Crime Stories with Nancy Grace - Former President Donald Trump Indicted, part 3 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 three of the verbatim reading of the document. See omnystudio.com/listener for privacy information.

This is an iHeart Podcast. Crime Stories with Nancy Grace. Thank you for listening to part three of our three-part verbatim reading of former President Donald Trump's indictment. Page 68. Act 156. Honor about the 17th day of September 2021, Donald John Trump committed the felony offense of solicitation of violation of oath by public officer in violation of OCGA 16-4-7 and 16-10-1 in Fulton County, Georgia,

by unlawfully soliciting, requesting, and importuning Georgia Secretary of State Brad Raffensperger, a public officer, to engage in conduct constituting the felony offense of violation of oath by public officer OCGA 16-10-1 by unlawfully, quote, decertifying the election or whatever the correct legal remedy is and announce the true winner, unquote, in willful and intentional violation of the terms of the oath of said person, as prescribed by law with intent that said person engage in said conduct. This was an overt act in furtherance of the conspiracy. Act 157.

On or about the 17th day of September 2021, Donald John Trump committed the felony offense of false statements and writings in violation of OCGA 16-10-20 in Fulton County, Georgia by knowingly, willfully, and unlawfully making the following false statement and representation to Georgia Secretary of State Brad Raffensperger.

One, quote, as stated to you previously, the number of false and or irregular votes is far greater than needed to change the Georgia election result, unquote. Said statement being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government and county and city law enforcement agencies. This was an act of racketeering activity under OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Page 69, Act 158.

On or about the 25th day of April 2022, David James Schaefer 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 in the presence of Fulton County District Attorney's Office investigators. One, that he attended and convened the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia, but that he did not call each of the individual members and notify them of the meeting or make any of the other preparations necessary for the meeting. Two, that a court reporter was not present

at the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia. Said statements being within the jurisdiction of the Fulton County District Attorney's Office, a department and agency of the government of a county of this state. This was an act of racketeering activity under OCGA 16-14-35A and an overt act in the furtherance of the conspiracy. Act 159. On or about the 7th day of May 2022, Sidney Catherine Powell made at least one of the following false statements and representations in a sworn deposition with the United States House of Representatives Select Committee

to investigate the January 6th attack on the United States Capitol. One, that she, quote, didn't have any role in really setting up, unquote, efforts to access voting machines in Coffey County, Georgia or Antrim County, Michigan. Two, that she was aware there was an effort by some people to get access to voting machines in Georgia, but that she didn't know what happened with that and did not remember whether that was Rudy or other folks. This was an overt act in furtherance of the conspiracy. Page 70, Act 160. On or about the first day of September 2022, Kathleen Alston Latham committed the felony offense of perjury in violation of OCGA 16-10-70A in Houston County, Georgia, by knowingly, willfully, and unlawfully making at least one of the following false statements in a deposition in the matter of Curling v. Raffensperger in the United States District Court for the Northern District of Georgia, a judicial proceeding after having been administered a lawful oath. One, that she was only present at the Coffey County Board of Elections and Registration Office in Coffey County, Georgia

for just a few minutes on January 7, 2021. Two, that she only walked into the front part of the Coffey County Board of Elections and Registration Office on January 7, 2021, and didn't go into the office. 3. That she had no idea if employees of Sullivan Strickler met Eric Chaney at the Coffey County Board of Elections and Registration Office on January 7, 2021. 4. That she did not see Misty Hampton at the Coffey County Board of Elections and Registration Office on January 7, 2021.

5. That her only interaction with Scott Hall at the Coffey County Board of Elections and Registration Office on January 7, 2021 was meeting him, speaking to him outside of the office, and then leaving the office. 6. That she did not see Scott Hall speak to anyone other than herself at the Coffey County Board of Elections and Registration Office on January 7, 2021. Said statements being material to the accused's own involvement in the January 7, 2021 unlawful breach of election equipment at the Coffey County Board of Elections and Registration Office and to the accused's communications with others involved the issue in question, this was an act of racketeering activity under OCGA 16-14-35A and an overt act in furtherance of the conspiracy. Page 71, Act 161. On or about the 15th day of September 2022, Robert David Sheely committed the felony offense of perjury in violation of OCGA

16-10-70A in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of the following false statements before the Fulton County Special Purpose Grand Jury, a judicial proceeding after having been administered a lawful oath. One, that he was unaware of the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia, until after the meeting had already taken place. Two, that he had no substantive conversations with anyone concerning the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County,

Georgia, until after the meeting had already taken place. Three, that he'd never suggested to anyone that the Trump presidential elector nominees in Georgia should meet on December 14, 2020. 4. That the only communication he had with John Eastman concerning the November 3, 2020 presidential election was for the purpose of connecting Eastman to Georgia Senator Brandon Beach, an

unindicted co-conspirator individual 8 whose identity is known to the grand jury for possible legal representation. Five, that he never worked to connect John Eastman with any Georgia legislators other than Georgia Senator Brandon Beach and unindicted co-conspirator Individual 8 whose identity is known to the grand jury. Said statements being material to the accused on involvement in the December 14, 2020 meeting at Trump's presidential elector nominees in Fulton County,

Georgia, and to the accused communications with others involved in the meeting, the issue in question. This was an act of racketeering activity under OCGA 16-14-35A and an overt act in furtherance of the conspiracy. The acts set forth above were committed in furtherance of the conspiracy alleged above and had the same and similar intents, results, accomplices, victims, and methods of commission and otherwise were interrelated by distinguishing characteristics and were not isolated acts. Page 72. Count 2 of 41. OCGA 16-4-7 and 16-10-1 for the said accused individually and as persons concerned in the commission of a crime and together with unindicted co-conspirators in the County of Fulton and the State of Georgia on the third day of December 2020. Unlawfully solicited, requested, and importuned,

certain public officers then serving as elected members of the Georgia Senate and present at a Senate Judiciary Subcommittee meeting, including unindicted co-conspirator Individual 8, whose identity is known to the grand jury, Senators Lee Anderson, Brandon Beach, Matt Brass, Greg Dolezal, Steve Gooch, Tyler Harper, Bill Heath, Jen Jordan, John F. Kennedy, William Ligon, Elena Parent, Michael 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 the State of Georgia in willful and intentional violation of the terms of the oath of said persons as prescribed by law, with intent that said persons engage in said conduct, said date being a material element of the offense,

contrary to the laws of said state, the good order, peace, and dignity thereof. Count 3 of 41 and the grand jurors aforesaid in the name and behalf of the citizens of georgia do charge and accuse rudolph william lewis giuliani with the offense of false statements and writings ocga 16-10-20 for the said accused in the county of fulton and the state of Georgia on or about the third day of December 2020, knowingly, willfully, and unlawfully, made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting. 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

officer. Two, that a Dominion voting systems machine used in the November 3rd, 2020 presidential election in Antrim County, Michigan, mistakenly recorded 6,000 votes for Joseph R. Biden when those votes were actually cast for Donald Trump. Said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said state, the good order, peace, and dignity thereof. Page 73, count 4 of 41 and the grand jurors aforesaid in the name and behalf of the citizens of georgia do charge and accuse ray stalling smith the third with the offense of false statements and writings ocga

16-10-20 for the said accused in the county of fulton and the state of georgia on or about the third day of december 2020 knowingly willfully and unlawfully made at least one of the following false statements and representations of members of the georgia senate present at a senate judiciary subcommittee meeting one that 2 506 felons voted illegally in the November 3rd, 2020 presidential election in Georgia. Two, that 66,248 underage people illegally registered to vote before their 17th birthday prior to the November 3rd, 2020 presidential election in Georgia. That at least 2,423 people voted in the November 3, 2020 presidential election in Georgia who were not listed as registered to vote. 4. That 1,043 people voted in the November 3, 2020 presidential election in Georgia who had illegally registered to vote using a post office box.

5. That 10,315 or more dead people voted in the November 3, 2020 presidential election in Georgia. 6. That Fulton County election workers at State Farm Arena ordered poll watchers and members of the media to leave the tabulation area on the night of November 3, 2020 and 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, contrary to the laws of said State, the good order, peace, and dignity thereof.

Page 74. Count 5 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Donald John Trump with the offense of solicitation of violation of oath by public officer, OCGA 16-4-7 and 16-10-1, for the said accused in the County of Fulton and State of Georgia, on or about the seventh day of December 2020, unlawfully solicited,

requested, and importuned Speaker of the Georgia House of Representatives David Ralston, a public officer, to engage in conduct constituting the felony offense of violation of oath by public officer OCGA 16-10-1 by calling for a special session of the Georgia General Assembly for the purpose of unlawfully appointing presidential electors from the state of Georgia in willful and intentional violation of the terms of the oath of said person as prescribed by law with intent that said person engage in said conduct contrary to the laws of said state the good order peace and dignity thereof count 6 of 41 and the grand jurors aforesaid in the name and behalf of the citizens of Georgia, do charge and accuse Rudolph William Lewis Giuliani and Ray Stalling Smith III with the offense

of solicitation of violation of oath by public officer O.C.G.A. 16-4-7 and 16-10-1 for the said accused individually and his persons concerned in the commission of a crime and together with unindicted co-conspirators in the county of Fulton and state of Georgia on the 10th day of December 2020 unlawfully solicited requested and importuned certain public officers then serving as elected members of the Georgia House of Representatives and present at a House Governmental Affairs Committee meeting, including Representatives Shaw Blackmon, John Burns, Barry Fleming, Todd Jones, Bea 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 the state of Georgia in willful and intentional violation of the terms of the oath of said persons as prescribed by law, with intent that said persons engage in said conduct, said date being a material element of the offense contrary to the laws of said state, the good order, peace, and dignity thereof. Page 75, Count 7 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia

do charge and accuse Rudolph William Lewis Giuliani with the offense of false statements and writings, OCGA 16-10-20, for the said accused in the County of Fulton and State of Georgia on or about the 10th day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia House of Representatives present at a House Governmental Affairs Committee meeting. 1. That it is quite clear from the State Farm Arena video from November 3, 2020, that Fulton County election workers at State Farm Arena on November 3, 2020 presidential election, which was accounted for by quadruple counting ballots.

5. That Ruby Freeman, Shea Moss, and a non-identified man were quite obviously, surreptitiously passing around USB ports as if they're vials of heroin or cocaine at State Farm Arena to be used to infiltrate the crooked Dominion voting machines. 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 the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government and county and city law enforcement agencies contrary to the laws of said state,

the good order, peace, and dignity thereof. Crime Stories with Nancy Grace. Page 76. Count 8 of 41. And the grand jurors, aforesaid in the name and behalf of the citizens of Georgia do charge and accuse David James Schaefer, Sean Micah Tresher Still, and Kathleen Alston Latham with the offense of impersonating a public officer, OCGA 16-10-23. For the said accused, individually and as persons concerned in the commission of a crime, and together with unindicted co-conspirators in the County of Fulton and state of georgia on or about the 14th day of december 2020 unlawfully falsely held

themselves out as the duly elected and qualified presidential electors from the state of georgia public officers with intent to mislead the president of the united states senate the archivist of the united states the georgia secretary of state and the chief judge of the United States 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, quote, Certificate of the Votes of the 2020 Electors from Georgia, unquote,

contrary to the laws of said state, the good order, peace, and dignity thereof. Count 9 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Donald John Trump, Rudolph William Louis Giuliani, John Charles Eastman, Kenneth John Cheeseborough, Ray Stalling Smith III,

Robert David Shealy, and Michael A. Roman with the offense of conspiracy to commit impersonating a public officer, OCGA 16-4-8 and 16-10-23, for the said accused individually and as persons concerned in the commission of a crime, and together with indicted and unindicted co-conspirators in the county of Fulton and state of Georgia on and between the sixth day of December 2020 and the 14th day of December 2020 unlawfully conspired to cause certain individuals to falsely hold themselves out as the duly elected and qualified presidential electors from the state of Georgia public officers with intent to mislead the President of the United States Senate, the Archivist of the United States, the Georgia Secretary of State, and the Chief Judge of the United States District Court

for the Northern District of Georgia into believing that they actually were such officers. And the defendants named in Count 8 acting as co-conspirators as described above and incorporated by reference as if fully set forth herein, falsely held themselves out, as said public officers, by placing in the United States mail to said persons a document titled, quote, Certificate of the Votes of the 2020 Electors from Georgia, unquote, in Fulton County, Georgia, which was an overt act to affect the object of the conspiracy contrary to the laws of said state, the good order, peace, and dignity thereof.

Page 77, count 10 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse David James Schaefer, Sean Micah Thresher Still, and Kathleen Alston Latham with the offense of forgery in the first degree, OCGA 16-9-1B, for the said accused individually and as persons concerned in the commission of a crime and together with unindicted co-conspirators in the County of Fulton and the State of Georgia, on or about the 14th day of December 2020, unlawfully and with the intent to defraud, knowingly made a document titled, quote, Certificate of the Votes of the 2020 Electors from Georgia, unquote, a writing

other than a check in such manner that the writings as made purports to have been made by authority of the duly elected and qualified presidential electors from the state of Georgia who did not give such authority and uttered and delivered said document to the archivist of the United States, contrary to the laws of said state, the good order, peace, and dignity thereof. Count eleven of forty-one. And the grand jurors, aforesaid in the name and behalf of the citizens of Georgia, do charge and accuse Donald John Trump, Rudolph William Louis Giuliani, John Charles Eastman, Kenneth John Cheesebro, Ray Stallingsmith III, Robert David Shealy, and Michael A. Roman with the offense of conspiracy to commit forgery in the first degree, OCGA 16-4-8 and 16-9-1b for the said accused individually and as persons concerned in the commission of a crime and together with indicted and unindicted co-conspirators in the county of fulton and state

of georgia on and between the 6th day of december 2020 and the 14th day of december 2020 unlawfully conspired with the intent to defraud to knowingly make a document titled quote certificate of the votes of the 2020 electors from Georgia, unquote, a writing other than a check, in such manner that the writing as made purports to have been made by authority of the duly elected and qualified presidential electors from the state of Georgia who did not give such authority, and to utter and deliver said document to the Archives of the United States. And the defendants named in Count 10, acting as co-conspirators,

as described above and incorporated by reference, as if fully set forth herein, made said document in Fulton County, Georgia, and uttered and delivered said document to the archivist of the United States in Fulton County, Georgia, which were overt acts to affect the object of conspiracy, contrary to the laws of said state, the good order, peace, and dignity thereof. Page 78. Count 12 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia, due charge and accused, David James Schaefer, Sean Micah Tresher Still, and Kathleen Austin Latham, with the offense of

false statements and writings, OCGA 16-10-20, for the said accused individually and as persons concerned in the commission of a crime, and together with unindicted co-conspirators in the County of Fulton and State of Georgia, on or about the 14th day of December 2020, knowingly, willfully, and unlawfully, made and used a false document titled, quote, Certificate of the Votes of the 2020 Electors from Georgia, unquote, with knowledge that said document contained the false statement, quote, 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, unquote, said document being within the jurisdiction of the office of the Georgia Secretary of State and the office of the Governor of Georgia, departments and agencies of the state government, contrary to the laws of said state, the good order, peace and dignity thereof. Count 13 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of georgia due charge and accused donald john trump rudolph william lewis giuliani john charles eastman kenneth john cheese bro ray stalling smith the third robert david sheely and michael a roman with the offense of conspiracy to commit false statements and writings ocga 16-4-8 and 16-10-20. For the said accused individually and as persons concerned in the commission of a crime, and together with indicted and unindicted co-conspirators in the County of Fulton and State of Georgia,

on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired to knowingly and willfully make and use a false document titled certificate of the votes of the 2020 electors from georgia with knowledge that said document contained the false statement we'd be undersigned being 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 Georgia Secretary of State and the Office of Governor of Georgia Departments and Agencies of State Government and the defendants named in count 12 acting as co-conspirators as described above and incorporated by reference

as if fully set forth herein made and used said document in Fulton County, Georgia, which were overt acts to affect the object of the conspiracy contrary to the laws of said state, the good order, and peace and dignity thereof. Page 79. Count 14 and 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse David James Schaefer, Sean Micah Thresher Still, and Kathleen Alston Latham with the offense of criminal attempt to commit filing false documents

OCGA 16-4-1 and 16-10-20.1b1 for the said accused individually and as persons concerned in the commission of a crime and together with unindicted co-conspirators in the county of fulton and state of georgia on or about the 14th day of december 2020 unlawfully with the intent to commit the crime of filing false documents ocga 16-10-20.1b1 placed in the united states mail a document titled certificate of the votes of the 2020 electors from Georgia Addressed to Chief Judge, U.S. District Court, Northern District of Georgia, 2188 Richard D. Russell Federal Office Building and U.S. Courthouse 75, Ted Turner Drive Southwest, Atlanta, Georgia 30303 A substantial step toward the commission of filing false documents

OCGA 16-10-20.1b1, with intent to knowingly file, enter, and record said document in a court of the United States, having reason to know that said document contained the materially false statement, we, the undersigned, being the duly elected and qualified electors for President and Vice President of the United States of America from the State of Georgia, Count 15 of 41. Donald John Trump, Rudolph William Lewis Giuliani, John Charles Eastman, Kenneth John Cheesebrough, Ray Stalling Smith III, Robert David Sheeley, and Michael A. Roman, with the offense of conspiracy to commit filing false documents OCGA 16-4-8 and 16-10-20.1b1, for the said accused individually and as persons concerned in the commission of a crime, and together with indicted and unindicted co-conspirators in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired to knowingly file, enter, and record a document titled

Certificate of the Votes of the 2020 Electors from Georgia in a court of the United States having reason to know that said document contained the materially false statement, we the undersigned, being the duly elected and qualified electors for the President and Vice President of the United States of America from the State of Georgia, do hereby certify the following. And the defendants named in Count 14, acting as co-conspirators as described above and incorporated by reference as if fully set forth herein placed in the united states mail said document addressed to chief judge u.s district court northern district of georgia 2188

richard d russell federal office building and u.s courthouse 75 ted turner drive southwest atlanta georgia 30303 in fulton county georgia which was an overt act to affect the object of the conspiracy contrary to the laws of said state the good order peace and dignity thereof page 80 count 16 to 41 and the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse David James Schaefer and Sean Micah Tresher Still with the offense of forgery in the first degree, OCGA 16-9-1B, for the said accused individually and as persons concerned in the commission of a crime and together with unindicted co-conspirators in the County of Fulton and State of Georgia on or about the 14th day of

December 2020, unlawfully and with the intent to defraud, knowingly made a document titled R.E. Notice of Filling of Electoral College Vacancy, a writing other than a check, in such a 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 Count 17 of 41 And the grand jurors aforesaid in the name and behalf of the citizens of Georgia, do charge and accuse Donald John Trump, Rudolph William Louis Giuliani, John Charles Eastman, Kenneth John Cheesebro, Ray Stalling Smith III, Robert David Shealy, and Michael A. Roman with the offense of conspiracy to commit forgery in the first degree, OCGA 16-4-8 and 16-9-1B.

For the said accused individually and as persons concerned in the commission of a crime and together with indicted and unindicted co-conspirators in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired with the intent to defraud to knowingly make a document titled, 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 to utter and deliver said document to the Archivist of the United States and the Office of the Governor of Georgia, and the

defendants named in Count 16, acting as co-conspirators as described above and incorporated by reference, as if fully set forth herein, made said document in Fulton County, Georgia, and uttered and delivered said document to the Archivist of the United States and the Office of the Governor of Georgia in Fulton County, Georgia, which were overt acts to affect the object of the conspiracy contrary to the laws of the said state, the good order, peace, and dignity thereof. Page 81, count 18 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia, due charge and accused David James Schaefer and Sean Micah Tresher Still, with the offense of false statements and writings,

OCGA 16-10-20, for the said accused individually and as persons concerned in the commission of a crime, and together with unindicted co-conspirators in the County of Fulton and State of Georgia, on or about the 14th day of December 2020, knowingly, willfully, and unlawfully made and used a false document titled, 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 Sean Micah Tresher Still was secretary of the 2020 Georgiaorgia electoral college meeting said document being within the jurisdiction of the office of the georgia secretary of state and the office of the governor of georgia departments and agencies of state government contrary to the laws of said state the good order peace and dignity thereof count 19 of 41 and the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Donald John Trump,

Rudolph William Louis Giuliani, John Charles Eastman, Kenneth John Cheesebro, Ray Stallings Smith III, Robert David Shealy, and Michael A. Roman, with the offense of conspiracy to commit false statements and writings, OCGA 16-4-8 and 16-10-20 for the set

accused individually and as persons concerned in the commission of a crime and together with indicted and unindicted co-conspirators in the county of fulton state of georgia on in between the sixth day of december 2020 and the 14th day of december, unlawfully conspired to knowingly and willfully make and use a false document titled RE Notice of Filling of Electoral College Vacancy with knowledge that said document contained the false statements that David James Schaefer was chairman of the 2020 Georgia Electoral College meeting and Sean Micah Tresher Still was secretary of the 2020 Georgia Electoral College meeting. Said document being within the jurisdiction of the office of the Georgia Secretary of State and the office of the Governor of Georgia, departments and agencies of state

government. And the defendants named in count 18 acting as co-conspirators as described above and incorporated by reference as if fully set forth herein, made and used said document in Fulton County, Georgia, which were overt acts to affect the object of the conspiracy contrary to the laws of said state, the good order, peace, and dignity thereof. Page 82, count 20 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia, due charge and accused Stephen Cliffguard Lee with the offensive criminal attempt to commit influencing witnesses,

OCGA 16-4-1 and 16-10-93B1A, for the said accused in the county of Fulton and state of Georgia on the 14th day of December, 2020. Unlawfully, with intent to commit the crime of influencing witnesses, traveled to the home of Ruby Freeman, a Fulton County, Georgia, election worker, and spoke to her neighbor, a substantial step toward the commission of influencing witnesses, OCGA 16-10-93B1A, with intent to knowingly engage in misleading conduct toward Ruby Freeman by purporting to offer her help and with intent

to influence her testimony in an official proceeding in Fulton County, Georgia concerning events at State Farm Arena in the November 3, 2020 presidential election in Georgia, said date being a material element of the offense contrary to the laws of said state, the good order, peace, and dignity thereof. Count 21 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Stephen Cliffguard Lee with the offense of criminal attempt to commit influencing witnesses OCGA 16-4-1 and 16-10-93B1A for the said accused in the county of Fulton and state of Georgia

on the 15th day of December 2020. Unlawfully, with intent to commit the crime of influencing witnesses, OCGA 16-10-93b-1a traveled to the home of Ruby Freeman, a Fulton County, Georgia, election worker, and knocked on her door, a substantial step toward the commission of influencing witnesses, OCGA 16-10-93-B1A, with intent to knowingly engage in misleading conduct toward Ruby Freeman. By purporting to offer her help and with intent to influence her testimony in an official proceeding in Fulton County, Georgia, concerning events at State Farm Arena in the November 3, 2020 presidential election in Georgia,

said date being a material element of the offense contrary to the laws of said state, the good order, peace, and dignity thereof. Page 83. Count 22 of 41. And the grand jurors, aforesaid in the name and behalf of the citizens of Georgia, do charge and accuse Jeffrey Boeser Clark with the offense of criminal attempt to commit false statements and writings OCGA 16-4-1 and 16-10-20 for the said accused individually and as a person concerned in the commission of a crime and together with unindicted co-conspirators in the county of Fulton and state of Georgia on and between the 28th day of December 2020 and the second day of January 2021.

Unlawfully, with intent to commit the crime of false statements and writings, OCGA 16-10-20 knowingly and willfully made a false writing and document knowing the same to contain the false statement that the United States Department of Justice had, quote, identified significant concerns that may have impacted the outcome of the election in multiple states, including the state of Georgia, unquote, said statement being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation Departments and Agencies of State Government and county and city law enforcement agencies. In honor about the 28th day of December 2020,

the said accused 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. And on or about the second day of January 2021, the said accused met with 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. And said acts constituted substantial steps toward the commission of false statements and writings, OCGA 16-10-20. And said conduct committed outside the state of Georgia constituted an attempt to commit a crime within the state of Georgia pursuant to OCGA 17-2-1B2, contrary to the laws of said state, the good order, peace, and dignity thereof.

Page 84, count 23 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia, do charge and accuse Rudolph William Lewis Giuliani, Ray Stalling Smith III, and Robert David Shealy, with the offense of solicitation of violation of oath by public officer OCGA 16-4-7 and 16-10-1, for the said accused individually and as persons concerned in the commission of a crime, and together with unindicted co-conspirators in the County of Fulton and State of Georgia,

on the 30th day of December 2020, unlawfully solicited, requested, and importuned certain public officers then serving as elected members of the Georgia Senate and present at a Senate Judiciary Subcommittee meeting, including unindicted co-conspirator Individual 8, whose identity is known to the grand jury, Senators Brandon Beach, Bill Heath, William Ligon, Michael Rett, and Blake Tillery to engage in conduct constituting the felony offense of violations 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, said date being a material element of the offense, contrary to the laws of said state,

the good order, peace, and dignity thereof. Count 24 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia, due charge and accused, Rudolph William Lewis Giuliani, with the offense of false statements and writings writings OCGA 16-10-20, for the said accused in the County of Fulton and State of Georgia on or about the 30th day of December 2020, knowingly, willfully, and unlawfully, made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting. 1. That Fulton County election workers fraudulently counted certain ballots

as many as five times at State Farm Arena on November 3, 2020. 2. That 2,560 felons voted illegally in the November 3, 2020 presidential election in Georgia. 3. That 10,315 dead people voted in the November 3, 2020 presidential election in Georgia. Said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government

and county and city law enforcement agencies, contrary to the laws of said state, the good order, peace and dignity thereof. of. Crime Stories with Nancy Grace. Page 85. Count 25 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Ray Stalling Smith III with the offense of false statements and writings OCGA 16-10-20 for the said accused in the County of Fulton and State of Georgia on or about the 30th day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the georgia senate present at a senate judiciary subcommittee meeting 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 3rd 2020 presidential election and told them not to vote in the jan 5, 2021 runoff election. And two, that the Georgia Secretary of State admitted that they had a 90% accuracy rate in the November 3, 2020 presidential election and that there's still a 10% margin that's not accurate. Said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said state, the good order, peace, and dignity thereof. Count 26 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia

do charge and accuse Robert David Shealy with the offense of false statements and writings OCGA 16-10-20 for the said accused in the county of Fulton in the state of Georgia on or about 30th day of December 2020 knowingly willfully and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting. One 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 3rd, 2020. Said statements being within the jurisdiction of the Office of the Georgia Secretary of State

and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said state, the good order, peace, and dignity thereof. Page 86 page 86 count 27 of 41 and the grand jurors aforesaid in the name and behalf of the citizens of georgia do charge and accuse donald john trump and john charles eastman with the offense of filing false documents ocga 16-10-20.1 b1 for the said accused individually and as persons concerned in the commission of a crime and together with unindicted co-conspirators in the County of Fulton and State of Georgia on or about the 31st day of December 2020, knowingly and unlawfully filed a document titled Verified Complaint for Emergency Injunctive and Declaratory Relief in the Matter of Trump v. Kemp. 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. 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 3rd, 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 3rd, 2020 at State Farm Arena in Fulton County, Georgia. Contrary to the laws of said state, the good order, peace,

and dignity thereof. Page 87. Count 28 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Donald John Trump and Mark Randall Meadows with the offense of solicitation of violation of oath by public officer OCGA 16-4-7 and 16-10-1 for the said accused individually and as persons concerned in the commission of a crime and together with unindicted co-conspirators in the county of Fulton and state of Georgia on or about the second day of January 2021 unlawfully solicited requested and importuned georgia secretary of state brad rafsonberger 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 contrary to the laws of said state, the good order, peace, and dignity thereof. Page 88, Count 29 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia, Page 88, Count 29 of 41. about the second day of January 2021, knowingly, willfully, and unlawfully, made at least one of the following false statements and representations to Georgia Secretary of State Brad Raffensperger, Georgia Deputy Secretary of State Jordan Fuchs, and Georgia Secretary of State General Counsel Ryan Germany. One, that anywhere from 250,000 to 300,000 ballots were dropped mysteriously into the rolls in the November 3rd, 2020 presidential election in Georgia.

Two, that thousands of people attempted to vote in the November 3rd, 2020 presidential election in Georgia and were told they could not because a ballot had already been cast in their name. Three, that 4,502 people voted in the November 3rd, 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. Six, 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 3rd, 2020 presidential election in Georgia. Seven, that close to 5,000 dead people voted in the November 3rd, 2020 presidential election in Georgia. Eight, that 139% of people voted in the November 3rd, 2020 presidential election in Detroit. Nine, that 200,000 more votes were recorded than the number of people who voted in the November 3rd, 2020 presidential election in Pennsylvania. Ten, that thousands of dead people voted in the November 3rd, 2020 Page 89. 13. That he won the November 3rd, 2020 presidential election in Georgia by 400,000 votes. Said statements being within the jurisdiction of the office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, contrary to the laws of said state,

the good order, peace, and dignity thereof. Count 30 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Stephen Cliffguard Lee, Harrison William Prescott Floyd, and Trevian C. Cuddy with the offense of conspiracy to commit solicitation of false statements and writings, OCGA 16-4-8, 16-4-7, and 16-10-20. For the said accused individually and as persons concerned in the commission of a crime, and together with unindicted co-conspirators in the County of Fulton and State of Georgia, on or about the fourth day of January 2021, unlawfully conspired to solicit, request, and importune Ruby Freeman, a Fulton County, Georgia, election worker,

to engage in conduct constituting the felony offense of false statements and writings, OCGA 16-10-20, by knowingly and willfully making a false statement and representation concerning events at State Farm Arena in the November 3, 2020, presidential election in Georgia, said statement and representation concerning events at State Farm Arena in the November 3, 2020 presidential election in Georgia. Said statement and representation being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation,

departments and agencies of state government and county and city law enforcement agencies with intent that said person engage in said conduct and Trevi and C. Cuddy traveled to Fulton County, Georgia and placed a telephone call to Ruby Freeman with intent that said person engage in said conduct and treviancy, Cuddy traveled to Fulton County, Georgia, and placed a telephone call to Ruby Freeman while in Fulton County, Georgia, which were overt acts to affect the object of the conspiracy, contrary to the laws of said state, the good order, peace, and dignity thereof.

Count 31 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia Count 31 of 41. 161A. For the said accused individually and his person's concern in the commission of a crime and together with the unindicted co-conspirators in the County of Fulton and State of Georgia on or about the fourth day of January 2021, knowingly and unlawfully engaged in misleading conduct toward Ruby Freeman, a Fulton County, Georgia election worker, by stating that she needed protection and by purporting to offer her help with intent to influence her testimony in an official proceeding in Fulton County, Georgia, concerning events at State Farm Arena in the November 3, 2020 presidential election in Georgia, contrary to the laws of said state, the good order, peace, and dignity thereof. Page 90. Count 32 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Sidney Catherine Powell, Kathleen Alston Latham,

Scott Graham Hall, and Misty Hampton with the offense of conspiracy to commit election fraud, OCGA 21-2-603 and 21-2-566, for the said accused individually and his persons concerned in the commission of a crime and together with unindicted co-conspirators in the county of Fulton and state of Georgia on and between the first day of December 2020 and the seventh day of January 2021 unlawfully conspired and agreed to willfully tamper with electronic ballot markers and tabulating machines in the state of Georgia. And Sidney Catherine Powell entered into a contract

with Sullivan Strickler LLC in Fulton County, Georgia, delivered a payment to Sullivan Strickler LLC in Fulton County, Georgia, and caused employees of Sullivan Strickler LLC to travel from Fulton County, Georgia to Coffey County, Georgia for the purpose of willfully tampering with said electronic equipment, markers, and tabulating machines, which were overt acts to affect the object of the conspiracy. And Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton aided, abetted, and encouraged employees of Sullivan Strickler LLC in willfully tampering

with electronic ballot markers and tabulating machines, while inside the Coffey County Elections and Registration Office in Coffey County, Georgia, which were overt acts to affect the object of the conspiracy, contrary to the laws of said state, the good order, peace, and dignity thereof. Page 91, count 33 of 41. And the grand jurors, aforesaid in the name and behalf of the citizens of Georgia, do charge and accuse Sidney Catherine Powell, Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton with the offense of conspiracy to commit election fraud, OCGA 21-2-603 and 21-2-574. For the said accused individually and his persons concerned in the commission of a

crime and together with unindicted co-conspirators in the county of Fulton and state of Georgia on and between the first day of December 2020 and the seventh day of January 2021 unlawfully conspired and agreed to cause certain members of the conspiracy who were not officers charged by law with the care of ballots and who were not persons entrusted by any such officer with the care of ballots for a purpose required by law to possess official ballots outside of the polling place in the state of Georgia. And Sidney Catherine Powell entered into a contract with Sullivan Strickler LLC in Fulton County, Georgia, delivered a payment to Sullivan Strickler LLC in Fulton County, Georgia, delivered a payment to Sullivan Strickler LLC in Fulton County, Georgia,

and caused employees of Sullivan Strickler LLC to travel from Fulton County, Georgia to Coffey County, Georgia for the purpose of causing certain members of the conspiracy, who were not officers charged by law with the care of ballots, and who were not persons entrusted by any such officer with the care of ballots for a purpose required by law to possess official ballots outside of the polling place, which were overt acts to affect the object of the conspiracy. And Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton aided and abetted and encouraged employees of Sullivan Strickler LLC in accessing election equipment while inside the Coffey

County Elections and Registration and registration office in coffee County, Georgia, for the purpose of causing certain members of the conspiracy who are not officers charged by law with the care of ballots and who were not persons entrusted by any such officer with the care of ballots for a purpose required by law to possess official ballots outside of the polling place, which were overt acts to affect the object of the conspiracy, contrary to the laws of said state, the good order, peace, and dignity thereof.

Page 92, count 34 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Sidney Catherine Powell, Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton with the offense of conspiracy to commit computer theft, OCGA 16-4-8, 16-9-93A, for the said accused unindicted co-conspirators in the County of Fulton and State of Georgia on and between the first day of December, 2020 and the seventh day of January, 2021 unlawfully conspired to use a computer with knowledge that such use was without authority.

And with the intention of taking and appropriating information, data and software, the property of dominion voting systems Systems Corporation, and Sidney Catherine Powell entered into a contract with Sullivan Strickler LLC in Fulton County, Georgia, delivered a payment to Sullivan Strickler LLC in Fulton County, Georgia, and caused employees of Sullivan Strickler LLC to travel from Fulton County, Georgia to Coffey County, Georgia for the purpose of using a computer with knowledge that such use was without authority and with the intention of taking and appropriating information, data and software, the property of Dominion Vler LLC in using a computer with knowledge that such use was without authority and with the intention of taking and appropriating information data

as software, the property of Dominion Voting Systems Corporation, while inside the Coffey County Elections and Registration Office in Coffey County, Georgia, which were overt acts to affect the object of the conspiracy contrary to the laws of said state the good order peace and dignity thereof page 93 count 35 of 41 and the grand jurors aforesaid in the name and behalf of the citizens of georgia due charge and accused sydney catherine powell kathleen Alston Latham, Scott Graham Hall, and Misty Hampton with the offense of conspiracy to commit computer trespass OCGA 16-4-8 and 16-9-93B

for the said accused individually and as persons concerned in the commission of a crime and together with unindicted co-conspirators in the County of Fulton and State of Georgia on and between the first day of December 2020 and the seventh day of January 2021, unlawfully conspired to use a computer with knowledge that such use was without authority and with the intention of removing voter data and Dominion Voting Systems Corporation data from said computer. And Sydney Catherine Powell entered into a contract with Sullivan Strickler LLC in Fulton County, Georgia, delivered a payment to Sullivan Strickler LLC in Fulton County, Georgia, and caused employees of Sullivan Strickler LLC to travel from Fulton County, Georgia to Coffey County, Georgia,

for the purpose of using a computer with knowledge that such use was without authority and with the intention of removing voter data and Dominion Voting System Corporation data from said computer, which were overt acts to affect the object of the conspiracy. And Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton aided, abetted, and encouraged employees of Sullivan Strickler LLC in using a computer with knowledge that such use was without authority and with the intention of removing voter data and Dominion Voting Systems Corporation data from said computer

while inside the Coffey County Elections and Registration Office in Coffey County, Georgia, which were overt acts to affect the object of the conspiracy, contrary to the laws of said state, the good order, peace, and dignity thereof. Page 94, Count 36 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Sidney Catherine Powell, Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton with the offense of conspiracy

to commit computer invasion of privacy, OCGA 16-4-8 and 16-9-93-C. For the said accused individually and as persons concerned in the commission of a crime, and together with unindicted co-conspirators in the County of Fulton and State of Georgia, on and between the first day of December 2020 and the seventh day of January 2021, unlawfully conspired to use a computer with the intention of examining personal voter data with knowledge that such examination was without authority. And Sidney Catherine Powell entered into a contract with Sullivan Strickler LLC in Fulton County, Georgia, delivered a payment to Sullivan Strickler LLC in Fulton County, Georgia, and caused employees of

Sullivan Strickler LLC to travel from Fulton County, Georgia to Coffey County, Georgia, and caused employees of Sullivan Strickler LLC to travel from Fulton County, Georgia to Coffey County, Georgia, for the purpose of using a computer with the intention of examining personal voter data with knowledge that such examination was without authority, which were overt acts to affect the object of the conspiracy. And Kathleen Alston Latham and Scott Graham Hall and Misty Hampton aided, abetted, and encouraged employees of Sullivan Strickler LLC in using a computer with the intention of examining personal voter data with knowledge that such examination was without authority while inside the Coffey County Elections and Registration Office in Coffey County, Georgia, which were overt acts to affect the object of the conspiracy contrary to the laws of said state the good order peace and dignity thereof page 95 count 37 of 41 and the grand jurors aforesaid in the name and behalf of the citizens of georgia do charge and accuse sydney katherine powell kathleen alston latham scott graham hall and misty hampton with the offense of conspiracy to defraud the state

OCGA 16-10-21 for the said accused individually and as persons concerned in the commission of a crime and together with unindicted co-conspirators in the county of Fulton and state of Georgia on and between the first day of December 2020 and the seventh day of January 2021 unlawfully conspired and agreed to commit theft of voter data property, which was under the control of Georgia Secretary of State Brad Raffensperger, a state officer in his official capacity, and Sidney Catherine Powell entered into a contract with Sullivan Strickler LLC in Fulton County, Georgia, delivered a payment to Sullivan Strickler LLC in Fulton County, Georgia, and caused employees of Sullivan Strickler LLC to travel from Fulton County, Georgia,

to Coffey County, Georgia, for the purposes of committing theft of voter data property, which was under the control of Georgia's Secretary of State, Brad Raffensperger, a state officer in his official capacity, which were overt acts to affect the object of the conspiracy. And Kathleen Alston Latham, Scott Graham, Hall, and Misty Hampton aided and abetted and encouraged employees of Sullivan Strickler LLC in accessing election equipment while inside Coffey County Elections and Registration Office in Douglas, Georgia, for the purpose of committing theft of voter data property, which was under the control of Georgia Secretary of State Brad R raffensperger a state officer in his official capacity which were overt acts to affect the

object of the conspiracy contrary to the laws of said state the good order peace and dignity thereof count 38 of 41 and the grand jurors aforesaid in the name and behalf of the citizens of georgia do charge and accuse donald john trump with the offense of solic of the citizens of Georgia, do charge and accuse Donald John Trump with the offense of solicitation of violation of oath by public officer OCGA 16-4-7 and 16-10-1 for the said accused in the County of Fulton and State of Georgia on or about the 17th day of September 2021. Unlawfully solicited, requested, and importuned Georgia Secretary of State Brad Raffensperger, a public officer, to engage in conduct constituting the felony offense of violation of oath by a public officer, OCGA 16-10-1, by un true winner, unquote, in willful and intentional violation of the terms of the oath of said person as prescribed by law with intent that said person engage in said conduct contrary to the laws of said state, the good order, peace, and dignity thereof.

Page 96, count 39 of 41. of September 2021, knowingly, willfully, and unlawfully made the following false statement and representation to Georgia Secretary of State Brad Raffensperger. One, quote, as stated to you previously, the number of false and or irregular votes is far greater than needed to change the Georgia election result, unquote. Said statement being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies,

contrary to the laws of said state, the good order, peace, and dignity thereof. Count 40 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of georgia do charge and accuse david james schaefer with the offense of false statements and writings ocga 16-10-20 for the said accused in the county of fulton and state of georgia honor about the 25th day of april 2022 knowingly willfully and unlawfully made at least one of the following

false statements and representations in the presence of Fulton County District Attorney's Office investigators. One, that he attended and convened the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia, but that he did not call each one of the individual members and notify them of the meeting or make any of the other preparations necessary for the meeting. Two, that a court reporter was not present at the December 14, 2020 meeting of Trump presidential electors, nominees in Fulton County, Georgia. Said statements being within the jurisdiction of Fulton County District Attorney's Office, a department and agency of the government of a county of this state,

contrary to the laws of said state, and good order, peace, and dignity thereof. Page 97. Count 41 of 41. And the grand jurors aforesaid in the name and behalf of the citizens of Georgia do charge and accuse Robert David Cheely with the offense of perjury OCGA 16-10-70A for the said accused in the county of Fulton and state of Georgia on or about the 15th day of September 2022 knowingly willfully and unlawfully made at least one of the following false statements before the Fulton County special purpose grand jury a judicial proceeding after having been administered a lawful oath. One, that he was unaware of the December 14, 2020 meeting

of Trump presidential elector nominees in Fulton County, Georgia until after the meeting had already taken place. Two, that he had no substantive conversations with anyone concerning the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia until after the meeting had already taken place. Three, that he never suggested to anyone that Trump presidential elector nominees in Georgia should meet on December 14, 2020. Four, that the only communication he had with John Eastman concerning the November 3, 2020

presidential election was for the purpose of connecting Eastman to Georgia Senator Brandon Beach and unindicted co-conspirator Individual 8 whose identity is known to the grand jury for possible legal representation. Five, that he never worked to connect John Eastman with any Georgia legislators other than Georgia Senator Brandon Beach and unindicted co-conspirator individual aid whose identity is known to the grand jury. Said statements, being material to the accused's own involvement in the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia, and to the accused's communications

with others involved in said meeting, the issue in question, contrary to the laws of said state, the good order, peace, and dignity thereof. Fannie T. Willis, District Attorney. Page 98, Witness List. Assistant Chief, Investigator M. Hill. Senior Investigator T. Swanson Lucas. This is an iHeart Podcast.