Crime Stories with Nancy Grace - Former President Donald Trump Indicted, part 2 of 3

Episode Date: August 19, 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 two of the verbatim reading of the document. See omnystudio.com/listener for privacy information.

You're listening to an iHeart Podcast. Crime Stories with Nancy Grace. Welcome to part two of our three-part verbatim reading of former President Donald Trump's indictment. Page 41. Act 81. 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 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 OCGA 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, Department and

Agencies of State Government. This was an act of racketeering activity under OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Act 82 Honor about the 14th day of December 2020. indicted 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 of offense of filing false documents in violation of OCGA 16-10-20.1B1 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 Southwest 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 material 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 OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Page 42. Act 83.

On or about the 14th day of December 2020, David James Schaefer and Sean Micah Tresher Still committed the felony offense of forgery in the first degree in violation of OCGA 16-9-1B in Fulton County, Georgia by, with the intent to defraud, knowingly making a document titled R.E. 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 OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Act 84. On or about the 14th day of December 2020, David James Schaefer and Sean Micah Tresher Still 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 and using a false document titled R.E. Notice of Filling of Electoral College Vacancy, with knowledge that said document contained the false statements that David James Schaefer was chairman of the 2020 Georgia Electoral College meeting

and Shawn Micah Tresher Still was secretary of the 2020 Georgia Electoral College meeting, Act 85. On or about the 14th day of December 2020, David James Schaefer 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 Schaefer and Sean 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. Honor about the 14th day of December 2020, unindicted co-conspirator Individual 4, whose identity is known to the grand jury,

sent an email to Michael A. Roman, unindicted co-conspirator Individual 4, whose identity is known to the grand jury, sent an email 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. Page 43, Act 87. On or about the 14th day of December 2020, Stephen Cliff Gardley attempted to commit the felony offense of influencing witnesses in violation of OCGA 16-10-93B1A in Fulton County, Georgia by traveling to the home of Ruby Freeman, a Fulton County, Georgia election worker, 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 OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Act 88. On or about the 15th day of December 2020, Stephen Cliffguard Lee attempted to commit felony offense of influencing witnesses in violation of OCGA 16-10-93-B1A 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 OCGA 16-14-35A 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 Cliff Gardley 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 Clifford Lee stated to Harrison William Prescott Floyd that Freeman was afraid to talk to Stephen Cliffguard 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 Catherine 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 Catherine Powell as special counsel with fraud authority to investigate allegations of voter fraud in Georgia and elsewhere.

This was an overt act in furtherance of the conspiracy. Page 44, Act 91. On or about the 21st day of December 2020, Sidney Catherine Powell sent an email to the Chief Operations Officer of Sullivan Strickler 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 Sullivan Strickler, LLC, from Dominion Voting Systems Equipment in Michigan. This was an overt act in furtherance of the conspiracy. Act 92. 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 Francis Watson, Georgia Bureau of Investigation Special Agent in Charge Bayhan 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 Francis 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. December 2020, John Charles Eastman sent an email to Kenneth John Cheesebro and unindicted co-conspirator Individual 3, whose identity is known to the grand jury, with the subject

FW Draft 2 with edits. In the email, John Charles Eastman attached a memorandum titled Privileged and Confidential, December 23 memo on January. 6 scenario 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, but for them just

to act boldly and be challenged, since the challenge would likely lead to the court denying review on non-justiciable political question grounds. This was an overt act in furtherance of the conspiracy. Page 45, 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 Francis Watson that stated in part, Is there a way to speed up Fulton County's signature verification

in order to have results before January 6th if the Trump campaign assists 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 Donahue to make a false statement by stating, quote, just say the election was corrupt and leave the rest to me and the Republican congressman, unquote. This was an overt act in furtherance of the conspiracy. Act 98. On or about the 28th day of December 2020, Jeffrey Bozart Clark attempted to commit the felony offense

of false statements and writings in violation of OCGA 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, quote, identified significant concerns that may have impacted the outcome of the election in multiple states, including the state of Georgia, unquote. 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. And on or about the 28th day, December

2020, Jeffrey Boeser Clark sent an email to Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney General Richard Donahue 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, OCGA 16-10-20. This was an act of racketeering activity under OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Page 46. Act 99. On or about the 28th day of December 2020,

Jeffrey Boeser Clark solicited Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney General Richard Donahue 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 at real donald trump quote hearings from atlanta on the georgia election overturn now being broadcast check it out at oann at newsmax and many more. At Brian Kemp, GA, should resign from office. He is an obstructionist who refuses to admit that we won Georgia big, also won the other swing states, unquote. 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 at RealDonaldTrump, quote, hearings from Atlanta on the Georgia election overturn now being broadcast live via at RSBN network.

This was an overt act in furtherance of the conspiracy. Act 102. 7 and 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 Senate Judiciary Subcommittee meeting, including unindicted co-conspirator to individual eight whose identity is known to the grand jury, Senators Brandon bill heath william ligan michael rett 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 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. Crime Stories with Nancy Grace. Page 47. Act 103. Honor about the 30th 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 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 OCGA 16-14-35A and an overt act in furtherance of the conspiracy.

Act 104. On or about the 30th 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. One, 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. Two, that the Georgia Secretary of State admitted that they had 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 OCGA 16-14-35A and an overt act in the furtherance of the conspiracy. Page 48, Act 105. On or about the 30th day of December 2020, Robert David Sheely 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 statements and representation 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 water main break. Two, 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 OCGA 16-14-35A 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 at RealDonaldTrump, quote, 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, unquote. 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 R.E. 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, quote, the vice president should therefore not open any of the votes, unquote, 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. Page 49, 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 OCGA 16-10-20.1b1 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 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 post 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. Six, 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 p.m. on November 3, 2020

at State Farm Arena in Fulton County, Georgia. Earlier on the same day, John Charles Eastman sent an email to attorneys associated with 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 OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Act 109. On or about the first day of January 2021, Kenneth John Cheesebro sent an email to John Charles Eastman and unindicted co-conspirator Individual 3, whose identity is known to the grand jury. In the email, Kenneth John Cheesebro 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. Page 50, Act 110. On or about the second day of January 2021, Scott Graham Hall, a Georgia bail bondsman, placed a telephone call to Jeffrey Bozart 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 second day of January 2021, Jeffrey Bozart Clark solicited Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney General Richard Donahue 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 the furtherance of the Georgia House of Representatives David Ralston, and President Pro Tempore of the Georgia Senate Butch Miller. This was an overt act in the furtherance of the conspiracy. Act 112. On or about the second day of January 2021, Donald John Trump and Mark Randall Meadows committed for 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 Georgia Secretary of State Brad

Raffsenberger, a public officer, to engage in conduct constituting the felony offense of violation of oath by public officer, OCGA 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. Page 51. Act 113. On or about the second day of January 2021, Donald John Trump 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 Georgia Secretary of State Brad Raffsenberger, Georgia Deputy Secretary of State Jordan Fuchs, and Georgia Secretary of State General Counsel Ryan Germany. One, that anywhere from 250,000 to 300,000 ballots were dropped mysteriously into the rolls in the November 3, 2020 presidential election in Georgia.

Two, that thousands of people attempted to vote in the November 3, 2020 presidential election in Georgia and were told they could not because that ballot had already been cast in their name. Three, 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. Page 52.

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 OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Act 114. On or about the third day of January 2021, Donald John Trump caused to be tweeted from the Twitter account at RealDonaldTrump, quote, I spoke to Secretary of State Brad Raffsenberger 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. Unquote. This was an overt act in furtherance of the conspiracy. Page 53. Act 115. On or about the third day of January 2021, Stephen Cliff Gardley, Harrison William Prescott Floyd, and Trevian C. Cuddy 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 Trevion C. Cuddy. 4. At 7.53 p.m., Harrison William Prescott Floyd sent a text message to Ruby Freeman. 5. At 8.03 p.m., Trevion C. Cuddy 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 Cliffguard Lee. 8. At 8.48 p.m., Harrison William Prescott Floyd placed a telephone call to Trevian C. Cuddy.

9. At 9.16 p.m., Harrison William Prescott Floyd placed a telephone call to Trevian C. Cuddy. 9. At 9.16 p.m., Harrison William Prescott Floyd placed a telephone call to Trevian C. Cuddy. 10. At 9.33 p.m., Harrison William Prescott Floyd placed a telephone call to Trevian C. Cuddy. 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. Page 54. Act 116. On or about the fourth day of January 2021, Trevian C. Cuddy, 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, 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 fourth day of January 2021, Trevian C. Cuddy traveled to Ruby Freeman's house in Cobb County, Georgia, and attempted to contact her but was unsuccessful. Trevian C. Cuddy 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 fourth day of January 2021, Trevian C. Cuddy, while in Fulton County, Georgia, placed a telephone call to Ruby Freeman and stated that Freeman was in danger. Trevian C. Cuddy stated that she could help Freeman and requested that Freeman meet and speak to her that night at 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 fourth day of January 2021, Trevian C. Cuddy 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. Cuddy 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. Page 55. Act 120. On or about the fourth day of January 2021, Stephen Cliff Gardley, Harrison William Prescott Floyd, and Trevian C. Cuddy committed the felony offense of solicitation of false statements and writings in violation of OCGA 16-4-7 and 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, OCGA 16-10-20 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 OCGA 16-14-3-5A and an overt act in furtherance of the conspiracy. Act 121. On or about the fourth day of January 2021, Stephen Cliffgard Lee, Harrison William Prescott Floyd, and Trevian C. Cuddy committed the felony offense of influencing witnesses in violation of OCGA 16-10-93B1A 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 OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Page 56. Act 122. On or about the fourth day of January 2021, Stephen Cliff Gardley, Harrison William Prescott Floyd, and Trevian C. Cuddy 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 Cliff Gardley 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 Schaefer. 3. At 12.25 p.m., Stephen Cliff Gardley placed a telephone call to Harrison William Prescott Floyd. 4. At 12.32 p.m., Stephen Cliff Gardley sent a text call to Harrison William Prescott Floyd. 4. At 12.32 p.m., Stephen Cliff Gardley 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 Schaefer. 6. At 10 p.m., Harrison William Prescott Floyd placed a telephone call to Stephen Cliff Gardley. 7. At 10.19 p.m., Harrison William Prescott Floyd placed a telephone call to Trevian C. Cuddy. 8. At 10.43 p.m., Trevian C. Cuddy placed a telephone call to Harrison William Prescott Floyd. 9. At 11.10 p.m., Trevian C. Cuddy placed a telephone call to Harrison William Prescott Floyd. 10. At 12.12 a.m. on January 5, 2021, Trevian C. Cuddy placed a telephone call to Harrison William Prescott Floyd. 10. At 12.12 a.m. on January 5, 2021,

Trevi and C. Cuddy placed a telephone call to Harrison William Prescott Floyd. These were overt acts in furtherance of the conspiracy. Page 57. Act 123. On or about the fourth 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 fourth day of January 2021, Kenneth John Cheesebrough sent an email to John Charles Eastman with the subject, Forward Draft 2 with Edits, and included within the body of the email another email that Kenneth John Cheesebro previously sent to Rudolph William Lewis 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 other states, and stated that the outcomes of any of these strategies were preferable to allowing the Electoral act to operate by its terms this was an overt act in furtherance of the conspiracy act 123 on or about the fourth day of january 2021 donald john trump and john charles eastman met with vice president mike pence chief of staff to the vice president mark short and counsel to the vice president greg jacob 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 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. Page 58, Act 126. On or about the fifth day of January 2021, Jenna Lynn Ellis wrote a memorandum titled, R.E. Vice President Authority in Counting Electors Pursuant to U.S. Constitution and Three 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. Crime Stories with Nancy Grace Page 59, Act 127 Honor about the 5th day of January 2021 Robert David Sheeley, Stephen Cliffguard Lee, Harrison William Prescott Floyd, Trevian C. Cuddy, and Scott Graham Hall placed multiple telephone calls to each other and to other individuals involved in the conspiracy. They include the following. 1. 11.32 a.m. Stephen

Cliffguard Lee placed a telephone call to Trevian C. Cuddy. 2. At 12.14 p.m. Harrison William Prescott Floyd, Trevian C. Cuddy, Stephen Cliffguard 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 Shealy. 4. At 12.34 p.m., Scott Graham Hall placed a telephone call to Robert David Shealy. 5. At 1.07 p.m., Robert David Shealy placed a telephone call to Scott Graham Hall. 6. At 1.09 p.m., Robert David Shealy placed a telephone call to Scott Graham Hall. 7. At 2.30 p.m., Robert David Shealy 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 Shealy. 9. At 3.59 p.m., Robert David Shealy placed a telephone call to Scott Graham Hall. 10. At 4.42 p.m., Stephen Cliff Gardley placed a telephone call to Robert David Shealy. 11. At 4.50 p.m., Stephen Cliffgard Lee placed a telephone call to Harrison William Prescott Floyd. Page 60. 13. At 7.19 p.m., Trevian C. Cuddy placed a telephone call to Robert David Shealy. 14. At 7.48 p.m., Robert David Shealy placed a telephone call to Trevian C. Cuddy. 15. At 8.27 p.m., Robert David Shealy placed a telephone call to Trevian C. Cuddy. 15. At 8.27 p.m., Robert David Shealy placed a telephone call to Trevian C. Cuddy.

16. At 8.49 p.m., Robert David Shealy placed a telephone call to Stephen Cliffguard Lee. 17. At 9.18 p.m., Scott Graham Hall placed a telephone call to Robert David Shealy. 18. At 9.31 p.m., Trevian C. Cuddy placed a telephone call to Robert David Shealy. 19. At 10.14 p.m., Robert David Shealy placed a telephone call to Stephen Cliffguard Lee. 20. At 11.16 p.m., Robert David Shealy placed a telephone call to Trevian C. Cuddy. 21. At 11.25 p.m., Scott Graham Hall placed a telephone call to Robert David Shealy. 22. At 11.35 p.m., Robert David Shealy, Trevian C. Cuddy, and Scott Graham Hall participated in a three-way call. 23. At 12.09 a.m. on January 6, 2021, Trevian C. Cuddy placed a telephone call to Robert David Shealy. 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 at RealDonaldTrump, quote, The Vice President has the power to reject fraudulently chosen electors, unquote. This was an overt act in furtherance of the conspiracy. Page 61. Act 129.

On or about the 5 fifth day of January 2021, John Charles Eastman met with Chief of Staff to the Vice President Mark 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 fifth 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, quote, play by marquee of Queensberry rules, unquote. 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, quote, doing a great disservice, unquote. This was an overt act in furtherance of the conspiracy. Act 131. On or about the fifth 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 legislators. 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, quote, you gotta be tough tomorrow, unquote. This was an overt act in the furtherance of the conspiracy. Act 133. On or about the fifth day of January 2021, Donald John Trump issued a statement through the Trump campaign that falsely stated, quote,

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, unquote. This was an overt act in furtherance of the conspiracy. Page 62. Act 134. Honor about the sixth day of January 2021, Kathleen Alston Latham placed a telephone call to Scott Graham Hall. Several hours later, Scott Graham Hall placed a telephone call to Kathleen 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 Coffey County Board of Elections and Registration Office in Coffey County, Georgia. These were overt acts in furtherance of the conspiracy. Act 135. On or about the sixth 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 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 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 sixth day of January 2021, Rudolph William Lewis Giuliani appeared and spoke at a rally at the Ellipse in Washington, D.C. During the rally, Rudolph William Lewis Giuliani appeared and spoke at a rally at the Ellipse in Washington, D.C. During the rally, Rudolph William Lewis 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 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 sixth 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. Page 63. Act 138. Honor about the sixth day of January 2021. Donald John Trump caused to be tweeted from the Twitter account at RealDonaldTrump, quote, If Vice President at Mike Pence comes through for us, we will win the presidency.

Many states want to decertify the mistake they made in certifying incorrect and even fraudulent numbers in a process not approved by their state legislatures, which it must be. Mike can send it back, unquote. This was an overt act in furtherance of the conspiracy. Act 139. On or about the sixth day of January 2021, Donald John Trump caused to be tweeted from the Twitter account at RealDonaldTrump quote, 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. Unquote. This was an overt act in is a time for extreme courage, unquote. This was an overt act in furtherance of the conspiracy.

Act 140. Honor about the sixth 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, quote, go down as a wimp, unquote, and that Pence was not protecting the United States. This was an overt act in furtherance of the conspiracy. Page 64. Act 141. On or about the sixth 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 two hours, violation of 3 U.S.C. 17, and the VP allowed further debate or statements by leadership after the question had been voted upon, violation of 3 U.S.C. 17. And they had that debate upon motion approved by the VP in violation of the requirement in 3 U.S.C. 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 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 voted for 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, Kathleen Alston Latham sent a text message to the Chief Operations Officer of Sullivan Strickler LLC with the address for the Douglas Municipal Airport in Coffey County, Georgia to a coordinate picking up Scott Graham Hall from the airport and driving him to the Coffey County Board of Elections and Registration Office for the purpose of assisting with the unlawful breach of election equipment at the Coffey County Board of Elections and Registration Office. This was an act of racketeering activity under OCGA 16-14-35B and an overt act in furtherance of the conspiracy act 143 honor 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 dekab peach tree airport in dekab county georgia to douglas municipal airport in coffee county georgia for the purpose of assisting with unlawful breach of election equipment at the Coffey County Board of Elections and Registration Office. This was an act of racketeering activity under OCGA 16-14-35B and an overt act in furtherance of the conspiracy. Page 65, Act 144. Honor about the 7th day of January 2021, Sidney Catherine Powell, Kathleen Alston Latham, Scott Graham Hall,

and Misty Hampton committed the felony offense of interference with primaries and elections in violation of OCGA 21-2-566 in Coffey County, Georgia, by willfully and unlawfully tampering with electronic ballot markers and tabulating machines in Coffey 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. Honor about the 7th day of January 2021. Sidney Catherine Powell, Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton committed the felony offense of unlawful possession of ballots in violation of OCGA 21-2-574 in Coffey 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 places in Coffey County, Georgia. This was an overt act in furtherance of the conspiracy. Act 146. On or about the 7th day of January 2021, Sidney Catherine Powell, Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton committed the felony offense of computer theft in violation of OCGA 16-9-93A

in Coffey 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 Coffey County, Georgia. This was an act of racketeering activity under OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Act 147. On or about the 7th day of January 2021, Sydney Catherine Powell, Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton

committed the felony offense of computer trespass in violation of OCGA 16-9-93B in Coffey 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 Coffey County, Georgia. This was an act of racketeering activity under OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Page 66, Act 148. On or about the 7th day of January 2021, Sydney Catherine Powell, Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton committed the felony offense of computer invasion of privacy in violation of OCGA 16-9-93C in Coffey 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 OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Act 149 on and between the sixth day of december 2020 and the seventh day of january 2021 sydney katherine powell kathleen alston latham scott graham hall and misty hampton committed the felony offense of conspiracy to defraud the state in violation of ocga 16-10-21 in Coffey 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 Raffsenberger,

a state officer in his official capacity. This was an act of racketeering activity under OCGA 16-14-35B and an overt act in furtherance of the conspiracy. Act 150. Honor 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 accessed certain data copied from

dominion voting systems equipment at the coffee county board of elections and registration office in coffee county georgia by downloading said data from a server maintained by sullivan strickler llc this was an act of racketeering activity under ocga 16-14-35b and an overt act in furtherance of the conspiracy. Act 151. Honor about the 9th day of January 2021, the 10th day of January 2021, the 11th day of January 2021, and 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 and registration office in coffee county georgia by downloading said data

from a server maintained by sullivan strickler llc this was an act of racketeering activity under OCGA 16-4-35B and an overt act in furtherance of the conspiracy. Page 67. Act 152. Honor 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 and Registrations Office in Coffee County, Georgia, by downloading said data

from a server maintained by Sullivan Strickler LLC. This was an act of racketeering activity under OCGA 16-14-35B 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 Coffey County Board of Elections and Registration Office in Coffey County, Georgia, by downloading said data from a server maintained by Sullivan Strickler LLC. This was an act of racketeering activity under OCGA 16-14-35B and an overt act

in the 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 Coffey County Board of Elections and Registration Office in Coffey 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 email to the Chief Operations Officer of Sullivan Strickler LLC, directing him to transmit all data copied from Dominion Voting Systems equipment at the Coffee County Board of Elections and 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 Catherine Powell,

and the Trump campaign. This was an active racketeering activity under OCGA 16-14-35B and an overt act in furtherance of the conspiracy. Thank you for listening to Part 2 of our three-part verbatim reading of former President Donald Trump's indictment. You're listening to an iHeart Podcast.