Steve J. Rosen - Ways, Manner and Means of The Conspiracy

Ways, Manner and Means of The Conspiracy

1. It was part of the conspiracy that, in an effort to influence persons within and outside the United States government, Rosen and Weissman would cultivate relationships with Franklin and others and would use their contacts within the U.S. government and elsewhere to gather sensitive U.S. government information, including classified information relating to the national defense, for subsequent unlawful communication, delivery and transmission to persons not entitled to receive it.

1. It was further part of the conspiracy that Franklin would use his position as a desk officer in the Office of the Secretary of Defense to gather information relating to the national defense, for subsequent unlawful communication, delivery and transmission to Rosen and Weissman and others not entitled to receive it.

1. It was further part of the conspiracy that Franklin, Rosen and Weissman would meet at locations in the Eastern District of Virginia and elsewhere, to exchange information, including classified information relating to the national defense.

1. It was further part of the conspiracy that Franklin would unlawfully deliver, communicate and transmit classified national defense information in an effort to advance his own personal foreign policy agenda and influence persons within and outside the United States government.

1. It was further part of the conspiracy that Rosen and Weissman, without lawful authority, would communicate to persons not entitled to receive it, classified information relating to the national defense.”

http://fl1.findlaw.com/news.findlaw.com/nytimes/docs/dod/usfrnklin80205ind.pdf