Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 29 of 37
Campaign (“Campaign Official 3”) involved in the campaign’s Florida operations. On or about August 20, 2016, Defendants and their co-conspirators used the “Matt Skiber” Facebook account to contact Campaign Official 3.
80. On or about August 19, 2016, Defendants and their co-conspirators used the false U.S. persona “Matt Skiber” account to write to the real U.S. person affiliated with a Texas-based grassroots organization who previously had advised the false persona to focus on “purple states like Colorado, Virginia & Florida.” Defendants and their co-conspirators told that U.S. person, “We were thinking about your recommendation to focus on purple states and this is what we’re organizing in FL.” Defendants and their co-conspirators then sent a link to the Facebook event page for the Florida rallies and asked that person to send the information to Tea Party members in Florida. The real U.S. person stated that he/she would share among his/her own social media contacts, who would pass on the information.
81. On or about August 24, 2016, Defendants and their co-conspirators updated an internal ORGANIZATION list of over 100 real U.S. persons contacted through ORGANIZATION-controlled false U.S. persona accounts and tracked to monitor recruitment efforts and requests. The list included contact information for the U.S. persons, a summary of their political views, and activities they had been asked to perform by Defendants and their co-conspirators.
82. On or about August 31, 2016, Defendants and their co-conspirators, using a U.S. persona, spoke by telephone with a real U.S. person affiliated with a grassroots group in Florida. That individual requested assistance in organizing a rally in Miami, Florida. On or about September 9, 2016, Defendants and their co-conspirators sent the group an interstate wire to pay for materials needed for the Florida rally on or about September 11, 2016.
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