COUNT ONE
(Conspiracy to Defraud the United States—18 U.S.C. § 371)
5. The allegations contained in paragraphs 1 through 4 of this Indictment are re-
alleged and fully incorporated here by reference.
The Conspiracy
6. From on or about November 14, 2020, through on or about January 20, 2021, in the
District of Columbia and elsewhere,
the Defendant, DONALD J . TRUMP,
did knowingly combine, conspire, confederate, and agree with co-conspirators, known and
unknown to the Grand Jury, to defraud the United States by using dishonesty, fraud, and deceit to
impair, obstruct, and defeat the lawful federal government function by which the results of the
presidential election are collected, counted, and certified by the federal government.
Purpose of the Conspiracy
7. The purpose of the conspiracy was to overturn the legitimate results of the 2020
presidential election by using knowingly false claims of election fraud to obstruct the federal
government function by which those results are collected, counted, and certified.
The Defendant's Co-Conspirators
8. The Defendant enlisted co-conspirators to assist him in his criminal efforts to
overturn the legitimate results of the 2020 presidential election and retain power. Among these
were:
a. Co-Conspirator 1, an attorney who was willing to spread knowingly false
claims and pursue strategies that the Defendant's 2020 re-election campaign
attorneys would not.
b. Co-Conspirator 2, an attorney who devised and attempted to implement a
strategy to leverage the Vice President's ceremonial role overseeing the
Case l:23-cr-00257-TSC Document 1 Filed 08/01/23 Page 4 of 45
certification proceeding to obstruct the certification of the presidential
election.
c. Co-Conspirator 3, an attorney whose unfounded claims of election fraud the
Defendant privately acknowledged to others sounded "crazy." Nonetheless,
the Defendant embraced and publicly amplified Co-Conspirator 3's
disinformation.
d. Co-Conspirator 4, a Justice Department official who worked on civil
matters and who, with the Defendant, attempted to use the Justice
Department to open sham election crime investigations and influence state
legislatures with knowingly false claims of election fraud.
e. Co-Conspirator 5, an attorney who assisted in devising and attempting to
implement a plan to submit fraudulent slates of presidential electors to
obstruct the certification proceeding.
f. Co-Conspirator 6, a political consultant who helped implement a plan to
submit fraudulent slates of presidential electors to obstruct the certification
proceeding.
