A grand jury in Fulton County, Ga., on Monday unveiled the fourth criminal indictment of former President Donald J. Trump. Like a federal indictment earlier this month, this one concerns Mr. Trump’s efforts to overturn his 2020 election loss. But it differs in that it charges 18 other defendants who are alleged to have taken part in the scheme.
Trump Georgia Election Tampering Indictment 23-SC-188947 – Aug 14, 2023
https://www.scribd.com/document/665041620/Trump-Georgia-Election-Tampering-Indictment-23-SC-188947-Aug-14-2023
Fulton County Superior Court – INDICTMENT
Date: August 14, 2023 Clerk No. 23-SC-188947
Che Alexander, Clerk of Court
FULTON SUPERIOR COURT
THE STATE OF GEORGIA
V.
DONALD JOHN TRUMP
Counts I; 5, 9, 11, 13, 15, 17, 19,
27-2?, 38-39
RUDOLPH WILLIAM LOUIS GIULIANI
Counts 1-3, 6-7, 9, 11, 13, 15, 17, 19,
23-24
JOHN CHARLES EASTMAN
Counts 1-2, 9, 11, 13, 15, 17, 19, 27
MARK RANDALL MEADOWS
Counts 1, 28
KENNETH JOHN CHESEBRO
Counts 1, 9, 11, 13, 15, 17, 19
JEFFREY BOSSERT CLARK
Counts 1, 22
JENNA LYNN ELLIS
Counts 1-2
RAY STALLINGS SMITH ID
Counts 1-2, 4, 6, 9, 11, 13, 15, 17, 19,
23,25
ROBERT DAVID CREELEY
Counts 1, 9, 11, 13, 15, 1_7, 19, 23, 26,
41
MICHAEL A. ROMAN
Counts 1,9, 11,13,15, 17, 19
DAVID JAMES SHAFER
Counts 1, 8, 10, 12, 14, 16, 18, 40
I VIOLATION OF THE GEORGIA RICO (RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS) ACT
O.C.G.A. § 16-14-4(c)
2 SOLICITATIONOFVIOLATIONOFOATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1
3 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
4 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
5 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1
6 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1
7 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
8 IMPERSONATING A PUBLIC OFFICER
O.C.G.A. § 16-10-23
9 CONSPIRACY TO COMMIT IMPERSONATING A PUBLIC OFFICER
O.C.G.A. §§ 16-4-8 & 16-10-23
10 FORGERYIN THE FIRST DEGREE
O.C.G.A. § 16-9-l(b)
11 CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE
O.C.G.A. §§ 16-4-8 & 16-9-l(b)
16 FORGERY IN THE FIRST DEGREE
O.C.G.A. § 16-9-l(b)
17 CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE
O.C.G.A. §§ 16-4-8 & 16-9-l(b)
18 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
19 CONSPIRACY TO COMMIT
FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-8 & 16-10-20
20 CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES
O.C.G.A. §§ 16-4-1 & 16-10-93(b)(l)(A)
21 CRIMINAL ATTEMPT TO COMMIT INFLUENCING WITNESSES
O.C.G.A. §§ 16-4-1 & 16-10-93(b)(l)(A)
22 CRIMINAL ATTEMPT TO COMMIT FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-1 & 16-10-20
23 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1
24 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
25 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
26 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
27 FILING FALSE DOCUMENTS
O.C.G.A. § 16-10-20.l(b)(l)
28 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1
29 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
30 CONSPIRACY TO COMMIT SOLICITATION OF FALSE STATEMENTS AND WRITINGS
O.C.G.A. §§ 16-4-8, 16-4-7 & 16-10-20
31 INFLUENCING WITNESSES
O.C.G.A. § 16-10-93(b)(l)(A)
32 CONSPIRACY TO COMMIT ELECTION FRAUD
O.C.G.A. §§ 21-2-603 & 21-2-566
33 CONSPIRACY TO COMMIT ELECTION FRAUD
O.C.G.A. §§ 21-2-603 & 21-2-574
34 CONSPIRACY TO COMMIT COMPUTER THEFf
O.C.G.A. §§ 16-4-8 & 16-9-93(a)
35 CONSPIRACY TO COMMIT COMPUTER TRESPASS
O.C.G.A. §§ 16-4-8 & 16-9-93(b)
36 CONSPIRACY TO COMMIT COMPUTER INVASION OF PRIVACY
O.C.G.A. §§ 16-4-8 & 16-9-93(c)
37 CONSPIRACY TO DEFRAUD THE STATE
O.C.G.A. § 16-10-21
38 SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER
O.C.G.A. §§ 16-4-7 & 16-10-1
39 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
40 FALSE STATEMENTS AND WRITINGS
O.C.G.A. § 16-10-20
41 PERJURY
O.C.G.A. § 16-10-?0(a)
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 CREELEY, MICHAELA. 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 OFTHE 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 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 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;
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 Chesebro, Jeffrey Bossert Clark, Jenna Lynn Ellis, Ray Stallings Smith Ill, 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. § 16-14-3(3), that is, a group of individuals associated in fact. The Defendants and other members and associates of the enterprise bad 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 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 ofthe Defendants, made false statements in Fulton County and elsewhere in tl1e State of Georgia to Georgia officials, including tile Governor, the Secretary of State, and the Speaker of the House of Representatives. Members of tile enterprise also corruptly solicited Georgia officials, including tile Secretary of State and tile Speaker of the House of Representatives, to violate tlleir 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 recrnited 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 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.
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 effect the objectives of the enterprise, including but not limited to:
On or about the 4th 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 l, 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 Individu_al 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.
On or about the 19th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI, JENNA LYNN ELLIS, SIDNEY KATHERINE 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 J, 2020, presidential election in Georgia and elsewhere. These were overt acts in furtherance of the conspiracy.
On or about the 20th day of November 2020, DAVID JAMES SHAFER sent an e-mail to unindicted co-conspirator Individual 4, whose identity is known to the Grand Jury, and other individuals. In the e-mail, DAVID JAMES SHAFER stated that SCOTT GRAHAM HALL, a Georgia bail bondsman, “has been looking into the election on behalf of the President at the request of David Bossie” and asked unindicted co-conspirator Individual 4 to exchange contact information with SCOTT GRAHAM HALL and to”help him as needed.” This was an overt act in furtherance of the conspiracy.
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 Shirkey, 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.
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, “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.
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, “I would not break my oath.” The false statements and solicitations were overt acts in furtherance of the conspiracy.
On or about the 25th day of November 2020, RUDOLPH WILLIAM LOUIS 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, 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.
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, RUDO3100 block of W. Flournoy on Aug. 15, 2023 at approx. 4:25 a.m. (11th District) Accidental Discharge, Death Investigation, Person Shot15-AUG-2023 08:00 AM
The victim, an 8-year-old male, was inside a residence with another male juvenile when they located a firearm. The weapon discharged one time, striking the victim in the chest. Officers transported the victim to Mt. Sinai Hospital, where he was later pronounced. No other injuries were reported. The weapon was recovered on scene. Area Four detectives are investigatingLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS placed a telephone call to Speaker of the Pennsylvania House of Representatives Bryan 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.
