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Defendants VIKTOR BORISOVICH NETYKSHO, BORIS ALEKSEYEVICH

ANTONOV, DMITRIY SERGEYEVICH BADIN, IVAN SERGEYEVICH YERMAKOV,

ALEKSEY VIKTOROVICH LUKASHEV, SERGEY ALEKSANDROVICH MORGACHEV,

NIKOL AY YURYEVICH KOZA CHEK , PAVE L VYACHESLAVOVICH YERSHOV, ARTEM

ANDREYEVICH MALYSHEV, ALEKSANDR VLADIMIROVICH OSADCHUK, and

ALEK SEY ALEKSAND ROVICH POTEM KIN were GRU officers who knowingly and

intentionally conspired with each other, and with persons known and unknown to the Grand Jury

(collectively the “Conspirators”), to gain unauthorized access (to “hack”) into the computers of

U.S. persons and entities involved in the 2016 U.S. presidential election, steal documents from

those computers, and stage releases of the stolen documents to interfere with the 2016 U.S.

presid ential election.

3. Starting in at least March 2016, the Cons pirators used a variety of means to hack the email

accounts of volunteers and employees of the U.S. presidential campaign of Hillary Clinton (the

“Clinton C ampaign”) , including the email account of the Clinton Campaign’s chairman.

4. By i n or around April 2016, the Cons pirators also hacked into the computer networks of

the Democratic Congressional Campaign Committee (“DCCC”) and the Democratic National

Committee (“DNC”). The Conspirators covertly monitored the comput ers o f dozens o f DCCC

and DNC employees, implanted hundreds of files containing malicious computer code

(“malware”), and stol e emails and other documents from the DCCC and DNC.

5. By in or around April 2016, the Conspi rators began to plan the release of materials stol en

from the Clinton Campaign, DCCC, and DNC.

6. Beginning in or around June 2016, the Conspirators staged and released tens of thousands

of the stolen ema ils and document s. They did so using f ictiti ous online personas, including

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