32. From at least as early as November 3, 2020, through January 6, 2021, in the District of Columbia and elsewhere, the defendants, THOMAS CALDWELL, DONOVAN CROWL, JESSICA WATKINS, SANDRA PARKER, BENNIE PARKER, GRAYDON YOUNG, LAURA STEELE, KELLY MEGGS, CONNIE MEGGS, KENNETH HARRELSON, ROBERTO MINUTA, JOSHUA JAMES, JOSEPH HACKETT, JASON DOLAN, and WILLIAM ISAACS, did knowingly combine, conspire, confederate, and agree with each other and others known and unknown, to commit an offense against the United States, namely, to corruptly obstruct, influence, and impede an official proceeding, that is, the Certification of the Electoral College vote, in violation of Title 18, United States Code, Section 1512(c)(2)
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Purpose of the Conspiracy
33. The purpose of the conspiracy was to stop, delay, and hinder the Certification of the Electoral College vote