Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 18 of 37
individuals and entities at times distributed the ORGANIZATION’s materials through their own accounts via retweets, reposts, and similar means. Defendants and their co-conspirators then monitored the propagation of content through such participants.
46. In or around the latter half of 2016, Defendants and their co-conspirators, through their ORGANIZATION-controlled personas, began to encourage U.S. minority groups not to vote in the 2016 U.S. presidential election or to vote for a third-party U.S. presidential candidate.
- a. On or about October 16, 2016, Defendants and their co-conspirators used the ORGANIZATION-controlled Instagram account “Woke Blacks” to post the following message: “[A] particular hype and hatred for Trump is misleading the people and forcing Blacks to vote Killary. We cannot resort to the lesser of two devils. Then we’d surely be better off without voting AT ALL.”
- b. On or about November 3, 2016, Defendants and their co-conspirators purchased an advertisement to promote a post on the ORGANIZATION-controlled Instagram account “Blacktivist” that read in part: “Choose peace and vote for Jill Stein. Trust me, it’s not a wasted vote.”
- c. By in or around early November 2016, Defendants and their co-conspirators used the ORGANIZATION-controlled “United Muslims of America” social media accounts to post anti-vote messages such as: “American Muslims [are] boycotting elections today, most of the American Muslim voters refuse to vote for Hillary Clinton because she wants to continue the war on Muslims in the middle east and voted yes for invading Iraq.”
47. Starting in or around the summer of 2016, Defendants and their co-conspirators also began to promote allegations of voter fraud by the Democratic Party through their fictitious U.S. personas
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