19 defendants and 41 separate criminal charges… 13 counts for #FPOTUS… 30 unindicted co-conspirators...
Grand Jury Indictment
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 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 1 through Individual 30, and others known and unknown to the Grand Jury, constituted criminal organization whose members and associates engaged in various related criminal activities including, but not limited to, false statements and writings, impersonating 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. § 16-14-3(3), that is, 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 continuing unit for 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 period of time sufficient to permit its members and associates to pursue its objectives.
Of the 19 defendants Trump and Giuliani face the most charges.
THE STATE OF GEORGIA
V.
DONALD JOHN TRUMP
Counts 1, 5, 9, 11, 13, 15, 17, 19, 27-29, 38-39 (13 Counts)
RUDOLPH WILLIAM LOUIS GIULIANI
Counts 1-3, 6-7, 9, 11, 13, 15, 17, 19, 23-24 (13 Counts)
JOHN CHARLES EASTMAN
Counts 1-2, 9, 11, 13, 15, 17, 19, 27 (9 Counts)
MARK RANDALL MEADOWS
Counts 1, 28 (2 Counts)
KENNETH JOHN CHESEBRO
Counts 1, 9, 11, 13, 15, 17, 19 (7 Counts)
JEFFREY BOSSERT CLARK
Counts 1, 22 (2 Counts)
JENNA LYNN ELLIS
Counts 1-2 (2 Counts)
RAY STALLINGS SMITH III
Counts 1-2, 4, 6, 9, 11, 13, 15, 17, 19, 23, 25 (12 Counts)
ROBERT DAVID CHEELEY
Counts 1, 9, 11, 13, 15, 17, 19, 23, 26, 41 (10 Counts)
MICHAEL A. ROMAN
Counts 1, 9, 11, 13, 15, 17, 19 (7 Counts)
DAVID JAMES SHAFER
Counts 1, 8, 10, 12, 14, 16, 18, 40 (8 Counts)
SHAWN MICAH TRESHER STILL
Counts 1, 8, 10, 12, 14, 16, 18 (7 Counts)
STEPHEN CLIFFGARD LEE
Counts 1, 20-21, 30-31 (5 Counts)
HARRISON WILLIAM PRESCOTT FLOYD
Counts 1, 30-31 (3 Counts)
TREVIAN C. KUTTI
Counts 1, 30-31 (3 Counts)
SIDNEY KATHERINE POWELL
Counts 1, 32-37 (7 Counts)
CATHLEEN ALSTON LATHAM
Counts 1, 8, 10, 12, 14, 32-37 (11 Counts)
SCOTT GRAHAM HALL
Counts 1, 32-37 (7 Counts)
MISTY HAMPTON AKA EMILY MISTY HAYES
Counts 1, 32-37 (7 Counts)
Charges faced by the #FPOTUS are in bold for clarity...
- VIOLATION OF THE GEORGIA RICO (RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS) ACT O.C.G.A. § 16-14-4[c]
- SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER O.C.G.A. §§ 164-7 16-10-1
- FALSE STATEMENTS AND WRITINGS O.C.G.A. § 16-10-20
- FALSE STATEMENTS AND WRITINGS O.C.G.A. § 16-10-20
- SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER O.C.G.A. §§ 16-4-7 & 16-10-1
- SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER O.C.G.A. §§ 16-4-7 & 16-10-1
- FALSE STATEMENTS AND WRITINGS O.C.G.A. § 16-10-20
-
IMPERSONATING A PUBLIC OFFICER O.C.G.A. § 16-10-23
-
CONSPIRACY TO COMMIT IMPERSONATING A PUBLIC OFFICER O.C.G.A. §§ 16-4-8 & 16-10-23
-
FORGERY IN THE FIRST DEGREE O.C.G.A. § 16-9-1[b]
-
CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE O.C.G.A. §§ 16-4-8 16-9-1[b]
-
FALSE STATEMENTS AND WRITINGS Counts O.C.G.A. § 16-10-20
-
CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS O.C.G.A. §§ 16-4-8 & 16-10-20
-
CRIMINAL ATTEMPT TO COMMIT FILING FALSE DOCUMENTS O.C.G.A. §§ 16-4-1 & 16-10-20.1[b][1]
-
CONSPIRACY TO COMMIT FILING FALSE DOCUMENTS O.C.G.A. §§ 16-4-8 & 16-10-20.1[b][1]
-
FORGERY IN THE FIRST DEGREE O.C.G.A. §§ 16-9-1[b]
-
CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE O.C.G.A. §§ 16-4-8 & 16-10-20.1[b]
-
FALSE STATEMENTS AND WRITINGS O.C.G.A. § 16-10-20
-
CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS O.C.G.A. §§ 16-4-8 & 16-10-20
-
CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES O.C.G.A. §§ 16-4-1 & 16-10-93[b][1][A]
-
CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES O.C.G.A. §§ 16-4-1 & 16-10-93[b][1][A]
-
CRIMINAL ATTEMPT TO COMMIT FALSE STATEMENTS AND WRITINGS O.C.G.A. §§ 16-4-1 & 16-10-20
-
SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER O.C.G.A. §§ 16-4-7 16-10-1
-
FALSE STATEMENTS AND WRITINGS O.C.G.A. § 16-10-20
-
FALSE STATEMENTS AND WRITINGS O.C.G.A. § 16-10-20
-
FALSE STATEMENTS AND WRITINGS O.C.G.A. § 16-10-20
-
FILING DOCUMENTS O.C.G.A. § 16-10-20.1[b][1]
-
SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER O.C.G.A. §§ 16-4-7 16-10-1
-
FALSE STATEMENTS AND WRITINGS O.C.G.A. § 16-10-20
-
CONSPIRACY TO COMMIT SOLICITATION OF FALSE STATEMENTS AND WRITINGS O.C.G.A. §§ 16-4-8, 16-4-7 & 16-10-20
-
INFLUENCING WITNESSES O.C.G.A. § 16-10-93[b][1][A]
-
CONSPIRACY TO COMMIT ELECTION FRAUD O.C.G.A. §§ 21-2-603 & 21-2-566
-
CONSPIRACY TO COMMIT ELECTION FRAUD O.C.G.A. §§ 21-2-603 & 21-2-574
-
CONSPIRACY TO COMMIT COMPUTER THEFT O.C.G.A. §§ 16-4-8 & 16-9-93[a]
-
CONSPIRACY TO COMMIT COMPUTER TRESPASS O.C.G.A. §§ 16-4-8 & 16-9-93[b]
-
CONSPIRACY TO COMMIT COMPUTER INVASION OF PRIVACY O.C.G.A. §§ 16-4-8 & 16-9-93[c]
-
CONSPIRACY TO DEFRAUD THE STATE O.C.G.A. § 16-10-21
-
SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER O.C.G.A. §§ 16-4-7 &16-10-1
-
FALSE STATEMENTS AND WRITINGS O.C.G.A. § 16-10-20
-
FALSE STATEMENTS AND WRITINGS O.C.G.A. § 16-10-20
-
PERJURY O.C.G.A. § 16-10-70[a]
The only defendant charged with the perjury count is Robert Cheeley...
There are 161 overt acts alleged in furtherance of the RICO racketeering conspiracy laid out in Count 1 of the indictment. Enough for several separate diaries. This indictment is huge. 98 pages.
Fani Willis seems to have left nothing out…
Act 6.
On or about the 21st day of November 2020, MARK RANDALL MEADOWS sent text message to United States Representative Scott Perry from Pennsylvania and stated, "Can you send me the number for the speaker and the leader of PA Legislature. POTUS wants to chat with them." This was an overt act in furtherance of the conspiracy.
Simply asking for a phone number was an act in furtherance of the conspiracy.
Act 33.
On or about the 6th day of December 2020, SIDNEY KATHERINE POWELL entered into written engagement agreement with SullivanStrickler LLC, forensic data firm located in Fulton County, Georgia, for the performance of computer forensic collections and analytics on Dominion Voting Systems equipment in Michigan and elsewhere. The unlawful breach of election equipment in Coffee County, Georgia, was subsequently performed under this agreement. This was an overt act in furtherance of the conspiracy.
Every phone call, tweet, and text between themselves and to others was an overt act in furtherance of the conspiracy.
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 O.C.G.A. §§ 16-4-7 & 16-10-1, in Fulton County, Georgia, by unlawfully soliciting, requesting, and importuning Speaker of the Georgia House of Representatives David Ralston, 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 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.
The Devil’s in the details…
Act 55.
On or about the 10th day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI and RAY STALLINGS SMITH III committed the felony offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, in Violation of O.C.G.A. §§ 16-4-7 & 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 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 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.
This isn’t all Georgia...
Act 64.
On or about the 12th day of December 2020, KENNETH JOHN CHESEBRO 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.
Crimes in various states are alleged….
Act 70.
On or about the 13th day of December 2020, KENNETH JOHN CHESEBRO sent an e-mail to RUDOLPH WILLIAM LOUIS GIULIANI with the subject "PRIVILEGED AND CONFIDENTIAL Brief notes on 'President of the Senate' strategy." In the email, KENNETH JOHN CHESEBRO 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 e-mail, KENNETH JOHN CHESEBRO stated that the strategies outlined by him were "preferable to allowing the Electoral Count Act to operate by its terms." This was an overt act in furtherance of the conspiracy.
Acts 78 through 85 revolve around the documents submitting the false electors…
Act 90.
On or about the 18th day of December 2020, DONALD JOHN TRUMP met with RUDOLPH WILLIAM LOUIS GIULIANI, SIDNEY KATHERINE 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 KATHERINE 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.
Lots to highlight...
Act 94.
On or about the 23rd day of December 2020, JOHN CHARLES EASTMAN sent an e-mail to KENNETH JOHN CHESEBRO and unindicted co-conspirator Individual 3, whose identity is known to the Grand Jury, with the subject "FW: Draft 2, with edits'." In the e-mail, JOHN CHARLES EASTMAN attached memorandum titled "PRIVILEGED AND CONFIDENTIAL — Dec 23 memo on Jan scenario.docx" and stated, "As for hearings, think both are unnecessary. The fact that we have multiple slates of electors demonstrates the uncertainty of either. That should be enough. And agree with Ken that Judiciary Committee hearings on the constitutionality of the Electoral Count Act could invite counter views that we do not believe should constrain Pence (or Grassley) in the exercise of power they have under the 12th Amendment. Better for them just to act boldly and be challenged, since the challenge would likely lead to the Court denying review on nonjusticiable political question grounds." This was an overt act in furtherance of the conspiracy.
Skipping past the stuff we already know...
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 Donoghue to sign and send document that falsely stated that the United States Department of Justice had "identified significant concerns that may have impacted the outcome of the election in multiple States, including the State of Georgia,"to Georgia Governor Brian Kemp, Speaker of the Georgia House of Representatives David Ralston, and President Pro Tempore of the Georgia Senate Butch Miller. This was an overt act in furtherance of the conspiracy.
Like the Raffensperger phone call...
Act 102.
On or about the 30th day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI, RAY STALLINGS SMITH III, and ROBERT DAVID CHEELEY committed the felony offense of SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER,in violation of O.C.G.A. §§ 16-4-7 16-10-1, in Fulton County, Georgia, by soliciting,requesting, and importuning certain public officers then serving as elected members of the Georgia Senate and present at Senate Judiciary Subcommittee meeting, including unindicted co-conspirator 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 Ofiicer, 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. This was an overt act in furtherance of the conspiracy.
And the intimidation of Ruby Freeman...
Act 145.
On or about the 7th day of January 2021, SIDNEY KATHERINE POWELL, CATHLEEN ALSTON LATHAM, SCOTT GRAHAM HALL, and MISTY HAMPTON committed the felony offense of UNLAWFUL POSSESSION OF BALLOTS, in Violation of O.C.G.A. 21-2-574, in Coffee County, Georgia, by causing certain members of the conspiracy, who were not officers charged by law with the care of ballots and who were not persons entrusted by any such officer with the care of ballots for purpose required by law, to possess official ballots outside of the pol
Counts 32 through 37 of the indictment concern voting machine tampering...
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 SullivanStrickler LLC directing him to transmit all data copied from Dominion Voting Systems equipment at the Coffee County Board of Elections Registration Office in Coffee County, Georgia, to unindicted co-conspirator Individual 30, whose identity is known to the Grand Jury, an attorney associated with SIDNEY KATHERINE POWELL and the Trump Campaign. This was an act of racketeering activity under O.C.G.A. 16-14-3(5)(B) and an overt act in furtherance of the conspiracy.
Everything and the kitchen sink in there. I don’t think we could have asked for a better indictment. Prosecutors only have to prove a defendant committed two overt acts in furtherance of one or more state crimes to get the RICO conviction.
I think this explains the large number of unindicted co-conspirators. If they only committed one overt act but not a second then they couldn’t be indicted under RICO.
These bozos are toast...