Fulton County Georgia Criminal Court case label for the Indictment of Donald J. Trump

Booking Record for Donald J. Trump on Aug 24 2023 at Fulton County Sheriff Office Rice Street jail.

Inmate #P01135809 Palm Beach, FL

RICO Grand Jury Indictment of 19 Defendants for 41 Counts, filed by Fulton County District Attorney Fani Willis office on August 14 2023.

Below are pages 1 – 4 of the Indictment as filed showing the names and counts. Most prominently showing the lead defendant, Donald John Trump, FORMER President of the United States, with the most Counts of 13 – 1, 5, 9, 11, 13, 15, 17, 19, 27, 28, 29, 38 and 39!!  Media bragging rights again for more than any of his co-conspirators!!

Below listed are the Indictment Table of Contents listing Counts 1 to 41 from pages 10-12.

Below is a complete re-statement of the individual Indictment Counts 1 – 41 from the original Indictment, pgs. 13 to 97.

Note that Count 1 (RICO) comprises pgs. 13 to 71 with sub-headings:

• O.C.G.A. §16-14-4 (pg. 13);

• Introduction (pg. 14)

• The Enterprise (pg. 15)

• Manner and Methods of the Enterprise (pg. 16)

• Acts of Racketeering Activity and Overt Acts in Furtherance of the Conspiracy (pgs. 20 – 71)

COUNT 1 (RICO) of 41 (pg. 13)

The Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do hereby charge and accuse:

DONALD JOHN TRUMP,
RUDOLPH WILLIAM LOUIS GIULIANI,
JOHN CHARLES EASTMAN,
MARK RANDALL MEADOWS,
KENNETH JOHN CHESEBRO,
JEFFREY BOSSERT CLARK,
JENNA LYNN ELLIS,
RAY STALLINGS SMITH III,
ROBERT DAVID CHEELEY,
MICHAEL A. ROMAN,
DAVID JAMES SHAFER,
SHAWN MICAH TRESHER STILL,
STEPHEN CLIFFGARD LEE,
HARRISON WILLIAM PRESCOTT FLOYD,
TREVIAN C. KUTTI,
SIDNEY KATHERINE POWELL,
CATHLEEN ALSTON LATHAM,
SCOTT GRAHAM HALL, and
MISTY HAMPTON

with the offense of VIOLATION OF THE GEORGIA RICO (RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS) ACT, O.C.G.A. § 16-14-4(c), for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the State of Georgia and County of Fulton, on and between the 4th day of November 2020 and the 15th day of September 2022, while associated with an enterprise, unlawfully conspired and endeavored to conduct and participate in, directly and indirectly, such enterprise through a pattern of racketeering activity in violation of O.C.G.A. §16-14-4(b), as described below and incorporated by reference as if fully set forth herein, contrary to the laws of said State, the good order, peace, and dignity thereof;

[Ed Note > This is original Count 1, the ‘RICO count’, from page 13 of the Indictment. Count 2 starts on page 72]

RICO INTRODUCTION (Indictment pg 14)

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 RICO ENTERPRISE (Indictment pgs. 15-19)

At all times relevant to this Count of the Indictment, the Defendants, as well as others not named as defendants, unlawfully conspired and endeavored to conduct and participate in a criminal enterprise in Fulton County, Georgia, and elsewhere. Defendants Donald John Trump, Rudolph William Louis Giuliani, John Charles Eastman, Mark Randall Meadows, Kenneth John Chesebro, Jeffrey Bossert Clark, Jenna Lynn Ellis, Ray Stallings Smith III, Robert David Cheeley, Michael A. Roman, David James Shafer, Shawn Micah Tresher Still, Stephen Cliffgard Lee, Harrison William Prescott Floyd, Trevian C. Kutti, Sidney Katherine Powell, Cathleen Alston Latham, Scott Graham Hall, Misty Hampton, unindicted co-conspirators Individual l through Individual 30, and others known and unknown to the Grand Jury, constituted a criminal organization whose members and associates engaged in various related criminal activities including, but not limited to, false statements and writings, impersonating a public officer, forgery, filing false documents, influencing witnesses, computer theft, computer trespass, computer invasion of privacy, conspiracy to defraud the state, acts involving theft, and perjury.

This criminal organization constituted an enterprise as that term is defined in O.C.G.A. §l6-14-3(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 RICO ENTERPRISE

The manner and methods used by the Defendants and other members and associates of the enterprise to further the goals of the enterprise and to achieve its purposes included, but were not limited to, the following:

1. False Statements to and Solicitation of State Legislatures

Members of the enterprise, including several of the Defendants, appeared at hearings in Fulton County, Georgia, before members of the Georgia General Assembly on December 3, 2020, December 10, 2020, and December 30, 2020. At these hearings, members of the enterprise made false statements concerning fraud in the November 3, 2020, presidential election. The purpose of these false statements was to persuade Georgia legislators to reject lawful electoral votes cast by the duly elected and qualified presidential electors from Georgia. Members of the enterprise corruptly solicited Georgia legislators instead to unlawfully appoint their own presidential electors for the purpose of casting electoral votes for Donald Trump. Members of the enterprise also made false statements to state legislators during hearings and meetings in Arizona, Michigan, and Pennsylvania in November and December 2020 to persuade legislators in those states to unlawfully appoint their own presidential electors.

2. False Statements to and Solicitation of High Ranking State Officials

Members of the enterprise, including several of the Defendants, made false statements in Fulton County and elsewhere in the State of Georgia to Georgia officials, including the Governor, the Secretary of State, and the Speaker of the House of Representatives. Members of the enterprise also corruptly solicited Georgia officials, including the Secretary of State and the Speaker of the House of Representatives, to violate their oaths to the Georgia Constitution and to the United States Constitution by unlawfully changing the outcome of the November 3, 2020, 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 Countv Election Worker Rubv Freeman

Members of the enterprise, including several of the Defendants, falsely accused Fulton County election worker Ruby Freeman of committing election crimes in Fulton County, Georgia. These false accusations were repeated to Georgia legislators and other. Georgia officials in an effort to persuade them to unlawfully change the outcome of the November 3, 2020, presidential election in favor of Donald Trump. In furtherance of this scheme, members of the enterprise traveled from out of state to harass Freeman, intimidate her, and solicit her to falsely confess to election crimes that she did not commit.

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, “Just say that the election was corrupt, and leave the rest to me and the Republican congressmen.”

6. Solicitation of the Vice President of the United States

Members of the enterprise, including several of the Defendants, corruptly solicited the Vice President of the United States to violate the United States Constitution and federal law by unlawfully rejecting Electoral College votes cast in Fulton County, Georgia, by the duly elected and qualified presidential electors from Georgia. Members of the enterprise also corruptly solicited the Vice President to reject votes cast by the duly elected and qualified presidential electors from several other states.

7. Unlawful Breach of Election Equipment in Georgia and Elsewhere

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

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.

[Ed. Note > End of the Manner and Methods of the RICO Enterprise, pg 19]

ACTS OF RACKETEERING ACTIVITY AND
OVERT ACTS IN FURTHERANCE OF THE CONSPIRACY

(Ed Note > RICO Acts paragraphs 1 to 161, pgs. 20-71, are provided below as an excerpt from the Indictment)

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

COUNT 2 of 41 (pg. 72)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, JENNA LYNN ELLIS, and RAY STALLINGS SMITH III with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 & 16-10-1, for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on the 3rd day 0f December 2020, unlawfully solicited, requested, and importuned certain public officers then serving as elected members of the Georgia Senate and present at a Senate Judiciary Subcommittee meeting, including un-indicted co-conspirator Individual 8, whose identity is known to the Grand Jury, Senators Lee Anderson, Brandon Beach, Matt Brass, Greg Dolezal, Steve Gooch, Tyler Harper, Bill Heath, Jen Jordan, John F. Kennedy, William Ligon, Elena Parent, Michael Rhett, Carden Summers, and Blake Tillery, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. § 16-10-1, by unlawfully appointing presidential electors from the State of Georgia, in willful and intentional violation of the terms of the oath of said persons as prescribed by law, with intent that said persons engage in said conduct, said date being a material element of the offense, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 3 of 41 (pg. 72)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 3rd day of December 2020,  knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:

1. That at least 96,600 mail-in ballots were counted in the November 3, 2020, presidential election in Georgia, despite there being no record of those ballots having been returned to a county elections office;
2. That a Dominion Voting Systems machine used in the November 3, 2020, presidential election in Antrim County, Michigan, mistakenly recorded 6,000 votes for Joseph R. Biden when the votes were actually cast for Donald Trump;

said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 4 0f 41 (pg. 73)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RAY STALLINGS SMITH III with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 3rd day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:

1. That 2,506 felons voted illegally in the November 3, 2020, presidential election in Georgia; That 66,248 underage people illegally registered to vote before their seventeenth birthday prior to the November 3, 2020, presidential election in Georgia;
2. That at least 2,423 people voted in the November 3, 2020, presidential election in Georgia who were not listed as registered to vote;
3. 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;
4. That 10,315 or more dead people voted in the November 3, 2020, presidential election in Georgia;
5. That Fulton County election workers at State Farm Arena ordered poll watchers and members of the media to leave the tabulation area on the night of November 3, 2020, and continued to operate after ordering everyone to leave;
6. said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 5 of 41 (pg. 74)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 & 16-10-1, for the said accused, in the County of Fulton and State of Georgia, on or about the 7th day 0f December 2020, unlawfully solicited, requested, and importuned Speaker of the Georgia House of Representatives David Ralston, a public officer, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. § 16-10-1, by calling for a special session of the Georgia General Assembly for the purpose of unlawfully appointing presidential electors from the State of Georgia, in willful and intentional Violation of the terms of the oath of said person as prescribed by law, with intent that said person engage in said conduct, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 6 of 41 (pg. 74)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI and RAY STALLINGS SMITH III with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 & 16-10-1, for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on the 10th day 0f December 2020, unlawfully solicited, requested, and importuned certain public officers then serving as elected members of the Georgia House of Representatives and present at a House Governmental Affairs Committee meeting, including Representatives Shaw Blackmon, Jon Burns, Barry Fleming, Todd Jones, Bee Nguyen, Mary Margaret Oliver, Alan Powell, Renitta Shannon, Robert Trammell, Scot Turner, and Bruce Williamson, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. § 16-10-1, by unlawfully appointing presidential electors from the State of Georgia, in willful and intentional violation of the terms of the oath of said persons as prescribed by law, with intent that said persons engage in said conduct, said date being a material element of the offense, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 7 of 41 (pg. 75)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 10th day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia House of Representatives present at a House Governmental Affairs Committee meeting:

1. That it is quite clear from the State Farm Arena Video from November 3, 2020, that Fulton County election workers were stealing votes and that Georgia officials were covering up a crime in plain sight;
2. That at State Farm Arena on November 3, 2020, Democratic officials “got rid of all of the reporters, all the observers, anyone that couldn’t be trusted,” used the excuse of a water main break, cleared out the voting area and then “went about their dirty, crooked business”;
3. That between 12,000 and 24,000 ballots were illegally counted by Fulton County election workers at State Farm Arena on November 3, 2020;
4. That in Michigan, there were 700,000 more ballots counted than were sent out to voters in the November 3, 2020, presidential election, which was accounted for by quadruple counting ballots;
5. That Ruby Freeman, Shaye Moss, and an unidentified man were “quite obviously surreptitiously passing around USB ports as if they’re vials of heroin or cocaine” at State Farm Arena to be used to “infiltrate the crooked Dominion voting machines”;
6. That 96,600 mail-in ballots were counted in the November 3, 2020, presidential election in Georgia, despite there being no record of those ballots having been returned to a county elections office;

said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 8 of 41 (pg. 76)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, and CATHLEEN ALSTON LATHAM with the offense of IMPERSONATING A PUBLIC OFFICER, O.C.G.A. § 16-10-23, for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 14th day of December 2020, unlawfully falsely held themselves out as the duly elected and qualified presidential electors from the State of Georgia, public officers, with intent to mislead the President of the United States Senate, the Archivist of the United States, the Georgia Secretary of State, and the Chief Judge of the United States District Court for the Northern District of Georgia into believing that they actually were such officers by placing in the United States mail to said persons a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 9 of 41 (pg. 76)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY, and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT IMPERSONATING A PUBLIC OFFICER, O.C.G.A. §§16-4-8 & 16-10-23, for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired to cause certain individuals to falsely hold themselves out as the duly elected and qualified presidential electors from the State of Georgia, public officers, with intent to mislead the President of the United States Senate, the Archivist of the United States, the Georgia Secretary of State, and the Chief Judge of the United States District Court for the Northern District of Georgia into believing that they actually were such officers;

And the Defendants named in Count 8, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, falsely held themselves out as said public officers by placing in the United States mail to said persons a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA” in Fulton County, Georgia, which was an overt act to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 10 of 41 (pg. 77)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, and CATHLEEN ALSTON LATHAM with the offense of. FORGERY IN THE FIRST DEGREE, O.C.G.A. § 16-9-1(b), for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 14th day of December 2020, unlawfully and with the intent to defraud, knowingly made a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” a writing other than a check, in such manner that the writing as made purports to have been made by authority of the duly elected and qualified presidential electors from the State of Georgia, who did not give such authority, and uttered and delivered said document to the Archivist of the United States, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 11 0f 41 (pg. 77)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY, and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE, O.C.G.A. §§ 16-4-8 & 16-9—1(b), for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired, with the intent to defraud, to knowingly make a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” a writing other than a check, in such manner that the writing as made purports to have been made by authority of the duly elected and qualified presidential electors from the State of Georgia, who did not give such authority, and to utter and deliver said document to the Archivist of the United States;

And the Defendants named in Count 10, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, made said document in Fulton County, Georgia, and uttered and delivered said document to the Archivist of the United States in Fulton County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 12 0f 41 (pg. 78)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, and CATHLEEN ALSTON LATHAM with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, individually and as persons concerned in the commission of a crime, and together With un-indicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 14th day of December 2020, knowingly, willfully, and unlawfully made and used a false document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” with knowledge that said document contained the false statement, “WE, THE UNDERSIGNED, being the duly elected and qualified Electors for President and Vice President of the United States of America from the State of Georgia, do hereby certify the following,” said document being within the jurisdiction of the Office of the Georgia Secretary of State and the Office of the Governor of Georgia, departments and agencies of state government, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 13 0f 41 (pg. 78)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY, and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS, O.C.G.A. §§ 16-4-8 & 16-10-20, for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired to knowingly and willfully make and use a false document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” with knowledge that said document contained the false statement, “WE, THE UNDERSIGNED, being the duly elected and qualified Electors for President and Vice President of the United States of America from the State of Georgia, do hereby certify the following,” said document being within the jurisdiction of the Office of the Georgia Secretary of State and the Office of the Governor of Georgia, departments and agencies of state government;

And the Defendants named in Count 12, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, made and used said document in Fulton County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 14 of 41 (pg. 78)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER, SHAWN MICAH TRESHER STILL, and CATHLEEN ALSTON LATHAM with the offense of CRIMINAL ATTEMPT TO COMMIT FILING FALSE DOCUMENTS, O.C.G.A. §§ 16-4-1 & 16-10-20.1(b)(1), for the said accused; individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 14th day of December 2020, unlawfully, with intent to commit the crime of Filing False Documents, O.C.G.A. § 16-10-20.l(b)(1), placed in the United States mail a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” addressed to Chief Judge, U.S. District Court, Northern District of Georgia, 2188 Richard D. Russell Federal Office Building and U.S. Courthouse, 75 Ted Turner Drive, SW, Atlanta, GA 30303, a substantial step toward the commission of Filing False Documents, O.C.G.A. § 16-10-20.1(b)(1), with intent to knowingly file, enter, and record said document in a court of the United States, having reason to know that said document contained the materially false statement, “WE, THE UNDERSIGNED, being the duly elected and qualified Electors for President and Vice President of the United States of America from the State of Georgia, do hereby certify the following,” contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 15 of 41 (pg. 79)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY, and MICHAEL A. ROMAN with the offense of CONSPIRACY T0 COMMIT FILING FALSE DOCUMENTS, O.C.G.A. §§ 16-4-8 & 16-10-20.1(b)(1), for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired to knowingly file, enter, and record a document titled “CERTIFICATE OF THE VOTES OF THE 2020 ELECTORS FROM GEORGIA,” in a court of
the United States, having reason to know that said document contained the materially false statement, “WE, THE UNDERSIGNED, being the duly elected and qualified Electors for President and Vice President of the United States of America from the State of Georgia, do hereby certify the following”;

And the Defendants named in Count 14, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, placed in the United States mail said document, addressed to Chief Judge, U.S. District Court, Northern District of Georgia, 2188 Richard D. Russell Federal Office Building and U.S. Courthouse, 75 Ted Turner Drive, SW, Atlanta, GA 30303, in Fulton County, Georgia, which was an overt act to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT l6 of 41 (pg. 80)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER and SHAWN MICAH TRESHER STILL with the offense of FORGERY IN THE FIRST DEGREE, O.C.G.A. § 16-9-1(b), for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 14th day of December 2020, unlawfully and with the intent to defraud, knowingly made a document titled “RE: Notice of Filling of Electoral College Vacancy,” a writing other than a check, in such manner that the writing as made purports to have been made by the authority of the duly elected and qualified presidential electors from the State of Georgia, who did not give such authority, and uttered and delivered said document to the Archivist of the United States and the Office of the Governor of Georgia, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 17 of 41 (pg. 80)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY, and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE, O.C.G.A. §§ 16-4-8 & 16-9-1(b), for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day of December 2020 and the 14th day of December 2020, unlawfully conspired, with the intent to defraud, to knowingly make a document titled “RE: Notice of Filling of Electoral College Vacancy,” a writing other than a check, in such manner that the writing as made purports to have been made by the authority of the duly elected and qualified presidential electors from the State of Georgia, who did not give such authority, and to utter and deliver said document to the Archivist of the United States and the Office of the Governor “of Georgia;

And the Defendants named in Count l6, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, made said document in Fulton County, Georgia, and uttered and delivered said document to the Archivist of the United States and the Office of the Governor of Georgia in Fulton County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 18 of 41 (pg. 81)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JAMES SHAFER and SHAWN MICAH TRESHER STILL with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 14th day of December 2020, knowingly, willfully, and unlawfully made and used a false document titled “RE: Notice of Filling of Electoral College Vacancy,” with knowledge that said document contained the false statements that DAVID JAMES SHAFER was Chairman of the 2020 Georgia Electoral College Meeting and SHAWN MICAH TRESHER STILL was Secretary of the 2020 Georgia Electoral College Meeting, said document being within the jurisdiction of the Office of the Georgia Secretary of State and the Office of the Governor of Georgia, departments and agencies of state government, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 19 0f 41 (pg. 81)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP, RUDOLPH WILLIAM LOUIS GIULIANI, JOHN CHARLES EASTMAN, KENNETH JOHN CHESEBRO, RAY STALLINGS SMITH III, ROBERT DAVID CHEELEY and MICHAEL A. ROMAN with the offense of CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS, O.C.G.A. §§ 16-4-8 & 16-10-20, for the said accused, individually and as persons concerned in the commission of a crime, and together with indicted and un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 6th day 0f December 2020 and the 14th day of December 2020, unlawfully conspired to knowingly and willfully make and use a false document titled “RE: Notice of Filling of Electoral College Vacancy,” with knowledge that said document contained the false statements that DAVID JAMES SHAFER was Chairman of the 2020 Georgia Electoral College Meeting and SHAWN MICAH TRESHER STILL was Secretary of the 2020 Georgia Electoral College Meeting, said document being within the jurisdiction of the Office of the Georgia Secretary of State and the Office of the Governor of Georgia, departments and agencies of state government;

And the Defendants named in Count l8, acting as co-conspirators, as described above and incorporated by reference as if fully set forth herein, made and used said document in Fulton County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 20 0f 41 (pg. 82)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse STEPHEN CLIFFGARD LEE with the offense of CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES, O.C.G.A. §§ 16-4-1 & 16-10-93(b)(1)(A), for the said accused, in the County of Fulton and State of Georgia, on the 14th day 0f December 2020, unlawfully, with intent to commit the crime of Influencing’ Witnesses, O.C.G.A. § l6-lO-93(b)(l)(A), traveled to the home of Ruby Freeman, a Fulton County, Georgia, election worker, and spoke to her neighbor, a substantial step toward the commission of Influencing Witnesses, O.C.G.A. § 16-10-93 (b)(l)(A), with intent to knowingly engage in misleading conduct toward Ruby Freeman, by purporting to offer her help, and with intent to influence her testimony in an official proceeding in Fulton County, Georgia, concerning events at State Farm Arena in the November 3, 2020, presidential election in Georgia, said date being a material element of the offense, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 21 0f 41 (pg. 82)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse STEPHEN CLIFFGARD LEE with the offense of CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES, O.C.G.A. §§ 16-4-1 & 16-10-93(b)(1)(A), for the said accused, in the County of Fulton and State of Georgia, on the 15th day of December 2020, unlawfully, with intent to commit the crime of Influencing Witnesses, O.C.G.A. § l6-lO-93(b)(l)(A), traveled to the home of Ruby Freeman, a Fulton County, Georgia, election worker, and knocked on her door, a substantial step toward the commission of Influencing Witnesses, O.C.G.A. § 16-10-93 (b)(l)(A), with intent to knowingly engage in misleading conduct toward Ruby Freeman, by purporting to offer her help, and with intent to influence her testimony in an official proceeding in Fulton County, Georgia, concerning events at State Farm Arena in the November 3, 2020, presidential election in Georgia, said date being a material element of the offense, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 22 0f 41 (pg. 83)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do Charge and accuse JEFFREY BOSSERT CLARK with the offense of CRIMINAL ATTEMPT TO COMMIT FALSE STATEMENTS AND WRITINGS, O.C.G.A. §§ 16-4-1 & 16-10-20, for the said accused, individually and as a person concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 28th day of December 2020 and the 2nd day of January 2021, unlawfully, With intent to commit the crime of False Statements and Writings, O.C.G.A. § 16-10-20, knowingly and willfully made a false writing and document knowing the same to contain the false statement that the United States Department of Justice had “identified significant concerns that may have impacted the outcome of the election in multiple State’s, including the State of Georgia,” said statement being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies;

And, on or about the 28th day of December 2020, the said accused sent an e-mail to Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney General Richard Donoghue and requested authorization to send said false writing and document to Georgia Governor Brian Kemp, Speaker of the Georgia House of Representatives David Ralston, and President Pro Tempore of the Georgia Senate Butch Miller;

And, on or about the 2nd day of January 2021, the said accused met with Acting United States Attorney General Jeffrey Rosen and Acting United States Deputy Attorney General Richard Donoghue and requested authorization to send said false writing and document to Georgia Governor Brian Kemp, Speaker of the Georgia House of Representatives David Ralston, and President Pro Tempore of the Georgia Senate Butch Miller;

And said acts constituted substantial steps toward the commission of False Statements and Writings, O.C.G.A. § 16-10-20, and said conduct committed outside the state of Georgia constituted an attempt to commit a crime within the state of Georgia, pursuant to O.C.G.A. § l7-2-1(b)(2), contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 23 of 41 (pg. 84)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI, RAY STALLINGS SMITH III, and ROBERT DAVID CHEELEY with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 & 16-10-1, for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on the 30th day of December 2020, unlawfully solicited, requested, and importuned certain public officers then serving as elected members of the Georgia Senate and present at a Senate Judiciary Subcommittee meeting, including un-indicted co-conspirator Individual 8, whose identity is known to the Grand Jury, Senators Brandon Beach, Bill Heath, William Ligon, Michael Rhett, and Blake Tillery, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. § 16-10-1, by unlawfully appointing presidential electors from the State of Georgia, in willful and intentional violation of the terms of the oath of said persons as prescribed by law, with intent that said persons engage in said conduct, said date being a material element of the offense, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 24 0f 41 (pg. 84)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RUDOLPH WILLIAM LOUIS GIULIANI with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 30th day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:

1. That Fulton County election workers fraudulently counted certain ballots as many as five times at State Farm Arena on November 3, 2020;
2. That 2,560 felons voted illegally in the November 3, 2020, presidential election in Georgia;
3. That 10,315 dead people voted in the November 3, 2020, presidential election in Georgia;

said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 25 0f 41 (pg. 85)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse RAY STALLINGS SMITH III with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 30th day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:

1. That Georgia Secretary of State General Counsel Ryan Germany stated that his office had sent letters to 8,000 people who voted illegally in the November 3, 2020, presidential election and told them not to vote in the January 5, 2021, runoff election;
2. That the Georgia Secretary of State admitted “that they had a 90% accuracy rate” in the November 3, 2020, presidential election and that “there’s still a 10% margin that’s not accurate”;

said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 26 of 41 (pg. 85)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse ROBERT DAVID CHEELEY with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 30th day of December 2020, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to members of the Georgia Senate present at a Senate Judiciary Subcommittee meeting:

1. That poll watchers and media at State Farm Arena were told late in the evening of November 3, 2020, that the vote count was being suspended until the next morning and to go home because of “a major water main break”;
2. That Fulton County election workers at State Farm Arena “voted” the same ballots “over and over again” on November 3, 2020;

said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 27 of 41 (pg. 86)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP and JOHN CHARLES EASTMAN with the offense of FILING FALSE DOCUMENTS, O.C.G.A. § 16-10-20.1(b)(1), for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 3lst day of December 2020, knowingly and unlawfully filed a document titled “VERIFIED COMPLAINT FOR EMERGENCY INJUNCTIVE AND DECLARATORY RELIEF” in the matter of Trump v. Kemp, Case 1:20-cv-05310-MHC, in the United States District Court for the Northern District of Georgia, a court of the United States, having reason to know that said document contained at least one of the following materially false statements:

1. That “as many as 2,506 felons with an uncompleted sentence” voted illegally in the November 3, 2020, presidential election in Georgia;
2. That “at least 66,247 underage” people voted illegally in the November 3, 2020, presidential election in Georgia;
3. That “at least 2,423 individuals” voted illegally in the November 3, 2020, presidential election in Georgia “who were not listed in the State’s records as having been registered to vote”;
4. That “at least 1,043 individuals” voted illegally in the N0vember 3, 2020, presidential election “who had illegally registered to vote using a postal office box as their habitation”;
5. That “as many as 10,315 or more” dead people voted in the November 3, 2020, presidential election in Georgia;
6. That “[d]eliberate misinformation was used to instruct Republican poll watchers and members of the press to leave the premises for the night at approximately 10:00 pm. on November 3, 2020” at State Farm Arena in Fulton County, Georgia;

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

COUNT 28 of 41 (pg. 87)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP and MARK RANDALL MEADOWS with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 & 16-10-1, for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 2nd day of January 2021, unlawfully solicited, requested, and importuned Georgia Secretary of State Brad Raffensperger, a public officer, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. § l6-10-1, by unlawfully altering, unlawfully adjusting, and otherwise unlawfully influencing the certified returns for presidential electors for the November 3, 2020, presidential election in Georgia, in willful and intentional violation of the terms of the oath of said person as prescribed by law, with intent that said person engage in said conduct, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 29 of 41 (pgs. 88-89)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 2nd day of January 2021, knowingly, willfully, and unlawfully made at least one of the following false statements and representations to Georgia Secretary of State Brad Raffensperger, Georgia Deputy Secretary of State Jordan Fuchs, and Georgia Secretary of State General Counsel Ryan Germany:

1. That anywhere from 250,000 to 300,000 ballots were dropped mysteriously into the rolls in the November 3, 2020, presidential election in Georgia;
2. That thousands of people attempted to vote in the November 3, 2020, presidential election in Georgia and were told they could not because a ballot had already been cast in their name;
3. That 4,502 people voted in the November 3, 2020, presidential election in Georgia who were not on the voter registration list;
4. That 904 people voted in the November 3, 2020, presidential election in Georgia who were registered at an address that was a post office box;
5. That Ruby Freeman was a professional vote scammer and a known political operative;
6. That Ruby Freeman, her daughter, and others were responsible for fraudulently awarding at least 18,000 ballots to Joseph R. Biden at State Farm Arena in the November 3, 2020, presidential election in Georgia;
7. That close to 5,000 dead people voted in the November 3, 2020, presidential election in Georgia;
8. That 139% of people voted in the November 3, 2020, presidential election in Detroit;
9. That 200,000 more votes were recorded than the number of people who voted in the November 3, 2020, presidential election in Pennsylvania;
10. That thousands of dead people voted in the November 3, 2020, presidential election in Michigan;
11. That Ruby Freeman stuffed the ballot boxes;
12. That hundreds of thousands of ballots had been “dumped” into Fulton County and another county adjacent to Fulton County in the November 3, 2020, presidential election in Georgia;
13. That he won the November 3, 2020, presidential election in Georgia by 400,000 votes;

said statements being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 30 of 41 (pg. 89)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse STEPHEN CLIFFGARD LEE, HARRISON WILLIAM PRESCOTT FLOYD, and TREVIAN C. KUTTI with the offense of CONSPIRACY TO COMMIT SOLICITATION OF FALSE STATEMENTS AND WRITINGS, O.C.G.A. §§ 16-4-8, 16-4-7, & 16-10-20, for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 4th day of January 2021, unlawfully conspired to solicit, request, and importune Ruby Freeman, a Fulton County, Georgia, election worker, to engage in conduct constituting the felony offense of False Statements and Writings, O.C.G.A. § 16-10-20, by knowingly and willfully making a false statement and representation concerning events at State Farm Arena in the November 3, 2020, presidential election in Georgia, said statement and representation being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, with intent that said person engage in said conduct; and TREVIAN C. KUTTI traveled to Fulton County, Georgia, and placed a telephone call to Ruby Freeman while in Fulton County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 31 of 41 (pg. 89)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse STEPHEN CLIFFGARD LEE, HARRISON WILLIAM PRESCOTT FLOYD and TREVIAN C. KUTTI with the offense of INFLUENCING WITNESSES, O.C.G.A. § 16-10-93(b)(1)(A), for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on or about the 4th day of January 2021, knowingly and unlawfully engaged in misleading conduct toward Ruby Freeman, a Fulton County, Georgia, election worker, by stating that she needed protection and by purporting to offer her help, with intent to influence her testimony in an official proceeding in Fulton County, Georgia, concerning events at State Farm Arena in the November 3, 2020, presidential election in Georgia, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 32 of 41 (pg. 90)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HANIPTON with the offense of CONSPIRACY TO COMMIT ELECTION FRAUD, O.C.G.A. §§ 21-2-603 & 21-2-566, for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 1st day of December 2020 and the 7th day of January 2021, unlawfully conspired and agreed to willfully tamper with electronic ballot markers and tabulating machines in the State of Georgia;

And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of willfully tampering with said electronic ballot markers and tabulating machines, which were overt acts to effect the object of the conspiracy;

And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in willfully tampering with electronic ballot markers and tabulating machines while inside the Coffee County Elections & Registration Office in Coffee County, Georgia, which were overt acts to effect the object of the conspiracy, contrary t0 the laws of said State, the good order, peace and dignity thereof;

COUNT 33 of 41 (pg. 91)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO COMMIT ELECTION FRAUD, O.C.G.A. §§ 21-2-603 & 21-2-574, for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 1st day of December 2020 and the 7th day of January 2021, unlawfully conspired and agreed to cause certain members of the conspiracy, who were not officers charged by law with the care of ballots and who were not persons entrusted by any such officer with the care of ballots for a purpose required by law, to possess official ballots outside of the polling place in the State of Georgia;

And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of causing certain members of the conspiracy, who were not officers charged by law with the care of ballots and who were not persons entrusted by any such officer with the care of ballots for a purpose required by law, to possess official ballots outside of the polling place, which were overt acts to effect the object of the conspiracy;

And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in accessing election equipment while inside the Coffee County Elections & Registration Office in Coffee County, Georgia, for the purpose of causing certain members of the conspiracy, who were not officers charged by law with the care of ballots and who were not persons entrusted by any such officer with the care of ballots for a purpose required by law, to possess official ballots outside of the polling place, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 34 of 41 (Pg. 92)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO COMMIT COMPUTER THEFT, O.C.G.A. §§ 16-4-8 & 16-9-93(a), for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 1st day of December 2020 and the 7th day of January 2021, unlawfully conspired to use a computer with knowledge that such use was without authority and with the intention of taking and appropriating information, data, and software, the property of Dominion Voting Systems Corporation,

And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of using a computer with knowledge that such use was without authority and with the intention of taking and appropriating information, data, and software, the property of Dominion Voting Systems Corporation, which were overt acts to effect the object of the conspiracy;

And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in using a computer with knowledge that such use was without authority and with the intention of taking and appropriating information, data, and software, the property of Dominion Voting Systems Corporation, while inside the Coffee County Elections & Registration Office in Coffee County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 35 of 41 (pg. 93)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO COMMIT COMPUTER TRESPASS, O.C.G.A. §§ 16-4-8 & 16-9-93(b), for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the lst day of December 2020 and the 7th day of January 2021, unlawfully conspired to use a computer with knowledge that such use was without authority and with the intention of removing voter data and Dominion Voting Systems Corporation data from said computer;

And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of using a computer with knowledge that such use was without authority and with the intention of removing voter data and Dominion Voting Systems Corporation data from said computer, which were overt acts to effect the object of the conspiracy;

And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in using a computer with knowledge that such use was without authority and with the intention of removing voter data and Dominion Voting Systems Corporation data from said computer, while inside the Coffee County Elections & Registration Office in Coffee County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 36 of 41 (pg. 94)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO COMMIT COMPUTER INVASION OF PRIVACY, O.C.G.A. §§ 16-4-8 & 16-9-93(c), for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the lst day of December 2020 and the 7th day of January 2021, unlawfully conspired to use a computer with the intention of examining personal voter data with knowledge that such examination was without authority;

And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of using a computer with the intention of examining personal voter data with knowledge that such examination was without authority, which were overt acts to effect the object of the conspiracy;

And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in using a computer with the intention of examining personal voter data with knowledge that such examination was without authority, while inside the Coffee County Elections & Registration Office in Coffee County, Georgia, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 37 of 41 (pg. 95)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON with the offense of CONSPIRACY TO DEFRAUD THE STATE, O.C.G.A. § 16-10-21, for the said accused, individually and as persons concerned in the commission of a crime, and together with un-indicted co-conspirators, in the County of Fulton and State of Georgia, on and between the 1st day of December 2020 and the 7th day of January 2021, unlawfully conspired and agreed to commit theft of voter data, property which was under the control of Georgia Secretary of State Brad Raffensperger, a state officer, in his official capacity;

And SIDNEY KATHERINE POWELL entered into a contract with SullivanStrickler LLC in Fulton County, Georgia, delivered a payment to SullivanStrickler LLC in Fulton County, Georgia, and caused employees of SullivanStrickler LLC to travel from Fulton County, Georgia, to Coffee County, Georgia, for the purpose of committing theft of voter data, property which was under the control of Georgia Secretary of State Brad Raffensperger, a state officer, in his official capacity, which were overt acts to effect the object of the conspiracy;

And CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON aided, abetted, and encouraged employees of SullivanStrickler LLC in accessing election equipment while inside the Coffee County Elections & Registration Office in Douglas, Georgia, for the purpose of committing theft of voter data, property which was under the control of Georgia Secretary of State Brad Raffensperger, a state officer, in his official capacity, which were overt acts to effect the object of the conspiracy, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 38 of 41 (pg. 95)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP with the offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4-7 and 16-10-1, for the said accused, in the County of Fulton and State of Georgia, on or about the 17th day of September 2021, unlawfully solicited, requested, and importuned Georgia Secretary of State Brad Raffensperger, a public officer, to engage in conduct constituting the felony offense of Violation of Oath by Public Officer, O.C.G.A. § 16-10-1, by unlawfully “decertifying the Election, or whatever the correct legal remedy is, and announce the true winner,” in willful and intentional violation of the terms of the oath of said person as prescribed by law, with intent that said person engage in said conduct, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 39 0f 41 (pg. 96)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DONALD JOHN TRUMP with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 17th day of September 2021, knowingly, willfully, and unlawfully made the following false statement and representation to Georgia Secretary of State Brad Raffensperger:

l. “As stated to you previously, the number of false and/or irregular votes is far greater than needed to change the Georgia election result”;

said statement being within the jurisdiction of the Office of the Georgia Secretary of State and the Georgia Bureau of Investigation, departments and agencies of state government, and county and city law enforcement agencies, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 40 of 41 (pg. 96)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse DAVID JANIES SHAFER with the offense of FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 25th day of April 2022, knowingly, willfully, and unlawfully made at least one of the following false statements and representations in the presence of Fulton County District Attorney’s Office investigators:

1. That he “attended and convened” the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia, but that he did not “call each of the individual members and notify them of the meeting or make any of the other preparations necessary for the meeting”;
2. That a court reporter was not present at the December 14, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia;

said statements being within the jurisdiction of the Fulton County District Attorney’s Office, a department and agency of the government of a county of this state, contrary to the laws of said State, the good order, peace and dignity thereof;

COUNT 41 of 41 (pg. 97)

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do charge and accuse ROBERT DAVID CHEELEY with the offense of PERJURY, O.C.G.A. §16-10-70(a), for the said accused, in the County of Fulton and State of Georgia, on or about the 15th day of September 2022, knowingly, willfully, and unlawfully made at least one of the following false statements before the Fulton County Special Purpose Grand Jury, a judicial proceeding, after having been administered a lawful oath:

1. That he was unaware of the December l4, 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 l4, 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 l4, 2020;
4. That the only communication he had with John Eastman concerning the November 3, 2020, presidential election was for the purpose of connecting Eastman to Georgia Senator Brandon Beach and un-indicted co-conspirator Individual 8, whose identity is known to the Grand Jury, for possible legal representation;
5. That he never worked to connect John Eastman with any Georgia legislators other than Georgia Senator Brandon Beach and un-indicted 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 l4, 2020, meeting of Trump presidential elector nominees in Fulton County, Georgia, and to the accused’s communications with others involved in said meeting, the issues in question, contrary to the laws of said State, the good order, peace and dignity thereof.

FANI T. WILLIS, District Attorney

WITNESS LIST (pg. 98)

Asst. Chief Inv. M. Hill – FCDA DA14
Sr. Inv. T. Swanson-Lucas – FCDA DA72

[End]

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