Trump Indictment

Ge

Fulton County Superior Court

INDICTMENT

**FI LE D**-CA----------- T--------Date: August 14, 2023

Che Alexander, Clerk of Court

Clerk No. 4

FULTON SUPERIOR COURT

THE STATE OF GEORGIA

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

JEFFREY BOSSERT CLARK

Counts 1, 22

<7

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20

JENNA LYNN ELLIS

Counts 1-2

g

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

IMPERSONATING A PUBLIC OFFICER

O.C.G.A. § 16-10-23

RAY STALLINGS SMITH HI

Counts 1-2, 4, 6, 9, 11, 13, 15, 17, 19,

23,25

9

CONSPIRACY TO COMMIT

IMPERSONATING A PUBLIC OFFICER

O.C.G.A. §§ 16-4-8 & 16-10-23

ROBERT DAVID CHEELEY

Counts 1,9, 11, 13, 15, 17, 19,23,26,

41

10

FORGERY IN THE FIRST DEGREE

MICHAEL A. ROMAN

Countsl, 9, 11, 13, 15, 17, 19

DAVID JAMES SHAFER

Counts 1,8, 10, 12, 14,16,18, 40

O.C.G.A. § 16-9-1(b)

..



CONSPIRACY TO COMMIT

FORGERY IN THE FIRST DEGREE

O.C.G.A. §§ 16-4-8 & 16-9-1(b)

SHAWN MICAH TRESHER STILL

Counts 1, 8, 10, 12, 14, 16, 18

12

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20

STEPHEN CLIFFGAR1) LEE

Counts 1,20-21, 30-31

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)(l)

15

CONSPIRACY TO COMMIT

FIFING FALSE DOCUMENTS

O.C.G.A. §§ 16-4-8 & 16-10-20.1(b)(1)

16

FORGERY IN THE FIRST DEGREE

HARRISON WILLIAM PRESCOTT

FLOYD

Counts 1, 30-31

TREVIAN C. KUTTI

Counts 1, 30-31

SIDNEY KATHERINE POWELL

Counts 1, 32-37

CATHLEEN ALSTON LATHAM

Counts 1, 8, 10, 12, 14, 32-37

O.C.G.A. 6 16-9-l(b)

17

SCOTT GRAHAM HALL

Counts 1, 32-37

MISTY HAMPTON

AKA EMILY MISTY HAYES

Counts 1, 32-37

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. 8 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

2

26

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20

27

FILING FALSE DOCUMENTS

O.C.G.A. § 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 COMMIT

COMPUTER 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

3

TABLE OF CONTENTS

COUNT 1:

A

VIOLATION OF THE GEORGIA RICO

(RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS) ACT

O.C.G.A. § 16-14-4(c)............................................................................................... 13

Introduction................................................................................................................. 14

The Enterprise.............................................................................................................15

Manner and Methods of the Enterprise.................................................................... 16

Acts of Racketeering Activity and Overt Acts in Furtherance of the

Conspiracy..................................................................................................................20

COUNT 2:

SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER

O.C.G.A. §§ 16-4-7 & 16-10-1.................................................................................72

COUNT 3:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20.................................................................................................. 72

COUNT 4:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20.................................................................................................. 73

COUNT 5:

SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER,

O.C.G.A. §§ 16-4-7 & 16-10-1.................................................................................74

COUNT 6:

SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER

O.C.G.A. §§ 16-4-7 & 16-10-1.................................................................................74

COUNT 7:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20.................................................................................................. 75

COUNT 8:

IMPERSONATING A PUBLIC OFFICER

O.C.G.A. § 16-10-23.................................................................................................. 76

COUNT 9:

CONSPIRACY TO COMMIT IMPERSONATING A PUBLIC OFFICER

O.C.G.A. §§ 16-4-8 & 16-10-23...............................................................................76

COUNT 10:

FORGERY IN THE FIRST DEGREE

O.C.G.A. § 16-9-l(b)................................................................................................. 77

COUNT 11:

CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE

O.C.G.A. §§ 16-4-8 & 16-9-l(b)..............................................................................77

COUNT 12:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20.................................................................................................. 78

COUNT 13:

CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS

O.C.G.A. §§ 16-4-8 & 16-10-20...............................................................................78

10

COUNT 14:

CRIMINAL ATTEMPT TO COMMIT FILING FALSE DOCUMENTS

O.C.G.A. §§ 16-4-1 & 16-10-20.1(b)(l).................................................................79

COUNT 15:

CONSPIRACY TO COMMIT FILING FALSE DOCUMENTS

O.C.G.A. §§ 16-4-8 & 16-10-20.1(b)(1).................................................................79

COUNT 16:

FORGERY IN THE FIRST DEGREE

O.C.G.A. § 16-9-l(b).................................................................................................80

COUNT 17:

CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE

O.C.G.A. §§ 16-4-8 & 16-9-l(b)..............................................................................80

COUNT 18:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20.................................................................................................. 81

COUNT 19:

CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS

O.C.G.A. §§ 16-4-8 & 16-10-20...............................................................................81

COUNT 20:

CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES

O.C.G.A. §§ 16-4-1 & 16-10-93 (b)(1)(A)..............................................................82

COUNT 21:

CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES

O.C.G.A. §§ 16-4-1 & 16-10-93(b)(l)(A)...............................................................82

COUNT 22:

CRIMINAL ATTEMPT TO COMMIT

FALSE STATEMENTS AND WRITINGS

O.C.G.A. §§ 16-4-1 & 16-10-20...............................................................................83

COUNT 23:

SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER

O.C.G.A. §§ 16-4-7 & 16-10-1.................................................................................84

COUNT 24:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20.................................................................................................. 84

COUNT 25:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20.................................................................................................. 85

COUNT 26:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20.................................................................................................. 85

COUNT 27:

FILING FALSE DOCUMENTS

O.C.G.A. § 16-10-20.1(b)(1).................................................................................... 86

COUNT 28:

SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER

O.C.G.A. §§ 16-4-7 & 16-10-1.................................................................................87

11

COUNT 29:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20.................................................................................................. 88

COUNT 30:

CONSPIRACY TO COMMIT SOLICITATION OF

FALSE STATEMENTS AND WRITINGS

O.C.G.A. §§ 16-4-8,16-4-7, & 16-10-20................................................................89

COUNT 31:

INFLUENCING WITNESSES

O.C.G.A. § 16-10-93(b)(l)(A) ..................................................................................89

COUNT 32:

CONSPIRACY TO COMMIT ELECTION FRAUD

O.C.G.A. §§ 21-2-603 & 21-2-566.......................................................................... 90

COUNT 33:

CONSPIRACY TO COMMIT ELECTION FRAUD

O.C.G.A. §§ 21-2-603 & 21-2-574.......................................................................... 91

COUNT 34:

CONSPIRACY TO COMMIT COMPUTER THEFT

O.C.G.A. §§ 16-4-8 & 16-9-93(a)........................................................................... 92

COUNT 35:

CONSPIRACY TO COMMIT COMPUTER TRESPASS

O.C.G.A. §§ 16-4-8 & 16-9-93(b)........................................................................... 93

COUNT 36:

CONSPIRACY TO COMMIT COMPUTER INVASION OF PRIVACY

O.C.G.A. §§ 16-4-8 & 16-9-93(c)........................................................................... 94

COUNT 37:

CONSPIRACY TO DEFRAUD THE STATE

O.C.G.A. § 16-10-21.................................................................................................. 95

COUNT 38:

SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER

O.C.G.A. §§ 16-4-7 & 16-10-1.................................................................................95

COUNT 39:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20..................................................................................................96

COUNT 40:

FALSE STATEMENTS AND WRITINGS

O.C.G.A. § 16-10-20.................................................................................................. 96

COUNT 41:

PERJURY

O.C.G.A. § 16-10-70(a)............................................................................................. 97

12

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;

13

INTRODUCTION

Defendant Donald John Trump lost the United States presidential election held on

November 3, 2020. One of the states he lost was Georgia. Trump and the other Defendants

charged in this Indictment refused to accept that Trump lost, and they knowingly and willfully

joined a conspiracy to unlawfully change the outcome of the election in favor of Trump. That

conspiracy contained a common plan and purpose to commit two or more acts of racketeering

activity in Fulton County, Georgia, elsewhere in the State of Georgia, and in other states.



14

THE ENTERPRISE

At all times relevant to this Count of the Indictment, the Defendants, as well as others not

named as defendants, unlawfully conspired and endeavored to conduct and participate in a

criminal enterprise in Fulton County, Georgia, and elsewhere. Defendants Donald John Trump,

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, 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.



15

MANNER AND METHODS OF THE ENTERPRISE

The manner and methods used by the Defendants and other members and associates of

the enterprise to further the goals of the enterprise and to achieve its purposes included, but were

not limited to, the following:

1. False Statements to and Solicitation of State Legislatures

Members of the enterprise, including several of the Defendants, appeared at hearings in

Fulton County, Georgia, before members of the Georgia General Assembly on December 3,

2020, December 10, 2020, and December 30, 2020. At these hearings, members of the enterprise

made false statements concerning fraud in the November 3, 2020, presidential election. The

purpose of these false statements was to persuade Georgia legislators to reject 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,

16

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.



17

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

Members of the enterprise, including several of the Defendants, corruptly solicited highranking United States Department of Justice officials to make false statements to government

officials in Fulton County, Georgia, including the Governor, the Speaker of the House of

Representatives, and the President Pro Tempore of the Senate. In one instance, Donald Trump

stated to the Acting United States Attorney General, “Just say that the election was corrupt, and

leave the rest to me and the Republican congressmen.”

6. Solicitation of the Vice President of the United States

Members of the enterprise, including several of the Defendants, corruptly solicited the

Vice President of the United States to violate the United States Constitution and federal law by

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.



18

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 peijury injudicial

proceedings in Fulton County, Georgia, and elsewhere in furtherance of and to cover up the

conspiracy.



19

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 8 3-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.

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.



20

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.



21

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.

Act 11.



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 12.

On or about the 27th day of November 2020, RUDOLPH WILLIAM LOUIS

GIULIANI and JENNA LYNN ELLIS placed a telephone call to President Pro Tempore of the

Pennsylvania Senate Jake Corman for the purpose of soliciting, requesting, and importuning

Corman to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in

furtherance of the conspiracy.



22

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.

s

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.



23

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 Kareri 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.



24

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. §§ 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 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. § 1614-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.



25

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. § 1614-3(5)(A)(xxii) 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.



26

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. Governor @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.



27

Act 34.

On or about the 6th day of December 2020, ROBERT DAVID CHEELEY sent an email 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 email 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 stated, “I assume you can make sure this happens.” This was an overt act in

furtherance of the conspiracy.



Act 37.



On or about the 7th day 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.



28

Act 38.

On or about the 7th 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.



29

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 A. 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.



30

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 co­

conspirator Individual 9, whose identity is known to the Grand Jury. KENNETH JOHN

CHESEBRO stated in the e-mail that certain individuals associated with the Trump Campaign

asked him “to help coordinate with the other 5 contested States, to help with logistics of the

electors in other States hopefully joining in casting their votes on Monday.” This was an overt

act in furtherance of the conspiracy.



Act 48.

On or about the 10th day 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 49.

On or about the 10th day of December 2020, KENNETH JOHN CHESEBRO sent an

e-mail with attached documents to Arizona Republican Party Executive Director Greg Safsten

and others. The documents were to be used by Trump presidential elector nominees in Arizona

for the purpose of casting electoral votes for DONALD JOHN TRUMP on December 14, 2020,

despite the fact that DONALD JOHN TRUMP lost the November 3, 2020, presidential election

in Arizona. This was an overt act in furtherance of the conspiracy.



31

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.



32

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-}, 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 Bums, Barry Fleming, Todd Jones, Bee Nguyen, Mary

Margaret Oliver, Alan Powell, Renitta Shannon, Robert Trammell, Scot Turner, and Bruce

Williamson, to engage in conduct constituting the felony offense of Violation of Oath by Public

Officer, O.C.G.A. § 16-10-1, by unlawfully appointing presidential electors from Georgia, in

willful and intentional violation of the terms of the oath of said persons as prescribed by law,

with intent that said persons engage in said conduct. This was an overt act in furtherance of the

conspiracy.



33

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. § 1614-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.



34

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

e-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.



35

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,

meeting of 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 Trump Campaign to populate entries on a shared spreadsheet listing Trump

presidential elector nominees in Georgia, Arizona, Michigan, Nevada, Pennsylvania, and

Wisconsin. The entries on the spreadsheet included contact information for the Trump

presidential elector nominees, whether the Trump presidential elector nominees had been

contacted, and whether the Trump presidential elector nominees had confirmed that they would

attend the December 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.



36

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 in the meeting, that

Georgia legislators had been contacted to ensure access to the Georgia Capitol, and that DAVID

JAMES SHAFER had reserved Room 216 for the meeting. This was an overt act in furtherance

of the conspiracy.



Act 67.

On or about the 12th day of December 2020, DAVID JAMES SHAFER sent an e-mail

to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, advising

them to “touch base” with each of the Trump presidential elector nominees in Georgia m 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.



37

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.



38

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.



39

Act 79.



On or about the 14th day of December 2020, DAVID JAMES SHAFER, SHAWN

MICAH TRESHER STILL, CATHLEEN ALSTON LATHAM, and unindicted co­

conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual 11, Individual 12,

Individual 13, Individual 14, Individual 15, Individual 16, Individual 17, Individual 18, and

Individual 19, whose identities are known to the Grand Jury, committed the felony offense of

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 co­

conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual 11, Individual 12,

Individual 13, Individual 14, Individual 15, Individual 16, Individual 17, Individual 18, and

Individual 19, whose identities are known to the Grand Jury, committed the felony offense of

FORGERY IN THE FIRST DEGREE, in violation of O.C.G.A. § 16-9-l(b), in Fulton

County, Georgia, by, with the intent to defraud, knowingly making a document titled

“CERTIFICATE OF THE VOTES OF TFIE 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.



40

Act 81.

On or about the 14th day of December 2020, DAVID JAMES SHAFER, SHAWN

MICAH TRESHER STILL, CATHLEEN ALSTON LATHAM, and unindicted co­

conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual 11, Individual 12,

Individual 13, Individual 14, Individual 15, Individual 16, Individual 17, Individual 18, and

Individual 19, whose identities are known to the Grand Jury, committed the felony offense of

FALSE STATEMENTS AND WRITINGS, in 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 co­

conspirators Individual 2, Individual 8, Individual 9, Individual 10, Individual 11, Individual 12,

Individual 13, Individual 14, Individual 15, Individual 16, Individual 17, Individual 18, and

Individual 19, whose identities are known to the Grand Jury, attempted to commit the felony

offense of FILING FALSE DOCUMENTS, in violation of O.C.G.A. § 16-10-20.1(b)(l), 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.



41

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-l(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. § 16-143(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.



42

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. § 1610-93(b)(l)(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. § 1610-93(b)(l)(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.



43

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.



44

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. § 16-143(5)(A)(xxii) and an overt act in furtherance of the conspiracy.



45

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 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 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 in, 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.



46

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. § 1614-3(5)(A)(xxii) 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. § 1614-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.



47

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. § 1614-3(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.



48

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)(l), 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 “[djeliberate 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(5)(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 states. This was an overt act in furtherance of the conspiracy.



49

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.



50

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. § 1610-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of

the following false statements and representations to Georgia Secretary of State Brad

Raffensperger, Georgia Deputy Secretary of State Jordan Fuchs, and Georgia Secretary of State

General Counsel Ryan Germany:

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;

51

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.



52

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.



53

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.



54

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. § 16-1093(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 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

under O.C.G.A. § 16-14-3 (5)(A)(xxvii) and an overt act in furtherance of the conspiracy.



55

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.



56

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 email to JOHN CHARLES EASTMAN with the subject “Fwd: 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 “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, 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.



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 to 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.



57

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.



58

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.



59

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.



60

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.



61

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.



62

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.



63

Act 141.

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

“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 DeKalbPeachtree 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.



64

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. § 21-2-566, 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. § 16-993(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.



65

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

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 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.



66

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 co­

conspirators 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.



67

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. § 1610-20, 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 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. § 1614-3(5)(A)(xxii) and an overt act in furtherance of the conspiracy.



68

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. § 1610-20, in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of

the following false statements and representations in the presence of Fulton County District

Attorney’s Office investigators:

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 a 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.”

This was an overt act in furtherance of the conspiracy.



69

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-02989AT 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.



70

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.



71

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;

72

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 HI 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;

73

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.GA. § 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 Bums, 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.GA. § 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;

74

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;

75

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;

76

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-l(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. §§ 16-4-8

& 16-9-l(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;

77

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. §§ 164-8 & 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;

78

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. §§ 16-4-1 & 16-10-20.1(b)(l), 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(b)(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 & 1610-20.1(b)(l), 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;

79

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-l(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

& 16-9-l(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;

80

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. §§ 164-8 & 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 “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;

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;

81

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 & 16-1093(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)(l)(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)(l)(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 & 16-1093(b)(1)(A), for the said accused, in the County of Fulton and State of Georgia, on the 15th day

of December 2020, unlawfully, with intent to commit the crime of Influencing Witnesses,

O.C.G.A. § 16-10-93(b)(l)(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)(l)(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;

82

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. § 172-1(b)(2), contrary to the laws of said State, the good order, peace and dignity thereof;

83

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 State, 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;

84

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 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, 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

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, contrary to the laws of said State, the good order, peace and

dignity thereof;

85

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)(l), 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 titled “VERIFIED

COMPLAINT FOR EMERGENCY INJUNCTIVE AND DECLARATORY RELIEF” in the

matter of Trump v. Kemp, Case l: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 “[deliberate 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;

86

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, a public officer, to engage in

conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. §1610-1, 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;

87

COUNT 29 of 41

And the Grand Jurors aforesaid, m 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;

88

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. §§ 16-4-8,16-47, & 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)(l)(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;

89

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;

90

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;

91

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), 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 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;

92

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;

93

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. §§ 16-4-8 & 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;

94

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 Raffensperger, 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 State, 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 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, contrary to the laws of said State, the good order, peace and

dignity thereof;

95

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 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 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 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 Attorney’s 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;

96

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 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 said meeting, the issues in question, contrary to the laws

of said State, the good order, peace and dignity thereof.



FANIT. WILLIS, District Attorney

97

WITNESS LIST

Asst Chief Inv. M. Hill - FCDADA14

Sr. Inv. T. Swanson-Lucas - FCDA DA72

98