Indictment, State of GA v. Donald John Trump, by Fani Willis

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Indictment
Fulton County Superior Court
State of Georgia v. Donald Trump, et al.
Case No. 23SC188947, Judge Mcafee
by Fani Willis, Fulton County District Attorney
August 14, 2023

Clerk No. 23SC188947
EJ15-Mcafee
Fulton County Superior Court
FILED: CA
Date: August 14, 2023
Che Alexander, Clerk of Court

THE STATE GEORGIA
v.
DONALD JOHN TRUMP
Counts 1, 5, 9, 11, 13, 15, 17, 19, 27-29, 38-39

RUDOLPH WILLIAM LOUIS GIULIANI
Counts 1-3, 6-7, 9, 11, 13, 15, 17, 19, 23-24

JOHN CHARLES EASTMAN
Counts 1-2, 9, 11, 13, 15, 17, 19, 27

MARK RANDALL MEADOWS
Counts 1, 28

KENNETH JOHN CHESEBRO
Counts 1, 9, 11, 13, 15, 17, 19

JEFFREY BOSSERT CLARK
1, 22

JENNA LYNN ELLIS
Counts 1-2

RAY STALLINGS SMITH III
Counts 1-2, 4, 6, 9, 11, 13, 15, 17, 19, 23, 25

ROBERT DAVID CHEELEY
Counts 1, 9, 11, 13, 15, 17, 19, 23, 26, 41

MICHAEL A. ROMAN
Counts 1, 9, 11, 13, 15, 17, 19

DAVID JAMES SHAFER
Counts 1, 8, 10, 12, 14, 16, 18, 40

SHAWN MICAH TRESHER STILL
Counts 1, 8, 10, 12, 14, 16, 18

STEPHEN CLIFFGARD LEE
Counts 1, 20-21, 30-31

HARRISON WILLIAM PRESCOTT FLOYD
Counts 1, 30-31

TREVIAN C. KUTTI
Counts 1, 30-31

CATHLEEN ALSTON LATHAM
Counts 1, 8, 10, 12, 14, 32-37

SCOTT GRAHAM HALL
Counts 1, 32-27

MISTY HAMPTON AKA EMILY MISTY HAYES
Counts 1, 32-37

***

1 VIOLATION OF THE GEORGIA RICO (RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS) ACT
O.C.G.A. § 16-14-4(c)

2 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1

3 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

4 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

5 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1

6 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1

7 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

8 IMPERSONATING A PUBLIC OFFICER
O.C.G.A. § 16-10-23

9 CONSPIRACY TO COMMIT IMPERSONATING A PUBLIC OFFICER
O.C.G.A. §§ 16-4-8 & 16-10-23

10 FORGERY IN THE FIRST DEGREE
O.C.G.A. § 16-9-1(b)

11 CONSPIRACY TO COMMIT FORGERY 1N THE FIRST DEGREE
O.C.G.A. §§ 16-4-8 & 16-9-1(b)

12 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

13 CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-8 & 16-10-20

14 CRIMINAL ATTEMPT TO COMMIT FILING FALSE DOCUMENTS
O.C.G.A. §§ 16-4-1 & 16-10-20.1(b)(1)

15 CONSPIRACY TO COMMIT FILING FALSE DOCUMENTS
O.C.G.A. §§ 16-4-8 & 16-10-20.1(b)(1)

16 FORGERY IN THE FIRST DEGREE
O.C.G.A. §§ 16-9-1(b)

17 CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE
O.C.G.A. §§ 16-4-8 & 16-9-1(b)

18 FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-10-20

19 CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS
O.C.G.A. 16-4-8 & 16-10-20

20 CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES
O.C.G.A. §§ 16-4-1 & 16-10-93(b)(1)(A)

21 CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES
O.C.G.A. §§ 16-4-1 & 16-10-93(b)(1)(A)

22 CRIMINAL ATTEMPT TO COMMIT FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-1 & 16-10-20

23 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1

24 FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-10-20

25 FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-10-20

26 FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-10-20

27 FILING FALSE DOCUMENTS
O.CGA.§ 16-10-20.1(b)(1)

28 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1

29 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

30 CONSPIRACY TO COMMIT SOLICITATION OF FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-8, 16-4-7 & 16-10-20

31 INFLUENCING WITNESSES
O.C.G.A. § 16-10-93(b)(1)(A)

32 CONSPIRACY TO COMMIT ELECTION FRAUD
O.C.G.A. §§ 21-2-603 & 21-2-566

33 CONSPIRACY TO COMMIT ELECTION FRAUD
O.C.G.A. §§ 21-2-603 & 21-2-574

34 CONSPIRACY TO COMMIT COMPUTER THEFT
O.C.G.A. §§ 16-4-8 & 16-9-93(a)

35 CONSPIRACY TO COMMITCOMPUTER TRESPASS
O.C.G.A §§ 16-4-8 & 16-9-93(b)

36 CONSPIRACY TO COMMIT COMPUTER INVASION OF PRIVACY
O.C.G.A. §§ 16-4-8 & 16-9-93(c)

37 CONSPIRACY TO DEFRAUD THE STATE
O.C.G.A. § 16-10-21

38 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1

39 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

40 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

41 PERJURY
O.C.G.A. § 16-10-70(a)

TRUE BILL
Aug. 14, 2023

____________________
Grand Jury Foreperson

____________________
FANI T. WILLIS, District Attorney

***

STATE OF GEORGIA, COUNTY OF FULTON

IN THE SUPERIOR COURT OF SAID COUNTY

THE GRAND JURORS, selected, chosen, and sworn for the County of Fulton, to wit:

1. ROBERT WELLS, Foreperson
2 ASHLEY MELVIN, Asst. FP
3. CLARISSA BRYAN, Secretary [MARKED OUT]
4. JULIA DECREDICO, Asst. Sec.
5. ERLE ARNOLD
6. DANIELLE BROWN
7. CAROL DICK
8. KATHY GOLD
9. WILLIS HARDY
10. BRENDA HART
11. ANTIONETTE HUDSON
12. ILE LIN
13. MAX MORTENSEN
14. GREGORY PETRALIA
15. JENNIFER PRICE
16. GEORGE PRINGLE
17. PAVAN PULAVARTY
18. FRANEEN SARIF
19. EMMA ST. JOHN
20. VLADIMIR TCHAKAROV
21. CEDRIC TRICE
22. ESTHER UDOJI
23. MARCUS WELBORN
24. JASMINE CASTRO [MARKED OUT]
25. KATHLEEN CHEN
26. CHRISTOPHER SUTTON [MARKED OUT]

***

TABLE OF CONTENTS

COUNT 1: VIOLATION OF THE GEORGIA RICO (RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS) ACT
O.C.G.A. § 16-14-4(c)
Introduction
The Enterprise
Manner and Methods of the Enterprise
Acts of Racketeering Activity and Overt Acts in Furtherance of the Conspiracy

COUNT 2: SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1

COUNT 3: FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-10-20

COUNT 4: FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

COUNT 5: SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER,
O.C.G.A. §§ 16-4-7 & 16-10-1

COUNT 6: SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7& 16-10-1

COUNT 7: FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

COUNT 8: IMPERSONATING A PUBLIC OFFICER
O.C.G.A. § 16-10-23

COUNT 9: CONSPIRACY TO COMMIT IMPERSONATING A PUBLIC OFFICER
O.C.G.A. §§ 16-4-8 & 16-10-23

COUNT 10: FORGERY IN THE FIRST DEGREE
O.C.G.A. §§ 16-9-1(b)

COUNT 11: CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE
O.C.G.A. §§ 16-4-8 & 16-9-1(b)

COUNT 12: FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

COUNT 13: CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-8 & 16-10-20

COUNT 14: CRIMINAL ATTEMPT TO COMMIT FILING FALSE DOCUMENTS
O.C.G.A. §§ 16-4-1 & 16-10-20.1(b)(1)

COUNT 15: CONSPIRACY TO COMMIT FILING FALSE DOCUMENTS
O.C.G.A. §§ 16-4-8 & 16-10-20.1(b)(1)

COUNT 16: FORGERY IN THE FIRST DEGREE
O.C.G.A. § 16-9-1(b)

COUNT 17: CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE
O.C.G.A. §§ 16-4-8 & 16-9-1(b)

COUNT 18: FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-10-20

COUNT 19: CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-8 & 16-10-2

COUNT 20: CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES
O.C.G.A. §§ 16-4-1 & 16-10-93(b)(1)(A)

COUNT 21: CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES
O.C.G.A. §§ 16-4-1 & 16-10-93(b)(1)(A)

COUNT 22: CRIMINAL ATTEMPT TO COMMIT FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-1 & 16-10-20

COUNT 23: SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER O.C.G.A. §§ 16-4-7& 16-10-84--1

COUNT 24: FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

COUNT 25: FALSE STATEMENTS AND WRITINGS
O.C.G.A § 16-10-20

COUNT 26: FALSE STATEMENTS AND WRITINGS
O.C.G.A § 16-10-20

COUNT 27: FILING FALSE DOCUMENTS
O.C.G.A § 16-10-20.1(b)(1)

COUNT 28: SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A § 16-4-7 & 16-10-1

COUNT 29: FALSE STATEMENTS AND WRITINGS
O.C.G.A § 16-10-20

COUNT 30: CONSPIRACY TO COMMIT SOLICITATION OF FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-8, 16-4-7, & 16-10-20

COUNT 31: INFLUENCING WITNESSES
O.C.G.A. § 16-10-93(b)(1)(A)

COUNT 32: CONSPIRACY TO COMMIT ELECTION FRAUD
O.C.G.A. §§ 21-2-603 & 21-2-566

COUNT 33: CONSPIRACY TO COMMIT ELECTION FRAUD
O.C.G.A. §§ 21-2-603 & 21-2-574

COUNT 34: CONSPIRACY TO COMMIT COMPUTER THEFT
O.C.G.A. §§ 16-4-8 & 16-9-93(a)

COUNT 35: CONSPIRACY TO COMMIT COMPUTER TRESPASS
O.C.G.A. §§ 16-4-8 & 16-9-93 (b)

COUNT 36: CONSPIRACY TO COMMIT COMPUTER INVASION OF PRIVACY
O.C.G.A. §§ 16-4-8 & 16-9-93(c)

COUNT 37: CONSPIRACY TO DEFRAUD THE STATE
O.C.G.A. §§ 16-10-21

COUNT 38: SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-95--1

COUNT 39: FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

COUNT 40: FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20

COUNT 41: PERJURY
O.C.G.A. § 16-10-70(a)

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COUNT 1 of 41

The Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do hereby charge and accuse:

DONALD JOHN TRUMP,
RUDOLPH WILLIAM LOUIS GIULIANI,
JOHN CHARLES EASTMAN,
MARK RANDALL MEADOWS,
KENNETH JOHN CHESEBRO,
JEFFREY BOSSERT CLARK,
JENNA LYNN ELLIS,
RAY STALLINGS SMITH III,
ROBERT DAVID CHEELEY,
MICHAEL A. ROMAN,
DAVID JAMES SHAFER,
SHAWN MICAH TRESHER STILL,
STEPHEN CLIFFGARD LEE,
HARRISON WILLIAM PRESCOTT FLOYD,
TREVIAN C. KUTTI,
SIDNEY KATHERINE POWELL,
CATHLEEN ALSTON LATHAM,
SCOTT GRAHAM HALL, and
MISTY HAMPTON

with the offense of VIOLATION OF THE GEORGIA RICO (RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS) ACT, O.C.G.A. § 16-14-4(c), for the said accused, individually and as persons concerned in the commission of a crime, and together with unindicted co-conspirators, in the State of Georgia and County of Fulton, on and between the 4th day of November 2020 and the 15th day of September 2022, while associated with an enterprise, unlawfully conspired and endeavored to conduct and participate in, directly and indirectly, such enterprise through a pattern of racketeering activity in violation of O.C.G.A. § 16-14-4(b), as described below and incorporated by reference as if fully set forth herein, contrary to the laws of said State, the good order, peace, and dignity thereof;

INTRODUCTION

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

THE ENTERPRISE

At all times relevant to this Count of the Indictment, the Defendants, as well as others not named as defendants, unlawfully conspired and endeavored to conduct and participate in a criminal enterprise in Fulton County, Georgia, and elsewhere. Defendants Donald John Trump, Rudolph William Lous Giuliani, John Charles Eastman, Mark Randall Meadows, Kenneth John Chesebro, Jeffrey Bossert Clark, Jenna Lynn Ellis, Ray Stallings Smith III, Robert David Cheeley, Michael A. Roman, David James Shafer, Shawn Micah Tresher Still, Stephen Cliffgard Lee, Harrison William Prescott Floyd, Trevian C. Kutt, Sidney Katherine Powell, Cathleen Alston Latham, Scott Graham Hell, Misty Hampton, unindicted co-conspirators Individual 1 through Individual 30, and others known and unknown to the Grand Jury, constituted a criminal organization whose members and associates engaged in various related criminal activities including, but not limited to, false statements and writings, impersonating a public officer, forgery, filing false documents, influencing witnesses, computer theft, computer trespass, computer invasion of privacy, conspiracy to defraud the state, acts involving theft, and perjury.

This criminal organization constituted an enterprise as that term is defined in O.C.G.A. § 16-14-3(3), that is, a group of individuals associated in fact. The Defendants and other members and associates of the enterprise had connections and relationships with one another and with the enterprise. The enterprise constituted an ongoing organization whose members and associates functioned as a continuing unit for a common purpose of achieving the objectives of the enterprise. The enterprise operated in Fulton County, Georgia, elsewhere in the State of Georgia, in other states, including, but not limited to, Arizona, Michigan, Nevada, New Mexico, Pennsylvania, and Wisconsin, and in the District of Columbia. The enterprise operated for a period of time sufficient to permit its members and associates to pursue its objectives.

MANNER AND METHODS OF THE ENTERPRISE

The manner and methods used by the Defendants and other members and associates of the enterprise to further the goals of the enterprise and to achieve its purposes included, but were not limited to, the following:

1. False Statements to and Solicitation of State Legislatures

Members of the enterprise, including several of the Defendants, appeared at hearings in Fulton County, Georgia, before members of the Georgia General Assembly on December 3, 2020, December 10, 2020, and December 30, 2020. At these hearings, members of the enterprise made false statements concerning fraud in the November 3, 2020, presidential election. The purpose of these false statements was to persuade Georgia legislators to reject lawful electoral votes cast by the duly elected and qualified presidential electors from Georgia. Members of the enterprise corruptly solicited Georgia legislators instead to unlawfully appoint their own presidential electors for the purpose of casting electoral votes for Donald Trump. Members of the enterprise also made false statements to state legislators during hearings and meetings in Arizona, Michigan, and Pennsylvania in November and December 2020 to persuade legislators in those states to unlawfully appoint their own presidential electors.

2. False Statements to and Solicitation of High-Ranking State Officials

Members of the enterprise, including several of the Defendants, made false statements in Fulton County and elsewhere in the State of Georgia to Georgia officials, including the Governor, the Secretary of State, and the Speaker of the House of Representatives. Members of the enterprise also corruptly solicited Georgia officials, including the Secretary of State and the Speaker of the House of Representatives, to violate their oaths to the Georgia Constitution and to the United States Constitution by unlawfully changing the outcome of the November 3, 2020, presidential election in Georgia in favor of Donald Trump. Members of the enterprise also made false statements to and solicited state officials in Arizona, Michigan, and Pennsylvania.

3. Creation and Distribution of False Electoral College Documents

Members of the enterprise, including several of the Defendants, created false Electoral College documents and recruited individuals to convene and cast false Electoral College votes at the Georgia State Capitol, in Fulton County, on December 14, 2020. After the false Electoral College votes were cast, members of the enterprise transmitted the votes to the President of the United States Senate, the Archivist of the United States, the Georgia Secretary of State, and the Chief Judge of the United States District Court for the Northern District of Georgia. The false documents were intended to disrupt and delay the joint session of Congress on January 6, 2021, in order to unlawfully change the outcome of the November 3, 2020, presidential election in favor of Donald Trump. Similar schemes were executed by members of the enterprise in Arizona, Michigan, Nevada, New Mexico, Pennsylvania, and Wisconsin.

4. Harassment and Intimidation of Fulton County Election Worker Ruby Freeman

Members of the enterprise, including several of the Defendants, falsely accused Fulton County election worker Ruby Freeman of committing election crimes in Fulton County, Georgia. These false accusations were repeated to Georgia legislators and other Georgia officials in an effort to persuade them to unlawfully change the outcome of the November 3, 2020, presidential election in favor of Donald Trump. In furtherance of this scheme, members of the enterprise traveled from out of state to harass Freeman, intimidate her, and solicit her to falsely confess to election crimes that she did not commit.

5. Solicitation of High-Ranking United States Department of Justice Officials

Members of the enterprise, including several of the Defendants, corruptly solicited high-ranking United States Department of Justice officials to make false statements to govern ment officials in Fulton County, Georgia, including the Governor, the Speaker of the House of Representatives, and the President Pro Tempore of the Senate. In one instance, Donald Trump stated to the Acting United States Attorney General, “Just say that the election was corrupt, and leave the rest to me and the Republican congressmen.”

6. Solicitation of the Vice President of the United States

Members of the enterprise, including several of the Defendants, corruptly solicited the Vice President of the United States to violate the United States Constitution and federal law by unlawfully rejecting Electoral College votes cast in Fulton County, Georgia, by the duly elected and qualified presidential electors from Georgia. Members of the enterprise also corruptly solicited the Vice President to reject votes cast by the duly elected and qualified presidential electors from several other states.

7. Unlawful Breach of Election Equipment in Georgia and Elsewhere

Members of the enterprise, including several of the Defendants, corruptly conspired in Fulton County, Georgia, and elsewhere to unlawfully access secure voting equipment and voter data. In Georgia, members of the enterprise stole data, including ballot images, voting equipment software, and personal voter information. The stolen data was then distributed to other members of the enterprise, including members in other states.

8. Obstructive Acts in Furtherance of the Conspiracy and the Cover Up

Members of the enterprise, including several of the Defendants, filed false documents, made false statements to government investigators, and committed perjury in judicial proceedings in Fulton County, Georgia, and elsewhere in furtherance of and to cover up the conspiracy.

ACTS OF RACKETEERING ACTIVITY AND OVERT ACTS IN FURTHERANCE OF THE CONSPIRACY.

As part of and on behalf of the criminal enterprise detailed above, the Defendants and other members and associates of the enterprise committed overt acts to effect the objectives of the enterprise, including but not limited to:

Act 1

On or about the 4th day of November 2020, DONALD JOHN TRUMP made a nationally televised speech falsely declaring victory in the 2020 presidential election. Approximately four days earlier, on or about October 31, 2020, DONALD JOHN TRUMP discussed a draft speech with unindicted co-conspirator Individual 1, whose identity is known to the Grand Jury, that falsely declared victory and falsely claimed voter fraud. The speech was an overt act in furtherance of the conspiracy.

Act 2

On or about the 15th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI placed a telephone call to unindicted co-conspirator Individual 2, whose identity is known to the Grand Jury, and left an approximately 83-second-long voicemail message for unindicted co-conspirator Individual 2 making statements concerning fraud in the November 3, 2020, election in Fulton County, Georgia. This telephone call was an overt act in furtherance of the conspiracy.

Act 2 [3]

On or about the 19th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI, JENNA LYNN ELLIS, SIDNEY KATHERINE POWELL, and unindicted coconspirator Individual 3, whose identity is known to the Grand Jury, appeared at a press conference at the Republican National Committee Headquarters on behalf of DONALD JOHN TRUMP and Donald J. Trump for President, Inc. (the “Trump Campaign”) and made false statements concerning fraud in the November 3, 2020, presidential election in Georgia and elsewhere. These were overt acts in furtherance of the conspiracy.

Act 4

On or about the 20th day of November 2020, DAVID JAMES SHAFER sent an e-mail to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, and other individuals. In the e-mail, DAVID JAMES SHAFER stated that SCOTT GRAHAM HALL, a Georgia bail bondsman, “has been looking into the election on behalf of the President at the request of David Bossie” and asked unindicted co-conspirator Individual 4 to exchange contact information with SCOTT GRAHAM HALL and to “help him as needed.” This was an overt act in furtherance of the conspiracy.

Act 5

On or about the 20th day of November 2020, DONALD JOHN TRUMP and MARK RANDALL MEADOWS met with Majority Leader of the Michigan Senate Michael Shirkey, Speaker of the Michigan House of Representatives Lee Chatfield, and other Michigan legislators in the Oval Office at the White House, and DONALD JOHN TRUMP made false statements concerning fraud in the November 3, 2020, presidential election in Michigan. RUDOLPH WILLIAM LOUIS GIULIANI joined the meeting by telephone. This meeting was an overt act in furtherance of the conspiracy.

Act 6

On or about the 21st day of November 2020, MARK RANDALL MEADOWS sent a text message to United States Representative Scott Perry from Pennsylvania and stated, “Can ‘you send me the number for the speaker and the leader of PA Legislature. POTUS wants to chat with them.” This was an overt act in furtherance of the conspiracy.

Act 7

On or about the 22nd day of November 2020, DONALD JOHN TRUMP and RUDOLPH WILLIAM LOUIS GIULIANI placed a telephone call to Speaker of the Arizona House of Representatives Russell “Rusty” Bowers. During the telephone call, RUDOLPH WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3, 2020, presidential election in Arizona and solicited, requested, and importuned Bowers to unlawfully appoint presidential electors from Arizona. Bowers declined and later testified to the United States House of Representatives Select Committee to Investigate the January 6th Attack on the United States Capitol that he told DONALD JOHN TRUMP, “I would not break my oath.” The false statements and solicitations were overt acts in furtherance of the conspiracy.

Act 8

On or about the 25th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses at a meeting of Pennsylvania legislators in Gettysburg, Pennsylvania. During the meeting, RUDOLPH WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3, 2020, presidential election in Pennsylvania and solicited, requested, and importuned the Pennsylvania legislators present at the meeting to unlawfully appoint presidential electors from Pennsylvania. During the meeting, JENNA LYNN ELLIS solicited, requested, and importuned the Pennsylvania legislators present at the meeting to unlawfully appoint presidential electors from Pennsylvania. DONALD JOHN TRUMP joined the meeting by telephone, made false statements concerning fraud in the November 3, 2020, presidential election in Pennsylvania, and solicited, requested, and importuned the Pennsylvania legislators present at the meeting to unlawfully appoint presidential electors from Pennsylvania. These were overt acts in furtherance of the conspiracy.

Act 9

On or about the 25th day of November 2020, immediately after the meeting of Pennsylvania legislators in Gettysburg, Pennsylvania, where RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses, DONALD JOHN TRUMP invited a group of the Pennsylvania legislators and others to meet with him at the White House. Later that day, DONALD JOHN TRUMP, MARK RANDALL MEADOWS, RUDOLPH WILLIAM LOUIS GIULIANI, JENNA LYNN ELLIS and unindicted co-conspirators Individual 5 and Individual 6, whose identities are known to the Grand Jury, met with the group of Pennsylvania legislators at the White House and discussed holding a special session of the Pennsylvania General Assembly. These were overt acts in furtherance of the conspiracy.

Act 10

On or about the 26th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS placed a telephone call to Speaker of the Pennsylvania House of Representatives Bryan Cutler and left Cutler a voicemail message for the purpose of soliciting, requesting, and importuning him to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy.

Act11

On or about the 26th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI placed a telephone call to President Pro Tempore of the Pennsylvania Senate Jacob “Jake” Corman for the purpose of soliciting, requesting, and importuning Corman to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy.

Act 12

On or about the 27th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS placed a telephone call to Speaker of the Pennsylvania House of Representatives Bryan Cutler and left Cutler a voicemail message for the purpose of soliciting, requesting, and importuning him to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy.

Act 14

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

On or about the 28th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI placed a telephone call to Speaker of the Pennsylvania House of Representatives Bryan Cutler and left Cutler a voicemail message for the purpose of soliciting, requesting, and importuning him to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy.

Act 16

On or about the 29th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI placed a telephone call to Speaker of the Pennsylvania House of Representatives Bryan Cutler and left Cutler a voicemail message for the purpose of soliciting, requesting, and importuning him to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy.

Act 17

On or about the 30th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses at a meeting of Arizona legislators in Phoenix, Arizona. Unindicted co-conspirators Individual 5 and Individual 6, whose identities are known to the Grand Jury, were also present. During the meeting, RUDOLPH WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3, 2020, presidential election in Arizona and solicited, requested, and importuned the Arizona legislators present at the meeting to unlawfully appoint presidential electors from Arizona. During the meeting, JENNA LYNN ELLIS solicited, requested, and importuned the Arizona legislators present at the meeting to unlawfully appoint presidential electors from Arizona. DONALD JOHN TRUMP joined the meeting by telephone and made false statements concerning fraud in the November 3, 2020, presidential election in Arizona. These were overt acts in furtherance of the conspiracy.

Act 18

On or about the 30th day of November 2020, MICHAEL A. ROMAN instructed unindicted co-conspirator Individual 7, whose identity is known to the Grand Jury, to coordinate with individuals associated with the Trump Campaign to contact state legislators in Georgia and elsewhere on behalf of DONALD JOHN TRUMP and to encourage them to unlawfully appoint presidential electors from their respective states. This was an overt act in furtherance of the conspiracy.

Act 19

On or between the 1st day of December 2020 and the 31st day of December 2020, DONALD JOHN TRUMP and MARK RANDALL MEADOWS met with John McEntee and requested that McEntee prepare a memorandum outlining a strategy for disrupting and delaying the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states. The strategy included having Vice President Michael R. “Mike” Pence count only half of the electoral votes from certain states and then return the remaining electoral votes to state legislatures. The request was an overt act in furtherance of the conspiracy.

Act 20

On or about the 1st day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS met with Speaker of the Arizona House of Representatives Rusty Bowers, President of the Arizona Senate Karen Fann, and other Arizona legislators in Phoenix, Arizona. Unindicted co-conspirator Individual 5, whose identity is known to the Grand Jury, was also present. During the meeting, RUDOLPH WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3, 2020, presidential election in Arizona and solicited, requested, and importuned the legislators present to call a special session of the Arizona State Legislature. These were overt acts in furtherance of the conspiracy.

Act 21

On or about the 2nd day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses at a meeting of the Michigan House of Representatives Oversight Committee. During the meeting, RUDOLPH WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3, 2020, presidential election in Michigan and solicited, requested, and importuned the Michigan legislators present at the meeting to unlawfully appoint presidential electors from Michigan. During the meeting, JENNA LYNN ELLIS solicited, requested, and importuned the Michigan legislators present at the meeting to unlawfully appoint presidential electors from Michigan. These were overt acts in furtherance of the conspiracy.

Act 22

On or about the 3rd day of December 2020, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, “Georgia hearings now on @OANN. Amazing!” This was an overt act in furtherance of the conspiracy.

Act 23

On or about the 3rd day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, JENNA LYNN ELLIS, and RAY STALLINGS SMITH III committed the felony offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, in violation of O.C.G.A. §§ 164-7 & 16-101, in Fulton County, Georgia, by unlawfully soliciting, requesting, and importuning certain public officers then serving as elected members of the Georgia Senate and present at a Senate Judiciary Subcommittee meeting, including unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, Senators Lee Anderson, Brandon Beach, Matt Brass, Greg Dolezal, Steve Gooch, Tyler Harper, Bill Heath, Jen Jordan, John F. Kennedy, William Ligon, Elena Parent, Michael Rhett, Carden Summers, and Blake Tillery, to engage in conduct constituting the felony offense 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.

Act 24

On or about the 3rd 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 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 Dominion Voting Systems equipment used in the November 3, 2020, presidential election in Antrim County, Michigan, mistakenly recorded 6,000 votes for Joseph R. Biden when the votes were actually cast for Donald John Trump;

said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies. This was an act of racketeering activity under O.C.G.A. § 16- 14-3(5)(A)(xii) and an overt act in furtherance of the conspiracy.

Act 25

On or about the 3rd day of December 2020, RAY STALLINGS SMITH III 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 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. This was an act of racketeering activity under O.C.G.A. § 16- 14-3(5)(A)(xii) and an overt act in furtherance of the conspiracy.

Act 26

On or about the 3rd day of December 2020, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, “Wow! Blockbuster testimony taking place right now in Georgia. Ballot stuffing by Dems when Republicans were forced to leave the large counting room. Plenty more coming, but this alone leads to an easy win of the State!” This was an overt act in furtherance of the conspiracy.

Act 27

On or about the 3rd day of December 2020, DONALD JOHN TRUMP caused to be: tweeted from the Twitter account @RealDonaldTrump, “People in Georgia got caught cold bringing in massive numbers of ballots and putting them in ‘voting’ machines. Great job @BrianKempGA!” This was an overt act in furtherance of the conspiracy.

Act 28

On or about the 3rd day of December 2020, DONALD JOHN TRUMP met with Speaker of the Pennsylvania House of Representatives Bryan Cutler in the Oval Office at the White House and discussed holding a special session of the Pennsylvania General Assembly. This was an overt act in furtherance of the conspiracy.

Act 29

On or between the 3rd day of December 2020 and the 26th day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI placed a telephone call to President Pro Tempore of the Georgia Senate Cecil Terrell “Butch” Miller for the purpose of making false statements concerning fraud in the November 3, 2020, presidential election in Georgia. This was an overt act in furtherance of the conspiracy.

Act 30

On or between the 3rd day of December 2020 and the 26th day of December 2020, DONALD JOHN TRUMP placed a telephone call to President Pro Tempore of the Georgia Senate Butch Miller. This was an overt act in furtherance of the conspiracy.

Act 31

On or about the 5th day of December 2020, DONALD JOHN TRUMP placed a telephone call to Georgia Governor Brian Kemp and solicited, requested, and importuned Kemp to call a special session of the Georgia General Assembly. This was an overt act in furtherance of the conspiracy.

Act 32

On or about the 6th day of December 2020, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, “Gee, what a surprise. Has anyone informed the so-called (says he has no power to do anything!) Governor @BrianKempGA & his puppet Lt. Govemor @GeoffDuncanGA, that they could easily solve this mess, & WIN. Signature verification & call a Special Session. So easy! https:/t.co/5cb4QdYzpU.” This was an overt act in furtherance of the conspiracy.

Act 33

On or about the 6th day of December 2020, SIDNEY KATHERINE POWELL entered into a written engagement agreement with SullivanStrickler LLC, a forensic data firm located in Fulton County, Georgia, for the performance of computer forensic collections and analytics on Dominion Voting Systems equipment in Michigan and elsewhere. The unlawful breach of election equipment in Coffee County, Georgia, was subsequently performed under this agreement. This was an overt act in furtherance of the conspiracy.

Act 34

On or about the 6th day of December 2020, ROBERT DAVID CHEELEY sent an e- mail to JOHN CHARLES EASTMAN, unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, and Georgia Senator Brandon Beach that stated, “I am working on setting up a call for you with the Speaker and the President Pro Tempore tomorrow. I am also making the leadership aware of the importance for Trump electors to meet on December 14. Please provide the citation to the requirements of the duties which they must comply with.” This was an overt act in furtherance of the conspiracy.

Act 35

On or about the 6th day of December 2020, JOHN CHARLES EASTMAN sent an e- mail to ROBERT DAVID CHEELEY, unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, and Georgia Senator Brandon Beach that stated that the Trump presidential elector nominees in Georgia needed to meet on December 14, 2020, sign six sets of certificates of vote, and mail them “to the President of the Senate and to other officials.” This was an overt act in furtherance of the conspiracy.

Act 36

On or about the 6th day of December 2020, ROBERT DAVID CHEELEY sent an email to unindicted co-conspirator Individual 2, whose identity is known to the Grand Jury, that stated he had been speaking with JOHN CHARLES EASTMAN and was attempting to set up a call with Speaker of the Georgia House of Representatives David Ralston and President Pro Tempore of the Georgia Senate Butch Miller to encourage them to call a special session of the Georgia General Assembly. In the e-mail, ROBERT DAVID CHEELEY stated, “Professor Eastman told me tonight that it is critical that the 16 Electors for President Trump meet next Monday and vote in accordance with 3 U.S.C. § 7.” In the e-mail, ROBERT DAVID CHEELEY further sated, “I assume you can make sure this happens.” This was an overt act in furtherance of the conspiracy.

Act 37

On or about the 7th day of December 2020, unindicted co-conspirator Individual 2, whose identity is known to the Grand Jury, sent an e-mail to ROBERT DAVID CHEELEY and DAVID JAMES SHAFER that stated, “Bob, can u get on a call with David Shafer, state GOP chair and I later this morning to discuss. David has been on top of a lot of efforts in the state. I get off of a board call around 10:30.” This was an overt act in furtherance of the conspiracy.

Act 38

On or about the 7¢h day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI caused to be tweeted from the Twitter account@RudyGiuliani a retweet of unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, that stated, “Georgia Patriot Call to Action: today is the day we need you to call your state Senate & House Reps & ask them to sign the petition for a special session. We must have free & fair elections in GA & a this is our only path to ensuring every legal vote is counted. @realDonaldTrump.” This was an overt act in furtherance of the conspiracy.

Act 39

On or about the 7th day of December 2020, JOHN CHARLES EASTMAN sent an email to RUDOLPH WILLIAM LOUIS GIULIANI with an attached memorandum titled “The Real Deadline for Settling a State’s Electoral Votes.” The body of the e-mail stated, “Here's the memo we discussed.” The memorandum was written by KENNETH JOHN CHESEBRO to James R. Troupis, an attorney associated with the Trump Campaign, and advocates for the position that Trump presidential elector nominees in Wisconsin should meet and cast electoral votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in Wisconsin. This e-mail was an overt act in furtherance of the conspiracy.

Act 40

On or about the 7th day of December 2020, DONALD JOHN TRUMP requested that Bill White, an individual associated with the Trump Campaign then residing in Fulton County, Georgia, provide him with certain information, including contact information for Majority Leader of the Georgia Senate Mike Dugan and President Pro Tempore of the Georgia Senate Butch Miller. The following day, White sent an e-mail containing the requested information to RUDOLPH WILLIAM LOUIS GIULIANI, unindicted co-conspirator Individual 5, whose identity is known to the Grand Jury, and others. This request was an overt act in furtherance of the conspiracy.

Act 41

On or about the 7th day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI placed a telephone call to Speaker of the Georgia House of Representatives David Ralston and discussed holding a special session of the Georgia General Assembly. This was an overt act in furtherance of the conspiracy.

Act 42

On or about the 7th day of December 2020, DONALD JOHN TRUMP 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 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 a special session of the Georgia General Assembly for the purpose of unlawfully appointing presidential electors from Georgia, in willful and intentional violation of the terms of the oath of said person as prescribed by law, with intent that said person engage in said conduct. This was an overt act in furtherance of the conspiracy.

Act 43

On or about the 8th day of December 2020, DONALD JOHN TRUMP placed a telephone call to Georgia Attorney General Chris Carr for the purpose of making false statements concerning fraud in the November 3, 2020, presidential election in Georgia and elsewhere. During the telephone call, DONALD JOHN TRUMP asked Carr not to discourage other state attorneys general from joining a federal lawsuit filed by the State of Texas contesting the administration of the November 3, 2020, presidential election in Georgia, Michigan, Pennsylvania, and Wisconsin. This was an overt act in furtherance of the conspiracy.

Act 44

On or about the 8th day of December 2020, DONALD JOHN TRUMP and JOHN CHARLES EASTMAN placed a telephone call to Republican National Committee Chairwoman Ronna McDaniel to request her assistance gathering certain individuals to meet and cast electoral votes for DONALD JOHN TRUMP on December 14, 2020, in certain states despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in those states. This was an overt act in furtherance of the conspiracy.

Act 45

On or about the 8th day of December 2020, MICHAEL ROMAN sent a text message to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, stated that he had spoken to MISTY HAMPTON, and asked unindicted co-conspirator Individual 4 to “get” MISTY HAMPTON to attend the hearing before the Georgia House of Representatives Governmental Affairs Committee on December 10, 2020. This was an overt act in furtherance of the conspiracy.

Act 46

On or about the 9th day of December 2020, KENNETH JOHN CHESEBRO wrote a memorandum titled “Statutory Requirements for December 14 Electoral Votes” to James R. Troupis, an attorney associated with the Trump Campaign. The memorandum provides detailed, state-specific instructions for how Trump presidential elector nominees in Georgia, Arizona, Michigan, Nevada, Pennsylvania, and Wisconsin would meet and cast electoral votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in those states. This was an overt act in furtherance of the conspiracy.

Act 47

On or about the 10th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail to Georgia Republican Party Chairman DAVID JAMES SHAFER and unindicted coconspirator Individual 9, whose identity is known to the Grand Jury. KENNETH JOHN CHESEBRO stated in the e-mail that certain individuals associated with the Trump Campaign asked him “to help coordinate with the other 5 contested States, to help with logistics of the electors in other States hopefully joining in casting their votes on Monday.” This was an overt act in furtherance of the conspiracy.

Act 49

On or about the 10th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail with attached documents to DAVID JAMES SHAFER and unindicted co-conspirators Individual 9, Individual 10, and Individual 11, whose identities are known to the Grand Jury. The documents were to be used by Trump presidential elector nominees in Georgia for the purpose of casting electoral votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in Georgia. This was an overt act in furtherance of the conspiracy.

Act 50

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 Trump 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.

Act 51

On or about the 10th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail to Nevada Republican Party Vice Chairman Jim DeGraffenreid. KENNETH JOHN CHESEBRO stated in the e-mail that RUDOLPH WILLIAM LOUIS GIULIANI and other individuals associated with the Trump Campaign asked him “to reach out to you and the other Nevada electors to run point on the plan to have all Trump-Pence electors in all six contested States meet and transmit their votes to Congress on Monday, Dec. 14.” This was an overt act in furtherance of the conspiracy.

Act 52

On or about the 10th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail with attached documents to Jim DeGraffenreid. The documents were to be used by Trump presidential elector nominees in Nevada for the purpose of casting electoral votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in Nevada. This was an overt act in furtherance of the conspiracy.

Act 52

On or about the 10th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail with attached documents to Republican Party of Pennsylvania General Counsel Thomas W. King III. The documents were to be used by Trump presidential elector nominees in Pennsylvania for the purpose of casting electoral votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in Pennsylvania. This was an overt act in furtherance of the conspiracy.

Act 54

On or between the 10th day of December 2020 and the 14th day of December 2020, DAVID JAMES SHAFER contacted unindicted co-conspirator Individual 2, whose identity is known to the Grand Jury, by telephone and discussed unindicted co-conspirator Individual 2's attendance at the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 55

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.

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 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 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. This was an act of racketeering activity under O.C.G.A. § 16- 14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 57

On or about the 11th day of December 2020, DAVID JAMES SHAFER reserved Room 216 at the Georgia State Capitol in Fulton County, Georgia, for the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 58

On or about the 11th day of December 2020, KENNETH JOHN CHESEBRO sent an mail to Jim DeGraffenreid and stated that “the purpose of having the electoral votes sent in to Congress is to provide the opportunity to debate the election irregularities in Congress, and to keep alive the possibility that the votes could be flipped to Trump.” This was an overt act in furtherance of the conspiracy.

Act 59

On or about the 11th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail with attached documents to Greg Safsten and others. The documents were to be used by Trump presidential elector nominees in Arizona for the purpose of casting electoral votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in Arizona. This was an overt act in furtherance of the conspiracy.

Act 60

On or about the 11th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail with attached documents to MICHAEL A. ROMAN and other individuals associated with the Trump Campaign. The documents were to be used by Trump presidential elector nominees in Nevada for the purpose of casting electoral votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in Nevada. This was an overt act in furtherance of the conspiracy.

Act 61

On or about the 11th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail with attached documents to MICHAEL A. ROMAN, unindicted co-conspirator Individual 5, whose identity is known to the Grand Jury, and others. The documents were to be used by Trump presidential elector nominees in Georgia for the purpose of casting electoral votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in Georgia. This was an overt act in furtherance of the conspiracy.

Act 62

On or about the 12th day of December 2020, DAVID JAMES SHAFER contacted unindicted co-conspirator Individual 12, whose identity is known to the Grand Jury, and discussed unindicted co-conspirator Individual 12's attendance at the December 14, 2020, meetingof Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 63

On or about the 12th day 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 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 elector nominees had confirmed that they would attend the December 14, 2020, meetings of Trump presidential elector nominees in their respective states, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in those states. This was an overt act in furtherance of the conspiracy.

Act 64

On or about the 12th day of December 2020, KENNETH JOHN CHESEBRO met with Brian Schimming and discussed the December 14, 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.

Act 65

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.

Act 66

On or about the 12th day of December 2020, unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, sent an e-mail to MICHAEL A. ROMAN and DAVID JAMES SHAFER with updates on the progress of organizing the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia. The e-mail stated which elector nominees had confirmed they would attend the meeting, that other individuals had been secured in case some of the elector nominees refused to participate the meeting, that Georgia legislators had been contacted to ensure access to the Georgia Capitol, and that DAVID JAMES SHAFER had reserved Room 216 for the meeting. This was an overt act in furtherance of the conspiracy.

Act 67

On or about the 12th day December 2020, DAVID JAMES SHAFER sent an email to unindicted co-conspirator Individual 4, whose identity is to the Grand Jury, advising them to “touch base” with each of the Trump presidential elector nominees in Georgia in advance of the December 14, 2020, meeting to confirm their attendance. This was an overt act in furtherance of the conspiracy.

Act 68

On or about the 12th day of December 2020, unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, sent a text message with contact information for unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, and Georgia Senator Brandon Beach to MICHAEL A. ROMAN for the purpose of providing the contact information to RUDOLPH WILLIAM LOUIS GIULIANI. This was an overt act in furtherance of the conspiracy.

Act 69

On or about the 13th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail with attached documents to MICHAEL A. ROMAN. The documents were to be used by Trump presidential elector nominees in New Mexico 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 New Mexico. This was an overt act in furtherance of the conspiracy.

Act 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 ‘President of the Senate’ strategy.” In the e-mail, 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.

Act 71

On or about the 13th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail with attached documents to MICHAEL A. ROMAN and unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury. The documents were to be used by Trump presidential elector nominees in Georgia for the purpose of casting electoral votes for DONALD JOHN TRUMP on December 14, 2020, despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election in Georgia. This was an overt act in furtherance of the conspiracy.

Act 72

On or about the 13th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail to MICHAEL A. ROMAN and unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, and stated that RUDOLPH WILLIAM LOUIS GIULIANI “wants to keep this quiet until after all the voting is done,” in reference to the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 73

On or about the 13th day of December 2020, DAVID JAMES SHAFER sent a text message to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, and stated that unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, would attend the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia, in the place of a Trump presidential elector nominee who refused to participate in the meeting. This was an overt act in furtherance of the conspiracy.

Act 74

On or about the 13th day of December 2020, unindicted co-conspirator Individual 9, whose identity is known to the Grand Jury, sent a text message to DAVID JAMES SHAFER and confirmed that he and unindicted co-conspirator Individual 13, whose identity is known to the Grand Jury, would attend the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 75

On or about the 14th day of December 2020, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, “What a fool Governor @BrianKempGA of Georgia is. Could have been so easy, but now we have to do it the hard way. Demand this clown call a Special Session and open up signature verification, NOW. Otherwise, could be a bad day for two GREAT Senators on January 5th.” This was an overt act in furtherance of the conspiracy.

Act 76

On or about the 14th day of December 2020, DAVID JAMES SHAFER sent a text message to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury that stated, “Listen. Tell them to go straight to Room 216 to avoid drawing attention to what we are doing,” in reference to the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 77

On or about the 14th day 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 of the conspiracy.

Act 78

On or about the 14th day of December 2020, RAY STALLINGS SMITH III and DAVID JAMES SHAFER encouraged certain individuals present at the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia, to sign the document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA.” This was an overt act in furtherance of the conspiracy.

Act 79

On or about the 14th day of December 2020, DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, CATHLEEN ALSTON LATHAM, and unindicted coconspirators 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 IMPERSONATING A PUBLIC OFFICER, in violation of O.C.G.A. § 16-10-23, in Fulton County, Georgia, by unlawfully falsely holding 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.” This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xxiii) and an overt act in furtherance of the conspiracy.

Act 80

On or about the 14th day of December 2020, DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, CATHLEEN ALSTON LATHAM, and unindicted coconspirators 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 FORGERY IN THE FIRST DEGREE, in violation of O.C.G.A. § 16-9-1(b), in Fulton County, Georgia, by, with the intent to defraud, knowingly making a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” a writing other than a check, in such manner that the writing as made purports to have been made by authority of the duly elected and qualified presidential electors from the State of Georgia, who did not give such authority, and uttered and delivered said document to the Archivist of the United States. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xvi) and an overt act in furtherance of the conspiracy.

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Act 81

On or about the 14th day of December 2020, DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, CATHLEEN ALSTON LATHAM, and unindicted coconspirators 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 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 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. § 16-14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 82

On or about the 14th day of December 2020, DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, CATHLEEN ALSTON LATHAM, and unindicted coconspirators 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, attempted to commit the felony offense of FILING FALSE DOCUMENTS, in violation of O.C.G.A. § 16-10-20.1(b)(1), in Fulton County, Georgia, by placing in the United States mail a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” addressed to Chief Judge, U.S. District Court, Northern District of Georgia, 2188 Richard D. Russell Federal Office: Building and U.S. Courthouse, 75 Ted Turner Drive, SW, Atlanta, GA 30303, with intent to knowingly file, enter, and record said document in a court of the United States, having reason to know that said document contained the materially false statement, “WE, THE UNDERSIGNED, being the duly elected and qualified Electors for President and Vice President of the United States of America from the State of Georgia, do hereby certify the following.” This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 83

On or about the 14th day of December 2020, DAVID JAMES SHAFER and SHAWN MICAH TRESHER STILL committed the felony offense of FORGERY IN THE FIRST DEGREE, in violation of O.C.G.A. § 16-9-1(b), in Fulton County, Georgia, by, with the intent to defraud, knowingly making 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. This was an act of racketeering activity under O.C.G.A. § 16-14- 3(5)(A)(xvi) and an overt act in furtherance of the conspiracy.

Act 84

On or about the 14th day 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. § 16-14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 85

On or about the 14th day of December 2020, DAVID JAMES SHAFER instructed unindicted co-conspirator Individual 15, whose identity is known to the Grand Jury, to deliver to the Office of the Governor of Georgia a document signed by DAVID JAMES SHAFER and SHAWN MICAH TRESHER STILL titled “RE: Notice of Filling of Electoral College Vacancy.” The document contained multiple false statements. This was an overt act in furtherance of the conspiracy.

Act 86

On or about the 14th day of December 2020, unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, sent an e-mail to MICHAEL A. ROMAN, unindicted co-conspirator Individual 7, whose identity is known to the Grand Jury, and others that stated, “All votes cast, paperwork complete, being mailed now. Ran pretty smoothly,” in reference to the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 87

On or about the 14th day of December 2020, STEPHEN CLIFFGARD LEE attempted to commit the felony offense of INFLUENCING WITNESSES, in violation of O.C.G.A. § 16- 10-93(b)(1)(A), in Fulton County, Georgia, by traveling to the home of Ruby Freeman, a Fulton County, Georgia, election worker, and speaking to her neighbor, with intent to knowingly engage in misleading conduct toward Ruby Freeman, by purporting to offer her help, and with intent to influence her testimony in an official proceeding in Fulton County, Georgia, concerning events at State Farm Arena in the November 3, 2020, presidential election in Georgia. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xxvii) and an overt act in furtherance of the conspiracy.

Act 88

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. § 16- 10-93(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 of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xxvii) and an overt act in furtherance of the conspiracy.

Act 89

On or between the 15th day of December 2020 and the 4th day of January 2021, STEPHEN CLIFFGARD LEE solicited HARRISON WILLIAM PRESCOTT FLOYD, an individual associated with the organization Black Voices for Trump, to assist with his effort to speak to Ruby Freeman, a Fulton County, Georgia, election worker. STEPHEN CLIFFGARD LEE stated to HARRISON WILLIAM PRESCOTT FLOYD that Freeman was afraid to talk to STEPHEN CLIFFGARD LEE because he was a white man. These were overt acts in furtherance of the conspiracy.

Act 90

On or about the 18th day of December 2020, DONALD JOHN TRUMP met with RUDOLPH WILLIAM LOUIS GIULIANI, SIDNEY KATHERINE POWELL, unindicted co-conspirator Individual 20, whose identity is known to the Grand Jury, and others at the White House. The individuals present at the meeting discussed certain strategies and theories intended to influence the outcome of the November 3, 2020, presidential election, including seizing voting equipment and appointing SIDNEY KATHERINE POWELL as special counsel with broad authority to investigate allegations of voter fraud in Georgia and elsewhere. This was an overt act in furtherance of the conspiracy.

Act 91

On or about the 21st day of December 2020, SIDNEY KATHERINE POWELL sent an e-mail to the Chief Operations Officer of SullivanStrickler LLC and instructed him that she and unindicted co-conspirators Individual 6, Individual 21, and Individual 22, whose identities are known to the Grand Jury, were to immediately “receive a copy of all data” obtained by SullivanStrickler LLC from Dominion Voting Systems equipment in Michigan. This was an overt act in furtherance of the conspiracy.

Act 92

On or about the 22nd day of December 2020, MARK RANDALL MEADOWS traveled to the Cobb County Civic Center in Cobb County, Georgia, and attempted to observe the signature match audit being performed there by law enforcement officers from the Georgia Bureau of Investigation and the Office of the Georgia Secretary of State, despite the fact that the audit process was not open to the public. While present at the center, MARK RANDALL MEADOWS spoke to Georgia Deputy Secretary of State Jordan Fuchs, Office of the Georgia Secretary of State Chief Investigator Frances Watson, Georgia Bureau of Investigation Special Agent in Charge Bahan Rich, and others, who prevented MARK RANDALL MEADOWS from entering into the space where the audit was being conducted. This was an overt act in furtherance of the conspiracy.

Act 93

On or about the 23rd day of December 2020, DONALD JOHN TRUMP placed a telephone call to Office of the Georgia Secretary of State Chief Investigator Frances Watson that had been previously arranged by MARK RANDALL MEADOWS. During the phone call, DONALD JOHN TRUMP falsely stated that he had won the November 3, 2020, presidential election in Georgia “by hundreds of thousands of votes” and stated to Watson that “when the right answer comes out you'll be praised.” This was an overt act in furtherance of the conspiracy.

Act 94

On or about the 23rd day of December 2020, JOHN CHARLES EASTMAN sent an email to KENNETH JOHN CHESEBRO and unindicted co-conspirator Individual 3, whose identity is known to the Grand Jury, with the subject “FW: Draft 2, with edits.” In the e-mail, JOHN CHARLES EASTMAN attached a memorandum titled “PRIVILEGED AND CONFIDENTIAL — Dec 23 memo on Jan 6 scenario.docx” and stated, “As for hearings, I think both are unnecessary. The fact that we have multiple slates of electors demonstrates the uncertainty of either. That should be enough. And I agree with Ken that Judiciary Committee hearings on the constitutionality of the Electoral Count Act could invite counter views that we do not believe should constrain Pence (or Grassley) in the exercise of power they have under the 12th Amendment. Better for them just to act boldly and be challenged, since the challenge would likely lead to the Court denying review on nonjusticiable political question grounds.” This was an overt act in furtherance of the conspiracy.

Act 95

On or about the 25th day of December 2020, DONALD JOHN TRUMP placed a telephone call to Speaker of the Arizona House of Representatives Rusty Bowers for the purpose of soliciting, requesting, and importuning Bowers to unlawfully appoint presidential electors from Arizona. During the call, Bowers stated to Trump, “I voted for you. I worked for you. I campaigned for you. I just won't do anything illegal for you.” This telephone call was an overt act in furtherance of the conspiracy.

Act 96

On or about the 27th day of December 2020, MARK RANDALL MEADOWS sent a text message to Office of the Georgia Secretary of State Chief Investigator Frances Watson that stated in part, “Is there a way to speed up Fulton county signature verification in order to have results before Jan 6 if the trump campaign assist financially.” This was an overt act in furtherance of the conspiracy.

Act 97

On or about the 27th day of December 2020, DONALD JOHN TRUMP solicited Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney General Richard Donoghue to make a false statement by stating, “Just say that the election was corrupt, and leave the rest to me and the Republican congressmen.” This was an overt act in furtherance of the conspiracy.

Act 98

On or about the 28th day of December 2020, JEFFREY BOSSERT CLARK attempted to commit the felony offense of FALSE STATEMENTS AND WRITINGS, in violation of O.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly and willfully making a false writing and document knowing the same to contain the false statement that the United States Department of Justice had “identified significant concerns that may have impacted the outcome of the election in multiple States, including the State 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, JEFFREY BOSSERT CLARK sent an e-mail to Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney General Richard Donoghue and requested authorization to send said false writing and document to Georgia Governor Brian Kemp, Speaker of the Georgia House of Representatives David Ralston, and President Pro Tempore of the Georgia Senate Butch Miller, which constitutes a substantial step toward the commission of False Statements and Writings, O.C.G.A. § 16-10-20. This was an act of racketeering activity under O.C.G.A. § 16-14- 3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 99

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 Attorrney 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.

Act 100

On or about the 30th day of December 2020, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, “Hearings from Atlanta on the Georgia Election overturn now being broadcast. Check it out. @OANN @newsmax and many more. @BrianKempGA should resign from office. He is an obstructionist who refuses to admit that we won Georgia, BIG! Also won the other Swing States.” This was an overt act in furtherance of the conspiracy.

Act 101

On or about the 30th day of December 2020, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, “Hearings from Atlanta on the Georgia Election overturn now being broadcast LIVE via @RSBNetwork! https://t.co/ogBvLbKfqG.” This was an overt act in furtherance of the conspiracy.

Act 102

On or about the 30th day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI, RAY STALLINGS SMITH II, and ROBERT DAVID CHEELEY 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 soliciting, requesting, and importuning certain public officers then serving as elected members of the Georgia Senate and present at a Senate Judiciary Subcommittee meeting, including unindicted co-conspirator Individual 8, whose identity is known to the Grand Jury, Senators Brandon Beach, Bill Heath, William Ligon, Michael Rhett, and Blake Tillery, to engage in conduct constituting the felony 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. This was an overt act in furtherance of the conspiracy.

Act 103

On or about the 30th 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 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. This was an act of racketeering activity under O.C.G.A. § 16- 14-3(5)(A)(xxi) and an overt act in furtherance of the conspiracy.

Act 104

On or about the 30th day of December 2020, RAY STALLINGS SMITH III 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 Senate present at a Senate Judiciary Subcommittee meeting:

1. That Georgia Secretary of State General Counsel Ryan Germany stated that his office had sent letters to 8,000 people who voted illegally in the November 3, 2020, presidential election and told them not to vote in the January 5, 2021, 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. This was an act of racketeering activity under O.C.G.A. § 16- 14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 105

On or about the 30th day of December 2020, ROBERT DAVID CHEELEY 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 Senate present at a Senate Judiciary Subcommittee meeting:

1. That poll watchers and media at State Farm Arena were told late in the evening of November 3, 2020, that the vote count was being suspended until the next morning and to go home because of “a major watermain break”;

2. That Fulton County election workers at State Farm Arena “voted” the same ballots “over and over again” on November 3, 2020;

said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies. This was an act of racketeering activity under O.C.G.A. § 16- 14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 106

On or about the 30th day of December 2020, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, “We now have far more votes than needed to flip Georgia in the Presidential race. Massive VOTER FRAUD took place. Thank you to the Georgia Legislature for today’s revealing meeting!” This was an overt act in furtherance of the conspiracy.  

Act 107

On or about the 31st day of December 2020, JENNA LYNN ELLIS wrote a memorandum titled “Memorandum Re: Constitutional Analysis of Vice President Authority for January 6, 2021 Electoral College Vote Count” to DONALD JOHN TRUMP. The memorandum outlined a strategy for disrupting and delaying the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states, and stated, “the Vice President should therefore not open any of the votes” from six states, including Georgia, that were falsely characterized as having “electoral delegates in dispute.” This was an overt act in furtherance of the conspiracy.

Act 108

On or about the 31st day of December 2020, DONALD JOHN TRUMP and JOHN CHARLES EASTMAN committed the felony offense of FILING FALSE DOCUMENTS, in violation of O.C.G.A. § 16-10-20.1(b)(1), in Fulton County, Georgia, by knowingly filing a document titled “VERIFIED COMPLAINT FOR EMERGENCY INJUNCTIVE AND DECLARATORY RELIEF” in the matter 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;

Earlier on the same day, JOHN CHARLES EASTMAN sent an e-mail to attorneys associated with the Trump Campaign admitting his knowledge that at least some of the allegations in the verified complaint were not accurate. This filing was an act of racketeering activity under O.C.G.A. § 16-14-3(S)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 109

On or about the 1st day of January 2021, KENNETH JOHN CHESEBRO sent an email to JOHN CHARLES EASTMAN and unindicted co-conspirator Individual 3, whose identity is known to the Grand Jury. In the e-mail, KENNETH JOHN CHESEBRO outlined a strategy for disrupting and delaying the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other sates. This was an overt act in furtherance of the conspiracy.  

Act 110

On or about the 2nd day of January 2021, SCOTT GRAHAM HALL, a Georgia bail bondsman, placed a telephone call to JEFFREY BOSSERT CLARK and discussed the November 3, 2020, presidential election in Georgia. The telephone call was 63 minutes in duration. This was an overt act in furtherance of the conspiracy.

Act 111

On or about the 2nd day of January 2021, 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.

Act 112

On or about the 2nd day of January 2021, DONALD JOHN TRUMP and MARK RANDALL MEADOWS 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 Georgia Secretary of State Brad Raffensperger, 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 altering, unlawfully adjusting, and otherwise unlawfully influencing the certified returns for presidential electors for the November 3, 2020, presidential election in Georgia, in willful and intentional violation of the terms of the oath of said person as prescribed by law, with intent that said person engage in said conduct. This was an overt act in furtherance of the conspiracy.  

Act 113

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. § 16- 10-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of the following false statements and representations to Georgia Secretary of State Brad Raffensperger, Georgia Deputy Secretary of State Jordan Fuchs, and Georgia Secretary of State General Counsel Ryan Germany:

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. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 114

On or about the 3rd day of January 2021, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, “I spoke to Secretary of State Brad Raffensperger yesterday about Fulton County and voter fraud in Georgia. He was unwilling, or unable, to answer questions such as the “ballots under table” scam, ballot destruction, out of state 'voters’, dead voters, and more. He has no clue!” This was an overt act in furtherance of the conspiracy.

Act 115

On or about the 3rd day of January 2021, STEPHEN CLIFFGARD LEE, HARRISON WILLIAM PRESCOTT FLOYD, and TREVIAN C. KUTTI placed multiple telephone calls and sent text messages to each other and to other individuals involved in the conspiracy. They include the following:

1. At 7:48 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to Ruby Freeman, a Fulton County, Georgia, election worker, that was unsuccessful.
2. At 7:49 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to Ruby Freeman that was unsuccessful.

3. At 7:49 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to TREVIAN C. KUTTI.

4. At 7:53 p.m., HARRISON WILLIAM PRESCOTT FLOYD sent a text message to Ruby Freeman.

5. At 8:03 p.m., TREVIAN C. KUTTI placed a telephone call to HARRISON WILLIAM PRESCOTT FLOYD.

6. At 8:11 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to unindicted co-conspirator Individual 23, whose identity is known to the Grand Jury.

7. At 8:18 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to STEPHEN CLIFFGARD LEE.

8. At 8:48 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to TREVIAN C. KUTTI.

9. At 9:16 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to TREVIAN C. KUTTI.

10. At 9:33 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to TREVIAN C. KUTTI.

11. At 9:50 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to STEPHEN CLIFFGARD LEE.

These were overt acts in furtherance of the conspiracy.

Act 116

On or about the 4th day of January 2021, TREVIAN C. KUTTI, having been recruited by HARRISON WILLIAM PRESCOTT FLOYD, traveled from Chicago, Illinois, to Atlanta, Georgia, and caused a certain individual, whose identity is known to the Grand Jury, to pick her up from a train station in Fulton County, Georgia, for the purpose of attempting to contact Ruby Freeman, a Fulton County, Georgia, election worker. This was an overt act in furtherance of the conspiracy.

Act 117

On or about the 4th day of January 2021, TREVIAN C. KUTTI traveled to Ruby Freeman's home in Cobb County, Georgia, and attempted to contact her but was unsuccessful. TREVIAN C. KUTTI spoke with Freeman's neighbor and falsely stated that she was a crisis manager attempting to “help” Freeman before leaving Freeman's home. This was an overt act in furtherance of the conspiracy.

Act 118

On or about the 4th day of January 2021, TREVIAN C. KUTTI, while in Fulton County, Georgia, placed a telephone call to Ruby Freeman and stated that Freeman was in danger. TREVIAN C. KUTTI stated that she could “help” Freeman and requested that Freeman meet with and speak to her that night at a Cobb County Police Department precinct in Cobb County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 119

On or about the 4th day of January 2021, TREVIAN C. KUTTI traveled to a Cobb County Police Department precinct in Cobb County, Georgia, and met with and spoke to Ruby Freeman for approximately one hour. HARRISON WILLIAM PRESCOTT FLOYD joined the meeting by telephone. TREVIAN C. KUTTI and HARRISON WILLIAM PRESCOTT FLOYD stated to Freeman that she needed protection and purported to offer her help. This was an overt act in furtherance of the conspiracy.

Act 120

On or about the 4th day of January 2021 STEPHEN CLIFFGARD LEE, HARRISON WILLIAM PRESCOTT FLOYD, and TREVIAN C. KUTTI committed the felony offense of SOLICITATION OF FALSE STATEMENTS AND WRITINGS, in 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. § 16-14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 121

On or about the 4th day of January 2021 STEPHEN CLIFFGARD LEE, HARRISON WILLIAM PRESCOTT FLOYD, and TREVIAN C. KUTTI committed the felony offense of INFLUENCING WITNESSES, in violation of O.C.G.A. § 16-10- 93(b)(1)(A), in Fulton County, Georgia, by knowingly and unlawfully engaging 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 o 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 under O.C.G.A. § 16-14-3(5)(A)(xxvii) and an overt act in furtherance of the conspiracy.

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Act 122

On or about the 4th day of January 2021, STEPHEN CLIFFGARD LEE, HARRISON WILLIAM PRESCOTT FLOYD, and TREVIAN C. KUTTI placed multiple telephone calls and sent text messages to each other and to other individuals involved in the conspiracy. They include the following:

1. At 9:41 a.m., STEPHEN CLIFFGARD LEE placed a telephone call to HARRISON WILLIAM PRESCOTT FLOYD.

2. At 11:24 a.m.. HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to DAVID JAMES SHAFER.

3. At 12:25 p.m., STEPHEN CLIFFGARD LEE placed a telephone call to HARRISON WILLIAM PRESCOTT FLOYD.

4. At 12:32 p.m., STEPHEN CLIFFGARD LEE sent a text message to HARRISON WILLIAM PRESCOTT FLOYD.

5. At 8:10 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to DAVID JAMES SHAFER.

6. At 10:00 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to STEPHEN CLIFFGARD LEE.

7. At 10:19 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to TREVIAN C. KUTTI.

8. At 10:43 p.m., TREVIAN C. KUTTI placed a telephone call to HARRISON WILLIAM PRESCOTT FLOYD.

9. At 11:10 p.m., TREVIAN C. KUTTI placed a telephone call to HARRISON WILLIAM PRESCOTT FLOYD.

10. At 12:12 a.m. on January 5, 2021, TREVIAN C. KUTTI placed a telephone call to HARRISON WILLIAM PRESCOTT FLOYD.

These were overt acts in furtherance of the conspiracy.

Act 123

On or about the 4th day of January 2020, JOHN CHARLES EASTMAN placed a telephone call to Speaker of the Arizona House of Representatives Rusty Bowers and solicited, requested, and importuned Bowers to unlawfully appoint presidential electors from Arizona. During the telephone call, Bowers declined to comply with Eastman’s request and stated that he would not risk violating his oath of office. The request was an overt act in furtherance of the conspiracy.

Act 124

On or about the 4th day of January 2021, KENNETH JOHN CHESEBRO sent an e- mail to JOHN CHARLES EASTMAN with the subject “Fw: Draft 2, with edits” and included within the body of the e-mail another e-mail that KENNETH JOHN CHESEBRO previously sent to RUDOLPH WILLIAM LOUIS GIULIANI with the subject “PRIVILEGEDAND CONFIDENTIAL - Brief notes on ‘President of the Senate’ strategy.” In the e-mail, 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, and stated that the outcomes of any of these strategies were “preferable to allowing the Electoral Count Act to operate by its terms.” This was an overt act in furtherance of the conspiracy.

Act 123 [125]

On or about the 4th day of January 2021, DONALD JOHN TRUMP and JOHN CHARLES EASTMAN met with Vice President Mike Pence, Chief of Staff of the Vice President Marc Short, and Counsel to the Vice President Greg Jacob in the Oval Office at the White House. During the meeting, DONALD JOHN TRUMP and JOHN CHARLES EASTMAN argued to Pence that he could either reject electoral votes from certain states or delay 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, for the purpose of allowing certain state legislatures to unlawfully appoint presidential electors in favor of DONALD JOHN TRUMP. During the meeting, JOHN CHARLES EASTMAN admitted both options violated the Electoral Count Act. This was an overt act in furtherance of the conspiracy.

Act 126

On or about the 5th day of January 2021, JENNA LYNN ELLIS wrote a memorandum titled “Re: Vice President Authority in Counting Electors pursuant to U.S. Constitution and 3 U.S. Code §§ 5 and 15” to an attorney associated with DONALD JOHN TRUMP. The memorandum outlined a strategy for disrupting and delaying the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states, and stated, “the Vice President should begin alphabetically in order of the states, and coming first to Arizona, not open the purported certification, but simply stop the count at that juncture.” This was an overt act in furtherance of the conspiracy.

Act 127

On or about the 5th day of January 2021, ROBERT DAVID CHEELEY, STEPHEN CLIFFGARD LEE, HARRISON WILLIAM PRESCOTT FLOYD, TREVIAN C. KUTTI, and SCOTT GRAHAM HALL placed multiple telephone calls to each other and to other individuals involved in the conspiracy. They include the following:

1. At 11:32 a.m., STEPHEN CLIFFGARD LEE placed a telephone call to TREVIAN C. KUTTI.

2. At 12:14 p.m., HARRISON WILLIAM PRESCOTT FLOYD, TREVIAN C. KUTTI, STEPHEN CLIFFGARD LEE, and unindicted co-conspirator Individual 23, whose identity is known to the Grand Jury, participated in a four-way telephone call.

3. At 12:19 p.m., SCOTT GRAHAM HALL placed a telephone call to ROBERT DAVID CHEELEY.

4. At 12:34 p.m., SCOTT GRAHAM HALL placed a telephone call to ROBERT DAVID CHEELEY.

5. At 1:07 p.m., ROBERT DAVID CHEELEY placed a telephone call to SCOTT GRAHAM HALL.

6. At 1:09 p.m., ROBERT DAVID CHEELEY placed a telephone call to SCOTT GRAHAM HALL.

7. At 2:30 p.m., ROBERT DAVID CHEELEY placed a telephone call to HARRISON WILLIAM PRESCOTT FLOYD.

8. At 2:45 p.m., HARRISON WILLIAM PRESCOTT FLOYD placed a telephone call to ROBERT DAVID CHEELEY.

9. At 3:59 p.m., ROBERT DAVID CHEELEY placed a telephone call to SCOTT GRAHAM HALL.

10. At 4:42 p.m., STEPHEN CLIFFGARD LEE placed a telephone call to ROBERT DAVID CHEELEY.

11. At 4:50 p.m., STEPHEN CLIFFGARD LEE placed a telephone call to HARRISON WILLIAM PRESCOTT FLOYD.

12. At 5:05 p.m., STEPHEN CLIFFGARD LEE placed a telephone call to HARRISON WILLIAM PRESCOTT FLOYD.

13. At 7:19 p.m., TREVIAN C. KUTTI placed a telephone call to ROBERT DAVID CHEELEY.

14. At 7:48 p.m., ROBERT DAVID CHEELEY placed a telephone call to TREVIAN C. KUTTI.

15. At 8:27 p.m., ROBERT DAVID CHEELEY placed a telephone call to TREVIAN C. KUTTI.

16. At 8:49 p.m., ROBERT DAVID CHEELEY placed a telephone call to STEPHEN CLIFFGARD LEE.

17. At 9:18 p.m., SCOTT GRAHAM HALL placed a telephone call to ROBERT DAVID CHEELEY.

18. At 9:31 p.m., TREVIAN C. KUTTI placed a telephone call to ROBERT DAVID CHEELEY.

19. At 10:14 p.m., ROBERT DAVID CHEELEY placed a telephone call to STEPHEN CLIFFGARD LEE.

20. At 11:16 p.m., ROBERT DAVID CHEELEY placed a telephone call to TREVIAN C. KUTTI.

21. At 11:25 p.m., SCOTT GRAHAM HALL placed a telephone call to ROBERT DAVID CHEELEY.

22. At 11:35 p.m., ROBERT DAVID CHEELEY, TREVIAN C. KUTTI, and SCOTT GRAHAM HALL participated in a three-way telephone call.

23. At 12:09 a.m., on January 6, 2021, TREVIAN C. KUTTI placed a telephone call to ROBERT DAVID CHEELEY.

These were overt acts in furtherance of the conspiracy.

Act 128

On or about the 5th day of January 2021, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, “The Vice President has the power to reject fraudulently chosen electors.” This was an overt act in furtherance of the conspiracy.

Act 129

On or about the 5th day of January 2021, JOHN CHARLES EASTMAN met with Chief of Staff to the Vice President Marc Short and Counsel to the Vice President Greg Jacob for the purpose of requesting that Vice President Mike Pence reject slates of presidential electors from Georgia and certain other states during the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states. This was an overt act in furtherance of the conspiracy.

Act 130

On or about the 5th day of January 2021, DONALD JOHN TRUMP met with Vice President Mike Pence in the Oval Office at the White House. During the meeting, DONALD JOHN TRUMP stated that Pence had the power to decertify the November 3, 2020, presidential election results, that people cheated, and that Pence wanted to “play by Marquess of Queensberry rules.” When Pence stated that it was his duty to support and defend the Constitution and that only Congress had the power to decide to reject slates of presidential electors, DONALD JOHN TRUMP stated that Pence was naive, implied that he lacked courage, and stated that Pence was doing “a great disservice.” This was an overt act in furtherance of the conspiracy.

Act 131

On or about the 5th day of January 2021, DONALD JOHN TRUMP placed a telephone call to Vice President Mike Pence. During the telephone call, DONALD JOHN TRUMP and JOHN CHARLES EASTMAN attempted to persuade Pence to reject slates of presidential electors or return the slates of presidential electors to state legislatures. This was an overt act in furtherance of the conspiracy.

Act 132

On or about the 5th day of January 2021, DONALD JOHN TRUMP placed a second telephone call to Vice President Mike Pence. During the telephone call, DONALD JOHN TRUMP asked Pence if he had received a copy of a letter from a group of Pennsylvania legislators urging Congress to return the state’s electoral college votes and stated to Pence, “You gotta be tough tomorrow.” This was an overt act in furtherance of the conspiracy.

Act 133

On or about the 5th day of January 2021, DONALD JOHN TRUMP issued a statement through the Trump Campaign that falsely stated, “The Vice President and I are in total agreement that the Vice President has the power to act... Our Vice President has several options under the U.S. Constitution. He can decertify the results or send them back to the states for change and certification. He can also decertify the illegal and corrupt results and send them to the House of Representatives for the one vote for one state tabulation.” This was an overt act in furtherance of the conspiracy.

Act 134

On or about the 6th day of January 2021, CATHLEEN ALSTON LATHAM placed a telephone call to SCOTT GRAHAM HALL. Several hours later, SCOTT GRAHAM HALL placed a telephone call to CATHLEEN ALSTON LATHAM. During at least one of the phone calls, they discussed SCOTT GRAHAM HALL’s request to assist with the unlawful breach of election equipment at the Coffee County Board of Elections & Registration Office in Coffee County, Georgia. These were overt acts in furtherance of the conspiracy.

Act 135

On or about the 6th day of January 2021, DONALD JOHN TRUMP appeared and spoke at a rally at the Ellipse in Washington, D.C. During the rally, DONALD JOHN TRUMP made false statements concerning fraud in the November 3, 2020, presidential election in Georgia and elsewhere, solicited Vice President Mike Pence to disrupt and delay the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states, and encouraged those in attendance at the rally to march to the United States Capitol. This was an overt act in furtherance of the conspiracy.

Act 136

On or about the 6th day of January 2021, RUDOLPH WILLIAM LOUIS GIULIANI appeared and spoke at a rally at the Ellipse in Washington, D.C. During the rally, RUDOLPH WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3, 2020, presidential election in Georgia and elsewhere and solicited Vice President Mike Pence to disrupt and delay the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states. This was an overt act in furtherance of the conspiracy.

Act 137

On or about the 6th day of January 2021, JOHN CHARLES EASTMAN appeared and spoke at a rally at the Ellipse in Washington, D.C. During the rally, JOHN CHARLES EASTMAN made false statements concerning fraud in the November 3, 2020, presidential election and solicited Vice President Mike Pence to disrupt and delay the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states. This was an overt act in furtherance of the conspiracy.

Act 138

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 the conspiracy.

Act 139

On or about the 6th day of January 2021, DONALD JOHN TRUMP caused to be tweeted from the Twitter account @RealDonaldTrump, “States want to correct their votes, which they now know were based on irregularities and fraud, plus corrupt process never received legislative approval. All Mike Pence has to do is send them back to the States, AND WE WIN. Do it Mike, this is a time for extreme courage!” This was an overt act in furtherance of the conspiracy.

Act 140

On or about the 6th day of January 2021, DONALD JOHN TRUMP placed a telephone call to Vice President Mike Pence and solicited him to disrupt and delay 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. When Pence refused, DONALD JOHN TRUMP stated that Pence would “go down as a wimp" and that Pence was not protecting the United States. This was an overt act in furtherance of the conspiracy.

Act 141

On or about the 6th day of January 2021, JOHN CHARLES EASTMAN sent an e- mail to Counsel to the Vice President Greg Jacob that sated:

“The Senate and House have both violated the Electoral Count Act this evening — they debated the Arizona objections for more than 2 hours. Violation of 3 USC 17. And the VP allowed further debate or statements by leadership after the question had been voted upon. Violation of 3 USC 17.” And they had that debate upon motion approved by the VP, in violation of the requirement in 3 USC 15 that after the vote in the separate houses, ‘they shall immediately again meet.'

So now that the precedent has been set that the Electoral Count Act is not quite so sacrosanct as was previously claimed, I implore you to consider one more relatively minor violation and adjourn for 10 days to allow the legislatures to finish their investigations, as well as to allow a full forensic audit of the massive amount of illegal activity that has occurred here. If none of that moves the needle, at least a good portion of the 75 million people who supported President. Trump will have seen a process that allowed the illegality to be aired.

John”

This was an overt act in furtherance of the conspiracy.

Act 142

On or about the 7th day of January 2021, CATHLEEN ALSTON LATHAM sent a text message to the Chief Operations Officer of SullivanStrickler LLC with the address for the Douglas Municipal Airport in Coffee County, Georgia, to coordinate picking up SCOTT GRAHAM HALL from the airport and driving him to the Coffee County Board of Elections & Registration Office for the purpose of assisting with the unlawful breach of election equipment at the Coffee County Board of Elections & Registration Office. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(B) and an overt act in furtherance of the conspiracy.

Act 143

On or about the 7th day of January 2021, SCOTT GRAHAM HALL and unindicted co-conspirator Individual 24, whose identity is known to the Grand Jury, flew from DeKalb- Peachtree Airport in DeKalb County, Georgia, to Douglas Municipal Airport in Coffee County, Georgia, for the purpose of assisting with the unlawful breach of election equipment at the Coffee County Board of Elections & Registration Office. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(B) and an overt act in furtherance of the conspiracy.

Act 144

On or about the 7th day of January 2021, SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON committed the felony offense of INTERFERENCE WITH PRIMARIES AND ELECTIONS, in violation of O.C.G.A. § 212-566, in Coffee County, Georgia, by willfully and unlawfully tampering with electronic ballot markers and tabulating machines in Coffee County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 145

On or about the 7th day of January 2021, SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON committed the felony offense of UNLAWFUL POSSESSION OF BALLOTS, in violation of O.C.G.A. § 21-2-574, in Coffee County, Georgia, by 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 in Coffee County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 146

On or about the 7th day of January 2021, SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON committed the felony offense of COMPUTER THEFT, in violation of O.C.G.A. § 16-9-93(a), in Coffee County, Georgia, by 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 in Coffee County, Georgia. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xix) and an overt act in furtherance of the conspiracy.

Act 147

On or about the 7th day of January 2021, SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON committed the felony offense of COMPUTER TRESPASS, in violation of O.C.G.A. § 16-9- 93(b), in Coffee County, Georgia, by 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 in Coffee County, Georgia. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xix) and an overt act in furtherance of the conspiracy.

Act 148

On or about the 7th day of January 2021, SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON committed the felony offense of COMPUTER INVASION OF PRIVACY, in violation of O.C.G.A. § 16-9-93(c), in Coffee County, Georgia, by using a computer with the intention of examining personal voter data with knowledge that such examination was without authority. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xix) and an overt act in furtherance of the conspiracy.

Act 149

On and between the 6th day of December 2020 and the 7th day of January 2021, SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON committed the felony offense of CONSPIRACY TO DEFRAUD THE STATE, in violation of O.C.G.A. § 16-10-21, in Coffee County, Georgia, by unlawfully conspiring and agreeing 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. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(B) and an overt act in furtherance of the conspiracy.

Act 150

On or about the 9th day of January 2021, the 10th day of January 2021, the 11th day of January 2021, and the 13th day of January 2021, unindicted co-conspirator Individual 25, whose identity is known to the Grand Jury, unlawfully accessed certain data copied from Dominion Voting Systems equipment at the Coffee County Board of Elections & Registration Office in Coffee County, Georgia, by downloading said data from a server maintained by SullivanSitrickler LLC. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(B) and an overt act in furtherance of the conspiracy.

Act 151

On or about the 9th day of January 2021, the 10th day of January 2021, the 11th day of January 2021, the 18th day of January 2021, and the 19th day of January 2021, unindicted co-conspirator Individual 26, whose identity is unknown to the Grand Jury, unlawfully accessed certain data copied from Dominion Voting Systems equipment at the Coffee County Board of Elections & Registration Office in Coffee County, Georgia, by downloading said data from a server maintained by SullivanStrickler LLC. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(B) and an overt act in furtherance of the conspiracy.

Act 152

On or about the 10th day of January 2021, the 12th day of January 2021, the 13th day of January 2021, the 25th day of February 2021, and the 26th day of February 2021, unindicted co-conspirator Individual 27, whose identity is unknown to the Grand Jury, unlawfully accessed certain data copied from Dominion Voting Systems equipment at the Coffee County Board of Elections & Registration Office in Coffee County, Georgia, by downloading said data from a server maintained by SullivanStrickler LLC. This was an act of racketeering. activity under O.C.G.A. § 16-14-3(5)(B) and an overt act in furtherance of the conspiracy.

Act 153

On or about the 13th day of January 2021, unindicted co-conspirator Individual 28, whose identity is known to the Grand Jury, unlawfully accessed certain data copied from Dominion Voting Systems equipment at the Coffee County Board of Elections & Registration Office in Coffee County, Georgia, by downloading said data from a server maintained by SullivanStrickler LLC. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(B) and an overt act in furtherance of the conspiracy.

Act 154

On or about the 18th day of January 2021, MISTY HAMPTON allowed unindicted coconspirators Individual 25 and Individual 29, whose identities are known to the Grand Jury, to access non-public areas of the Coffee County Board of Elections & Registration Office in Coffee County, Georgia, and facilitated their access to Dominion Voting Systems equipment. This was an overt act in furtherance of the conspiracy.

Act 155

On or about the 22nd day of April 2021, unindicted co-conspirator Individual 28, whose identity is known to the Grand Jury, sent an e-mail to the Chief Operations Officer of SullivanStrickler LLC directing him to transmit all data copied from Dominion Voting Systems equipment at the Coffee County Board of Elections & Registration Office in Coffee County, Georgia, to unindicted co-conspirator Individual 30, whose identity is known to the Grand Jury, an attorney associated with SIDNEY KATHERINE POWELL and the Trump Campaign. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(B) and an overt act in furtherance of the conspiracy.

Act 156

On or about the 17th day of September 2021, DONALD JOHN TRUMP committed the felony offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, in violation of O.C.G.A. §§ 16-4-7 and 16-10-1, in Fulton County, Georgia, by unlawfully soliciting, requesting, and importuning Georgia Secretary of State Brad Raffensperger, a public officer, to engage in conduct constituting the felony offense of Violation of Oath by Public 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. This was an overt act in furtherance of the conspiracy.

Act 157

On or about the 17th day of September 2021, DONALD JOHN TRUMP 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 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 irregular 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 Sate and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies. This was an act of racketeering activity under O.C.G.A. § 16- 14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.


Act 158

On or about the 25th day of April 2022, DAVID JAMES SHAFER 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 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 Attorney's Office, a department and agency of the government of county of this state. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.

Act 159

On or about the 7th day of May 2022, SIDNEY KATHERINE POWELL made at least one of the following false statements and representations in a sworn deposition with the United States House of Representatives Select Committee to Investigate the January 6th Attack on the United States Capitol:

1. That she “didn’t have any role in really setting up” efforts to access voting machines in Coffee County, Georgia, or Antrim County, Michigan;

2. That she was aware there was an “effort by some people” to get access to voting machines in Georgia but that she did not “know what happened with that” and did not “remember whether that was Rudy or other folks.”

Act 160

On or about the 1st day of September 2022, CATHLEEN ALSTON LATHAM committed the felony offense of PERJURY, in violation of O.C.G.A. § 16-10-70(a), in Houston County, Georgia, by knowingly, willfully, and unlawfully making at least one of the following false statements in a deposition in the matter of Curling v. Raffensperger, Case 1:17-cv-02989- AT in the United States District Court for the Northern District of Georgia, a judicial proceeding, after having been administered a lawful oath:

1. That she was only present at the Coffee County Board of Elections & Registration Office in Coffee County, Georgia, for “just a few minutes” on January 7, 2021;

2. That she only “walked into the front part” of the Coffee County Board of Elections & Registration Office on January 7, 2021, and “didn’t go into the office”;

3. That she had “no idea” if employees of SullivanStrickler met Eric Chaney at the Coffee County Board of Elections & Registration Office on January 7, 2021;

4. That she did not see Misty Hampton at the Coffee County Board of Elections & Registration Office on January 7, 2021;

5. That her only interaction with Scott Hall at the Coffee County Board of Elections & Registration Office on January 7, 2021, was meeting him, speaking to him outside of the office, and then leaving the office;

6. That she did not see Scott Hall speak to anyone other than herself at the Coffee County Board of Elections & Registration Office on January 7, 2021;

said statements being material to the accused’s own involvement in the January 7, 2021, unlawful breach of election equipment at the Coffee County Board of Elections & Registration Office and to the accused's communications with others involved, the issues in question. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xxv) and an overt act in furtherance of the conspiracy.


Act 161

On or about the 15th day of September 2022, ROBERT DAVID CHEELEY committed the felony offense of PERJURY, in violation of O.C.G.A. § 16-10-70(a), in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of the following false statements before the Fulton 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 the meeting, the issues in question. This was an act of racketeering activity under O.C.G.A. § 16-14-3(5)(A)(xxv) and an overt act in furtherance of the conspiracy.

***

“The acts set forth above were committed in furtherance of the conspiracy alleged above and had the same and similar intents, results, accomplices, victims, and methods of commission and otherwise were interrelated by distinguishing characteristics and were not isolated acts.

[admin]

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