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--- superseding_indictment_-_24-06-2020 [2020/06/25 11:51] – editor42
+++ superseding_indictment_-_24-06-2020 [2020/07/05 17:16] (current) – editor42
@@ Line 1: / Line 1: @@
-<WRAP center round important> This is a text version of the 24th June 2020 Superceding Indictment.
+{{ docs:superceding_indictment_p1.png?300|}}<WRAP centerl round important> This is a plain text version of the 24th June 2020 Superceding Indictment.
 It has been converted to text from {{ :06_24_20_returned_redacted_foreperson_name_0.pdf |}} using OCR software, so it DOES contain transcription mistakes ("i" and "1" and "l" used interchangeably, "5" and "S" etc.) . Please help correct.</WRAP>
+<WRAP centerl round tip>
+Redacted names in the indictment:
+  * WLA-2 = Daniel Domscheit-Berg
+  * WLA-3 = Jacob Appelbaum
+  * WLA-4 = Sarah Harrison
+  * "Teenager" = Sigurdur Thordarson
+  * "NATO Country-1" = Iceland
+</WRAP>
 FILED IN OPEN COURT ON  JUN. 24 2020 CLERK U.S. DISTRICT COURT ALEXANDRIA, VIRGINIA
@@ Line 51: / Line 59: @@
 =====A. ASSANGE and WikiLeaks=====
-cL. From at least 2007, JULIAN PAUL ASSANGE (“ASSANGE”): was the public
+. From at least 2007(( When the Grand Jury alleges in this Superseding Indictment that an event occurred on a
+particular date, the Grand Jury means to convey that the event occurred “on or about” that date.)), JULIAN PAUL ASSANGE (“ASSANGE”): was the public face of “WikiLeaks,” a website he founded with others as an “intelligence agency of the people.”
- When the Grand Jury alleges in this Superseding Indictment that an event occurred on a
-particular date, the Grand Jury means to convey that the event occurred “on or about” that date.
-face of “WikiLeaks,” a website he founded with others as an “intelligence agency of the people.”
 To obtain information to release on the WikiLeaks website, ASSANGE recruited sources and
 predicated the success of WikiLeaks in part upon the recruitment of sources to (4) illegally
@@ Line 139: / Line 144: @@
 information nondisclosure agreement, acknowledging that the unauthorized disclosure or
 retention or negligent handling of classified information could cause irreparable injury to the
 United States or be used to the advantage of a foreign nation.
@@ Line 165: / Line 169: @@
 ====ii, Manning Steals and Provides to WikiLeaks Classified Information about Iraq, Afghanistan, and Guantanamo Bay====
-. Between January 2010 and May 201 0, consistent with WikiLeaks’s “Most Wanted
+. Between January 2010 and May 2010, consistent with WikiLeaks’s “Most Wanted
 Leaks” solicitation of bulk databases and military and intelligence categories, Manning
 downloaded four nearly complete databases from departments and agencies of the United States,
@@ Line 176: / Line 180: @@
 . No later than January 2010, Manning repeatedly used an online chat service,
-Jabber.ccc.de, to chat with ASSANGE, who used multiple monikers attributable to him.”
+Jabber.ccc.de, to chat with ASSANGE, who used multiple monikers attributable to him(( The Grand Jury will allege that the person using these monikers is ASSANGE without reference to the specific moniker used.))
+.
 . On March 7, 2010, Manning asked ASSANGE how valuable the Guantanamo Bay
@@ Line 185: / Line 190: @@
 , On March 8, 2010, when Manning brought up the “osc,” meaning the CIA Open
-Source Center, AS SANGE replied, “that’s something we want to mine entirely, btw,” which was
+Source Center, ASSANGE replied, “that’s something we want to mine entirely, btw,” which was
 consistent with WikiLeaks’s list of “Most Wanted Leaks,” which solicited “the complete CIA
 Open Source Center analytical database,” an unclassified (but non-public) database.
@@ Line 195: / Line 200: @@
 . 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
-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
 them to WikiLeaks, ASSANGE replied, “curious eyes never run dry in my experience.”
@@ Line 278: / Line 281: @@
 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
 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,
@@ Line 306: / Line 308: @@
 . In early 2010, around the same time that ASSANGE was working with Manning
-to obtain classified information, ASSANGE met a 7-year oldin NATO Country-1 (“Teenager”),
+to obtain classified information, ASSANGE met a 17-year oldin NATO Country-1 (“Teenager”),
 who provided ASSANGE with data stolen from a bank.
 .  In early 2010, ASSANGE asked Teenager to commit computer intrusions and steal
 additional information, including audio recordings of phone conversations between high-ranking
 officials of the government of NATO Country-1, including members of the Parliament of NATO
 Country-1.
@@ Line 347: / Line 342: @@
 vehicles (provided to ASSANGE by a source) to determine that NATO Country-1 police were
 monitoring ASSANGE.
 , On March 29, 2010, WikiLeaks posted to its website classified State Department
@@ Line 377: / Line 370: @@
 PayPal, Visa, and MasterCard in retaliation for their decisions to stop processing payments for
 WikiLeaks. Anonymous called these attacks “Operation Payback.”
 . Later in December 2010, “Laurelai,” a hacker affiliated with Anonymous, who
@@ Line 409: / Line 400: @@
 about Kayla’s penetration of a hosting service, so that WikiLeaks could determine if WikiLeaks
 needed information hosted there.
 . On February 17, 2011, Teenager told Laurelai that WikiLeaks was the world’s
@@ Line 432: / Line 411: @@
 . On March 15, 2011, Laurelai emailed WikiLeaks (through Teenager) a list of
 approximately 200 purported passwords to U.S. and state government email accounts, including
 passwords (hashed and plaintext) that purported to be for accounts associated with information
 technology specialists at government institutions.
@@ Line 481: / Line 457: @@
 . — Inthe fall of 2011, Teenager left WikiLeaks.
 =====E. Sabu, Hammond, and ASSANGE=====
@@ Line 500: / Line 464: @@
 consulting company (“Intelligence Consulting Company”’).
 . On December 29, 2011, in a chat with other hackers on an IRC channel called
-“#1 ulzxmas,” a hacker affiliated with LulzSec/AntiSec, Jeremy Hammond, told the others that
+“#lulzxmas,” a hacker affiliated with LulzSec/AntiSec, Jeremy Hammond, told the others that
 information hacked from Intelligence Consulting Company was being sent to Wikileaks.
-— 69. On December 29, 2011, in a chat with other hackers on the “#Lulzxmas” IRC
+. On December 29, 2011, in a chat with other hackers on the “#Lulzxmas” IRC
 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.”
@@ Line 517: / Line 481: @@
 . 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
-hacking two U.S. state police associations. On j anuary 3, 2012, WikiLeaks tweeted a link to
+hacking two U.S. state police associations. On january 3, 2012, WikiLeaks tweeted a link to
 information that LulzSec/AntiSec had hacked and published in 2011, _ stating,
 | «Anonymous/Antisec/Luzsec releases in 2011.” On January 6, 2012, WikiLeaks tweeted a link
 to a spoofed email sent by Hammond to the clients of Intelligence Consulting Company,
-i
-a
-i
-:
 purporting to be the CEO of that company, stating, “AnonymousIRC email sent by #AntiSec to
 [Intelligence Consulting Company]’s customers #Anonymous #Lulzsec.”
@@ Line 547: / Line 493: @@
 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
-limited to the following”:
+limited to the following
+(( 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
@@ Line 561: / Line 509: @@
 could survive prosecution and prison without talking to law enforcement.
-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.
 b. On January 16, 2012, Sabu asked ASSANGE how “the case [was] going.” In
@@ Line 591: / Line 533: @@
 Research and Investigative Firm, Sabu and other members of LulzSec/AntiSec should look for |
 and provide to WikiLeaks mail and documents, databases and pdfs.
- On January 23, 2012, WikiLeaks announced a new television series that would start in
+((On January 23, 2012, WikiLeaks announced a new television series that would start in
 March 2012, in which ASSANGE would host conversations with key political players over the
 course of approximately ten weekly episodes... Airing on the Russia Today network, the guests
 interviewed by ASSANGE included the Presidents of Tunisia and Ecuador, the leader of
 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.))
 . On February 21, 2012, and in response to Sabu’s request, ASSANGE provided
@@ Line 615: / Line 553: @@
 others hacked from Intelligence Consulting Company.
-, On F ebruary 27, 2012, Hammond told Sabu, “we started giving JA” materials that
+. On February 27, 2012, Hammond told Sabu, “we started giving JA” materials that
 had been. obtained from other hacks.
@@ Line 631: / Line 569: @@
 . In March 2012, Hammond was arrested.
-SRO
 =====F. ASSANGE’s Efforts to Recruit System Administrators=====
@@ Line 666: / Line 596: @@
 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
 ballpark and get the ball and bring it out.”
 , At the same presentation, in responding to the audience’s question as to what they
@@ Line 692: / Line 617: @@
 Leaks” list from 2009 list that remained on WikiLeaks’s website.
-. Inaninterview on May 25, 2015, ASSANGE claimed to have arranged distraction
+. In an interview on May 25, 2015, ASSANGE claimed to have arranged distraction
 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
+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.
 So we worked against that, and we got him out of Hong Kong and got him to
@@ Line 705: / Line 630: @@
 alternatives? And so, we looked into private flights, private jets, other unusual
 routes for commercial jets, and presidential jets. ...
 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
@@ Line 739: / Line 659: @@
 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
 reports, 400,000 Iraq war-related significant activity reports, 800 Guantanamo Bay detainee
 assessment briefs, and 250,000 U.S. Department of State cables.
@@ Line 773: / Line 684: @@
 we don’t say that it is absolutely impossible that anything we ever publish will ever-result in
 harm—we cannot say that.”
 . On May 2, 2011, United States armed forces raided the compound of Osama bin
@@ Line 814: / Line 711: @@
 c. Classified Document D1 was a 2009 report discussing an improvised explosive
 device (“IED”) attack in Iraq. Classified Document D1 named local human
-.
 sources who provided information on the attack. Classified Document D1 was
 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.
 Classified Document D2 was classified at the SECRET level.
-The following are examples of State Department cables that ASSANGE
+. The following are examples of State Department cables that ASSANGE
 disseminated and published without redacting the names of human sources who were vulnerable
 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
 located in Iran and indicated that the source’s identity needed to be protected.
@@ Line 841: / Line 729: @@
 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
 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.
-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
 source of information located in China and indicated that the source’s identity
@@ Line 852: / Line 740: @@
 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
 information located in Syria and indicated that the sources’ identities needed to be
 protected. Classified Document A4 was classified at the SECRET level.
@@ Line 872: / Line 750: @@
 protected. Classified Document A5 was classified at the SECRET level.
-, ASSANGE knew that his dissemination and publication of Afghanistan and Iraq
+. ASSANGE knew that his dissemination and publication of Afghanistan and Iraq
 war-related significant activity reports endangered sources, whom he named as having provided
 information to U.S. and coalition forces.
@@ Line 892: / Line 770: @@
 his dissemination and publication of the unredacted State Department cables, ASSANGE claimed
 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.”
@@ Line 923: / Line 792: @@
 States security clearance or otherwise have authorization to receive, possess, or communicate
 classified information.
 ===== COUNT 1 (Conspiracy to Obtain and Disclose National Defense Information)=====
@@ Line 957: / Line 820: @@
 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
 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);
@@ Line 994: / Line 848: @@
 (All in violation of Title 18, United States Code, Section 793(g))
 =====COUNT 2 (Conspiracy To Commit Computer Intrusions)=====
@@ Line 1026: / Line 877: @@
 States and from protected computers; committed in furtherance of criminal and tortious acts
 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);
@@ Line 1050: / Line 896: @@
 C. In furtherance of the conspiracy, and to accomplish its objects, ASSANGE and his
 conspirators committed lawful and unlawful overt acts, including but not limited to, those
 described in the General Allegations Section of this Indictment.
@@ Line 1059: / Line 903: @@
 (All in violation of Title 18, United States Code, Sections 371)
 =====COUNT 3 (Unauthorized Obtaining of National Defense Information) (State Department Cables)=====
@@ Line 1081: / Line 922: @@
 (All in violation of Title 18, United States Code, Sections 793(b) and 2)
 =====COUNT 4 (Unauthorized Obtaining of National Defense Information) (Iraq Rules of Engagement Files)=====
@@ Line 1112: / Line 947: @@
 (All in violation of Title 18, United States Code, Sections 793(b) and 2)
 =====COUNT 5 (Attempted Unauthorized Obtaining and Receiving of National Defense Information)=====
@@ Line 1135: / Line 968: @@
 (All in violation of Title 18, United States Code, Sections 793(c) and 2)
@@ Line 1167: / Line 994: @@
 (All in violation of Title 18, United States Code, Sections 793(c) and 2)
@@ Line 1185: / Line 1008: @@
 connected with the national defense—namely, U.S. Department of State cables classified up to
 the SECRET level—for the purpose of obtaining information respecting the national defense,
 knowing and having reason to believe, at the time that he received and obtained them, that such
 materials had been and would be obtained, taken, made, and disposed of by a person contrary to
 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)
@@ Line 1215: / Line 1027: @@
 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
 connected with the national defense—namely, Iraq rules of engagement files classified up to the
 SECRET level—for the purpose of obtaining information respecting the national defense,
 knowing and having reason to believe, at the time that he received and obtained them, that such |
 materials had been and would be obtained, taken, made, and disposed of by a person contrary to
 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)
@@ Line 1253: / Line 1055: @@
 (All in violation of Title 18, United States Code, Sections 793(d) and 2)
 =====COUNT 10 (Unauthorized Disclosure of National Defense Information) (State Department Cables)=====
@@ Line 1274: / Line 1073: @@
 (All in violation of Title 18, United States Code, Sections 793(d) and 2)
@@ Line 1302: / Line 1100: @@
 (All in violation of Title 18, United States Code, Sections 793(d) and 2)
 =====COUNT 12 (Unauthorized Disclosure of National Defense Information) (Detainee Assessment Briefs)=====
@@ Line 1316: / Line 1112: @@
 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
 documents relating to the national defense—namely, detainee assessment briefs classified up to
 the SECRET level related to detainees -who were held at Guantanamo Bay—to communicate,
 deliver, and transmit the documents to ASSANGE, a person not entitled to receive them.
@@ Line 1333: / Line 1124: @@
 (All in violation of Title 18, United States Code, Sections 793(e) and 2) : |
 =====COUNT 13 (Unauthorized Disclosure of National Defense Information) (State Department Cables)=====
@@ Line 1352: / Line 1142: @@
 (All in violation of Title 18, United States Code, Sections 793(e) and 2)
@@ Line 1374: / Line 1161: @@
 (All in violation of Title 18, United States Code, Sections 793(e) and 2)
@@ Line 1405: / Line 1190: @@
 (All in violation of Title 18, United States Code, Section 793(e))
 =====COUNT 16 (Unauthorized Disclosure of National Defense Information)=====
@@ Line 1432: / Line 1215: @@
 (All in violation of Title 18, United States Code, Section 793(e))
@@ Line 1459: / Line 1240: @@
 (All in violation of Title 18, United States Code, Section 793(e))
@@ Line 1483: / Line 1262: @@
 (All in violation of Title 18, United States Code, Sections 793(b) and 2)
@@ Line 1531: / Line 1308: @@
 U.S. Department of Justice