This is a plain text version of the 06 March 2018 Indictment.

It has been converted to text from PDF using OCR software, so it DOES contain transcription mistakes (lots of “?” or what otherwise looks like typos). Please help correct.

IN THE UNITED STATES DISTRICT COURT FOR THE

FILED EASTERN DISTRICT or VIRGINIA Alexandria Division 3% 5 ZUIB

UNITED STATES OF AMERICA (QEDER SEAL)

v. Criminal No. 1:18cr I ll JULIAN PAUL ASSANGE, Count 1: Conspiracy to Commit Computer Intrusion (18 U.S.C. 371, Defendant. 1030(a)(1), 1030(a)(2), 1030(C)(2)(B)(ii))

March 2018 Term at Alexandria- Virginia

THE GRAND JURY CHARGES THAT:

At times material to this Indictment:

1. Chelsea Manning, formerly known as Bradley Manning, was an intelligence analyst in the United States Anny, who was deployed to Forward Operating Base Hammer in Iraq.

2. Manning held a “Top Secret” security clearance, and signed a classified information nondisclosure agreement, acknowledging that the unauthorized disclosure or retention or negligent handling of classi?ed information could cause irreparable injury to the United States or be used to the advantage of a foreign nation.

3. Executive Order No. 13526 and its predecessor orders de?ne the classi?cation levels assigned to classi?ed information. Under the Executive Order, information may be

classi?ed as ?Secret? if its unauthorized disclosure reasonably could be expected to cause serious

..

hi.- 93;.

damage to the national security. Further, under the Executive Order, classi?ed information can generally only be disclosed to those persons who have been granted an appropriate level of United

States government security clearance and possess a need to know the classi?ed infonnation in

connection to their of?cial duties.

4. Julian Paul Assange was the founder and leader of the WikiLeaks website. The WildLeaks Website publicly solicited submissions of classi?ed, censored, and other restricted information.

5. Assange, who did not possess a security clearance or need to know, was not authorized to receive classi?ed information of the United States.

6. Between in or around January 2010 and May 2010, Manning downloaded four, nearly complete databases from departments and agencies of the United States. These databases contained approximately 90,000 Afghanistan war?related signi?cant activity reports, 400,000 Iraq war-related signi?cant activities reports, 800 Guantanamo Bay detainee assessment briefs, and 250,000 US. Department of State cables. Many of these records were classi?ed pursuant to Executive Order No. 13526 or its predecessor orders. Manning provided the records to agents of WildLeaks so that WikiLeaks could publicly disclose them on its website. WikiLeaks publicly released the vast majority of the classi?ed records on its website in 2010 and 2011.

7. On or about March 8, 2010, Assange agreed to assist Manning in cracking a password stored on United States Department of Defense computers connected to the Secret Internet Protocol Network, a United States government network used for classi?ed documents and communications, as designated according to Executive Order No. 13526 or its predecessor orders.

8. Manning, who had access to the computers in connection with her duties as an

intelligence analyst, was also using the computers to download classi?ed records to transmit to

WikiLeaks. Army regulations prohibited Manning from attempting to bypass or circumvent security mechanisms on Government-provided information systems and from sharing personal accounts and authenticators, such as passwords.

9. The portion of the password Manning gave to Assange to crack was stored as a ?hash value? in a computer ?le that was accessible only by users with administrative?level privileges. Manning did not have administrative-level privileges, and used special software, namely a Linux operating system, to access the computer ?le and obtain the portion of the password provided to Assange.

10. Cracking the password would have allowed Manning to log onto the computers under a username that did not belong to her. Such a measure would have made it more dif?cult for investigators to identify Manning as the source of disclosures of classi?ed information.

11. Prior to the formation of the password-cracking agreement, Manning had already provided WikiLeaks with hundreds of thousands of classi?ed records that she downloaded from departments and agencies of the United States, including the Afghanistan war-related signi?cant activity reports and Iraq war-related signi?cant activities reports.

12. At the time he entered into this agreement, Assange knew that Manning was providing WikiLealcs with classi?ed records containing national defense information ofthe United States. Assange was knowingly receiving such classi?ed records from Manning for the purpose of publicly disclosing them on the WikiLeaks website.

13. For example, on March 7, 2010, Manning and Assange discussed the value of the Guantanamo Bay detainee assessment briefs, and on March 8, 2010, before entering the password crackinguagreement, Manning told Assange that she was ?throwing everything [she had] on JTF

GTMO at [Assange] now.? Manning also said ?after this upload, that?s all I really have got left.?

To which Assange replied, ?curious eyes never run dry in my experience.? Following this, between March 28, 2010, and April 9, 2010, Manning used a United States Department of Defense computer to download the US. Department of State cables that WikiLeaks later released publicly.

14. The general allegations set forth in paragraphs 1 through 13 are re-alleged and incorporated into this Count as though ?illy set forth herein. 15. Beginning on or about March 2, 2010, and continuing thereafter until on or about

March 10, 2010, the exact date being unknown to the Grand Jury, both dates being approximate and inclusive, in an offense begun and committed outside of the jurisdiction of any particular State or district of the United States, the defendant, JULIAN PAUL ASSANGE, who will be ?rst brought to the Eastern District of Virginia, did knowingly and intentionally combine, conspire, confederate and agree with other co-conspirators known and unknown to the Grand Jury to commit an offense against the United States, to wit:

(A) to knowingly access a computer, without authorization and exceeding authorized access, to obtain information that has been determined by the United States Government pursuant to an Executive order and statute to require protection against unauthorized disclosure for reasons of national defense and foreign relations, namely, documents relating to the national defense classi?ed up to the ?Secret? level, with reason to believe that such information so obtained could be used to the injury of the United States and the advantage of any foreign nation, and to willfully communicate, deliver, transmit, and cause to be communicated, delivered, or transmitted the same, to any person not entitled to receive it, and willfully retain the same and fail' to deliver it to the of?cer or employee

entitled to receive it; and

(B) to intentionally access a computer, without authorization and exceeding authorized access, to obtain information from a department and agency of the United States in ?mherance of a criminal act in violation of the laws of the United States, that is, a violation of Title 18, United States Code, Sections 641, 793©, and 793(e).

(In violation of Title 18, United States Code, Sections 371, 1030(a)(1), 1030(a)(2), 1 030©(2)(B)

16. The primary purpose of the consPiracy was to facilitate Manning?s acquisition and transmission of classi?ed information related to the national defense of the United States so that WikiLealcs could publicly disseminate the information on its website.

17. Assange and his co-conspirators used the following ways, manners and means, among others, to carry out this purpose: 18. It was part of the compiracy that Assange and Manning used the ?Jabber? online chat service to collaborate on the acquisition and dissemination of the classi?ed records, and to enter into the agreement to crack the password stored on United States Department of Defense

computers connected to the Secret Intemet Protocol Network.

19. It was part of the conspiracy that Assange and Manning took measures to conceal Manning as the source of the disclosure of classi?ed records to WikiLeaks, including by removing usernames from the disclosed information and deleting chat logs between Assange and Manning.

20. It was part of the conspiracy that Assange encouraged Manning to provide

information and records from departments and agencies of the United States.

21. It was part of the consPiracy that Assange and Manning used a special folder on a cloud drop box of WikiLeaks to transmit classi?ed records containing information related to the national defense of the United States.

22. In order to ?irther the goals and purposes of the conspiracy, Assange and his co- conspirators committed overt acts, including, but not limited to, the following:

23. On or about March 2, 2010, Manning copied a Linux operating system to a CD, to allow Manning to access a United States Department of Defense computer ?le that was accessible only to users with administrative?level privileges.

24. On or about March 8, 2010, Manning provided Assange with part of a password stored on United States Department of Defense computers connected to the Secret Internet Protocol Network.

25. On or about March 10, 2010, Assange requested more information from Manning related to the password. Assange indicated that he had been trying to crack the password by

stating that he had ?no luck so far.?

A TRUE BILL DATE

Tracy Doherty?McCormick Acting United States Attorney

. Wyatt

Thomas W. Trailer Assistant United States Attorneys

No.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA Alexandria Division

THE UNITED STATES OF WRICA vs.

JULIAN ASSANGE

ovum?.1

In violation of Title 18 U.S.C. 371, 1030(a)(1), 1030(a)(2), 1030©(2)(B)(ii)) Conspiracy to Commit Computer Intrusion

A true bill.

Foreman

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