by admin » Sat Aug 19, 2023 8:17 am
COUNT 2 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, JENNA LYNN ELLIS, and RAY STALLINGS SMITH III with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 & 16-10-1, 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 the 3rd day of December 2020, unlawfully solicited, requested, and importuned certain public officers then serving as elected members of the Georgia Senate and present at a Senate Judiciary Subcommittee meeting, including unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, Senators Lee Anderson, Brandon Beach, Matt Brass, Greg Dolezal, Steve Gooch, Tyler Harper, Bill Heath, Jen Jordan, John F. Kennedy, William Ligon, Elena Parent, Michael Rhett, Carden Summers, and Blake Tillery, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. § 16-10-1, by unlawfully appointing presidential electors from the State of 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, said date being a material element of the offense, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 3 of 41
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 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 3rd day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:
1. That at least 96,600 mail-in-ballots were counted in the November 3, 2020, presidential election in Georgia, despite there being no record of those ballots having been returned to a county elections office;
2. That a Dominion Voting Systems machine used in the November 3, 2020, presidential election in Antrim County, Michigan, mistakenly recorded 6,000 votes for Joseph R. Biden when the votes were actually cast for Donald Trump;
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 4 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RAY STALLINGS SMITH III 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 3rd day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:
1. That 2,506 felons voted illegally in the November 3, 2020, presidential election in Georgia;
2. That 66,248 underage people illegally registered to vote before their seventeenth birthday prior to the November 3, 2020, presidential election in Georgia;
3. That at least 2,423 people voted in the November 3, 2020, presidential election in Georgia who were not listed as registered to vote;
4. That 1,043 people voted in the November 3, 2020, presidential election in Georgia who had illegally registered to vote using a post office box;
5. That 10,315 or more dead people voted in the November 3, 2020, presidential election in Georgia;
6. That Fulton County election workers at State Farm Arena ordered poll watchers and members of the media to leave the tabulation area on the night of November 3, 2020, and continued to operate after ordering everyone to leave;
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 5 of 41
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 & 16-10-1, for the said accused, in the County of Fulton and State of Georgia, on or about the 7th day of December 2020, unlawfully solicited, requested, and importuned Speaker of the Georgia House of Representatives David Ralston, a public officer, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. § 16-10-1, by calling for a special session of the Georgia General Assembly for the purpose of unlawfully appointing presidential electors from the State of Georgia, in willful and intentional violation of the terms of the oath of said person as prescribed by law, with intent that said person engage in said conduct, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 6 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI and RAY STALLINGS SMITH III with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 & 16-10-1, 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 the 10th day of December 2020, unlawfully solicited, requested, and importuned 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 Tumer, 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 the State of 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, said date being a material element of the offense, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 7 of 41
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 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 10th day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia House of Representatives present at a House Governmental Affairs Committee meeting:
1. That it is quite clear from the State Farm Arena video from November 3, 2020, that Fulton County election workers were stealing votes and that Georgia officials were covering up a crime in plain sight;
2. That at State Farm Arena on November 3, 2020, Democratic officials “got rid of all of the reporters, all the observers, anyone that couldn’t be trusted,” used the excuse of a watermain break, cleared out the voting area and then “went about their dirty, crooked business”;
3. That between 12,000 and 24,000 ballots were illegally counted by Fulton County election workers at State Farm Arena on November 3, 2020;
4. That in Michigan, there were 700,000 more ballots counted than were sent out to voters in the November 3, 2020, presidential election, which was accounted for by quadruple counting ballots;
5. That Ruby Freeman, Shaye Moss, and an unidentified man were “quite obviously surreptitiously passing around USB ports as if they're vials of heroin or cocaine” at State Farm Arena to be used to “infiltrate the crooked Dominion voting machines”;
6. That 96,600 mail-in ballots were counted in the November 3, 2020, presidential election in Georgia, despite there being no record of those ballots having been returned to a county elections office;
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 8 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, and CATHLEEN ALSTON LATHAM with the offense of IMPERSONATING A PUBLIC OFFICER, O.C.G.A. § 16-10-23, 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 falsely held themselves out as the duly elected and qualified presidential electors from the State of Georgia, public officers, with intent to mislead the President of the United States Senate, the Archivist of the United States, the Georgia Secretary of State, and the Chief Judge of the United States District Court for the Northern District of Georgia into believing that they actually were such officers by placing in the United States mail to said persons a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 9 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY, and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT IMPERSONATING A PUBLIC OFFICER, O.C.G.A. §§ 16-4-8 & 16-10-23, for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and unindicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired to cause certain individuals to falsely hold themselves out as the duly elected and qualified presidential electors from the State of Georgia, public officers, with intent to mislead the President of the United States Senate, the Archivist of the United States, the Georgia Secretary of State, and the Chief Judge of the United States District Court for the Northern District of Georgia into believing that they actually were such officers;
And the Defendants named in Count 8, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, falsely held themselves out as said public officers by placing in the United States mail to said persons a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA” in Fulton County, Georgia, which was an overt act to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 10 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, and CATHLEEN ALSTON LATHAM with 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 “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” a writing other than a check, in such manner that the writing as made purports to have been made by authority of the duly elected and qualified presidential electors from the State of Georgia, who did not give such authority, and uttered and delivered said document to the Archivist of the United States, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 11 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY, and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE, O.C.G.A. §§ 164-8 & 16-9-1(b), for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and unindicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired, with the intent to defraud, to knowingly make a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” a writing other than a check, in such manner that the writing as made purports to have been made by authority of the duly elected and qualified presidential electors from the State of Georgia, who did not give such authority, and to utter and deliver said document to the Archivist of the United States;
And the Defendants named in Count 10, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, made said document in Fulton County, Georgia, and uttered and delivered said document to the Archivist of the United States in Fulton County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 12 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, and CATHLEEN ALSTON LATHAM with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, 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, knowingly, willfully, and unlawfully made and used 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 Office of the Georgia Secretary of State and the Office of the Governor of Georgia, departments and agencies of state government, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 13 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY, and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS, O.C.G.A. §§ 16- 4-8 & 16-10-20, for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and unindicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired to knowingly and willfully make and use 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 Office of the Georgia Secretary of State and the Office of the Governor of Georgia, departments and agencies of state government;
And the Defendants named in Count 12, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, made and used said document in Fulton County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 14 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, and CATHLEEN ALSTON LATHAM with the offense of CRIMINAL ATTEMPT TO COMMIT FILING FALSE DOCUMENTS, O.C.G.A. §§ 164-1 & 16-10-20.1(B)(1), 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, with intent to commit the crime of Filing False Documents, O.C.G.A. § 16-10-20.1(b)(1, placed in the United States mail a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” addressed to Chief Judge, U.S. District Court, Northern District of Georgia, 2188 Richard D. Russell Federal Office Building and U.S. Courthouse, 75 Ted Turner Drive, SW, Atlanta, GA 30303, a substantial step toward the commission of Filing False Documents, O.C.G.A. § 16-10-20.1()(1), with intent to knowingly file, enter, and record said document in a court of the United States, having reason to know that said document contained the materially false statement, “WE, THE UNDERSIGNED, being the duly elected and qualified Electors for President and Vice President of the United States of America from the State of Georgia, do hereby certify the following, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 15 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY, and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT FILING FALSE DOCUMENTS, O.C.G.A. §§ 16-4-8 & 16- 10-20.1(b)(1), for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and unindicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired to knowingly file, enter, and record a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” in a court of the United States, having reason to know that said document contained the materially false statement, “WE, THE UNDERSIGNED, being the duly elected and qualified Electors for President and Vice President of the United States of America from the State of Georgia, do hereby certify the following”;
And the Defendants named in Count 14, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, placed in the United States mail said document, addressed to Chief Judge, U.S. District Court, Northern District of Georgia, 2188 Richard D. Russell Federal Office Building and U.S. Courthouse, 75 Ted Turner Drive, SW, Atlanta, GA 30303, in Fulton County, Georgia, which was an overt act to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 16 of 41
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 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 thereof;
COUNT 17 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY, and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE, O.C.G.A. §§ 16-4-8 & 169-1(b), for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and unindicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired, with the intent to defraud, to knowingly make 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 to utter and deliver said document to the Archivist of the United States and the Office of the Governor of Georgia;
And the Defendants named in Count 16, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, made said document in Fulton County, Georgia, and uttered and delivered said document to the Archivist of the United States and the Office of the Governor of Georgia in Fulton County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 18 of 41
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 the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, 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, knowingly, willfully, and unlawfully made and used 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, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 19 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS, O.C.G.A. §§ 16- 4-8 & 16-10-20, for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and unindicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired to knowingly and willfully make and use a false document tiled “RE: Notice of Filing 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;
And the Defendants named in Count 18, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, made and used said document in Fulton County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 20 of 41
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 & 16-10- 93(b)(1)(A), for the said accused, in the County of Fulton and State of Georgia, on the 14th day of December 2020, unlawfully, with intent to commit the crime of Influencing Witnesses, O.C.G.A. § 16-10-93(b)(1)(A), traveled to the home of Ruby Freeman, a Fulton County, Georgia, election worker, and spoke to her neighbor, a substantial step toward the commission of Influencing Witnesses, O.C.G.A. § 16-10-93(b)(1)(A), 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, said date being a material element of the offense, contrary to the laws of said State, the good order, peace and dignity thereof,
COUNT 21 of 41
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 & 16-10- 93(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.GA. § 16-10-93(b)(1)(A), traveled to the home of Ruby Freeman, a Fulton County, Georgia, election worker, and knocked on her door, a substantial step toward the commission of Influencing Witnesses, O.C.G.A. § 16-10-93(b)(1)(A), 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, said date being a material element of the offense, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 22 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse JEFFREY BOSSERT CLARK with the offense of CRIMINAL ATTEMPT TO COMMIT FALSE STATEMENTS AND WRITINGS, O.C.G.A. §§ 16-4-1 & 16-10-20, for the said accused, individually and as a person concerned in the commission of a crime, and together with unindicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 28th day of December 2020 and the 2nd day of January 2021, unlawfully, with intent to commit the crime of False Statements and Writings, O.C.G.A. § 16-10-20, knowingly and willfully made a false writing and document knowing the same to contain the false statement that the United States Department of Justice had “identified significant concerns that may have impacted the outcome of the election in multiple States, including the State of Georgia,” said statement being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies;
And, on or about the 28th day of December 2020, the said accused sent an e-mail to Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney General Richard Donoghue and requested authorization to send said false writing and document to Georgia Governor Brian Kemp, Speaker of the Georgia House of Representatives David Ralston, and President Pro Tempore of the Georgia Senate Butch Miller;
And, on or about the 2nd day of January 2021, the said accused met with Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney General Richard Donoghue and requested authorization to send said false writing and document to Georgia Governor Brian Kemp, Speaker of the Georgia House of Representatives David Ralston, and President Pro Tempore of the Georgia Senate Butch Miller;
And said acts constituted substantial steps toward the commission of False Statements and Writings, O.C.G.A. § 16-10-20, and said conduct committed outside the state of Georgia. constituted an attempt to commit a crime within the state of Georgia, pursuant to O.C.G.A. § 17- 2-1(b)(2), contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 23 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI, RAY STALLINGS SMITH III, and ROBERT DAVID CHEELEY with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 & 16-10-1, 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 the 30th day of December 2020, unlawfully solicited, requested, and importuned certain public officers then serving as elected members of the Georgia Senate and present at a Senate Judiciary Subcommittee meeting, including unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, Senators Brandon Beach, Bill Heath, William Ligon, Michael Rhett, and Blake Tillery, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. § 16-10-1, by unlawfully appointing presidential electors from the State: of 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, said date being a material element of the offense, contrary to the laws of said Stat, the good order, peace and dignity thereof;
COUNT 24 of 41
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 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 30th day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:
1. That Fulton County election workers fraudulently counted certain ballots as many as five times at State Farm Arena on November 3, 2020;
2. That 2,560 felons voted illegally in the November 3, 2020, presidential election in Georgia;
3. That 10,315 dead people voted in the November 3, 2020, presidential election in Georgia; said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 25 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RAY STALLINGS SMITH III 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 30th day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:
1. That Georgia Secretary of State General Counsel Ryan Germany stated that his office had sent letters to 8,000 people who voted illegally in the November 3, 2020, presidential election and told them not to vote in the January 3, 2021, runoff election;
2. That the Georgia Secretary of State admitted “that they had a 90% accuracy rate” in the November 3, 2020, presidential election and that “there’s still a 10% margin that's not accurate”;
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 26 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse ROBERT DAVID CHEELEY 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 30th day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting;
1. That poll watchers and media at State Farm Arena were told late in the evening of November 3, 2020, that the vote count was being suspended until the next morning and to gp home because of “a major watermain break’;
2. That Fulton County election workers at State Farm Arena “voted” the same ballots “over and over again” on November 3, 2020;
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 27 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP and JOHN CHARLES EASTMAN with the offense of FILING FALSE DOCUMENTS, O.C.G.A. § 16-10-20.1(b)(1), 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 31st day of December 2020, knowingly and unlawfully filed a document tiled “VERIFIED COMPLAINT FOR EMERGENCY INJUNCTIVE AND DECLARATORY RELIEF” in the matter of Trump v. Kemp, Case 1:20-cv-05310-MHC, in the United States District Court for the Northern District of Georgia, a court of the United States, having reason to know that said document contained at least one of the following materially false statements:
1. That “as many as 2,506 felons with an uncompleted sentence” voted illegally in the November 3, 2020, presidential election in Georgia;
2. That “at least 66,247 underage” people voted illegally in the November 3, 2020, presidential election in Georgia;
3. That “at least 2,423 individuals” voted illegally in the November 3, 2020, presidential election in Georgia “who were not listed in the State's records as having been registered to vote”;
4. That “at least 1,043 individuals” voted illegally in the November 3, 2020, presidential election “who had illegally registered to vote using a postal office box as their habitation”;
5. That “as many as 10,315 or more” dead people voted in the November 3, 2020, presidential election in Georgia;
6. That “[d]eliberate misinformation was used to instruct Republican poll watchers and members of the press to leave the premises for the night at approximately 10:00 p.m. on November 3, 2020” at State Farm Arena in Fulton County, Georgia;
contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 28 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP and MARK RANDALL MEADOWS with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 & 16-10-1, 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 2nd day of January 2021, unlawfully solicited, requested, and importuned Georgia Secretary of State Brad Raffensperger, public officer, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. § 16- 10-1, by unlawfully altering, unlawfully adjusting, and otherwise unlawfully influencing the certified returns for presidential electors for the November 3, 2020, presidential election in Georgia, in willful and intentional violation of the terms of the oath of said person as prescribed by law, with intent that said person engage in said conduct, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 29 of 41
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:
1. That anywhere from 250,000 to 300, 000 ballots were dropped mysteriously into the rolls in the November 3, 2020, presidential election in Georgia;
2. That thousands of people attempted to vote in the November 3, 2020, presidential election in Georgia and were told they could not because a ballot had already been cast in their name;
3. That 4,502 people voted in the November 3, 2020, presidential election in Georgia who were not on the voter registration list;
4. That 904 people voted in the November 3, 2020, presidential election in Georgia who were registered at an address that was a post office box;
5. That Ruby Freeman was a professional vote scammer and a known political operative;
6. That Ruby Freeman, her daughter, and others were responsible for fraudulently awarding at least 18,000 ballots to Joseph R. Biden at State Farm Arena in the November 3, 2020, presidential election in Georgia;
7. That close to 5,000 dead people voted in the November 3, 2020, presidential election in Georgia;
8. That 139% of people voted in the November 3, 2020, presidential election in Detroit;
9. That 200,000 more votes were recorded than the number of people who voted in the November 3, 2020, presidential election in Pennsylvania;
10. That thousands of dead people voted in the November 3, 2020, presidential election in Michigan;
11. That Ruby Freeman stuffed the ballot boxes;
12. That hundreds of thousands of ballots had been “dumped” into Fulton County and another county adjacent to Fulton County in the November 3, 2020, presidential election in Georgia;
13. That he won the November 3, 2020, presidential election in Georgia by 400,000 votes;
said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 30 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse STEPHEN CLIFFGARD LEE, HARRISON WILLIAM PRESCOTT FLOYD, and TREVIAN C. KUTTI with the offense of CONSPIRACY TO COMMIT SOLICITATION OF FALSE STATEMENTS AND WRITINGS, O.C.G.A. §§ 16-4-8, 16-4- 7, & 16-10-20, 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 4th day of January 2021, unlawfully conspired to solicit, request, and importune 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; and TREVIAN C. KUTTI traveled to Fulton County, Georgia, and placed a telephone call to Ruby Freeman while in Fulton County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 31 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse STEPHEN CLIFFGARD LEE, HARRISON WILLIAM PRESCOTT FLOYD and TREVIAN C. KUTTI with the offense of INFLUENCING WITNESSES, O.C.G.A. § 16-10-93(b)(1)(A), 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 4th day of January 2021, knowingly and unlawfully engaged in misleading conduct toward Ruby Freeman, a Fulton County, Georgia, election worker, by stating that she needed protection and by purporting to offer her help, 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, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 32 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO COMMIT ELECTION FRAUD, O.C.G.A. §§ 21-2-603 & 21-2-566, 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 and between the 1st day of December 2020 and the 7th day of January 2021, unlawfully conspired and agreed to willfully tamper with electronic ballot markers and tabulating machines in the State of Georgia;
And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of willfully tampering with said electronic ballot markers and tabulating machines, which were overt acts to effect the object of the conspiracy;
And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in willfully tampering with electronic ballot markers and tabulating machines while inside the Coffee County Elections & Registration Office in Coffee County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 33 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO COMMIT ELECTION FRAUD, O.C.G.A. §§ 21-2-603 & 21-2-574, 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 and between the 1st day of December 2020 and the 7th day of January 2021, unlawfully conspired and agreed to cause certain members of the conspiracy, who were not officers charged by law with the care of ballots and who were not persons entrusted by any such officer with the care of ballots for a purpose required by law, to possess official ballots outside of the polling place in the State of Georgia;
And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of causing certain members of the conspiracy, who were not officers charged by law with the care of ballots and who were not persons entrusted by any such officer with the care of ballots for a purpose required by law, to possess official ballots outside of the polling place, which were overt acts to effect the object of the conspiracy;
And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in accessing election equipment while inside the Coffee County Elections & Registration Office in Coffee County, Georgia, for the purpose of causing certain members of the conspiracy, who were not officers charged by law with the care of ballots and who were not persons entrusted by any such officer with the care of ballots for a purpose required by law, to possess official ballots outside of the polling place, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 34 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO COMMIT COMPUTER THEFT, O.C.G.A. §§ 16-4-8 & 16-9-93(a), or 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 and between the 1st day of December 2020 and the 7th day of January 2021, unlawfully conspired to use a computer with knowledge that such use was without authority and with the intention of taking and appropriating information, data, and software, the property of Dominion Voting Systems Corporation,
And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of using a computer with knowledge that such use was without authority and with the intention of taking and appropriating information, data, and software, the property of Dominion Voting Systems Corporation, which were overt acts to effect the object of the conspiracy;
And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in using a computer with knowledge that such use was without authority and with the intention of taking and appropriating information, data, and software, the property of Dominion Voting Systems Corporation, while inside the Coffee County Elections & Registration Office in Coffee County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 35 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO COMMIT COMPUTER TRESPASS, O.C.G.A. §§ 16-4-8 & 16-9-93(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 and between the 1st day of December 2020 and the 7th day of January 2021, unlawfully conspired to use a computer with knowledge that such use was without authority and with the intention of removing voter data and Dominion Voting Systems Corporation data from said computer;
And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of using a computer with knowledge that such use was without authority and with the intention of removing voter data and Dominion Voting Systems Corporation data from said computer, which were overt acts to effect the object of the conspiracy;
And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in using a computer with knowledge that such use was without authority and with the intention of removing voter data and Dominion Voting Systems Corporation data from said computer, while inside the Coffee County Elections & Registration Office in Coffee County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 36 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO COMMIT COMPUTER INVASION OF PRIVACY, O.C.G.A. §§ 164-8 & 16-9-93(c), 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 and between the 1st day of December 2020 and the 7th day of January 2021, unlawfully conspired to use a computer with the intention of examining personal voter data with knowledge that such examination was without authority;
And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of using a computer with the intention of examining personal voter data with knowledge that such examination was without authority, which were overt acts to effect the object of the conspiracy;
And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in using a computer with the intention of examining personal voter data with knowledge that such examination was without authority, while inside the Coffee County Elections & Registration Office in Coffee County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 37 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO DEFRAUD THE STATE, O.C.G.A. § 16-10-21, 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 and between the 1st day of December 2020 and the 7th day of January 2021, unlawfully conspired and agreed to commit theft of voter data, property which was under the control of Georgia Secretary of State Brad Raffensperger, a state: officer, in his official capacity;
And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of committing theft of voter data, property which was under the control of Georgia Secretary of State Brad Raffenspenger, a state officer, in his official capacity, which were overt acts to effect the object of the conspiracy;
And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in accessing election equipment while inside the Coffee County Elections & Registration Office in Douglas, Georgia, for the purpose of committing theft of voter data, property which was under the control of Georgia Secretary of State Brad Raffensperger, a state officer, in his official capacity, which were overt acts to effect the object of the conspiracy, contrary to the laws of said Stat, the good order, peace and dignity thereof;
COUNT 38 of 41
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 Raffenspenger, a public officer, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.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 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;
COUNT 39 of 41
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 Brad Raffensperger:
1. “As stated to you previously, the number of false and/or regular votes is far greater than needed to change the Georgia election result”;
said statement being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agenciesof sate government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and. dignity thereof;
COUNT 40 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER 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 25th day of April 2022, knowingly, willfully, and unlawfully made at least one of the following false statements and representations in the presence of Fulton County District Attorney's Office investigators:
1. That he “attended and convened” the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia, but that he did not “call each of the individual members and notify them of the meeting or make any of the other preparations necessary for the meeting”;
2. That a court reporter was not present at the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia;
said statements being within the jurisdiction of the Fulton County District Attorneys Office, a department and agency of the government of a county of this state, contrary to the laws of said State, the good order, peace and dignity thereof;
COUNT 41 of 41
And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse ROBERT DAVID CHEELEY with the offense of PERJURY, O.C.G.A. § 16-10-70(a), for the said accused, in the County of Fulton and State of Georgia, on or about the 15th day of September 2022, knowingly, willfully, and unlawfully made at least one of the following false statements before the Futon County Special Purpose Grand Jury, a judicial proceeding, after having been administered a lawful oath:
1. That he was unaware of the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia, until after the meeting had already taken place;
2. That he had no substantive conversations with anyone concerning the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia, until after the meeting had already taken place;
3. That he never suggested to anyone that the Trump presidential elector nominees in Georgia should meet on December 14, 2020;
4. That the only communication he had with John Eastman concerning the November 3, 2020, presidential election was for the purpose of connecting Eastman to Georgia Senator Brandon Beach and unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, for possible legal representation;
5. That he never worked to connect John Eastman with any Georgia legislators other than Georgia Senator Brandon Beach and unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury;
said statements being material to the accused’s own involvement in the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia, and to the accused’s communications with others involved in said meeting, the issues in question, contrary to the laws of said State, the good order, peace and dignity thereof.
FANI T. WILLIS, District Attorney
WITNESS LIST
Asst. Chief Inv. M. Hill - FCDA DA14
Sr. Inv. T. Swanson-Lucas - FCDA DA72