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superseding_indictment_-_24-06-2020 [2020/06/25 13:51]
editor42
superseding_indictment_-_24-06-2020 [2020/07/05 19:16] (current)
editor42
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-<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> 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 FILED IN OPEN COURT ON  JUN. 24 2020 CLERK U.S. DISTRICT COURT ALEXANDRIA, VIRGINIA
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 =====A. ASSANGE and WikiLeaks===== =====A. ASSANGE and WikiLeaks=====
-cL. From at least 2007, JULIAN PAUL ASSANGE (“ASSANGE”): was the public +1. 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 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 predicated the success of WikiLeaks in part upon the recruitment of sources to (4) illegally
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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
- 
 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, and Guantanamo Bay==== ====ii, Manning Steals and Provides to WikiLeaks Classified Information about Iraq, Afghanistan, and Guantanamo Bay====
  
-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, 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.)) 
 +.
  
 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, 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 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. Open Source Center analytical database,” an unclassified (but non-public) 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
- 
 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, 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. 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, including audio recordings of phone conversations between high-ranking additional information, including audio recordings of phone conversations between high-ranking
- 
-10 
- 
-  
- 
-  
- 
 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.
- 
-  
  
 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.”
- 
-  
  
 48. Later in December 2010, “Laurelai,” a hacker affiliated with Anonymous, who 48. Later in December 2010, “Laurelai,” a hacker affiliated with Anonymous, who
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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.
- 
-13 
- 
-  
- 
-  
- 
-  
- 
-  
- 
-  
  
 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
- 
 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
- 
 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
- 
 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.
  
-15 
  
-  
- 
-  
- 
-  
- 
-  
- 
-  
- 
-  
  
 =====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/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. 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+69. 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.” 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 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, 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 | «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, to a spoofed email sent by Hammond to the clients of Intelligence Consulting Company,
- 
-16 
- 
-  
- 
-  
- 
-  
- 
-i 
-a 
-i 
-: 
- 
-  
- 
-  
- 
 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 #Lulzsec.” [Intelligence Consulting Company]’s customers #Anonymous #Lulzsec.”
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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  
 +(( 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.
  
-  
-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. 
  
-17 
- 
-  
  
 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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 Research and Investigative Firm, Sabu and other members of LulzSec/AntiSec should look for | Research and Investigative Firm, Sabu and other members of LulzSec/AntiSec should look for |
 and provide to WikiLeaks mail and documents, databases and pdfs. 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 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 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 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 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.))
- +
-  +
- +
- +
  
 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.
  
-79On F ebruary 27, 2012, Hammond told Sabu, “we started giving JA” materials that+79On February 27, 2012, Hammond told Sabu, “we started giving JA” materials that
 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.
- 
-19 
- 
-  
- 
-SRO 
- 
-  
  
 =====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
- 
 ballpark and get the ball and bring it out.” ballpark and get the ball and bring it out.”
- 
-20 
- 
-  
  
 87, At the same presentation, in responding to the audience’s question as to what they 87, At the same presentation, in responding to the audience’s question as to what they
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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 on May 25, 2015, ASSANGE claimed to have arranged distraction+90. In an interview on May 25, 2015, ASSANGE claimed to have arranged distraction
 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+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? And so, we looked into private flights, private jets, other unusual alternatives? And so, we looked into private flights, private jets, other unusual
 routes for commercial jets, and presidential jets. ... routes for commercial jets, and presidential jets. ...
- 
-21 
- 
-  
- 
 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
- 
-22 
- 
-  
- 
-  
- 
-  
- 
 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.”
- 
-23 
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-  
- 
-  
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-  
- 
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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
- 
-24 
- 
-  
- 
-  
- 
-98. 
- 
 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
- 
-25 
- 
-  
- 
-  
- 
-  
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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.
  
-99ASSANGE knew that his dissemination and publication of Afghanistan and Iraq+99ASSANGE 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
- 
-26 
- 
-  
- 
-  
- 
-  
- 
 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.
- 
-27 
- 
-  
- 
-  
  
 ===== 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
- 
-28 
- 
-  
- 
-  
- 
-  
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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))
  
-29 
- 
-  
  
 =====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
- 
-30 
- 
-  
- 
 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
- 
 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
- 
 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)
  
-31 
- 
-  
  
 =====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)
  
-32 
  
-  
- 
-  
- 
-  
  
 =====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)
  
-33 
  
-  
  
 =====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)
  
-34 
  
-  
- 
-  
- 
-  
  
    
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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)
- 
-35 
- 
-  
  
    
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 connected with the national defense—namely, U.S. Department of State cables classified up to 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, 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 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 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. 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)
- 
-36 
- 
    
  
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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
- 
 connected with the national defense—namely, Iraq rules of engagement files classified up to the 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, 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 | 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 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. 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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 (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 
- 
-  
  
 =====COUNT 10 (Unauthorized Disclosure of National Defense Information) (State Department Cables)===== =====COUNT 10 (Unauthorized Disclosure of National Defense Information) (State Department Cables)=====
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 (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 
  
    
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 (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 
  
-  
  
 =====COUNT 12 (Unauthorized Disclosure of National Defense Information) (Detainee Assessment Briefs)===== =====COUNT 12 (Unauthorized Disclosure of National Defense Information) (Detainee Assessment Briefs)=====
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 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
- 
 documents relating to the national defense—namely, detainee assessment briefs classified up to documents relating to the national defense—namely, detainee assessment briefs classified up to
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-  
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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,
- 
 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.
  
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 (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)=====
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 (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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- 
    
  
 (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 
  
    
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 (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 
  
-  
  
 =====COUNT 16 (Unauthorized Disclosure of National Defense Information)===== =====COUNT 16 (Unauthorized Disclosure of National Defense Information)=====
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 (All in violation of Title 18, United States Code, Section 793(e)) (All in violation of Title 18, United States Code, Section 793(e))
- 
-45 
  
  
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 (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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 (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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 U.S. Department of Justice U.S. Department of Justice
  
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  • Last modified: 2020/06/25 13:51