America Online (“AOL”) email account, a Google email account, a non-governmental commercial

messaging application, or other non-governmental systems.
7. While National Security Advisor, BOLTON learned national defense and classified information through a variety of means, including intelligence briefings, intelligence reports, and meetings with members of the U.S. intelligence community, including the National Security Agency (“NSA”) and the Central Intelligence Agency (“CIA”), the U.S. military, and foreign government officials. In addition to having a home SCIF, while National Security Advisor, BOLTON also had access to a variety of secure telecommunication systems that he could use to discuss and communicate classified information. Moreover, BOLTON had access, as the National Security Advisor, to classified spaces in the White House, the Eisenhower Executive Office Building, and other locations, in the Washington, D.C., area and elsewhere, where he could readily learn, read, and discuss classified and sensitive information with others who were authorized to know, receive, discuss, and make decisions based on such information.
8. From on or about April 9, 2018, through at least on or about August 22, 2025, BOLTON abused his position as National Security Advisor by sharing more than a thousand pages of information about his day-to-day activities as the National Security Advisor—including information relating to the national defense which was classified up to the TOP SECRET/SCI level with two unauthorized individuals, namely Individuals 1 and 2. BOLTON also unlawfully retained documents, writings, and notes relating to the national defense, including information classified up to the TOP SECRET/SCI level, in his home in Montgomery County, Maryland. Individual 1, whose identity is known to the Grand Jury, was related to BOLTON, resided in the District of Maryland, never held a U.S. security clearance, and was not authorized to

9.

access, receive, or maintain the classified information that BOLTON shared related to his work as the National Security Advisor.

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