Crime Stories with Nancy Grace - Former President Donald Trump Indicted, part 1 of 3

Episode Date: August 18, 2023

Former President Donald Trump has been indicted by a Georgia grand jury. Eighteen allies are also facing state charges stemming from efforts to overturn Trump's 2020 electoral defeat in the state.  The 41-count indictment  is the fourth criminal case that Trump is facing. Listen to part one of the verbatim reading of the document. See omnystudio.com/listener for privacy information.

This is an iHeart Podcast. Crime Stories with Nancy Grace. Page 10, Table of Contents. Count 1, Violation of the Georgia RICO, Racketeer Influenced and Corrupt Organizations Act. Page 13. Introduction, page 14. The Enterprise, page 15. Manner and methods of the Enterprise, page 16. Acts of racketeering activity and overt acts in furtherance of the conspiracy, page 20. Count two, solicitation of violation of oath by public officer, page 72. Count 3, false statements and writings, page 72.

Count 4, false statements and writings, page 73. Count 5, solicitation of violation of oath by public officer, page 74. Count 6, solicitation of violation of oath by public officer, page 74. Count 7, false statements and writings, page 75. Count 8, impersonating a public officer, page 74. Count seven, false statements and writings, page 75. Count eight, impersonating a public officer, page 76. Count nine, conspiracy to commit impersonating a public officer, page 76. Count 10, forgery in the first degree, page 77. Count 11, conspiracy to commit forgery in the first degree, page 77. Count 12, false statements and writings, page 78. Count 13, conspiracy to commit false statements and writings, page 78. Page 11. Count 14, criminal attempt to commit filing false documents, page 79. Count 15, conspiracy to commit filing false documents,

page 79. Count 16, forgery in the first degree, page 80. Count 17, conspiracy count 16 forgery in the first degree page 80 count 17 conspiracy to commit forgery in the first degree page 80. count 18 false statements and writings page 81 count 19 conspiracy to commit false statements and writings page 81 count 20 criminal attempt to commit influencing witnesses page 82. count 21 criminal attempt to commit influencing witnesses, page 82. Count 21, criminal attempt to commit influencing witnesses, page 82. Count 22, criminal attempt to commit false statements and writings, page 83. Count 23, solicitation of violation of oath by public officer, page 84. Count 24, false statements and writings, page 84. Count 25, false statements and writings, page 85 count 25 false statements and writings page 85. count 26 false statements and writings page 85. count 27 filing false documents page 86. count 28 solicitation of

violation of oath by public officer page 87. page 12. count 29 false statements and writings page 88. count 30 conspiracy to commit solicitation of false statements and writings, page 89. Count 31, influencing witnesses, page 89. Count 32, conspiracy to commit election fraud, page 90. Count 33, conspiracy to commit election fraud, page 91. Count 34, conspiracy to commit computer theft, page 92. Count 35, conspiracy to commit computer trespass, page 93. Count 36, conspiracy to commit computer invasion of privacy, page 94.

Count 37, conspiracy to defraud the state, page 95. Count 38, solicitation of violation of oath by public officer, page 95. Count 39, false statements and writings, page 96. Count 40, false statements and writings, page 96. Count 41, perjury, page 97. Page 13, count 1 of 41. The grand jurors aforesaid in the name and behalf of the citizens of Georgia do hear my charge and accuse Donald John Trump, Rudolph William Louis Giuliani, John Charles Eastman, Mark Randall Meadows, Kenneth John Cheesebro, Jeffrey Bozart Clark, Jenna Lynn Ellis, Ray Stalling Smith III, Robert David

Cheely, Michael A. Roman, David James Schaefer, Sean Micah Tresher Still, Stephen Cliffguard Lee, Harrison William Prescott Floyd, Trevian C. Cuddy, Sydney Catherine Powell, Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton. With the offense of violations of the Georgia RICO, Racketeer Influenced and Corrupt Organizations Act, 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 OCGA 16-14-4B, 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. Page 14, Introduction. Defendant Donald John Trump lost the United States presidential election held on November 3rd, 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. Page 15. 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 Cheesebro, Jeffrey Bozart Clark, Jenna Lynn Ellis, Ray Stalling Smith III, Robert David Shealy, Michael A. Roman, David James Schaefer, Sean Micah Treasure Still, Stephen Cliffguard Lee, Harrison William Prescott Floyd, Trevian C. Cuddy, Sydney Catherine Powell, Kathleen 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 the criminal organization constituted an enterprise as the term is defined in OCGA 16-14-3 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. Page 16. 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 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 we're not limited to the following one false statements two and solicitation of state legislators 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. Two, 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, page 17, 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. Number three, 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 of 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 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, Page 18. enterprise, including several of the defendants, corruptly solicited high-ranking United States Department of Justice officials to make false statements to government officials in Fulton County, Georgia, including the governor, the Speaker of the House of Representatives, and the

President pro tempore of the Senate. In one instance, Donald Trump stated to the acting United States Attorney General, quote, just say that the election was corrupt and leave the rest to me and the Republican congressman, unquote. Number six, 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 F 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 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. Page 19. Number 8.

Obstructive acts in furtherance of the conspiracy and the cover-up. Members of the enterprise, including several other defendants, filed false documents, made false statements to government investigators, and committed perjury in judicial proceedings in Fulton County, Georgia, and elsewhere in furtherance of and to cover up the conspiracy. Page 20. 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 affect the objectives of the enterprise,

including but not limited to Act 1. On or about the fourth 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 31st, 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 Lewis Giuliani placed a telephone call to unindicted co-conspirator Individual 2, whose identity is known to the grand jury, and left an approximately 83-second-long voicemail message for unindicted co-conspirator Individual 2 making statements concerning fraud in the November 3, 2020 election in Fulton County, Georgia. This telephone call was an overt act in furtherance of the conspiracy. Act 2, on or about the 19th day of November 2020,

Rudolph William Lewis Giuliani, Jenna Lynn Ellis, Sydney Catherine Powell, and unindicted co-conspirator Individual 3, whose identity is known to the grand jury, appeared at a press conference at the Republican National Committee headquarters on 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 Schaefer sent an email to unindicted co-conspirator Individual 4, whose identity is known to the grand jury and

other individuals. In the email, David James Schaefer stated that Scott Graham Hall, a Georgia bail bondsman, quote, has been looking into the election on behalf of the president at the request of David Bossie, unquote, and asked unindicted co-conspirator individual Ford to exchange contact information with Scott Graham Hall and to, quote, help him as needed, unquote. This was an overt act in furtherance of the conspiracy. Page 21, 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 Shirky, Speaker of the Michigan House of Representatives Lee Chanfield, 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 Lewis 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, quote, Can you send me the number for the Speaker and the leader of Pennsylvania legislature?

POTUS wants to chat with them. Unquote. 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,

quote, I would not break my oath, unquote. 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 Lewis Giuliani and Jenna Lynn Ellis appeared, spoke, and presented witnesses at a meeting of Pennsylvania legislators in Gettysburg, Pennsylvania. During the meeting, Rudolph William Lewis 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. Crime Stories with Nancy Grace. Page 22.

Act 9. Honor about the 25th day of November 2020. Immediately after the meeting of Pennsylvania legislators in Gettysburg, Pennsylvania, where Rudolph William Lewis 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 Lewis 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 Lewis Giuliani and Jenna Lynn Ellis placed a telephone call to Speaker of the Pennsylvania House of Representatives Brian 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. Honor about the 26th day of November 2020. Rudolph William Lewis 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 Lewis Giuliani and Jenna Lynn Ellis placed a telephone call to Speaker of the Pennsylvania House of Representatives Brian 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 Lewis Giuliani and Jenna Lynn Ellis placed a telephone call to President Pro Tempura 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. Page 23. Act 14. Honor about the 27thance of the conspiracy. Page 23, Act 14. On or about the 27th day of November 2020, Donald John Trump placed a telephone call

to President Pro Tempore of the Pennsylvania Senate, Jake Corman, for the purpose of soliciting, requesting, and importuning Corman to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy. Act 15. On or about the 28th day of November 2020,

Rudolph William Lewis Giuliani placed a telephone call to Speaker of the Pennsylvania House of Representatives Brian 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 Lewis Giuliani placed a telephone call to Speaker of the Pennsylvania House of Representatives Brian 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. Honor about the in furtherance of the conspiracy. Act 17. On or about the 30th day of November 2020, Rudolph William Lewis 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 Lewis 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 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. Page 24, Act 19. On or between the first 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 the state legislatures. The request was an overt act in furtherance of the conspiracy. Act 20. On or about the first day of December 2020, Rudolph William Lewis Giuliani and Jenna Lynn Ellis met with Speaker of the Arizona House of Representatives Rusty Bowers, President of the Arizona Senate Karen Phan, 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 Lewis 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 second day of December 2020, Rudolph William Lewis 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 Lewis 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 and furtherance of the conspiracy. Act 22.

On or about the third day of December 2020, Donald John Trump caused to be tweeting from the Twitter account at RealDonaldTrump, quote, Georgia hearings now on at OANN, amazing, unquote. This was an overt act in furtherance of the conspiracy. Page 25. Act 23. On or about the third day of December 2020,

Rudolph William Lewis Giuliani, John Charles Eastman, Jenna Lynn Ellis, and Ray Stalling Smith III committed the felony offense of solicitation of violation of oath by a public officer in violation of OCGA 16-4-7 and 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 Rett, Cardin Summers, and Blake Tillery to engage in conduct constituting the felony offense of violation of oath by public officer OCGA 16-10-1 by unlawfully appointing presidential electors from Georgia in willful and intentional violation of furtherance of the conspiracy. Louis Giuliani committed the felony offense of false statements and writings in violation of OCGA 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. One, that at least 96,600 mail-in ballots were counted in the November 3rd, 2020 presidential election in Georgia, despite there being no record of those ballots having been returned to a county elections office. Two, that Dominion Voting Systems equipment used in November 3rd, 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 OCGA 16-14-3-5A and an overt act in furtherance of the conspiracy. Page 26, Act 25. On or about the third day of December 2020, Ray Stalling Smith III committed the felony offense of false statements and writings in violation of OCGA 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 17th 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 are 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 continue 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 OCGA 16-14-3-5A and an overt act in furtherance of the conspiracy. Act 26. On or about the third day of December 2020,

Donald John Trump caused to be tweeted from the Twitter account at RealDonaldTrump, quote, wow, blockbuster testimony taking place right now in Georgia. Ballot stuffing by Dems when When Republicans were forced to leave. The large counting room. Plenty more coming. But this alone leads to an easy win of the state. Unquote. This was an overt act in furtherance.

Of the conspiracy. Act 27. On or about the third day of December 2020. Donald John Trump. Caused to be tweeted from the Twitter account. At real Donald Trump. Quote. People in Georgia got caught. Cold. December 2020, Donald John Trump caused to be tweeted from the Twitter account at RealDonaldTrump, quote, people in Georgia got caught cold bringing in massive numbers of ballots and putting them in voting machines. Great job at Brian Kemp GA. This was an overt act in furtherance of the conspiracy. Page 27, Act 28. On or about the third day of December 2020,

Donald John Trump met with the Speaker of the Pennsylvania House of Representatives, Brian 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 third 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 3rd, 2020 presidential election in Georgia. This was an overt act in furtherance of the conspiracy. Act 30. On or between the third 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 fifth 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 at RealDonaldTrump, quote, Gee, what a surprise. Has anyone informed the so-called says-he-has-no-power-to-do-anything governor at Brian Kemp GA and his puppet lieutenant governor at Jeff Duncan GA that they could easily solve this mess and win?

Signature verification and call a special session. So easy, unquote. This was an overt act in furtherance of the conspiracy. Act 33. On or about the sixth day of December 2020, Sidney Catherine Powell entered into a written engagement agreement with Sullivan Stickler 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 Coffey County, Georgia, was subsequently performed under this agreement. This was an overt act in furtherance of the conspiracy. Page 28, Act 34. On or about the 6th day of December 2020, Robert David Cheely 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, quote, I am working on setting up a call for you with 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, unquote. 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 Cheely, 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, quote, to the President of the Senate and to other officials, unquote. This was an overt act in furtherance of the conspiracy.

Act 36. Honor about the furtherance of the conspiracy. Act 36. On or about the sixth day of December 2020, Robert David Sheely sent an email to unindicted co-conspirator individual 2 whose identity is known to the grand jury and stated that he had been speaking with John Charles Eastman and was attempting to set up a call with Speaker of the Georgia House of Representatives David Ralston and President Pro Tempore of the Georgia Senate Butch Miller to encourage them to call a special session of the Georgia General Assembly.

In the email, Robert David Shealy stated, quote, 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. Unquote. In the email, Robert David Shealy further stated, quote, I assume you can make sure this happens. Unquote. 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 email to Robert David Shealy and David James Schaefer that stated, quote, Bob, can you get on a call with David Schaefer, 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 1030, unquote. This was an overt act in furtherance of the conspiracy. Page 29. Act 38. Honor about the 7th day of December 2020. Rudolph William Louis Giuliani caused to be tweeted from the Twitter account at Rudy Giuliani a retweet of unindicted co-conspirator Individual 8 whose identity is known to the grand jury, that stated, quote,

Georgia Patriot call to action. Today is the day we need you to call your state Senate and House reps and ask them to sign the petition for a special session. We must have free and fair elections in Georgia, and this is our only path to ensuring every legal vote is counted. At real Donald Trump, unquote. 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, quote, The Real Deadline for Settling a State's Electoral Votes, unquote. The body of the email stated, quote, Here's the memo we discussed, unquote. The memorandum was written by Kenneth John Cheeseborough 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 email was an overt act in furtherance of the conspiracy. Act 40. On or about the seventh 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 email containing the requested information to Rudolph William Lewis 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 seventh day of December 2020,

Rudolph William Lewis 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. Crime Stories with Nancy Grace. Page 30, 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 OCGA 16-4-7 and 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, OCGA 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 the 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, 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 3rd 2020 presidential election in those states this was an overt act in furtherance of the conspiracy act 45 on or about the eighth day of december, 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, quote, get, unquote, 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.

Page 31. Act 46. On or about the ninth day of December 2020, Kenneth John Cheesebro wrote a memorandum titled Statutory Requirements for December 14 Electoral Votes to James R. Troopas, 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 Cheesebrough sent an email to Georgia Republican Party Chairman David James Schaefer and unindicted co-conspirator Individual 9, whose identity is known to the grand jury. Kenneth John Cheesebro stated in the email that certain individuals associated with the Trump campaign asked him to quote, to help coordinate with the other five contested states to help with logistics of the

electors in other states, hopefully joining and casting their votes on Monday. Unquote. This was an overt act, in furtherance of the conspiracy. Act 48. On or about the 10th day of December 2020, Kenneth John Cheesebrough sent an email with attached documents to David James Schaefer 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 Cheesebro sent an email with attached documents to Arizona Republican Party Executive Director Graves Saffston 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. Page 32. Act 50. Honor about the 10th day of December 2020. Kenneth John Cheesebrough sent an email 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 Cheesebro sent an email to Nevada Republican Party Vice Chairman Jim DeGraffenried. Kenneth John Cheesebro stated in the email that Rudolph William Louis Giuliani and other individuals associated with the Trump campaign asked him to quote, 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, December 14, unquote. This was an overt act in furtherance of the conspiracy. Act 52.

On or about the 10th day of December 2020, Kenneth John Cheesebro sent an email with attached documents to Jim DeGraff and Reed. 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 Cheesebrough sent an email 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 Schaefer 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 Decembercember 14 2020 meeting of trump

presidential elector nominees in fulton county georgia this was an overt act in furtherance of the conspiracy page 33 act 55 on or about the 10th day of december 2020 rudolph william lewis giuliani and ray stalling smith the third committed the felony offense of solicitation of violation of oath by public officer in violation of OCGA 16-4-7 and 16-10-1 in Fulton County, Georgia, by unlawfully soliciting, requesting, and importuning certain public officials, then serving as elected members of the Georgia House of Representatives, and present at a House Governmental Affairs Committee meeting, including Representatives Shaw Blackmon, John Burns, Barry Fleming, Todd Jones, B. Gwynn, Mary Margaret Oliver,

Alan Powell, Renita Shannon, Robert Trammell, Scott Turner, and Bruce Williamson to engage in conduct constituting the felony offense of violation of oath by public officer OCGA 16-10-1 by unlawfully appointing presidential electors from Georgia in willful and intentional violation of the terms of the oath of said persons as prescribed by law with intent that said persons engage in said conduct. This was an overt act in furtherance of the conspiracy. Page 34, Act 56. On or about the 10th day of December 2020, Rudolph William Lewis Giuliani committed the felony offense of false statements and writings in violation of OCGA 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. One, 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.

Two, that at State Farm Arena on November 3, 2020, Democratic officials, quote, got rid of all of the reporters, all of the observers, anyone that couldn't be trusted, unquote, used the excuse of a water main break, cleared out the voting area, and trusted, unquote, used the excuse of a water main break, cleared out the voting area, and then, quote, went about their dirty, crooked business, unquote.

Three, that between 12,000 and 24,000 ballots were illegally counted by Fulton County election workers at State Farm Arena on November 3, 2020. Number four, that in Michigan there there were 700 000 more ballots counted than were sent out to voters in the november 3rd 2020 presidential election which was accounted for by quadruple counting ballots number five that ruby freeman shea moss and an unidentified man were quote quite obviously surreptitiously passing around usb ports as if they are vials of heroin or cocaine, unquote, at State Farm Arena to be used to infiltrate the crooked Dominion voting machines. Number six, that 96,600 mail-in ballots were counted in the November 3rd, 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 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 OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Page 35. Act 57. Honor about the 11th day of December 2020. David James Schaefer 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 Cheesebrough sent an email to Jim DeGraffenried and stated that the purpose of having the electoral vote sent into 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 Cheesebro sent an email with attached documents to Greg Safstan 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 Cheesebro sent an email 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 Cheesebrough sent an email with attached documents to Michael A. Roman, unindicted co-conspirator to 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. Page 36, Act 62. On or about the 12th day of December 2020, David James Schaefer contacted unindicted co-conspirator Individual 12 Page 36, Act 62. On or about the 12th day of December 2020, David James Schaefer 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 email 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 email, Michael A. Roman stated, I need a tracker for the electors, and then instructed individuals associated with the Trump campaign to populate entries on a shared spreadsheet listing Trump presidential elector nominees in Georgia, Arizona, 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 Cheesebrough met with Brian Schimming and discussed the December 14, 2020 meeting with 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. Page 37, Act 66. page 37 act 66 honor about the 12th day of december 2020 unindicted co-conspirator individual four whose identity is known to the grand jury sent an email to michael a roman and david james schaefer with updates on the progress of organizing the december 14 2020 meeting of trump's presidential elector nominees in fulton county georg. The email 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 Schaefer 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 Schaefer sent an email to unindicted co-conspirator Individual 4, whose identity is known to the grand jury, advising them to touch base with each of the Trump presidential elector nominees in Georgia in advance of the December 14, 2020 meeting to confirm their attendance. This was an overt act in furtherance of the conspiracy. Act 68. On or about the 12th day 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 Lewis Giuliani. This was an overt act in furtherance of the conspiracy. Act 69. On or about the 13th day of December 2020, Kenneth John Cheesebrough sent an email 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. Page 38, Act 70. On or about the 13th day of December 2020, Kenneth John Cheesebro sent an email to Rudolph William Louis Giuliani with the subject, Privileged and Confidential, brief notes on President of the Senate strategy.

In the email, Kenneth John Cheesebrough 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 email, Kenneth John Cheesebrough 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 Cheesbrough sent an email with attached documents to Michael A. Roman and unindicted co-conspirator individual for 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 Cheesebro sent an email to Michael A. Roman and unindicted co-conspirator individual for whose identity is known to the grand jury and stated that Rudolph William Louis Giuliani, quote, wants to keep this quiet until after all the voting is done, unquote, 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 Schaefer 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 and stated that unindicted co-conspirator individual eight 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 page 39 act 74 honor 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 Schaefer 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 at RealDonaldTrump, quote, what a fool Governor at Brian Kemp, GA 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. Unquote. This was an overt act in furtherance of the conspiracy. Act 76.

On or about the 14th day of December 2020, David James Schaefer sent a text message to unindicted co-conspirator Individual 4, whose identity is known to the grand jury, and 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 email to unindicted co-conspirator Individual 4 and Individual 7

whose identities are known to the grand jury and stated, quote, Please send me an update as soon as the State Electoral college has adjourned and all paperwork is secured, unquote. 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 Schaefer encouraged certain individuals present at the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia, to sign the document titled,

quote, Certificate of the Votes of the 2020 Electors from Georgia, unquote. This was an overt act in furtherance of the conspiracy. Page 40, Act 79, on or about the 14th day of December 2020, David James Schaefer, Sean Micah Treasure Still, Kathleen 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 OCGA 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 OCGA 16-14-35A and an overt act in furtherance of the conspiracy act 80 honor about the 14th day of December 2020 David James Schaefer Sean Micah Tresher Still Kathleen Alston Latham and unindicted co-conspirators individual 2 individual 8 individual 9 individual 10 individual 11 individual 12 individual 13 individual 14 Individual 2, Individual 8, Individual 9, Individual 10, Individual 11, Individual 12, Individual 13, Individual 14, Individual 15,GA 16-9-1B in Fulton County, Georgia, by with the intent to defraud knowingly making a document titled Certificate of the Votes

of the 2020 Electors from Georgia, a writing other than a check in such manner that the writing as made purports to have been made by authority of the duly elected and qualified presidential electors from the state of Georgia who did not give such authority and uttered and delivered said document to the archivist of the United States. This was an act of racketeering activity under OCGA 16-14-35A and an overt act in furtherance of the conspiracy thank you for listening to part one of our three-part verbatim reading of former president donald trump's indictment this is an iheart podcast