U.S. Complaint Against Julian Assange
U.S. Complaint Against Julian Assange
U.S. Complaint Against Julian Assange
»-.J
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
•I '
UNITED STATES OF AMERICA
Defendant,
the defendant, Julian P. Assange, with violating 18 U.S.C. §371 by conspiring to (1) access a
computer, without authorization and exceeding authorized access, to obtain classified national
defense information in violation of 18 U.S.C. § 1030(a)(1); and (2) access a computer, without
1030(a)(2), (c)(2)(B)(ii).
2. I am a Special Agent with the Federal Bureau of Investigation (FBI) and have
been so employed since February 2011. Since joining the FBI, I have investigated violations of
federal law involving counterterrorism and counterintelligence matters, and I have gained
experience through training and everyday work related to conducting these types of
investigations. Since February 2017,1 have been assigned to a Counterespionage squad at the
Washington Field Office in Washington, D.C. In this capacity, I investigate matters involving
related crimes. As a Special Agent with the FBI, I have received classroom and on-the-job
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training in general law enforcement and also in such specialized areas as counterintelligence,
conducted physical and electronic surveillance, executed search warrants, and debriefed
investigations, I have gained knowledge in the use ofvarious investigative techniques including
the utilization of Rule 41 search warrants, subpoenas, national security letters, physical and
federal agent, I am authorized to investigate violations of the laws of the United States. I have
classified information, including violations related to the illegal possession, distribution, and/or
receipt of classified information, and related crimes, in violation of 18 U.S.C. §§ 793, 794, 1030,
and 1924. I also am authorized to execute warrants issued under the authority of the United
States, and I have participated in arrest warrants and search warrants in my capacity as an FBI
Special Agent.
obtained fi*om other agents and witnesses, my training and experience, and my review of records,
reports, articles, and websites. Unless otherwise noted, information provided to me by other law
enforcement personnel does not necessarily reflect my personal observations or investigation, but
rather has been passed to me by individuals with first-hand knowledge. This Affidavit does not
set forth all ofmy knowledge about this matter, but is intended merely to establish probable
communications, mask their identities, and destroy any trace of their conduct, using, for
example, encryption and anonymization techniques, and erasing and wiping data. For this
reason, the facts are derived in large part from forensic analysis of available computer data,
in the history of the United States. Between in or around January 2010 and May 2010, Chelsea
Manning,' an intelligence analyst in the U.S. Army, downloaded four, nearly complete and
activity reports, 400,000 Iraq war-related significant activity reports, 800 Guantanamo Bay
detainee assessments, and 250,000 U.S. State Department cables. Manning provided these
records to WikiLeaks, a website founded and led by the defendant, Julian P. Assange. On its
WikiLeaks publicly released the vast majority of the classified records on its website in 2010 and
2011. Manning has since been tried and convicted by court-martial for her illegal acts in
6. The charges in this criminal complaint focus on a specific illegal agreement that
' Manning used the name"Bradley E. Manning" at the time of the events at issue in this
Affidavit. According to a statement fi*om Manning's attorney published on or around August 22,
2013, Manning has identified as a female since childhood and was changing her name to
"Chelsea Manning." As a result, I refer to Manning using her current name and the female
gender.
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Assange and Manning from March 2010, The chats reflect that on March 8, 2010, Assange
agreed to assist Manning in cracking a password stored on United States Department of Defense
(DoD) computers connected to the classified Secret Internet Protocol Router Network
(SIPRNet). Manning, who had access to the computers in connection with her duties as an
intelligence analyst, was using the computers to download classified records to transmit to
WikiLeaks.
7. Cracking the password would have allowed Manning to log onto the computers
under a usemame that did not belong to her. Such a deceptive measure would have made it more
difficult for investigators to determine the source of the illegal disclosures. While it remains
unknown whether Manning and Assange were successfiil in cracking the password, a follow-up
message from Assange to Manning on March 10, 2010, reflects that Assange was actively trying
8. Circumstantial evidence reflects that Assange and Manning intended to crack the
password to facilitate Manning's illegal disclosure of classified information. At the time they
formed their illegal password-cracking agreement, Manning had already provided WikiLeaks
with hundreds of thousands of classified records relating to, among other things, the wars in
Afghanistan and Iraq. In the recovered chats surrounding the illegal agreement. Manning and
to Assange. The chats also reflect the two collaborating on the public release of the information
and Assange actively encouraging Manning to provide more information. The chats, moreover,
reflect that Manning actively took steps to try to conceal herself as the source of the leaks. Thus,
the context of the agreement demonstrates that Assange and Manning intended to crack the
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I. BACKGROUND OF CO-CONSPIRATORS
10. Although associates and volunteers worked for WikiLeaks in various capacities,
WikiLeaks was closely identified with Assange himself. As reported in an article published in
Wired magazine in or around September 2010, Assange stated, "I am the heart and soul of this
organization, its founder, philosopher, spokesperson, original coder, organizer, financier, and all
the rest." As stated by Assange in a January 2010 interview during the 26th Chaos
Communication Congress, WikiLeaks had a fiill-time staff of five and 800 "occasional helpers."
Assange has also stated that he made the final decision as to whether a particular document
11. Assange, who has never possessed a security clearance or need to know, was
12. Manning, a United States citizen, enlisted in the U.S. Army in October 2007 and
subsequently attended the U.S. Army Intelligence Analyst Course at Fort Huachuca, Arizona.
Agreement. In doing so. Manning acknowledged being advised that unauthorized disclosure or
^At some pointbetween September and December 2010, WikiLeaks deleted the word
"classified" fi-om a description of the kinds of material it accepted.
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14. On January 22, 2009, Manning was granted a U.S. government security clearance
at the "Top Secret" level and signed a Sensitive Compartmented Information (SCI)
Nondisclosure Statement. In so doing. Manning acknowledged that she would be granted access
to SCI material, which involves or derives from intelligence sources or methods and is classified
or in the process ofbeing classified. She further acknowledged being advised that her
unauthorized disclosure or retention or negligent handling of SCI could cause irreparable injury
to the United States or be used to advantage by a foreign nation, and could constitute a federal
crime.
15. Executive Order No. 13526 and its predecessor orders define the classification
levels assigned to national security and national defense information. Under Executive Order
reasonably could be expected to cause damage to the national security; "Secret" if its
unauthorized disclosure reasonably could be expected to cause serious damage to the national
security; and "Top Secret" if its unauthorized disclosure reasonably could be expected to cause
16. On or about October 12, 2009, Manning was deployed as a Military Occupational
Specialty ("MOS") 35F - Intelligence Analyst, to Forward Operating Base ("FOB") Hammer in
Iraq.
17. Manning worked as an intelligence analyst in Iraq from October 2009 to May
2010. During that time, she had access to classified national defense information through
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various U.S. Army and DoD computer network systems, including SIPRNet—a. network used for
classified documents and communications at the Confidential and Secret levels, as designated
18. Manning had access to multiple classified databases and websites on SIPRNet,
including the following: (1) the Combined Information Data Network Exchange ("CIDNE"), a
set of DoD databases containing classified reports regarding the Afghanistan and Iraq wars,
many of which contained raw intelligence information such as source names and locations; (2) a
civilian deaths caused by U.S. forces; (3) an Intellipedia website named "JTF-GTMO Detainee
Assessments," which included documents regarding detainees at the U.S. Naval Base in
Guantanamo Bay, Cuba; (4) Net Centric Diplomacy ("NCD"), a Department of State database
containing classified diplomatic cables; and (5) an Intelink-S search engine, which was a web
portal that provided U.S. intelligence agencies with a single point of service to search for
Facility ("SCIF"). Under Executive Order No. 13526, Section 4.1, and Army regulations.
Manning was prohibited firom removing classified information firom the SCIF in which she
worked, fi"om storing the information in her residential quarters, and firom loading the
information onto a personal computer. Further, the act of removing classified media firom a
SCIF and hand carrying that information was permitted only when approved by the appropriate
official.
20. In the SCIF, Manning had access to several SIPRNet computers, two of which she
principally used at different times. In this affidavit, I refer to these two computers as "IPl" and
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"IP2."
21. Manning's use ofthe computers was also governed by the AR-25-2. The AR-25-
2 is an Army regulation that establishes the standards, processes, and procedures for information
assurance practices in the United States Army. It applies to everyone within the Army.
22. In March 2010, the AR-25-2 prohibited certain "activities ... by any authorized
mechanisms." The AR-25-2 also prohibited "[s]haring personal accounts and authenticators
(passwords or PINs)."
23. According to Manning, she began helping WikiLeaks soon after WikiLeaks
publicly released messages from the September 11, 2001 terrorist attacks on November 25, 2009.
24. As the examples in the following two sections demonstrate, Manning transmitted
a large amount of classified information to WikiLeaks prior to March 2010, which was when she
formed the agreement with Assange that is the subject of this complaint.
25. During her court-martial proceedings. Manning has admitted that, prior to March
2010, she provided WikiLeaks with classified significant activity reports from the Iraq and
Afghanistan wars ("Iraq War Reports" and "Afghanistan War Reports," respectively).
26. According to Manning, she downloaded the Iraq War Reports and Afghanistan
War Reports from the relevant CIDNE databases in late December 2009 and early January 2010,
and initially saved the records on a CD-RW that she kept in her SCIF. Manning admitted that
she later took the CD-RW out of the SCIF and copied the data from the CD-RW onto her
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personal laptop. Manning stated that she transferred the data from her laptop to a Secure Digital
("SD") memory card, which she took with her when she went on leave later in January 2010.
27. Investigators later recovered the SD card that Manning used to transport the Iraq
War Reports and Afghanistan War Reports. Forensic analysis of the SD card revealed that it
contained the CIDNE databases for Iraq (391,883 records) and Afghanistan (91,911 records).
The SD card also contained a README.txt file, which contained the following message:
28. According to Manning, she uploaded the Iraq War Reports, Afghanistan War
Reports, and README.txt file to the WikiLeaks website on or around February 3, 2010.
29. WikiLeaks publicly released the Iraq War Reports and Afghanistan War Reports
on its website later in 2010. In July 2010, WikiLeaks released approximately 76,000 of the
Afghanistan War Reports. Then, in October 2010, WikiLeaks released approximately 391,832
30. Manning and WikiLeaks had reason to believe that public disclosure of the
Afghanistan War Reports and Iraq War Reports would cause injury to the United States.
Documents included in the Afghanistan War Reports contained information the disclosure of
which potentially endangered U.S. troops and Afghan civilians, and aided enemies of the United
States. Numerous Secret reports, for example, related to the identity and significance of local
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31. In fact, according to a July 30, 2010 New York Times article entitled "Taliban
Study WikiLeaks to Hunt Informants," after the release ofthe Afghanistan War Reports, a
member of the Taliban contacted the New York Times and stated, "We are studying the report.
We knew about the spies and people who collaborate with U.S. forces. We will investigate
through our own secret service whether the people mentioned are really spies working for the
U.S. If they are U.S. spies, then we will know how to punish them."
32. Moreover, on May 2, 2011, United States government officials raided the
compound of Usama bin Laden in Abbottabad, Pakistan. During the raid, they collected a
number of items of digital media, which included, among other things, (1) a letter firom bin
Laden to another member of the terrorist organization al-Qaeda in which bin Laden requested
that the member gather the DoD material posted to WikiLeaks, and (2) a letter from that member
of al-Qaeda to Bin Laden with information from the Afghanistan War Reports released by
WikiLeaks.
33. In addition, some of the Afghanistan War Reports included detailed reports of
improvised explosive device ("lED") attacks on United States and Coalition forces in
Afghanistan. The enemy could use these reports to plan future lED attacks because they
described lED techniques, devices, and explosives, and revealed the countermeasures used by
United States and Coalition forces against lED attacks and potential limitations to those
countermeasures,
34. I have reviewed a number of the Afghanistan War Reports and Iraq War Reports
that WikiLeaks released. The reports that I reviewed contained classification markings reflecting
that they were classified as "SECRET." This suggests that the versions of the Afghanistan War
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Reports and Iraq War Reports that Manning transmitted to WikiLeaks clearly reflected that they
were classified.
36. According to Manning, she accessed the NCD portal on February 14, 2010, and
found a cable entitled "10 Reykjavik 13," which addressed an Icelandic issue known as
"Icesave." Manning admitted that she burned the information onto a CD-RW on February 15,
2010, took it to her personal housing unit, saved the document to her personal laptop, and then
uploaded it to WikiLeaks.
37. WikiLeaks released this "Icesave" cable on its website on or around February 18,
2010. I have reviewed the document that WikiLeaks released on its website. It contained clear
markings reflecting it was classified as "Confidential," That suggests that the version of the
Icesave cable that Manning transmitted to WikiLeaks clearly reflected that it was classified.
38. In addition, on February 14,2010, Manning, using IPl identified to her, viewed
the Intellipedia website for Iceland. From this website. Manning clicked on links to, and viewed,
examination of Manning's personal laptop computer showed that a storage device was inserted
into her machine. The volume name of the CD—"100215_0621"—vindicated that the CD was
burned on February 15, 2010, at 6:21 a.m. The file names "Jonsson.pdf," "Sigurdardottir.pdf,"
39. On March 29, 2010, WikiLeaks posted on its website classified U.S. State
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Sigurdardottir; Icelandic Minister of Foreign Affairs and External Trade Ossur Skarphedinsson;
and Icelandic Ambassador to the United States Albert Jonsson. I have reviewed the three
biographies released by WikiLeaks. They contained clear markings indicating that they were
classified as "Confidential."
40. Thus, as the examples in these two sections demonstrate. Manning provided
received and published the classified documents, despite their clear markings indicating that they
were classified.
41. A person assigned a name with initials '"NF" held a series of online chat
conversations with Manning in which the pair discussed providing classified documents to
WikiLeaks and the protection of Manning's identity as a source of the documents. According to
the dates on the chats, they occurred between March 5, 2010, and March 18,2010. During the
chat conversations, Manning used the alias "Nobody" and the account
42. Those chats took place on the "Jabber" chat server. Jabber is used for real-time
instant messaging. Manning and NF used a Jabber chat service hosted on jabber.ccc.de. "CCC"
is a commonly used acronym for the Berlin-based Chaos Computer Club, which according to
conversation often" with NF, "sometimes as long as an hour or more." Forensic analysis showed
that Manning deleted or removed the NF chat logs fi"om her laptop. Nevertheless, investigators
have been able to recover several portions of the chats between Manning and NF from
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44. A complete copy of the recovered chats between Manning and NF is attached to
45. At her court-martial proceeding, Manning claimed that she believed the individual
with whom she was chatting "was likely Mr. Julian Assange, Mr. Daniel Schmidt, or a proxy
46. As summarized below, however, the evidence demonstrates that Assange was the
47. Specific information provided by NF in the March 2010 chats indicates that NF
was Assange. For example, when chatting with Maiming on March 5, 2010, NF confided that he
liked debates, and that he "[j]ust finished one on the IMMI, and crushed some wretch firom the
journalists union." NF told Manning that the debate was "[v]ery satisfying," and that "the
husband of the wretch" had exposed a source, an IT consultant who had given NF "10Gb of
banking documents."
48. "IMMI" refers to the Icelandic Modem Media Initiative, a legislative proposal of
considerable public interest in Iceland at the time. According to accounts available on the
Internet, on March 5,2010, before NF's chat with Manning about a debate, the University of
Iceland presented a panel that discussed media topics, including the IMMI. Assange was a
member of that panel, as was the female deputy president of the Icelandic journalists association.
49. Moreover, the NF in the March 2010 chats with Manning appeared to have
of information to the organization, as well as of financial matters. During the chats, on March 8,
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2010, and March 16, 2010, Manning asked NF about the financial state of WikiLeaks. On both
such as losing its credit card vendor. NF also stated that WikiLeaks had raised half a million of
50. Further, the NF in the chats with Manning mentioned that he planned to attend a
told Manning that NF would "be doing an investigative joumo conf in norway this week end, so
may be out of contact most of the time." In fact, on March 18, 2010, according to an article on
the Internet authored by Assange, Assange traveled from Iceland eventually to Oslo, Norway,
list of individuals scheduled to attend the conference, and Assange was identified as a "lecturer."
A review of the other names on the list revealed no other persons known to be associated with
WikiLeaks, and no one named NF. Further, SKUP's website had a photo ofAssange speaking at
the conference.
51. In addition, NF repeatedly discussed with Manning details about a video being
prepared for release, which NF referred to as "Project B." As reported in the New Yorker on
June 7,2010, "Project B" was the code name Assange and WikiLeaks used for the video about
the 2007 Apache helicopter attack, later released under the name "Collateral Murder."
52. Also, on June 27, 2011, the FBI interviewed U.S. Person No. 1 (USl), who met
Assange in December 2009 in Berlin, Germany. According to USl, Assange and USl
exchanged email addresses at this time and began communicating via email. Eventually,
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Assange and USl began using the Jabber instant messaging service to communicate. According
USl via Jabber. Assange used pressassociation@jabber.ccc.de until the summer of 2010 to
communicate with USl. As noted, pressassociation@jabber.ccc.de was the Jabber account used
53. The evidence further reflects that Manning believed NF was Assange. In chats
with U.S. Person No. 2 (US2) on May 23, 2010, Manning stated that Assange "*might*" have
used the "ccc.de jabber server," the same server used in the chats between NF and Manning.
And on May 22,2010, Manning told US2 that she had communicated with Assange when
explaining that she was a source for WikiLeaks. Manning stated, "im a high profile source... and
i've developed a relationship with assange... but i don't know much more than what he tells me,
which is very little, it took me four months to confirm that the person i was communicating was
in fact assange."
May 28, 2010, revealed that pressassociation@jabber.ccc.de was associated with Assange in
Manning's "Buddy List" configuration file (blist.xml), and that deleted versions of Manning's
blist.xml file identified pressassociation@jabber.ccc.de as an alias for NF. The file had a
55. Based on this evidence, I have concluded that Manning's partner in the chats,
assigned the usemame "NF," was in fact Assange. Accordingly, in the following discussion of
the March 2010 chats, I identify Assange as the person with whom Manning communicated.
56. As the below examples illustrate, the recovered chats between Manning and
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Assange reflect that the two collaborated on Manning's disclosure of classified information to
1. JTF-GTMO Documents
57. At her court-martial proceeding, Manning admitted that she provided WikiLeaks
with Joint Task Force Guantanamo ("JTF-GTMO") Detainee Assessment Briefs ("DABs") in
58. In fact, Attachment A reflects discussions between Manning and Assange about
59. On March 7, 2010, Manning asked Assange, "how valuable are JTF GTMO
detention memos containing summaries, background info, capture info, etc?" Assange replied,
"time period?" Manning answered, "2002-2008." Assange responded, "quite valuable to the
lav^^ers of these guys who are trying to get them out, where those memos suggest their
innocence/bad procedure...also valuable to merge into the general history, politically gitmo is
60. Manning has admitted that "[a]fter this discussion, [she] decided to download the
DABs."
61. On March 8, 2010, Manning told Assange, "im sending one last archive of
interesting stuff... should be in the x folder at some point in the next 24 hours." Assange replied,
"ok. great!" Manning added, "you'll need to figure out what to do with it all..."
62. Later that day. Manning wrote to Assange, "anyway, im throwing everything i
got on JTF GTMO at you now... should take awhile to get up tho...summary/history/health
conditions/reasons for retaining or transfer of nearly every detainee (about 95%)." Assange
replied, "ok, great! what period does it cover for each internment?" Manning replied "2002-
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evaluation?"
63. Also on March 8, 2010, Manning updated Assange about the ongoing upload,
stating that the "upload is at about 36%." Assange asked for an "ETA," to which Manning
responded "11-12 hours... guessing since its been going for 6 already." Assange asked, "how
many mb?" Manning replied "about 440mb" and "a lot of scanned pdf[']s."
64. Two days later, on March 10,2010, Assange reported to Manning, "there[']s a
usemame in the gitmo docs" and asked "i assume i should filter it out?" Manning stated that
"any usemames should probably be filtered, period." Manning then recognized, "but at the same
65. Later in the chat on March 10, 2010, Manning asked, "anything useful in there?"
Assange replied "no time, but have someone on it." Assange then followed up that "there surely
will be" and that "these sorts of things are always motivating to other sources too." Assange
noted that such disclosures provided "inspiration" for other leakers because "gitmo=bad,
66. WikiLeaks ultimately released the JTF-GTMO DABs starting in April 2011. By
67. As General Robert Carr testified during Manning's court martial, the release of
the DABs caused problems for the United States' efforts to move detainees out of Guantanamo
Bay to other countries. According to General Carr, at the time of the release ofthe DABs, the
Department of State was negotiating with foreign governments regarding the transfer of the
detainees. The release of the classified DABs threatened to conflict with those negotiations.
68. I have reviewed a number of the JTF-GTMO DABs that WikiLeaks released.
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They contained clear markings indicating that they were classified as "SECRET."
69. The March 2010 chats also reveal that Assange provided Manning with
70. On March 8,2010, when discussing the JTF GTMO upload. Manning told
Assange, "after this upload, thats all i really have got left." Assange replied, "curious eyes never
71. hi response, Manning stated, "ive already exposed quite a bit, just no-one knows
yet. ill slip into darkness for a few years, let the heat die down." Manning added, "considering
just how much one source has given you, i can only imagine the overl[o]ad."
72. Earlier in the same day, Assange noted that there had been "2500 articles in .is
referendum in the past 15 hours, despite it being a Sunday." (The domain name for Iceland is
".is.") Manning stated, "oh yeah.. .osc went haywire digging into .is." (Based on the context, in
using the term "osc," Manning likely was referring to the CIA's open source center.) Assange
73. During his chats with Manning, Assange asked whether documents sent by
Manning about an arrest by Iraqi police were "releasable." Manning advised Assange that
certain documents could be released, but that an original incident report could not be, and that a
translation of a report was "super not releasable." Assange asked that Manning "be sure to tell
me these things as soon as possible," and "better yet in the submission itself," since Assange was
"not the only one to process this stuff and also will forget details if publication is delayed a long
time due to the flood of other things." After Manning asked if Assange was "gonna give release
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a shot?," Assange opined that a lack of detail in the releasablematerial "may be problematic,"
Manning suggested that WikiLeaks could refer to a hotel located near where the arrest occurred;
she "figured it would make it look more like a journalist acquired it... ifthe hotel was
mentioned." Manning also advised Assangethat she was "all over the place ... clearing logs,"
and that she was "not logging at all... safe .... i just wanted to be certain."
74. Thus, in the quoted communications Manning and Assange discussed the form in
which WikiLeaks could disclose the information about the arrest by Iraqi police, and the
suppression ofparticular material that if released might reveal Manning's identity as the source.
75. In addition. Manning assured Assange that by "clearing logs" she was taking the
proper steps to prevent discovery, by leaving no trace on her computer of their communications.
4. Assange's Knowledge That Manning Was In The U.S. Armed Forces In Iraq
*
76. The March 2010 chats between Manning and Assange included military jargon
and references to current events in Iraq suggesting that Assange knew Manning was an American
77. For example, on March 6, 2010, Assange asked Manning, "it looks like a MiTT
report?" MiTT is a military acronym for Military Transition Team, a team that trains local Iraqi
troops.
78. On March 18, 2010, Manning used the military term "MI" (for Military
Intelligence) in a chat with Assange. Later that day, Assange wrote to Manning, "but
remember...rules are just for the grunts..." in response to a discussion about the breaking of rules
by an Army Lieutenant Colonel and senior officers. "Grunts" is military slang for enlisted
79. Further, Manning made several references to specific events and places in Iraq
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(including the Tigris River) that indicated Manning was then in Iraq.
80. As described below, during their March 2010 chats. Manning and Assange
reached an agreement for Assange to assist Manning in cracking a password related to two
computers with access to classified national security information. I understand the following
81. A computer using a Microsoft Windows operating system does not store users'
passwords in plain text for security reasons. Instead, the computer stores passwords as "hash
values." When a user creates a password for the relevant usemame, the password passes through
a mathematical algorithm, which creates a "hash value" for the password. Essentially, the
creation of the hash value is a form of encryption for storing the password. The hash value—^not
82. As additional security, the computer does not store the full hash value in one
location. Instead, the hash value for that usemame is broken into two parts. One part is stored in
the Security Accounts Manager (SAM) database as the SAM registry file. The SAM file in a
Windows operating system keeps usemames and parts of the hash value associated with the
usemame. The other part of the hash is stored in the "system file." To obtain the fiill hash value
associated with the password, one needs the parts fi"om the SAM file and the system file.
83. Finally, as further security, Windows locks the SAM file and system file. Only
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84. However, even if a user does not have administrative level privileges, the user
might be able to access the system file or the SAM file by using special software, such as a
Linux operating system. A person, for example, can reboot a computer using a CD with the
Linux operating system and view the contents of the SAM file or system file.
85. The evidence suggests that Manning did just that. Forensic analysis of Manning's
personal laptop computer reflects that she burned the Linux operating system to a CD on or
around March 2, 2010. Through forensic analysis, investigators have further determined that
Manning therefore could have viewed the SAM file ofboth IPl and IP2—^the SIPRNet
computers that Maiming primarily used—^by rebooting them with the Linux operating system
86. On March 8, 2010, at approximately 3:55 p.m., Manning asked Assange whether
a. At the time, Windows operating systems commonly used two methods for
hashing and storing passwords, Lan Manager (LM) and New Technology Lan
asked Assange if he was able to crack passwords for computers running Windows
operating systems.
stated, "we have rainbow tables for Im." A "rainbow table" is a tool used to crack a hash value
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operating system version Vista or newer, LM is disabled, and only NTLM is used.
Manning's remark that she "thought" that the hash was "Im + Imnt" suggests that
89. A few minutes later, Manning further explained, "not even sure if thats the
hash....i had to hexdump a SAM file, since i don't have the system file." Assange asked, "what
makes youthink [it's] Im?"^ Assange asked, "its from a SAM?" Manning answered "yeah."
a. hi the above-described chats Manning informed Assange that she had accessed
the SAM file with a program and had identified this particular 16-byte
b. By saying she retrieved the password hash through a "hexdump," Manning likely
meant that she used a sofl;ware program to view the SAM file in "hexadecimal
90. Two days later, at approximately 11:30 p.m. on March 10, 2010, Assange
followed up on the issue. Assange messagedManning and asked, "any more hints about this Im
and there is no other evidence as to what Assange did, if anything, with respect to the password.
^The numbers provided by Manningwere part of, but not the full, hash. Manning would have
needed the part of the hash from the system file as well to obtain the fiill value.
22
Case 1:18-cr-00111-CMH Document 2 Filed 12/21/17 Page 23 of 40 PageID# 24
The next chats that investigators were able to recover were dated March 16,2010. Thus, there is
approximately a six-day gap in the chats after Assange asked for further hints on the hash.
92. Nevertheless, the recovered chats described above reflect an agreement between
93. Forensic investigators have determined that the hash that Assange agreed to help
94. Using an image of Manning's SIPRNet computer hard drives, the forensic
investigator booted it with the same Linux operating system that Manning burned to a CD on her
personal computer.
95. The forensic investigator then navigated to the SAM file on the computers. Using
a hex editor, the investigator was able to view and obtain the precise hash value that Manning
forwarded to Assange.
96. The hash value that Manning forwarded to Assange was associated with the
password for an "FTP" user on IPl and IP2. The FTP user was not attributable to any specific
person.
97. Although there is no evidence that the password to the FTP user was obtained,
had Manning done so, she would have been able to take steps to procure classified information
under a usemame that did not belong to her. Such measures would have fhistrated attempts to
98. On May 27, 2010, based on information provided by US2, Army investigators in
Iraq took Manning into military custody at FOB Hammer. Manning was subsequentlycharged
23
Case 1:18-cr-00111-CMH Document 2 Filed 12/21/17 Page 24 of 40 PageID# 25
99. On July 30, 2013, Manning was convicted of most ofthese charges, including
unlawftil gathering or transmission of national defense information, computer intrusion, and theft
of government property. Manningwas acquitted of aiding the enemy and of one count of 18
100. Meanwhile, beginning as early as November 2010 and as late as April 2017,
media outlets reported that the Departmentof Justice was investigating charges against
international arrest warrant was issued against Assange. Following litigation between December
2010 and May 2012, the United Kingdom (U.K.) Supreme Court determinedthat Sweden's
extradition request had been lawfully made, and the U.K. had ten days to take Assange to
Sweden. Instead of appealingto the European Court of Human Rights, in June 2012, Assange
fled to the Ecuadorian embassy in London. Ecuador formally granted Assange diplomatic
asylum on August 16, 2012, "citinghis well-founded fears of political persecution and the
possibility of the deathpenaltywerehe sent to the United States." Specifically, Assange feared
that "ifhe were to be sent to USA, he might be prosecuted and perhaps be executed by a military
court in regard to his involvement in the release of stolen and leaked American documents on its
http://www.aalco.int/Ruling%20of%20UNWGAD%20on%20Julian%20Assange.pdf.
24
Case 1:18-cr-00111-CMH Document 2 Filed 12/21/17 Page 25 of 40 PageID# 26
102. Assange has made numerous comments reflecting that he took refuge in the
103. For example, in 2013, the WikiLeaks website posted an affidavit by Assange
concerning alleged monitoring of his activities and the search and seizure of his property. In this
affidavit, Assange acknowledged that he was "granted asylum after a formal assessment by the
government of Ecuador in relation to the current and future risks of persecution and cruel,
inhuman and degrading treatment in the United States in response to my publishing activities and
my political opinions. I remain under the protection of the embassy of Ecuador in London for
investigation regarding suspected rape by Julian Assange, Assange publicly stated, "While today
was an important victory and an important vindication ... the road is far fi*om over The
war, the proper war, is just commencing. The UK has said it will arrest me regardless. Now the
United States, CIA Director Pompeo, and the U.S. Attorney General have said that I and other
WikiLeaks staff have no rights ... we have no first amendment rights.. .and my arrest and the
arrest of our other staff is a priority.... The U.K. refuses to confirm or deny at this stage
whether a U.S. extradition warrant is already in the U.K. territory. So, this is a dialogue that we
want to happen. Similarly, with the United States, while there have been extremely threatening
remarks made, I am always happy to engage in a dialogue with the Department of Justice about
prosecutors-to-drop-rape-investigation-against-assange.
25
Case 1:18-cr-00111-CMH Document 2 Filed 12/21/17 Page 26 of 40 PageID# 27
CONCLUSION
105. The evidence summarized in this Affidavit establishes probable cause to believe
that the defendant, Julian P. Assange, committed the offense alleged in the complaint; namely,
Assange violated 18 U.S.C. § 371 by conspiring to (1) access a computer, without authorization
and exceeding authorized access, to obtain classified national defense information in violation of
18 U.S.C. § 1030(a)(1); and (2) access a computer, without authorization and exceeding
authorized access, to obtain information from a department or agency of the United States in
Respectfully submitted,
26
Case 1:18-cr-00111-CMH Document 2 Filed 12/21/17 Page 27 of 40 PageID# 28
Attachment A
Case 1:18-cr-00111-CMH Document 2 Filed 12/21/17 Page 28 of 40 PageID# 29
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-05 21:15:04 needed to offload them so they'd stop going
after him
dawgnetwork@jabber.ccc.de Nobody 2010-03-05 21:17:31 >yawn<
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-05 21:19:26 tired?
dawgnetwork@jabber.ccc.de Nobody 2010-03-05 21:20:54 waking up =)
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-05 22:53:22 ping
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-05 23:41:17 ping
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 00:31:55 here
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 00:32:52 pong
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 00:39:19 ...and zero reply status =P
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:40:54 ping
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:41:22 ping
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:41:27 pong
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:41:34 can you tell me more about these files?
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:41:41 or the status of the issue?
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:41:58 uhmm... no new information... everybody is focused
on the election
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:42:07 what's the caps thing?
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:42:15 caps?
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:42:22 CAPS
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:42:38 who's the author?
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:42:39 and are all these releasable?
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:42:42 so much going on... ahhhh
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:42:46 what about the english translation?
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:42:55 yes
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:42:55 everything is notes
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:43:02 minus the photos
dawgnetworl<@jabber.ccc.de Nobody 2010-03-06 06:43:13 the photos are releasable
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:43:29 ok, what about the incident report?
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:43:52 cant release the original, but the information can be
scraped from it
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:44:08 i.e. sources indicate this happened at this place at
this time
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:44:17 yup
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:44:38 it looks like a MiTT report?
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:44:39 translation is super not releasable
Case 1:18-cr-00111-CMH Document 2 Filed 12/21/17 Page 29 of 40 PageID# 30
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-06 06:59:09 i.e ":easier": stories for press to get
dawgnetwork@jabber.ccc.de Nobody 2010-03-06 06:59:10 im sure you can try to confirm SOMETHING... there is
a hotel called the Hotel Ishtar nearby to that location
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:11:03 a lot of odd things are happening lately
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:11:08 such as?
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:11:48 it's hard to describe without going through them
ail
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:11:53 but there&aposis something in the air.
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:12:07 in Iceland, or globally
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:12:40 this is what l&apos:m trying to detenmine. people in
germany say the same thing
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:12:49 and there's some evidence of that
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:13:13 such as... (i hate to inquire too much, but im benign)
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:13:36 it may be more readily visible in .is due to less inertia
[small economy]
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:14:09 definitely feel something odd here...
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:14:38 some recent things... in denmark the main newspaper
printed an entire book in afghanistan that was about
to be injuncted suddenly in its Sunday paper
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:19:10 1had an account there, but changed ips too quickly
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:19:16 usually its pretty dull reading, one or two things on .is
a day... but its like 20-25 for today alone
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:19:40 just FBIS or analysis included?
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:19:54 no analysis, too early...
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:20:03 24-48 hours it takes for analysis if done
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:22:01 anyway, im throwing everything i got on JTF GTMO at
you now... should take awhile to get up tho
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:23:22 summary / history / health conditions / reasons for
retaining or transfer of nearly every detainee (about
95%)
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:24:01 ok, great!
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:24:15 what period does it cover for each internment?
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:24:48 2002-2009...
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:25:21 so initial medical evaluation to exit evaluation?
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:25:37 no, just summaries...
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:25:52 but summaries of that?
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:26:26 i.e from entry to exit?
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:26:31 not quite
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:26:33 gaps
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:26:50 where do the gaps come from?
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:26:58 Memos such asSUBJECT: Recommendation to
Retain under DoD Control (DoD) for Guantanamo
Detainee.<br />ISN; US9AS-000002DP
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:27:51 i have a csv that organizes the info as much as
possible
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:27:55 1 hate these gitmo guys
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:28:29 OFAFBU sums up the sort of people they ended up
with
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:28:48 [one flight away from being ugly] aka ":gitmo
cute"
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:28:56 haha
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:30:57 anyway, gotta run, have a nice day
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:31:14 you too. and take care!
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:31:42 after this upload, thats all i really have got left
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:32:15 curious eyes never run dry in my experience
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:32:18 i sat on it for a bit, and figured, eh. why not
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:32:52 ive already exposed quite a bit, just no-one knows yet
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:33:34 illslip into darkness for a few years, let the heat die
down
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:34:05 won't take a few years at the present rate of
change
dawgnetwork@jabber.ccc.de Nobody 2010-03-08 06:34:08 true
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-08 06:34:19 almost feels like the singularity is coming
there's such acceleration
Case 1:18-cr-00111-CMH Document 2 Filed 12/21/17 Page 33 of 40 PageID# 34
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 05:59:30 and they came back with the last 4 months of
parliament
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 05:59:47 xD
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 05:59:49 hilarious
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:00:40 thats a wtf... who did this kind of moment
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:00:54 fall-out =P
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 06:00:55 So, that's what 1think the future is like;)
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 06:01:15 yes
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:01:57 now that humans are getting more and more
integrated into this information society... a level of
transparency never imagined or even truly desired is
coming into play
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:02:18 it makes us more human if anything
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:03:13 we've created states, governments, religious
institutions, corporations... all these organizations to
hide behind...
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:03:26 but at the end of the day, we&apos:re just guys and
girls
Case 1:18-cr-00111-CMH Document 2 Filed 12/21/17 Page 35 of 40 PageID# 36
dawgnetworl<@jabber.ccc.de Nobody 2010-03-10 06:11:24 basic gist: retired general takes over a toy company,
invests in video games for kids to "play":,
but they're actually training to remotely use
little toy sized weapons
dawgnetworl<@jabber.ccc.de Nobody 2010-03-10 06:11:40 former toy owner tries to stop him
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:11:52 •company
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 06:12:11 heh. that's the example 1was going to use for
mmorpg (with drones) but decided it was too
grotesque
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:12:47 its not... its logical in frightening ways
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:13:04 i think like that... i dont know how it happened, but i
think that way
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 06:13:32 i predict war will turn into a continuous spectrum of
spying and violence
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:13:32 ":how can i take advantage of two things that
most people wouldn't think are
connected"
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 06:15:50 with companies doing a lot of the lower end
{spying/violence} for their own reasons and a totally
seemless crossover (as is happening with the us)
between contractors/military to the degree that its not
clear who is tasking who
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:16:12 wow, dead on
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 06:16:57 everywhere, greater degrees of freedom, more fluidity
and mixing.
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:17:23 always an interesting discussion =)
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 06:17:26 ttyl
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 06:17:31 night!
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 20:58:03 hello
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 20:59:41 heya!
dawgnetwork@jabber.ccc.de Nobody 2010-03-10 20:59:52 whats new?
Case 1:18-cr-00111-CMH Document 2 Filed 12/21/17 Page 36 of 40 PageID# 37
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 21:06:37 They're important because their organized free
labor.
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-10 21:06:54 And they may or may not break free of their masters.
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-17 22:59:09 via email or any other mechanism
dawgnetwork@jabber.ccc.de Nobody 2010-03-17 22:59:15 >nod<
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-17 22:59:44 will be doing an investigative journo conf in norway
this week end, so may be out of contact most of the
time
dawgnetwork@jabber.ccc.de Nobody 2010-03-17 22:59:55 its good
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-17 23:00:17 ok.
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-17 23:00:27 off to do some work.
dawgnetwork@jabber.ccc.de Nobody 2010-03-17 23:00:43 k, but def read the reflection i sent
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-17 23:00:53 iwill
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-17 23:01:01 now
dawgnetwork@jabber.ccc.de Nobody 2010-03-17 23:34:21 food meaning money, of course... and treatment
being, well, treatment
dawgnetwork@jabber.ccc.de Nobody 2010-03-17 23:34:42 weird analogy, i know... lol
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-17 23:38:21 yes
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-17 23:38:34 that's possible
pressassociation@jabber.ccc.de Nxxxxxxxx Fxxxx 2010-03-17 23:39:09 and there are social vales that arise out of the internet
that have evolved beyond those inside the isolated
military-contractor complex
dawgnetwork@jabber.ccc.de Nobody 2010-03-18 00:04:31 its like a classroom run by an overbearing teacher...
when a kid strikes back anonymously by sabotaging
the desk... the other kids get a little excited and
rowdy, because they wanted too, but were afraid of
getting caught... the teacher is embarassed and cant
control the kids, so the teacher just makes an
announcement that the students should continue
working quiety after they have a look at the mess on
the desk that the teacher is cleaning up