully 0.C.G.A. §§ 16-10-20, knowingly, willfully, County, Georgia, Georgia, by members to of the and membersofthe one of statements to at least false representations and statements faise following oneofthe least at making representations thefollowing making a Subcommittee Senate at Senate Georgia present at a Senate Judiciary meeting: Judiciary Subcommittee meeting: Georgia Senate present General Counsel 1. That Counsel Ryan Ryan Germany Germany stated stated that that his his 1. That Georgia State General Georgia Secretaryof Secretary of State ofﬁce had sent officehad sent letters letters toto 8,000 people who who voted voted illegally illegally inin the the November November 3,3, 8,000 people in to vote the and them not election told 2020, presidential election and told them not to vote in the January 5,5, 2021, 2021, runoﬂ' runoff January 2020, presidential election; election; 2. That the Georgia admitted "that “that they they had hadaa 90% 90% accuracy rate” That the 2. accuracy rate" Georgia SecretaryofState Secretary of State admitted a 10% "there's still still a 10% margin and that election and in the November in the November 3,3, 2020, presidential election that “there’s 2020, presidential margin not aceurate”; that's not that’s accurate"; of the Georgia and said statements being being within thejurisdictionofthe Office ofthe Georgia SecretaryofState within the said statements Secretary of State and jurisdiction of the Ofﬁce of state and and the Georgia Bureauof Investigation, departments and agenciesofstate government, and county Bureau of the Georgia government, county agencies Investigation, departments under 0.C.G.A. act of was an and city city law This was an actofracketeering activity under O.C.G.A. §§ l616enforcement agencies. This law enforcement and racketeering activity agencies. of the and an overt act in furtherance l43 14-3(5)(A)(xxii) conspiracy. (5)(A)(xxii) and an overt act in furtheranceofthe conspiracy. a 47

PDF Page 49	Act 105. committed CHEELEY committed of December On or or about about the 30th day On the 30th December 2020, 2020, ROBERT ROBERT DAVID DAVID CHEELEY day of Violation of AND WRITINGS, of 0.C.G.A. O.C.G.A. §§ the offense of STATEMENTS AND the felony felony offense of FALSE FALSE STATEMENTS WRITINGS, inin violation and unlawﬁllly 16-10-20, inin Fulton Fulton County, Georgia, by by knowingly, knowingly, willfully, willfully, and unlawfully making making atat least least 16-10-20, County, Georgia, of the Georgia Senate oneofthe following false false statements statements and and representations representations toto members membersofthe Senate of the following one Georgia Subcommittee meeting: present atat aa Senate Senate Judiciary meeting: present Judiciary Subcommittee of Arena were State Farm 1. 1. That That poll poll watchers watchers and and media mediaatat State Farm Arena were told told late late inin the the evening evening of the next was being November count was that the November 3,3, 2020, the vote vote count being suspended suspended until until the next 2020, that "a watermain of and to home because morning and to go go home because of “a major break”; major watermain break"; morning Arena “voted” "voted" the same State Farm 2.2. That workers atat State Farm Arena the same. That Fulton Fulton County election workers County election ballots "over and and over on November over again” ballots “over November 3,3, 2020; 2020; again" on of the Georgia of State and said statements being the jurisdiction of the Office said statements within thejurisdictionofthe Officeofthe Georgia Secretary Secretary ofStateand being within and county the of Investigation, the Georgia Georgia Bureau Bureau of Investigation, departments departments and and agenciesofstate county agencies of state goverment, government, and under O.C.G.A. an act of and city enforcement agencies. This was ‘and law enforcement was an actofracketeering 16+ racketeering activity activity under 0.C.G.A. §§ l6 city law agencies. This of the in furtherance 14-3 and an overt act 14-3(5)(A)(xxii) and an overt act in furtherance ofthe conspiracy. conspiracy. (5)(A)(xxii) Act Act 106. 106. caused to JOHN TRUMP TRUMP caused or about December 2020, On the 30th 30th dayof DONALD JOHN to be be On or about the 2020, DONALD day of December "We now have far more votes than from the tweeted from the Twitter Twitter account account @RealDonaldTrump, “We now have far more votes than tweeted @RealDonaldTrump, needed needed toto ﬂip flip Georgia Georgia inin the the Presidential Presidential race. race. Massive Massive VOTER VOTER FRAUD FRAUD took took place. Thank you place. Thank you an act of This was overt in furtherance to for to the the Georgia Legislature for today’s revealingmeeting!” This was an overt act in furtherance of Georgia Legislature today's revealing meeting!" the the conspiracy. conspiracy. Act107. Act107wrote aa On or or about 3lst day the 31st On about the day of of December December 2020, JENNA LYNN LYNN ELLIS ELLIS wrote 2020, JENNA 0f Vice for President Authority Constitutional Analysis memorandum ‘memorandum titled titled "Memorandum “Memorandum Re: Re: Constitutional Analysis of Vice President Authority for TRUMP. The to DONALD JOHN Count" 2021 Vote Electoral January 6, 2021 Electoral College Vote Count” toDONALD JOHN TRUMP. The College January 6, on and delaying of Congress memorandum outlined aa strategy memorandum outlined for disrupting disrupting and delaying the the joint joint session session of Congress on strategy for cast by for counting January 6, 2021, 2021, the the day prescribed by by law law for votes cast by the the duly elected and and counting votes duly elected January 6, day prescribed the other and "the Vice President and electors from qualified presidential electors from Georgia and the other states, and stated, “the Vice President states, stated, Georgia qualiﬁed presidential six states, should therefore therefore not should not open the votes" votes” from from six including Georgia, that were were falsely falsely states, including Georgia, that any of the open anyof This an overt act in furtherance of in was characterized as "electoral characterized as having “electoral delegates in dispute.” This was an overt act in furtherance of delegates dispute." having the conspiracy. the conspiracy. Act105- 4 48

PDF Page 50	Act Act 108. 108. JOHN and JOHN TRUMP and JOHN TRUNIP of December DONALD JOHN 31st day 2020, DONALD On or or about about the December 2020, day of the 31st On in of FILING FALSE offense in the DOCUMENTS, FALSE committed CHARLES EASTMAN DOCUMENTS, offenseofFILING felony the (CHARLES EASTMAN committed felony Fulton County, filing aa knowingly ﬁling by knowingly violation of of O.C.G.A. Georgia, by 16-10-20.1(b)(1), inin Fulton 0.C.G.A. §§ 16-10-20.1(b)(1), violation County, Georgia, INJUNCTIVE AND AND COMPLAINT FOR document titled "VERIFIED COMPLAINT EMERGENCY INJUNCTIVE FOR EMERGENCY itled “VERIFIED document Case 1:20cv05310-MHC, the matter the DECLARATORY RELIEF" 1:20-cv-05310-MHC, inin the Kemp, Case Trump v.V. Kemp, matterofof Trump RELIEF” inin the DECLARATORY of Georgia, aa courtofthe court of the United for the United States the Northern Northern District DistrictofGeorgia, United States States Court for United States District District Court false contained at at least one of the following materially false following materially document contained least oneofthe said document reason to know that that said to know having reason having statements: statements: sentence" voted illegally the in the l.1. That That "as as 2,506 felons uncompletedsentence”voted an uncompleted with an felons with manyas2,506 “as many illegally in in election November 3, November 3, 2020, presidential election in Georgia; Georgia; 2020, presidential November 3,3, 2020, the November 2. That "at in the voted illegally 2020, people voted underage” people 6,247 underage" least 66,247 “at least 2. That illegally in in election presidential election in Georgia; Georgia; presidential in the November presidential 2020, presidential November 3,3, 2020, illegallyinthe voted illegally That "at individuals” voted 2,423 individuals" least 2,423 “at least 3.3. That been as in the State's records registered been not listed having as were records "who State’s the in election in in Georgia listed not were “who election registered having Georgia to to vote"; vote”; presidential 2020, presidential 4. November 3,3, 2020, the November That "at least 1,043 illegally inin the voted illegally individuals” voted 1,043 individuals" “at least 4. That as their to vote a ofﬁce box their as box office postal a election "who using vote to registered had illegally “who had election using postal illegally registered habitation"; habitation"; November 3, dead people or more" 5. That “as many many asas 10,315 10,315 or more” dead people voted voted inin the the November 5. That "as 2020, 3, 2020, in election presidential election in Georgia; Georgia; presidential and watchers and Republican poll 6. instruct Republican used toto instruct That “[djeliberate was used misinformation was 6. That poll watchers "[d]eliberate misinformation at 10:00 for the the on. p.m. to leave 10:00 approximately at members of the night the for premises the leave to press p.m. on ‘membersofthe press night approximately premises State Farm November November 3,3, 2020" 2020” atat State Farm Arena Arena inin Fulton Fulton County, County, Georgia; Georgia; associated an e-mail email to attorneys associated to attorneys CHARLES EASTMAN sent an EASTMAN sent Earlier on on the JOHN CHARLES same day, the same Earlier day, JOHN some of the allegations the in the with least someofthe thataat least knowledge that his knowledge Campaign admitting allegations in the Trump with the admitting his Trump Campaign under of was an act This not accurate. verified complaint were not accurate. This filing was an actofracketeering activity under veriﬁed were ﬁling racketeering activity complaint act in furtherance of the conspiracy. overt act O.C.G.A. §§ 16-14-3(5)(A)(xxii) O.C.G.A. 16-14-3(S)(A)(xxii) and and an an overt in furtheranceofthe conspiracy. Act 109. Act 109. an esent an On or oraboutthe Ist dayof January 2021, 2021, KENNETH KENNETH JOHN JOHN CHESEBRO CHESEBRO sent On about the lst day of January whose and unindicted mail toto JOHN unindicted co-conspirator Individual 3,3, whose mail CHARLES EASTMAN EASTMAN and JOHN CHARLES co-conspirator Individual outlined JOHN CHESEBRO In the KENNETH identity is known to the Grand Jury. In the e-mail, KENNETH JOHN CHESEBRO outlined aa is known to the Grand e-mail, Jury. identity on January session of Congress the day and delaying 6, 2021, for disrupting thejoint 2021, the day strategy Congress on January 6, joint sessionof delaying the strategy for disrupting and electors the elected and votes cast clectors presidential law for qualified and elected by the duly counting votes cast by by law for counting prescribed by duly qualiﬁed presidential prescribed an overt act in furtherance of the conspiracy. states. This This was from from Georgia Georgia and and the the other other sates. was an overt actin furtheranceofthe conspiracy. - e 49 9

PDF Page 51	Act Act 110. bail 0f January 2021, SCOTT GRAHAM GRAHAM HALL, Georgia bail HALL, aa Georgia On oraboutthe or about the 2nd 2021, SCOTT dayofJanuary 2nd day On and discussed call to JEFFREY BOSSERT the a telephone call discussed the CLARK and BOSSERT CLARK to JEFFREY placed atelephone bondsman, placed bondsman, 63 minutes The telephone election in was 63 minutes inin November call was telephone call in Georgia. 3,3, 2020, November 2020, presidential Georgia. The presidential election act in duration. overt act in furtherance furtherance of of the the conspiracy. conspiracy. This was an overt duration. Thiswasan Act 111. Act111, CLARK solicited JEFFREY BOSSERT BOSSERT CLARK solicited On or or about 2nd dayofJanuary the 2nd about the 2021, JEFFREY On day 0f January 2021, J Rosen United States General and Atiomey Deputy States United States United Acting Acting United States Attorney Deputy Attorney eﬁ'rey Rosen and Acting Attorney General Jeffrey Acting States stated that and send send aa document document that General Richard Donoghue Donoghue toto sign that falsely falsely stated that the the United United States General Richard sign and outcome the concerns that have had "identiﬁed Departmentof Justice had “identified significant conces that may have impacted the outcome of Justice signiﬁcant may impacted Department Brian Governor Brian of Georgia,” ofthe election inin multiple States, including including the the State Stateof to Georgia Georgia Governor of the election Georgia," to multiple States, and President House of Representatives David Kemp, Speakerof the Georgia David Ralston, Ralston, and President Pro Pro Georgia HouseofRepresentatives Kemp, Speaker of the the of Miller. This was an act in furtherance Butch Miller. This was an overt overt act in furtherance ofthe Senate Butch of the Georgia ‘Temporeofthe Georgia Senate Tempore conspiracy. conspiracy. Act 112. Act 112. MARK and MARK JOHN TRUMP TRUMP and 2nd day On or or about the 2nd dayof0f January 2021, DONALD DONALD JOHN On about the January 2021, OF VIOLATION of SOLICITATION OF RANDALL MEADOWS MEADOWS committed committed the the felony felony offense offenseofSOLICITATION VIOLATION RANDALL Fulton in Fulton of 0.C.G.A. O.C.G.A. §§ 164-7 && 16-10-1, OF OATH BY violation of OFFICER, inin violation PUBLIC OFFICER, 16-10-1, in BY PUBLIC OF OATH §§ 16-4-7 of and Secretary Georgia importuning and requesting, soliciting, unlawfully soliciting, requesting, importuning Georgia Secretary of by unlawfully County, Georgia, County, Georgia, by offense of of conduct constituting felony offense the felony State Brad Brad Raffensperger, in conduct to engage ofﬁcer, to Raffensperger, aa public State engage in constituting the public officer, O.C.G.A. unlawfully Public altering, of Oath unlawfully by Violation 16-10-1, § 0.C.G.A. Officer, by Public Oﬁicer, ViolationofOath by § 16-10-1, by unlawfully altering, unlawfully for the certiﬁed adjusting, unlawfully influencing certified returns returns for for presidential presidential electors electors for and otherwise otherwise unlawfully inﬂuencingthe adjusting, and of the in willful election in and intentional the November November 3,3, 2020, 2020, presidential presidential election in Georgia, willful and intentional violation violation of the the Georgia, in in said with intent that said termsofthe oathofsaid person asas prescribed prescribed by by law, law, with intent that said person person engage engage in said terms of the oath of said person of the an overt overt act conduct. This was an conduct. This was act inin furtherance furtherance of the conspiracy. conspiracy. 110. 50 50

PDF Page 52	Act 113. Act113. On or about the 2nd dayof January2021, DONALD JOHN TRUMP committed the felony offense ofFALSE STATEMENTS AND WRITINGS, in violation of 0.C.G.A. § 1610-20, 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 SecretaryofState Jordan Fuchs, and Georgia SecretaryofState General Counsel Ryan Germany: from 250,000 were dropped anywhere from 250,000 toto 300,000 ballots were mysteriously l.1. That That anywhere 300,000 ballots dropped mysteriously in November 3, election into the the rolls rolls inin the the November 3, 2020, presidential election in Georgia; into 2020, presidential Georgia; to vote thousands of people attempted 2. That That thousandsofpeople vote inin the the November November 3,3, 2020, 2020, 2. attempted to not because ballot election in and were told could aa ballot because not they could Georgia and were told they presidential election in Georgia presidential had had already been cast cast inin their their name; name; already been election in 3. That That 4,502 people voted voted inin the the November November 3,3, 2020, 2020, presidential presidential election in 3. 4,502 people were not on the voter who Georgia who were not on the voter registration registration list; list; Georgia November 3, 904 people 4.4. That That 904 people voted voted inin the the November 3, 2020, presidential election election inin 2020, presidential an address ofﬁce box; address that was aa post Georgia who who were were registered registered atat an thatwas post office box; Georgia vote scammer scammer and 5.5. That Freeman was was a.aprofessional and aa known known political political That Ruby Ruby Freeman professional vote operative; operative; and others others were were responsible 6.6. That That Ruby Freeman, her her daughter, responsible for for daughter, and Ruby Freeman, State Farm Biden at least ballots to R. fraudulently awarding at least 18,000 ballots to Joseph R. Biden atat State Farm 18,000 Joseph fraudulently awarding in Georgio; election in Arena Arena inin the the November November 3,3, 2020, 2020, presidential presidential election Georgia; dead people November 3, 7.7. That close toto 5,000 people voted voted inin the the November 2020, presidential presidential That close 5,000 dead 3, 2020, election in election in Georgia; Georgia; election in in the 8.8. That 139%ofpeople the November November 3,3, 2020, 2020, presidential presidential election in of people voted voted in That 139% Detroit; Detroit; votes were of people who the number 9. That That 200,000 more votes were recorded recorded than than the numberofpeople who voted voted 9. 200,000 more in November3, inin the the November presidential election election in Pennsylvania; Pennsylvania; 3, 2020, 2020, presidential the November 3, 10. thousands of dead people 10. That That thousandsofdead people voted voted inintheNovember 3, 2020, 2020, presidential presidential election Michigan; election inin Michigan; Freeman stuffed stuﬁ'ed the l11. l. That That Ruby Ruby Freeman the ballot ballot boxes; boxes; hundreds of thousands of ballots had That hundredsof 12. thousandsofballots had been been "dumped" “dumped into into Fulton Fulton County County 12. That to Fulton in the November ‘and another county county adjacent to Fulton County in the November 3, 2020, and another 3, 2020, County adjacent election in presidential Georgia; in Georgia; presidential election On or about the 2nd day of January 2021, DONALD JOHN TRUMP committed the felony offense of FALSE STATEMENTS AND WRITINGS, in violation of O.C.G.A. § 1610-20, 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: 51 s1

PDF Page 53	13. That he won the November 3, 2020, presidential lection in Georgia by 400,000 votes; 400,000 votes; of State and and of the Georgia SecretaryofState Office ofthe the Oﬁice of the statements being jurisdiction of said the jurisdiction within the being within Georgia Secretary said statements an This was of state an was Bureau of Investigation, agenciesofstate goverment. the and agencies government. This Investigation, departments the Georgia departments and Georgia Bureauof overt act furtherance an overt act inin furtherance and an act of 16-14-3(S)(A)(xxii) 0.C.G.A. §§ 16-14-3 under O.C.G.A. racketeering activity of racketeering act activity under (5)(A)(xxii) and of the conspiracy. ofthe conspiracy. Act 114. Act 114, caused to TRUMP caused JOHN TRUMP be to be about the On DONALD JOHN 3rd dayofJanuary the 3rd or about On or 2021, DONALD day of January 2021, of State Brad to account @RealDonaldTrump, "I from the “I spoke tweeted Twitter account@RealDonaldTrump, the Twitter Secretary of State Brad tweeted from spoke to Secretary or He was unwilling, in voter fraud about and Fulton unwilling, or He was Georgia. in fraud voter and County Fulton Georgia. about yesterday Raffensperger yesterday County Raﬁensperger out of state ballot under table' 'ballots under table” sca, unable, toto answer answer questions questions such such asas the the “ballots destruction, outofstate scam, ballot destruction, unable, of the furtherance act in an overt was furtheranceofthe in and more. He no clue!" This act overt an has was This dead clue!” no has He more. and voters, dead voters’, voters, 'voters', conspiracy. conspiracy. 13. That he won the November 3, 2020, presidential election in Georgia by 52 52

PDF Page 54	Act 115. ALIS.CLIFFGARD LEE, STEPHEN CLIFFGARD LEE, the 3rd 3rd dayof On or about the or about 2021, STEPHEN On January 2021, day of January C. KUTTI TREVIAN and multiple WILLIAM PRESCOTT placed multiple KUTTI C. HARRISON TREVIAN and FLOYD, PRESCOTT FLOYD, placed HARRISON WILLIAM telephone calls and sent text messages to each other and to other individuals involved in the conspiracy. They include the following: a telephone FLOYD placed WILLIAM PRESCOTT 1.l. At7:48 pm, HARRISON HARRISON WILLIAM PRESCOTT FLOYD telephone At 7:48 p.m., placeda election that was to a Fulton call call to Ruby Ruby Freeman, Freeman, a Fulton County, worker, Georgia, election worker,thatwas County, Georgia, unsuccessful. unsuccessful. 2. At At7:49 p.m., HARRISON HARRISON WILLIAM PRESCOTT FLOYD FLOYD placed telephone WILLIAM PRESCOTT 2. 7:49 p.m., placed aa telephone call to call to Ruby Ruby Freeman Freeman that that was was unsuccessful. unsuccessful. FLOYD placed 7:49 p.m., WILLIAM PRESCOTT 3.3. At At7:49 p.m, HARRISON HARRISON WILLIAM PRESCOTT FLOYD placed aa telephone telephone call to to TREVIAN TREVIAN C. C. KUTTI. call KUTTI. a text message to sent atext 7:53 p.m., FLOYD sent PRESCOTT FLOYD WILLIAM PRESCOTT HARRISON WILLIAM pm, HARRISON At7:53 4.4. At message to Freeman. Ruby Freeman. Ruby 8:03 p.m., TREVIAN C. C. KUTTI 5. At At8:03 pm, TREVIAN KUTTI placed placed aatelephone call toto HARRISON HARRISON 5. telephone call WILLIAM PRESCOTT FLOYD. WILLIAM PRESCOTT FLOYD. 8:11 p.m., HARRISON WILLIAM 6. 6. At At8:11 p.m, HARRISON WILLIAM PRESCOTT PRESCOTT FLOYD FLOYD placeda telephone placed a telephone to Grand who'se identity call to call to unindicted unindicted co-conspirator Individual 23, 23, whose identity isis known known to the the Grand co-conspirator Individual Jury. Jury. 7. At At8:18 pm, HARRISON WILLIAM PRESCOTT PRESCOTT FLOYD FLOYD placed telephone HARRISON WILLIAM 7. 8:18 p.m., placed aa telephone LEE. call to STEPHEN CLIFFGARD call to STEPHEN CLIFFGARD LEE. 8. 8:48 pm, 8. At At8:48 HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD FLOYD placed placed aa telephone telephone p.m., HARRISON C. KUTTI. call call toto TREVIAN TREVIAN C. KUTTL. telephone placed aa telephone 9:16 p.m., FLOYD placed PRESCOTT FLOYD WILLIAM PRESCOTT HARRISON WILLIAM At9:16 9.9. At p.m., HARRISON call to C. KUTTI. TREVIAN C. call to TREVIAN KUTTL. 10. 9:33 p.m., 10. At At9:33 p.m., HARRISON HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD FLOYD placed placedaa telephone telephone call to TREVIAN C. C. KUTTI. call to TREVIAN KUTTL. FLOYD placed a telephone PRESCOTT FLOYD 9:50 p.m., 11.11. At At9:50 p.m, HARRISON HARRISON WILLIAM WILLIAM PRESCOTT placed atelephone LEE. call to STEPHEN CLIFFGARD call to STEPHEN CLIFFGARD LEE. overt acts of the were overt acts in These were ‘These in furtherance furtherance of the conspiracy. conspiracy. telephone calls and sent text messages to each other and to other individuals involved in the conspiracy. They include the following: ' 53 53

PDF Page 55	Act 116. ALILQC. KUTTI, recruited On the 4th TREVIAN C. KUTT, having having been been recruited On or or about about the 4th dayof 2021, TREVIAN January 2021, day of January from to traveled PRESCOTT HARRISON WILLIAM by HARRISON WILLIAM PRESCOTT FLOYD, traveled from Chicago, Illinois, to Atlanta, FLOYD, Chicago, Illinois, Atlanta, by known to Grand Jury, her pick her to pick the Grand and caused a certain individual, to the is known whose identity individual, Whose caused acertain Georgia, identity is Jury, to Georgia, and for the of to contact up from a train station in Fulton County, Georgia, for the purposeofattempting to contact Ruby ﬁom a train station in Fulton Ruby purpose attempting County, Georgia, up an overt act in of the worker. This Freeman,aa Fulton Fulton County, County, Georgia, election worker. This was was an overt act in furtherance furtheranceofthe Freeman, Georgia, election conspiracy. conspiracy. Act 117. Act117. TREVIAN C. On or about about the 4th dayofJanuary Onor the 4th C. KUTTI KUTTI traveled traveled toto Ruby Ruby 2021, TREVIAN day of January 2021, to contact her unsuccessful. and but was Freeman's Cobb County, Freeman's home home inin Cobb Georgia, and attempted to contact her but was unsuccessful. attempted County, Georgia, stated that she was crisis Freeman's neighbor TREVIAN C. TREVIAN C. KUTTI KUTTI spoke with Freeman's neighbor and and falsely falsely stated that she was aa crisis spoke with act in Freeman's home. This was an overt before ‘manager attempting to “help” Freeman before leaving Freeman's home. This was an overt act in to Freeman leaving manager attempting "help" furtherance of the conspiracy. furtheranceofthe conspiracy. 118. Act 118, Act TREVIAN C. while in Fulton Fulton On or of January 2021, or about about the 4th day On the 4th dayofJanuary 2021, TREVIAN C. KUTT, KUTTI, whilein and stated Freeman and stated that call to County, placed aa telephone telephone call to Ruby that Freeman Freeman was was inin Ruby Freeman County, Georgia, Georgia, placed Freeman and she could danger. TREVIAN C. KUTTI stated that she could “help” Freeman and requested that Freeman stated that TREVIAN C. KUTTI "help" requested that Freeman danger. in Cobb Cobb Cobb County meet with with and to her that night night atat aa Cobb County Police Police Department Department precinct meet and speak her that precinct in speak to of the in furtherance an overt act County, Georgia. This was an overt act in furtheranceofthe conspiracy. This was conspiracy. County, Georgia. Act 119, Act112 C. KUTTI to aa Cobb Cobb On about the 4th dayofJanuary On or or about the 4th TREVIAN C. KUTTI traveled traveled to 2021, TREVIAN day of January 2021, and to met with and in Cobb County Police Department precinct in Cobb County, Georgia, and met with and spoke to Ruby Police Ruby County, Georgia, spoke County Department precinct FLOYD joined Freeman for approximately hour. HARRISON HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD Freeman for one hour. joined approximately one and HARRISON HARRISON WILLIAM WILLIAM PRESCOTT C. KUTTI the TREVIAN C. the meeting meeting by by telephone. telephone. TREVIAN KUTTIand PRESCOTT and purported to offer offer her FLOYD stated to that she she needed FLOYD stated to Freeman Freeman that needed protection protection and purported to her help. help. This This was was an overt act act in of the conspiracy. an overt in ﬁthherance furtheranceofthe conspiracy. 54 54

PDF Page 56	Act 120. Act 120, On or about the 4th 2021 STEPHEN STEPHEN CLIFFGARD CLIFFGARD LEE, LEE, about the 4th dayof On or January 2021 day of January and committed TREVIAN C. KUTTI HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD,andTREVIAN C. KUTTI committed the the HARRISON FLOYD, offense of of SOLICITATION SOLICITATION OF felony OF FALSE FALSE STATEMENTS STATEMENTS AND AND WRITINGS, WRITINGS, inin felony offense violation of 0.C.G.A. §§ 16-4-7 & 16-10-20, in Cobb County, Georgia, by soliciting, requesting, and importuning Ruby Freeman, a Fulton County, Georgia, election worker, to engage in conduct constituting the felony offenseof False Statements and Writings, 0.C.G.A. § 16-10-20, by knowingly and willfully making a false statement and representation conceming events at State Farm Arena in the November 3, 2020, presidential election in Georgia, said statement and representation being within thejurisdictionofthe Officeofthe Georgia SecretaryofState and the Georgia Bureauof Investigation, departments and agenciesof state goverment, and county and city law enforcement agencies, with intent that said person engage in said conduct, This was an actofracketeering activity under O.C.G.A. § 16-14-3(5)(A)xxii) and an overt act in furtheranceofthe conspiracy. Act 121. Act 121. STEPHEN CLIFFGARD CLIFFGARD LEE, On or the 4th On or about about the 4th dayof 2021 STEPHEN LEE, January 2021 day of January and the C. KUTTI HARRISON HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD, TREVIAN C. KUTTI committed committed the FLOYD, and TREVIAN offense of of INFLUENCING felony offense INFLUENCING WITNESSES, in violation violation of of O.C.G.A. 0.C.G.A. §§ 16-1016-10WITNESSES, in felony and 93(b)(1)(A), in Fulton Fulton County, engaging inin misleading misleading Georgia, by by knowingly knowingly and unlawfully unlawfully engaging County, Georgia, 93(b)(1)(A), in she election worker, conduct toward conduct Ruby Freeman, Freeman, aa Fulton Fulton County, County, Georgia, Georgia, election worker, by by stating stating that that she toward Ruby her with her to offer intent to inﬂuence needed and needed protection protection and by purporting to offer her help, help, with intent o influence her testimony in testimony in by purporting Arena in the events at State Farm an official in Fulton ofﬁcial proceeding an in Fulton County, Georgia, concerningeventsat State Farm Arena inthe Georgia, County, concerning proceeding in Georgia. This was election in act ofracketeering of racketeering activity November November 3,3, 2020, 2020, presidential presidential election was an an act activity Georgia. This an overt act in furtherance of the conspiracy. under O.C.G.A. §§ 16-14-3 under 0.C.G.A. 16-14-3(5)(A)xxvii) and an overt act in furtheranceofthe conspiracy. (5)(A)(xxvii) and Violation of O.C.G.A. §§ 16-4-7 & 16-10-20, in Cobb County, Georgia, by soliciting, requesting, and importuning Ruby Freeman, a Fulton County, Georgia, election worker, to engage in conduct constituting the felony offense of False Statements and Writings, O.C.G.A. § 16-10-20, by knowingly and willfully making a false statement and representation concerning events at State Farm Arena in the November 3, 2020, presidential election in Georgia, said statement and representation 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, with intent that said person engage in said conduct. This was an act of racketeering activity under O.C.G.A. § l614-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy. 55 55

PDF Page 57	Act122. Act 122. CLIFFGARD LEE, On or about the 4th 4th dayofJanuary STEPHEN CLIFFGARD about the On or LEE, 2021, STEPHEN day of January 2021, HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD, and TREVIAN C. KUTTI placed multiple and C. KUTTI TREVIAN HARRISON FLOYD, placed multiple telephone calls and and sent text messages messages toto each to other involved inin the the each other other and and to other individuals individuals involved sent text telephone calls conspiracy. They include the following: the include following: conspiracy. They HARRISON call to HARRISON telephonecallto placed aa telephone CLIFFGARD LEE LEE placed STEPHEN CLIFFGARD l.1. At 9:41 am, At9:41 a.m., STEPHEN WILLIAM PRESCOTT PRESCOTT FLOYD. FLOYD. WILLIAM 2. At At11:24 HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD FLOYD placed placed aa telephone telephone call call 2 11:24 am. a.m., HARRISON to DAVID DAVID JAMES JAMES SHAFER. SHAFER. to 3. At1225 pm, STEPHEN LEE placed call toto HARRISON HARRISON CLIFF GARD LEE STEPHEN CLIFFGARD 3 At 12:25 p.m., placed aa telephone telephone call . FLOYD. PRESCOTT FLOYD. PRESCOTT WILLIAM WILLIAM HARRISON 4.4 At At12:32 p.m., STEPHEN LEE sent sent aa text text message message toto HARRISON CLIFFGARD LEE STEPHEN CLIFFGARD 12:32 p.m., FLOYD. WILLIAM PRESCOTT PRESCOTT FLOYD. WILLIAM 5. At At8:10 p.m, HARRISON HARRISON WILLIAM PRESCOTT FLOYD FLOYD placed placedaa telephone telephone call to call to WILLIAM PRESCOTT 5 8:10 p.m., SHAFER. DAVID JAMES DAVID JAMES SHAFER. call 6.6 At At10:00 HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD FLOYD placed placed aa telephone telephone call 10:00 p.m, p.m., HARRISON toto STEPHEN CLIFFGARD LEE, CLIFFGARD LEE. STEPHEN call At10:19 pm, HARRISON HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD FLOYD placed telephone call 77. At 10:19 p.m., placed aa telephone to TREVIAN KUTTL. C. KUTTI. TREVIAN C. to TREVIAN C. 8. At AU1043 pm, TREVIAN C. KUTTI KUTTI placed placed aa telephone call toto HARRISON HARRISON 10:43 p.m., telephone call PRESCOTT FLOYD. WILLIAM PRESCOTT FLOYD. WILLIAM C. KUTTI call to 11:10 p.m., TREVIAN C. 9.9 At At11:10 pm, TREVIAN KUTTI placed placed aa telephone telephone call to HARRISON HARRISON WILLIAM PRESCOTT FLOYD. WILLIAM PRESCOTT FLOYD. to 10. At At 12:12 12:12 a.m. a.m. on on January January 5,5, 2021', 2021, TREVIAN KUTTI placed telephone call TREVIAN C. C. KUTTI call to 10. placed aa telephone HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD. FLOYD. HARRISON ‘These were overt in furtheranceofthe furtherance of the conspiracy. overt acts acts in These were conspiracy. ~ 56 56

PDF Page 58	Act 123. Act 123. CHARLES EASTMAN 4th day of January 2020, EASTMAN placed or about about the On or JOHN CHARLES dayofJanuary the dth On 2020, JOHN placedaa telephone call to Speakerofthe Arizona House House of of Representatives Representatives Rusty Bowers and and solicited, solicited, call to Rusty Bowers Speaker of the Arizona telephone from Arizona. electors Bowers to requested, and importuned Bowers to unlawfully appoint presidential electors from Arizona. and importuned unlawﬁilly appoint presidential requested, that he and stated stated that Bowers declined to with Eastman’s Eastman's request During the telephone call, Bowers declined to comply request and he the call, comply with telephone During the act in oath of oﬁice. The The request an overt would not no risk risk Violating violating his his oathofoffice. request was was an overt act in furtherance furtherance of ofthe would conspiracy. conspiracy. Act 124. Act124, sent an CHESEBRO sent the 4th 4th dayof JOHN CHESEBRO On about the KENNETH JOHN an e-eOn or or about 2021, KENNETH day 0f January January 2021, edits" and included Draft 2, EASTMAN with with the ‘mail toto JOHN JOHN CHARLES the subject subject "Fwd: “Fw: Draft 2, with with edits” and included CHARLES EASTMAN mail CHESEBRO the e-mail another e-mail JOHN of that KENNETH within the bodyofthe e-mail another e-mail that KENNETH JOHN CHESEBRO previously within the body previously "PRIVILEGED AND with the sentto RUDOLPH WILLIAM WILLIAM LOUIS LOUIS GIULIANI GIULIANI with the subject sent to RUDOLPH subject “PRIVILEGEDAND the e-mail, on ‘Presidentofthe Brief notes on 'President of the Senate’ Senate' strategy.” CONFIDENTIAL CONFIDENTIAL -Briefnotes In the KENNETH email, KENNETH strategy." In session of of outlined multiple and delaying CHESEBRO outlined JOHN JOHN CHESEBRO for disrupting thejoint joint session delaying the multiple strategies strategies for disrupting and cast the votes on the law for Congress on January 6, 2021,theday prescribed by law for counting votes cast by the duly by duly counting January 6, 2021, day prescribed by Congress and stated that the and the the other elected qualified presidential electors from from Georgia other states, stated that the and qualiﬁed elected and states, and presidential electors Georgia and Act Count to the Electoral to outcomes of any of these strategies were “preferable outcomesofanyofthesestrategieswere to allowing the Electoral Count Act to "preferable allowing This was an overt act in its terms." of the conspiracy. operate by its terms.” This was an overt act in furtherance furtheranceofthe conspiracy. operate by ' Act 123. Act123, JOHN and JOHN JOHN TRUMP On or or about about the On the 4th 4th dayofJanuary DONALD JOHN TRUMP and 2021, DONALD day of January 2021, Chiefof of Staﬂ' CHARLES EASTMAN CHARLES EASTMAN met met with with Vice Vice President President Mike Mike Pence, Pence, Chief Staff toto the the Vice Vice in the Oval Ofﬁce and Counsel to the Vice President Jacob President Marc PresidentMare Short, Short, and Counsel to the Vice President Greg Greg Jacob in the Oval Office atat the the TRUMP and and JOHN White House. During White House. the meeting, meeting, DONALD DONALD JOHN JOHN TRUMP JOHN CHARLES CHARLES During the states or could either electoral votes votes from EASTMAN EASTMANarguedto Pence that that he he could either reject reject electoral from certain certain sates or argued to Pence on January session of Congress the day delay thejoint 6, 2021, day prescribed prescribed by law for for counting counting 2021, the Congress on January 6, by law joint sessionof delay the the other elected and and qualified votes cast by Votes cast by the the duly duly elected presidential electors electors from from Georgia Georgia and and the other qualiﬁed presidential of allowing certain state legislatures states, for the the purpose purposeofallowing certain state legislatures toto unlawfully states, for presidential unlawfully appoint appoint presidential CHARLES DONALD JOHN the meeting, JOHN CHARLES TRUMP. During electors electors inin favor favor of ofDONALD JOHN TRUMP. meeting, JOHN During the act in This was admitted both Count Act. EASTMAN EASTMAN admitted both options violated the the Electoral Electoral Count Act. This was an an overt overt act in options violated furtherance of the conspiracy. furtheranceofthe conspiracy. 57 57

PDF Page 59	Act 126. Act126On 5th dayof JENNA LYNN LYNN ELLIS ELLIS wrote wroteaa memorandum memorandum or about the 5th On oraboutthe January 2021, JENNA day 0f January2021, and 33 to U.S. Constitution and Constitution Electors U.S. to in pursuant Electors Counting in "Re: Vice titled President Authority Vice President titled “Re: pursuant Authority Counting TRUMP. The JOHN DONALD The with TRUMP. to an an attorney and 15" associated with DONALD JOHN U.S. attomey associated 15”to Code §§ U.S. Code §§ 55 and of Congress on on for sessionofCongress joint session the joint outlinedaa strategy delaying the and delaying memorandum disrupting for ‘memorandum outlined strategy disrupting and elected and the votes cast and law for elected duly the the by counting votes cast by duly by law for counting prescribed by 6, 2021, January 2021, the day day prescribed January 6, "the Vice and the other states, electors from President Vice President stated, “the and stated, states, and the other and Georgia from electors presidential qualified Georgia qualiﬁed presidential not the to ﬁrst and order of the in open not Arizona, to firs should begin Arizona, open the states, and coming begin alphabetically should coming alphabetically in orderofthe states, was an overt overt act act in in purported certification, but simply stop the the count count atat that thatjuncture.” Thiswasan certiﬁcation, but juncture." This simply stop purported of the furtherance furtheranceof the conspiracy. conspiracy. 58 58

PDF Page 60	Act 127 Act127, STEPHEN DAVID CHEELEY, CHEELEY, STEPHEN ROBERT DAVID On or about the Sth dayof January 2021, ROBERT TREVIAN C. C. KUTTI, CLIFFGARD LEE, HARRISON HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD, FLOYD, TREVIAN KUTTI, CLIFFGARD LEE, each other and to other calls to and SCOTT GRAHAM HALL placed multiple telephone calls to cach other and to other GRAHAM HALL and SCOTT placed multiple telephone individuals involved in the conspiracy. They include include the the following: following: in the individuals involved conspiracy. They TREVIAN call toto TREVIAN CLIFFGARD LEE telephone call 11:32 am, placed aa telephone LEE placed l. STEPHEN CLIFFGARD At11:32 1. At a.m., STEPHEN C. KUTTI. C.KUTTL C. TREVIAN C. 2.2 At At12:14 p.m, HARRISON HARRISON WILLIAM WILLIAM PRESCOTT PRESCOTT FLOYD, FLOYD, TREVIAN 12:14 p.m., Individual and unindicted KUTTI, STEPHEN CLIFFGARD LEE, LEE, and unindicted co-conspirator STEPHEN CLIFFGARD coconspirator Individual KUTTI, in four-way telephone: to the Grand in aa four-way known participated Jury, whose is Grand the to known is identity whose 23, telephone Jury, participated 23, identity call. call. GRAHAM HALL ROBERT call toto ROBERT 3 12:19 p.m., placed aatelephone HALL placed SCOTT GRAHAM pm, SCOTT At12:19 3. At telephone call DAVID DAVID CHEELEY. CHEELEY. GRAHAM HALL 4.4 At At12:34 SCOTT GRAHAM HALL placed placed aatelephone call toto ROBERT ROBERT 12:34 pm. telephone call p.m., SCOTT DAVID CHEELEY. DAVID CHEELEY. call to a telephone call SCOTT to SCOTT 5 1:07 p.m., placedatelephone CHEELEY placed DAVID CHEELEY ROBERT DAVID pm, ROBERT At1:07 5. At GRAHAM HALL. GRAHAM HALL. call to SCOTT to SCOTT 6 1:09 p.m., telephone call placed aa telephone CHEELEY placed DAVID CHEELEY ROBERT DAVID pm, ROBERT At1:09 6. At GRAHAM HALL. GRAHAM HALL. HARRISON call to 2:30 p.m., DAVID CHEELEY 7.7 At At2:30 pm, ROBERT ROBERT DAVID CHEELEY placed placed aa telephone to HARRISON telephone call FLOYD. WILLIAM PRESCOTT WILLIAM PRESCOTT FLOYD. PRESCOTT FLOYD placed aatelephone 2:45 pm, FLOYD placed WILLIAM PRESCOTT HARRISON WILLIAM At2:45 8. At telephone p.m., HARRISON call to call to ROBERT ROBERT DAVID DAVID CHEELEY. CHEELEY. call to CHEELEY placedatelephone 9.9 At At3:59 ROBERT DAVID to SCOTT SCOTT DAVID CHEELEY 3:5 9 pm. placed a telephone call p.m., ROBERT GRAHAM GRAHAM HALL. HALL. call to to ROBERT CLIFFGARD LEE 10. At At 4:42 4:42 p.m., p.m., STEPHEN LEE placed placed aa telephone telephone call ROBERT 10. STEPHEN CLIFFGARD DAVID DAVID CHEELEY. CHEELEY. call to to LEE placed 11. p.m, STEPHEN STEPHEN CLIFFGARD CLIFFGARD LEE placed aa telephone telephone call ll. At4:50 At 4:50 p.m., FLOYD. PRESCOTT HARRISON WILLIAM HARRISON WILLIAM PRESCOTT FLOYD. call to 12. At5:05 pm, STEPHEN CLIFFGARD LEE LEE placed placed aatelephone to 12. At 5:05 p.m., STEPHEN CLIFFGARD telephone call FLOYD. HARRISON WILLIAM WILLIAM PRESCOTT HARRISON PRESCOTT FLOYD. On or about the 5th day of January 2021, o 59 59 \

PDF Page 61	call to 13. At At 7:19 pm, TREVIAN TREVIAN C. C. KUTTI KUTTI placed placed aa telephone telephone call to ROBERT ROBERT DAVID DAVID 7:19 p.m., CIIEELEY. CHEELEY. a telephone call call to TREVIAN to TREVIAN 14. At 7:48 placed atelephone CHEELEY placed DAVID CHEELEY ROBERT DAVID p.m, ROBERT 7:48 p.m., 14. At C. KUTTI. C.KUTTL TREVIAN CHEELEY placed DAVID CHEELEY 15. At pm., ROBERT ROBERT DAVID placed aa telephone call toto TREVIAN 15. At 8:27 8:27 p.m., telephone call C. KUTTI. C.KUTTL CHEELEY placed call to STEPHEN DAVID CHEELEY 16. At At 8:49 16. 8:49 p.m., p.m, ROBERT ROBERT DAVID to STEPHEN placed aa telephone telephone call LEE. CLIFFGARD CLIFFGARD LEE. call to to ROBERT GRAHAM HALL l7. 9:18 p.m., 17. At At9:18 p.m, SCOTT SCOTT GRAHAM HALL placed placed aa telephone telephone call ROBERT DAVID DAVID CHEELEY. CHEELEY. call t0 C. KUTTI TREVIAN C. 18. 9:31 p.m., 18. At At9:31 pm, TREVIAN KUTTI placed placed aatelephone to ROBERT ROBERT DAVID DAVID telephone call CHEELEY. CHEELEY. call to to STEPHEN 19. At At10:14 DAVID CHEELEY CHEELEY placed placed aa telephone telephone call STEPHEN 19. 10:14 p.m, ROBERT DAVID p.m., ROBERT LEE. CLIFFGARD LEE. CLIFFGARD 20. At11:16 p.m., ROBERT DAVID DAVID CHEELEY CHEELEY placed placed aa telephone telephone call call toto TREVIAN TREVIAN 20. At 11:16 p.m., ROBERT C. KUTTI. C.KUTTL call to ROBERT SCOTT GRAHAM GRAHAM HALL 21. At 1125 HALL placed placed aatelephone to ROBERT 21. At 11:25 p.m, telephone call p.m., SCOTT DAVID CHEELEY. DAVID CHEELEY. TREVIAN C. SCOTT 22. At 11:35 p.m., 22. At11:35 ROBERT DAVID DAVID CHEELEY, C. KUTTI, KUTTI, and and SCOTT CHEELEY, TREVIAN p.m., ROBERT call. GRAHAM GRAHAM HALL HALL participated participated inin aa three-way threeway telephone telephone call. call to TREVIAN C. 23. 12:09 am. afm. on on January 23. At At12:09 2021, TREVIAN C. KUTTI KUTT placed placed aa telephone telephone call to 6, 2021, January 6, DAVID CHEELEY. CHEELEY. ROBERT ROBERT DAVID of the These were acts in ‘These were overt overt acts in furtherance furtherance of the conspiracy. conspiracy. Act Act 128. 128. caused to to be be JOHN TRUMP TRUMP caused about the 5th dayof On or about the 5th DONALD JOHN On or 2021, DONALD January 2021, day of January "The Vice the power President has Twitter account account @RealDonaldTrump, tweeted from the Twitter tweeted from the Vice President has the to power to @RealDonaldTrump, “The was an overt act in of the This furtherance chosen electors." reject fraudulently chosen electors.” This was an overt act in furtheranceofthe conspiracy. conspiracy. reject fraudulently 13. ' 60 60

PDF Page 62	Act 129. Act 129, with met with EASTMAN met JOHN CHARLES CHARLES EASTMAN the 5th 2021, JOHN On or or about about the 5th dayof On January 2021, day of January Jacob for for Vice President and Counsel Counsel to to the the Vice President Greg Chief of Staffto Staff to the Short and Marc Short President Marc Vice President Greg Jacob the Vice Chiefof electors electors slates of Mike Pence ofpresidential sates Vice President reject Pence that Mike the of requesting that Vice President purposeofrequesting the purpose reject presidential on the session of January 6,6, 2021, on January Congress of other states session certain 2021, thejoint during from and states other certain and from Georgia Congress during joint Georgia elected and votes cast the presidential qualified and law for elected duly the the by cast votes counting prescribed by the day by qualiﬁed presidential duly by law for counting day prescribed of the conspiracy. an overt overt act act in in furtherance furtherance ofthe states. This other states. electors from was an This was the other and the conspiracy. from Georgia electors Georgia and Act Act 130. 130, met with Vice JOHN TRUMP with Vice TRUMP met 5th dayof the 5th DONALD JOHN 2021, DONALD On or about the or about On January 2021, day of January the meeting, at the DONALD Ofﬁce at in the Oval Office House. During Pence in White House. the White President the Oval Mike Pence President Mike meeting, DONALD During the to the November had the presidential 2020, that Pence 3, stated that Pence had the power decertify the November 3, 2020, presidential JOHN power to decertify TRUMP stated JOHN TRUMP of Queensberry and that wanted to Marquess of to “play election results, Pence wanted that Pence people cheated, that people Queensberry results, that cheated, and election by Marquess "play by and that to and defend the Constitution it was his that that and stated Constitution the rules." When Pence supportand defend rules.” When Pence stated that it was his duty duty to support JOHN of presidential electors, decide to only Congress had the the power power toto decide to reject slates ofpresidential DONALD JOHN electors, DONALD reject slates Congress had only was Pence that was that he lacked and stated Pence that stated and was courage, lacked he that Pence that implied TRUMP stated naive, was Pence that TRUMP stated naive, implied courage, act in furtherance of the the conspiracy. This was "a great disservice." This doing “agreatdisservice.” was an an overt overt actin furtheranceof conspiracy. doing Act 131. Act 131. JOHN TRUMP TRUMP placed 5th day placed aa On or about about the DONALD JOHN January 2021, dayofof January 2021, DONALD the Sth On or JOHN telephone call call toto Vice Vice President President Mike Mike Pence. Pence. During During the the telephone telephone call, DONALD JOHN call, DONALD telephone of slates of Pence to to EASTMAN CHARLES EASTMAN attempted TRUMP persuade Pence to reject reject slates and JOHN JOHN CHARLES TRUMP and attempted to persuade an This was was an slates of presidential electors electors or or return presidential electors return the the slatesofpresidential electors toto state state legislatures. legislatures. This presidential the of act in furtherance overt act in furtheranceofthe conspiracy. overt conspiracy. Act 132. Act132. second JOHN TRUMP TRUMP placed placed aa second or about about the the 5th DONALD JOHN On or 5th dayof On 2021, DONALD January 2021, day of January JOHN the DONALD Pence. During Mike Pence. call to Vice President telephone call to Vice President Mike During the telephone telephone call, call, DONALD JOHN telephone of Pennsylvania Pennsylvania of a letter from aa group received aa copy letter from copyofa if he had TRUMP asked Pence had received Pence ifhe group of TRUMP asked "You to stated the electoral votes and return state's Pence, “You to Pence, stated to and votes college electoral urging Congress legislators urging college Congress to return the state’s legislators an overt overt act the conspiracy. tomorrow." This gotta be tough tough tomorrow.” This was was an act inin furtherance furtheranceofof the conspiracy. gotta be Act 133. Act 133, issuedaa TRUMP issued or about On about the the 5th 5th dayof 2021, DONALD DONALD JOHN JOHN TRUMP On or January 2021, day of January and I\| are are in that falsely total in total President and Vice President “The Vice statement falsely stated, the Trump statement through stated, "The Trump Campaign Campaign that through the several to act. has has the Our Vice President Vice President that the ‘agreement that the Vice President has the power to act... Our Vice President has several options options power agreement states for send them Constitution. He can decertify under under the the U.S. U.S. Constitution.Hecan decertify the the results results or or send them back back toto the the states for and send send them the illegal can also also decertify certiﬁcation. He change and certification. He can decertify the illegal and and cormupt results and them toto corrupt results change and an overt act in one state state tabulation.” one vote tabulation." This of Representatives the Representatives for for the the one vote for for one This was was an overt act in the House House of furtheranceof the conspiracy. furtherance of the conspiracy. 61 61

PDF Page 63	Act 134. Act134, LATHAM placed placed aa 6th dayof ALSTON LATHAM about the CATHLEEN ALSTON 2021, CATI-ILEEN On or the 6th or about On day of January January 2021, GRAHAM HALL SCOTT GRAHAM HALL. Several Several hours GRAHAM HALL. HALL to SCOTT SCOTT GRAHAM later, SCOTT hours later, callto telephone telephone call one of the least at ALSTON LATHAM. to CATHLEEN placed a telephone call to CATHLEEN ALSTON LATHAM. During at least oneofthe phone call phone During placed a telephone with the of breach of assist with unlawful breach the unlawﬁJl GRAHAM HALL's SCOTT GRAHAM request toto assist HALL’ request calls,theydiscussed calls, they discussed SCOTT in Coffee Ofﬁce Coffee in Board of Elections & Office at the Coffee Registration & election BoardofElections County election equipment Registration equipment at the Coffee County acts in were overt overt acts furtherance of the County, Georgia. These were in furtheranceof the conspiracy. conspiracy. County, Georgia. These Act 135. Act 135. and TRUMP appeared 6th day Onoraboutthe dayofof January January 2021, 2021, DONALD DONALD JOHN JOHN TRUMP appeared and or about the 6th On TRUMP JOHN TRUMP at the spoke a rally the Ellipse Ellipse inin Washington, Washington, D.C. D.C. During During the the rally, DONALD JOHN at a rally, DONALD rally at spoke at election fraud in the November ‘made statements concerning concerning fraud in the November 3,3, 2020, 2020, presidential presidential election inin made false false statements session and delay solicited Vice to disrupt thejoint disrupt and and elsewhere, Pence to Mike Pence President Mike Vice President Georgia delay the joint session elsewhere, solicited Georgia and the cast votes the law for duly the by cast votes on counting for of by law counting prescribed by 2021,the day duly by ofCongress 6, 2021, day prescribed January 6, Congress on January and from and the other electors encouraged and states, elected and and qualified other the and Georgia from electors states, presidential encouraged elected Georgia presidential qualiﬁed act in an overt This was march to to the States Capitol. the rally those inin attendance attendance atat the rally toto march the United United States Capitol. This was an overt act in those of the conspiracy. furtherance furtheranceofthe conspiracy. Act 136. Act 136. GIULIANI On the 6th 2021, RUDOLPH RUDOLPH WILLIAM WILLIAM LOUIS LOUIS GIULIANI 6th dayofJanuary about the On or or about day of January 2021, ataa rally appeared and spoke rally atat the the Ellipse Ellipse inin Washington, Washington, D.C. D.C. During During the the rally, rally, RUDOLPH RUDOLPH spoke at appeared and in the November fraud made false statements GIULIANI LOUIS WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3,3, WILLIAM concerning Vice President Pence toto Mike Pence and elsewhere elsewhere and and solicited solicited Vice President Mike election in in Georgia 2020, presidential Georgia and 2020, presidential election law for the for of on by the session prescribed day the and 2021, 6, January on disrupt day prescribed by law Congress January 6, 2021, delay thejoint joint sessionofCongress disrupt and delay the electors from fromGeorgiaand votes cast by presidential electors qualified presidential and qualiﬁed elected and the duly by the countingvotescast Georgia and the duly elected counting overt act act in of the conspiracy. This was other states. This other states. was an an overt in furtherance furtheranceofthe conspiracy. Act 137. Act137, JOHN CHARLES the 6th 6th dayof EASTMANappearedand. CHARLES EASTMAN On 2021, JOHN appeared and abouthe or about On or January 2021, day of January CHARLES JOHN in D.C. the the at spoke at a rally at the Ellipse in Washington, D.C. During the rally, JOHN CHARLES at a During rally, Ellipse Washington, rally spoke statements concerning presidential made false false statements 2020, presidential November 3,3, 2020, the November EASTMAN made fraud inin the EASTMAN concerning fraud of the session and President Mike Mike Pence to disrupt election Vice President Pence to and delay thejoint session of solicited Vice election and and solicited delay joint disrupt cast the votes for ‘Congress on January January 6,6, 2021, the day by law law for counting by the duly duly 2021, the counting votes cast by day prescribed prescribed by Congress on was an overt states. This electors from and the other wasanovert This states. other elected and the and Georgia from electors qualified presidential and qualiﬁed elected Georgia presidential the of furtherance act in actin furtheranceofthe conspiracy. conspiracy. 62 62

PDF Page 64	Act Act 138 138. On or about the 6th dayof January 2021, DONALD JOHN TRUMP caused to be tweeted from the Twitter account@RealDonaldTrump, “IfVice President @Mfike_Pence comes through for us, we will win the Presidency. Many States want to decertify the mistake they made in certifying incorrect & even fraudulent numbers ina process NOT approved by their State Legislatures (which it must be). Mike can send it back!” This was an overt act in furtherance of the conspiracy. the conspiracy. Act 139. Act139. caused to be JOHN TRUMP about the On or or about On the 6th 6th dayofJanuary DONALD JOHN TRUMP caused to be 2021, DONALD day of January 2021, account @RealDonaldTrump, "States tweeted tweeted from from the the Twitter Twitter account@RealDonaldTrump, “States want want toto correct correct their their votes, votes, which which never received on know were based and now they now know were based on irregularities plus corrupt process never received fraud, plus irregularities and fraud, corrupt process they WIN. All Mike Mike Pence Pence has has to send them legislative approval. to do do isis send them back back toto the the States, AND WE WE WIN. States, AND legislative approval. All furtherance of the act in This was an overt Dotit Mike, Mike, this this iss aa time time for for extreme extreme courage!” This was an overt act in furtherance ofthe Do courage!" conspiracy. conspiracy. Act 140. Act 140. TRUMP placed about the 6th day On or or about the 6th dayofof January 2021, DONALD DONALD JOHN JOHN TRUMP placed aa On January 2021, and delay President Mike and solicited solicited him Pence and telephone call call t0to Vice Vice President Mike Pence him toto disrupt delay the thejoint joint disrupt and telephone for votes cast the on law the session of of Congress session on January 6, 2021, the day prescribed by law for counting votes cast by the by counting Congress January 6, 2021, day prescribed by When Pence the other other states. states. When and qualified and the elected and electors from duly elected presidential electors from Georgia Pence Georgia and duly qualiﬁed presidential down as a and that JOHN TRUMP stated that Pence would DONALD refused, DONALD JOHN TRUMP stated that Pence would “go down as a wimp" and that refused, wimp" "go of the the United This was overt act act in States. This Pence was not Pence was not protecting protecting the United States. was an an overt in furtherance furtheranceofthe conspiracy. conspiracy. On or about the 6th day of January 2021, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, "If Vice President @Mike_Pence comes through for us, we will Win the Presidency. Many States want to decertify the mistake they made in certifying incorrect & even fraudulent numbers in a process NOT approved by their State Legislatures (which it must be). Mike can send it back!" This was an overt act in furtherance of 63 6

PDF Page 65	Act 141. Act141, CHARLES EASTMAN sent an eOn about the 6th dayof On or or abou the 6th JOHN CHARLES EASTMAN scatan ¢2021, JOHN day of January January 2021, that stated: to Counsel Jacob mail mail to Counsel toto the the Vice Vice President President Greg Jacob that sated: Greg Act this violated the the Electoral “The Senate House have have both both violated Electoral Count Count Act ths evening evening — "The Senate and and House Violation of 2 hours. more than debated the Arizona for they debated the Arizona objections for more than 2 hous. Violation of 33 USC USC they objections after the debate or or statements l7. 17. And And the the VP VP allowed allowed fmther further debate statements by leadership after the by leadership And had that debate USC 17. had been Violation of voted question had been voted upon. Violation of 3USC 17.” Andtheyhad that debate they question upon. in USC the that motion approved of the VP, ‘upon bythe VP, inin violation violationofthe requirement 15 that requirement in 3 USC 15 upon motion approved by meet.' afterthe the vote shall immediately after vote inin the the separate separate houses, houses, 'they ‘they shall immediately again again meet. Act is So now been set set that the Electoral So now that that the the precedent precedent has hasbeen that the Electoral Count Count Act is not not quite so quite so consider one more to as was was previously I sacrosanctas sacrosanct previously claimed, I implore you to consider one more claimed, implore you allow the violation and and adjourn relatively minor violation for 1010 days to allow the legislatures legislatures toto relatively minor days to adjourn for audit of the the massive a full forensic ﬁnish their their investigations, as well as to allow finish as well as to allow a full forensic auditof massive investigations, If none of that moves amount of illegal activity amountofillegal activity that that has has occurred here. Ifnoneofthat moves the the occurred here. who President million at least a of the needle, atleast a good portionofthe 75 million people who supported President. 75 needle, supported people good portion be aired. aired. seen aa process that allowed allowed the “Tramp will will have have seen process that the illegality illegality toto be Trump John" John” an overt overt act This was furtherance of the conspiracy. ‘This was an actinin furtheranceofthe conspiracy. Act 142. Act142. LATHAM sent sent aa On or about about the 7th day On or the 7th dayofof January January 2021, CATHLEEN ALSTON ALSTON LATHAM 2021, CATI-ILEEN LLC the with address for to the of SullivanStrickler text message Chief Operations Ofﬁcer of SullivanStrickler LLC with the address for the text the message to the Chief Operations Officer to coordinate SCOTT in Coffee Douglas Municipal Airport in Coffee County, Georgia, to coordinate picking up SCOTT picking up County, Georgia, Douglas Municipal Airport & HALL from him to of Elections & GRAHAM and driving GRAHAM HALL from the the airport airport and driving him to the the Coffee Coffee County BoardofElections County Board of election equipment at Ofﬁce for the unlawﬁll of assisting with Registration for the the purpose purposeofassisting with the unlawful breach breachofelection equipment at Registration Office an Ofﬁce. was act of & This the Coffee County Board of Elections theCoffee Board of Elections & Registration Office,Thiswas an actofracketeering racketeering County Registration of the in furtherance furtherance of an overt overt act act in O.C.G.A. §§ 16-14-3(5)(B) and an activity under O.C.G.A. 16-14-3(5)(B) and the conspiracy. conspiracy. activity under Act 143. Act143, and unindicted SCOTT GRAHAM On abou the 7th dayof GRAHAM HALL HALL and unindicted On or or about the 7th 2021, SCOTT day of January January 2021, Grand Jury, from DeKalbknown to co-conspirator Individual Individual 24, 24, whose whose identity identity isis known to the the Grand Jury, ﬂew flew from DeKalbco-conspirator in Coffee in to Peachtree DeKalb Peachtree Airport in DeKalb County, Georgia, to Douglas Municipal Airport in Coffee County, County, Airport County, Georgia, Douglas Municipal Airport of election with unlawful breach at the for the the purposeofassisting the unlawful breachofelection equipment Georgia, for equipment at the Georgia, purpose of assisting with the This was act of racketeering activity Ofﬁce. This Coffee County of Elections&& Registration Coffee County Board BoardofElections Registration Office. was an an actofracketeering activity in furtherance of the under O.C.G.A. and an overt act under 0.C.G.A. §§ 16-14-3(5)(B) conspiracy. l6-l4-3(5)(B) andanovert act in furtheranceofthe conspiracy. 3 3 64 64

PDF Page 66	Act Act 144. 144. SIDNEY KATHERINE POWELL, KATHERINE POWELL, On or 7th dayof the 7th about the or about On 2021, SIDNEY January 2021, day of January and MISTY SCOTT GRAHAM HAMPTON MISTY HAMPTON HALL, and CATHLEEN ALSTON GRAHAM HALL, LATHAM, SCOTT ALSTON LATHAM, CATHLEEN PRIMARIES AND WITH ELECTIONS, AND INTERFERENCE PRIMARIES of INTERFERENCE WITH ELECTIONS, offense of committed the felony offense the felony committed and unlawfully unlawfully Coffee County, Georgia, by County, Georgia, 212-566, inin Coffee of O.C.G.A. §§ 21-2-566, violationof0.C.G.A. inin Violation willfully and by wilfully in Coffee machines County, and Coffee in markers machines ballot tabulating and with electronic markers tampering with electronic ballot Georgia. County, Georgia. tabulating tampering of the conspiracy. an overt overt act ‘This was an act inin furtherance furtheranceofthe conspiracy. This was 145. Act 145 Act SIDNEY KATHERINE On about the the 7th 7th dayof KATHERINE POWELL, POWELL, On or or about 2021, SIDNEY January 2021, day of January and MISTY HAMPTON MISTY HAMPTON HALL, and SCOTT GRAHAM GRAHAM HALL, ALST ON LAT CATHLEEN ALSTON LATHAM, CATHLEEN HAM, SCOTT of Violation of OF POSSESSION in violation UNLAWFUL BALLOTS, of UNLAWFUL POSSESSION OF BALLOTS, in offense of committed the felony offense the felony committed certain members of the the conspiracy, Coffee County, membersof by causing O.C.G.A. §§ 21-2-57 Georgia, by County, Georgia, 212-574,4, inin Coffee conspiracy, 0.C.G.A. causing certain not ballots and who were care of with the persons law not were were ofﬁcers who and who were not by law with the care of ballots not officers charged persons who charged by to a for of ballots the care possess with to possess law, by entrusted by such officer required purpose a for law, officerwiththecareofballots by such by any required entrusted purpose any act in This an overt was Coffee County, official polling place place inin Coffee Georgia. This was an overt act in outside of the polling ofﬁcial ballots ballots outsideofthe County, Georgia. furtherance of the conspiracy. furtheranceofthe conspiracy. Act 146. Act 146. SIDNEY KATHERINE POWELL, On or or about KATHERINE POWELL, 2021, SIDNEY 7th dayof the 7th about the On January 2021, day 0f January HAMPTON and MISTY SCOTT GRAHAM MISTY HAMPTON CATHLEEN ALSTON ALSTON LATHAM, HALL, and GRAHAM HALL, LATHAM, SCOTT CATHLEEN in Violation of O.C.G.A. of COMPUTER committed the committed the felony felony offense offense of COMPUTER THEFT, THEFT, in violation of 0.C.G.A. §§ 16-9-93(a), 169-93(a), without that such use was with without was use such that a knowledge with computer Coffee County, a using by Georgia, inin Coffee knowledge computer by using County, Georgia, and software, the software, the of taking and information, data, and with with the appropriating information, and appropriating data, and intentionoftaking the intention authority authority and act of was an This was an act of of Dominion Voting County, Georgia. Coffee County, Corporation inin Coffee Systems Corporation propertyofDominion Georgia. This Voting Systems property of the act in and an overt act furtheranceofthe in furtherance an overt 16-14-3(5)(A)(xix) O.C.G.A. §§ 1614-3 under O.C.G.A. activity under racketeering activity (5)(A)(Xix) and racketeering conspiracy. conspiracy. Act 147. Act 147. POWELL, KATHERINE POWELL, On or about the 7th day SIDNEY KATHERINE 2021, SIDNEY dayofof January the 7th or about On January 2021, GRAHAM HALL, and MISTY SCOTT GRAHAM HAMPTON MISTY HAMPTON CATHLEEN ALSTON HALL, and LATHAM, SCOTT ALSTON LATHAM, CATHLEEN of 0.C.G.A. 16-9O.C.G.A. §§ 169COMPUTER TRESPASS, ‘committed the felony felony offense offense of ofCOMPUTER TRESPASS, inin Violation violation of committed the with that such use was a was use such knowledge that Coffee County, using a computer by using in Coffee 93(b), computer with knowledge Georgia, by 93(b), in County, Georgia, data and and Dominion without authority and with the the intentionofremoving voter data Dominion Voting intention of removing voter and with without authority Voting Systems Systems of This was an act racketeering of act an in Coffee was This Georgia. County, data from said Coffee in computer Corporation racketeering County, Georgia. Corporation data from said computer act in furtherance of the conspiracy. and an conspiracy. furtheranceofthe O.C.G.A. §§ 16-14-3 overt actin an overt 16-14-3(5)(A)(xix) under O.C.G.A. activity (5)(A)(xix) and activity under 65 65

PDF Page 67	Act Act 148. 148, SIDNEY KATHERINE of January 2021, 7th day On or or about about the KATHERINE POWELL, POWELL, 2021, SIDNEY dayofJanuary the 7th On HAMPTON GRAHAM HALL, CATHLEEN ALSTON LATHAM, LATHAM, SCOTT SCOTT GRAHAM and MISTY MISTY HAMPTON CATHLEEN ALSTON HALL, and of in Violation OF INVASION COMPUTER INVASION OF PRIVACY, offense of committed the felony felony offense of COMPUTER PRIVACY, in violation of committed the of the intention with the intention of Coffee County, using aa computer by using O.C.G.A. §§ 169-93(c), in Coffee 0.C.G.A. County, Georgia, Georgia, by computer with 16-9-93(c), in that such examination was without This authority. data with without was voter personal voter data with knowledge authority. This examining knowledge that such examination examining personal act in and an an overt O.C.G.A. §§ 16-14-3 in overt act was an of racketeering activity 16-14-3(S)(A)(xix) under O.C.G.A. actofracketeering an act ‘was (5)(A)(xix) and activity under the furtheranCe of furtheranceofthe conspiracy. conspiracy. Act 149. Act 149, and the the 7th 7th day of January 6th day On between the the 6th of December December 2020 2020 and dayof On and and between 2021, January 2021, day 0f GRAHAM ALSTON SCOTT CATHLEEN ALSTON LATHAM, SIDNEY KATHERINE SIDNEY KATHERINE POWELL, POWELL, CATHLEEN LATHAM, SCOTT GRAHAM TO the oﬁense of CONSPIRACY TO committed of CONSPIRACY HAMPTON offense and MISTY felony the committed HAMPTON MISTY and HALL, felony HALL, in of O.C.G.A. Coﬁee by Georgia, County, Georgia, by DEFRAUD THE 16-10-21, in Coffee County, violation of0.C.G.A. §§ 16-10-21, in Violation THE STATE, DEFRAUD STATE, in commit theft of voter voter data, which was the under the was under theftof agreeing toto commit and agreeing data, property unlawfully property which unlawfully conspiring conspiring and a in his ofﬁcial Brad state of State capacity. of official his in control officer, Brad Raffensperger,a capacity. controlofGeorgia Raﬁensperger, state ofﬁcer, Secretary Georgia SecretaryofState act in and an an overt “This was was an under O.C.G.A. O.C.G.A. §§ 16-14-3 16-14-3(5)(B) overt act in This an actofracketeering act of racketeering activity (5)(B) and activity under furtherance of the furtheranceofthe conspiracy. conspiracy. Act Act 150. 150. 10th dayof 11th day the 11th On or about the 9th 9th dayof January 2021, the 10th 2021, the day oraboutthe On January 2021, the day of January day of January2021, Individual of unindicted of 2021, and the 13th 13th dayofJanuary 25, 0f January and the 2021, unindicted co-conspirator co-conspirator Individual 25, day January 2021, January 2021, accessed certain certain data Grand Jury, whose whose identity identity isis known known toto the the Grand data copied from Jury, unlawfully unlawfully accessed copied from & Registration Coﬁee County of Elections & Dominion Voting Voting Systems equipment atat the the Coffee County Board BoardofElections Registration Dominion Systems equipment said data data ﬁom Office inin Coffee by downloading from aa server server maintained maintained by by Ofﬁce Coﬁee County, downloading said Georgia, by County, Georgia, an actofracketeering act of racketeering activity under O.C.G.A. SullivanStrickler LLC. This SullivanSitrickler LLC. This was was an under 0.C.G.A. § 16-14-3(5)(B) § l6-l43(5)(B) activity of the conspiracy. and an an overt overt act act in and in furtherance furtheranceofthe conspiracy. Act 151. Act 151. the 10th of January 2021, On or 9th day or about On about the the 9th dayofJanuary 2021, the 10th dayofJanuary 2021, the the 11th 11th day day day of January 2021, and the the 18th of 2021, the 18th dayofJanuary the 19th 19th dayof January 2021, 2021, 0f January 2021, and day of January day of January 2021, January 2021, the Grand unindicted unindicted co-conspirator co-conspirator Individual Individual 26, whose identity identity isis unknown unknown toto the Grand Jury, Jury, 26, whose at the unlawfully accessed copied from from Dominion Dominion Voting Voting Systems the Coffee Coffee data copied accessed certain certain data Systems equipment equipment at unlawfully Oﬁice in Coffee & County Board ofElections& Registration Office in Coffee County, Georgia, by downloading of Elections Board downloading Registration County, Georgia, by County SullivanStrickler LLC. This was was an an act act of of racketeering said data from from aa server server maintained said data maintained by by SullivanStrickler LLC. This racketeering and an overt act in furtherance of the under O.C.G.A. 16-14-3 activity under O.C.G.A. § 16-14-3(5)(B) and an overt actin furtherance of the conspiracy. conspiracy. (5)(B) § activity 66 66

PDF Page 68	Act 152. Act152. of January 13th the 13th 2021, the 0f January 2021, January 2021, dayof 12th day the 12th or about about the On or dayofJanuary 2021, the 10th day the 10th On of and the 26th 2021, of February of day the 25th 26th the and 2021, 2021, February dayof of 25th the 2021, February January dayof 2021, day day February day January 2021, Grand Jury, to the Whose identity unknown to Jury, the Grand identity isis unknown unindicted co-conspirator Individual 27, co-conspirator Individual unindicted 27, whose Coffee at the Dominion Voting the Coffee data copied accessed certain Voting Systems from Dominion copied from certain data unlawfully accessed equipment at Systems equipment unlawfully Oﬁice in Coffee & downloading by downloading of Elections & Registration County, Georgia, Registration Office in Coffee County, BoardofElections Georgia, by County Board County of racketeering an act SullivanStrickler LLC. actofracketeering. was an This was said data LLC, This maintained by server maintained from aa server data from said by SullivanStrickler the of and an overt act in furtherance conspiracy. the of O.C.G.A. §§ 16-14-3(5)(B) conspiracy. 16-14-3(5)(B) and an overt act in furtherance under O.C.G.A. activity activity under Act 153. Act 153. Individual 28, about the co-conspirator Individual On or or about 28, unindicted co-conspirator 2021, unindicted 13th dayof the 13th On January 2021, day 0f January from data certain accessed certain data copied Grand Jury, known to whose Jury, unlawfully the Grand to the identity isis known copied from ‘whose identity unlawfully accessed & at the Coffee Board of Elections Registration & Registration Elections Boardof Dominion County Coffee the at equipment Systems Voting Dominion Voting Systems equipment County maintained a server said data from by Oﬁice in Coffee County, Georgia, by County, Georgia, in Coffee Office by downloading downloading said data from a server maintained by O.C.G.A. §§ l614-3(5)(B) 16-14-3(5)(B) was an act of racketeering LLC. This This was under O.C.G.A. activity under racketeering activity an actof SullivanStrickler SullivanStrickler LLC. furtherance of the conspiracy. an overt overt act and act inin furtheranceofthe and an conspiracy. Act 154. Actise, counindicted cothe 18th 18th dayof On MISTY HAMPTON HAMPTON allowed allowed unindicted or about about the On or 2021, MISTY January 2021, day of January to Grand Jury, are known conspirators Individual 25 25 and and Individual Individual 29, whose identities identitiesare known toto the the Grand Jury, to 29, whose conspirators Individual in Oﬁice & Coffee in Coﬂee Coffee Board of Elections Office Registration of the & areas ofElections Board access non-public County Coffee the areasof access Registration County non-public This access to was Voting Systems Dominion Voting to Dominion their access facilitated their and facilitated Georgia, and County, equipment This was Systems equipment. County, Georgia, of the conspiracy. an overt act an overt act inin furtherance furtheranceofthe conspiracy. Act Act 155. 155. Individual 28, whose 28, whose 22nd dayof unindicted co-conspirator On or or about the 22nd about the On 2021, unindicted co-conspirator Individual day of April April 2021, of Oﬁicer sent an email to the Chief Grand to the is known identity is known to the Grand Jury, sent an e-mail to theChief Operations Officer of Jury, Operations identity all data data copied from Dominion Systems Voting Systems Dominion Voting SullivanStrickler LLC transmit all him toto transmit directing him LLC directing SullivanStrickler copied from Coffee in Ofﬁce County, & Coffee in of Elections Office Board Registration & at the Coffee County, BoardofElections County Coffee Registration equipment at the County equipment Grand Jury, known to Individual 30, whose identity the Grand to the identity isis known unindicted co-conspirator 30, whose Jury, Georgia, toto unindicted co-conspirator Individual Georgia, This and the SIDNEY KATHERINE with SIDNEY associated with the Trump an attorney POWELL and KATHERINE POWELL Campaign. This Trump Campaign. attomey associated an in overt act and an under O.C.G.A. of was an act of racketeering activity under 0.C.G.A. § 16-14-3(5)(B) and an overt act in an act was § 16-14-3(5)(B) racketeering activity furtherance of the conspiracy. furtheranceofthe conspiracy. 67 67

PDF Page 69	Act 156. Act 156. committed JOHN TRUMP TRUMP committed On or DONALD JOHN September 2021, of September 17¢h day the 17th about the 2021, DONALD or about On day of OF VIOLATION offense of the OFFICER, the felony felony offense of SOLICITATION SOLICITATION OF VIOLATION OF OF OATH OATH BY BY PUBLIC PUBLIC OFFICER, unlawfully by unlawfully and 16-10-1, Fulton County, of O.C.G.A. §§ 16-10-1, inin Fulton 164-7 and violationof0.C.G.A. inin Violation Georgia, by County, Georgia, §§ 16-4-7 Brad of State public aa public and Raffensperger, Brad SecretaryofState Georgia importuning and requesting, soliciting, Raffensperger, importuning Georgia Secretary soliciting, requesting, Public Oath of of Violation the oﬁ'ense Public by Oath in conduct to engage by officer, ofﬁcer, to constituting the felony felony offenseof Violationof engage in conduct constituting correct or Whatever the correct whatever the O.C.G.A. §§ 16-10-1, Election, or the Election, “decertifying the unlawfully "decertifying 16-10-1, by Officer, Ofﬁcer, 0.C.G.A. by unlawfully of the terms Violation and intentional the true in willful and announce terms the violationof winner,” in willful and intentional remedy is, legal is, and announce the true Winner," legal remedy said said person ofthe person asas prescribed by law, law, with with intent intent that that said person engage engage inin said oath of said person of the oathofsaid prescribed by act in furtherance of the an overt This was conduct. conduct. This was an overt act in furtheranceofthe conspiracy. conspiracy. Act 157. Act 157, committed the of September 2021, the about the TRUMP committed On JOHN TRUMP DONALD JOHN 17th day the 17th On oror about 2021, DONALD day ofSeptember of Violation O.C.G.A. in 16oﬁ'ense of FALSE AND WRITINGS, STATEMENTS AND FALSE STATEMENTS WRITINGS, in violation of 0.C.G.A. §§ 16felony felony offenseof the and 10-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making the following in Fulton making following unlawfully 10-20, County, Georgia, by knowingly, willfully, Brad Raffensperger of State falsestatementand representation toto Georgia Georgia Secretary State Brad false statement and representation Raffensperger: Secretary of than of false and/or and/or irregular greater than far greater votes sis far irregular votes stated to numberoffalse the number previously, the to you “As stated 1.l. "As you previously, needed needed toto change change the the Georgia election result”; result"; Georgia election State and and within thejurisdictionof the jurisdiction of the Office of the Georgia said statement statement being the Officeofthe Secretary of Sate being within said Georgia Secretaryof and county of state government, of Investigation, and agencies the Georgia Bureauof agenciesofstate the county government, and Investigation, departments departments and Georgia Bureau under O.C.G.A. This was an act of enforcement agencies. ‘and city law law enforcement of racketeering racketeering activity 16+ and city activity under 0.C.G.A. §§ l6agencies. Thiswasanact act in the an overt furtherance of and l4-3 14-3(5)(A)(xii) and an overt act in furtheranceofthe conspiracy. conspiracy. (5)(A)(xxii) 68 68

PDF Page 70	Act Act 158. 158. On or about the 25th dayof April 2022, DAVID JAMES SHAFER commited the felony offense of FALSE STATEMENTS AND WRITINGS, in violationof 0.C.G.A. § 1610-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of the following false statements and representations in the presence of Fulton County District Attorney’s Office investigators: of Trump presidential and convened" the December That he 1.1. That he "attended “attended and convened the December 14, 14, 2020, 2020, meeting meetingofTrump presidential each of the he did not "call that but eachofthe “call not elector nominees Georgia, but that he did County, Georgia, Fulton County, nominees inin Fulton elector other preparations or make make anyofthe individual members members and notify them themofthe meeting or and notify of the meeting individual any of the other preparations for the necessary meeting”; necessary for the meeting"; Thataa court 2.2. That court reporter reporter was was not not present present atat the the December December 14, 14, 2020, Trump 2020, meetingof meeting of Trump elector nominees presidential elector nominees inin Fulton Fulton County, County, Georgia; Georgia; presidential the jurisdiction of the Fulton said being within within thejurisdictionofthe Fulton County District Attomey's Attorney's Office, said statements statements being Ofﬁce, aa County District an act act of was an state. This of the of a countyofthis department and and agency agency of the government government of This was of county of this state. department act in overt furtherance of the and an furtheranceofthe in act under O.C.G.A. overt an and 16-14-3(S)(A)(xxii) activity underO.C.G.A. §§ 16-14-3(5)(A)(xxii) racketeering activity racketeering conspiracy. conspiracy. Act 159. Act159. POWELL made least KATHERINE POWELL 7th dayofMay SIDNEY KATHERINE On or about the On or about the 7th made atat least 2022, SIDNEY day of May 2022, with the sworn deposition false statements United the United statements and and representations deposition with of the following in aa sworn one following false oneofthe representations in the 6th Attack on to States HouseofRepresentatives Select Committee to Investigate the January 6th Attack on the the of Select Committee States House January Investigate Representatives United United States States Capitol: Capitol: machines in in "didn't have voting machines That she she “didn’t have any access voting 1. efforts toto access up” efforts setting up" really setting role inin really 1. That any role or Antrim County, Coffee Coffee County, County, Georgia, Georgia,orAntrim Michigan; County, Michigan; access to some people" to get That she she was an "effort by 2.2. That was aware aware there there was was an“effort by somepeople”to get access to voting voting that" and did not with what machines inin Georgia but that she did not “know what happened with that” and did not but did not "know machines that she happened Georgia or other "remember whether that was was Rudy “remember whether that Rudy or other folks." folks.” overt act act in of the conspiracy. This was ‘This was an an overt in furtherance furtheranceofthe conspiracy. On or about the 25th day of April 2022, DAVID JAMES SHAF ER committed the felony offense of FALSE STATEMENTS AND WRITINGS, in Violation of O.C.G.A. § 1610-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of the following false statements and representations in the presence of Fulton County District Attorney's Ofﬁce investigators: ' 6 69

PDF Page 71	Act 160. Act 160. CATHLEEN ALSTON ALSTON LATHAM On or about about the LATHAM of September On or the 1st It day September 2022, 2022, CATHLEEN day of of O.C.G.A. committed the offense of PERJURY, in commited the felony felony offenseofPERJURY, in Violation violationof 0.C.G.A. §§ 16-1070(a), 16-10-70(a), inin Houston Houston one of the following and unlawfully ‘County, by knowingly, knowingly, willfully, making atat least least oneofthe following unlawfully making County, Georgia, Georgia, by willfully, and Case 1:17-cv-02989 false statements statements ina in a deposition of Curling V. in the matter false depositioninthe matterofCurling v. Raffensperger, Raffensperger, Case 1:17-cv-02989a judicial proceeding, AT in the States District Court for ATin the United United States District Court for the the Northern Northern District District of of Georgia, Georgia, ajudicial proceeding, been after having administered a lawful oath: after been administered a lawful oath: having of Elections & & Registration l. she was Office 1. That That she was only presentaat the the Coffee Coffee County County Board BoardofElections Registration Office only present on in Coffee County, few minutes" for a in Coffee Georgia, for “justa few minutes”on January 7, 2021; January 7, 2021; County, Georgia, "just of Elections&& she only of the Coffee "walked into front part" ofthe 2.2 That That she only “walked into the the frontpart” Coffee County BoardofElections County Board the office"; Oﬁice on on January Registration Office January 7,7, 2021, 2021, and and "didn't “didn’t go go into into the office”; Registration Eric Chaney That shehad she had “no at the Coffee "no idea" of SullivanStrickler SullivanStrickler met 3.3 That idea” ifif employees employeesof met Eric the Coffee Chaney at 2021 Board of & Oﬁice on Elections County BoardofElections & Registration Office on January 7, 2021; 7, January County Registration 4 That she of Elections& & did not see Misty at the 4. That she did not see Misty Hampton the Coffee Coffee County BoardofElections County Board Hampton at Oﬁice on Registration 7, 2021; 2021; Registration Office on January January 7, Coffee County Board of Elections & & That her Scott Hall 5.5 That her only interaction with with Scott Hall atat the the Coffee County BoardofElections only interaction him outside of the Ofﬁce on on January Registration January 7,7, 2021, 2021, was was meeting him, speaking to him outsideofthe meeting him, Registration Office speaking to and then then leaving office, leaving the the office; office, and office; other thanherselfat than herself at the the Coffee she did Scott Hall 6.6 That That she did not not see see Scott Hall speak to anyone Coffee County anyone other County speak to 2021 Board of Elections on & Ofﬁce Board of Elections & Registration Registration Office on January 7, 2021 January 7, statements being said accused's own said statements being material material toto the the accused’s own involvement involvement inin the the January 7, 2021, 2021, January 7, of Elections & & Registration unlawful breach of election equipment Coffee County unlawful breachofelection at the the Coffee BoardofElections County Board Registration equipment at Oﬂice and to to the the accused's with others communications with Office and accused's communications others involved, involved, the the issues issues inin question. question. This This was an act ofracketeering of racketeering activity and an act in O.C.G.A. §§ l6-l4-3(5)(A)(xxv) ‘was an act under O.C.G.A. 16-14-3(S)(A)(xxv) and an overt overt act in activity under furtherance of the conspiracy. furtheranceofthe conspiracy. ; ; 70 0

PDF Page 72	Act 161. Act161DAVID CHEELEY CHEELEY ROBERT DAVID On or or about about the 2022, ROBERT dayofof September 15th day the 15th On September 2022, Fulton in Fulton Violation of 0.C.G.A. O.C.G.A. §§ 16-10-70(a), committed the felony felony offense offense of PERJURY, inin violationof 16-10-70(w), in of PERJURY, committed the one of the following ‘County, Georgia, by by knowingly, willfully, and and unlawfully unlawfully making making atat least least oneofthe following County, Georgia, knowingly, willfully, Grand a proceeding, false statements before Fulton County the Fulton before the false statements Jury, ajudicial judicial proceeding, Purpose Grand Jury, County Special Special Purpose oath: after having after having been been administered administered aa lawful lawful oath: elector 1.1. That he was unawareofthe December 14, 14, 2020, Trump presidential presidential elector That he was unaware of the December 2020, meetingof meeting of Trump the had taken until after ‘nominces in Fulton Georgia, until after the meeting had already taken place; Fulton County, nominees in meeting already place; County, Georgia, December 14, 14, the December conversations with concerning the 2. That he substantive conversations with anyone no substantive had no he had 2. That anyone concerning until Georgia, until elector nominees Fulton County, nominees inin Fulton of Trump presidential presidential elector meetingofTrump 2020, County, Georgia, 2020, meeting after the had already after the meeting meeting had taken place; place; already taken elector nominees 3. That he 3. That he never never suggested suggested toto anyone that the the Trump presidential elector nominees inin Trump presidential anyone that on December should meet Georgia meet on December 14, 2020; 14, 2020; Georgia should 4.4. That the only only communication he had had with with John John Eastman Eastman concerning the November November 3,3, That the communication he concerning the Senator of connecting Eastman Eastman toto Georgia election was purposeofconnecting the purpose for the was for 2020, Georgia Senator 2020, presidential presidential election to known Individual whose is and unindicted Brandon Beach unindicted co-conspirator Brandon Beach and Individual 8, whose identity is known to 8, identity coconspirator the Grand Jury, the Grand Jury, for for possible possible legal legal representation; representation; other than with any John Eastman 5.5. That he never never wo'rked worked toto connect Eastman with legislators other than connect John That he any Georgia Georgia legislators Individual whose unindicted and Beach Georgia Senator Brandon Beach and unindicted co-conspirator Individual 8, whose Senator Brandon 8, co-conspirator Georgia the Grand identity is known known toto the Grand Jury; Jury; identity is 2020, accused's own 14, 2020, December 14, the December said statements involvement inin the own involvement the accuseds material toto the statements being said being material the accused's accused's in Fulton and to nominees in 10 the of Trump Fulton County, elector nominees presidential elector County, Georgia, meeting Georgia, and meeting of Trump presidential of an act of the issues in This was communications with others involved inin the the meeting, the issues in question. This was an act communications with others involved meeting, question. the of and an overt act in furtherance 16-14-3(5)(A)(xxv) O.C.G.A. §§ 1614-3 under O.C.G.A. racketeering activity (5)(A)(xxv) and an overt act in furtherance ofthe racketeering activity under conspiracy. conspiracy. furtherance of the committed in “The forth above above were were committed in furtheranceof the conspiracy alleged above above The acts acts set set forth conspiracy alleged and methods of commission commission methodsof and had had the same and similar accomplices, victims, similar intents, victims, and thesameand results, accomplices, and intents, results, and were acts were interrelated isolated acts. not isolated were not and otherwise otherwise were interrelated by characteristics and distinguishing characteristics by distinguishing and 7 71

PDF Page 73	COUNT 22 of of 41 COUNT 41 do in the and behalf of the citizensofGeorgia, citizens of Georgia, do And the the Grand the name name and behalf ofthe And Grand Jurors Jurors aforesaid, aforesaid, in and accuse accuse RUDOLPH charge RUDOLPH WILLIAM WILLIAM LOUIS LOUIS GIULIANI, GIULIANI, JOHN JOHN CHARLES CHARLES charge and of and RAY with the STALLINGS SMITH III offense of the offense LYNN IIT JENNA LYNN ELLIS, ELLIS, and RAY STALLINGS SMITH with EASTMAN, JENNA EASTMAN, O.C.G.A. §§ OF OATH SOLICITATION OF VIOLATION OF OATH BY BY PUBLIC PUBLIC OFFICER, 16-47 OF VIOLATION SOLICITATION OFFICER, O.C.G.A. §§ 16-4-7 ofaa in commission and as concerned the & 16-10-1, for the said accused, individually and as persons concerned in the commission of & for the said accused, individually 16-10-1, persons of and State crime, and together together with with unindicted unindicted co-conspirators, co-conspirators, inin the the CountyofFulton State of crime, and County of Fulton and and importuned December and 0f requested, solicited, on the 3rd unlawfully 2020, dayofDecember 3rd the on 2020, Georgia, importuned unlawfully solicited, requested, day Georgia, of the Georgia elected members Senate andpresent and present atat aa certain Georgia Senate membersofthe serving asas elected then serving officers then public oﬂicers certain public Senate unindicted co-conspirator Individual 8,8, Senate Judiciary Subcommittee meeting, including unindicted meeting, including co-conspirator Individual Judiciary Subcommittee Grand Senators Lee Brandon to the whose is known whose identity known to the Grand Jury, Jury, Senators Lee Anderson, Anderson, Brandon Beach, Beach, Matt Matt Brass, Brass, identity is William Bill Jen F. John Steve Greg Dolezal, Steve Gooch, Tyler Harper, Bill Heath, Jen Jordan, John F. Kennedy, William Heath, Jordan, Gooch, Dolezal, Kennedy, Tyler Harper, Greg Carden Summers, Blake Tillery, Ligon, Elena Elena Parent, Parent, Michael Michael Rhett, Rhett, Carden Summers, and and Blake to engage engage inin conduct conduct Tillery, to Ligon, O.C.G.A. §§ 16-10-1, of Violation of Oath by the felony constituting felony oﬂ'ense offenseofViolationofOath Public Officer, 16-10-1, by Oﬂicer, 0.C.G.A. by by Public constitutingthe intentional from the of in and electors State willful unlawfully appointing presidential electors from the State ofGeorgia, in willful and intentional Georgia, unlawfully appointing presidential said of the termsofthe terms of the oath violation ofthe violation oath of of said said persons persons asas prescribed prescribed by by law, with intent intent that that said law, with to the the date a the said material element of in persons engage in said conduct, said date being a material elementofthe offense, contrary said oﬂ'ense, conduct, contrary to being persons engage and dignity laws of said State, lawsofsaid the good peace and thereof; order, peace State, the dignity thereof; good order, 3 of 41 COUNT 3of 41 COUNT in the name and and behalf of the citizensofGeorgia, citizens of Georgia, do Grand Jurors Jurors aforesaid, And the theGrand the name behalf ofthe do And aforesaid, in of FALSE LOUIS GIULIANI with the offense WILLIAM and accuse RUDOLPH charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI with the offense of FALSE. charge O.C.G.A. §§ 16-10-20, STATEMENTS AND STATEMENTS AND WRITINGS, WRITINGS, 0.C.G.A. 16-10-20, for for the the said said accused, in the the County accused, in County willfully, knowingly, 2020, or about about the the 3rd 3rd day of December of on or December of Fulton and StateofGeorgia, State of Georgia, on Fulton and of 2020, knowingly, willfully, day to the false statements one of and and unlawfully and made atat least least oneofthe following following false statements and representations representations to unlawfully made Senate at a Subcommittee Senate ‘membersofthe Senate present at a Senate Judiciary Subcommittee meeting: members of the Georgia meeting: present Judiciary Georgia ballots were counted counted in in the November 3, 1. 1. That That atat least least 96,600 mail-inballotswere the November 3, 2020, 2020, presidential presidential 96,600 mail-in been returned no record of those there ballots election inin Georgia, Georgia, despite there being no recordofthose ballots having been returned toto election being having despite a a county elections ofﬁce; office; county elections the November 2.2. That That aa Dominion Voting Systems machine used used inin the November 3,3, 2020, presidential Dominion Voting 2020, presidential Systems machine in Antrim Antrim County, election Michigan, mistakenly mistakenly recorded recorded 6,000 votes for for Joseph R. election in 6,000 votes Joseph R. County, Michigan, cast for Donald Trump; Biden Biden when when the the votes votes were were actually actually cast for Donald Trump; of the Oﬂice and of the Georgia within the said being within the jurisdiction jurisdictionofthe Officeofthe Georgia SecretaryofState said statements statements being Secretary of State and and and of state of Investigation, the the Georgia Bureauof Investigation, departments agenciesofstate government, county departments and agencies government, and county Georgia Bureau and to the laws of said the and city law enforcement and law enforcement agencies, contrary to the lawsofsaid State, the good order, peace and order, State, contrary peace good agencies, city dignity thereof; dignity thereof; 7 72

PDF Page 74	COUNT 0f 41 COUNT 44 of 41 citizens of Georgia, do in the of the citizensofGeorgia, do And the Grand ofthe behalf and behalf name and the name aforesaid, in Jurors aforesaid, Grand Jurors Andthe STATEMENTS of FALSE STATEMENTS SMITH III with the offense FALSE of RAY STALLINGS offense the with accuse III SMITH and STALLINGS RAY accuse and charge charge of Fulton and the County said accused, AND WRITINGS, WRITINGS, O.C.G.A. 0.C.G.A. §§ 16-10-20, 16-10-20, for for the the said in the CountyofFulton and AND accused, in and 3rd day about the on or 2020, knowingly, State of Georgia, on December 2020, of December the 3rd or about willfully, and StateofGeorgia, knowingly, willfully, day of members to the false and one of statements of members of at least to made representations and statements false following unlawfully made at least oneofthe following representations unlawfully at aa Senate Senate Judiciary Subcommittee meeting: Senate present the the Georgia meeting: Judiciary Subcommittee present at Georgia Senate election in the November voted illegally 2,506 felons felons voted in the November 3,3, 2020, presidential election in l.1. That That 2,506 2020, presidential illegally in Georgia; Georgia; seventeenth birthday birthday 2 That 66,248 their seventeenth before their vote before registered toto vote illegally registered people illegally underage people 2. That 66,248 underage election in November priorto the November 3,3, 2020, 2020, presidential Georgia; presidential election in Georgia; prior to the voted in 3.3 That at least least 2,423 people voted in the the November November 3,3, 2020, presidential election election inin That at 2020, presidential 2,423 people listed as registered to wh'o were were not ‘Georgia not listedasregistered to vote; vote; Georgia who who. Georgia who 4 election inin Georgia That 1,043 November 3,3, 2020, the November voted inin the 1,043 people 4. That 2020, presidential presidential election people voted a to vote ofﬁce had had illegally registered to vote using a post office box; box; using post illegally registered or more dead people 5. That 10,315 ormoredead voted inin the the November November 3,3, 2020, 2020, presidential presidential election lection inin 5 That 10,315 people voted Georgia; Georgia; and watchers and workers at at State 6.6 That State Farm FarmArena ordered poll poll watchers election workers Arena ordered Fulton County That Fulton County election and tabulation area on the of November 3, ‘membersofthe media toto leave leave the the tabulation area on the night nightofNovember 2020, and of the media members 3, 2020, after to to continued continued to operate operate afer ordering everyone to leave; leave; ordering everyone and of State and Office of the Georgia said statements being said statements being within within the thejurisdictionofthe SecretaryofState jurisdiction of the Officeofthe Georgia Secretary and agenciesofstate of Investigation, the Georgia the Georgia Bureau Bureauof Investigation, departments and county county departments and agencies of state goverment, government, and the to the laws of said and city law enforcement ‘and law enforcement agencies, contrary to the lawsofsaid State, the good order, peace and order, State, peace and good agencies, contrary city dignity thereof; dignity thereof; ' 73 7

PDF Page 75	COUNT 5 of 41 41 COUNTSof Jurors aforesaid, citizens of Georgia, do And Grand Jurors in the name and and behalf behalfofthe of the citizensofGeorgia, And the the Grand the name do aforesaid, in OF accuse DONALD JOHN TRUMP with the offense of SOLICITATION and charge and accuse DONALD JOHN TRUMP with the offense ofSOLICITATION OF charge OF OATH OATH BY for the O.C.G.A. §§ VIOLATION VIOLATION OF BY PUBLIC PUBLIC OFFICER, OFFICER, 0.C.G.A. 164-7 && 16-10-1, 16-10-1,forthe §§ 16-4-7 0f in the of Fulton or the 7th and State of on about said accused, said inthe County of Fulton and State of Georgia, on or about the 7th day of accused, day County Georgia, and importuned December December 2020, unlawfully solicited, requested, and importuned Speakerof the Georgia Georgia House House 2020, unlawfully solicited, requested, Speaker of the the in conduct David Ralston, of Representatives David ofRepresentatives Ralston,aa public public ofﬁcer, officer, toto engage in conduct constituting the felony constituting felony engage of Oath by of Violation O.C.G.A. §§ 16-10-1, offense of offense ViolationofOath Public Officer, 16-10-1, by for aa special Oﬁicer, 0.C.G.A. by Public by calling calling for special General Assembly for the the purpose of unlawfully appointing session of the Georgia sessionofthe Georgia General Assembly for purposeofunlawfully appointing presidential presidential of the oath oath of the State of in of the terms from willful and intentional Violation electors electors from the Stateof Georgia, Georgia, in willful and intentional violationofthe termsofthe of intent that said said person person asas prescribed by law, law, with with intent that said said person person engage engage inin said said conduct, to conduct, contrary contrary to prescribed by the laws of said and the the lawsofsaid State, peace and dignity dignity thereof; thereof; State, the good order, peace good order, 41 COUNT 66of of 41 COUNT And the Grand Grand Jurors Jurors aforesaid, in the of the citizensofGeorgia, citizens of Georgia, do do name and and behalf behalfofthe And the the name aforesaid, in RAY STALLINGS and accuse RUDOLPH WILLIAM and LOUIS GIULIANI charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI and RAY STALLINGS charge offense of of SOLICITATION OATH BY SMITH SOLICITATION OF SMITH III IIT with with the the offense OF VIOLATION VIOLATION OF OF OATH BY PUBLIC PUBLIC and as O.C.G.A. 16-4-7 & for the said OFFICER, 0.C.G.A. §§ 164-7 & 16-10-1, for the said accused, individually andaspersons OFFICER, 16-10-1, accused, individually §§ persons in the commission of concerned with unindicted concerned inin the the commission ofaa crime, and together together with unindicted co-conspirators, the. crime, and co-conspirators, in and State of of Fulton on the 10th 0f December Countyof Fultonand StateofGeorgia, on the 10th day of December 2020, unlawfully solicited, 2020, solicited, unlawfully County Georgia, day certain public of the oﬁicers then as elected elected members requested, and and importuned public officers then serving membersof the Georgia Georgia importuned certain serving as requested, and present Affairs Committee Committee meeting, of Representatives and House HouseofRepresentatives present atat aa House House Governmental Governmental Affairs meeting, Shaw Blackmon, including Representatives Representatives Shaw Blackmon, Jon Jon Burns, Barry Fleming, Todd Jones, Jones, Bee Bee Nguyen, Burns, Barry Fleming, Todd Nguyen, including and Bruce Bruce Scot Tumer, Mary Margaret Oliver, Alan Alan Powell, Powell, Renitta Renitta Shannon, Shannon, Robert Robert Trammell, Turner, and Trammell, Scot Margaret Oliver, Mary of in conduct of Violation Oath Public to the offense Williamson, to engage in conduct constituting the felony offenseof Violation of Oath by Public Williamson, engage by constituting felony the State of electors from O.C.G.A. §§ 16101, Officer, 0.C.G.A. 16-10-1, by by unlawfully unlawfully appointing from the State of Oﬁicer, appointing presidential presidential electors and of as in willful intentional violation of the terms of the oath said Georgia, in willful and intentional violation ofthe termsofthe oathofsaid persons as prescribed persons prescribed Georgia, said date date being element of of with intent said conduct, by law, law, with intent that that said said persons persons engage in said beingaa material material element conduct, said by engage in and to the laws of said the the offense, the contrary to the lawsofsaid State, the good order, peace and dignity thereof; thereof; order, offense, contrary State, dignity good peace 7 74

PDF Page 76	7 of 41 COUNT COUNT 7of41 And the Grand Jurors aforesaid, in the name and behalf ofthe citizensofGeorgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI with the offense of FALSE said accused, AND WRITINGS, STATEMENTS 0.C.G.A. §§ 16-10-20, 16-10-20, for for the the said in the the County STATEMENTS AND accused, in WRITINGS, O.C.G.A. County and StateofGeorgia, State of Georgia, on the 10th 10th day of Fulton Fulton and on or or about of December December 2020, knowingly, of about the 2020, knowingly, day of at least one made atleast of the following willfully, and unlawfully unlawfully made oneofthe following false false statements statements and and representations representations willfully, and at a House Governmental the of House of Representatives present to to members membersofthe Georgia HouseofRepresentatives present at a House Governmental Affairs Affairs Georgia Committee Committee meeting: meeting: November 3, l. That it is quite clear from State Farm Arena Video 1. Thatitis from the the State Farm Arena video from from November that 3, 2020, 2020, that quite clear ofﬁcials and that were Fulton County election votes workers were Fulton election workers were stealing votes and that Georgia officials were Georgia County stealing covering up aa crime crime inin plain covering up sight; plain sight; ofﬁcials “got rid of all of the Democratic officials the 2 That at at State State Farm Farm Arena 2. That Arena on on November November 3,3, 2020, 2020, Democratic "got ridofallof used the excuse of a all that couldn't be the reporters, all the observers, anyone that couldn’t be trusted,” used the excuse of a trusted," observers, anyone reporters, about their "went about crooked cleared out area and and then ‘watermain break, break, cleared out the the voting voting area then “went their dirty, watermain dirty, crooked business”; business"; counted by election and 24,000 ballots were were illegally 3.3 That That between between 12,000 12,000 and by Fulton Fulton County 24,000 ballots County election illegally counted workers Farm Arena on November workers atat State State Farm Arena on November 3,3, 2020; 2020; than were sent sent out out to counted thanwere there were 4.4 That That inin Michigan, Michigan, there were 700,000 700,000 more more ballots ballots counted to voters voters accounted for in the November which was inthe November 3,3, 2020, was accounted for by by quadruple election, which 2020, presidential quadruple presidential election, counting ballots; counting ballots; were “quite That Ruby 5.5 That Ruby Freeman, Freeman, Shaye Shaye Moss, and an an unidentified unidentified man man were Moss, and "quite obviously obviously of or vials heroin cocaine" USB as if surreptitiously passing around USB ports as if t heyre vials of heroin or cocaine” atat State State around surreptitiously passing ports they're Farm "inﬁltrate the Farm Arena Arena toto be be used used toto “infiltrate the crooked crooked Dominion Dominion voting machines"; voting machines”; in the election That 96,600 mailin ballots were counted counted in 6.6 That ballots were the November November 3,3, 2020, 2020, presidential 96,600 mail-in presidential election been ballots returned to in there no record of those in Georgia, despite there being no record of those ballots having been returned to aa having Georgia, despite being elections office; county office; county elections Office of the Georgia the jurisdiction of the Officeofthe said statements being being within within thejurisdictionofthe Georgia SecretaryofState and said statements Secretary of State and and county of Investigation, and agenciesofstate the the Georgia Bureau of Investigation, departments goverment, and agencies of state government, county Georgia Bureau departments and the to the laws of said and law enforcement and and city law enforcement agencies, contrary to the lawsof said State, the good order, peace State, good order, peace and agencies, contrary city dignity thereof; dignity thereof; And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI with the offense of FALSE 75 75

PDF Page 77	COUNT 8 of 41 COUNTSof41 of the citizensofGeorgia, citizens of Georgia, do and behalf do And the Grand ofthe behalf name and the name in the Jurors aforesaid, Grand Jurors And the aforesaid, in TRESHER STILL, SHAWN MICAH and accuse accuse DAVID SHAFER, SHAWN charge MICAH TRESHER and DAVID JAMES JAMES SHAFER, STILL, and charge and PUBLIC of IMPERSONATING A offense ofIMPERSONATING LATHAM with CATHLEEN ALSTON ALSTON LATHAM with the the offense A PUBLIC CATHLEEN and as concerned in as persons the said O.C.G.A. §§ 16-10-23, OFFICER, 0.C.G.A. 16-10-23, for for the said accused, individually and persons concerned in accused, individually OFFICER, Fulton in the of with unindicted CountyofFulton a the in the commission of and co-conspirators, unindicted with together and crime, the commission of a crime, together County co-conspirators, of December held falsely held and StateofGeorgia, State of Georgia, on on or or about unlawfully falsely 2020, unlawfully December 2020, 14th day the 14th about the ‘and day of electors from the State of themselves out the duly elected and qualified presidential electors from the Stateof Georgia, as the elected and themselves out as Georgia, duly qualiﬁed presidential of the United ‘public with intent intent toto mislead mislead the the President President of ofthe United States States Senate, Senate, the the Archivist Archivist of ofﬁcers, with public officers, Chief Judgeofthe United States States the Georgia the Georgia SecretaryofState, and the theChief the United United States, Judge of the United States, the Secretary of State, and that were such into District of District Court for the the Norther Northern DistrictofGeorgia District Court for they actually believing that they actually were such Georgia into believing document titled titled “CERTIFICATE "CERTIFICATE mail to ofﬁcers officers by by placing placing inin the the United United States States mail to said said persons persons aadocument to laws of said FROM THE VOTES OF THE 2020 ELECTORS OF OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” the lawsofsaid GEORGIA," contrary contrary to the and dignity State, the the good peace and thereof; State, order, peace good order, dignity thereof; 41 of 41 COUNT 99of COUNT do of the citizensofGeorgia, citizens of Georgia, do and behalf And Grand Jurors Jurors aforesaid, ofthe behalf name and the name aforesaid, inin the the Grand And the WILLIAM LOUIS RUDOLPH charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, GIULIANI, charge and accuse DONALD JOHN TRUMP, RAY STALLINGS STALLINGS JOHN CHARLES CHARLES EASTMAN, EASTMAN, KENNETH KENNETH JOHN JOHN CHESEBRO, JOHN CHESEBRO, RAY of with the the offense and MICHAEL DAVID CHEELEY, SMITH III, ROBERT ROBERT DAVID MICHAEL A. A. ROMAN ROMAN with offense of SMITH III, CHEELEY, and O.C.G.A. §§ A PUBLIC IMPERSONATING A TO COMMIT CONSPIRACY COMMIT IMPERSONATING PUBLIC OFFICER, §§ CONSPIRACY TO OFFICER, 0.C.G.A. as concerned in the and for the said 16-4-8 16-4-8 && 16-10-23, for the said accused, individually and as persons concemed in the accused, individually 16-10-23, persons and unindicted commission of ofaa crime, and together commission crime, and together with with indicted indicted and unindicted co-conspirators, in the the County County co-conspirators, in December and the 14th the 6th of 2020 of Fulton and between the 6th day of December 2020 and the 14th and StateofGeorgie, State of Georgia, on on and and between of Fulton day cause certain certain individuals hold dayofDecember unlawfully conspired to cause individuals toto falsely falsely hold 2020, unlawfully conspired to day of December 2020, electors from of Georgia, themselves out out asas the and qualified presidential electors from the the State Stateof the duly elected and themselves Georgia, qualiﬁed presidential duly elected the Archivist of of the United States President public officers, with intent intent toto mislead mislead the the Presidentofthe United States Senate, Senate, the Archivist of ofﬁcers, with public Chief Judge of the United United States States and the of State, and the the United United States, States, the the Georgia SecretaryofState, theChief Judgeofthe Georgia Secretary that were into of Court for the Northern District District District Court for the Norther Districtof Georgia believing that they they actually such actually were such Georgia into believing officers; ofﬁcers; as co-conspirators, as described described above above and and the Defendants Count 8, And the And Defendants named named inin Count actingas 8, acting co-conspirators, as held themselves out as said public set forth incorporated by by reference reference as if fully fully set forth herein, falsely held themselves out as said public as if herein, falsely incorporated a document titled "CERTIFICATE mail to said in States ofﬁcers by the United officers by placing in the United States mail to said persons a document titled “CERTIFICATE persons placing GEORGIA" in Georgia, 2020 ELECTORS OF THE THE VOTES THE 2020 Fulton County, in Fulton FROM GEORGIA” ELECTORS FROM OF THE VOTES OF OF County, Georgia, to the laws of said of the conspiracy, overt act act to the object ‘which was an an overt to effect effect the objectofthe contrary to the lawsofsaid State, which was State, conspiracy, contrary and dignity the the good peace and thereof; order, peace good order, dignity thereof; 6 76

PDF Page 78	COUNT COUNT of 41 10 of41 do of the citizens citizens of Georgia, do of Georgia, Jurors aforesaid, ofthe behalf and behalf And the the Grand name and the name in the Grand Jurors And aforesaid, in and SHAWN MICAH chargeandaccuse DAVID JAMES MICAH TRESHER TRESHER STILL, SHAFER, SHAWN JAMES SHAFER, STILL, and charge and accuse DAVID FIRST of. FORGERY IN THE the offense with CATHLEEN ALSTON LATHAM with the offense of FORGERY IN THE FIRST LATHAM CATHLEEN ALSTON DEGREE, 0.C.G.A. for the the said said accused, and asas persons concerned inin O.C.G.A. §§ 16-9-1(b), accused, individually individually and persons concerned DEGREE, 16-9-1(b), for unindicted in the Fulton with Countyof the in a and co-conspirators, unindicted the commission of with together and the commissionofa crime, County of Fulton crime, co-conspirators, together with the and with of December the about the unlawfully and 2020, unlawfully and State of Georgia, on or or about December 2020, 14th day the 14th and Stateof day of Georgia, on OF THE THE VOTES titled "CERTIFICATE OF document OF THE made a VOTES to THE OF intent “CERTIFICATE titled document a knowinglymade intentto defraud, defraud, knowingly the that such manner manner that the a writing other other than 2020 ELECTORS in such than aa check, check, in FROM GEORGIA,” GEORGIA," awriting ELECTORS FROM 2020 and of the elected made have been writingas made purports tohavebeen made by authorityofthe duly elected and qualified as to made qualiﬁed by authority duly writing purports and and did not who such State of Georgia, who did not give presidential from the the StateofGeorgia, authority, and uttered uttered and electors from give such authority, presidential electors of said State, United States, of the United delivered to the State, States, contrary delivered said said document document to the Archivist Archivistofthe contrary toto the the laws lawsofsaid and the good the good order, thereof; order, peace dignity thereof; peace and dignity 10 41 0f 41 COUNT 11 COUNT 11 of do of the citizensof name and and behalf citizens of Georgia, And Grand Jurors Jurors aforesaid, And the the Grand aforesaid, inin the the name behalf ofthe Georgia, do LOUIS GIULIANI, and accuse accuse DONALD charge DONALD JOHN JOHN TRUMP, TRUMP, RUDOLPH RUDOLPH WILLIAM WILLIAM LOUIS GIULIANI, charge and RAY STALLINGS JOHN JOHN CHESEBRO, KENNETH JOHN CHESEBRO, RAY STALLINGS CHARLES EASTMAN, JOHN CHARLES EASTMAN, KENNETH offense of of the offense with the SMITH III, ROMAN with A. ROMAN MICHAEL A. and MICHAEL DAVID CHEELEY, ROBERT DAVID III, ROBERT CHEELEY, and SMITH 16-4-8 IN THE FIRST O.C.G.A. CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE, 0.C.G.A. §§ 164-8 CONSPIRACY TO COMMIT FORGERY DEGREE, §§ commission ofa a and as as persons concerned in && 16-91(b), 16-9-1(b), for for the the said accused, individually individually and persons concerned in the the commissionof said accused, and unindicted and together with indicted crime, together with indicted and unindicted co-conspirators, in the the County County of of Fulton Fulton and and crime, and co-conspirators, in of and the and between State of Georgia, on on and StateofGeorgia, between the the 6th 6th dayofDecember 2020 and the 14th 14th day day of day of December 2020 make the intent to to aa with make knowingly to December defraud, to intent the with conspired, unlawfully conspired, 2020, unlawfully defraud, December 2020, knowingly THE 2020 2020 ELECTORS document titled "CERTIFICATE “CERTIFICATE OF OF THE VOTES OF OF THE ELECTORS FROM FROM THE VOTES document titled the as made in such manner that a a other than purports toto made as writing the that manner such in check, a than writing other check, GEORGIA,” writing purports GEORGIA," a writing State electors from have been been made made by by authorityofthe elected and and qualified presidential electors from the the State have qualiﬁed presidential duly elected authority of the duly to utter and deliver deliver said document to such authority, of Georgia, did not of who did not give and to utter and said document to the the authority, and Georgia, who give such Archivist Archivist of of the the United United States; States; above as co-conspirators, as described described above named in And the Defendants Defendants named And the in Count Count 10, 10, acting acting as co-conspirators, as set forth document in ‘and incorporated by by reference reference asiffully forth herein, made said said document in Fulton Fulton County, as if ﬁilly set and incorporated herein, made County, in Fulton to the Archivist of the United States document said Georgia, and uttered and delivered said document to the Archivist of the United States in Fulton uttered and delivered and Georgia, the to the of the the to to effect contrary overt acts effect the object conspiracy, contrary objectofthe conspiracy, were overtactsto which were Georgia, which ‘County, County, Georgia, and laws of said State, lawsofsaid the good order, peace and dignity thereof; thereof; order, State, the dignity good peace 77 kd

PDF Page 79	COUNT 12 of 0f 41 41 COUNT 12 the name name and and behalf citizens of Georgia, do of the citizensofGeorgia, Grand Jurors And the the Grand Jurors aforesaid, aforesaid, inin the behalf ofthe do And and SHAF SHAWN TRESHER MICAH JAMES and accuse DAVID charge and accuse DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, and STILL, ER, charge the offense of FALSE offense of FALSE STATEMENTS STATEMENTS AND AND CATHLEEN with the LATHAM with ALSTON LATHAM CATHLEEN ALSTON concerned for the said and as WRITINGS, 0.C.G.A. § 16-10-20,forthe said accused, individually and as persons O.C.G.A. 16-10-20, accused, WRITINGS, individually persons concerned § in With the and unindicted in the the commission commission of ofaa crime, crime, and together together with unindicted co-conspirators, co-conspirators, in the County of in County of about the or about State of Georgia, on Fulton and and StateofGeorgia, on or the 14th 14th dayofDecember knowingly, willfully, willfully, Fulton 2020, knowingly, day of December 2020, THE VOTES "CERTIFICATE OF OF THE and made and and unlawfully unlawfully made and used used aa false false document document titled titled “CERTIFICATE VOTES OF OF contained the that said said document THE 2020 2020 ELECTORS THE ELECTORS FROM FROM GEORGIA,” with knowledge document contained the GEORGIA," with knowledge that Electors for the elected and THE false false statement, statement, “WE, THE UNDERSIGNED, being the duly elected and qualified Electors for UNDERSIGNED, being "WE, duly qualiﬁed do States of of America of the United United States from the State of Georgia, President and Vice President and Vice President Presidentofthe America from the Stateof Georgia, do the of document within of the Ofﬁce said the the hereby certify the following,” said document being within the jurisdictionofthe Officeof the being following," jurisdiction hereby certify and agencies Ofﬁce of Governor of of Georgia, Georgia SecretaryofState and the the Office of the the Governor Georgia, departments agencies departments and Georgia Secretary of State and the laws of said the and to ofof state contrary to the lawsofsaid State, the good order, peace and dignity thereof; state government, State, dignity thereof; good order, peace government, contrary COUNT 13 0f 41 41 COUNT 13of do the name citizens of Georgia, of the citizensof And the Grand Grand Jurors Andthe Jurors aforesaid, inthe name and and behalf behalf ofthe aforesaid, in Georgia, do RUDOLPH WILLIAM and accuse accuse DONALD charge DONALD JOHN JOHN TRUMP, TRUMP, RUDOLPH WILLIAM LOUIS LOUIS GIULIANI, GIULIANI, charge and GS JOHN RAY STALLIN KENNETH JOHN CHARLES JOHN CHARLES EASTMAN, EASTMAN, KENNETH JOHN CHESEBRO, CHESEBRO, RAY STALLINGS offense of of SMITH III, ROBERT DAVID SMITH III, ROBERT DAVID CHEELEY, and MICHAEL MICHAEL A. A. ROMAN ROMAN with with the the offense CHEELEY, and O.C.G.A. §§ COMMIT FALSE STATEMENTS AND TO COMMIT CONSPIRACY FALSE STATEMENTS AND WRITINGS, WRITINGS, O.C.G.A. 16CONSPIRACY TO §§ 16 and as in the as persons concerned in said accused, 4-8 & 48 & 16-10-20, 16-10-20, for for the the said individually and the commission commission accused, individually persons concermed indicted and unindicted in the ofaa crime, and with of and together with indictedand unindicted co-conspirators, in the CountyofFulton crime, County of Fulton together co-conspirators, of the 6th of 14th day and the and State State of of Georgia, and on and and between between the 6th day December 2020 2020 and the 14th day of day of December Georgia, on December December 2020, 2020, unlawfully unlawfully conspired conspired toto knowingly knowingly and and willfully willfully make make and and use use aa false false THE FROM OF VOTES OF THE 2020 ELECTORS "CERTIFICATE document document titled titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM THE said document document contained with knowledge GEORGIA,” knowledge that that said contained the the false false statement, "WE, THE statement, “WE, GEORGIA," with and Vice President elected Electors for President and the UNDERSIGNED, being the duly elected and qualified Electors for President and Vice President UNDERSIGNED, being duly qualiﬁed said from the State States of of America ofthe United States Americafromthe Stateofof Georgia, do hereby hereby certify the following," following,” said of the United Georgia, do certify the the State and of the the Ofﬁce of the and State of of Secretary the Georgia t he of document Office within jurisdictionofthe the being within jurisdiction document being Georgia Secretary and agencies state government; of Georgia, Ofﬁce of the Governor Officeofthe Governor of Georgia, departments of state agencies of departments and government; above Count 12, as co-conspirators, as described described above And the And the Defendants Defendants named named inin Count co-conspirators, as 12, acting acting as in Fulton document in if fully set and used said document and by reference reference asas iffully set forth forth herein, made and used said Fulton and incorporated herein, made incorporated by to the to effect the were overt acts of the which County, Georgia, which were overt acts to effect the objectofthe conspiracy, contrary to the object conspiracy, contrary County, Georgia, and dignity laws of said State, lawsofsaid the good dignity thereof; thereof; order, peace State, the good order, peace and 78 78

PDF Page 80	COUNT 14 14 of of 41 41 COUNT do citizens of Georgia, do of the citizensofGeorgia, the name And the the Grand aforesaid, inin the name and and behalf behalf ofthe Jurors aforesaid, Grand Jurors And and TRESHER STILL, JAMES SHAFER, MICAH TRESHER SHAWN MICAH and accuse DAVID JAMES STILL, and accuse DAVID charge and SHAFER, SHAWN charge TO ATTEMPT with the offense ofCRIMINAL of CRIMINAL ATTEMPT TO CATHLEEN ALSTON ALSTON LATHAM LATHAM with the offense CATHLEEN the for the O.C.G.A. §§ 16-10-20.1(B)(1), for 164-1 && 16-10-20.1(b)(1), §§ 164-1 COMMIT DOCUMENTS, 0.C.G.A. FALSE DOCUMENTS, FILING FALSE COMMIT FILING and a of as concerned in the commission together and as persons said persons concerned in the commission ofa crime, crime, and together said accused, accused; individually individually and on about the of the in the of Fulton and State or about on or StateofGeorgia, and with Fulton of County the in unindicted co-conspirators, with unindicted Georgia, County co-conspirators, False of the crime with intent to commit False 14th day unlawfully, with intent to commit the crimeofFiling December 2020, of December Filing 14th 2020, unlawfully, day of document titled in the United States States mail Documents, 0.C.G.A. 16-10-20.1(b)(1, placed placed in the United mailaa document titled O.C.G.A. §§ 16-10-20.l(b)(1), Documents, addressed FROM VOTES OF THE 2020 ELECTORS OF THE addressed "CERTIFICATE GEORGIA," “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” 2188 Richard Northern District District ofGeorgia, of Georgia, 2188 toChiefJudge, U.S. District District Court, Court, Northern Richard D. D. Russell Russell to Chief Judge, U.S. GA 30303, GA and U.S. 75 Ted Turner Atlanta, SW, Drive, Turner Ofﬁce Ted 75 Federal Courthouse, U.S. 30303, aa and Federal Office Building Drive, SW, Atlanta, Courthouse, Building O.C.G.A. §§ 16-10-20.1()(1), of Filing False Documents, 0.C.G.A. False Documents, substantial commissionofFiling the commission toward the step toward substantial step 1610-20.1(b)(1), the United a court of and record said document in to intent with States, ‘with intent to knowingly knowingly ﬁle, file, enter,andrecord said document ina courtofthe United States, enter, THE that said false statement, the materially contained the statement, “WE, "WE, THE document contained said document know that reason toto know having reason materially false having and Vice and qualified the duly elected and President Vice President President and for President Electors for duly elected being the UNDERSIGNED, being UNDERSIGNED, qualiﬁed Electors the State of Georgia, States of America from following,” certify the following," United StatesofAmerica hereby certify do hereby of the United the Stateof from the ofthe Georgia, do the of said and to the laws contrary to the lawsofsaid State, the good order, peace and dignity thereof; thereof; State, order, good peace dignity contrary COUNT 15 of 41 41 COUNT 15of do of the citizensofGeorgia, citizens of Georgia, do Jurors aforesaid, Grand Jurors And And the the Grand in the the name name and and behalf behalfofthe aforesaid, in JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, accuse DONALD WILLIAM LOUIS GIULIANI, DONALD JOHN and accuse charge and TRUMP, RUDOLPH charge RAY STALLINGS JOHN KENNETH STALLINGS CHARLES RAY JOHN CHESEBRO, JOHN EASTMAN, KENNETH CHESEBRO, JOHN CHARLES EASTMAN, of offense of and MICHAEL A. ROMAN the offense with the ROMAN with SMITH III, MICHAEL A. DAVID CHEELEY, ROBERT DAVID CHEELEY, and III, ROBERT SMITH 16O.C.G.A. §§ FILING FALSE CONSPIRACY COMMIT FILING FALSE DOCUMENTS, DOCUMENTS, O.C.G.A. §§ 16-48 16-4-8 && 16T0 COMMIT CONSPIRACYTO of and as as persons concerned in said accused, 10-20.1(b)(1), for for the the said individually and persons concerned in the the commission commission of accused, individually 10-20.1(b)(1), of Fulton and the County and unindicted indicted and unindicted co-conspirators, together with with indicted in the Fulton and aa crime, and together County of crime, and co-conspirators, in 14th of and the between the 6th day of December 2020 2020 and the 1th day and between State of Georgia, on StateofGeorgia, on and the 6th dayofDecember day of titled document a to and record titled document a record and enter, file, December knowingly to conspired enter, December 2020, ﬁle, 2020, unlawfully unlawfully conspired knowingly in FROM THE ELECTORS OF 2020 of OF THE VOTES court of GEORGIA,” in aa court "CERTIFICATE “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA," that said said document contained the false materially false the materially the document contained know that reason toto know having reason United States, the United States, having Electors for the elected and THE statement, “WE, THE UNDERSIGNED, being the duly elected and qualified Electors for UNDERSIGNED, being statement, "WE, duly qualiﬁed State of Georgia, of the United of America from Vice President President and and Vice Presidentofthe United States States ofAmerica from the the Stateof do President Georgia, do the hereby certify the following”; following"; hereby certify as described described above Count 14, the Defendants Defendants named And And the named inin Count 14, acting acting asas co-conspirators, above co-conspirators, as States mail said as if fully set and incorporated ‘and incorporated by by reference reference asiffully set forth forth herein, herein, placed placed inin the the United United States mail said of Georgia, 2188 Chief Judge, U.S. U.S. District District Court, addressed to document, toChiefJudge, Court, Northern Northern District District ofGeorgia, 2188 document, addressed Ted Turner Ofﬁce Building 75 Federal Office Richard D. Richard D. Russell Russell Federal Building and and U.S. U.S. Courthouse, 75 Ted Turner Drive, SW, Drive, SW, Courthouse, of the to effect effect the act o Fulton County, an overt act Atlanta, GA GA 30303, 30303, inin Fulton Georgia, which which was wasanovert the object objectofthe Atlanta, County, Georgia, of said the and to the laws conspiracy, contrary to the lawsofsaid State, the good order, peace and dignity thereof; State, dignity thereof; good order, peace conspiracy, contrary 79 79

PDF Page 81	41 COUNT of 41 COUNT l6 16 of ofthe citizensofGeorgia, do And the Grand Jurors aforesaid, in the name and behalf TRESHER STILL with MICAH SHAWN and SHAFER charge and accuse DAVID JAMES the offense of FORGERY IN THE FIRST DEGREE, 0.C.G.A. § 16-9-1(b), for the said accused, individually and as persons concerned in the commission ofa crime, and together with unindicted co-conspirators, in the Countyof Fulton and StateofGeorgia, on or about the 14th dayofDecember 2020, unlawfully and with the intent to defraud, knowingly made adocument titled “RE: NoticeofFillingof Electoral College Vacancy,” a writing other than a check, in such manner that the writing as made purports to have been made by the authorityofthe duly elected and qualified presidential electors from the StateofGeorgia, who did not give such authority, and uttered and delivered said document to the Archivistofthe United States and the Office of the Governorof Georgia, contrary to the lawsofsaid State, the good order, peace and dignity thereof; thereof; And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do accuse DAVID JAMES SHAFER and SHAWN MICAH TRESHER STILL with and charge the offense of FORGERY IN THE FIRST DEGREE, O.C.G.A. § 16-9-1(b), for the said accused, individually and as persons concerned in the commission of a crime, and together with unindicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 14th day of December 2020, unlawfully and with the intent to defraud, knowingly made a document titled "RE: Notice of Filling of Electoral College Vacancy," a writing other than a check, in such manner that the writing as made purports to have been made by the authority of the duly elected and qualified presidential electors from the State of Georgia, who did not give such authority, and uttered and delivered said document to the Archivist of the United States and the Ofﬁce of the Governor of Georgia, contrary to the laws of said State, the good order, peace and dignity 41 COUNT of 41 COUNT 17 17of And the Grand Jurors aforesaid, in the name and behalf ofthe citizensofGeorgia, do and accuse accuse DONALD charge DONALD JOHN JOHN TRUMP, RUDOLPH WILLIAM WILLIAM LOUIS LOUIS GIULIANI, GIULIANI, TRUMP, RUDOLPH charge and STALLINGS JOHN CHESEBRO, CHARLES EASTMAN, JOHN CHARLES JOHN EASTMAN, KENNETH KENNETH JOHN CHESEBRO, RAY RAY STALLINGS with the offense of A. ROMAN of the offense ROMAN with SMITH III, MICHAEL A. and MICHAEL DAVID CHEELEY, ROBERT DAVID III, ROBERT SMITH CHEELEY, and O.C.G.A. §§ TO COMMIT IN THE THE FIRST 16-4-8 CONSPIRACY DEGREE, 0.C.G.A. FIRST DEGREE, FORGERY IN COMMIT FORGERY §§ 16-4-8 CONSPIRACY TO commission of of aa concerned in and as as persons said accused, & 16-9-1(b), 169-1(b), for for the the said accused, individually individually and persons concemed in the the commission & Fulton and and indicted and and nindicted unindicted co-conspirators, with indicted crime, co-conspirators, inin the the County County ofof Fulton and together crime, and together with 14th of and the 2020 on and and between the 6th of December StateofGeorgia, between the 6th day of December 2020 and the 14th day of State of Georgia, on day day intent to with the December unlawfully conspired, conspired, with the intent to defraud, defraud, toto knowingly make aa December 2020, knowingly make 2020, unlawfully a other than of Filling of titled "RE: document titled document “RE: Notice NoticeofFilling of Electoral Electoral College College Vacancy,” a writing than aa Vacancy," writing other the authority been made by the have beenmadeby that the such manner check, in such manner that the writing writing asas made made purports purports toto have authority of of check, in did not who State of electors from the the duly elected and qualified presidential electors from the StateofGeorgia, who did not give elected and the Georgia, give qualiﬁed presidential duly States and and the Archivistofthe Archivist of the United utter and and deliver deliver said said document United States such authority, document toto the and toto utter authority, and such Governor "of the Ofﬁce of the the Officeof the Govemor of Georgia; Georgia; as described described above above named in in Count And the the Defendants Defendants named And Count 16,actingas l6, acting as co-conspirators, coconspirators, as document in if fully set set forth and incorporated by by reference reference asas iffully forth herein, herein, made made said said document in Fulton Fulton County, and incorporated County, States and and the United States Archivist of delivered said said document document to and uttered the the United of the the Archivist to the and delivered uttered and Georgia, Georgia, and acts to effect the were overt in Fulton which Governor of Georgia of the Governorof Ofﬁce Officeofthe in Fulton County, Georgia, which were overt acts to effect the Georgia County, Georgia, and the objectofthe to the the laws laws of of said said State, peace and dignity order, peace State, the good dignity good order, contrary to conspiracy, contrary object of the conspiracy, thereof; thereof; And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do 80 80

PDF Page 82	41 of 41 COUNT COUNT 18 18of And the Grand Jurors aforesaid, in the name and behalf ofthe citizensofGeorgia, do charge and accuse DAVID JAMES SHAFER andSHAWN MICAH TRESHER STILL with said the said for the of FALSE STATEMENTS AND O.C.G.A. §§ 16-10-20, offense of AND WRITINGS, the 16-1020, for FALSE STATEMENTS WRITINGS, O.C.G.A. the offense in the commission commission of With together with and together crime, and ofaa crime, as persons concernedinthe persons concerned and as accused, accused, individually individually and on 14th of or about the State and 14th the about of Fulton or on in the and StateofGeorgia, unindicted the CountyofFulton unindicted co-conspirators, Georgia, County co-conspirators, in and used document made and false docunent used aa false and December made of unlawfully and willfully, knowingly, 2020, December of day 2020, unlawﬁllly willfully, knowingly, day that said document with document said Notice of of Electoral that "RE: knowledge titled College titled “RE: NoticeofFillingofElectoral Vacancy," with knowledge College Vacancy,” Filling of the 2020 2020 SHAFER was JAMES SHAFER statements that Chairmanofthe was Chairman contained the DAVID JAMES that DAVID false statements the false contained of STILL was TRESHER MICAH ‘Georgia Electoral College Meeting and SHAWN MICAH TRESHER STILL was Secretary and SHAWN Electoral Secretary of College Meeting Georgia within the said document the 2020 Georgia Electoral Meeting, said document being being within thejurisdictionof the Electoral College 2020 Georgia the jurisdiction of the College Meeting, Governor of of the Ofﬁce of State and the Officeof the Georgia Secretary of State and the Officeofthe GovemorofGeorgia, departments Office of the Georgia, departments Georgia Secretary and the good of said State, and agenciesofstate ‘and goverment, contrary contrary toto the the laws lawsofsaid State, the peace and order, peace good order, agencies of state government, dignity thereof; dignity thereof; And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER and SHAWN MICAH TRESHER STILL with COUNT COUNT 19 of 41 citizens of Georgia, behalfofthe of the citizensof and behalf in the do And the the Grand Grand Jurors the name name and And Jurors aforesaid, Georgia, do aforesaid, in charge accuse DONALD RUDOLPH WILLIAM WILLIAM LOUIS LOUIS GIULIANI, GIULIANI, and accuse DONALD JOHN JOHN TRUMP, TRUMP, RUDOLPH charge and RAY STALLIN GS JOHN CHARLES EASTMAN, KENNETH KENNETH JOHN JOHN CHESEBRO, RAY STALLINGS CHARLES EASTMAN, JOHN CHESEBRO, with the CHEELEY and SMITH IIT, ROBERT ROBERT DAVID DAVID CHEELEY and MICHAEL MICHAEL A. A. ROMAN ROMAN with the offense offense of of SMITH III, O.C.G.A. §§ 16STATEMENTS AND TO COMMIT CONSPIRACY COMMIT FALSE FALSE STATEMENTS AND WRITINGS, WRITINGS, O.C.G.A. §§ 16CONSPIRACY TO concerned in commission and as as persons for the & 16-10-20, said accused, 4-8 16-10-20, for the said accused, individually persons concerned in the the commission 4-8 & individually and in the unindicted CountyofFulton the and with indicted and in of a co-conspirators, unindicted and indicted with together of a crime, County of Fulton crime, and together co-conspirators, and the 14th day of day of and between on and 2020 and the 14th and Stateof State of Georgia, December 2020 6th dayof the 6th between the and day 0f December Georgia, on make and a false and use false a to use and make willfully December and knowingly to conspired unlawfully 2020, December 2020, unlawfully conspired knowingly willfully said document tiled “RE: NoticeofFillingof Electoral College Vacancy,” with with knowledge that said "RE: Notice of Filling of Electoral document titled knowledge that College Vacancy," the Chairman of SHAF ER was contained the false statements document contained the false statements that that DAVID DAVID JAMES JAMES SHAFER was Chairman ofthe document TRESHER STILL was SHAWN MICAH Electoral and 2020 Georgia Georgia Electoral College Meeting and SHAWN MICAH TRESHER STILL was 2020 College Meeting document being said document of the 2020 Electoral Secretaryofthe 2020 Georgia Electoral College Meeting, said being within within the the College Meeting, Secretary Georgia the Governor of the Ofﬁce of and of State of Governor of of the Ofﬁce the Officeofthe the and State Officeof the Georgia jurisdictionofthe Secretary Georgia Secretaryof jurisdiction and agencies Georgia, departments of state state government; government; agencies of Georgia, departments and described above above And the Defendants named inin Count Count 18, as co-conspirators, co-conspirators, asas described And the Defendants named l8, acting acting as said document made and and used used said document in if fully set and incorporated ‘and incorporated by by reference reference asasiffully set forth forth herein, herein, made in Fulton Fulton to of the the to eﬁect the which were overt acts County, Georgia, which were overt acts to effect the objectofthe conspiracy, contrary to the object conspiracy, contrary County, Georgia, of said State, laws lawsofsaid the good order, peace peace and and dignity thereof; State, the dignity thereof; good order, 81 81 19 0f 41 '

PDF Page 83	0f 41 41 COUNT 20 COUNT 20of do of the citizensofGeorgia, citizens of Georgia, do And the the Grand Jurors aforesaid, in the the name name and and behalf behalf ofthe And Grand Jurors aforesaid, in the offense of CRIMINAL LEE with charge and accuse STEPHEN CLIFFGARD LEE with the offense of CRIMINAL and accuse STEPHEN CLIFFGARD charge 16-10ATTEMPT TO TO COMMIT INFLUENCING WITNESSES, 0.C.G.A. §§ §§ 16-4-1 16-4-1 && 16-10ATTEMPT COMMIT INFLUENCING WITNESSES, O.C.G.A. 93(b)(1)(A), for the said accused, in the CountyofFulton and State of Georgia, on the 14th day day of on the 14th of Fulton and State the said in the for accused, County Georgia, 93(b)(1)(A), of December 2020, unlawfully, vith intent to commit the crimeof Influencing Witnesses, crime of 0f December 2020, unlawfully, with intent to commit the Inﬂuencing'Witnesses, 0.C.G.A. 16-10-93(b)(1)(A), traveled traveled toto the the home homeofof Ruby Ruby Freeman, Freeman, 2a Fulton Fulton County, O.C.G.A. §§ l6-lO-93(b)(l)(A), County, Georgia, election worker, and spoke to her neighbor, a substantial step toward the commission commission of of a substantial toward the step Georgia, election worker, and spoke to her neighbor, with intent intent to Influencing Witnesses, Witnesses, O.C.G.A. 16-10-93(b)(1)(A), to knowingly knowingly engage in O.C.G.A. §§ 16-10-93 engage in (b)(l)(A), with Inﬂuencing and with intent to to offer her misleading conduct toward Ruby Freeman, by purporting to offer her help, and with intent to conduct toward help, misleading Ruby Freeman, by purporting events influence her testimony inin an an official proceeding inin Fulton Fulton County, concerning events inﬂuence her testimony ofﬁcial proceeding Counw, Georgia, Georgia, concerning election in said date atat State in the November 3,3, 2020, presidential election in Georgia, said date being aa State Farm Farm Arena Arena in the November 2020, presidential being Georgia, of said State, ‘material elementofthe offense, contrary to the the laws lawsofsaid the good peace and and material element of the offense, State, the order, peace good order, contrary to dignity thereof, dignity thereof; 21 of 0f 41 41 COUNT COUNT 21 ‘And the Grand Jurors aforesaid, in the name and behalf ofthe citizens of Georgia, do charge and accuse STEPHEN CLIFFGARD LEE with the offense of CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES, 0.C.G.A. §§ 16-4-1 & 16-1093(b)(1)(A), for the said accused, in the CountyofFulton and Stateof Georgia, on the 15th day of December 2020, unlawfully, with intent to commit the crime of Influencing Witnesses, O.C.GA. § 16-10-93(b)(1)(A), traveled to the homeofRuby Freeman, a Fulton County, Georgia, worker, and and knocked knocked on her door, substantial step step toward toward the of a substantial the commission commission of on her election worker, door, a Georgia, election Influencing Witnesses, Witnesses, 0.C.G.A. 16-10-93(b)(1)(A), with intent intent toto knowingly in O.C.G.A. §§ 16-10-93 knowingly engage engage in (b)(l)(A), with Inﬂuencing misleading conduct toward Ruby Freeman, by purporting to offer her help, and with intent toto offer with to her and intent conduct toward help, misleading Ruby Freeman, by purporting influence her her testimony in an proceeding inin Fulton Georgia, concerning Fulton County, events inﬂuence an official ofﬁcial proceeding County, Georgia, concerning events testimony in election in said date at State Farm Arena Arena inin the 3, 2020, presidential election in Georgia, said date being aa at State Farm the November November 3, 2020, presidential being Georgia, and material elementofthe offense, contrary to the the lawsofsaid the good peace and laws of said State, element of the offense, material State, the order, peace good order, contrary to dignity thereof; dignity thereof; And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse STEPHEN CLIFFGARD LEE with the offense of CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES, O.C.G.A. §§ 16-4-1 & 161093(b)(1)(A), for the said accused, in the County of Fulton and State of Georgia, on the 15th day of December 2020, unlawfully, with intent to commit the crime of Inﬂuencing Witnesses, O.C.G.A. § l6-lO-93(b)(l)(A), traveled to the home of Ruby Freeman, a Fulton County, 82 82

PDF Page 84	0f 41 COUNT COUNT 22 22041 and behalf of the of Georgia, do And the the Grand name andbehalfof the citizens citizensofGeorgia, do in the the name And Grand Jurors Jurors aforesaid, aforesaid, in ATTEMPT CRIMINALATTEMPT with the offense of CRIMINAL of offense the CLARK with BOSSERT CLARK BOSSERT and accuse JEFFREY JEFFREY accuse and charge Charge 16-10-20, & 16-10-20, 16-4-1 & AND WRITINGS, O.C.G.A. §§ WRITINGS, O.C.G.A. STATEMENTS AND TO COMMIT FALSE STATEMENTS COMMIT FALSE TO §§ 16-4-1 and a for the the said individually and as a person concerned in the commission of a crime, and in of as a concerned the commission and for said accused, crime, accused, individually person and on together with unindicted co-conspirators, in the County of Fultonand Stateof Georgia, on and of and State of Fulton Georgia, together with unindicted co-conspirators, in the County between the the 28th 28th day of December 2020 and the 2nd dayofJanuary 2021, unlawfully, With with 2020 and the 2nd of of December between 2021, unlawfully, day January day intent to commit the crimeofFalse Statements and Writings, 0.C.G.A. § 16-10-20, knowingly Statements and O.C.G.A. False intent to commit the crime of Writings, § 16-1020, knowingly and willfully willfullymadea false writing writing and knowing the the same to contain contain the the false false statement statement and document document knowing same to and made a false concerns that that the United States Department of Justicehad “identified significant concerns that may have of Justice had "identiﬁed that the United States Department may have signiﬁcant said the Stateof State of Georgia," impacted the the outcome of the the election in multiple including the Georgia,” said election in outcome of State's, including multiple States, impacted and the the of State of the Ofﬁce of statement being within thejurisdictionof the Office of the Georgia Secretaryof State and the statement within the Georgia Secretary jurisdiction being and county and of state government, and county agenciesofstate and agencies departments and of Investigation, Investigation, departments Bureau of Georgia Bureau government, and Georgia city law enforcement agencies; law enforcement city agencies; And, on or or about about the 28th day December 2020, the said e-mail t0to of December said accusedsentan accused sent an e-mail the 28th 2020, the And, on day of and Acting States Deputy Acting United States Attomey General Rosen and Acting United United States Deputy Attomey General Jeffrey States Attorney Attorney Jeffrey Rosen Acting United and document authorization to send said ‘General Richard Donoghue Donoghue and and requested requested authorization to send false writing and document said false General Richard writing House of toto Georgia Kemp, Speakerofthe of Representatives Representatives David David Brian Kemp, Governor Brian Georgia House Speaker of the Georgia Georgia Governor Ralston, and President President Pro the Georgia Senate Butch Butch Miller; Pro Temporeof Miller; Georgia Senate Ralston, and Tempore of the the said 2nd dayof accused met And, on oror about the 2nd said accused met with with Acting Acting United United about the 2021, the And, on January 2021, day of January and United States General Rosen States Attomey General Jeffrey Rosen and Acting United States Deputy Attomey General General States Attorney Acting Jeffrey Deputy Attorney send said and document document to Richard Donoghue and requested authorization authorization toto send said false false writing writing and to and requested Richard Donoghue Georgia Govemor Brian Kemp, Speaker ofthe Georgia House of Representatives David Ralston, the David of House of Brian Governor Ralston, Georgia Representatives Georgia Kemp, Speaker and Senate Butch Butch Miller; Miller; and President Pro Temporeofthe President Pro Georgia Senate Tempore of the Georgia Statements And said said acts constituted substantial toward the the commissionofFalse substantial steps commission of False Statements acts constituted And steps toward and said conduct committed outside the state of and 0.C.G.A. § 16-10-20, and said conduct committed outside the stateof Georgia. and Writings, O.C.G.A. Georgia § 16-10-20, Writings, constitutedanattempt to commitacrime within the state o fGeorgia, pursuant to O.C.G.A. 17constituted an attempt to commit a crime within the state of Georgia, pursuant to O.C.G.A. §§ l7the good of said State, 2-1(b)(2), contrary to the the laws lawsofsaid peace and and dignity dignity thereof; thereof; order, peace State, the good order, contrary to 2-1(b)(2), 8 83

PDF Page 85	COUNT 23 of 41 41 COUNT 23of do of Georgia, do citizensofGeorgia, behalfofthe and behalf of the citizens name and the name in the Jurors aforesaid, Grand Jurors the Grand And the And aforesaid, in SMITH RAY STALLINGS STALLINGS SMITH LOUIS GIULIANI, WILLIAM LOUIS accuse RUDOLPH RUDOLPH WILLIAM and accuse charge GIULIANI, RAY charge and OF VIOLATION the offense offense of SOLICITATION OF VIOLATION of SOLICITATION with the CHEELEY with and ROBERT DAVID CHEELEY ROBERT DAVID III, and III, said accused, the said for the O.C.G.A. §§ 16-10-1, for 16-4-7 && 16101, §§ 16-4-7 PUBLIC OFFICER, OF OATH BY BY PUBLIC accused, OF OATH OFFICER, O.C.G.A. with individually and as persons concemed in the commission of a crime, and together with in the commission of a and crime, together individually and as persons concerned 0f the 30th unindicted co-conspirators, in the County ofFulton and StateofGeorgia, 30th day on the the of Fulton and State of in unindicted day of Georgia, on County co-conspirators, then ofﬁcers December 2020, unlawfully solicited, requested, and importuned certain public officers then and certain December 2020, unlawfully solicited, requested, public importuned serving as elected membersofthe Georgia Senate and present at a Senate Judiciary the Senate and at a Senate of members as elected Judiciary Georgia present serving identity isis whose identity 8, Individual co-conspirator unindicted Individual unindicted including meeting, Subcommittee Subcommittee meeting, including 8, whose co-conspirator Rhett, Michael Rhett, Ligon, Michael Bill Heath,William Beach, Bill Brandon Beach, Senators Brandon Grand Jury, the Grand to the known to known Heath, William Ligon, Jury, Senators by Oath of Oath of Violation ofViolation offense the offense of felony the in conduct constituting to conduct in engage Blake to Tillery, and Blake and by constituting felony Tillery, engage State the State: from the electors from presidential electors appointing presidential O.C.G.A. §§ 16-10-1, 16-10-1, by Public Officer, 0.C.G.A. Public Officer, by unlawfully unlawfully appointing as of said intentional violation of the terms of the oath of in willful and intentional violationofthe termsofthe oath of said persons as and in willful of Georgia, persons Georgia, material being aamaterial date being said persons said conduct, said date in said persons engage with intent that said intent that law, with by law, prescribed by conduct, said engage in prescribed dignity and and peace laws of order, good to the said the the Stat, said of laws the element to contrary the offense, of the element of dignity State, offense, contrary good order, peace thereof; thereof; COUNT 24 24 of41 COUNT 0f 41 do of Georgia, do and behalf of the citizens And the the Grand in the the name name and behalf ofthe citizensofGeorgia, Grand Jurors Jurors aforesaid, And aforesaid, in of FALSE with the oﬁense WILLIAM LOUIS GIULIANI charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI with the offense of FALSE and accuse RUDOLPH charge County the County in the said accused, the said for the O.C.G.A. §§ 16-10-20, 16-10-20, for AND WRITINGS, WRITINGS, O.C.G.A. STATEMENTS AND STATEMENTS accused, in on or December of of Fulton Fulton and or about about the the 30th 30th day of December 2020, knowingly, and StateofGeorgia, State of Georgia, on of 2020, knowingly, day willfully, and unlawfully made made atat least least oneofthe following false false statements and representations one of the following statements and and unlawfully representations willfully, to members membersofthe Senate present at a Senate Judiciary Subcommittee meeting: at a Senate Subcommittee Senate of the Georgia to meeting: Judiciary Georgia present election workers workers fraudulently fraudulently counted certain ballots as five five ballots as as many counted certain l.1. That That Fulton Fulton County many as County election times atat State Farm Arena Arena on November 3,3, 2020; 2020; on November State Farm times in election in presidential election November 3,3, 2020, the November illegally inin the voted illegally felons voted 2,560 felons That 2,560 2.2. That 2020, presidential Georgia; Georgia; 3.3. That 10,315 dead dead people people voted voted inintheNovember 3, 2020, presidential election election inin Georgia; Georgia; the November 3, That 10,315 2020, presidential and State and said being within within the thejurisdictionofthe of State Office of the the Georgia statements being said statements Secretary of Georgia Secretary jurisdiction of the Officeof and county and agenciesofstate of Investigation, the Bureauof the Georgia county agencies of state government, government, and Investigation, departments departments and Georgia Bureau and city law enforcement agencies, contrary to the lawsofsaid State, the good order, peace and the to laws of said the law enforcement and State, agencies, contrary good order, peace and city dignity thereof; thereof; dignity 8 84

PDF Page 86	25 of 0f 41 41 COUNT 25 COUNT citizens of Georgia, do of the citizensofGeorgia, the name and behalf And the Grand Jurors Jurors aforesaid, in the name and behalf ofthe do the Grand And aforesaid, in STATEMENTS of FALSE offense SMITH III with the RAY STALLINGS charge and accuse RAY STALLINGS SMITH IIT with the offense ofFALSE STATEMENTS and accuse charge of Fulton and said accused, AND WRITINGS, O.C.G.A. §§ 16-10-20, for the the said in the the County CountyofFulton and AND accused, in 16-10-20, for WRITINGS, O.C.G.A. and the 30th 30th day of December 2020, about the StateofGeorgia, on or or about day ofDecember 2020, knowingly, willfully, and State of Georgia, on knowingly, willfully, of and representations of the following false statements statements and members of representations toto members following false oneofthe least one made atat least unlawfully made unlawfully Senate Judiciary Subcommittee meeting: Senate present the Georgia present atat aa Senate the meeting: Judiciary Subcommittee Georgia Senate office had had General Counsel Counsel Ryan Germany stated stated that that his his office l.1. That That Georgia Ryan Germany Georgia SecretaryofState Secretary of State General November who voted in the sent to 8,000 people who voted illegally in the November 3, 2020, presidential letters to sent letters 3, 2020, presidential 8,000 people illegally them not not to to vote and told election told them vote inin the the January January $,5, 2021, runoffelection; election and election; 2021, runoff 90% accuracy of State admitted “that "that they That the 2. That the Georgia State admitted they had had aa 90% rate” inin the the 2. accuracy rate" Secretary of Georgia Secretary that's not a 10% that "there's still not that's election and margin 10% stila November “there’s that and election presidential 2020, 3, November 3, 2020, presidential margin accurate”; accurate"; within the of the Office of said being within thejurisdiction the Office of the the Georgia Georgia Secretary of State State and and said statements statements being Secretary of jurisdiction of and of state of and Bureau the Georgia Bureauof Investigation, departments and agenciesofstate government, and county the county government, agencies Investigation, departments Georgia and of said State, enforcement agencies, and law enforcement agencies, contrary to the the laws lawsofsaid the good order, peace peace and and city State, the good order, contrary to city law dignity thereof; dignity thereof; 41 26 of 41 COUNT 26of COUNT do citizens of Georgia, do the name of the citizensofGeorgia, Grand Jurors Jurors aforesaid,in And the the Grand name and and behalf behalf ofthe And aforesaid, in the STATEMENTS of FALSE STATEMENTS ROBERT DAVID with the accuse ROBERT CHEELEY with charge DAVID CHEELEY the offense offenseofFALSE and accuse charge and and in the O.C.G.A. for the said AND WRITINGS, 0.C.G.A. § 16-10-20, for the said accused, in the Countyofof Fulton Fulton and AND accused, WRITINGS, County § 16-10-20, and on or about the 30th day of December 2020, State of Georgia, on StateofGeorgia, or about the 30th knowingly, willfully, willfully, and 2020, knowingly, day ofDecember to members at least one of the false statements and made unlawfully made at least one ofthe following false statements and representations members of of following representationsto unlawfully at a Senate Senate Subcommittee the the Georgia meeting: Judiciary Subcommittee meeting; Georgia Senate present present at a Senate Judiciary late in in the at State were told and media media at State Farm Arenawere 1. That poll watchers watchers and FarmArena told lat the evening of That poll l. evening of next and to until the to morning and November the next morning being suspended was being count was vote count the vote that the 2020, that November 3,3, 2020, suspended until of "a watermain because home 0 home because of“a major watermain break’; break"; major go same ballots Arena “voted” "voted" the "over election workers State Farm 2. That Fulton 2. That Fulton County workers atat State Farm Arena the same ballots “over County election on November and over and over again” 3,3, 2020; 2020; again" on November of State and within the the jurisdiction Office of said statements statements being said being within jurisdiction of of the the Office of the the Georgia Georgia Secretary State and Secretary of and county and agencies of state government, of Investigation, the the Georgia Bureauof Investigation, departments departments and agenciesofstate county government, and Georgia Bureau the and to the laws of said law enforcement and and city law enforcement agencies, contrary to the lawsofsaid State, the good order, peace State, good order, peace and. agencies, contrary city dignity thereof; thereof; dignity 85 85

PDF Page 87	41 COUNT 27of COUNT 27 of 41 do ‘And the Grand Grand Jurors Jurors aforesaid, aforesaid, inin the name and and behalf behalf ofthe of the citizensofGeorgia, citizens of Georgia, do And the the name the CHARLES EASTMAN with charge and accuse DONALD JOHN TRUMP and JOHN CHARLES EASTMAN with the and accuse DONALD J OIﬂ'I TRUMP and JOHN charge for the said accused, offenseofFILING FALSE DOCUMENTS, 16-10-20.1(b)(1), for the said O.C.G.A. §§ 16-10-20.1(b)(1), offense of FILING FALSE accused, DOCUMENTS, 0.C.G.A. a and with and as of individually and as persons concerned in the commission of a crime, and together with concerned in the commission crime, together individually persons about the of Fulton and State of unindicted co-conspirators, in the the County CountyofFulton and State of Georgia, on or or about the 3lst 31st unindicted Georgia, on co-conspirators, in dayof December 2020, knowingly and unlawfully filed a document tiled “VERIFIED titled "VERIFIED a document December and ﬁled of 2020, knowingly unlawfully day COMPLAINT EMERGENCY INJUNCTIVE INJUNCTIVE AND AND DECLARATORY DECLARATORY RELIEF” the RELIEF" in in the FOR EMERGENCY COMPLAINT FOR States District Court for for the matterof Kemp, Case 1:20-cv-05310-MHC, inin the the United United States District Court the of Trump v. Kemp, Case 1:20-cv05310MHC, matter Trump v. to know that said Northen District District ofGeorgia, United States, having reason to know that said of Georgia, aa courtofthe reason Northern court of the United States, having statements: document contained following materially materially false false statements: at least least oneofthe document contained at one of the following "as many as 2,506 an uncompleted 1l.. That many as 2,506 felons felons with with an uncompleted sentence" sentence” voted voted illegally illegally inin the the That “as in November 3,3, 2020, 2020, presidential election in Georgia; November election Georgia; presidential 2.2 That That “at least 66,247 underage” people people voted November 3,3, 2020, the November in the "at least voted illegally 2020, 66,247 underage" illegally in election in presidential election in Georgia; Georgia; presidential 3.3 That That “at least 2,423 2,423 individuals” the November November 3,3, 2020, 2020, presidential presidential in the "at least voted illegally individuals" voted illegally in election inin Georgia not listed in the the State's havingbeenregistered records as as having been registered State's records election "who were were not listed in Georgia “who to to vote"; vote”; 4.4 That least 1,043 1,043 individuals" individuals” voted voted illegally illegally inin the the N0vember November 3,3, 2020, 2020, presidential presidential "at least That “at ofﬁce box as their election “who had illegally registered toto vote vote using using aa postal postal office boxastheir election "who had illegally registered habitation”; habitation"; 5. That “as many many asas 10,315 10,315 or or more" more” dead in the the November November 3,3, 2020, 2020, That "as dead people voted in people voted election in presidential election in Georgia; Georgia; presidential watchers and and 6. That misinformation was wasusedto instruct Republican poll watchers 6 That “[d]eliberate used to instruct Republican poll "[d]eliberate misinformation on ‘membersofof the the press press toto leave leave the the premises premises for night atat approximately approximately 10:00 10:00 pm. p.m. on members for the the night Fulton 2020" at State Farm Arena in November 3,3, 2020” at State Farm Arena in Fulton County, Georgia; November County, Georgia; of said State, and dignity contrarytoto the the laws lawsofsaid the good thereof; State, the order, peace dignity thereof; contrary good order, peace and o 86 86

PDF Page 88	of 41 28 of41 COUNT COUNT 28 of Georgia, do do behalfofthe of the citizens and behalf in the And the Grand Jurors And the Grand the name name and citizensofGeorgia, Jurors aforesaid, aforesaid, in the TRUMP and MARK RANDALL with the MEADOWS with RANDALL MEADOWS JOHN TRUMPandMARK DONALD JOHN accuse DONALD and accuse charge charge and O.C.G.A. OATH BY PUBLIC OF O.C.G.A. of OF VIOLATION OFFICER, PUBLIC offense SOLICITATION BY OATH OF OFFICER, offense ofSOLICITATION OF VIOLATION concerned in in the and as the said accused, persons concemed as persons individually and accused, individually the said for the 16-10-1, for 164-7 && 16-10-1, §§ §§ 16-4-7 Fulton in the of with unindicted of a and CountyofFulton the in commission co-conspirators, unindicted with together crime, and together County commission ofa crime, co-conspirators, 2nd dayof requested, and State of Georgia, on on or or about unlawfully solicited, 2021, unlawfully solicited, requested, the 2nd about the January 2021, and StateofGeorgia, day of January to a Brad and importuned Georgia SecretaryofState Brad Raffensperger, public officer, to engage in of State and ofﬁcer, engage in Raffensperger, public importuned Georgia Secretary l6Public O.C.G.A. conduct constituting of Oath Oath by by Public Officer, the felony offense of Violation of conduct Officer, 0.C.G.A. §§ 16constituting the felony offenseofViolation otherwise unlawfully and otherwise 10-1, by by unlawfully unlawfully altering, unlawfully adjusting, unlawfully inﬂuencing influencing the the 10-1, adjusting, and altering, unlawfully in election November for the electors for certiﬁed for presidential certified returns returns for presidential electors the November 3,3, 2020, 2020, presidential presidential election in of said person as prescribed of the oath the terms prescribed of in willful and intentional violation oathofsaid the termsof violationofthe intentional and willful in Georgia, person as Georgia, to the laws of said the in said State, the intent lawsofsaid said person person engage State, that said conduct, contrary with intent that law, with by contrary to the engage in said conduct, by law, and dignity ‘200d dignity thereof; thereof; order, peace good order, peace and 87 87

PDF Page 89	COUNT 29 29 of 41 of 41 COUNT ofthe citizensofGeorgia, do And the Grand Jurors aforesaid, in the name and behalf charge and accuse DONALD JOHN TRUMP with the offense of FALSE STATEMENTS AND WRITINGS, 0.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and Stateof Georgia, on or about the 2nd day of January 2021, knowingly, willfully, and unlawfully made at leastoneofthe following false statements and representations to Georgia Secretary of State Brad Raffensperger, Georgia Deputy Secretaryof State Jordan Fuchs, and Georgia Secretary of State General Counsel Ryan Germany: rolls the rolls into the mysteriously into dropped mysteriously were dropped ballots were 300,000 ballots to 300,000 to 250,000 1. from 250,000 That anywhere 1. That anywhere from election in inin the the November November 3,3, 2020, presidential election in Georgia; 2020, presidential Georgia; 2.2. That thousandsofpeople attempted toto vote vote inin the the November November3,3, 2020, presidential That thousands of people attempted 2020, presidential in cast in election and were told they could not because a ballot had already been cast could not because a ballot had told in Georgia and were election in already been they Georgia their name; their name; 3.3. That 4,502 people people voted voted inin the the November November 3,3, 2020, election inin Georgia who That 4,502 2020, presidential Georgia who presidential election ‘were not on the voter voter registration registration list; list; were not on the who in Georgia 4. That 904 people people voted in the the November November 3,3, 2020, presidential election election in 4. That 904 voted in 2020, presidential Georgia who a oﬁice were registered at an address that was a post office box; that was address were registered at an box; post 5. That Ruby Freeman Freemanwas professional vote vote scammer scammer and and aa known known political operative; 5. That Ruby was aa professional political operative; 6. That “That Ruby Ruby Freeman, her daughter, were responsible responsible for for fraudulently fraudulently awarding and others others were 6. awarding Freeman, her daughter, and atat least least 18,000 18,000 ballots ballots toJoseph Biden atat State Arena inin the the November 3, 2020, State Farm Farm Arena R. Biden November 3, to Joseph R. 2020, election in presidential election in Georgia; Georgia; presidential November 3, 7. That That elose people voted voted inin the the November 2020, presidential presidential election election inin close to to 5,000 dead people 7. 3, 2020, 5,000 dead Georgia; Georgia; Detroit; election inin Detroit; November 3, presidential election the November 8. That 139% of people voted voted inin the 139%ofpeople 3, 2020, 2020, presidential 8. That in the the numberof number of people 9.9. That more votes votes were were recorded recorded than thanthe people who who voted votedinthe That 200,000 200,000 more ‘November 3, 2020, in Pennsylvania; Pennsylvania; election in November 3, 2020, presidential presidential election in election in presidential election November 3, the November of dead people voted inin the 10. That thousands people voted thousandsofdead 10. That 3, 2020, 2020, presidential Michigan; Michigan; 11. Freeman stuffed the ballot boxes; ballot boxes; ll. That That Ruby stuffed the Ruby Freeman 12. hundredsof thousandsofballots had been been “dumped” Fulton County and into Fulton of ballots had That hundreds of thousands 12. That "dumped" into County and another county adjacent to Fulton County in the November 3, 2020, presidential in the election November Fulton to another county 3, 2020, presidential election County adjacent in Georgia; Georgia; in And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 2nd day of January 2021, knowingly, willfully, and unlawfully made 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: 88 88

PDF Page 90	votes; 400,000 votes; by 400,000 in Georgia presidential election election in 2020, presidential the November November 3,3, 2020, 13. That That he won the he won 13. Georgia by and SecretaryofState of State and thejurisdictionofthe Ofﬁce of the Georgia within the being within said said statements statements being Georgia Secretary jurisdiction of the Officeofthe to and agenciesofstate Investigation, departments the Bureau of Investigation, the Georgia contrary to agencies of state government, government, contrary departments and Georgia Bureauof and the lawsofsaid State, the good order, peace and dignity thereof; the laws of said State, the good order, peace dignity thereof; COUNT of 41 41 COUNT 30 30 of do of Georgia, Georgia, do citizens of and behalfof of the the citizens name andbehalf Jurors aforesaid, the name in the And Grand Jurors the Grand And the aforesaid, in PRESCOTT PRESCOTT CLIFFGARD HARRISON WILLIAM WILLIAM HARRISON LEE, STEPHEN CLIFFGARD and accuse STEPHEN accuse and charge LEE, charge FLOYD, and and TREVIAN KUTTI with with the the offense COMMIT ofCONSPIRACY offense of TO COMMIT CONSPIRACY TO C. KUTTI TREVIAN C. FLOYD, SOLICITATION FALSE STATEMENTS O.C.G.A. §§ AND WRITINGS, WRITINGS, 0.C.G.A. 16-4-8, 16-416-4STATEMENTS AND SOLICITATION OF OF FALSE §§ 16-4-8, of of commission the in concerned commission as persons and as individually and said accused, the said for the 16-10-20, for 7,7, && 16-10-20, accused, individually persons concerned in the State of a crime, together with unindicted co-conspirators, in the the Countyof Fulton and and State of with unindicted a and together coconspirators, in County of Fulton crime, and and request, solicit, to conspired to unlawfully 4th dayof the 4th or about on or about the Georgia, on 2021, unlawfully conspired solicit, request, and January 2021, day of January Georgia, in conduct conduct worker,toto engage election worker, County, Georgia, Fulton County, Freeman, aa Fulton importune Ruby engage in Georgia, election Ruby Freeman, importune by. 16-10-20, § 0.C.G.A. Statements and O.C.G.A. Writings, and of False Statements offense of False felony offense the felony constituting § 16-10-20, by Writings, constituting the State events atat State and representation false statement statement and representation concerning and willfully making aa false willfully making knowingly and concerning events knowingly and and statement statement said election in said Georgia, in election presidential Arena in the November 2020, 3, Farm Farm Arena in the November 3, 2020, presidential Georgia, and representation being within thejurisdictionof the Officeofthe Georgia Secretary of of State State and the of Ofﬁce of the within the Georgia Secretary jurisdiction representation being and the Georgia Georgia Bureau BureauofInvestigation, departments and goverment, and county and agenciesofstate of state the of Investigation, departments county agencies government, and and law enforcement with intent intent that that said said person person engage in said said conduct; and city enforcement agencies, conduct; and engage in agencies, with city law a telephone call TREVIAN C. KUTTI KUTTItraveledto Fulton County, County, Georgia, Georgia, and placedatelephone call toto Ruby Ruby and placed traveled to Fulton TREVIAN C. of the which were were overt effect the Freeman while in Fulton Fulton County, overt acts to effect the object objectofthe acts to while in Freeman Georgia, which County, Georgia, said the and ‘conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof; laws of to the thereof; State, dignity good order, peace conspiracy, contrary COUNT 31of 31 of 41 41 COUNT do And the Grand Jurors aforesaid, the name behalf ofthe in the name and of the citizensofGeorgia, citizens of Georgia, do and behalf And the Grand Jurors aforesaid, in charge and accuse accuse STEPHEN LEE, HARRISON HARRISON WILLIAM PRESCOTT WILLIAM PRESCOTT CLIFFGARD LEE, STEPHEN CLIFFGARD charge and with the offense of C. KUTTI FLOYD and KUTTI with the offense of INFLUENCING INFLUENCING WITNESSES, FLOYD and TREVIAN TREVIAN C. WITNESSES, and as concerned inin said accused, as persons individually and the said for the O.C.G.A. §§ 1610-93(b)(1)(A), 16-10-93(b)(1)(A), for 0.C.G.A. accused, individually persons concerned in the the commission crime, and and together together with with unindicted unindicted co-conspirators, the Countyof Fulton the commission of of aa crime, County of Fulton co-conspirators, in of and the 4th and State of Georgia, onor about the 4th dayofJanuary 2021, knowingly and unlawfully and State of Georgia, on or about unlawfully day January 2021, knowingly engaged in misleading conduct toward Ruby Freeman, a Fulton County, Georgia, election election a Fulton conduct toward in Freeman, Georgia, Ruby County, engaged misleading intent to and with worker, by stating that she neededprotectionand by purporting to offer her help, with intent to to her needed offer she that by purporting help, worker, by stating protection events Georgia, concerning County, Georgia, Fulton County, in Fulton an official official proceeding testimony inin an her testimony inﬂuence influence her concerning events proceeding in the election in atat State Farm Arena Arena inin the the November 2020, presidential election in Georgia, to the November 3, State Farm 3, 2020, presidential contrary to Georgia, contrary and dignity lawsofsaid State, the peace and thereof; the good laws of said State, order, peace dignity thereof; good order, 89 89

PDF Page 91	COUNT 32 of 41 COUNT 32 of 41 do Georgia, do of Georgia, citizens of the citizens and behalf of the name andbehalfof the name in the Jurors aforesaid, the Grand Grand Jurors And And the aforesaid, in LATHAM, ALSTON LATHAM, CATHLEEN ALSTON SIDNEY KATHERINE KATHERINE POWELL, and accuse accuse SIDNEY charge POWELL, CATHLEEN charge and TO of CONSPIRACY TO with the offense offenseofCONSPIRACY the and MISTY HANIPTON with HAMPTON HALL, and MISTY GRAHAM HALL, SCOTT GRAHAM SCOTT said accused, the said for the O.C.G.A. §§ 21-2-603 && 21-2-566, accused, ELECTION FRAUD, COMMIT ELECTION COMMIT 21-2-566, for FRAUD, 0.C.G.A. §§ 21-2-603 with with and andtogether in the commission of a crime, a of concerned commission as the in and concemed persons individually and as persons crime, together individually Ist the 1st between the and between on and of Georgia, Stateof of Fulton and and State CountyofFulton the County unindicted co-conspirators, co-conspirators, inin the unindicted Georgia, on to and agreed conspired and unlawfully conspired 2020 and and the 7th dayof the 7th December 2020 dayof agreed to 2021, unlawfully day of January January 2021, day of December of Georgia; the State machines in StateofGeorgia; ballot markers and tabulating in the with electronic electronic ballot tabulating machines markers and tamper with willfully willfully tamper SullivanStrickler with SullivanStrickler into aa contract contract with entered into POWELL entered KATHERINE POWELL SIDNEY KATHERINE And And SIDNEY County, Fulton County, in Fulton LLC in to SullivanStrickler delivered aa payment SullivanStrickler LLC Fulton County, in Fulton LLC LLC in payment to Georgia, delivered County, Georgia, Fulton Georgia, County, Georgia, from Fulton County, caused employees travel from LLC toto travel and caused SullivanStrickler LLC of SullivanStrickler Georgia, employees of Georgia, and ballot ballot electronic electronic said with said tampering with the of purposeofwillfully the for for Georgia, to Coffee to Coffee County, purpose willfully tampering County, Georgia, the conspiracy; of the the object to effect effect the were overt overt acts acts to which were machines, which tabulating machines, markers and tabulating ‘markers and conspiracy; object of MISTY and MISTY HALL, and GRAHAM HALL, SCOTT GRAHAM LATHAM, SCOTT ALSTON LATHAM, And CATHLEEN CATHLEEN ALSTON And willfully LLC inin willfully SullivanStrickler LLC of SullivanStrickler and encouraged HAMPTON HAMPTON aided, abetted, and aided, abetted, encouraged employees employees of Coffee the County inside Coffee the inside machines while while ballot markers and machines tabulating and electronic ballot markers tabulating with electronic tampering with County tampering to effect effect the the overt acts acts to Coffee County, were overt which were County, Georgia, Office inin Coffee Elections Registration Ofﬁce Elections && Registration Georgia, which and dignity and peace t0 the laws of said the order, good the State, lawsofsaid the to contrary objectofthe dignity State, good order, peace conspiracy, contrary object of the conspiracy, thereof; thereof; 9 9O

PDF Page 92	COUNT 33 33 of 41 COUNT of 41 of Georgia, do And the Grand in the name and behalf ofthe citizensofGeorgia, do of the citizens Jurors aforesaid, the name and behalf Grand Jurors And the aforesaid, in ALSTON CATHLEEN KATHERINE SIDNEY and accuse charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, LATHAM, POWELL, charge TO CONSPIRACY TO of CONSPIRACY the offense offense of with the HAMPTON with MISTY HAMPTON and MISTY HALL, and GRAHAM HALL, SCOTT SCOTT GRAHAM accused, said accused, the said for the & 21-2-574, 21-2-603 & 0.C.G.A. §§ FRAUD, O.C.G.A. ELECTION FRAUD, COMMIT ELECTION COMMIT 21-2-574, for §§ 21-2-603 with with and together and a crime, a of of commission concerned in the commission the persons concerned in and asas persons individually and crime, together individually the 1st on and and between between the Ist of on in the Fulton and State StateofGeorgia, and of Fulton Countyof the in unindicted unindicted co-conspirators, Georgia, co-conspirators, County and to day of December 2020 and the 7th dayof January 2021, unlawfully conspired andagreedto and the 7th of 2020 December agreed day January 2021, unlawfully conspired day of care of of cause conspiracy, who law with with the the care not officers ofﬁcers charged members of the conspiracy, who were were not cause certain certain membersofthe by law charged by a for for a careofballots the care of ballots the with with officer such any ofﬁcer by entrusted entrusted such not persons were not who were and who ballots and ballots by any persons State of of the State place inin the polling place ballots outsideofthe official to ofﬁcial ballots outside of the polling possess to law, by required ‘purpose law, by posSess required purpose Georgia; Georgia; with SullivanStrickler SullivanStrickler And POWELL entered entered into into aa contract contract with KATHERINE POWELL And SIDNEY SIDNEY KATHERINE LLC LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC inin Fulton Fulton County, LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler County, Fulton from Georgia, and caused employeesofSullivanStrickler LLC to travel from Fulton County, Georgia, to travel of LLC caused SullivanStrickler and Georgia, County, employees Georgia, who members of the conspiracy, to Coffee for the purpose of of causing causing certain certain membersofthe conspiracy, who the purpose Coffee County, to County, Georgia, Georgia, for entrusted by not persons were not not ofﬁcers officers charged by law the careofballots and who who were were not by law with with the care of ballots and were persons entrusted charged by ballots official ofﬁcial ballots possess to to law, by required purpose a for the a with care of ballots for ofﬁcer withthecareofballots such officer any possess purpose required by law, any such of the the which acts to effect were overt outside of the polling outsideofthe polling place, which were overt acts to effect the object of the conspiracy; conspiracy; object place, MISTY and MISTY HALL, and GRAHAM HALL, SCOTT GRAHAM LATHAM, SCOTT And ALSTON LATHAM, CATHLEEN ALSTON And CATHLEEN LLC in accessing in LLC SullivanStrickler and of SullivanStrickler employeesof encouraged and abetted, HAMPTON aided, HAMPTON aided, abetted, encouraged employees accessing Ofﬁce in in Coffee Coffee election equipment while inside inside the the Coffee Elections && Registration Coffee County election Registration Office County Elections equipment while who were not the County, Georgia, for the purposeofcausing certain members of the conspiracy, who were not of the of certain members for conspiracy, causing purpose County, Georgia, such entrusted not persons officers charged charged by with the the careofballots who were by any any such care of ballots and and who were not law with ofﬁcers persons entrusted by by law outside of of ballots outside official ballots to possess law, to by law, required by care of ballots for foraa purpose with the the careofballots ofﬁcer officer with possess ofﬁcial purpose required to the the to contrary the conspiracy, the of overt acts acts to effect the objectofthe to effect were overt the which were place, which polling place, the polling conspiracy, contrary object and lawsofsaid the good order, peace and dignity thereof; of said State, laws thereof; State, the order, dignity good peace 91 91

PDF Page 93	+ of 41 COUNT 34 COUNT 34of41 of the citizensof citizens of Georgia, do and behalf Grand Jurors And the Jurors aforesaid, And the Grand in the the name name and behalf ofthe Georgia, do aforesaid, in ALSTON LATHAM, and accuse accuse SIDNEY SIDNEY KATHERINE CATHLEEN ALSTON POWELL, CATHLEEN KATHERINE POWELL, LATHAM, charge charge and of TO with the offense CONSPIRACY HAMPTON GRAHAM HALL, and MISTY MISTY HAMPTON with the offense of CONSPIRACY TO SCOTT SCOTT GRAHAM HALL, and said accused, & 16-9-93(a), 16-4-8 & COMMIT COMPUTER THEFT, 0.C.G.A. §§ 16-4-8 16-9-93(a), for or the the said COMPUTER THEFT, O.C.G.A. §§ COMMIT accused, a and with of commission and as concerned in the individually and as persons concerned in the commission of a crime, and together with crime, together individually persons and between 1st on and and State of Fulton in the of unindicted co-conspirators, in the CountyofFulton and StateofGeorgia, on between the the 1st unindicted Georgia, co-conspirators, County a to use of of December 2020 and the 7th dayofDecember 2020 and the 7th dayofJanuary 2021, unlawfully conspired to use a day January 2021, unlawfully conspired day the intention and with of taking that such was without with knowledge such use computer with knowledge that use was without authority with the intentionoftaking authority and computer of Dominion the and and and appropriating information, data, and software, the property of Dominion Voting Systems software, Voting Systems property appropriating information, data, Corporation, Corporation, SullivanStrickler contract with entered into SIDNEY KATHERINE And And SIDNEY KATHERINE POWELL POWELL entered into aa contract with SullivanStrickler SullivanStrickler LLC delivered aa payment LLC LLC inin Fulton Fulton County, Georgia, delivered payment toto SullivanStrickler LLC inin Fulton Fulton County, County, County, Georgia, Fulton to travel from LLC to travel from Fulton County, caused employeesofSullivanSirickler Georgia, and and caused County, Georgia, Georgia, employees of SullivanStrickler LLC Georgia, with that such use a of for the to Coffee Coffee County, Georgia, for the purpose of using a computer with knowledge that such use to knowledge using computer County, Georgia, purpose and and with the of ‘was without authority authority and with the intention intentionoftaking appropriating information, information, data, and was without data, and taking and appropriating which were acts to effect of Dominion software, the property property of Dominion Voting Voting Systems Corporation, which were overt overt acts to effect software, the Systems Corporation, the the objectofthe object of the conspiracy; conspiracy; and MISTY SCOTT GRAHAM And And CATHLEEN CATHLEEN ALSTON ALSTON LATHAM, LATHAM, SCOTT GRAHAM HALL, HALL, and MISTY of SullivanStrickler LLC HAMPTON aided, abetted, and employeesofSullivanStrickler LLC inin using and encouraged HAMPTON aided, abetted, using aa encouraged employees the of taking and with intention with that such use was without computer with knowledge that such use was without authority and with the intentionoftaking authority knowledge computer of Dominion and appropriating and information, data, and software, software, the the property propertyof Dominion Voting Voting Systems data, and Systems appropriating information, Ofﬁce in Coffee & inside the Elections while Coffee Corporation, while inside the Coffee County Elections & Registration Office in Coffee County, Registration County, County Corporation, to the laws of said which were were overt overt acts effect the Georgia, acts toto effect the objectofthe conspiracy, contrary contrary to the lawsofsaid object of the conspiracy, Georgia, which State, the good good order, peace and and dignity dignity thereof; thereof; order, peace State, the 92 92

PDF Page 94	. 35 of of 41 COUNT 35 COUNT 41 of the citizensofGeorgia, citizens of Georgia, do and behalf in the And the Grand Jurors aforesaid, And the Grand Jurors the name name and behalf ofthe do aforesaid, in CATHLEEN ALSTON and accuse KATHERINE SIDNEY charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, POWELL, LATI-IAM, charge with the offense of of CONSPIRACY HAMPTON with and MISTY SCOTT GRAHAM HALL, SCOTT GRAHAM HALL, and MISTY HAMPTON the offense CONSPIRACY TO TO said accused, O.C.G.A. §§ COMMIT COMPUTER COMPUTER TRESPASS, TRESPASS, 0.C.G.A. 16-4-8 && 16-9-93(b), 16-9-93(b), for for the the said COMMIT accused, §§ 16-4-8 and together ofaa crime, with and as as persons concerned in individually and persons concerned in the the commission commission of together with crime, and individually and State State of of Georgia, on and and between of Fulton unindicted co-conspirators, ‘unindicted in the the County Fulton and Georgia, on between the the lst Ist County of co-conspirators, in a to use of of December 2020 and the 7th day of December 2020 and the 7th dayof January 2021, unlawfully conspired to use a day January 2021, unlawfully conspired day the intention of removing with knowledge that such ‘computer knowledge that such use use was was without without authority and with with the authority and intentionofremoving computer with data from said voter Voter data data and and Dominion Dominion Voting Voting Systems Corporation data from said computer; computer; Systems Corporation entered into SullivanStrickler And SIDNEY KATHERINE KATHERINE POWELL And SIDNEY POWELL entered intoaa contract contract with with SullivanStrickler a to SullivanStrickler LLC LLC Fulton County, delivered a payment LLC inin Fulton County, Georgia, payment to SullivanStrickler LLC inin Fulton Fulton County, County, Georgia, delivered from LLC to travel Fulton and SullivanStrickler caused of Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, Georgia, County, Georgia, employees of using to Coffee County, to Coffee County, Georgia, for the the purpose purpose of using aa computer computer with with knowledge that such such use use knowledge that Georgia, for of removing voter data and and Dominion was the intention was without without authority authority and and with with the intentionofremoving voter data Dominion Voting Voting overt acts acts to effect the of the data from Systems from said said computer, computer, which which were were overt to effect the object objectofthe Systems Corporation Corporation data conspiracy; conspiracy; SCOTT GRAHAM GRAHAM HALL, and MISTY And CATHLEEN ALSTON And CATHLEEN ALSTON LATHAM, LATHAM, SCOTT HALL, and MISTY of SullivanStrickler LLC in HAMPTON and HAMPTON aided, abetted, and encouraged employeesof SullivanStrickler LLC in using aided, abetted, using aa encouraged employees and with with the without authority of removing use was computer with with knowledge that such such use was without the intention intentionofremoving authority and computer knowledge that data from said while inside voter data and and Dominion voter data Dominion Voting Systems Corporation data from said computer, while inside the the computer, Voting Systems Corporation which were Coffee Ofﬁce in Coffee County Elections && Registration in Coffee Coffee County, were overt overt County, Georgia, Georgia, which County Elections Registration Office to the laws of said the effect the acts of the conspiracy, acts toto effect the object objectofthe contrary to the lawsofsaid State, the good order, State, order, good conspiracy, contrary and dignity peace and thereof; peace dignity thereof; 93 9%

PDF Page 95	36 of of 41 41 COUNT 36 COUNT do ‘And the Grand Jurors aforesaid, aforesaid, inintthe hename behalf ofthe name and and behalf of the citizensofGeorgia, citizens of Georgia, do And the Grand Jurors LATHAM, ALSTON CAT HLEEN ALST ON LATHAM, POWELL, CATHLEEN KATHERINE POWELL, accuse SIDNEY SIDNEY KATHERINE and accuse charge charge and TO TO CONSPIRACY ofCONSPIRACY offense HAMPTON withythe offense of the with HAMPTON MISTY and MISTY HALL, and GRAHAM HALL, SCOTT GRAHAM SCOTT for 16-9-93(c), for O.C.G.A. §§ 164-8 && 16-9-93(c), OF PRIVACY, PRIVACY, O.C.G.A. INVASION OF COMMIT COMPUTER COMPUTER INVASION COMMIT §§ 16-4-8 and the accused, individually individually and persons concerned in the the commission commission of and concerned in ofaa crime, and as as persons the said said accused, crime, together with unindicted co-conspirators, in the County of Fulton and Stateof Georgia, on and and on in of Fulton and State of the unindicted with Georgia, County together co-conspirators, between the lst Ist dayof December 2020 and the 7th dayofJanuary 2021, unlawfully conspired and the 7th of 2020 December between the of day January 2021, unlawfully conspired day that such 10to use use acomputer with the the intention intentionof examining personal personal voter data with with knowledge knowledge that such voter data of examining a computer with examination examination was was without without authority; authority; And SIDNEY KATHERINE POWELL POWELL entered contract with with SullivanStrickler entered into into aa contract SullivanStrickler And SIDNEY KATHERINE delivered aa payment LLC in Fulton County, LLC in Fulton County, Georgia, payment toto SullivanStrickler SullivanStrickler LLC LLC inin Fulton Fulton County, County, Georgia, delivered Georgia, County, Fulton from to from travel to LLC LLC travel Fulton SullivanStrickler of SullivanStrickler of employees caused and and caused Georgia, Georgia, County, Georgia, employees with the the intentionofexamining intention of examining to Coffee County, Georgia, Georgia, for for the the purposeof using aa computer to Coffee County, computer with purpose of using were which were such examination examination was without authority, was without that such knowledge that with knowledge data with voter data personal voter authority, which personal of the conspiracy; overt to effect the object objectofthe overt acts acts to effect the conspiracy; And CATHLEEN LATHAM, SCOTT HALL, and MISTY GRAHAM HALL, and MISTY SCOTT GRAHAM ALSTON LATHAM, And CAT HLEEN ALSTON HAMPTON aided, abetted, and LLC inin using using aa SullivanStrickler LLC and encouraged HAMPTON aided, abetted, encouraged employeesof employees of SullivanStrickler that such computer with the intention of examining personal voter data with knowledge that such voter data with of the intention with knowledge examining personal computer examination was was without inside the the Coffee County Elections Elections && Registration Registration Coffee County while inside examination without authority, authority, while conspiracy, objectofthe the effect overt acts to effect the of the to acts overt which were were which Georgia, Ofﬁce in in Coffee Coffee County, Office conspiracy, object County, Georgia, and dignity contrary toto the lawsofsaid peace and thereof; the good the laws of said State, order, peace State, the dignity thereof; good order, contrary 9% 94

PDF Page 96	COUNT 37 of 41 41 COUNT 37of do the name name and and behalf And the the Grand Grand Jurors of the citizensofGeorgia, citizens of Georgia, do And Jurors aforesaid, aforesaid, inin the behalf ofthe SIDNEY KATHERINE CATHLEEN ALSTON charge and accuse accuse SIDNEY KATHERINE POWELL, ALSTON LATHAM, LATHAM, POWELL, CATHLEEN charge and TO of CONSPIRACY TO SCOTT GRAHAM the offense SCOTT GRAHAM HALL, HALL, and and MISTY MISTY HAMPTON HAMPTON with with the offense ofCONSPIRACY O.C.G.A. §§ 16-10-21, DEFRAUD THE THE STATE, said accused, DEFRAUD STATE, O.C.G.A. 16-10-21, for for the the said individually and and asas accused, individually of a and in the commission with unindicted concerned persons concerned in the commission of a crime, and together with unindicted co-conspirators, in crime, co-conspirators, in together persons on and 2020 and and State State of of Georgia, the 1st day the County of Fulton Fulton and between the the 1st of December December 2020 and Georgia, on and between County of day of and to theft of voter data, the 7th of commit the 7th dayofJanuary 2021, unlawfully conspired and agreed to commit theft ofvoter data, 2021, unlawfully conspired agreed day January a state the control of was under State Brad property which which was under the control of Georgia Brad Raffensperger, Raffensperger,a state: Georgia Secretaryof Secretary of State property ofﬁcial capacity; officer, inin his his official officer, capacity; entered into with SullivanStrickler SullivanStrickler And SIDNEY contract with And SIDNEY KATHERINE KATHERINE POWELL POWELL entered intoaa contract a delivered to SullivanStrickler LLC LLC LLC inin Fulton Fulton County, Georgia, delivered a payment to SullivanStrickler LLC inin Fulton Fulton County, payment County, County, Georgia, from Fulton and caused caused employees Georgia, and of SullivanStrickler SullivanStrickler LLC LLC toto travel travel from Fulton County, Georgia, County, Georgia, Georgia, employees of of committing theft was to of voter voter data, to Coffee Coffee County, for the the purpose purpose ofcommitting theft of data, property property which which was Georgia, for County, Georgia, ofﬁcial under state office, under the the control control of of Georgia of State State Brad Brad Raffensperger, Raffenspenger,aa sate in his his official officer, in Georgia Secretary Secretary of the overt acts to effect of the which were capacity, objectofthe conspiracy; capacity, which were overt acts to effect the object conspiracy; SCOTT GRAHAM and MISTY ALSTON LATHAM, And CATHLEEN ALSTON And CATHLEEN LATHAM, SCOTT GRAHAM HALL, HALL, and MISTY and encouraged HAMPTON SullivanStrickler LLC HAMPTON aided, aided, abetted, abetted, and LLC inin accessing accessing encouraged employeesof employees of SullivanStrickler the while inside Coffee Ofﬁce in election equipment Elections & election while inside the Coffee County Elections & Registration Office in Douglas, Douglas, County Registration equipment theft of the the of voter was under Georgia, for the purpose purposeofcommitting property which which was under the control control data, property committing theft ofvoter data, Georgia, for State Brad a which of of state in his ofﬁcial of Georgia Georgia Secretaryof State Brad Raffensperger,a state officer, in his official capacity, which officer, Raffensperger, Secretary capacity, were overt acts acts to to effect of said Stat, were overt effect the the objectofthe conspiracy, contrary contrary toto the the laws lawsofsaid the good good State, the object of the conspiracy, and dignity order, peace peace and dignity thereof; thereof order, COUNT 38 of of 41 COUNT 38 41 ‘And the Grand Jurors aforeseid, in the name and behalf ofthe citizensofGeorgia, do charge and accuse DONALD JOHN TRUMP with the offenseofSOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, 0.C.G.A. §§ 164-7 and 16-10-1, for the said accused, in the CountyofFulton and StateofGeorgia, on or about the 17th day of September 2021, unlawfully solicited, requested, and importuned Georgia Secretary of State. Brad Raffenspenger,a public officer, to engage in conduct constituting the felony offense of ViolationofOathby Public Officer, 0.C.G.A. § 16-10-1, by unlawfully “decertifying the Election, or whatever the correct legal remedy is, and announce the true winner,” in willful and intentional violationofthe termsofthe oathofsaid person as prescribed by law; with intent that said person engage in said conduct, contrary to the lawsofsaid State, the good order, peace and dignity thereof; And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 and 16-10-1, for the said accused, in the County of Fulton and State of Georgia, on or about the 17th day of September 2021, unlawfully solicited, requested, and importuned 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. § 16-101, by unlawfully "decertifying the Election, or whatever the correct legal remedy is, and announce the true winner," 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, contrary to the laws of said State, the good order, peace and dignity thereof; 95 95

PDF Page 97	COUNT 39 of 0f 41 COUNT 39 41 And the Grand Jurors aforesaid, in the name and behalf ofthe citizensofGeorgia, do charge and accuse DONALD JOHN TRUMP with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the CountyofFulton and StateofGeorgia, on or about the 17th day of September 2021, knowingly, willfully, and unlawfully made the following fase statement and representation to Georgia Secretary of State Brad Brad Raffensperger: Raffensperger: than number of false and/or and/or irregular far greater "As stated stated to votes isis far l.1. “As regular votes the numberoffalse greater than previously, the to you you previously, the election to needed needed to change result”; Georgia election result"; change the Georgia of State and within thejurisdictionofthe the jurisdiction of the Officeofthe Oﬁice of the Georgia and statement being SecretaryofState said statement being within said Georgia Secretary and of state government, and agencies of Investigation, county the agenciesofsate departments and Investigation, departments Bureau of government, and county the Georgia Georgia Bureau and the to the laws of said enforcement and city law enforcement agencies, contrary to the lawsofsaid State, the good order, peace and. and law order, State, peace good agencies, contrary city dignity thereof; thereof; dignity And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 17th day of September 2021, knowingly, willfully, and unlawfully made the following false statement and representation to Georgia Secretary of State COUNT 40of 40 of 41 41 COUNT do the citizensofGeorgia, citizens of Georgia, do the name Grand Jurors And the the Grand Jurors aforesaid, aforesaid, inin the name and and behalf behalf ofofthe And STATEMENTS of FALSE JANIES SHAFER with the offense DAVID charge and accuse DAVID JAMES SHAFER with the offense of FALSE STATEMENTS and accuse charge and in the O.C.G.A. §§ 16-10-20, said accused, AND WRITINGS, 16-10-20, for for the the said the County of Fulton Fulton and AND accused, in WRITINGS, 0.C.G.A. County of and the 25th of on or about Stateof on or about the 25th dayof April 2022, knowingly, willfully, and unlawfully State of Georgia, unlawfully day April 2022, knowingly, willfully, Georgia, Fulton made least oneofthe one of the following made atat least following false false statements statements and and representations representations inin the the presence presenceofof Fulton Office District County Attorney's Office investigators: investigators: County District Attorney's of Trump presidential and convened” convened" the the December presidential meetingofTrump That he 2020, meeting 1. December 14, “attended and he "attended 1. That 14, 2020, the each of not "call in Fulton but that he did elector nominees Georgia, but that he did not “call eachofthe nominees in Fulton County, elector County, Georgia, the other other preparations make anyof and notify them of the meeting or make individual members and themofthe meeting or preparations individual members any ofthe notify the necessary for for the meeting”; meeting"; necessary at the the December 2.2. That Thataa court court reporter reporter was was not not present December 14, 14, 2020, 2020, meeting meetingofof Trump. Trump present at nominees in Fulton County, presidential elector elector nominees in Fulton Georgia; County, Georgia; presidential of the Fulton District Attorneys said statements being said statements being within within the the jurisdiction jurisdictionofthe Fulton County Ofﬁce, aa Attorney's Office, County District said ofaa countyofthis department to the the laws lawsofof said and agencyofthe state, contrary contrary to government of county of this state, agency of the government department and and State, the good order,peaceand dignity thereof; the State, dignity thereof; good order, peace ' 96 9%

PDF Page 98	of 41 41 COUNT 41 of COUNT 41 do of the citizens Grand Jurors Jurors aforesaid, in the the name And the Grand aforesaid, in name and and behalf behalf ofthe citizensofof Georgia, And the Georgia, do of PERJURY, O.C.G.A. with the accuse ROBERT CHEELEY with and accuse charge and ROBERT DAVID DAVID CHEELEY the offense offenseofPERJURY, 0.C.G.A. §§ charge on or about the of and State Fulton for the said in the of 16-10-70(a), for the said accused, in the County of Fulton and StateofGeorgia, on or about the Georgia, accused, County 16-10-70(a), least oneofthe one of the made at at least and unlawfully 15th dayof 2022, knowingly, knowingly, willfully, willfully, and unlawfully made 15th September 2022, day of September a Grand false statements before the Fulton following false statements before the Futon County Special Purpose Grand Jury, ajudicial Jury, judicial County Special Purpose following been administered a lawﬁll oath: after proceeding,after having been administered a lawful oath: having proceeding, elector unaware of the December he was was unawareofthe December l4, 14, 2020, 2020, meeting meetingofof Trump presidential elector l.1. That That he Trump presidential after the until after ‘nominees in Fulton Fulton County, the meeting meeting had had already already taken taken place; place; nominees in County, Georgia, Georgia, until December l4, substantive conversations had no 2. That he had no substantive conversations with with anyone anyone concerning the December 14, 2 That he concerning the Fulton in elector nominees 2020, meetingof presidential elector nominees in Fulton County, until County, Georgia, Georgia, until 2020, meeting of Trump Trump presidential after the the meeting after meeting had had already already taken taken place; place; nominces inin elector nominees he never suggested presidential elector 3 the Trump that the anyone that to anyone henever That 3. That suggested to Trump presidential meet should on December Georgia should meet on December l4, 14, 2020; 2020; Georgia the November November 3, with John Eastman concerning 4.4 That That the the only communication he he had had with John Eastman 3, concerning the only communication Senator Eastman to was for of connecting 2020, presidential election election was for the the purpose purposeof connecting Eastman to Georgia Georgia Senator 2020, presidential whose is known to Individual Beach and and unindicted Brandon Beach unindicted co-conspirator Individual 8, whose identity is known to Brandon 8, identity co-conspirator the Grand the Grand Jury, Jury, for for possible possible legal legal representation; representation; other than than with any connect John Eastman with That he 5.5 That he never never worked worked toto connect John Eastman legislators other Georgia legislators any Georgia Individual 8, and unindicted whose Senator Brandon Beach and co-conspirator Individual unindicted coconspirator 8, whose Brandon Beach Georgia Georgia Senator identity isis known known toto the the Grand Grand Jury; Jury; identity material to to the the accused’s accused's own own involvement said involvement inin the the December December 14, said statements statements being l4, 2020, 2020, being material and to the accused's in Fulton elector nominees ‘meetingof Trump presidential elector nominees in Fulton County, Georgia, and to the acused’s of Georgia, County, Trump presidential meeting to the others involved involved in in said said meeting, communications with communications with others meeting, the the issues issues inin question, contrary to the laws laws question, contrary the good and dignity of said State, ofsaid State, the thereof. order, peace good order, peace and dignity thereof. FANI T. WILLIS, FANIT. WILLIS, District District Attorney Attorney 97 97

PDF Page 99	WITNESS LIST WITNESS LIST Asst.Chief Inv.M. Hill ~ FCDA FCDA DA14 DA14 Asst. Chief Inv. M. Hill FCDA DA72 St. Swanson-Lucas - FCDA DAT2 T. Swanson-Lucas Sr. Inv. Inv. T. 9% 98 i

The State of Georgia v. Donald John Trump Document 1: Criminal Indictment