The GA Indictment Read by Ali Velshi: Part 1
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Hello and welcome to a special episode of Prosecuting Donald Trump. I'm Ali Velshi. By now you've heard about the stunning new indictment handed down in Georgia charging Donald Trump and his allies with felony racketeering and conspiracy charges as part of their alleged efforts to overturn the 2020 election there.

Fulton County DA Fani Willis laying out her case in a 41 count, 98 page document. And I want to read every word to you as I have with previous indictments. But because this one is so long, we will break it up into two parts released on two different days. The first part covers count one, the racketeering charges, something normally reserved for mobsters.

Part two covers the rest. Trump, of course, denies any wrongdoing. But as I've done previously, I'll read you the entire document so that you have all the information. So here we go with part one of the Georgia indictment.

Fulton County Superior Court Indictment, Count 1 of 41. The grand jurors aforesaid in the name and behalf of the citizens of Georgia do hereby charge and accuse Donald John Trump, Rudolph William Louis Giuliani, John Charles Eastman, Mark Randall Meadows, Kenneth John Cheeseborough, Jeffrey Bossert Clark,

Jenna Lynn Ellis, Ray Stallings Smith III, Robert David Cheely, Michael A. Roman, David James Schaefer, Sean Micah Tresher Still, Stephen Cliffguard Lee, Harrison William Prescott Floyd, Trevian C. Cootey, Sydney Catherine Powell, Kathleen Alston Latham,

Scott Graham Hall, and Misty Hampton with the offense of violation of the Georgia RICO, Racketeer Influenced and Corrupt Organizations Act, Official Code of Georgia Annotated, Section 16-14-4C.

For the said accused, individually and as persons concerned in the commission of a crime, and together with unindicted co-conspirators, in the state of Georgia and county of Fulton, on and between the 4th day of November 2020 and the 15th day of September 2022—

while associated with an enterprise unlawfully conspired and endeavored to conduct and participate in, directly and indirectly, such enterprise through a pattern of racketeering activity in violation of OCGA section 16-14-4b, as described below and incorporated by reference as if fully set forth herein.

contrary to the laws of said state, the good order, peace, and dignity thereof.

Introduction. Defendant Donald John Trump lost the United States presidential election held on November 3, 2020. One of the states he lost was Georgia. Trump and the other defendants charged in this indictment refused to accept that Trump lost, and they knowingly and willfully joined a conspiracy to unlawfully change the outcome of the election in favor of Trump.

That conspiracy contained a common plan and purpose to commit two or more acts of racketeering activity in Fulton County, Georgia, elsewhere in the state of Georgia, and in other states.

The Enterprise. At all times relevant to this count of the indictment, the defendants, as well as others not named as defendants, unlawfully conspired and endeavored to conduct and participate in a criminal enterprise in Fulton County, Georgia and elsewhere. Defendants Donald John Trump,

Rudolph William Louis Giuliani, John Charles Eastman, Mark Randall Meadows, Kenneth John Cheesebrough, Jeffrey Bossert Clark, Jenna Lynn Ellis, Ray Stalling Smith III,

Robert David Cheely, Michael A. Roman, David James Schaefer, Sean Micah Tresher Still, Stephen Cliffguard Lee, Harrison William Prescott Floyd, Trevian C. Cootey, Sydney Catherine Powell, Kathleen Alston Latham,

Scott Graham Hall, Misty Hampton, unindicted co-conspirators Individual 1 through Individual 30, and others known and unknown to the grand jury, constituted a criminal organization whose members and associates engaged in various related criminal activities, including, but not limited to, false statements and writings impersonating a public officer,

Forgery, filing false documents, influencing witnesses, computer theft, computer trespass, computer invasion of privacy, conspiracy to defraud the state, acts involving theft and perjury.

This criminal organization constituted an enterprise as that term is defined in OCGA section 16-14-3-3. That is, a group of individuals associated in fact. The defendants and other members and associates of the enterprise had connections and relationships with one another and with the enterprise.

The enterprise constituted an ongoing organization whose members and associates functioned as a continuing unit for a common purpose of achieving the objectives of the enterprise.

The enterprise operated in Fulton County, Georgia, elsewhere in the state of Georgia, in other states including, but not limited to, Arizona, Michigan, Nevada, New Mexico, Pennsylvania, and Wisconsin, and in the District of Columbia. The enterprise operated for a period of time sufficient to permit its members and associates to pursue its objectives.

Manner and methods of the enterprise. The manner and methods used by the defendants and other members and associates of the enterprise to further the goals of the enterprise and to achieve its purpose included, but were not limited to, the following. 1. False statements to and solicitation of state legislatures.

Members of the Enterprise, including several of the defendants, appeared at hearings in Fulton County, Georgia, before members of the Georgia General Assembly on December 3, 2020, December 10, 2020, and December 30, 2020. At these hearings, members of the Enterprise made false statements concerning fraud in the November 3, 2020 presidential election.

The purpose of these false statements was to persuade Georgia legislators to reject lawful electoral votes cast by the duly elected and qualified presidential electors from Georgia. Members of the enterprise corruptly solicited Georgia legislators instead to unlawfully appoint their own presidential electors for the purpose of casting electoral votes for Donald Trump.

Members of the enterprise also made false statements to state legislators during hearings and meetings in Arizona, Michigan, and Pennsylvania in November and December 2020 to persuade legislators in those states to unlawfully appoint their own presidential electors. 2. False statements to and solicitation of high-ranking state officials.

Members of the enterprise, including several of the defendants, made false statements in Fulton County and elsewhere in the state of Georgia to Georgia officials, including the governor, the secretary of state, and the speaker of the House of Representatives.

Members of the enterprise also corruptly solicited Georgia officials, including the Secretary of State and the Speaker of the House of Representatives, to violate their oaths to the Georgia Constitution and to the United States Constitution by unlawfully changing the outcome of the November 3, 2020 presidential election in Georgia in favor of Donald Trump.

Members of the enterprise also made false statements to and solicited state officials in Arizona, Michigan, and Pennsylvania.

3. Creation and distribution of false Electoral College documents. Members of the enterprise, including several of the defendants, created false Electoral College documents and recruited individuals to convene and cast false Electoral College votes at the Georgia State Capitol in Fulton County on December 14, 2020.

After the false Electoral College votes were cast, members of the enterprise transmitted the votes to the President of the United States Senate, the Archivist of the United States, the Georgia Secretary of State, and the Chief Judge of the United States District Court for the Northern District of Georgia.

The false documents were intended to disrupt and delay the joint session of Congress on January 6, 2021, in order to unlawfully change the outcome of the November 3, 2020 presidential election in favor of Donald Trump.

Similar schemes were executed by members of the enterprise in Arizona, Michigan, Nevada, New Mexico, Pennsylvania, and Wisconsin. 4. Harassment and intimidation of Fulton County election worker Ruby Freeman.

Members of the enterprise, including several of the defendants, falsely accused Fulton County election worker Ruby Freeman of committing election crimes in Fulton County, Georgia. These false accusations were repeated to Georgia legislators and other Georgia officials in an effort to persuade them to unlawfully change the outcome of the November 3, 2020 presidential election in favor of Donald Trump.

In furtherance of this scheme, members of the enterprise traveled from out of state to harass Freeman, intimidate her, and solicit her to falsely confess to election crimes she did not commit. 5. Solicitation of high-ranking United States Department of Justice officials.

Members of the enterprise, including several of the defendants, corruptly solicited high-ranking United States Department of Justice officials to make false statements to government officials in Fulton County, Georgia, including the governor, the Speaker of the House of Representatives, and the President Pro Tempore of the Senate.

In one instance, Donald Trump stated to the acting United States Attorney General, quote, just say the election was corrupt and leave the rest to me and the Republican congressman, end quote.

6. Solicitation of the Vice President of the United States. Members of the enterprise, including several of the defendants, corruptly solicited the Vice President of the United States to violate the United States Constitution and federal law by unlawfully rejecting electoral college votes cast in Fulton County, Georgia, by the duly elected and qualified presidential electors from Georgia.

Members of the enterprise also corruptly solicited the vice president to reject votes cast by the duly elected and qualified presidential electors from several other states. Seven, unlawful breach of election equipment in Georgia and elsewhere.

Members of the enterprise, including several of the defendants, corruptly conspired in Fulton County, Georgia and elsewhere to unlawfully access secure voting equipment and voter data. In Georgia, members of the enterprise stole data, including ballot images, voting equipment software, and personal voter information. The stolen data was then distributed to other members of the enterprise, including members in other states. 8.

obstructive acts in furtherance of the conspiracy and the cover-up. Members of the enterprise, including several of the defendants, filed false documents, made false statements to government investigators, and committed perjury in judicial proceedings in Fulton County, Georgia and elsewhere in furtherance of and to cover up the conspiracy. Acts of racketeering activity and overt acts in furtherance of the conspiracy.

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

Act 1. On or about the fourth day of November 2020, Donald John Trump made a nationally televised speech falsely declaring victory in the 2020 presidential election. Approximately four days earlier, on or about October 31, 2020, Donald John Trump discussed a draft speech with unindicted co-conspirator Individual 1,

whose identity is known to the grand jury, that falsely declared victory and falsely claimed voter fraud. The speech was an overt act in furtherance of the conspiracy.

On or about the 15th day of November 2020, Rudolph William Louis Giuliani placed a telephone call to unindicted co-conspirator Individual 2, whose identity is known to the grand jury, and left an approximately 83-second-long voicemail message for unindicted co-conspirator Individual 2, making statements concerning fraud in the November 3, 2020 election in Fulton County, Georgia.

This telephone call was an overt act in furtherance of the conspiracy. Act 3.

On or about the 19th day of November 2020, Rudolph William Louis Giuliani, Jenna Lynn Ellis, Sidney Catherine Powell, and unindicted co-conspirator Individual 3, whose identity is known to the grand jury, appeared at a press conference at the Republican National Committee headquarters on behalf of Donald John Trump and Donald J. Trump for President, Inc., the Trump campaign.

and made false statements concerning fraud in the November 3, 2020 presidential election in Georgia and elsewhere. These were overt acts in furtherance of the conspiracy. Act 4.

On or about the 20th day of November 2020, David James Schaefer sent an email to unindicted co-conspirator Individual 4, whose identity is known to the grand jury and other individuals. In the email, David James Schaefer stated that Scott Graham Hall, a Georgia bail bondsman, quote, has been looking into the election on behalf of the president at the request previously.

of David Bossie, end quote, and asked unindicted co-conspirator Individual Four to exchange contact information with Scott Graham Hall and to, quote, help him as needed, end quote. This was an overt act in furtherance of the conspiracy.

Act 5. On or about the 20th day of November 2020, Donald John Trump and Mark Randall Meadows met with Majority Leader of the Michigan Senate Michael Shirky, Speaker of the Michigan House of Representatives Lee Chatfield, and other Michigan legislators in the Oval Office at the White House, and Donald John Trump made false statements concerning fraud in the November 3, 2020 presidential election in Michigan.

Rudolph William Louis Giuliani joined the meeting by telephone. This meeting was an overt act in furtherance of the conspiracy.

Act six on or about the 21st day of November, 2020, Mark Randall Meadows sent a text message to United States representative Scott Perry from Pennsylvania and stated, quote, can you send me the number for the speaker and leader of PA legislature? POTUS wants to chat with them. End quote. This was an overt act in furtherance of the conspiracy.

Act 7. On or about the 22nd day of November 2020, Donald John Trump and Rudolph William Louis Giuliani placed a telephone call to Speaker of the Arizona House of Representatives, Russell Rusty Bowers.

During the telephone call, Rudolph William Louis Giuliani made false statements concerning fraud in the November 3, 2020 presidential election in Arizona and solicited, requested, and importuned Bowers to unlawfully appoint presidential electors from Arizona.

Bowers declined and later testified to the United States House of Representatives Select Committee to investigate the January 6th attack on the United States Capitol that he told Donald John Trump, quote, I would not break my oath, end quote. The false statements and solicitations were overt acts in furtherance of the conspiracy.

Act 8. On or about the 25th day of November 2020, Rudolph William Lewis Giuliani and Jenna Lynn Ellis appeared, spoke, and presented witnesses at a meeting of Pennsylvania legislators in Gettysburg, Pennsylvania.

During the meeting, Rudolph William Louis Giuliani made false statements concerning fraud in the November 3, 2020 presidential election in Pennsylvania and solicited, requested, and importuned the Pennsylvania legislators present at the meeting to unlawfully appoint presidential electors from Pennsylvania.

During the meeting, Jenna Lynn Ellis solicited, requested, and importuned the Pennsylvania legislators present at the meeting to unlawfully appoint presidential electors from Pennsylvania. Donald John Trump joined the meeting by telephone and

made false statements concerning fraud in the November 3, 2020 presidential election in Pennsylvania, and solicited, requested, and importuned the Pennsylvania legislators present at the meeting to unlawfully appoint presidential electors from Pennsylvania. These were overt acts in furtherance of the conspiracy.

Act 9. On or about the 25th day of November 2020, immediately after the meeting of Pennsylvania legislators in Gettysburg, Pennsylvania, where Rudolph William Louis Giuliani and Jenna Lynn Ellis appeared, spoke, and presented witnesses, Donald John Trump invited a group of the Pennsylvania legislators and others to meet with him at the White House.

Later that day, Donald John Trump, Mark Randall Meadows, Rudolph William Louis Giuliani, Jenna Lynn Ellis, and unindicted co-conspirators Individual 5 and Individual 6, whose identities are known to the grand jury, met with the group of Pennsylvania legislators at the White House and discussed holding a special session of the Pennsylvania General Assembly.

These were overt acts in furtherance of the conspiracy. Act 10.

On or about the 26th day of November 2020, Rudolph William Louis Giuliani and Jenna Lynn Ellis placed a telephone call to Speaker of the Pennsylvania House of Representatives Brian Cutler and left Cutler a voicemail message for the purpose of soliciting, requesting, and importuning him to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy.

Act 11. On or about the 26th day of November 2020, Rudolph William Louis Giuliani placed a telephone call to President Pro Tempore of the Pennsylvania Senate, Jacob Jake Corman, for the purpose of soliciting, requesting, and importuning Corman to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy. Act 12.

On or about the 27th day of November 2020, Rudolph William Louis Giuliani and Jenna Lynn Ellis placed a telephone call to Speaker of the Pennsylvania House of Representatives Brian Cutler and left Cutler a voicemail message for the purpose of soliciting, requesting, and importuning him to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy.

Act 13. On or about the 27th day of November 2020, Rudolph William Louis Giuliani and Jenna Lynn Ellis placed a telephone call to President Pro Tempore of the Pennsylvania Senate, Jake Corman, for the purpose of soliciting, requesting, and importuning Corman to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy.

Act 14. On or about the 27th day of November 2020, Donald John Trump placed a telephone call to President Pro Tempore of the Pennsylvania Senate, Jake Corman, for the purpose of soliciting, requesting, and importuning Corman to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy. Act 15.

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

Act 16. On or about the 29th day of November 2020, Rudolph William Louis Giuliani placed a telephone call to Speaker of the Pennsylvania House of Representatives Brian Cutler and left Cutler a voicemail message for the purpose of soliciting, requesting, and importuning him to unlawfully appoint presidential electors from Pennsylvania. This was an overt act in furtherance of the conspiracy.

Act 17. On or about the 30th day of November 2020, Rudolph William Lewis Giuliani and Jenna Lynn Ellis appeared, spoke, and presented witnesses at a meeting of Arizona legislators in Phoenix, Arizona. Unindicted co-conspirators Individual 5 and Individual 6, whose identities are known to the grand jury, were also present.

During the meeting, Rudolph William Louis Giuliani made false statements concerning fraud in the November 3, 2020 presidential election in Arizona and solicited, requested, and importuned the Arizona legislators present at the meeting to unlawfully appoint presidential electors from Arizona.

During the meeting, Jenna Lynn Ellis solicited, requested, and importuned the Arizona legislators present at the meeting to unlawfully appoint presidential electors from Arizona. Donald John Trump joined the meeting by telephone and made false statements concerning fraud in the November 3, 2020 presidential election in Arizona. These were overt acts in furtherance of the conspiracy.

Act 18. On or about the 30th day of November 2020, Michael A. Roman instructed unindicted co-conspirator Individual 7, whose identity is known to the grand jury, to coordinate with individuals associated with the Trump campaign, to contact state legislators in Georgia and elsewhere on behalf of Donald John Trump, and to encourage them to unlawfully appoint presidential electors from their respective states.

This was an overt act in furtherance of the conspiracy.

On or between the first day of December 2020 and the 31st day of December 2020, Donald John Trump and Mark Randall Meadows met with John McEntee and requested that McEntee prepare a memorandum outlining a strategy for disrupting and delaying the joint session of Congress on January 6, 2021.

the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states. The strategy included having Vice President Michael R. Mike Pence count only half of the electoral votes from certain states and then return the remaining electoral votes to state legislators. The request was an overt act in furtherance of the conspiracy.

Act 20. On or about the first day of December 2020, Rudolph William Lewis Giuliani and Jenna Lynn Ellis met with the Speaker of the Arizona House of Representatives, Rusty Bowers, President of the Arizona Senate, Karen Fann, and other Arizona legislators in Phoenix, Arizona. Unindicted co-conspirator Individual 5, whose identity is known to the grand jury, was also present. During the

During the meeting, Rudolph William Louis Giuliani made false statements concerning fraud in the November 3, 2020 presidential election in Arizona and solicited, requested, and importuned the legislators present to call a special session of the Arizona State Legislature. These were overt acts in furtherance of the conspiracy. Act 21.

On or about the second day of December 2020, Rudolph William Louis Giuliani and Jenna Lynn Ellis appeared, spoke, and presented witnesses at a meeting of the Michigan House of Representatives Oversight Committee.

During the meeting, Rudolph William Louis Giuliani made false statements concerning fraud in the November 3, 2020 presidential election in Michigan and solicited, requested, and importuned the Michigan legislators present at the meeting to unlawfully appoint presidential electors from Michigan.

During the meeting, Jenna Lynn Ellis solicited, requested, and importuned the Michigan legislators present at the meeting to unlawfully appoint presidential electors from Michigan. These were overt acts in furtherance of the conspiracy.

Act 22. On or about the third day of December 2020, Donald John Trump caused to be tweeted from the Twitter account at real Donald Trump, quote, Georgia hearings now on at OANN. Amazing, end quote. This was an overt act in furtherance of the conspiracy.

Act 23. On or about the third day of December 2020, Rudolph William Lewis Giuliani, John Charles Eastman, Jenna Lynn Ellis, and Ray Stalling Smith III committed the felony offense of solicitation of violation of oath by public officer.

in violation of OCGA Sections 16-4-7 and 16-10-1 in Fulton County, Georgia, by unlawfully soliciting, requesting, and importuning certain public officers

then serving as elected members of the Georgia Senate and present at a Senate Judiciary Subcommittee meeting, including unindicted co-conspirator Individual 8, whose identity is known to the grand jury, Senators Lee Anderson, Brandon Beach, Matt Brass, Grisham,

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 section 16-10-1 by unlawfully appointing presidential electors from Georgia in willful and intentional violation of the terms of the oath of said persons as prescribed by law."

with the intent that said persons engage in said conduct. This was an overt act in furtherance of the conspiracy. Act 24. On or about the third day of December 2020, Rudolph William Lewis Giuliani committed the felony offense of false statements and writings in violation of OCGA section 16-10-20 in Fulton County, Georgia,

by knowingly, willfully, and unlawfully making at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting. One, that at least 96,600 mail-in ballots were counted in the November 3, 2020 presidential election in Georgia, despite there being no record of those ballots having been returned to a county elections office.

Two, that Dominion Voting System's equipment used in the November 3, 2020 presidential election in Antrim County, Michigan, mistakenly recorded 6,000 votes for Joseph R. Biden when the votes were actually cast for Donald John Trump.

Said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies. This was an act of racketeering activity under OCGA Section 16-14-3, Subsection 5A-22, and an overt act in furtherance of the conspiracy.

Act 25, on or about the third day of December 2020, Ray Stalling Smith III committed the felony offense of false statements and writings in violation of OCGA section 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 2,506 felons voted illegally in the November 3, 2020 presidential election in Georgia. Two, that 66,248 underage people illegally registered to vote before their 17th birthday prior to the November 3, 2020 presidential election in Georgia.

Three, that at least 2,423 people voted in the November 3, 2020 presidential election in Georgia who were not listed as registered to vote. Four, 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.

Five, that 10,315 or more dead people voted in the November 3, 2020 presidential election in Georgia. Six, that Fulton County election workers at State Farm Arena ordered poll watchers and members of the media to leave the tabulation area on the night of November 3, 2020 and continue to operate after ordering everyone to leave.

said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies. This was an act of racketeering activity under OCGA Section 16-14-3, Subsection 5A-22, and an overt act in furtherance of the conspiracy. Act 26.

On or about the third day of December 2020, Donald John Trump caused to be tweeted from the Twitter account at real Donald Trump, quote, wow, blockbuster testimony taking place right now in Georgia. Ballot stuffing by Dems when Republicans were forced to leave the large counting room. Plenty more coming, but this alone leads to an easy win of the state, end quote.

This was an overt act in furtherance of the conspiracy.

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

Act 28. On or about the third day of December 2020, Donald John Trump met with the Speaker of the Pennsylvania House of Representatives, Brian Cutler, in the Oval Office at the White House and discussed holding a special session of the Pennsylvania General Assembly. This was an overt act in furtherance of the conspiracy.

Act 29. On or between the third day of December 2020 and the 26th day of December 2020, Rudolph William Louis Giuliani placed a telephone call to President Pro Tempore of the Georgia Senate Cecil Terrell Butch Miller for the purpose of making false statements concerning fraud in the November 3, 2020 presidential election in Georgia.

This was an overt act in furtherance of the conspiracy. Act 30. On or between the third day of December and the 26th day of December 2020, Donald John Trump placed a telephone call to President Pro Tempore of the Georgia Senate, Butch Miller. This was an overt act in furtherance of the conspiracy.

Act 31. On or about the fifth day of December 2020, Donald John Trump placed a telephone call to Georgia Governor Brian Kemp and solicited, requested, and importuned Kemp to call a special session of the Georgia General Assembly. This was an overt act in furtherance of the conspiracy.

Act 32. On or about the sixth day of December 2020, Donald John Trump caused to be tweeted from the Twitter account at real Donald Trump, quote, "'Gee, what a surprise. Has anyone informed the so-called parentheses says he has no power to do anything, close parentheses, governor at Brian Kemp GA and his puppet lieutenant governor at Jeff Duncan GA that they could easily solve this mess and win?'

Signature verification and call a special session so easy, end quote. This was an overt act in furtherance of the conspiracy.

Act 33. On or about the sixth day of December 2020, Sidney Catherine Powell entered into a written engagement agreement with Sullivan Strickler LLC, a forensic data firm located in Fulton County, Georgia, for the performance of computer forensic collections and analytics on Dominion Voting Systems equipment in Michigan and elsewhere.

Act 34.

On or about the sixth day of December 2020, Robert David Shealy sent an email to John Charles Eastman, unindicted co-conspirator Individual 8, whose identity is known to the grand jury, and Georgia Senator Brandon Beach that stated, quote, I am working on setting up a call for you with the Speaker and the President pro tempore tomorrow. I am also making the leadership aware of the importance for Trump electors to meet on December 14th.

Please provide the citation to the requirements of the duties which they must comply with, end quote. This was an overt act in furtherance of the conspiracy. Act 35. On or about the sixth day of December 2020, John Charles Eastman sent an email to Robert David Cheely, unindicted co-conspirator Individual 8, whose identity is known to the grand jury, and Georgia Senator Brandon Beach,

that stated that the Trump presidential elector nominees in Georgia needed to meet on December 14, 2020, sign six sets of certificates of vote, and mail them, quote, to the president of the Senate and to other officials, end quote. This was an overt act in furtherance of the conspiracy. Act 36.

On or about the 6th day of December 2020, Robert David Cheely sent an email to unindicted co-conspirator Individual 2, whose identity is known to the grand jury, that stated he had been speaking with John Charles Eastman and was attempting to set up a call

Thank you.

In the email, Robert David Cheely stated, quote, Professor Eastman told me tonight that it is critical that the 16 electors for President Trump meet next Monday and vote in accordance with Title III, United States Code, Section 7, end quote. In the email, Robert David Cheely further stated, quote, I assume you can make sure this happens, end quote. This was an overt act in furtherance of the conspiracy. Act 37.

On or about the seventh day of December 2020, unindicted co-conspirator Individual 2, whose identity is known to the grand jury, sent an email to Robert David Cheely and David James Schaefer that stated, quote, Bob, can you get on a call with David Schaefer, state GOP chair, and I later this morning to discuss? David has been on top of a lot of efforts in the state. I get off a board call around 1030, end quote.

This was an overt act in furtherance of the conspiracy. Act 38. On or about the 7th day of December 2020, Rudolph William Lewis Giuliani caused to be tweeted from the Twitter account at Rudy Giuliani a retweet of unindicted co-conspirator Individual 8, whose identity is known to the grand jury, that stated, quote, Georgia Patriot Call to Action.

Today is the day we need you to call your state Senate and House reps and ask them to sign the petition for a special session. We must have free and fair elections in Georgia, and this is our only path to ensuring every legal vote is counted at real Donald Trump, end quote. This was an overt act in furtherance of the conspiracy.

Act 39. On or about the 7th day of December 2020, John Charles Eastman sent an email to Rudolph William Louis Giuliani with an attached memorandum titled, quote, the real deadline for settling a state's electoral votes, end quote.

The body of the email stated, quote, here's the memo we discussed, end quote. The memorandum was written by Kenneth John Cheesebro to James R. Troopas, an attorney associated with the Trump campaign, and advocates for the position that Trump presidential elector nominees in Wisconsin should meet and cast electoral votes for Donald John Trump on December 14, 2020, despite the fact that

that Donald John Trump lost the November 3, 2020 presidential election in Wisconsin. This email was an overt act in furtherance of the conspiracy.

Act 40. On or about the 7th day of December 2020, Donald John Trump requested that Bill White, an individual associated with the Trump campaign then residing in Fulton County, Georgia, provide him with certain information, including contact information for Majority Leader of the Georgia Senate Mike Dugan and President Pro Tempore of the Georgia Senate Butch Miller. The

The following day, White sent an email containing the requested information to Rudolph William Lewis Giuliani, unindicted co-conspirator Individual 5, whose identity is known to the grand jury, and others. This request was an overt act in furtherance of the conspiracy.

Act 41. Act 42.

On or about the 7th day of December 2020, Donald John Trump committed the felony offense of solicitation of violation of oath by public officer in violation of OCGA section 16-4-7 and 16-10-1 in Fulton County, Georgia,

by unlawfully soliciting, requesting, and importuning Speaker of the Georgia House of Representatives, David Ralston, a public officer, to engage in conduct constituting the felony offense of violation of oath by public officer, OCGA Section 16-10-1,

by calling a special session of the Georgia General Assembly for the purpose of unlawfully appointing presidential electors from Georgia in willful and intentional violation of the terms of the oath of said person as prescribed by law with intent that said person engage in said conduct. This was an overt act in furtherance of the conspiracy.

Act 43. On or about the 8th day of December 2020, Donald John Trump placed a telephone call to Georgia Attorney General Chris Carr for the purpose of making false statements concerning fraud in the November 3, 2020 presidential election in Georgia and elsewhere.

During the telephone call, Donald John Trump asked Carr not to discourage other state attorneys general from joining a federal lawsuit filed by the state of Texas contesting the administration of the November 3, 2020 presidential election in Georgia, Michigan, Pennsylvania, and Wisconsin. This was an overt act in furtherance of the conspiracy. Act 44.

On or about the eighth day of December 2020, Donald John Trump and John Charles Eastman placed a telephone call to Republican National Committee Chairwoman Ronna McDaniel to request her assistance gathering certain individuals to meet and cast electoral votes for Donald John Trump on December 14, 2020 in certain states, despite the fact that Donald John Trump lost the November 3, 2020 presidential election in those states.

This was an overt act in furtherance of the conspiracy.

Act 45. On or about the eighth day of December 2020, Michael A. Roman sent a text message to unindicted co-conspirator Individual 4, whose identity is known to the grand jury, stated that he had spoken to Misty Hampton and asked unindicted co-conspirator Individual 4 to, quote, get, end quote, Misty Hampton to attend the hearing before the Georgia House of Representatives Governmental Affairs Committee on December 10, 2020.

This was an overt act in furtherance of the conspiracy. Act 46. On or about the 9th day of December 2020, Kenneth John Cheesebro wrote a memorandum titled, quote, end quote, to James R. Troopas, an attorney associated with the Trump campaign.

The memorandum provides detailed state-specific instructions for how Trump presidential elector nominees in Georgia, Arizona, Michigan, Nevada, Pennsylvania, and Wisconsin would meet and cast electoral votes for Donald John Trump on December 14, 2020, despite the fact that Donald John Trump lost the November 3, 2020 presidential election in those states.

This was an overt act in furtherance of the conspiracy. Act 47. On or about the 10th day of December 2020, Kenneth John Cheesebro sent an email to Georgia Republican Party Chairman David James Schaefer, an unindicted co-conspirator Individual 9 whose identity is known to the grand jury.

Kenneth John Cheesebrough stated in the email that certain individuals associated with the Trump campaign asked him to, quote, help coordinate with the other five contested states to help with the logistics of the electors in other states, hopefully joining in casting their votes on Monday, end quote. This was an overt act in furtherance of the conspiracy.

Act 48. On or about the 10th day of December 2020, Kenneth John Cheesebro sent an email with attached documents to David James Schaefer and unindicted co-conspirators Individual 9, Individual 10, and Individual 11, whose identities are known to the grand jury.

The documents were to be used by Trump presidential elector nominees in Georgia for the purpose of casting electoral votes for Donald John Trump on December 14, 2020, despite the fact that Donald John Trump lost the November 2020 presidential election in Georgia. This was an overt act in furtherance of the conspiracy.

Act 49. On or about the 10th day of December 2020, Kenneth John Cheesebro sent an email with attached documents to Arizona Republican Party Executive Director Greg Safstan and others.

The documents were to be used by Trump presidential elector nominees in Arizona for the purpose of casting electoral votes for Donald John Trump on December 14, 2020, despite the fact that Donald John Trump lost the November 3, 2020 presidential election in Arizona. This was an overt act in furtherance of the conspiracy. Act 50.

On or about the 10th day of December 2020, Kenneth John Cheesebrough sent an email to Republican Party of Wisconsin Chairman Brian Schimming with proposed language for documents to be used by Trump presidential elector nominees in Wisconsin for the purpose of casting electoral votes for Donald John Trump on December 14, 2020, despite the fact that Donald John Trump lost the November 3, 2020 presidential election in Wisconsin.

This was an overt act in furtherance of the conspiracy.

Act 51. On or about the 10th day of December 2020, Kenneth John Cheesebro sent an email to Nevada Republican Party Vice Chairman Jim DeGraffenreid. Kenneth John Cheesebro stated in the email that Rudolph William Louis Giuliani and other individuals associated with the Trump campaign asked him, quote, to reach out to you and the other Nevada electors to run point on the plan to have all Trump candidates

Pence electors in all six contested states meet and transmit their votes to Congress on Monday, December 14, end quote. This was an overt act in furtherance of the conspiracy.

Act 52. On or about the 10th day of December 2020, Kenneth John Cheesebro sent an email with attached documents to Jim DeGraffenried. The documents were to be used by Trump presidential elector nominees in Nevada for the purpose of casting electoral votes for Donald John Trump on December 14, 2020, despite the fact that Donald John Trump lost the November 3, 2020 presidential election in Nevada.

This was an overt act in furtherance of the conspiracy.

Act 53. On or about the 10th day of December 2020, Kenneth John Cheesebrough sent an email with attached documents to Republican Party of Pennsylvania General Counsel Thomas W. King III. The documents were to be used by Trump presidential elector nominees in Pennsylvania for the purpose of casting electoral votes for Donald John Trump on December 14, 2020, despite the fact

that Donald John Trump lost the November 3, 2020 presidential election in Pennsylvania. This was an overt act in furtherance of the conspiracy.

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Act 54. On or between the 10th day of December 2020 and the 14th day of December 2020, David James Schaefer contacted unindicted co-conspirator Individual 2, whose identity is known to the grand jury, by telephone and discussed unindicted co-conspirator Individual 2's attendance at the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia.

This was an overt act in furtherance of the conspiracy. Act 55. On or about the 10th day of December 2020, Rudolph William Lewis Giuliani and Ray Stallings Smith III committed the felony offense of solicitation of violation of oath by public officer in violation of OCGA section 16-4-7 and 16-10-1 in Fulton County, Georgia,

by unlawfully soliciting, requesting, and importuning certain public officers, then serving as elected members of the Georgia House of Representatives and present at a House Governmental Affairs Committee meeting, including Representatives Shaw Blackmun, John Burns, Barry Fleming, Todd Jones, Bea Nguyen, 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 section 16-10-1 by unlawfully appointing presidential electors from Georgia in willful and intentional violation of the terms of the oath of said persons as prescribed by law

with intent that said persons engage in said conduct. This was an overt act in furtherance of the conspiracy. Act 56.

On or about the 10th day of December 2020, Rudolph William Louis Giuliani committed the felony offense of false statements and writings in violation of OCGA section 16-10-20 in Fulton County, Georgia, by knowingly, willfully, and unlawfully making at least one of the following false statements and representations to members of the Georgia House of Representatives,

present at a House Governmental Affairs Committee meeting. One, that it is quite clear from the State Farm Arena videos from November 3, 2020, that Fulton County election workers were stealing votes and that Georgia officials were covering up a crime in plain sight.

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

3. That between 12,000 and 24,000 ballots were illegally counted by Fulton County election workers at State Farm Arena on November 3, 2020. 4. That in Michigan, there were 700,000 more ballots counted than were sent out to voters in the November 3, 2020 presidential election, which was accounted for by quadruple counting ballots.

Five, that Ruby Freeman, Shea Moss, and an unidentified man were quite obviously surreptitiously passing around USB ports as if they're vials of heroin or cocaine, end quote, at State Farm Arena to be used to, quote, infiltrate the crooked Dominion voting machines, end quote.

Six, that 96,600 mail-in ballots were counted in the November 3, 2020 presidential election in Georgia, despite there being no record of those ballots having been returned to a county elections office.

said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies. This was an act of racketeering activity under OCGA Section 16-14-3, Subsection 5A-22, and an overt act in furtherance of the conspiracy.

Act 57. On or about the 11th day of December 2020, David James Schaefer reserved room 216 at the Georgia State Capitol in Fulton County, Georgia, for the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 58. On or about the 11th day of December 2020, Kenneth John Cheeseborough sent an email to Jim DeGraffenreid and stated that, quote, the purpose of having the electoral votes sent into Congress is to provide the opportunity to debate the election irregularities in Congress and to keep alive the possibility that the votes could be flipped to Trump, end quote. This was an overt act in furtherance of the conspiracy.

Act 59. On or about the 11th day of December 2020, Kenneth John Cheeseborough sent an email with attached documents to Greg Safstan and others.

The documents were to be used by Trump presidential elector nominees in Arizona for the purpose of casting electoral votes for Donald John Trump on December 14, 2020, despite the fact that Donald John Trump lost the November 3, 2020 presidential election in Arizona. This was an overt act in furtherance of the conspiracy.

Act 60. On or about the 11th day of December 2020, Kenneth John Cheeseborough sent an email with attached documents to Michael A. Roman and other individuals associated with the Trump campaign. The documents were to be used by Trump presidential elector nominees in Nevada for the purpose of casting electoral votes for Donald John Trump on December 14, 2020, despite the fact that

that Donald John Trump lost the November 3, 2020 presidential election in Nevada. This was an overt act in furtherance of the conspiracy.

Act 61. On or about the 11th day of December 2020, Kenneth John Cheesebrough sent an email with attached documents to Michael A. Roman, unindicted co-conspirator Individual 5, whose identity is known to the grand jury, and others. The documents were to be used by Trump presidential elector nominees in Georgia for the purpose of casting electoral votes for Donald John Trump on December 14, 2020, despite the fact that

that Donald John Trump lost the November 3, 2020 presidential election in Georgia. This was an overt act in furtherance of the conspiracy.

Act 62. On or about the 12th day of December 2020, David James Schaefer contacted unindicted co-conspirator Individual 12, whose identity is known to the grand jury, and discussed unindicted co-conspirator Individual 12's attendance at the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 63. On or about the 12th day of December 2020, Michael A. Roman sent an email to unindicted co-conspirators Individual 4 and Individual 7, whose identities are known to the grand jury and other individuals associated with the Trump campaign.

In the email, Michael A. Roman stated, quote, I need a tracker for the electors, end quote, and instructed individuals associated with the Trump campaign to populate entries on a shared spreadsheet listing Trump presidential elector nominees in Georgia, Arizona, Michigan, Nevada, Pennsylvania, and Wisconsin. The

The entries on the spreadsheet included contact information for the Trump presidential elector nominees, whether the Trump presidential elector nominees had been contacted, and whether the Trump presidential elector nominees had confirmed that they would attend the December 14, 2020 meetings of Trump presidential elector nominees in their respective states, despite the fact that Donald John Trump lost the November 3, 2020 presidential elections previously.

in those states. This was an overt act in furtherance of the conspiracy.

Act 64. On or about the 12th day of December 2020, Kenneth John Cheeseborough met with Brian Schimming and discussed the December 14, 2020 meeting of Trump presidential elector nominees in Wisconsin. Rudolph William Louis Giuliani joined the meeting by telephone and stated that the media should not be notified of the December 14, 2020 meeting of Trump presidential elector nominees in Wisconsin.

These were overt acts in furtherance of the conspiracy. Act 65. On or about the 12th day of December 2020, Michael A. Roman instructed an individual associated with the Trump campaign to distribute certain information related to the December 14, 2020 meetings of Trump presidential elector nominees in Georgia, Arizona, Michigan, and

Nevada, New Mexico, Pennsylvania, and Wisconsin to unindicted co-conspirator individual four, whose identity is known to the grand jury and to other individuals associated with the Trump campaign. This was an overt act in furtherance of the conspiracy.

Act 66. On or about the 12th day of December 2020, unindicted co-conspirator Individual 4, whose identity is known to the grand jury, sent an email to Michael A. Roman and David James Schaefer with updates on the progress of organizing the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia.

The email stated which elector nominees had confirmed they would attend the meeting, that other individuals had been secured in case some of the elector nominees refused to participate in the meeting, that Georgia legislators had been contacted to ensure access to the Georgia Capitol, and that David James Schaefer had reserved room 216 for the meeting. This was an overt act in furtherance of the conspiracy.

Act 67. On or about the 12th day of December 2020, David James Schaefer sent an email to unindicted co-conspirator Individual 4, whose identity is known to the grand jury, advising them to, quote, touch base, end quote, with each of the Trump presidential elector nominees in Georgia in advance of the December 14, 2020 meeting to confirm their attendance. This was an overt act in furtherance of the conspiracy.

Act 68. On or about the 12th day of December 2020, unindicted co-conspirator Individual 4, whose identity is known to the grand jury, sent a text message with contact information for unindicted co-conspirator Individual 8, whose identity is known to the grand jury, and Georgia Senator Brandon Beach to Michael A. Roman for the purpose of providing the contact information to Rudolph William Lewis Giuliani.

This was an overt act in furtherance of the conspiracy.

Act 69. On or about the 13th day of December 2020, Kenneth John Cheesebro sent an email with attached documents to Michael A. Roman. The documents were to be used by Trump presidential elector nominees in New Mexico for the purpose of casting electoral votes for Donald John Trump on December 14, 2020, despite the fact that Donald John Trump lost the November 3, 2020 presidential election in New Mexico.

This was an overt act in furtherance of the conspiracy. Act 70. On or about the 13th day of December 2020, Kenneth John Cheesebrough sent an email to Rudolph William Lewis Giuliani with the subject, quote, privileged and confidential brief notes on president of the Senate strategy, end quote.

In the email, Kenneth John Cheeseborough outlined multiple strategies for disrupting and delaying the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states.

In the email, Kenneth John Cheeseborough stated that the strategies outlined by him were, quote, preferable to allowing the Electoral Count Act to operate by its terms, end quote.

This was an overt act in furtherance of the conspiracy. Act 71. On or about the 13th day of December 2020, Kenneth John Cheeseborough sent an email with attached documents to Michael A. Roman, an unindicted co-conspirator Individual 4, whose identity is known to the grand jury. The

The documents were to be used by Trump presidential elector nominees in Georgia for the purpose of casting electoral votes for Donald John Trump on December 14, 2020, despite the fact that Donald John Trump lost the November 3, 2020 presidential election in Georgia. This was an overt act in furtherance of the conspiracy.

Act 72. On or about the 13th day of December 2020, Kenneth John Cheeseborough sent an email to Michael A. Roman and unindicted co-conspirator Individual 4, whose identity is known to the grand jury, and stated that Rudolph William Louis Giuliani, quote, wants to keep this quiet until after all the voting is done, end quote, in reference to the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia.

This was an overt act in furtherance of the conspiracy.

Act 73. On or about the 13th day of December 2020, David James Schaefer sent a text message to unindicted co-conspirator Individual 4, whose identity is known to the grand jury, and stated that unindicted co-conspirator Individual 8, whose identity is known to the grand jury, would attend the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia,

in place of a Trump presidential elector nominee who refused to participate in the meeting. This was an overt act in furtherance of the conspiracy. Act 74, on or about the 13th day of December 2020, unindicted co-conspirator Individual 9, whose identity is known to the grand jury, sent a text message to David James Schaefer and confirmed that he and unindicted co-conspirator Individual 13

whose identity is known to the grand jury, would attend the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy. Act 75.

On or about the 14th day of December 2020, Donald John Trump caused to be tweeted from the Twitter account at real Donald Trump, quote, what a fool Governor at Brian Kemp, GA of Georgia is. Could have been so easy, but now we have to do it the hard way. Demand this clown call a special session and open up signature verification now. Otherwise could be a bad day for two great senators on January 5th, end quote.

This was an overt act in furtherance of the conspiracy.

Act 76. On or about the 14th day of December 2020, David James Schaefer sent a text message to unindicted co-conspirator Individual 4, whose identity is known to the grand jury, that stated, quote, Listen, tell them to go straight to room 216 to avoid drawing attention to what we are doing, end quote, in reference to the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia.

This was an overt act in furtherance of the conspiracy. Act 77. On or about the 14th day of December 2020, Michael A. Roman sent an email to unindicted co-conspirators Individual 4 and Individual 7, whose identities are known to the grand jury, and stated, quote, Please send me an update as soon as State Electoral College has adjourned and all paperwork is secured, end quote.

This was an overt act in furtherance of the conspiracy. Act 78. On or about the 14th day of December 2020, Ray Stallings Smith III and David James Schaefer encouraged certain individuals present at the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia, to sign the document titled Certificate of the Votes of the 2020 Electors from Georgia.

This was an overt act in furtherance of the conspiracy. Act 79. On or about the 14th day of December 2020, David James 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 impersonating a public officer in violation of OCGA section 16-10-23 in Fulton County, Georgia, by unlawfully falsely holding themselves out as the duly elected and qualified presidential electors from the state of Georgia and

public officers with intent to mislead the president of the United States Senate, the archivist of the United States, the Georgia secretary of state and the chief judge of the United States district court for the Northern district of Georgia into believing that they actually were such officers by placing in the United States mail to said persons, a document titled quote certificate of the votes of the 2020 electors from Georgia end quote.

This was an act of racketeering activity under OCGA section 16-14-3, subsection 5A-23, and an overt act in furtherance of the conspiracy. Act 80.

On or 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, Individual 20,

and Individual 19, whose identities are known to the grand jury, committed the felony offense of forgery in the first degree in violation of OCGA Section 16-9-1B in Fulton County, Georgia, by, with the intent to defraud, knowingly making a document titled, quote, Certificate of the Votes of the 2020 Electors from Georgia, end quote. A writing, other than a check,

in such manner that the writing as made purports to have been made by authority of the duly elected and qualified presidential electors from the state of Georgia, who did not give such authority and uttered and delivered said document to the archivist of the United States."

This was an act of racketeering activity under OCGA section 16-14-3 subsection 5A-16 and an overt act in furtherance of the conspiracy.

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Act 81.

On or about the 14th day of December 2020, David James 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 were

whose identities are known to the grand jury, committed the felony offense of false statements and writings in violation of OCGA section 16-10-20 in Fulton County, Georgia, by knowingly, willfully, and

and unlawfully making and using a false document titled, quote, Certificate of the Votes of the 2020 Electors from Georgia, end quote, 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, end quote,

Said document being within the jurisdiction of the Office of the Georgia Secretary of State and the Office of the Governor of Georgia, Departments and Agencies of State Government, this was an act of racketeering activity under OCGA Section 16-14-3, Subsection 5A-22, and an overt act in furtherance of the conspiracy.

Act 82, on or 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,

Individual 18 and Individual 19, whose identities are known to the grand jury, attempted to commit the felony offense of filing false documents in violation of OCGA Section 16-10-20.1-2.

B.1. in Fulton County, Georgia, by placing in the United States mail a document titled, quote, Certificate of the Votes of the 2020 Electors from Georgia, end quote, 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, 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, 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, end quote. This was an act of racketeering activity under OCGA Section 16-14-3, Subsection 5A-22, and an overt act in furtherance of the conspiracy. 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 Section 16-9-1B in Fulton County, Georgia.

by, with the intent to defraud, knowingly making a document titled, quote, re, notice of filing of electoral college vacancy, end quote, 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 section 16-14-3, subsection 5A-16, 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 Section 16-10-20 in Fulton County, Georgia,

by knowingly, willfully, and unlawfully making and using a false document titled, quote, re, notice of filing of Electoral College vacancy, end quote, 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.

said document being within the jurisdiction of the Office of the Georgia Secretary of State and the Office of the Governor of Georgia, Departments and Agencies of State Government. This was an act of racketeering activity under OCGA Section 16-14-3, Subsection 5A-22, and an overt act in furtherance of the conspiracy. 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 Shawn Micah Tresher Still titled, quote, Re-.

Notice of filing of electoral college vacancy, end quote. The document contained multiple false statements. This was an overt act in furtherance of the conspiracy. Act 86. On or about the 14th day of December 2020, unindicted co-conspirator individual four, whose identity is known to the grand jury, sent an email to Michael A. Roman, unindicted co-conspirator individual seven, whose identity is known to the grand jury and others.

that stated, quote, all votes cast, paperwork complete, being mailed now ran pretty smoothly, end quote, in reference to the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 87. On or about the 14th day of December 2020, Stephen Cliffguard Lee attempted to commit a felony offense of influencing witnesses in violation of OCGA Section 16-10-93-B

B1A in Fulton County, Georgia, by traveling to the home of Ruby Freeman, a Fulton County, Georgia, election worker, and speaking to her neighbor with intent to knowingly engage in misleading conduct toward Ruby Freeman by purporting to offer her help and with intent to influence her testimony in an official proceeding in Fulton County, Georgia, concerning events at State Farm Arena in the November 3, 2020 presidential election in Georgia.

This was an act of racketeering activity pursuant to OCGA section 16-14-3, subsection 5A-27, 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 the felony offense of influencing witnesses in violation of OCGA Section 16-10-93,

B-1A 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 section 16-14-3, subsection 5A-27, 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 Cliffguard Lee solicited Harrison William Prescott Floyd, an individual associated with the organization Black Voices for Trump, to assist with his effort to speak to Ruby Freeman, a Fulton County, Georgia, election worker.

Stephen Cliffguard 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 broad authority to investigate allegations of voter fraud in Georgia and elsewhere. This was an overt act in furtherance of the conspiracy.

Act 91. On or about the 21st day of December 2020, Sidney Catherine Powell sent an email to the chief operations officer of Sullivan Strickler LLC and instructed him that she and unindicted co-conspirators Individual Sick

Individual 21 and individual 22, whose identities are known to the grand jury, were to immediately, quote, receive a copy of all data, end quote, obtained by Sullivan Strickler LLC from Dominion Voting Systems equipment in Michigan. This was an overt act in furtherance of the conspiracy.

Act 92. On or about the 22nd day of December 2020, Mark Randall Meadows traveled to the Cobb County Civic Center in Cobb County, Georgia, and attempted to observe the signature match audit being performed there by law enforcement officers from the Georgia Bureau of Investigation and the Office of the Georgia Secretary of State, despite the fact that the audit process was not open to the public.

While present at the center, Mark Randall Meadows spoke to Georgia's 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 Behan 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 the 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, quote, by hundreds of thousands of votes, end quote, and stated to Watson that, quote, when the right answer comes out, you'll be praised, end quote. This was an overt act in furtherance of the conspiracy.

Act 94. On or about the 23rd day of December 2020, John Charles Eastman sent an email to Kenneth John Cheeseborough and unindicted co-conspirator Individual 3, whose identity is known to the grand jury, with the subject, quote, forward, draft two with edits, end quote.

In the email, John Charles Eastman attached a memorandum titled, quote, privileged and confidential December 23 memo on January 6 scenario, end quote, and stated, quote, 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 that they have under the 12th Amendment. Better for them to just act boldly and be challenged, since the challenge would likely lead to the court denying review on non-justiciable political question grounds, end quote. This was an overt act in furtherance of the conspiracy.

Act 95, on or about the 25th day of December 2020, Donald John Trump placed a telephone call to the 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, quote, I voted for you. I worked for you. I campaigned for you. I just won't do anything illegal for you. End quote. The 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, quote, is there a way to speed up Fulton County signature verification in order to have results before January 6th if Trump campaign assists financially, end quote. 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 Jeffrey Rosen and acting United States Deputy Attorney General Richard Donahue to make false statements by stating, quote, just say that the election was corrupt and leave the rest to me and the Republican congressman, end quote. This was an overt act in furtherance of the conspiracy.

Act 98. On or about the 28th day of December 2020, Jeffrey Bossert Clark attempted to commit the felony offense of false statements and writings in violation of OCGA Section 16-10-20 in Fulton County, Georgia.

End quote.

quote, said statement being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies.

And on or about the 28th day of December 2020, Jeffrey Bossert Clark sent an 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 section 16-10-20. This was an act of racketeering activity under OCGA section 16-14-3, subsection 5A-22, and an overt act in furtherance of the conspiracy.

Act 99. On or about the 28th day of December 2020, Jeffrey Bossert Clark solicited Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney General Richard Donahue to sign and send a document that falsely stated 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, end quote,

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 Ralston.

at RealDonaldTrump, 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, end quote. 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 RSB network, end quote. This was an overt act in furtherance of the conspiracy.

Act 102. On or about the 30th day of December 2020, Rudolph William Lewis Giuliani, Ray Stalling Smith III, and Robert David Scheele committed the felony offense of solicitation of violation of oath by public officer.

in violation of OCGA Sections 16-4-7 and Sections 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 the 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 violation of oath by public officer, OCGA Section 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 the intent that said persons engage in said conduct. This was an overt act in furtherance of the conspiracy.

Act 103. On or about the 30th day of December 2020, Rudolph William Lewis Giuliani committed the felony offense of false statements and writings in violation of OCGA section 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 and

at a Senate Judiciary Subcommittee meeting. One, that Fulton County election workers fraudulently counted certain ballots as many as five times at State Farm Arena on November 3, 2020. Two, that 2,560 felons voted illegally in the November 3, 2020 presidential election in Georgia. Three, 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 Section 16-14-3, Subsection 5A-22, and an overt act in furtherance of the conspiracy.

Act 104. On or about the 30th day of December 2020, Ray Stallings Smith III committed the felony offense of false statements and writings in violation of OCGA Section 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, quote, that they had a 90 percent accuracy rate, end quote, in the November 3, 2020 presidential election. And that, quote, there's still a 10 percent margin that's not accurate, end quote. 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 section 16-14-3, subsection 5A-22, and an overt act in furtherance of the conspiracy.

Act 105. On or about the 30th day of December 2020, Robert David Shealy committed the felony offense of false statements and writings in violation of OCGA Section 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 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, quote, a major water main break, end quote.

Two, that Fulton County election workers at State Farm Arena voted the same ballots, quote, over and over again, end quote, 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 section 16-14-3, subsection 5A-22, 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, end quote. This was an overt act in furtherance of the conspiracy.

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Act 107. On or about the 31st day of December 2020, Jenna Lynn Ellis wrote a memorandum titled, quote, Memorandum Reconstitution Analysis of Vice President Authority for January 6, 2021 Electoral College Vote Count, end quote, 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, end quote, from six states, including Georgia, that were falsely characterized as having, quote, electoral delegates in dispute, end quote. This was an overt act in furtherance of the conspiracy.

Act 108. On or about the 31st day of December 2020, Donald John Trump and John Charles Eastman committed the felony offense of filing false documents in violation of OCGA section 16-10-20.1.

In Fulton County, Georgia, by knowingly filing a document titled, quote,

a court of the United States having reason to know that said document contained at least one of the following materially false statements. One, that, quote, "...as many as 2,506 felons with an uncompleted sentence," end quote, "...voted illegally in the November 3, 2020 presidential election in Georgia."

Two, that, quote, at least 66,247 underage, end quote, people voted illegally in the November 3, 2020 presidential election in Georgia. Three, that, quote, at least 2,423 individuals, end quote, voted illegally in the November 3, 2020 presidential election in Georgia, quote, who were not listed in the state's records as having been registered to vote, end quote.

Four, that, quote, at least 1,043 individuals, end quote, voted illegally in the November 3, 2020 presidential election, quote, who had illegally registered to vote using a postal office box as their habitation, end quote.

Five, that, quote, as many as 10,315 or more, end quote, dead people voted in the November 3, 2020 presidential election in Georgia. Six, that, quote, 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, end quote, at State Farm Arena in Fulton County, Georgia.

Earlier on the same day, John Charles Eastman sent an email to attorneys associated with the Trump campaign, admitting his knowledge that at least some of the allegations in the verified complaint were not accurate. This filing was an act of racketeering activity under OCGA section 16-14-3, subsection 5A-22, 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, an unindicted co-conspirator Individual 3 whose identity is known to the grand jury.

In the email, Kenneth John Cheesebrough 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.

Act 110. On or about the second day of January 2021, Scott Graham Hall, a Georgia bail bondsman, placed a telephone call to Jeffrey Bossert Clark and discussed the November 3, 2020 presidential election in Georgia. The telephone call was 63 minutes in duration. This was an overt act in furtherance of the conspiracy.

Act 111. On or about the second day of January 2021, Jeffrey Bossert 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, quote, identified significant concerns about the

that may have impacted the outcome of the election in multiple states, including the state of Georgia, end quote, to Georgia Governor Brian Kemp, Speaker of the Georgia House of Representatives David Ralston, and President Pro Tempore of the Georgia Senate, Butch Miller. This was an overt act in furtherance of the conspiracy. Act 112.

On or about the second day of January 2021, Donald John Trump and Mark Randall Meadows committed the felony offense of solicitation of violation of oath by public officer in violation of OCGA sections 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 Section 16-10-1-2.

by unlawfully altering, unlawfully adjusting, and otherwise unlawfully influencing the certified return for presidential electors for the November 3, 2020 presidential election in Georgia in willful and intentional violation of the terms of the oath of said person as prescribed by law with intent that said person engage in said conduct. This was an overt act in furtherance of the conspiracy. Act 113.

On or about the second day of January 2021, Donald John Trump committed the felony offense of false statements and writings in violation of OCGA section 16-10-20 in Fulton County, Georgia.

by knowingly, willfully, and unlawfully making at least one of the following false statements and representations to Georgia Secretary of State Brad Raffensperger, Georgia Deputy Secretary of State Jordan Fuchs, and Georgia Secretary of State General Counsel Ryan Germany.

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 a ballot had already been cast in their name.

3. That 4,502 people voted in the November 3, 2020 presidential election in Georgia who were not on the voter registration list. 4. That 904 people voted in the November 3, 2020 presidential election in Georgia who were registered at an address that was a post office box. 5. That Ruby Freeman was a professional vote scammer and a known political operative.

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 3, 2020 presidential election in Georgia. Seven, 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.

11. That Ruby Freeman stuffed the ballot boxes. 12. That hundreds of thousands of ballots had been, quote, dumped, end quote, into Fulton County and another county adjacent to Fulton County in the November 3, 2020 presidential election in Georgia. 13. That he won the November 3, 2020 presidential election in Georgia by 400,000 votes.

Said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government. This was an act of racketeering activity under OCGA Section 16-14-3, Subsection 5A-22, and an overt act in the 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 Raffensperger yesterday about Fulton County and voter fraud in Georgia. He was unwilling or unable to answer questions such as the ballot under table scam, ballot destruction, out-of-state voters, dead voters, and more. He has no clue, end quote.

This was an overt act in furtherance of the conspiracy.

Act 115. On or about the third day of January, Stephen Cliffguard Lee, Harrison William Prescott Floyd, and Trevian C. Coote 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.

Two, at 7.49 p.m., Harrison William Prescott Floyd placed a telephone call to Ruby Freeman that was unsuccessful. Three, at 7.49 p.m., Harrison William Prescott Floyd placed a telephone call to Trevian C. Cootey.

4. At 7.53 p.m., Harrison William Prescott Floyd sent a text message to Ruby Freeman. 5. At 8.03 p.m., Trevian C. Coote 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. Cootey.

9. At 9.16 p.m., Harrison William Prescott Floyd placed a telephone call to Trevian C. Coote. 10. At 9.33 p.m., Harrison William Prescott Floyd placed a telephone call to Trevian C. Coote. 11. At 9.50 p.m., Harrison William Prescott Floyd placed a telephone call to Stephen Cliffguard Lee. These were overt acts in furtherance of the conspiracy.

Act 116. On or about the fourth day of January 2021, Trevian C. Coote, having been recruited by Harrison William Prescott Floyd, traveled from Chicago, Illinois to Atlanta, Georgia, and caused a certain individual, whose identity is known to the grand jury, to pick her up from a train station in Fulton County, Georgia, for the purpose of attempting to contact Ruby Freeman, a Fulton County, Georgia, election worker. This was an overt act in furtherance of the conspiracy.

Act 117. On or about the fourth day of January 2021, Trevian C. Coote traveled to Ruby Freeman's home in Cobb County, Georgia, and attempted to contact her but was unsuccessful. Trevian C. Coote 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. Coote, while in Fulton County, Georgia, placed a telephone call to Ruby Freeman and stated that Freeman was in danger. Trevian C. Coote stated that she could help Freeman and requested that Freeman meet with and speak to her that night at a Cobb County Police Department precinct in Cobb County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 119, on or about the fourth day of January 2021, Trevian C. Coote 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. Coote and Harrison William Prescott Floyd stated to Freeman that she needed protection and purported to offer her help. This was an overt act in furtherance of the conspiracy.

Act 120. On or about the fourth day of January 2021, Stephen Cliffguard Lee, Harrison William Prescott Floyd, and Trevian C. Cootey committed the felony offense of solicitation of false statements and writings in violation of OCGA Sections 1A,

16-4-7 and Section 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 Section 16-10-20 by knowingly and willfully making a false statement and representation concerning events at State Farm Arena in the November 3, 2020 presidential election in Georgia. Said statement and representation being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, Departments and Agencies of State Government, and County and City Law Enforcement Agencies."

with intent that said person engage in said conduct. This was an act of racketeering activity under OCGA section 16-14-3, subsection 5A-22, and an overt act in furtherance of the conspiracy.

Act 121, on or about the fourth day of January 2021, Stephen Cliffguard Lee, Harrison William Prescott Floyd, and Trevian C. Coote committed the felony offense of influencing witnesses in violation of OCGA Section 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 section 16-14-3, subsection 5A-27, and an overt act in furtherance of the conspiracy.

Act 122. On or about the fourth day of January 2021, Stephen Cliffguard Lee, Harrison William Prescott Floyd, and Trevian C. Cootey 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 Cliffguard Lee placed a telephone call to Harrison William Prescott Floyd. 2.

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 Cliffguard Lee placed a telephone call to Harrison William Prescott Floyd. 4. At 12.32 p.m., Stephen Cliffguard Lee sent a text message to Harrison William Prescott Floyd.

5. At 8.10 p.m., Harrison William Prescott Floyd placed a telephone call to David James Schaefer. 6. At 10 p.m., Harrison William Prescott Floyd placed a telephone call to Stephen Cliffguard Lee. 7. At 10.19 p.m., Harrison William Prescott Floyd placed a telephone call to Trevian C. Cootey.

8. At 10.43 p.m., Trevian C. Coote placed a telephone call to Harrison William Prescott Floyd. 9. At 11.10 p.m., Trevian C. Coote placed a telephone call to Harrison William Prescott Floyd. 10. At 12.12 a.m. on January 5, 2021, Trevian C. Coote placed a telephone call to Harrison William Prescott Floyd. These were overt acts in furtherance of the conspiracy.

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 Cheeseborough sent an email to John Charles Eastman with the subject, quote, forward draft two with edits, end quote, and included within the body of the email another email that Kenneth John Cheeseborough previously sent to Rudolph William Lewis Giuliani with the subject, quote, privileged and confidential brief notes on president of the Senate strategy, end quote.

In the email, Kenneth John Cheeseborough outlined multiple strategies for disrupting and delaying the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states, and stated that the outcomes of any of these strategies were, quote, preferable to allowing the Electoral Count Act to operate by its terms, end quote. This was an overt act in furtherance of the conspiracy.

Act 125. 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 in the Oval Office at the White House.

During the meeting, Donald John Trump and John Charles Eastman argued to Pence that he could either reject electoral votes from certain states or delay the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states for the purpose of allowing certain state legislatures to unlawfully appoint presidential electors in favor of Donald John Trump.

During the meeting, John Charles Eastman admitted both options violated the Electoral Count Act. This was an overt act in furtherance of the conspiracy.

Act 126. On or about 5th day of January 2021, Jenna Lynn Ellis wrote a memorandum titled, quote, RE, Vice President Authority in Counting Electors Pursuant to U.S. Constitution and Title III U.S. Code Sections 5 and 15, end quote, 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, quote, the vice president should begin alphabetically in order of the states and coming first to Arizona, not open the purported certification, but simply stop the count at that juncture.

This was an overt act in furtherance of the conspiracy.

Act 127. On or about the 5th day of January 2021, Robert David Shealy, Stephen Cliffguard Lee, Harrison William Prescott Floyd, Trevian C. Cootey, and Scott Graham Hall placed multiple phone calls to each other and to other individuals involved in the conspiracy. They include the following. 1. At 11.32 a.m., Stephen Cliffguard Lee placed a telephone call to Trevian C. Cootey. 2.

Two, at 12.14 p.m., Harrison William Prescott Floyd, Trevian C. Cootey, Stephen Cliffguard Lee, and unindicted co-conspirator Individual 23, whose identity is known to the grand jury, participated in a four-way telephone call. Three, at 12.19 p.m., Scott Graham Hall placed a telephone call to Robert David Cheely.

4. At 12.34 p.m., Scott Graham Hall placed a telephone call to Robert David Cheely. 5. At 1.07 p.m., Robert David Cheely placed a telephone call to Scott Graham Hall. 6. At 1.09 p.m., Robert David Cheely placed a telephone call to Scott Graham Hall. 7. At 2.30 p.m., Robert David Cheely 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 Cheely. 9. At 3.59 p.m., Robert David Cheely placed a telephone call to Scott Graham Hall. 10. At 4.42 p.m., Stephen Cliffguard Lee placed a telephone call to Robert David Cheely.

11. At 4.50 p.m., Stephen Cliffguard Lee placed a telephone call to Harrison William Prescott Floyd. 12. At 5.05 p.m., Stephen Cliffguard Lee placed a telephone call to Harrison William Prescott Floyd. 13. At 7.19 p.m., Trevian C. Cootey placed a telephone call to Robert David Cheely. 14. At 7.48 p.m., Robert David Cheely placed a telephone call to Trevian C. Cootey.

15 at 8.27 p.m., Robert David Cheely placed a telephone call to Trevian C. Cootey. 16 at 8.49 p.m., Robert David Cheely placed a telephone call to Stephen Cliffguard Lee. 17 at 9.18 p.m., Scott Graham Hall placed a telephone call to Robert David Cheely.

18. At 9.31 p.m., Trevian C. Cootey placed a telephone call to Robert David Cheely. 19. At 10.14 p.m., Robert David Cheely placed a telephone call to Stephen Cliffguard Lee. 20. At 11.16 p.m., Robert David Cheely placed a telephone call to Trevian C. Cootey. 21. At 11.25 p.m., Scott Graham Hall placed a telephone call to Robert David Cheely.

22 at 11.35 p.m., Robert David Cheely, Trevian C. Cootey, and Scott Graham Hall participated in a three-way telephone call. 23 at 12.09 a.m. on January 6, 2021, Trevian C. Cootey placed a telephone call to Robert David Cheely. These were overt acts in furtherance of the conspiracy.

Act 128, on or about the fifth day of January 2021, Donald John Trump caused to be tweeted from the Twitter account at real Donald Trump, quote, the vice president has the power to reject fraudulently chosen electors, end quote. This was an overt act in furtherance of the conspiracy.

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When news breaks, go beyond the headlines with the MSNBC app. Watch your favorite shows live. Get analysis from live blogs to in-depth essays and the latest updates on the 2024 election. Go beyond the what to understand the why. Download the app now at msnbc.com slash app. Act 129.

On or about the 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 Marquess of Queensbury rules, end quote. What

When Pence stated that it was his duty to support and defend the Constitution and that only Congress had the power to decide to reject slates of presidential electors, Donald John Trump stated that Pence was naive, implied that he lacked courage, and stated that Pence was doing, quote, a great disservice, end quote. 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 legislatures. This was an overt act in furtherance of the conspiracy.

Act 132. On or about the fifth 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 got to be tough tomorrow, end quote. This was an overt act in 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,

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, end quote. This was an overt act in furtherance of the conspiracy.

Act 134. On or 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 6th day of January 2021, Donald John Trump appeared and spoke at a rally at the Ellipse in Washington, D.C.,

During the rally, Donald John Trump made false statements concerning fraud in the November 3, 2020 presidential election in Georgia and elsewhere, solicited Vice President Mike Pence to disrupt and delay the joint session of Congress on January 6, 2021, the date prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states.

and encouraged those in attendance at the rally to march to the United States Capitol. This was an overt act in furtherance of the conspiracy. Act 136. On or about the sixth day of January 2021, Rudolph William Louis Giuliani appeared and spoke at a rally at the Ellipse in Washington, D.C.,

During the rally, Rudolph William Louis Giuliani made false statements concerning fraud in the November 3, 2020 presidential election in Georgia and elsewhere and solicited Vice President Mike Pence to disrupt and delay the joint session of Congress on January 6, 2021, the day prescribed by law for counting votes cast by the duly elected and qualified presidential electors from Georgia and the other states. This was an overt act in furtherance of the conspiracy.

Act 137. On or about the 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 for the election.

by the duly elected and qualified presidential electors from Georgia and the other states. This was an overt act in furtherance of the conspiracy.

Act 138. On or about the sixth day of January 2021, Donald John Trump caused to be tweeted from the Twitter account at real Donald Trump, quote, if Vice President Mike Pence comes through for us, we will win the presidency. Many states want to decertify the mistake they made in certifying incorrect and even fraudulent numbers in a process not approved by their state legislatures, which it must be. Mike can send it back, end quote.

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, end quote.

This was an overt act in furtherance of the conspiracy. Act 140, on or 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, end quote, and that Pence was not protecting the United States. This was an overt act in furtherance of the conspiracy. Act 141. On or about the sixth day of January 2021, John Charles Eastman sent an email to counsel to the Vice President Greg Jacob that stated, quote,

The Senate and the House have both violated the Electoral Count Act this evening. They debated the Arizona objections for more than two hours, violations of Title III, United States Code, Section 17. And the VP allowed further debate or statements by leadership after the question had been voted upon, violation of Title III, United States Code, Section 17.

And they had that debate upon motion approved by the VP in violation of the requirements in Title III, United States Code, Section 15, that after the vote in the separate houses, quote, they shall immediately again meet, end quote. 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 of

and adjourn for 10 days to allow the legislatures to finish their investigations, as well as to allow a full forensic audit of the massive amount of illegal activity that has occurred here. If none of that moves the needle, at least a good portion of the 75 million people who supported President Trump will have seen a process that allowed the illegality to be aired. John, end quote.

This was an overt act in furtherance of the conspiracy. Act 142, on or about the 7th day of January 2021, Kathleen Alstom 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 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 Section 16-14-3, Subsection 5B, and an overt act in furtherance of the conspiracy.

Act 143. On or about the 7th day of January 2021, Scott Graham Hall and unindicted co-conspirator Individual 24, whose identity is known to the grand jury, flew from DeKalb Peachtree Airport in DeKalb County, Georgia, to Douglas Municipal Airport in Coffey County, Georgia, for the purpose of assisting with the unlawful breach of election equipment at the Coffey County Board of Elections and Registration Office. The

This was an act of racketeering activity under OCGA section 16-14-3, subsection 5b, and an overt act in the furtherance of the conspiracy.

Act 144, 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 interference with primaries and elections in violation of OCGA Section 21-2-566 in Coffey County, Georgia, by willfully and unlawfully tampering with electronic ballot markers and tabulating machines in Coffey County, Georgia.

This was an overt act in furtherance of the conspiracy.

Act 145, 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 unlawful possession of ballots in violation of OCGA Section 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 in

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 Coffey County, Georgia. This was an overt act in furtherance of the conspiracy.

Act 146. 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 theft in violation of OCGA Section 16-9-93A in Coffey County, Georgia, by using a computer with knowledge that

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 section 16-14-3, subsection 5A-19, and an overt act in furtherance of the conspiracy.

Act 147, 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 trespass in violation of OCGA section 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 section 16-14-3 subsection 5A19 and an overt act in furtherance of the conspiracy.

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 Section 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 section 16-14-3, subsection 5A-19, 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, Sidney Catherine Powell and Kathleen Alston Latham, Scott Graham Hall, and Misty Hampton committed the felony offense of conspiracy to defraud the state in violation of OCGA section 16-10-21 in Coffey County, Georgia, by unlawfully conspiring and agreeing to commit the

theft of voter data, property which was under the control of Georgia Secretary of State Brad Raffensperger, a state officer in his official capacity. This was an act of racketeering activity under OCGA Section 16-14-3, Subsection 5B, and an overt act in furtherance of the conspiracy.

Act 150, on or about the 9th day of January 2021, the 10th day of January 2021, the 11th day of January 2021, and the 13th day of January 2021, unindicted co-conspirator individual 25, whose identity is known to the grand jury, unlawfully accessed certain data copied from Dominion Voting System's 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 section 16-14-3, subsection 5b, and an overt act in furtherance of the conspiracy.

Act 151. On or about the 9th day of January 2021, the 10th day of January 2021, the 11th day of January 2021, the 18th day of January 2021, and the 19th day of January 2021, unindicted co-conspirator individual 26, whose identity is unknown to the grand jury, unlawfully accessed certain data copied from Dominion Voting Systems equipment

at the 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 Section 16-14-3, Subsection 5B, and an overt act in furtherance of the conspiracy.

Act 152, on or about the 10th day of January 2021, the 12th day of January 2021, the 13th day of January 2021, the 25th day of February 2021, and the 26th day of February 2021—

Unindicted co-conspirator Individual 27, whose identity is unknown to the grand jury, unlawfully accessed certain data copied from Dominion Voting Systems equipment at the 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 section 16-14-3, subsection 5b, 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 section 16-14-3, subsection 5b, and an overt act in furtherance of the conspiracy.

Act 154. On or about the 18th day of January 2021, Misty Hampton allowed unindicted co-conspirators Individual 25 and Individual 29, whose identities are known to the grand jury, to access non-public areas of the 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 and

at the Coffey County Board of Elections and Registration Office in Coffey 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 act of racketeering activity under OCGA Section 16-14-3, Subsection 5B, and an overt act in furtherance of the conspiracy.

Act 156. On or about the 17th day of September 2021, Donald John Trump committed the felony offense of solicitation of violation of oath by public officer in violation of OCGA Sections 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 section 16-10-1, by unlawfully, quote, decertifying the election or whatever the correct legal remedy is and announce the true winner, end quote, 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 Section 16-10-20 in Fulton County, Georgia, by knowingly, willfully, and unlawfully making the following false statement and representation to Georgia Secretary of State Brad Raffensperger. 1.

"...as stated to you previously, the number of false and or irregular votes is far greater than needed to change the Georgia election result." "...said statement being within the jurisdiction of the Office of the Georgia Secretary of 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 section 16-14-3, subsection 5A-22, and an overt act in furtherance of the conspiracy. 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 Section 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, quote, attended and convened, end quote, the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia, but that he did not, quote, call each of the individual members and notify them of the meeting or make any of the other preparations necessary for the meeting, end quote.

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 a government of a county of the state. This was an act of racketeering activity under OCGA Section 16-14-3, Subsection 5A-22, and an overt act in 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, end quote, efforts to access voting machines in Coffey County, Georgia or Antrim County, Michigan.

Two, that she was aware that there was an, quote, effort by some people, end quote, to get access to voting machines in Georgia, but that she did not, quote, know what happened with that, end quote, and did not, quote, remember whether that was Rudy or other folks, end quote. This was an overt act in furtherance of the conspiracy.

Act 160. On or about the first day of September 2022, Kathleen Alston Latham committed the felony offense of perjury in violation of OCGA Section 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.

Case 117CV-02989-AT 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, quote, just a few minutes, end quote, on January 7, 2021. Two, that she only, quote, walked into the front part, end quote, of the Coffey County Board of Elections and Registration Office on January 7, 2021, end quote, didn't go into the office, end quote.

Three, that she had, quote, no idea, end quote, if employees of Sullivan Strickler met Eric Cheney at the Coffey County Board of Elections and Registration Office on January 7, 2021. Four, that she did not see Misty Hampton at the Coffey County Board of Elections and Registration Office on January 7, 2021.

Five, 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. Six, 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 issues in question. This was an act of racketeering activity under OCGA Section 16-14-3, Subsection 5A25, and an overt act in furtherance of the conspiracy.

Act 161. On or about the 15th day of September 2022, Robert David Cheely committed the felony offense of perjury in violation of OCGA Section 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.

1. That he was unaware of the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia until after the meeting had already taken place. 2. That he had no substantive conversations with anyone concerning the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia until after the meeting had already taken place.

3. That he never suggested to anyone that the Trump presidential elector nominees in Georgia should meet on December 14, 2020. 4. That the only communication he had with John Eastman concerning the November 3, 2020 presidential election was for the purpose of connecting Eastman to Georgia Senator Brandon Beach, 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, an unindicted co-conspirator Individual 8 whose identity is known to the grand jury.

said statements being material to the accused's own involvement in the December 14, 2020 meeting of Trump presidential elector nominees in Fulton County, Georgia, and to the accused's communication with others involved in the meeting, the issues in question. This was an act of racketeering activity under OCGA section 16-14-3, subsection 5A-25, and an overt act in the 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.

Thanks so much for listening. Part two will be released soon. You can catch Velshi every weekend at 10 a.m. Eastern on MSNBC. The senior producer for Prosecuting Donald Trump is Alicia Conley. Ivy Green is a segment producer. Our technical director is Bryson Barnes.

Search for Prosecuting Donald Trump wherever you get your podcasts and follow the series.

Hi, everyone. It's Chris Hayes. This week on my podcast, Why Is This Happening? Author and philosopher Daniel Chandler on the roots of a just society. I think that those genuinely big fundamental questions about whether liberal democracy will survive, what the shape of our society should be, feel like they're genuinely back on the agenda. I think it feels like we're at a real, you know, an inflection point or a turning point in the history of liberal democracy. That's this week on Why Is This Happening? Search for Why Is This Happening wherever you're listening right now and follow.