Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 26 of 37
66. On or about July 12, 2016, Defendants and their co-conspirators created and purchased Facebook advertisements for the “Down With Hillary” rally in New York.
67. On or about July 23, 2016, Defendants and their co-conspirators used the email address of a false U.S. persona, joshmilton024@gmail.com, to send out press releases to over thirty media outlets promoting the “Down With Hillary” rally at Trump Tower in New York City.
68. On or about July 28, 2016, Defendants and their co-conspirators posted a series of tweets through the false U.S. persona account @March_for_Trump stating that “[w]e’re currently planning a series of rallies across the state of Florida” and seeking volunteers to assist.
69. On or about August 2, 2016, Defendants and their co-conspirators used the false U.S. persona “Matt Skiber” Facebook account to send a private message to a real Facebook account, “Florida for Trump,” set up to assist then-candidate Trump in the state of Florida. In the first message, Defendants and their co-conspirators wrote:
Hi there! I’m a member of Being Patriotic online community. Listen, we’ve got an idea. Florida is still a purple state and we need to paint it red. If we lose Florida, we lose America. We can’t let it happen, right? What about organizing a YUGE pro-Trump flash mob in every Florida town? We are currently reaching out to local activists and we’ve got the folks who are okay to be in charge of organizing their events almost everywhere in FL. However, we still need your support. What do you think about that? Are you in?
70. On or about August 2, 2016, and August 3, 2016, Defendants and their co-conspirators, through the use of a stolen identity of a real U.S. person, T.W., sent emails to certain grassroots groups located in Florida that stated in part:
My name is [T.W.] and I represent a conservative patriot community named as “Being Patriotic.” . . . So we’re gonna organize a flash mob across Florida to support Mr. Trump. We clearly understand that the elections winner will be predestined by purple states. And we must win Florida. … We got a lot of volunteers in ~25 locations and it’s just the beginning. We’re currently choosing venues for each
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