Chart: Names of the “Unindicted Co-Conspirators" in Fulton

County Georgia Indictment

By Ryan Goodman, Norman Eisen, Siven Watt, Allison Rice, Francois

Barrilleaux, Beth Markman, Michael Nevett

Just Security
August 16, 2023; updated on August 17 and 25, 2023 (updates are noted in the Chart itself and
also listed below the Chart)

In a 41-count indictment unsealed on Monday, a Fulton County, Georgia grand jury charged
former President Donald Trump and 18 other defendants with a constellation of crimes. The
indictment alleges several interconnected schemes to overturn the legitimate results of Georgia’s
2020 presidential election—and efforts to conceal those schemes.

The indictment also catalogs the acts of 30 unnamed “unindicted co-conspirators,” who were
allegedly involved in “overt acts in furtherance of the conspiracy.” In the Chart below we
assembled ample clues throughout the charging document to match the anonymous co-
conspirators to possible identities. In many cases, the attribution is clear because the Indictment
references communications sent or received by a particular individual which can be compared to
communications in the publicly available record (including the final report and documents
produced by the House Select Committee and in litigation). While there is not sufficient
information to fully confirm all 30—and prosecutors are ethically barred from identifying
unindicted co-conspirators without issuing charges—we have pieced together many of their
potential identities. We also show the basis for any potential attributions in the Chart.

The Chart will be updated as more information becomes publicly available.

We welcome readers’ feedback and additional information (email address).

Chart. Who are The Potential Unindicted Co-Conspirators?

Unindicted Co- Possible Identity References in
Conspirator Indictment
Individual 1 Tom Fitton Act 1, p. 20

Act 1 in the indictment references a

10/31/2020 discussion Individual 1 had
with Trump; a record of which is included
in the House Select Committee’s document
production.

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Unindicted Co- Possible Identity References in
Conspirator Indictment
Individual 2 False Elector Act 2, p. 20
Act 36, p. 28
Acts 79-82 in the indictment indicate that Act 37, p. 28
Individual 2 is one of Georgia’s 16 false Act 54, p. 32
electors. We list each false elector who Act 79, p. 40
was not indicted or otherwise identified in Act 80, p. 40
this chart. Act 81, p. 41
Act 82, p. 41
1. Mark Amick
2. "Ken" Carroll
3. Brad Carver
4. Vikki Townsend Consiglio
5. John Downey
6. Carolyn Hall Fisher
7. Gloria Kay Godwin
8. David G. Hanna
9. Mark W. Hennessy
10. Daryl Moody
11. C.B. Yada

Individual 3 Boris Epshteyn Act 3, p. 20*

Act 94, p. 44
Act 109 in the indictment references an Act 109, p. 49
email Individual 3 received on 01/01/2021;
a record of which is included in the House *Note that Act 3 is apparently
Select Committee’s document production. mislabeled as Act 2.
Individual 4 Robert Sinners Act 4, p. 20
Act 45, p. 30
Act 63, p. 36
Act 4 in the indictment references an email Act 65, p.36
sent on 11/20/2020 by David Shafer to Act 66, p. 37
Individual 4 and other individuals, Act 67, p. 37
introducing Individual 4 to Scott Hall. The Act 68, p. 37
same email is accounted for in Curling v. Act 71, p. 38
Raffensperger and discussed during Act 72, p. 38
Sinners’ deposition (at p. 80:4-19). Act 86 Act 73, p. 38
in the indictment references an email sent Act 76, p. 39
on 12/14/2020 by Individual 4 to Mike Act 77, p. 39
Roman and others, a record of which is Act 86, p. 42
included in the House Select Committee’s
document production.

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Unindicted Co- Possible Identity References in
Conspirator Indictment
Individual 5 Bernard Kerik Act 9, p. 22
Act 17, p. 23
Act 20, p. 24
Act 40 in the indictment references an Act 40, p. 29
email sent on 12/08/2020, at Trump’s Act 61, p. 35
request, by Bill White to Individual 5,
Giuliani, and others, containing
information on Majority Leader of the
Georgia Senate Mike Dugan and President
Pro Tempore of the Georgia Senate Butch
Miller. A record of the email is included in
the House Select Committee’s documents
production. In addition to Giuliani and
Kerik, Molly Michael and Dan Scavino
were the other two recipients of White’s
email. It is unlikely that either of these
White House staffers are Individual 5
given neither are reported to have attended
a 12/01/2020 meeting alongside Giuliani
with Speaker of the Arizona House,
President of the Arizona Senate, and other
Arizona legislators. Kerik did attend this
meeting (per Rusty Bowers informal
congressional interview referenced in
House Select Committee final report, p.
313, n. 207).

Individual 6 Phil Waldron Act 9, p. 22

Act 17, p. 23
Act 91, p. 44
Act 91 in the indictment alleges that on
12/21/2020 Sidney Powell sent an email to
SullivanStrickler COO Maggio, asking
him to send “a copy of all data” from
Michigan to Individual 6, Individual 21,
and Individual 22. The email was disclosed
during Curling v. Raffensperger and shows
that Powell sent this email to Phil Waldron
and two linked to ASOG, Todd Sanders
and Conan Hayes (Individuals 21 and 22 –
see below). Waldron was also present
during a 11/25/2020 White House meeting
described in Act 9, where Giuliani, Kerik,
Giuliani and others met with Pennsylvania

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Unindicted Co- Possible Identity References in
Conspirator Indictment
legislators to discuss holding a special
session of the Pennsylvania General
Assembly. Waldron attended this meeting
(per Rusty Bowers informal congressional
interview referenced in House Select
Committee final report, p. 313, n. 207).
Waldron also confirmed his attendance to
the Washington Post.

Individual 7 G. Michael Brown (or else Act 18, p. 23

Act 63, p. 36
James Fitzpatrick, Shawn Act 77, p. 39
Flynn, Thomas Lane, Valerie Act 86, p. 42
McConahay)
Act 77 in the indictment alleges that Mike
Roman sent an email on 12/14/2020 to Robert
Sinners, Individual 7, and others, stating:
“Please send me an update as soon as the State
Electoral College has adjourned and all
paperwork is secured.”

The House Select Committee has the email,

which was sent to: G. Michael Brown; James
Fitzpatrick; Shawn Flynn; Thomas Lane;
Valerie Phillips McConahay; Ryan Terrill;
Andrew Iverson; Jesse Law; Robert Sinners.

Act 63 in the indictment alleges that Mike

Roman sent an email on 12/12/20 to Sinners,
Individual 7, and others: “I need a tracker for
electors.”

The House Select Committee has the email,

which was sent to: G. Michael Brown; James
Fitzpatrick; Shawn Flynn; Thomas Lane;
Valerie Phillips McConahay; Jesse Law;
Robert Sinners; Peter McGinnis

Given these two emails, Individual 7 could

only be either Brown, Fitzpatrick, Flynn, Lane,
or McConahay.

UPDATE: The evidence points most likely to

Brown, who served as deputy to Roman, the

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Unindicted Co- Possible Identity References in
Conspirator Indictment
director of election day operations for Trump’s
campaign. The other four people in the list
were responsible for single states. James
Fitzpatrick (PA), Shawn Flynn (MI), Thomas
Lane (NM), Valerie Phillips McConahay (NV)
(House Select Committee final report ch 3.4 n.
76). We thank Kevin Skoglund for this
insight.

Individual 8 Lt. Gov. Burt Jones Act 23, p. 25

Act 34, p. 28
Act 35, p. 28
Identified by Atlanta Journal Constitution Act 38, p. 29
(the indictment cites a Tweet by Jones). Act 68, p. 37
Act 73, p. 37
Act 79, p. 40
Act 80, p. 40
Act 81, p. 41
Act 82, p. 41
Act 102, p. 46
Act 161, p. 71
Count 2, p. 72
Count 23, p. 84
Count 41, p. 97
Individual 9 Joseph Brannan [Updated] Act 47, p. 31
Act 48, p. 31
Act 74, p. 39
Acts 79-82 in the indictment indicate that Act 79, p. 40
Individual 2 is one of Georgia’s 16 false Act 80, p. 40
electors. Act 47 of the indictment Act 81, p. 41
references a 12/10/20 email from Kenneth Act 82, p. 41
Chesebro to David Shafer and Individual
9, asking “to help coordinate with the other
5 contested States...”

The House Select Committee produced the

email which was sent to Shafer, copying
the email address “[email protected].”
Brannan, one of the fake electors, was the
Treasurer of the Georgia GOP at the time.
There are two other recipients of the email
message, but they are both women and
Individual 9 is identified in the Indictment
as a man.

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Unindicted Co- Possible Identity References in
Conspirator Indictment
Identified by The Daily Beast.
See also David Shafer congressional
deposition (66: 18-23)

Individual 10 Vikki Townsend Consiglio or Act 48, p. 31

Act 79, p. 40
Carolyn Fisher [Updated] Act 80, p. 40
Act 81, p. 41
Act 48 of the indictment references an Act 82, p. 41
email that Individuals 9, 10 and 11
received on or about 12/10/20 from
Kenneth Chesebro. The description
matches an email sent by Chesebro on that
date to Joseph Brannan (separately
identified as Individual 9), Vikki
Townsend Consiglio, and Carolyn Fisher.

Identified by The Hill.

Individual 11 Vikki Townsend Consiglio or Act 48, p. 31

Act 79, p. 40
Carolyn Fisher [Updated] Act 80, p. 40
Act 81, p. 41
Act 48 of the indictment references an Act 82, p. 41
email that Individuals 9, 10 and 11
received on or about 12/10/20 from
Kenneth Chesebro. The description
matches an email sent by Chesebro on that
date to Joseph Brannan (separately
identified as Individual 9), Vikki
Townsend Consiglio, and Carolyn Fisher.

Identified by The Hill.

Individual 12 False elector Act 62, p. 36

Act 79, p. 40
Act 80, p. 40
See the entry for “Individual 2” for the list Act 81, p. 41
of unidentified false electors. Act 82, p. 41
Individual 13 False elector Act 74, p. 39
Act 79, p. 40
Act 80, p. 40
See the entry for “Individual 2” for the list Act 81, p. 41
of unidentified false electors.

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Unindicted Co- Possible Identity References in
Conspirator Indictment
Act 82, p. 41
Individual 14 False elector Act 79, p. 40
Act 80, p. 40
Act 81, p. 41
See the entry for “Individual 2” for the list Act 82, p. 41
of unidentified false electors.
Individual 15 False elector Act 79, p. 40
Act 80, p. 40
Act 81, p. 41
See the entry for “Individual 2” for the list Act 82, p. 41
of unidentified false electors. Act 85, p. 42
Individual 16 False elector Act 79, p. 40
Act 80, p. 40
Act 81, p. 41
See the entry for “Individual 2” for the list Act 82, p. 41
of unidentified false electors.
Individual 17 False elector Act 79, p. 40
Act 80, p. 40
Act 81, p. 41
See the entry for “Individual 2” for the list Act 82, p. 41
of unidentified false electors.
Individual 18 False elector Act 79, p. 40
Act 80, p. 40
Act 81, p. 41
See the entry for “Individual 10 for the list Act 82, p. 41
of unidentified false electors.
Individual 19 False elector Act 79, p. 40
Act 80, p. 40
Act 81, p. 41
See the entry for “Individual 2” for the list Act 82, p. 41
of unidentified false electors.
Individual 20 Maybe Michael Flynn or Act 90, p. 43
Patrick Byrne or else Emily
Newman

Act 90 in the indictment references a

12/18/2020 meeting Individual 20 had with
Trump, Giuliani and Powell, in the White
House; as the House Select Committee
final report states, as well as Derek Lyon’s
committee deposition (at p. 111:3-19) and
other reporting, it was Powell, Giuliani,
Flynn, Byrne, and Emily Newman

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Unindicted Co- Possible Identity References in
Conspirator Indictment
advancing different “strategies and
theories” during the 12/18/2020 meeting.

Update: On Aug. 16, Byrne appeared to

deny that he is Individual 20 in an
interview with the Salt Lake Tribune, and
said he has no contact with the Georgia
investigators before the indictment. That
said, Byrne said, “Never talked to them,
never heard from them, but I happily
welcome them blaming it on me”
(emphasis added). And his denial of being
Individual 20 was based on a flawed
premise that unindicted co-conspirators are
usually cooperators (“An unindicted co-
conspirator is usually cooperating with
prosecutors to avoid imprisonment,” Byrne
said in a text message to The Tribune.
“Not me.”).

Individual 21 Todd Sanders or Conan Act 91, p. 44

Hayes

Act 91 in the indictment references an

email sent by Powell that mentioned
Sanders, Hayes, and Waldron; a record of
which was obtained in Curling v.
Raffensperger. Waldron is identified as
Individual 6.

Individual 22 Todd Sanders or Conan Act 91, p. 44

Hayes

Act 91 in the indictment references an

email sent by Powell that mentioned
Sanders, Hayes, and Waldron; a record of
which was obtained in Curling v.
Raffensperger. Waldron is identified as
Individual 6.

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Unindicted Co- Possible Identity References in
Conspirator Indictment
Individual 23 Participant in phone calls Act 115, p. 53
Act 127, p. 59
with Harrison Floyd and
others.

Act 115 in the indictment references a call

from Harrison Floyd to Individual 23 on
01/03/2021 at 8:11pm.

Act 127 in the indictment references a

four-way call between Harrison Floyd,
Trevian Kutti, Stephen Lee, and Individual
23 on 01/05/2021 at 12:14pm.

Individual 24 Alex Cruce Act 143, p. 64

Act 143 in the indictment references

Individual 24 flying into Coffee County
with Scott Hall. Alex Cruce admitted to
this during his deposition in Curling v.
Raffensperger (p. 46:6-16).

Individual 25 Doug Logan Act 150, p. 66

Act 154, p. 67
Act 154 in the indictment references Misty
Hampton allowing Individual 25 and
Individual 29 to access non-public areas of
the Coffee County Board of Elections and
Registration Office on 01/18/2021. Videos
reported by ABC News show her letting in
Douglas Logan and Jeff Lenberg on that
date. Act 150 in the indictment references
Individual 25 downloading data taken from
Coffee County and stored on
SullivanStrickler’s ShareFile. Individual
25 downloaded data on 01/09/2021,
01/10/2021, 01/11/2021, and 01/13/2021.
Activity logs show Logan downloading
data on these days.

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Unindicted Co- Possible Identity References in
Conspirator Indictment
Individual 26 Probably Todd Sanders, a.k.a. Act 151, p. 66
“Scott T.” (a second time)
[Update]

It is important to note here that the

indictment refers to Individual 26 as
someone “whose identity is unknown to
the Grand Jury” (emphasis added).

With advice from Kevin Skoglund, we are

able to determine that it is most likely
Todd Sanders (who also appears as
Individual 21 or 22 above).

Act 151 of the indictment states that

Individual 26 unlawfully accessed and
downloaded the Coffee County data on
January 9, 10, 11, 18, and 19, 2021.

Activity logs show Sanders downloaded

data on these days. Additionally, the
activity logs do not show Sanders
downloaded the data on February 25 and
26, which Individual 27 did.

The Grand Jury may not have identified

Sanders because he used “Scott T.” as his
login name (Skoglund’s declaration (§ 59)
and Doug London’s deposition (108-
109)).

Note: Skoglund’s declaration (§ 75) in

Curling v. Raffensperger identifies six
individuals who downloaded election
software between 1/10/21 and 2/25/21:
Doug Logan, Sanders, Hayes, James
Penrose, Pospieszalski, and Pulitzer. J.
Alex Halderman’s declaration (§ 13)
identifies five individuals—the same six
except for Pulitzer—who downloaded
Coffee County data in January and
February 2021.

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Unindicted Co- Possible Identity References in
Conspirator Indictment
Individual 27 Probably Conan Hayes (a Act 152, p. 67
second time) [Update]

It is important to note here that the

indictment refers to Individual 27 as
someone “whose identity is unknown to
the Grand Jury” (emphasis added).

With advice from Kevin Skoglund, we are

able to determine that it is most likely
Conan Hayes (who also appears as
Individual 21 or 22 above).

Act 152 of the indictment states that

Individual 27 unlawfully accessed and
downloaded the Coffee County data on
January 10, 12, 13 and February 25 and
26.

Activity logs show Hayes downloaded data

on these days. Additionally, the activity
logs do not show Hayes downloaded the
data on January 9, which Individual 26
did.

Note: Skoglund’s declaration (§ 75) in

Curling v. Raffensperger identifies six
individuals who downloaded election
software between 1/10/21 and 2/25/21:
Doug Logan, Sanders, Hayes, James
Penrose, Pospieszalski, and Pulitzer. J.
Alex Halderman’s declaration (§ 13)
identifies five individuals—the same six
except for Pulitzer—who downloaded
Coffee County data in January and
February 2021.

Individual 28 Jim Penrose Act 153, p. 67

Act 155, p. 67
Act 155 in the indictment alleges that
Individual 28 sent an email on 04/22/2021
to SullivanStrickler COO Paul Maggio,

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Unindicted Co- Possible Identity References in
Conspirator Indictment
asking him to send voting data taken from
Coffee County to an attorney associated
with Sidney Powell. The email was sent by
Jim Penrose, and copied Stephanie
Lambert, and it was accounted for in
Curling v. Raffensperger (see Gabriel
Sterling’s deposition, at p. 286:22-25;
Kevin Skoglund declaration, at § 77).
Penrose was also the one person who
downloaded all voting data from
SullivanStrickler’s ShareFile on
01/13/2021, according to activity logs
(p.6), which Act 153 in the indictment
alleges.

Individual 29 Jeffrey Lenberg Act 154, p. 67

Act 154 in the indictment references Misty

Hampton allowing two individuals to
access non-public areas of the Coffee
County Board of Elections and
Registration Office on 01/18/2021. Videos
reported on by media show her letting in
Douglas Logan and Jeff Lenberg on that
date. Because Individual 25 is likely Doug
Logan, Individual 29 is likely Jeffrey
Lenberg.

Individual 30 Stefanie Lambert Act 155, p. 67

Act 155 in the indictment alleges that Jim

Penrose sent an email to SullivanStrickler
COO Paul Maggio on 04/22/2021, asking
“to transmit” all Coffee County data “to
unindicted co-conspirator Individual 30.”
The email is accounted for in Curling v.
Raffensperger, which indicates Stefanie
Lambert was to receive the data. Penrose
wrote to send the materials to “the same
address as before” and “[i]nvoice Stefanie
Lambert for the work like last time,” and a

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Unindicted Co- Possible Identity References in
Conspirator Indictment
FedEx package was sent to Lambert– See
Gabriel Sterling’s deposition, at p. 286:
22-25; Kevin Skoglund declaration, at §§
77-78).

Updates made on August 17, 2023:

1. Individual 7: New analysis of information indicating higher likelihood of G. Michael Brown (with
appreciation to Kevin Skoglund for advice)

2. Individual 9: The Daily Beast identified Individual 9 as then-Georgia GOP treasurer Joseph
Brannan (reporting for Daily Beast by Roger Sollenberger and William Bredderman)

3. Individual 20: Include August 16, 2023 denial by Patrick Byrne (interview with Salt Lake Tribune’s
Bryan Schott)

4. Individual 26: New analysis of SullivanStrickler activity logs indicating Individual 26 is Todd Sanders,
a.k.a “Scott T” (with appreciation to Kevin Skoglund for advice)

5. Individual 27: New analysis of SullivanStrickler activity logs indicating Individual 27 is Conan Hayes
(with appreciation to Kevin Skoglund for advice)

Updates made on August 25, 2023:

Individuals 10 and 11: The Hill’s Zach Schonfeld identified Individuals 10 and 11 as Vikki Townsend
Consiglio or Carolyn Fisher based on a matching email.

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