discussions of, among other things, U.S. Company-1's funding, hiring, and contract negotiations with Commentator-1 and Commentator-2.
9. ELENA AFANASYEVA, a/k/a "Lena," the defendant, is a citizen of Russia and an employee of RT. AFANASYEVA has identified herself on social media as "a producer at RT, dealing with overseas affairs and news." As set forth below, KALASHNIKOV introduced AFANASYEVA to U.S. Company-1 staff and contributors as a member of KALASHNIKOV's editing team, and AFANASYEVA collected information from and gave direction to U.S. Company-1 personnel on behalf of RT in that covert capacity. AFANASYEVA utilized multiple fake personas at U.S. Company-1, including "Helena Shudra" and "Victoria Pesti."
10. Founder-1 and Founder-2 are foreign nationals who reside in the United States. Founder-1 and Founder-2 jointly control and operate U.S. Company-1, and they are the only authorized signatories for U.S. Company-1's business checking account (the "U.S. Company-1 Bank Account"), which is held at a bank in the United States. Before operating U.S. Company-1 for RT, as set forth below, Founder-1 and Founder-2 worked directly for RT and its affiliates, including as follows:
- From in or about March 2021 to in or about February 2022, Founder-1 created videos, posted social media content, and wrote articles pursuant to a written contract between Founder-1's Canadian company ("Canadian Company-1"), and RT's parent organization, ANO TV-Novosti. This content generally consisted of English-language social commentary. RT directly published some of Founder-1's paid work, while Founder-1 posted other of Founder-1's paid work on Founder-1's personal accounts (without attribution to RT). For example, Founder-1's invoices reflect that Founder-1 billed ANO TV-Novosti for approximately 217 videos, of which approximately 209 were published on Founder-1's personal YouTube channels. Founder-
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