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superseding_indictment_-_24-06-2020 [2020/06/25 11:51] – editor42 | superseding_indictment_-_24-06-2020 [2020/06/28 09:36] – [E. Sabu, Hammond, and ASSANGE] editor42 | ||
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- | < | + | < |
It has been converted to text from {{ : | It has been converted to text from {{ : | ||
+ | <WRAP centerl round tip> | ||
+ | Redacted names in the indictment: | ||
+ | * WLA-2 = Daniel Domscheit-Berg | ||
+ | * WLA-3 = Jacob Appelbaum | ||
+ | * WLA-4 = Sarah Harrison | ||
+ | * " | ||
+ | </ | ||
FILED IN OPEN COURT ON JUN. 24 2020 CLERK U.S. DISTRICT COURT ALEXANDRIA, VIRGINIA | FILED IN OPEN COURT ON JUN. 24 2020 CLERK U.S. DISTRICT COURT ALEXANDRIA, VIRGINIA | ||
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information nondisclosure agreement, acknowledging that the unauthorized disclosure or | information nondisclosure agreement, acknowledging that the unauthorized disclosure or | ||
retention or negligent handling of classified information could cause irreparable injury to the | retention or negligent handling of classified information could cause irreparable injury to the | ||
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United States or be used to the advantage of a foreign nation. | United States or be used to the advantage of a foreign nation. | ||
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====ii, Manning Steals and Provides to WikiLeaks Classified Information about Iraq, Afghanistan, | ====ii, Manning Steals and Provides to WikiLeaks Classified Information about Iraq, Afghanistan, | ||
- | 13. Between January 2010 and May 201 0, consistent with WikiLeaks’s “Most Wanted | + | 13. Between January 2010 and May 2010, consistent with WikiLeaks’s “Most Wanted |
Leaks” solicitation of bulk databases and military and intelligence categories, Manning | Leaks” solicitation of bulk databases and military and intelligence categories, Manning | ||
downloaded four nearly complete databases from departments and agencies of the United States, | downloaded four nearly complete databases from departments and agencies of the United States, | ||
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14. No later than January 2010, Manning repeatedly used an online chat service, | 14. No later than January 2010, Manning repeatedly used an online chat service, | ||
- | Jabber.ccc.de, | + | Jabber.ccc.de, |
+ | . | ||
15. On March 7, 2010, Manning asked ASSANGE how valuable the Guantanamo Bay | 15. On March 7, 2010, Manning asked ASSANGE how valuable the Guantanamo Bay | ||
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16, On March 8, 2010, when Manning brought up the “osc,” meaning the CIA Open | 16, On March 8, 2010, when Manning brought up the “osc,” meaning the CIA Open | ||
- | Source Center, | + | Source Center, |
consistent with WikiLeaks’s list of “Most Wanted Leaks,” which solicited “the complete CIA | consistent with WikiLeaks’s list of “Most Wanted Leaks,” which solicited “the complete CIA | ||
Open Source Center analytical database, | Open Source Center analytical database, | ||
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18. On March 8, 2010, in response to Manning’s comment that, after transmitting the | 18. On March 8, 2010, in response to Manning’s comment that, after transmitting the | ||
detainee assessment briefs to ASSANGE and WikiLeaks, “thats all I really have got left,” and to | detainee assessment briefs to ASSANGE and WikiLeaks, “thats all I really have got left,” and to | ||
- | 2 The Grand Jury will allege that the person using these monikers is ASSANGE without | ||
- | reference to the specific moniker used. | ||
encourage Manning to continue to steal classified documents from the United States and provide | encourage Manning to continue to steal classified documents from the United States and provide | ||
them to WikiLeaks, ASSANGE replied, “curious eyes never run dry in my experience.” | them to WikiLeaks, ASSANGE replied, “curious eyes never run dry in my experience.” | ||
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said that WikiLeaks had “never lost a source,” told the audience that it should reject the thought | said that WikiLeaks had “never lost a source,” told the audience that it should reject the thought | ||
that someone else was more qualified than them to determine whether a document should be kept | that someone else was more qualified than them to determine whether a document should be kept | ||
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secret, and urged attendees to assist WikiLeaks and emulate others who had broken the law to | secret, and urged attendees to assist WikiLeaks and emulate others who had broken the law to | ||
disseminate classified information. WLA-3 ended his request for assistance with the slogan, | disseminate classified information. WLA-3 ended his request for assistance with the slogan, | ||
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35. In early 2010, around the same time that ASSANGE was working with Manning | 35. In early 2010, around the same time that ASSANGE was working with Manning | ||
- | to obtain classified information, | + | to obtain classified information, |
who provided ASSANGE with data stolen from a bank. | who provided ASSANGE with data stolen from a bank. | ||
36. In early 2010, ASSANGE asked Teenager to commit computer intrusions and steal | 36. In early 2010, ASSANGE asked Teenager to commit computer intrusions and steal | ||
additional information, | additional information, | ||
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officials of the government of NATO Country-1, including members of the Parliament of NATO | officials of the government of NATO Country-1, including members of the Parliament of NATO | ||
Country-1. | Country-1. | ||
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vehicles (provided to ASSANGE by a source) to determine that NATO Country-1 police were | vehicles (provided to ASSANGE by a source) to determine that NATO Country-1 police were | ||
monitoring ASSANGE. | monitoring ASSANGE. | ||
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43, On March 29, 2010, WikiLeaks posted to its website classified State Department | 43, On March 29, 2010, WikiLeaks posted to its website classified State Department | ||
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PayPal, Visa, and MasterCard in retaliation for their decisions to stop processing payments for | PayPal, Visa, and MasterCard in retaliation for their decisions to stop processing payments for | ||
WikiLeaks. Anonymous called these attacks “Operation Payback.” | WikiLeaks. Anonymous called these attacks “Operation Payback.” | ||
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48. Later in December 2010, “Laurelai, | 48. Later in December 2010, “Laurelai, | ||
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about Kayla’s penetration of a hosting service, so that WikiLeaks could determine if WikiLeaks | about Kayla’s penetration of a hosting service, so that WikiLeaks could determine if WikiLeaks | ||
needed information hosted there. | needed information hosted there. | ||
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55. On February 17, 2011, Teenager told Laurelai that WikiLeaks was the world’s | 55. On February 17, 2011, Teenager told Laurelai that WikiLeaks was the world’s | ||
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58. On March 15, 2011, Laurelai emailed WikiLeaks (through Teenager) a list of | 58. On March 15, 2011, Laurelai emailed WikiLeaks (through Teenager) a list of | ||
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approximately 200 purported passwords to U.S. and state government email accounts, including | approximately 200 purported passwords to U.S. and state government email accounts, including | ||
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passwords (hashed and plaintext) that purported to be for accounts associated with information | passwords (hashed and plaintext) that purported to be for accounts associated with information | ||
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technology specialists at government institutions. | technology specialists at government institutions. | ||
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66. — Inthe fall of 2011, Teenager left WikiLeaks. | 66. — Inthe fall of 2011, Teenager left WikiLeaks. | ||
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=====E. Sabu, Hammond, and ASSANGE===== | =====E. Sabu, Hammond, and ASSANGE===== | ||
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consulting company (“Intelligence Consulting Company”’). | consulting company (“Intelligence Consulting Company”’). | ||
68. On December 29, 2011, in a chat with other hackers on an IRC channel called | 68. On December 29, 2011, in a chat with other hackers on an IRC channel called | ||
- | “#1 ulzxmas,” a hacker affiliated with LulzSec/ | + | “#lulzxmas,” a hacker affiliated with LulzSec/ |
information hacked from Intelligence Consulting Company was being sent to Wikileaks. | information hacked from Intelligence Consulting Company was being sent to Wikileaks. | ||
- | — 69. On December 29, 2011, in a chat with other hackers on the “# | + | 69. On December 29, 2011, in a chat with other hackers on the “# |
channel, Hammond informed elChe and others in the group, “JA almost done copying the files.” | channel, Hammond informed elChe and others in the group, “JA almost done copying the files.” | ||
Hammond also told elChe that there should be “no leaks about this partnering.” | Hammond also told elChe that there should be “no leaks about this partnering.” | ||
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71. On December 31, 2011, WikiLeaks tweeted “ffantisec owning Law enforcement | 71. On December 31, 2011, WikiLeaks tweeted “ffantisec owning Law enforcement | ||
in 2012,” as well as links to emails and databases that Hammond and AntiSec had obtained from | in 2012,” as well as links to emails and databases that Hammond and AntiSec had obtained from | ||
- | hacking two U.S. state police associations. On j anuary | + | hacking two U.S. state police associations. On january |
information that LulzSec/ | information that LulzSec/ | ||
| «Anonymous/ | | «Anonymous/ | ||
to a spoofed email sent by Hammond to the clients of Intelligence Consulting Company, | to a spoofed email sent by Hammond to the clients of Intelligence Consulting Company, | ||
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purporting to be the CEO of that company, stating, “AnonymousIRC email sent by #AntiSec to | purporting to be the CEO of that company, stating, “AnonymousIRC email sent by #AntiSec to | ||
[Intelligence Consulting Company]’s customers #Anonymous # | [Intelligence Consulting Company]’s customers #Anonymous # | ||
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January and February 2012, Sabu used Jabber to chat with this WikiLeaks leader, who used | January and February 2012, Sabu used Jabber to chat with this WikiLeaks leader, who used | ||
various monikers on Jabber.ccc.de that are attributed to ASSANGE for reasons including but not | various monikers on Jabber.ccc.de that are attributed to ASSANGE for reasons including but not | ||
- | limited to the following”: | + | limited to the following |
+ | ((3) For the remainder of the Second Superseding Indictment, the Grand Jury will alle ge that | ||
+ | the person using these monikers is ASSANGE without reference to the specific moniker used.)): | ||
a. When Sabu suggested that it had to be “boring” to stay at Ellingham Hall “every | a. When Sabu suggested that it had to be “boring” to stay at Ellingham Hall “every | ||
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could survive prosecution and prison without talking to law enforcement. | could survive prosecution and prison without talking to law enforcement. | ||
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- | 3 For the remainder of the Second Superseding Indictment, the Grand Jury will alle ge that | ||
- | the person using these monikers is ASSANGE without reference to the specific moniker used. | ||
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b. On January 16, 2012, Sabu asked ASSANGE how “the case [was] going.” In | b. On January 16, 2012, Sabu asked ASSANGE how “the case [was] going.” In | ||
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Hezbollah, representatives of the Occupy Movement, and an individual who claimed to be a | Hezbollah, representatives of the Occupy Movement, and an individual who claimed to be a | ||
former Guantanamo Bay prisoner who ran the website cageprisoners.org in 2012. | former Guantanamo Bay prisoner who ran the website cageprisoners.org in 2012. | ||
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75. On February 21, 2012, and in response to Sabu’s request, ASSANGE provided | 75. On February 21, 2012, and in response to Sabu’s request, ASSANGE provided | ||
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others hacked from Intelligence Consulting Company. | others hacked from Intelligence Consulting Company. | ||
- | 79, On F ebruary | + | 79. On February |
had been. obtained from other hacks. | had been. obtained from other hacks. | ||
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82. In March 2012, Hammond was arrested. | 82. In March 2012, Hammond was arrested. | ||
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- | SRO | ||
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=====F. ASSANGE’s Efforts to Recruit System Administrators===== | =====F. ASSANGE’s Efforts to Recruit System Administrators===== | ||
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exhorted the audience to join the CIA in order to steal and provide information to WikiLeaks, | exhorted the audience to join the CIA in order to steal and provide information to WikiLeaks, | ||
stating, “I’m not saying don’t join the CIA; no, go and join the CIA. Go in there, go into the | stating, “I’m not saying don’t join the CIA; no, go and join the CIA. Go in there, go into the | ||
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ballpark and get the ball and bring it out.” | ballpark and get the ball and bring it out.” | ||
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87, At the same presentation, | 87, At the same presentation, | ||
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Leaks” list from 2009 list that remained on WikiLeaks’s website. | Leaks” list from 2009 list that remained on WikiLeaks’s website. | ||
- | 90. Inaninterview | + | 90. In an interview |
operations to assist Snowden in avoiding arrest by the United States: | operations to assist Snowden in avoiding arrest by the United States: | ||
- | Let’s go back to 2013. There was a worldwide manhunt for Edward Snowden . . | + | "Let’s go back to 2013. There was a worldwide manhunt for Edward Snowden . . |
- | " | + | vast resources were put into trying to grab Edward Snowden or work out where |
he might go, if he was leaving Hong Kong, and grab him there. | he might go, if he was leaving Hong Kong, and grab him there. | ||
So we worked against that, and we got him out of Hong Kong and got him to | So we worked against that, and we got him out of Hong Kong and got him to | ||
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alternatives? | alternatives? | ||
routes for commercial jets, and presidential jets. ... | routes for commercial jets, and presidential jets. ... | ||
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There was an oil conference on in—-there was an international oil conference in | There was an oil conference on in—-there was an international oil conference in | ||
Moscow that week. Edward Snowden and our journalist, [WLA-4], still mm the | Moscow that week. Edward Snowden and our journalist, [WLA-4], still mm the | ||
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website the documents classified up to the SECRET level that he had obtained from Manning, | website the documents classified up to the SECRET level that he had obtained from Manning, | ||
as described above, including approximately 75,000 Afghanistan war-related significant activity | as described above, including approximately 75,000 Afghanistan war-related significant activity | ||
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reports, 400,000 Iraq war-related significant activity reports, 800 Guantanamo Bay detainee | reports, 400,000 Iraq war-related significant activity reports, 800 Guantanamo Bay detainee | ||
assessment briefs, and 250,000 U.S. Department of State cables. | assessment briefs, and 250,000 U.S. Department of State cables. | ||
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we don’t say that it is absolutely impossible that anything we ever publish will ever-result in | we don’t say that it is absolutely impossible that anything we ever publish will ever-result in | ||
harm—we cannot say that.” | harm—we cannot say that.” | ||
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96. On May 2, 2011, United States armed forces raided the compound of Osama bin | 96. On May 2, 2011, United States armed forces raided the compound of Osama bin | ||
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c. Classified Document D1 was a 2009 report discussing an improvised explosive | c. Classified Document D1 was a 2009 report discussing an improvised explosive | ||
device (“IED”) attack in Iraq. Classified Document D1 named local human | device (“IED”) attack in Iraq. Classified Document D1 named local human | ||
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- | 98. | ||
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sources who provided information on the attack. Classified Document D1 was | sources who provided information on the attack. Classified Document D1 was | ||
classified at the SECRET level. | classified at the SECRET level. | ||
- | Classified Document D2 was a 2008 report that named a local person in Iraq who | + | d. Classified Document D2 was a 2008 report that named a local person in Iraq who |
had turned in weapons to coalition forces and had been threatened afterward. | had turned in weapons to coalition forces and had been threatened afterward. | ||
Classified Document D2 was classified at the SECRET level. | Classified Document D2 was classified at the SECRET level. | ||
- | The following are examples of State Department cables that ASSANGE | + | 98. The following are examples of State Department cables that ASSANGE |
disseminated and published without redacting the names of human sources who were vulnerable | disseminated and published without redacting the names of human sources who were vulnerable | ||
to retribution. | to retribution. | ||
- | Classified Document Al was a 2009 State Department cable discussing a political | + | a. Classified Document Al was a 2009 State Department cable discussing a political |
situation in Iran. Classified Document Al named-a human source of information | situation in Iran. Classified Document Al named-a human source of information | ||
located in Iran and indicated that the source’s identity needed to be protected. | located in Iran and indicated that the source’s identity needed to be protected. | ||
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Classified Document A1 was classified at the SECRET level. | Classified Document A1 was classified at the SECRET level. | ||
- | Classified Document A2 was a 2009 State Department cable discussing political | + | b. Classified Document A2 was a 2009 State Department cable discussing political |
dynamics in Iran. Classified Document A2 named a human source of information | dynamics in Iran. Classified Document A2 named a human source of information | ||
who regularly traveled to Iran and indicated that the source’s identity needed to be | who regularly traveled to Iran and indicated that the source’s identity needed to be | ||
protected. Classified Document A2 was classified at the SECRET level. | protected. Classified Document A2 was classified at the SECRET level. | ||
- | Classified Document A3 was a 2009 State Department cable discussing issues | + | |
+ | c. Classified Document A3 was a 2009 State Department cable discussing issues | ||
related to ethnic conflict in China. Classified Document A3 named a human | related to ethnic conflict in China. Classified Document A3 named a human | ||
source of information located in China and indicated that the source’s identity | source of information located in China and indicated that the source’s identity | ||
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level. | level. | ||
- | Classified Document A4-was a 2009 State Department cable discussing relations | + | d. Classified Document A4-was a 2009 State Department cable discussing relations |
between Iran and Syria. Classified Document A4 named human sources of | between Iran and Syria. Classified Document A4 named human sources of | ||
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information located in Syria and indicated that the sources’ identities needed to be | information located in Syria and indicated that the sources’ identities needed to be | ||
protected. Classified Document A4 was classified at the SECRET level. | protected. Classified Document A4 was classified at the SECRET level. | ||
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protected. Classified Document A5 was classified at the SECRET level. | protected. Classified Document A5 was classified at the SECRET level. | ||
- | 99, ASSANGE knew that his dissemination and publication of Afghanistan and Iraq | + | 99. ASSANGE knew that his dissemination and publication of Afghanistan and Iraq |
war-related significant activity reports endangered sources, whom he named as having provided | war-related significant activity reports endangered sources, whom he named as having provided | ||
information to U.S. and coalition forces. | information to U.S. and coalition forces. | ||
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his dissemination and publication of the unredacted State Department cables, ASSANGE claimed | his dissemination and publication of the unredacted State Department cables, ASSANGE claimed | ||
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that he intended “to gradually roll [the cables] out in a safe way” by partnering with mainstream | that he intended “to gradually roll [the cables] out in a safe way” by partnering with mainstream | ||
media outlets and “read[ing] through every single cable and redact[ing] identities accordingly.” | media outlets and “read[ing] through every single cable and redact[ing] identities accordingly.” | ||
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States security clearance or otherwise have authorization to receive, possess, or communicate | States security clearance or otherwise have authorization to receive, possess, or communicate | ||
classified information. | classified information. | ||
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===== COUNT 1 (Conspiracy to Obtain and Disclose National Defense Information)===== | ===== COUNT 1 (Conspiracy to Obtain and Disclose National Defense Information)===== | ||
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the national defense, and knowing and with reason to believe at the time such materials | the national defense, and knowing and with reason to believe at the time such materials | ||
were received and obtained, they had been and would be taken, obtained, and disposed of | were received and obtained, they had been and would be taken, obtained, and disposed of | ||
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by a person contrary to the provisions of Chapter 37 of Title 18 of the United States Code, | by a person contrary to the provisions of Chapter 37 of Title 18 of the United States Code, | ||
in violation of Title 18, United States Code, Section 793(c); | in violation of Title 18, United States Code, Section 793(c); | ||
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(All in violation of Title 18, United States Code, Section 793(g)) | (All in violation of Title 18, United States Code, Section 793(g)) | ||
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=====COUNT 2 (Conspiracy To Commit Computer Intrusions)===== | =====COUNT 2 (Conspiracy To Commit Computer Intrusions)===== | ||
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States and from protected computers; committed in furtherance of criminal and tortious acts | States and from protected computers; committed in furtherance of criminal and tortious acts | ||
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in violation of the laws of the United States and of any State, and to obtain information that | in violation of the laws of the United States and of any State, and to obtain information that | ||
exceeded $5,000 in value, in violation of 18 U.S.C. §§ 1030(a)(2) and 1030(c)(2)(B); | exceeded $5,000 in value, in violation of 18 U.S.C. §§ 1030(a)(2) and 1030(c)(2)(B); | ||
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C. In furtherance of the conspiracy, and to accomplish its objects, ASSANGE and his | C. In furtherance of the conspiracy, and to accomplish its objects, ASSANGE and his | ||
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conspirators committed lawful and unlawful overt acts, including but not limited to, those | conspirators committed lawful and unlawful overt acts, including but not limited to, those | ||
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described in the General Allegations Section of this Indictment. | described in the General Allegations Section of this Indictment. | ||
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(All in violation of Title 18, United States Code, Sections 371) | (All in violation of Title 18, United States Code, Sections 371) | ||
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=====COUNT 3 (Unauthorized Obtaining of National Defense Information) (State Department Cables)===== | =====COUNT 3 (Unauthorized Obtaining of National Defense Information) (State Department Cables)===== | ||
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(All in violation of Title 18, United States Code, Sections 793(b) and 2) | (All in violation of Title 18, United States Code, Sections 793(b) and 2) | ||
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=====COUNT 4 (Unauthorized Obtaining of National Defense Information) (Iraq Rules of Engagement Files)===== | =====COUNT 4 (Unauthorized Obtaining of National Defense Information) (Iraq Rules of Engagement Files)===== | ||
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(All in violation of Title 18, United States Code, Sections 793(b) and 2) | (All in violation of Title 18, United States Code, Sections 793(b) and 2) | ||
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=====COUNT 5 (Attempted Unauthorized Obtaining and Receiving of National Defense Information)===== | =====COUNT 5 (Attempted Unauthorized Obtaining and Receiving of National Defense Information)===== | ||
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(All in violation of Title 18, United States Code, Sections 793(c) and 2) | (All in violation of Title 18, United States Code, Sections 793(c) and 2) | ||
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(All in violation of Title 18, United States Code, Sections 793(c) and 2) | (All in violation of Title 18, United States Code, Sections 793(c) and 2) | ||
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connected with the national defense—namely, | connected with the national defense—namely, | ||
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the SECRET level—for the purpose of obtaining information respecting the national defense, | the SECRET level—for the purpose of obtaining information respecting the national defense, | ||
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knowing and having reason to believe, at the time that he received and obtained them, that such | knowing and having reason to believe, at the time that he received and obtained them, that such | ||
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materials had been and would be obtained, taken, made, and disposed of by a person contrary to | materials had been and would be obtained, taken, made, and disposed of by a person contrary to | ||
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the provisions of Chapter 37 of Title 18 of the United States Code. | the provisions of Chapter 37 of Title 18 of the United States Code. | ||
(All in violation of Title 18, United States Code, Sections 793(c) and 2) | (All in violation of Title 18, United States Code, Sections 793(c) and 2) | ||
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States, the defendant, JULIAN PAUL ASSANGE, who will be first brought to the Eastern District | States, the defendant, JULIAN PAUL ASSANGE, who will be first brought to the Eastern District | ||
of Virginia, knowingly and unlawfully recerved and obtained documents, writings, and notes | of Virginia, knowingly and unlawfully recerved and obtained documents, writings, and notes | ||
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connected with the national defense—namely, | connected with the national defense—namely, | ||
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SECRET level—for the purpose of obtaining information respecting the national defense, | SECRET level—for the purpose of obtaining information respecting the national defense, | ||
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knowing and having reason to believe, at the time that he received and obtained them, that such | | knowing and having reason to believe, at the time that he received and obtained them, that such | | ||
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materials had been and would be obtained, taken, made, and disposed of by a person contrary to | materials had been and would be obtained, taken, made, and disposed of by a person contrary to | ||
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the provisions of Chapter 37 of Title 18 of the United States Code. | the provisions of Chapter 37 of Title 18 of the United States Code. | ||
(All in violation of Title 18, United States Code, Sections 793(c) and 2) | (All in violation of Title 18, United States Code, Sections 793(c) and 2) | ||
- | 37 | ||
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Line 1253: | Line 1057: | ||
(All in violation of Title 18, United States Code, Sections 793(d) and 2) | (All in violation of Title 18, United States Code, Sections 793(d) and 2) | ||
- | 38 | ||
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=====COUNT 10 (Unauthorized Disclosure of National Defense Information) (State Department Cables)===== | =====COUNT 10 (Unauthorized Disclosure of National Defense Information) (State Department Cables)===== | ||
Line 1274: | Line 1075: | ||
(All in violation of Title 18, United States Code, Sections 793(d) and 2) | (All in violation of Title 18, United States Code, Sections 793(d) and 2) | ||
- | 39 | ||
Line 1302: | Line 1102: | ||
(All in violation of Title 18, United States Code, Sections 793(d) and 2) | (All in violation of Title 18, United States Code, Sections 793(d) and 2) | ||
- | 40 | ||
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=====COUNT 12 (Unauthorized Disclosure of National Defense Information) (Detainee Assessment Briefs)===== | =====COUNT 12 (Unauthorized Disclosure of National Defense Information) (Detainee Assessment Briefs)===== | ||
Line 1316: | Line 1114: | ||
of Virginia, and others unknown to the Grand Jury, aided, abetted, counseled, induced, procured | of Virginia, and others unknown to the Grand Jury, aided, abetted, counseled, induced, procured | ||
and willfully caused Manning, who had unauthorized possession of, access to, and control over | and willfully caused Manning, who had unauthorized possession of, access to, and control over | ||
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documents relating to the national defense—namely, | documents relating to the national defense—namely, | ||
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the SECRET level related to detainees -who were held at Guantanamo Bay—to communicate, | the SECRET level related to detainees -who were held at Guantanamo Bay—to communicate, | ||
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deliver, and transmit the documents to ASSANGE, a person not entitled to receive them. | deliver, and transmit the documents to ASSANGE, a person not entitled to receive them. | ||
Line 1333: | Line 1126: | ||
(All in violation of Title 18, United States Code, Sections 793(e) and 2) : | | (All in violation of Title 18, United States Code, Sections 793(e) and 2) : | | ||
- | 41 | ||
=====COUNT 13 (Unauthorized Disclosure of National Defense Information) (State Department Cables)===== | =====COUNT 13 (Unauthorized Disclosure of National Defense Information) (State Department Cables)===== | ||
Line 1352: | Line 1144: | ||
(All in violation of Title 18, United States Code, Sections 793(e) and 2) | (All in violation of Title 18, United States Code, Sections 793(e) and 2) | ||
- | 42 | ||
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Line 1374: | Line 1163: | ||
- | |||
(All in violation of Title 18, United States Code, Sections 793(e) and 2) | (All in violation of Title 18, United States Code, Sections 793(e) and 2) | ||
- | 43 | ||
Line 1405: | Line 1192: | ||
(All in violation of Title 18, United States Code, Section 793(e)) | (All in violation of Title 18, United States Code, Section 793(e)) | ||
- | 44 | ||
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=====COUNT 16 (Unauthorized Disclosure of National Defense Information)===== | =====COUNT 16 (Unauthorized Disclosure of National Defense Information)===== | ||
Line 1432: | Line 1217: | ||
(All in violation of Title 18, United States Code, Section 793(e)) | (All in violation of Title 18, United States Code, Section 793(e)) | ||
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- | 45 | ||
Line 1459: | Line 1242: | ||
(All in violation of Title 18, United States Code, Section 793(e)) | (All in violation of Title 18, United States Code, Section 793(e)) | ||
- | 46 | ||
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Line 1483: | Line 1264: | ||
(All in violation of Title 18, United States Code, Sections 793(b) and 2) | (All in violation of Title 18, United States Code, Sections 793(b) and 2) | ||
- | 47 | ||
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Line 1531: | Line 1310: | ||
U.S. Department of Justice | U.S. Department of Justice | ||
- | 48 | ||