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.
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 ofthe enterprise, including several ofthe 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 unlawfillly 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 unlawfillly appoint their own presidential electors.
2. False Statements to and Solicitation of HighRanking State Officials.Members ofthe enterprise, including several ofthe Defendants, made false statements in Fulton County and elsewhere in the State of Georgia to Georgia officials, including the Governor, the Secretary cf 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 ofthe enterprise, including several ofthe 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.
5. Solicitation of High-Ranking United States Department of Justice Officials
Members ofthe enterprise, including several ofthe 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. unlawfiilly rejecting Electoral College votes cast in Fulton County, Georgia, by the duly elected and qualified presidential electors fiom Georgia. Members of the enterprise also corruptly solicited the Vice President to reject votes cast by the duly elected and qualified presidential electors fiom several other states.
8. Obstructive Acts in Furtherance of the Conspiracy and the Cover Up. Members ofthe enterprise, including several ofthe 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.
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 3', 2020, presidential election in Georgia and elsewhere. These were overt acts in furtherance of the conspiracy.
Act 8. 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 fiaud 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 our the conspiracy.
21
Act 9. On or about the 25th day of November 2020, immediately after the meeting of. Pennsylvania legislators in Gettysburg, Pennsylvania, where RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses, DONALD JOHN TRUMP invited a group of the Pennsylvania legislators and others to meet with him at the White House. Later that day, DONALD JOHN TRUMP, MARK RANDALL MEADOWS, RUDOLPH WILLIAM LOUIS GIULIANI, JENNA LYNN ELLIS and unindicted co-conspirators Individual 5 and Individual 6, whose identities are known to the Grand Jury, met with the group of Pennsylvania legislators at the White House and discussed holding a special session of the Pennsylvania General Assembly. These were overt acts in flirtherance ofthe conspiracy.
Act 10. On or about the 26th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS placed a telephone call to Speaker of the Pennsylvania House of Representatives 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.
Act 12. On or about the 27th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS placed a telephone call to President Pro Tempore of the Pennsylvania Senate Jake Corman for the purpose of soliciting, requesting, and importuning Corman to unlawfiilly appoint presidential electors from Pennsylvania. This was an overt act in turtherance ofthe conspiracy.
Act 17. '1 On or about the 30th day of November 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses at a meeting of Arizona legislators in Phoenix, Arizona. Unindicted co-conspirators Individual 5 and Individual 6, whose identities are known to the Grand Jury, were also present. During the meeting, RUDOLPH WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3, 2020, presidential election in Arizona and solicited, requested, and importuned the Arizona legislators present at the meeting to unlawfully appoint presidential electors from Arizona. During the meeting, JENNA LYNN ELLIS solicited, requested, and importuned the Arizona legislators present at the meeting to unlawfully appoint presidential electors from Arizona.These were overt acts in furtherance of the conspiracy.
Act 20. On or about the 1st day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS met with Speaker of the Arizona House of Representatives Rusty Bowers, President of the Arizona Senate Karen Fann, and other Arizona legislators in Phoenix, Arizona. Unindicted co-conspirator Individual 5, whose identity is known to the Grand Jury, was also present. During the meeting, RUDOLPH WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3, 2020, presidential election in Arizona and solicited, requested, and importuned the legislators present to call a special session of the Arizona State Legislature. These were overt acts in furtherance of the conspiracy.
Act 21. On or about the 2nd day of December 2020, RUDOLPH WILLIAM LOUIS GIULIANI and JENNA LYNN ELLIS appeared, spoke, and presented witnesses at a meeting of the Michigan House of Representatives Oversight Committee. During the meeting, RUDOLPH WILLIAM LOUIS GIULIANI made false statements concerning fraud in the November 3, 2020, presidential election in Michigan and solicited, requested, and importuned the Michigan legislators present at the meeting to unlawfully appoint presidential electors from Michigan. During the meeting, JENNA LYNN ELLIS solicited, requested, and importuned the Michigan legislators present at the meeting to unlawfully appoint presidential electors from Michigan. These were overt'acts in fiirtherance of the conspiracy.