PACER USA Vs Pierre Girgis Jan 6 2022 Indictment

Case 1:22-cr-00006-AJN Document 1 Filed 01/06/22 Page 1 of 6
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
X
UNITED STATES OF AMERICA SEALED INDICTMENT
- V. - 22 Cr.
PIERRE GIRGIS,
Defendant.
006
---------------- X
COUNT ONE
(Conspiracy to Act as an Agent of a Foreign Government
Without Notifying the Attorney General)
The Grand Jury charges:
Overview
1. From at least in or about 2014, up to and including in
or about April 2019, PIERRE GIRGIS, the defendant, acted in the
United States as an agent of the Arab Republic of Egypt (the
"Egyptian Government") without notifying the Attorney General of
the United States as required by law. GIRGIS, a dual citizen of
Egypt and the United States, operated at the direction and control
of multiple employees of the Egyptian Government in an effort to
further in the United States the interests of the Egyptian
Government.
2. At the direction of Egyptian Government personnel,
PIERRE GIRGIS, the defendant, among other things: tracked and
obtained information regarding l political opponents of Egyptian
president Abdel Fattah el-Sisi ( "el-Sisi"); and leveraged his

connections with local U.S. law enforcement officers to collect
non-public information at the direction of Egyptian officials,
arrange benefits for visiting Egyptian officials, and arrange
meetings between U.S. and Egyptian law enforcement.
3. On or about May 7, 2018, an Egyptian Government official
( "Egyptian Official-1") and PIERRE GIRGIS, the defendant,
exchanged encrypted communications referencing GIRGIS's status as
an agent of the Egyptian Government. 1 During the conversation,
Egyptian Official-1 expressed frustration that GIRGIS had
communicated with personnel from a different Egyptian agency:
[I] t is not possible to open with all the

agencies. I'm letting you open with us only.
Everything I have stated has been written and
sent to Egypt. All this talk has been written
and sent to Egypt . Seriously, you are
humiliating me, you have no idea what can
happen. This way the good things you do, you
ruin in a second. I'm the one to be humiliated
because you do not listen to my words.
I had warned you, and you insist on opening
with [another Egyptian agency]. This way you
are hurting me . . Really I'm very, very
sad. Because you do a lot of good things, but
you ruin them in a second, not just that, you
are also hurting me.
Later in the encrypted messaging exchange, Egyptian Official-1
advised GIRGIS that other Egyptian Government agencies "want
sources for themselves, and you [GIRGIS] have become an important
source for them to collect information." GIRGIS responded, "I
1 The statements described in this Indictment are set forth in

substance and in part.
2
know and I see and I learn from you," and then informed Egyptian
Official-1, "it will not be repeated again."
4. On or about March 8, 2019, PIERRE GIRGIS, the defendant,
and Egyptian Official-1 discussed an upcoming trip of certain
Egyptian officials to the United States. During that conversation,
GIRGIS stated, "Tell me what you want me to do," to which Egyptian
Official-1 responded by inquiring about GIRGIS's relationship with
a particular U.S. law enforcement officer. Egyptian Official-1
then instructed GIRGIS "to ask [the U.S. law enforcement officer]
for something. We want you to find out if there are any police
trainings happening in Manhattan in the coming days, and if so,
who are the people in charge of these trainings? We would like to
attend." Later in the conversation, GIRGIS again asked, "What you
want me to do?", and Egyptian Official-1 directed GIRGIS, "Make
follow up, Ok?", and GIRGIS agreed by responding, "Ok."
STATUTORY ALLEGATIONS
5. From at least in or about 2014, up to and including at
least in or about April 2019, in the Southern District of New York
and elsewhere, PIERRE GIRGIS, the defendant, and others known and
unknown, knowingly did combine, conspire, confederate, and agree
together and with each other to commit an offense against the
United States, to wit, acting as an agent of a foreign government
without prior notification to the Attorney General, in violation
of Title 18, United States Code, Section 951.
3
6. It was a part and an object of the conspiracy that PIERRE
GIRGIS, the defendant, and others known and unknown, knowingly
acted in the United States as an agent of a foreign government, to
wit, the Arab Republic of Egypt, without prior notification to the
Attorney General, as required by law, in violation of Title 18,
United States Code, Section 951.
Overt Acts
7. In furtherance of the conspiracy and to effect the
illegal object thereof, PIERRE GIRGIS, the defendant, and others
known and unknown, committed the following overt acts, among
others, in the Southern District of New York and elsewhere:
a. On or about April 3, 2017, GIRGIS sent information
about an anti-el-Sisi activist that he had received from Egyptian
Government officials to a local U.S . law enforcement officer.
b. On April 9, 2017, GIRGIS sent a photograph that he
had received from an Egyptian Government official to a local U.S.
law enforcement officer.
c. On or about November 28, 2017 , GIRGIS sent an
identification card for a particular individual that he had
received from an Egyptian Government official to a local U.S. law
enforcement officer. GIRGIS relayed back to the Egyptian
Government official questions GIRGIS had received from a local
U.S. law enforcement officer.
d. On or about May 7, 2018, GIRGIS and Egyptian
4
Official-1 exchanged electronic communications.
e. On or about March 8, 2019, GIRGIS communicated with
Egyptian Official-1 official over the telephone.
f. In or about March 2019, GIRGIS arranged and
attended a meeting between Egyptian law enforcement and local U.S.
law enforcement.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Acting as an Agent of a Foreign Government
Without Notifying the Attorney General)
The Grand Jury further charges:
8. The allegations contained in Paragraphs One through
Three of this Indictment are repeated and realleged as if fully
set forth herein.
9. From at least in or about 2014, up to and including at
least in or about April 2019, in the Southern District of New York
and elsewhere, PIERRE GIRGIS, the defendant, knowingly acted in
the United States as an agent of a foreign government, namely, the
Arab Republic of Egypt, without prior notification to the Attorney
General, as required by law.
(Title 18, United States Code, Sections 951 and 2.)
DAMIAN WILLIAMS
United States Attorney
5
... ' ~ , Case 1:22-cr-00006-AJN Document 1 Filed 01/06/22 Page 6 of 6
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
v.
PIERRE GIRGIS,
Defendant.
SEALED INDICTMENT
22 Cr.
(18 U.S.C. §§ 371, 951, and 2.)
DAMIAN WILLIAMS
United States Attorney
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PACER USA Vs Pierre Girgis Jan 6 2022 Indictment

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Case 1:22-cr-00006-AJN Document 1 Filed 01/06/22 Page 1 of 6

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA SEALED INDICTMENT

The Grand Jury charges:

1. From at least in or about 2014, up to and including in

or about April 2019, PIERRE GIRGIS, the defendant, acted in the

United States as an agent of the Arab Republic of Egypt (the

"Egyptian Government") without notifying the Attorney General of

the United States as required by law. GIRGIS, a dual citizen of

of multiple employees of the Egyptian Government in an effort to

further in the United States the interests of the Egyptian

2. At the direction of Egyptian Government personnel,

PIERRE GIRGIS, the defendant, among other things: tracked and

obtained information regarding l political opponents of Egyptian

president Abdel Fattah el-Sisi ( "el-Sisi"); and leveraged his

connections with local U.S. law enforcement officers to collect

non-public information at the direction of Egyptian officials,

arrange benefits for visiting Egyptian officials, and arrange

meetings between U.S. and Egyptian law enforcement.

3. On or about May 7, 2018, an Egyptian Government official

( "Egyptian Official-1") and PIERRE GIRGIS, the defendant,

exchanged encrypted communications referencing GIRGIS's status as

an agent of the Egyptian Government. 1 During the conversation,

Egyptian Official-1 expressed frustration that GIRGIS had

communicated with personnel from a different Egyptian agency:

[I] t is not possible to open with all the

Later in the encrypted messaging exchange, Egyptian Official-1

advised GIRGIS that other Egyptian Government agencies "want

sources for themselves, and you [GIRGIS] have become an important

source for them to collect information." GIRGIS responded, "I

1 The statements described in this Indictment are set forth in

Official-1, "it will not be repeated again."

4. On or about March 8, 2019, PIERRE GIRGIS, the defendant,

and Egyptian Official-1 discussed an upcoming trip of certain

Egyptian officials to the United States. During that conversation,

GIRGIS stated, "Tell me what you want me to do," to which Egyptian

Official-1 responded by inquiring about GIRGIS's relationship with

a particular U.S. law enforcement officer. Egyptian Official-1

trainings happening in Manhattan in the coming days, and if so,

who are the people in charge of these trainings? We would like to

attend." Later in the conversation, GIRGIS again asked, "What you

want me to do?", and Egyptian Official-1 directed GIRGIS, "Make

follow up, Ok?", and GIRGIS agreed by responding, "Ok."

5. From at least in or about 2014, up to and including at

least in or about April 2019, in the Southern District of New York

unknown, knowingly did combine, conspire, confederate, and agree

together and with each other to commit an offense against the

United States, to wit, acting as an agent of a foreign government

without prior notification to the Attorney General, in violation

of Title 18, United States Code, Section 951.

6. It was a part and an object of the conspiracy that PIERRE

GIRGIS, the defendant, and others known and unknown, knowingly

acted in the United States as an agent of a foreign government, to

wit, the Arab Republic of Egypt, without prior notification to the

Attorney General, as required by law, in violation of Title 18,

United States Code, Section 951.

7. In furtherance of the conspiracy and to effect the

illegal object thereof, PIERRE GIRGIS, the defendant, and others

known and unknown, committed the following overt acts, among

others, in the Southern District of New York and elsewhere:

a. On or about April 3, 2017, GIRGIS sent information

about an anti-el-Sisi activist that he had received from Egyptian