IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
Alexandria Division
[date stamped:] May 16, 2001
UNITED STATES OF AMERICA ) CRIMINAL NO. 01-188-A
)
v. ) Count 1: Conspiracy to Commit
) Espionage
ROBERT PHILIP HANSSEN, ) 18 U.S.C. § 794(c)
)
) Count 2-20: Espionage
) 18 U.S.C. § 794(a)
)
) Count 21: Attempted Espionage
) 18 U.S.C. § 794(a)
)
) Forfeiture
) 18 U.S.C. § 794
MAY 2001 TERM -- AT ALEXANDRIA
INDICTMENT
THE GRAND JURY CHARGES THAT:
GENERAL ALLEGATIONS
At all times material to this indictment:
1. The defendant ROBERT PHILIP HANSSEN was a Special Agent
of the Federal Bureau of Investigation (FBI), who entered on duty
with the FBI on January 12, 1976, and served continuously until
February 18, 2001. For most of his FBI career, defendant HANSSEN
worked in the FBI's Intelligence Division, renamed the National
Security Division. In that capacity, defendant HANSSEN worked
with, and had access to, classified information relating to the
foreign intelligence and counterintelligence activities of the
FBI and other United States Intelligence Community agencies,
including the Central Intelligence Agency (CIA), the National
Security Agency (NSA), and the Defense Intelligence Agency (DIA).
2. From in or about January 1981 to in or about September
1985, defendant HANSSEN was assigned to FBI Headquarters in
Washington, D.C. From in or about September 1985 to in or about
August 1987, defendant HANSSEN was assigned to the FBI Field
Office in New York, New York. In or about August 1987, he
returned to Washington, D.C., where he served in a variety of FBI
assignments until February 18, 2001.
3. Upon entering on duty with the FBI on January 12, 1976,
defendant HANSSEN signed an Oath of Office in which he swore
that: "I will support and defend the Constitution of the United
States against all enemies, foreign and domestic; that I will
bear true faith and allegiance to the same; that I take this
obligation freely, without any mental reservation or purpose of
evasion; and that I will well and faithfully discharge the duties
of the office on which I am about to enter. So help me God."
That same day, he signed the FBI Pledge for Law Enforcement
Officers, in which he pledged, in part: "I accept the obligation
in connection with my assignments to . . . consider the
information, coming into my knowledge by virtue of my position as
a sacred trust, to be used solely for official purposes. . . . In
the performance of my duties and assignments, I shall not engage
in unlawful and unethical practices."
4. Executive Order 12958 and its predecessor orders
establish that information in any form that (1) is owned by,
produced by or for, or under the control of the United States
Government, and (2) falls within any of the categories set forth
in Section 1.5 of the Order (including: intelligence sources or
methods; cryptology; military plans; and vulnerabilities or
capabilities of systems, installations, projects or plans
relating to the national security), may be classified by an
original classification authority who determines that the
unauthorized disclosure of such information reasonably could be
expected to result in damage to the national security. Where
such damage would be "serious", the information may be classified
as SECRET. Where such damage would be "exceptionally grave", the
information may be classified as TOP SECRET. Access to
classified information at any level may be further restricted
through compartmentation in SENSITIVE COMPARTMENTED INFORMATION
(SCI) categories. Dissemination of classified information at any
level may also be restricted through caveats such as NOFORN (Not
Releasable to Foreign Nationals) or ORCON (Dissemination and
Extraction of Information Controlled by Originator), and was
formerly likewise restricted through the caveats NOCONTRACT (Not
Releasable to Contractors or Contractor/Consultants) and WNINTEL
(Warning Notice: Intelligence Sources and Methods Involved).
5. Defendant HANSSEN held TOP SECRET clearances
continuously from the time he joined the FBI in 1976, and was
indoctrinated for access to a variety of SCI programs.
Specifically:
a. Upon entering on duty with the FBI, on January 12,
1976, defendant HANSSEN signed an Employment Agreement in which
he acknowledged that:
I understand that Federal Law such as Title 18, United
States Code, Sections 793, 794, and 798; . . .
(Executive Order 11652); and regulations issued by the
Attorney General . . . prohibit loss, misuse, or
unauthorized disclosure or production of national
security information, other classified information and
other nonclassified information in the files of the
FBI; . . . I understand that unauthorized disclosure of
information in the files of the FBI or information I
may acquire as an employee of the FBI could result in
impairment of national security, place human life in
jeopardy, . . . or prevent the FBI from effectively
discharging its responsibilities. . . . I agree that I
will never divulge, publish, or reveal either by word
or conduct, or by any other means disclose to any
unauthorized recipient without official written
authorization . . . any information from the
investigatory files of the FBI or any information
relating to material contained in the files, or
disclose any information or produce any material
acquired as part of the performance of my official
duties or because of my official status . . .
b. On various occasions throughout his FBI employment,
defendant HANSSEN signed various iterations of the Nondisclosure
Agreement for Sensitive Compartmented Information, in which he
acknowledged that he had received security indoctrinations and
understood, among other things, that he had been advised that the
direct or indirect unauthorized disclosure by him of SCI
information "could cause irreparable injury to the United States,
and be used to advantage by a foreign nation," and pledged that
"I will never divulge such information, in any form or any
manner, to anyone who is not authorized to receive it, without
prior written authorization from an appropriate official of the
United States Government." He also acknowledged that he had been
advised that such unauthorized disclosure could constitute
violations of criminal laws including Title 18, United States
Code, Section 794.
6. The Komitet Gosudarstvennoy Bezopasnosty, known as the
KGB, was the intelligence service of the Union of Soviet
Socialist Republics (USSR). In or about December 1991, the
Sluzhba Vneshney Razvedki Rossi, known as the SVR, assumed the
foreign intelligence functions of the former KGB for the
principal successor state of the USSR, the Russian Federation.
In this indictment, term "KGB/SVR" refers to activities of either
the KGB or the SVR.
7. As used by those who engage in espionage activities:
a. The term "dead drop" site refers to a prearranged
hidden location used for the clandestine exchange of packages,
messages, and payments, which avoids the necessity of an
intelligence officer and an agent being present at the same time.
b. A "signal site" is a prearranged fixed location,
usually in a public place, on which an agent or an intelligence
officer can place a predetermined mark in order to alert the
other to operational activity.
c. An "accommodation address" is a "safe" address, not
overtly associated with intelligence activity, used by an agent
to communicate with the intelligence service for which he is
working.
COUNT ONE
(18 U.S.C. § 794(a) and (c))
(Conspiracy to Commit Espionage)
THE GRAND JURY FURTHER CHARGES THAT:
A. THE CONSPIRACY
1. The Grand Jury realleges and incorporates by reference
the GENERAL ALLEGATIONS of this Indictment.
2. From on or about October 1, 1985, through on or about
February 18, 2001, in the Eastern District of Virginia and
elsewhere, the defendant ROBERT PHILIP HANSSEN did knowingly and
unlawfully combine, confederate, and agree with other persons,
both known and unknown to the Grand Jury, including officers of
the KGB/SVR, to knowingly and unlawfully communicate, deliver,
and transmit to foreign governments, specifically the Union of
Soviet Socialist Republics (USSR) and its successor, the Russian
Federation, and to those foreign governments' representatives,
officers, and agents, directly and indirectly, documents and
information relating to the national defense of the United
States, with intent and reason to believe that the same would be
used to the injury of the United States and to the advantage of
the USSR and its successor, the Russian Federation, such
communication, delivery and transmission resulting in the
identification by a foreign power (as defined in Section 101 (a)
of the Foreign Intelligence Surveillance Act of 1978) of an
individual acting as an agent of the United States and
consequently in the death of that individual, and directly
concerning satellites, early warning systems, means of defense or
retaliation against large-scale attack, communications
intelligence, and major element of defense strategy, in violation
of Title 18, United States Code, Section 794 (a).
B. WAYS, MANNER, AND MEANS OF THE CONSPIRACY
1. It was a part of the conspiracy that defendant HANSSEN
would and did use his position as a Special Agent of the FBI, and
his official access to classified information relating to the
national defense, to acquire, accumulate, and transmit such
information, including information classified SECRET and TOP
SECRET, some of which was designated as SCI, to the KGB/SVR.
2. It was a further part of the conspiracy that defendant
HANSSEN would and did secretly remove classified information
relating to the national defense from United States Government
facilities in order to provide such information to the KGB/SVR.
3. It was a further part of the conspiracy that defendant
HANSSEN would and did write letters to the KGB/SVR conveying
information of interest to the KGB/SVR, including classified
information relating to the national defense, that he had learned
or otherwise obtained in the course of his official FBI duties.
4. It was a further part of the conspiracy that defendant
HANSSEN would and did write letters to the KGB/SVR proposing
communications plans, locations for signal sites and dead drop
exchange sites, and schedules for operational activity.
5. It was a further part of the conspiracy that defendant
HANSSEN would and did select signal sites and dead drop exchange
sites in public areas, including parks near his home in the
Eastern District of Virginia, and along routes he would drive in
the ordinary course of his daily business.
6. It was a further part of the conspiracy that in their
communications to each other defendant HANSSEN and the KGB/SVR
would and did use a code for dates and times of operational
activity.
7. It was a further part of the conspiracy that defendant
HANSSEN would and did mail letters and packages to the KGB/SVR
through "accommodation addresses" in the Eastern District of
Virginia and elsewhere.
8. It was a further part of the conspiracy that defendant
HANSSEN would and did exchange packages with the KGB/SVR at "dead
drop" sites in the Eastern District of Virginia, and thereby
avoided personal meetings, in order to continue to conceal his
true identity from the KGB/SVR and help ensure his continued
safety.
9. It was a further part of the conspiracy that defendant
HANSSEN would and did wrap his materials for the KGB/SVR in
plastic garbage bags, secured with clear tape.
10. It was a further part of the conspiracy that, in their
communications regarding operational activity, defendant HANSSEN
and the KGB/SVR would and did use code names including "PARK",
"LEWIS", "ELLIS" and "V" to refer to established dead drop and
signal sites.
11. It was a further part of the conspiracy that defendant
HANSSEN and the KGB/SVR would and did use, and in their
communications would and did refer to, standard ADC maps of
Northern Virginia and other areas, to identify with specificity
locations for operational activity.
12. It was a further part of the conspiracy that defendant
HANSSEN would and did maintain and use apparently innocuous
materials, such as adhesive tape, thumbtacks, colored chalk, and
plastic garbage bags in conducting his operational activity with
the KGB/SVR.
13. It was a further part of the conspiracy that defendant
HANSSEN would and did use a code in the return address of items
he mailed to the KGB/SVR, in order to indicate that a dead drop
operation should occur on a particular day.
14. It was a further part of the conspiracy that defendant
HANSSEN and the KGB/SVR would and did communicate by telephone,
and would and did use a classified advertisement in order to make
specific telephone call arrangements.
15. It was a further part of the conspiracy that defendant
HANSSEN would and did provide correspondence and other
information, including classified information relating to the
national defense, to the KGB/SVR in the form of computer disks.
16. It was a further part of the conspiracy that defendant
HANSSEN would and did arrange with the KGB/SVR to use special
computer programs, called keys, to encrypt and decrypt the
correspondence and other information they exchanged in the form
of computer diskettes.
17. It was a further part of the conspiracy that the
KGB/SVR would and did pay substantial amounts of money to
defendant HANSSEN in the form of cash payments for his espionage-related activities.
18. It was a further part of the conspiracy that the
KGB/SVR would and did place additional sums of money in escrow
for defendant HANSSEN, representing additional payments for
defendant HANSSEN's espionage-related activities.
19. It was a further part of the conspiracy that defendant
HANSSEN would and did ask the KGB/SVR for additional payment in
the form of diamonds, and that the KGB/SVR would and did pay him
in diamonds on several occasions.
20. It was a further part of the conspiracy that defendant
HANSSEN would and did propose to the KGB/SVR that a Swiss bank
account be used for the receipt of payments from the KGB/SVR.
21. It was a further part of the conspiracy that defendant
HANSSEN would and did respond to specific requests for classified
information which the KGB/SVR asked him to obtain or otherwise
provide.
22. It was a further part of the conspiracy that defendant
HANSSEN's espionage relationship with the USSR was converted into
an espionage relationship with the Russian Federation after the
USSR dissolved and the Russian Federation came into existence.
23. It was a further part of the conspiracy that the
KGB/SVR would and did use codenames to refer to defendant HANSSEN
in its internal files, and limited access to those files by
KGB/SVR personnel, in order to protect the operation involving
defendant HANSSEN.
24. It was a further part of the conspiracy that defendant
HANSSEN would and did sign his letters to the KGB/SVR, if at all,
with a name other than his true name.
25. It was a further part of the conspiracy that defendant
HANSSEN and the KGB/SVR would and did take steps to conceal and
maintain the secrecy of his espionage activities in order to
protect himself from prosecution and to permit him to engage in
additional espionage activity.
C. OVERT ACTS
In furtherance of the conspiracy and to effect the objects
thereof, defendant HANSSEN and unindicted co-conspirators did
commit overt acts in the Eastern District of Virginia and
elsewhere, including but not limited to the following:
1. On or about October 1, 1985, defendant HANSSEN mailed a
letter to the KGB, addressed to the residence of a Soviet Embassy
official in the Eastern District of Virginia, which letter
contained classified information relating to the national
defense, the transmission of a portion of which resulted in the
identification by a foreign power (as defined in Section 101 (a)
of the Foreign Intelligence Surveillance Act of 1978) of two
individuals acting as agents of the United States and
consequently in the deaths of these individuals, and the
transmission of another portion of which concerned communications
intelligence.
2. On or about October 15, 1985, defendant HANSSEN mailed a
package to the KGB, addressed to the residence of a Soviet
Embassy official in the Eastern District of Virginia, which
package contained classified documents.
3. On or about October 24, 1985, defendant HANSSEN mailed a
message to the KGB, addressed to the residence of a Soviet
Embassy official in the Eastern District of Virginia.
4. Between on or about November 2 and November 8, 1985,
defendant HANSSEN retrieved from a dead drop site in Nottoway
Park in the Eastern District of Virginia a package from the KGB
containing $50,000 cash and a message.
5. On or about November 8, 1985, defendant HANSSEN mailed a
letter to the KGB, addressed to the residence of a Soviet Embassy
official in the Eastern District of Virginia, which letter
contained classified information relating to the national defense
the transmission of a portion of which resulted in the
identification by a foreign power (as defined in Section 101 (a)
of the Foreign Intelligence Surveillance Act of 1978) of an
individual acting as an agent of the United States and
consequently in the death of that individual, such individual
also being one of the subjects of Overt Act 1.
6. On or about June 30, 1986, defendant HANSSEN mailed a
letter to the KGB, addressed to the residence of a Soviet Embassy
official in the Eastern District of Virginia, which letter
contained classified information relating to the national defense
a portion of which directly concerned satellites.
7. On or about June 30, 1986, defendant HANSSEN signed a
letter to the KGB in the name of "Ramon."
8. From on or about July 14, 1986, to on or about July 18,
1986, the KGB placed the following advertisement in The
Washington Times:
DODGE - '71, DIPLOMAT, NEEDS ENGINE WORK, $1000. Phone
(703) 451-9780 (CALL NEXT Mon., Wed., Fri. 1 p.m.)
9. On or about Monday, July 21, 1986, defendant HANSSEN
placed a call to the telephone number given in the KGB's
Washington Times advertisement, and gave a phone number to a KGB
officer with whom he spoke.
10. On or about Monday, July 21, 1986, about an hour after
the conversation described in the foregoing paragraph, the KGB
officer placed a call to the number defendant HANSSEN had given
him, and informed defendant HANSSEN that the Nottoway Park dead
drop site was being loaded for him.
11. On or about August 7, 1986, defendant HANSSEN mailed a
letter to the KGB, addressed to the residence of a Soviet Embassy
official in the Eastern District of Virginia.
12. On or about August 18, 1986, defendant HANSSEN placed a
telephone call to the telephone number given in the
KGB's Washington Times advertisement, and spoke to a KGB officer.
13. On or about August 19, 1986, defendant HANSSEN
retrieved from the Nottoway Park dead drop site in the Eastern
District of Virginia a package from the KGB containing $10,000
cash and a letter.
14. On or about August 19, 1986, defendant HANSSEN mailed a
note to the KGB, addressed and delivered to the residence of a
Soviet Embassy official in the Eastern District of Virginia.
15. On or about September 8, 1987, defendant HANSSEN mailed
a letter to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia.
16. On or about September 14, 1987, defendant HANSSEN
mailed a package to the KGB containing classified documents.
17. On or about September 15, 1987, defendant HANSSEN
retrieved from the Nottoway Park dead drop site in the Eastern
District of Virginia a package from the KGB containing $10,000
cash and a message.
18. On or about September 26, 1987, defendant HANSSEN
placed at the Nottoway Park dead drop site in the Eastern
District of Virginia a package for the KGB containing a letter
and a classified document.
19. On or about September 29, 1987, the KGB deposited
$100,000 in a Moscow bank account for defendant HANSSEN.
20. On or about November 7, 1987, defendant HANSSEN mailed
a letter to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia.
21. On or about November 17, 1987, defendant HANSSEN mailed
a letter to the KGB.
22. On or about November 23, 1987, defendant HANSSEN placed
at the Nottoway Park dead drop site in the Eastern District of
Virginia a package for the KGB containing classified documents
relating to the national defense.
23. On or about November 23, 1987, defendant HANSSEN
retrieved from the Nottoway Park dead drop site in the Eastern
District of Virginia a package from the KGB containing $20,000
cash and a letter.
24. On or about November 23, 1987, the KGB informed
defendant HANSSEN that $100,000 had been placed in a bank on his
behalf.
25. On or about February 3, 1988, defendant HANSSEN mailed
a note to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia.
26. On or about February 8, 1988, defendant HANSSEN placed
at the Nottoway Park dead drop site in the Eastern District of
Virginia a package for the KGB containing a letter, classified
documents, and a computer diskette, including classified
information relating to the national defense a portion of which
directly concerned communications intelligence.
27. On or about February 8, 1988, defendant HANSSEN
retrieved from the Nottoway Park dead drop site in the Eastern
District of Virginia a package from the KGB containing $25,000
cash and a letter.
28. On or about March 15, 1988, defendant HANSSEN mailed a
computer diskette to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia.
29. On or about March 16, 1988, defendant HANSSEN mailed a
note to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia.
30. On or about March 24, 1988, defendant HANSSEN mailed a
computer diskette to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia.
31. On or about March 28, 1988, defendant HANSSEN placed at
the Nottoway Park dead drop site in the Eastern District of
Virginia a package for the KGB containing classified documents
relating to the national defense and a computer diskette.
32. On or about March 28, 1988, defendant HANSSEN retrieved
from the Nottoway Park dead drop site in the Eastern District of
Virginia a package from the KGB containing $25,000 cash and a
letter.
33. On or about March 31, 1988, defendant HANSSEN mailed a
note to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia.
34. On or about April 5, 1988, in the Eastern District of
Virginia, defendant HANSSEN mailed a computer diskette to the
KGB, addressed and delivered to a Soviet accommodation address in
the Eastern District of Virginia, which computer diskette
contained classified information.
35. On or about April 5, 1988, in the Eastern District of
Virginia, defendant HANSSEN asked the KGB for diamonds.
36. On or about May 17, 1988, in the Eastern District of
Virginia, defendant HANSSEN mailed a computer diskette to the
KGB, addressed and delivered to a Soviet accommodation address,
which computer diskette contained classified information.
37. On or about July 13, 1988, defendant HANSSEN mailed a
letter to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia.
38. On or about July 18, 1988, defendant HANSSEN placed at
the Nottoway Park dead drop site in the Eastern District of
Virginia a package for the KGB containing classified documents
relating to the national defense, including a document directly
concerning early warning systems and other means of defense or
retaliation against large-scale attack.
39. On or about July 18, 1988, defendant HANSSEN retrieved
from the Nottoway Park dead drop site in the Eastern District of
Virginia a package from the KGB containing $25,000 cash and a
letter.
40. On or about July 29, 1988, defendant HANSSEN mailed a
computer diskette to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia, which
computer diskette contained classified information.
41. On or about August 22, 1988, the KGB deposited $50,000
in a Moscow bank account for defendant HANSSEN.
42. On or about September 20, 1988, defendant HANSSEN
mailed a note and computer diskette to the KGB, addressed and
delivered to a Soviet accommodation address in the Eastern
District of Virginia, which computer diskette contained
classified information.
43. On or about September 26, 1988, defendant HANSSEN
placed at a dead drop site in the Eastern District of Virginia a
package for the KGB containing classified documents.
44. On or about September 26, 1988, defendant HANSSEN
retrieved from a dead drop site in the Eastern District of
Virginia a package from the KGB containing a diamond and a
letter.
45. On or about September 26, 1988, the KGB advised
defendant HANSSEN that $50,000 had been deposited in defendant
HANSSEN's account.
46. On or about November 30, 1988, defendant HANSSEN mailed
a computer diskette to the KGB, addressed and delivered to a
Soviet accommodation address in the Eastern District of Virginia,
which computer diskette contained classified information.
47. On or about December 26, 1988, defendant HANSSEN placed
at a dead drop site in the Eastern District o'f Virginia a package
for the KGB containing documents and a computer diskette, which
computer diskette contained classified information relating to
the national defense and directly concerning communications
intelligence.
48. On or about December 26, 1988, defendant HANSSEN
retrieved from a dead drop site in the Eastern District of
Virginia a package from the KGB containing $10,000 cash, a
diamond, and a message.
49. On or about January 31, 1989, defendant HANSSEN placed
at a dead drop site in the Eastern District of Virginia a package
for the KGB containing a note, a classified document, and a
computer diskette which contained classified information.
50. On or about January 31, 1989, defendant HANSSEN placed
an emergency call-out signal for the KGB at a pre-designated
signal site.
51. On or about March 16, 1989, defendant HANSSEN placed a
call-out signal for the KGB at a pre-designated signal site.
52. On or about March 20, 1989, defendant HANSSEN placed at
a dead drop site in the Eastern District of Virginia two packages
for the KGB containing classified documents relating to the
national defense and a computer diskette which contained
classified information.
53. On or about March 20, 1989, defendant HANSSEN retrieved
from a dead drop site in the Eastern District of Virginia a
package from the KGB containing $18,000 cash, a diamond, and a
letter.
54. On or about May 17, 1989, defendant HANSSEN placed a
call-out signal for the KGB at a pre-designated signal site.
55. On or about May 22, 1989, defendant HANSSEN placed at a
dead drop site in the Eastern District of Virginia a package for
the KGB containing classified documents, two of the three
diamonds that he had previously received from the KGB and which
he was returning for cash, and a computer-diskette which
contained classified information relating to the national defense
including information directly concerning communications
intelligence.
56. On or about May 22, 1989, defendant HANSSEN suggested
to the KGB that an account in Switzerland be used for the receipt
of payments from the KGB.
57. On or about May 22, 1989, defendant HANSSEN retrieved
from a dead drop site in the Eastern District of Virginia a
package from the KGB containing a letter and a classified
document relating to the national defense that HANSSEN had
previously provided to the KGB and had asked the KGB to return to
him.
58. On or about August 1, 1989, defendant HANSSEN placed
two simultaneous call-out signals for the KGB at pre-designated
signal sites.
59. On or about August 7, 1989, defendant HANSSEN placed at
a dead drop site in the Eastern District of Virginia a package
for the KGB containing a computer diskette which contained
classified information, and rolls of undeveloped film depicting
the contents of a classified document relating to the national
defense which directly concerned means of defense or retaliation
against large-scale nuclear attack and other elements of defense
strategy.
60. On or about August 7. 1989, defendant HANSSEN retrieved
from a dead drop site in the Eastern District of Virginia a
package from the KGB containing $30,000 cash and a letter.
61. On or about August 17, 1989, the KGB deposited $50,000
in a Moscow bank account for defendant HANSSEN.
62. On or about September 22, 1989, defendant HANSSEN
placed a call-out signal for the KGB at a pre-designated signal
site.
63. On or about September 25, 1989, defendant HANSSEN
placed at a dead drop site in the Eastern District of Virginia a
package for the KGB containing classified documents relating to
the national defense which directly concerned communications
intelligence, and a computer diskette which contained classified
information.
64. On or about September 25, 1989, defendant HANSSEN
retrieved from a dead drop site in the Eastern District of
Virginia a package from the KGB containing $30,000 cash, a
letter, and a KGB computer diskette.
65. On or about September 28, 1989, defendant HANSSEN
mailed a letter to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia.
66. On or about October 16, 1989, defendant HANSSEN mailed
a computer diskette to the KGB, addressed and delivered to a
Soviet accommodation address in the Eastern District of Virginia.
67. On or about October 23, 1989, defendant HANSSEN placed
at a dead drop site in Foxstone Park in the Eastern District of
Virginia a package for the KGB containing a computer diskette
which contained classified information relating to the national
defense, including information which directly concerned
communications intelligence.
68. Between on or about October 31 and November 3, 1989,
defendant HANSSEN retrieved from the Foxstone Park dead drop site
in the Eastern District of Virginia a package from the KGB
containing $55,000 cash and a KGB computer diskette.
69. Between on or about October 31 and November 3, 1989,
the KGB advised defendant HANSSEN that $50,000 had been deposited
into his account in Moscow.
70. On or about December 20, 1989, defendant HANSSEN placed
a call-out signal for the KGB at a pre-designated signal site.
71. On or about December 25, 1989, defendant HANSSEN placed
at a dead drop site in the Eastern District of Virginia a package
for the KGB containing classified documents relating to the
national defense which included information directly concerning
communications intelligence, and a computer diskette which
contained classified information.
72. On or about December 25, 1989, defendant HANSSEN
retrieved from a dead drop site in the Eastern District of
Virginia a package from the KGB containing $38,000 cash and two
KGB computer diskettes.
73. On or about March 1, 1990, defendant HANSSEN placed a
call-out signal for the KGB at a pre-designated signal site.
74. On or about March 5, 1990, defendant HANSSEN placed at
a dead drop site in the Eastern District of Virginia a package
for the KGB containing a document and a computer diskette which
contained classified information relating to the national
defense.
75. On or about March 5, 1990, defendant HANSSEN retrieved
from a dead drop site in the Eastern District of Virginia a
package from the KGB containing $40,000 cash and a KGB computer
diskette.
76. On or about May 3, 1990, defendant HANSSEN placed a
call-out signal for the KGB at a pre-designated signal site.
77. On or about May 7, 1990, defendant HANSSEN placed at a
dead drop site in the Eastern District of Virginia a package for
the KGB containing classified documents and a computer diskette
which contained classified information.
78. On or about May 7, 1990, defendant HANSSEN retrieved
from a dead drop site in the Eastern District of Virginia a
package from the KGB containing $35,000 cash and a KGB computer
diskette.
79. On or about May 17, 1990, defendant HANSSEN mailed a
letter and a computer diskette to the KGB, addressed and
delivered to a Soviet accommodation address in the Eastern
District of Virginia.
80. On or about May 21, 1990, defendant HANSSEN retrieved
from the Foxstone Park dead drop site in the Eastern District of
Virginia a package from the KGB containing two KGB computer
diskettes.
81. On or about August 20, 1990, defendant HANSSEN mailed a
computer diskette to the KGB, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia, which
computer diskette contained classified information.
82. On or about September 3, 1990, defendant HANSSEN
retrieved from a dead drop site in the Eastern District of
Virginia a package from the KGB containing $40,000 cash and a KGB
computer diskette.
83. On or about February 2, 1991, defendant HANSSEN placed
an emergency call-out signal for the KGB.
84. On or about February 2, 1991, defendant HANSSEN placed
at a dead drop site in the Eastern District of Virginia a package
for the KGB containing a computer diskette which contained
classified information relating to the national defense.
85. On or about February 18, 1991, the KGB placed at a dead
drop site in the Eastern District of Virginia a package
containing $10,000 cash and a KGB computer diskette.
86. On or about April 10, 1991, defendant HANSSEN placed a
call-out signal for the KGB at a pre-designated signal site.
87. On or about April 15, 1991, defendant HANSSEN placed at
a dead drop site in the Eastern District of Virginia a package
for the KGB containing classified documents and a computer
diskette.
88. On or about April 15, 1991, defendant HANSSEN retrieved
from a dead drop site in the Eastern District of Virginia a
package from the KGB containing $10,000 cash and a KGB computer
diskette.
89. On or about July 9, 1991, defendant HANSSEN placed a
call-out signal for the KGB at a pre-designated signal site.
90. On or about July 15, 1991, defendant HANSSEN placed at
the Foxstone Park dead drop site in the Eastern District of
Virginia a package for the KGB containing classified documents
and a computer diskette.
91. On or about July 15, 1991, defendant HANSSEN retrieved
from the Foxstone Park dead 'drop site in the Eastern District of
Virginia a package from the KGB containing $12,000 cash and a KGB
computer diskette.
92. On or about August 19, 1991, defendant HANSSEN placed
at a dead drop site in the Eastern District of Virginia a package
for the KGB containing aclassified document relating to the
national defense and a computer diskette containing classified
information relating to the national defense, which included
information directly concerning communications intelligence.
93. On or about August 19, 1991, defendant HANSSEN
retrieved from a dead drop site in the Eastern District of
Virginia a package from the KGB containing $20,000 cash and a
message.
94. On or about October 1, 1991, defendant HANSSEN placed a
call-out signal for the KGB at a pre-designated signal site.
95. On or about October 7, 1991, defendant HANSSEN placed
at a dead drop site a package for the KGB containing a classified
document and a computer diskette which contained classified
information.
96. On or about October 7, 1991, defendant HANSSEN
retrieved from a dead drop site a package from the KGB containing
$12,000 cash and a KGB computer diskette.
97. On or about December 12, 1991, defendant HANSSEN mailed
a note to the KGB/SVR, addressed and delivered to a Soviet
accommodation address in the Eastern District of Virginia, which
note contained classified information relating to the national
defense.
98. On or about December 16, 1991, defendant HANSSEN placed
at a dead drop site in the Eastern District of Virginia a package
for the KGB/SVR containing classified documents relating to the
national defense and a computer diskette which contained
classified information relating to the national defense,
including information directly concerning communications
intelligence.
99. On or about December 16, 1991, defendant HANSSEN
retrieved from a dead drop site in the Eastern District of
Virginia a package from the KGB/SVR containing $12,000 cash and a
KGB computer diskette.
100. On or about August 11, 1999, defendant HANSSEN
conducted searches of the FBI's collected computerized databases
of classified and unclassified investigative files and indices,
called the Automated Case Support (ACS) System, for the purpose
of determining whether the FBI was aware of operational activity
at Foxstone Park.
101. On or about October 6, 1999, defendant HANSSEN
maintained, on a computer memory storage device known as a Versa
Card, a letter from the KGB/SVR.
102. On or about November 3, 1999, defendant HANSSEN
conducted searches of the FBI's ACS System for the purpose of
determining whether the FBI was aware of recent dead drops in
Virginia or of operational activity at Foxstone Park.
103. On or about November 15, 1999, defendant HANSSEN
conducted searches of the FBI's ACS System for the purpose of
determining whether the FBI was aware of recent dead drops in
Virginia or of operational activity at Foxstone Park.
104. On or about March 14, 2000, defendant HANSSEN created
or last modified a letter to the KGB/SVR.
105. On or about March 31, 2000, defendant HANSSEN
conducted searches of the FBI's ACS System for the purpose of
determining whether the FBI was aware of recent dead drops
involving Russia.
106. On or about June 8, 2000, defendant HANSSEN created or
last modified a letter to the KGB/SVR.
107. On or about July 31, 2000, defendant HANSSEN
maintained, on the Versa Card described above, a letter from the
KGB/SVR.
108. On or about October 4, 2000, defendant HANSSEN
conducted searches of the FBI's ACS System for the purpose of
determining whether the FBI was aware of recent dead drops.
109. On or about November 13, 2000, defendant HANSSEN
conducted searches of the FBI's ACS System for the purpose of
determining whether the FBI was aware of recent dead drops.
110. On or about November 17, 2000, defendant HANSSEN
created or last modified a letter to the KGB/SVR.
111. On or about December 21, 2000, defendant HANSSEN
conducted searches of the FBI's ACS System for the purpose of
determining whether the FBI was aware of recent dead drops.
112. In or about January 2001, defendant HANSSEN possessed
a personal PALM III device which contained on it a record
referring to "ELLIS" and the date February 18 and the time 8:00.
113. On or about January 16, 2001, defendant HANSSEN
conducted searches of the FBI's ACS System for the purpose of
determining whether the FBI was aware of recent dead drops.
114. On or about January 19, 2001, defendant HANSSEN
conducted searches of the FBI's ACS System for the purpose of
determining whether the FBI was aware of recent dead drops.
115. On or about January 22, 2001, defendant HANSSEN
conducted searches of the FBI's ACS System for the purpose of
determining whether the FBI was aware of recent dead drops or of
operational activity at Foxstone Park.
116. On or about January 30, 2001, defendant HANSSEN
maintained in the glove compartment of his personal automobile a
roll of white Johnson & Johnson medical adhesive tape and a box
of Crayola colored chalk.
117. On or about January 30, 2001, defendant HANSSEN
maintained in the trunk of his personal automobile a roll of
Superior Performance Scotch clear mailing tape and a number of
dark colored Hefty garbage bags.
118. On or about February 12, 2001, defendant HANSSEN
maintained in the glove compartment of his personal automobile a
box containing thumbtacks of various colors, including yellow and
white.
119. On or about February 18, 2001, defendant HANSSEN
possessed classified documents relating to the national defense
in the trunk of his personal automobile.
120. On or about February 18, 2001, defendant HANSSEN
wrapped classified documents relating to the national defense and
a computer diskette in a plastic garbage bag secured with clear
tape.
121. On or about February 18, 2001, defendant HANSSEN went
to Foxstone Park in the Eastern District of Virginia.
122. On or about February 18, 2001, at Foxstone Park in the
Eastern District of Virginia, defendant HANSSEN placed a piece of
white adhesive tape on a pole.
123. On or about February 18, 2001, at Foxstone Park in the
Eastern District of Virginia, defendant HANSSEN placed a package,
wrapped in a plastic garbage bag secured with clear tape, and
containing classified documents relating to the national defense
and a computer diskette, under afootbridge in a manner which
concealed the package from view.
(In violation of Title 18, United States Code, § 794(c).)
COUNTS TWO THROUGH TWENTY
(18 U.S.C. § 794(a))
(Espionage)
THE GRAND JURY FURTHER CHARGES THAT:
1. The Grand Jury realleges and incorporates by reference
the GENERAL ALLEGATIONS of this Indictment.
2. On or about the following specified dates, in the
Eastern District of Virginia and elsewhere, defendant ROBERT
PHILIP HANSSEN, with the intent and reason to believe that they
were to be used to the injury of the United States and to the
advantage of a foreign government, specifically the Union of
Soviet Socialist Republics (USSR), did knowingly and unlawfully
communicate, deliver, and transmit, and attempt to communicate,
deliver, and transmit, to representatives of a foreign
government, specifically the USSR, and to representatives,
officers, agents, and employees thereof, directly and indirectly,
documents and information relating to the national defense of the
United States, specifically the following documents and
information:
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 2 | October 1, 1985 | (a) The fact that Valeriy Martynov,
a KGB officer, had been recruited by
the United States intelligence
services, which information was
classified SECRET, and the transmission
of which information resulted in the
identification by a foreign power (as
defined in section 101 (a) of the Foreign
Intelligence Surveillance Act of 1978)
of an individual acting as an agent of
the United States and consequently in
the death of that individual.
(b) The fact that Sergey Motorin, a
KGB officer, had been recruited by
the United States intelligence
services, which information was
classified SECRET, and the transmission
of which information resulted in the
identification by a foreign power (as
defined in section 101 (a) of the Foreign
Intelligence Surveillance Act of 1978)
of an individual acting as an agent of
the United States and consequently in
the death of that individual.
(c) The fact that Boris Yuzhin, a
KGB officer, had been recruited by
the United States intelligence
services, which information was
classified SECRET.
(d) The existence of an FBI technical
penetration of a particular Soviet
establishment, as well as the specific
location of the penetration device,
and the methods and technology
utilized, which information was
classified TOP SECRET, and directly
concerned communications intelligence.
| Letter mailed to an address
in the City of Alexandria, Virginia |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 3 | November 8, 1985 |
(a) The fact that Valeriy Martynov
used a particular and described
concealment device, which information
was classified SECRET, and the
transmission of which information
resulted in the identification by a
foreign power (as defined in section
101 (a) of the Foreign Intelligence
Surveillance Act of 1978) of an
individual acting as an agent of
the United States and consequently in
the death of that individual.
(b) The existence of a successful
intelligence collection operation
against a specific Soviet target,
which information was classified
TOP SECRET/SCI.
|
Letter mailed to an address in the City of Alexandria, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 4 | June 30, 1986 | The fact that the United States knew
of a particular technical vulnerability in Soviet satellite transmissions and was actively exploiting
the vulnerability, which information
was classified TOP SECRET/SCI, and
directly concerned satellites. |
Letter mailed to an address in the City of Alexandria, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 5 | November 23, 1987 | A report about a recent FBI/CIA
meeting with a Soviet intelligence
officer who was an FBI/CIA recruitment
target, which report was classified
SECRET. |
Dead drop in Nottoway Park, in Fairfax County, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 6 | February 8, 1988 | (a) Specific information about a
recruited KGB officer who had
secretly defected to the United
States, which information was
classified SECRET.
(b) The identity, by KGB codename
and recent specific assignment,
of a KGB agent who was currently
operating as an illegal in a
particular United States city and
who had been recruited by the FBI
to serve as a double agent, which
information was classified SECRET.
(c) A particular limitation of the
National Security Agency's ability
to read certain Soviet communications,
which information was classified
TOP SECRET/SCI, and directly concerned
communications intelligence. |
Dead drop in Nottoway Park, in
Fairfax County, Virqinia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 7 | March 28, 1988 |
A version of a TOP SECRET document
entitled "The FBI's Double Agent
Program", which contained a detailed
evaluation of FBI double agent
operations, including joint operations
with other United States intelligence
agencies, conducted worldwide over a
ten-year period. |
Dead drop in Nottoway Park, in Fairfax County, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 8 | July 18, 1988 |
(a) A TOP SECRET United States intelligence analysis of the effectiveness
of Soviet intelligence collection
efforts against certain United States
nuclear weapons capabilities, which
analysis directly concerned early
warning systems and other means of
defense or retaliation against
large-scale attack.
(b) A TOP SECRET/SCI document entitled
"Compendium of Future Intelligence Requirements: Volume II", dated September
1987, prepared for the Director of
Central Intelligence by the Staff of the
Intelligence Producers Council, containing a comprehensive listing of specific
current intelligence information,
including information about military
capabilities and preparedness, sought
by the United States regarding the
Soviet Union and other nations.
(c) A TOP SECRET comprehensive
historical FBI review of allegations
from recruitments and detectors over
a period of years that the Soviet
intelligence services had penetrated
the FBI, which identified Soviet
recruitments and detectors with
specificity, and described particular
information they provided.
(d) A SECRET Central Intelligence
Agency Counterintelligence Staff
Study entitled "The Soviet
Counterintelligence Offensive: KGB
Recruitment Operations Against
CIA", dated March 1988.
|
Dead drop in Nottoway Park, in Fairfax County, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 9 | December 26, 1988 |
The fact that the United States was
targeting a particular category of
Soviet communications, which information was classified TOP SECRET/SCI,
and directly concerned communications
intelligence. |
Dead drop in Eakin Community Park in Fairfax County, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 10 | March 20, 1989 |
A TOP SECRET/SCI document entitled
"DCI Guidance for the National MASINT
Intelligence Program (FY1991-FY2000)",
prepared by the Measurement and Signature Intelligence (MASINT) Committee
and dated November 1988, which represented the United States Intelligence
Community's consensus as to specific
MASINT objectives and studies leading
to needed capabilities, and whose
contents were highly specific and technical, and which document defendant
HANSSEN requested be returned to him. |
Dead drop in Eakin Community
Park in Fairfax County, Virginia |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 11 | May 22, 1989 |
(a) The existence, and details of, an
ongoing FBI espionage investigation
of United States Department of State
officer Felix Bloch, which information
was classified SECRET, and which
transmission led the Soviet Union to
warn Bloch of the investigation and
thereby prevent the FBI from concluding
its investigation.
(b) The fact that the United States
was targeting a particular category of
Soviet communications, which information was classified TOP SECRET/SCI and
directly concerned communications
intelligence. |
Dead drop in Idylwood Park in
Fairfax County, Virginia.
|
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 12 | August 7, 1989 |
A highly-restricted TOP SECRET/SCI
analysis, dated May 1987, of the
Soviet intelligence threat to a
specific and named highly-compartmented United States
Government program to ensure the
continuity of government in the
event of a Soviet nuclear attack,
which analysis directly concerned
means of defense or retaliation
against large-scale nuclear attack
and other elements of defense
strategy. |
Dead drop in Eakin Community Park in Fairfax County, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 13 | September 25, 1989 |
(a) Documentary material containing
details of a United States program of
technical penetration of a particular
Soviet establishment, which information was classified TOP SECRET/SCI
and directly concerned communications
intelligence.
(b) Documentary material concerning a
United States technical operation
against a specific foreign target,
which information was classified TOP
SECRET and directly concerned
communications intelligence. |
Dead drop in Canterbury Woods Park in Fairfax County, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 14 | October 23, 1989 |
The fact that the United States had
the capability to read certain Soviet
communications, which information was
classified TOP SECRET/SCI and directly
concerned communications intelligence. |
Dead drop in Foxstone Park in Fairfax County, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 15 | December 25, 1989 |
(a) Documentary material containing
details of a United States program of
technical penetration of a particular
Soviet establishment, which information was classified TOP SECRET/SCI
and directly concerned communications
intelligence.
(b) A Director of Central Intelligence
National Intelligence Estimate (NIE)
entitled "The Soviet System in Crisis:
Prospects for the Next Two Years",
dated November 1989 and classified
SECRET. |
Dead drop in Idylwood Park in Fairfax County, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 16 | March 5, 1990 |
(a) Confirmation that a particular
Soviet person was a recruited
intelligence asset of the FBI, which
information was classified SECRET.
(b) The fact that a particular named
Soviet Embassy employee in the United
States was a recruited intelligence
asset of the FBI, which information
was classified SECRET. |
Dead drop in Eakin Community Park in Fairfax County, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 17 | February 2, 1991 |
(a) Confirmation of the true identity
of a Soviet person in the United
States who was operating as an FBI
recruitment-in-place, which information was classified SECRET.
(b) The fact that a particular Soviet
person in the United States was a
recruited reporting asset of the FBI,
which information was classified SECRET. |
Dead drop in Eakin Community
Park in Fairfax County,
Virginia.
|
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 18 | August 19, 1991 |
(a) The fact that the National
Security Agency was reading the
communications of a specific foreign
country, and the specific methods used
to do so, which information was
classified TOP SECRET/SCI and directly
concerned communications intelligence.
(b) A document, classified SECRET,
disclosing details of a proposed FBI
technical surveillance operation
against a Soviet person in the United
States.
(c) The fact that the FBI was
initiating a "dangle" operation
against the Soviets at a particular
named United States military facility,
which information was classified
SECRET |
Dead drop in Lewinsville Park in Fairfax County, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 19 | December 12, 1991 |
The fact that approval had been given
for a device the FBI was to implant
in a technical surveillance operation
against a Soviet person in the United
States, about which defendant HANSSEN
had first reported to the KGB on
August 19, 1991, which information
was classified SECRET. |
Note mailed to an address in the City of Alexandria, Virginia. |
|
COUNT
|
DATE
|
MATERIAL OR INFORMATION TRANSMITTED
|
MEANS AND PLACE OF TRANSMITTAL
|
| 20 | December 16, 1991 |
(a) The fact that the United States
Intelligence Community was obtaining
especially sensitive material derived
from the communications of a specific
foreign country, which fact was
classified TOP SECRET/SCI and directly
concerned communications intelligence.
(b) A SECRET document entitled "The
KGB's First Chief Directorate:
Structure, Functions, and Methods",
produced by the Director of Central
Intelligence Counterintelligence
Center, dated November 1990.
(c) A SECRET document entitled
"Director of Central Intelligence
FY 1992 Congressional Budget
Justification, Volume X: Federal
Bureau of Investigation Foreign
Counterintelligence Program." |
Dead drop in Idylwood Park in
Fairfax County, Virginia |
(In violation of Title 18, United States Code, § 794 (a).)
COUNT TWENTY-ONE
THE GRAND JURY FURTHER CHARGES THAT:
1. The Grand Jury realleges and incorporates by reference
the GENERAL ALLEGATIONS of this Indictment.
2. On or about February 18, 2001, in the Eastern District
of Virginia, defendant ROBERT PHILIP HANSSEN, with the intent and
reason to believe that they were to be used to the injury of the
United States and to the advantage of a foreign government,
specifically the Russian Federation, did knowingly and unlawfully
attempt to communicate, deliver, and transmit, to representatives
of a foreign government, that is the Russian Federation, and to
representatives, officer, agents, and employees thereof, directly
and indirectly, the following documents relating to the national
defense of the United States:
seven internal FBI documents classified SECRET, disclosing
details of ongoing and proposed FBI counterintelligence
operations against Russian persons in the United States.
(In violation of Title 18, United States Code, § 794 (a).)
FORFEITURE
Defendant ROBERT PHILIP HANSSEN, if convicted of any of the
violations charged in this Indictment, shall forfeit to the
United States any property constituting, or derived from, any
proceeds he obtained, directly or indirectly, as the result of
such violation; and any of the defendant's property used, or
intended to be used, in any manner or part, to commit, or to
facilitate the commission of, such violation. This property
includes, but is not limited to $1,437,000 received from the
Soviets and/or Russians, directly or indirectly, in proceeds of
the charged espionage and espionage conspiracy of which he is
charged, which $1,437,000 itself includes, but is not limited to:
1. Approximately $800,000, plus applicable interest,
maintained on the behalf of the defendant by or through
the KGB and SVR and which may have been deposited, at
one point, in the Vneshtorg Bank in Moscow;
2. Approximately $600,000 in cash and diamonds obtained by
the defendant from the KGB and SVR;
3. $50,000 recovered by the FBI from the "Lewis" drop site
in Long Branch Nature Center; and
4. Two Rolex watches, bearing the serial numbers L859772
and R16710A30B9315/E458859.
(Pursuant to Title 18, United States Code, § 794 (incorporating
provisions of Title 21, United States Code, § 853).)
KENNETH E. MELSON
United States Attorney
Randy I. Bellows
Assistant United States Attorney
Justin W. Williams
Assistant United States Attorney
Gordon D. Kromberg
Assistant United States Attorney
Laura A. Ingersoll
Senior Trial Attorney
Internal Security Section
Criminal Division
United States Department of Justice
